HUD PIH Notice § 2011-53

                                                                    U.S.
Department of Housing and Urban Development
                                                                     Public
and Indian Housing
Public and Indian Housing
_________________________________________________________________________
Special Attention of:                                    Notice PIH 2011-
53(HA)
Directors of HUD Regional and Field
Offices of Public Housing; Housing                 Issued:  September 20,
                                  2011
Choice Voucher Program Administrators
                                              Expires:  Effective until
                                       amended,       superseded, or
                                       rescinded

                                       _______________________________
                                             Cross References: Notice PIH
2008-37(HA)
                                                               Notice PIH
2010-12 (HA)

Subject:  Reporting and Portability Requirements for the HUD-Veterans
Affairs Supportive Housing (VASH) Program

1. Purpose.  The purpose of this notice is to revise and extend PIH Notice
2010-12.  The revisions occur in section 2. (Operating Requirements) in
regard to Moving to Work (MTW) agencies, section 2.b. (Leasing and Ongoing
Reporting) in regard to portability, and section 3.d. (PHA Tracking) in
regard to Voucher Management System (VMS) reporting.  These reporting
requirements are still essential to the coordination of data between HUD
and the Department of Veterans Affairs and to ensure that the HUD-VASH
Housing Choice Vouchers (HCV) remain available to the same population upon
turnover.  The Public and Indian Housing Information Center (PIC) reporting
requirements were initially described in section II. f. and III. of the
Implementation of the HUD-VASH Program (Operating Requirements) published
in the Federal Register on May 6, 2008, and are still applicable with
exceptions noted in section 2.b of this notice.

2.  Operating Requirements.  In accordance with Section III of the
Operating Requirements, a code (VASH) was established for use on line 2n of
the form HUD-50058 (Family Report) to indicate that the family is
participating in this special program.  This code must be entered on each
form HUD-50058 for the duration of the HUD-VASH family’s participation in
the program by the initial and receiving PHA, if applicable (see
Portability Attachment).  Please note that MTW agencies are required to use
the regular form HUD-50058 for HUD-VASH families unless they have received
approval from HUD to operate their HUD-VASH program in accordance with
their MTW agreement.


   a. Issuance of Voucher.  The PHA must track issuance of HCVs for families
      referred by the Veterans Affairs Medical Center (VAMC or VA Community-
      Based Outpatient Clinic (CBOC)).  Both VAMCs and CBOCs will be
      referred to as VA facilities for the purpose of this notice.  Tracking
      issuance of vouchers will be done in PIC.  The PHA must enter the VASH
      code at the time of issuance of the HUD-VASH voucher (Action Code
      2a=10 on form HUD-50058) in order to ensure proper tracking for the
      HUD-VASH program.  Under the portability regulation, 24 CFR §
      982.355(c)(6), the receiving PHA must issue a voucher to the family.
      The receiving PHA is also required to enter a form HUD-50058 into PIC
      for this action, issuance of voucher.


   b. Leasing and Ongoing Reporting and Portability Requirements.


        1) All initial funding for HUD-VASH families must be used to lease
           the number of homeless veterans for which the funds were
           awarded.  This funding cannot be used for any other purpose.


        2) PHAs that experience funding shortfalls in a given calendar year
           generally stop issuing vouchers and some may recall vouchers
           from families that are searching for units.  If the PHA is not
           assisting the required number of HUD-VASH families, when it
           resumes issuing vouchers, it must issue vouchers first to HUD-
           VASH and other special purpose families (non-elderly disabled
           (NED) and Family Unification Program (FUP)) on its waiting list
           until the PHA is assisting its required number of special
           purpose vouchers.  A PHA must establish policies in its
           administrative plan regarding the order of selection of special
           purpose voucher families once the PHA resumes issuing vouchers
           after a funding shortfall. Should the PHA have to terminate
           families from its HCV program due to a funding shortfall, HUD-
           VASH, NED and FUP families that comprise the required number of
           families served must be last to be terminated.  An
           administrative policy must also address the order of terminating
           special purpose voucher families should termination be
           necessary.  Administrative plans should be amended as soon as
           practicable.


        3) The VASH special program code must be maintained on line 2n of
           the form HUD-50058 by the initial and, if applicable, receiving
           PHA for all HUD-VASH families when the family is admitted to the
           HCV program and throughout the family’s participation in the
           program.  If, under portability, the receiving PHA does not
           enter the VASH code, the initial PHA will not get credit for the
           family’s leasing.


        4) If the HUD-VASH family no longer requires case management
           services, and the PHA has the funding and elects to serve the
           family under its regular HCV program, the PHA will no longer use
           the VASH code on future form HUD-50058s for this family.  Please
           reference Section II.g. of the Operating Requirements.  In
           addition, these families will not be considered new admissions
           if they receive a regular HCV and will not be subject to
           eligibility determinations for new admissions.


        5) Portability policies under HUD-VASH depend on whether the family
           wants to move within or outside of the initial VA facility’s
           catchment area (the area in which the VAMC or CBOC operates).
           In all cases of portability, the initial VA facility must be
           consulted prior to the move and provide written confirmation
           that case management will continue to be provided in the
           family’s new location.


        6) If the receiving PHA does not administer a HUD-VASH program, it
           must always bill the initial PHA.  If the receiving PHA does
           administer HUD-VASH vouchers, it may only absorb the family if a
           HUD-VASH voucher is available and case management can be
           provided through a VA facility that partners with the receiving
           PHA.  In all cases of portability within the same catchment
           area, the initial VA facility must make the determination
           regarding which VA facility will provide the family with case
           management.  This determination will ultimately affect whether
           the receiving PHA can absorb the family.


        7) Attached to this notice is the Attachment to Portability Form
           for the HUD-VASH Program.  This attachment, which is also
           available on the HUD-VASH website
           (http://www.hud.gov/offices/pih/programs/hcv/vash/), provides
           specific directions for receiving PHAs in regard to reporting
           and alternative requirements published in the aforementioned
           Operating Requirements for HUD-VASH families.


3. PHA Tracking.

   a. PHAs must monitor their HUD-VASH reporting which includes checking the
      use of the special code (VASH) on line 2n. through ad hoc reports.
      PHAs should run an ad hoc report by accessing PIC and then selecting
      “Form 50058 Adhoc Report” under the “ADHOC” heading.  After choosing
      the hub, field office and PHA from the pull-down menus, PHAs should
      select the appropriate action codes and field codes to view on the
      form HUD-50058, including line 2n.  For example, PHAs may choose to
      view new admission and port-out action codes along with head of
      household last name and line 2n fields.  PHAs should then generate a
      report which can be downloaded in Excel format and filtered to view
      the VASH code in the line 2n field.


   b. If a PHA believes that a receiving PHA either mistakenly absorbed the
      family or failed to enter the VASH code in PIC, the initial PHA should
      try to resolve the matter with the receiving PHA.  If the matter
      cannot be resolved, the local Field Office should be contacted if the
      receiving PHA is under the jurisdiction of the same Field Office.  If
      the receiving PHA is under the jurisdiction of another Field Office,
      this information should be provided to Headquarters at the following
      email address: Phyllis.A.Smelkinson@hud.gov.   Each PHA should also
      compare the data for its HUD-VASH program in VMS and PIC.  Any
      problems related to vendor software, including coding issues, must be
      addressed with the vendor.


   c. In VMS, the PHA should report all families that are supported by
      housing assistance payments (HAP) funds under its own Annual
      Contributions Contract.  This would include families that are being
      served within the PHA’s jurisdiction as well as families for which it
      is billed under portability.


   d. Special purpose vouchers, such as HUD-VASH vouchers, that have been
      ported and are being billed to the initial PHA must be reported under
      the appropriate special purpose voucher category (i.e. VASH).  HUD-
      VASH and other special purpose vouchers must be reported in their
      special purpose voucher field rather than under the Port Vouchers Paid
      category.  Therefore, if the PHA has HUD-VASH vouchers that fall under
      both the VASH and Port Vouchers Paid categories it must report them
      under the VASH column.  Then, the PHA must use the VASH comments field
      to specify that xyz VASH units and HAP could also be applied to the
      Port Vouchers Paid category. 


4. HUD Tracking.  HUD Headquarters will match data from the Department of
Veterans Affairs with data in PIC and VMS.  If there are discrepancies
(such as in the number of families referred by the VAMCs and those issued
vouchers by the initial PHA or the success rate), HUD may contact these
PHAs to address these issues.  In addition, HUD will monitor the data in
VMS and PIC to ensure that families served under the initial PHA’s award of
HUD-VASH vouchers (either directly or through portability) match in both
systems.

5. Implementation.  The reporting requirements described above, must be
implemented immediately and retroactively, if necessary, for all HUD-VASH
families.  However, if the HUD-VASH family has already been reported in the
PIC system as leased (new admission or portability move-in), there is no
need to retroactively enter a form HUD-50058 for the issuance of the
voucher.

6. Information Contact.  Inquiries about this notice should be directed to
Phyllis Smelkinson in the Housing Voucher Management and Operations
Division, Office of Public Housing and Voucher Programs, at (202) 402-4138.

7. Paperwork Reduction Act.  The information collection requirements
contained in this Notice have been approved by the Office of Management and
Budget (OMB) under the Paperwork Reduction Act (PRA) of 1995 (44 U.S.C
3520).  In accordance with the PRA, HUD may not conduct or sponsor, and a
person is not required to respond to, a collection of information unless
the collection displays a currently valid OMB control number.  The
following active information collections contained in this Notice have been
approved under the PRA and assigned OMB Control Number 2577-0083.


                                              /s/
                                 Sandra B. Henriquez, Assistant Secretary
                 for
                                             Public and Indian Housing

Attachment


 Attachment to Portability Form (form HUD-52665) for the HUD-VASH Program

Based on the nature of the HUD-VASH voucher program and the population that
is being served, alternative operating requirements, as well as specific
reporting requirements have been established for this program. Receiving
PHAs that are administering HUD-VASH vouchers are subject to these
alternative requirements, which can be found on the HUD-VASH website at:
http://www.hud.gov/offices/pih/programs/hcv/vash/.

These procedures only apply to portability moves where the family’s case
management services are being provided by the initial PHA’s partnering
Veterans Affairs Medical Center (VAMC).

Following is a summary of the most important items to be aware of:

1. When a family requests to move under portability while staying within
the catchment area of the initial PHA’s partnering VAMC, portability
procedures vary according to whether or not the receiving PHA has been
awarded HUD-VASH vouchers.
If the receiving PHA has been awarded HUD-VASH vouchers, it can choose to
bill the initial PHA or absorb the family if it has a HUD-VASH voucher
available.

If the receiving PHA has not been awarded HUD-VASH vouchers, the initial
PHA (the one that has been selected to partner with the local VAMC) must be
billed for all portable families under the HUD-VASH program.

2. The receiving PHA must enter “VASH” on line 2n of the Family Report
(form HUD-50058). This code must remain on the HUD-50058 for the duration
of the HUD-VASH family’s participation in the program.

3. Receiving PHAs must follow Operating Requirements published on May 6,
2008, in the Federal Register in regard to other alternative requirements
for this program. These requirements include, but are not limited to:

      a. For new admissions, PHAs may only deny assistance if the family is
over-income or if any member of the household is subject to a lifetime
registration requirement under a state sex offender registration program.
PHAs may not deny assistance for any other reason.

      b. HUD-VASH vouchers must have an initial term of at least 120 days.

      c. Veterans are required to participate in case management.
Therefore, families that fail to comply with case management requirements,
as determined by the VA case manager, must be terminated from the voucher
program

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