A recent notice in the federal register was released in conjunction with the President’s Executive Order in reducing unnecessary government regulation and waste.
President Trump’s Executive Order in a Nutshell: To cut to the chase, a committee has been established to identify unnecessary rules and regulations in the government with the further mission of replacing, reducing or modifying them. This is important to us in the public housing authority realm because of the unique opportunity to remove some really bad regulations that we have been dealing with for a long time.
Because this is the government the process of submitting comments are not straight forward or easy. Lets get to what HUD is specifically looking in regards to feedback.
The question HUD is asking is are there any regulations that should be repealed, replaced, or modified? For every regulation that you think should be removed or changed, there are several follow up questions. They are not difficult to answer but are bureaucratic in nature. Since you can read the questions yourself here, I will not get into each of them.
This is a rare opportunity to reduce some of the regulatory burden in our programs. MTW agencies have long played with different ideas to make their respective programs more cost effective. Here is a little brain stimulation to get you thinking:
- Get rid of annual housing inspections in HCV (flexibility on how often and why an inspection takes place.)
- Eliminate income based rent calculations
- Get rid of escrows in the FSS program
- Multi-year review cycles
- Eliminate interim’s completely
- Allow PHAs with public housing to lease up to 10% of their units for market rate prices (help with cash-flow)
- Allow for more than 25% of vouchers to be project based
- Adopt tax credit regulations and paperwork in lieu of HUD regulations and paperwork in PBV or public housing programs
Conclusion: Now is the time to act. It might be wise for housing authorities to band together and submit ideas in a coordinated method. Lets hope that NAHRO, CLPHA and PHADA are all doing their parts to lead this effort. Please see the link below to submit your comments. Submit your personal or agency comments here