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The question HUD is asking is are there any regulations that should be repealed, replaced, or modified?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
Interesting idea’s Josh. I’ve noticed a slew of them come across my desk in a variety of programs, such as the multi-year certification cycle of the rental demonstration program. I wonder if one was to take a Lean look at public housing, what would be identified as muda. I would even suggest that identifying value might be different for some. I could imagine 3 values:
1. Housing the greatest number of residents with the funds available.
2. Working to get residents self-sufficient as quickly as possible.
3. Ensuring the funds utilizes are going towards the “right” people, however you define those people.
At which point you could optimize the stream toward that goal. It sounds as though you and your colleagues are heavily invested in Lean, how would you approach this?
Josh and Ryan,
Both of you have raised some excellent points. I have reviewed thousands of tenant case files and want to add some detail.
Ryan;s Item 1 may mean changes in occupancy standards. Other cultures seem to be okay with crowding, say 5 people to one bedroom and I have done this in my own family (two bunk beds and a cot). Americans are used to having more privacy! If it means saving a family from homelessness, then yes- I would abridge or bypass the occupancy standards.
Ryan’s Item 2. At least a third of the cases I reviewed were working households. But jobs that residents have will never allow them to be self sufficient. Retailers control wages and hours both. Most all of these households received food stamps as well as housing assistance, and some claimed welfare, EITC or child care assistance. So government assistance is helping to swell the profits of many corporations. Housing agencies have the ability to track specific employers via Work Number or DOL’s. Shouldn’t we be reclaiming social safety net money through a social cost tax to corporations? Maybe the threat of imposing this type of tax would impel big business to raise minimum hourly wages, especially for part-time or on call employees. These employees need that income much more than CEO’s and shareholders.
Remember settlement houses from the early part of the twentieth century. These were like one stop shops for newly arrived immigrants. I know they did not offer housing help, but the model is otherwise useful. Any effort to increase self sufficiency needs to be multifaceted. Housing, food and cash assistance should be a package- so why not just include a housing budget as part of a welfare claim? New York City does this with Welfare Rent which is paid to the NYCHA based on a schedule using number of people in the household and a total needs budget. Training and job placement should also be part of the mix of services.
Josh’s point of allowing public housing agencies to lease a percentage at market rate is out of left field, but has some positives not only in raising funding, but possibly diversifying a local population with higher income levels.
I would recommend that PHA’s own more scattered site stock. Instead of enriching entrepreneurs with tax sale bargains, first option should go to a local PHA. Volunteer groups might help to fix these properties and then use a lease to own model to ensure that a low income family is properly housed. Once the PHA has recouped their investment plus a reasonable interest, the house should belong to the family.
Hope this gives you more ideas of ways to fulfill needs of all individuals while keeping costs reasonable.
I am not sure how I missed this comment but very informing. Thank you for adding such great content!