Several issues came up at the NAHMA Fall Meeting Regulatory Issues Forum and the NLHA Seminar: The Mature Section 8 Project meetings I attended in DC the last week of October that are of general interest to Section 8 Contract Administrators.

MORs: HUD’s Office of General Counsel has ruled that HUD cannot have PBCAs operating under the original ACC (the 42 states) do Management and Occupancy Reviews.  Accordingly, HUD is looking at possible temporary solutions that will allow the backlog of MORs to be cleared in advance of the recompete so that the new CAs can start out on the new risk based model. One option mentioned was contracting with a third party to do the work.

HR3700—Housing Modernization Bill: This is a bill introduced with bipartisan support in the House that, among other things, changes the child care and elderly deductions, changes the child care allowance to an amount greater than 5% of income and changes the medical and disability deductions to be the amount greater than 10% of income. Both the deduction amounts and percentages would be subject to annual COLAs. Apparently the House strategy is to attempt to have the bill included as part of the omnibus spending bill that needs to pass in December. Needless to say, should the bill pass, both site and CA software vendors as well as TRACS, will need time to implement the changes.

Homeless Households: HUD will be publishing a toolkit in the very near future with guidance on acceptable modifications to waiting list procedures to accommodate the homeless.

Family Self Sufficiency and rent disregards: HUD will be issuing a notice on this topic in about a month.

Redacting PII such as SSN’s and Dates of Birth: HUD is studying the issue and will issue guidance in the near future.  The issue is whether or not to redact this information on printed certifications and other HUD forms at the site and/or CA level.

TRACS Server Update: There will be a TRACS call in November to determine the schedule for moving to the new servers. The move will require all software vendors to recompile its TRACS communication modules and distribute a software update.

So, there are a lot of things either in the pipeline or potentially in the pipeline. It is very important to stay informed so that proper planning can be done for things that actually are implemented.