The United States Government Accountability Office (GAO) has issued a new report titled, “Department of Housing and Urban Development: Better Guidance and Performance Measures Would Help Strengthen Enforcement Efforts.” The GAO found that the three program offices of the Department of Housing and Urban Development (HUD) that GAO examined have a process in place for referring cases of potential noncompliance to the Departmental Enforcement Center (DEC), but two of the offices do not provide their staff with specific guidance on when to make referrals. The Office of Multifamily Housing makes referrals to DEC based on defined thresholds for noncompliance, such as for properties that do not pass physical inspections. In contrast, the Offices of Public and Indian Housing (PIH) and Community Planning and Development (CPD) have broad guidelines but not specific thresholds for when to refer an entity to DEC. These two offices do not provide field staff with specific guidance to help determine which housing agencies or grantees to refer to DEC for possible enforcement action.
As a result, the offices cannot ensure that decisions on whether to make referrals are made on a well-supported and consistent basis, potentially limiting DEC’s effectiveness in fulfilling its mission of providing independent oversight of HUD’s programs. In addition, PIH and CPD have targets for how many annual referrals the program office will make to DEC, but the targets are not based on program risk. According to federal internal control standards, management should identify, analyze, and respond to risks related to achieving the defined objectives. Without a target number of referrals based on program risk, PIH and CPD cannot be confident that the number of cases referred to DEC is appropriate and that DEC resources are being used efficiently.
DEC tracks some performance measures, but it largely measures outputs, such as number of work assignments completed, rather than outcomes, such as financial performance improvements resulting from its work, that would help assess the impact of its activities.
GAO is making eight recommendations to HUD related to DEC, including for staff guidance on when to make referrals; targets for the number of DEC referrals based on program risk; outcome measures to track performance; and controls to ensure consistent data recording. HUD agreed with five of the eight recommendations, noting that setting referral targets was inconsistent with basing them on program risk. GAO maintains that setting referral targets can help ensure that program offices make referrals to DEC.
IRS Issues Opportunity Zone Proposed Regulations*
On Friday, October 19 the Internal Revenue Service (IRS) issued several critical documents relating to the Opportunity Zone Incentive. This includes:
Taken together, this package of guidance addresses several critical areas relating to the structuring of Opportunity Zone investments. The guidance addresses many heretofore, unanswered questions relating to the new incentive created in last year’s Tax Cut and Jobs Act. Below we have highlighted a number of items most relevant to NH&RA members and link to additional industry analysis issued by NH&RA members.
With the issue of these proposed regulations, a 60-day public comment period (comments due December 22, 2018) has opened and a public hearing has been scheduled for January 10, 2019.
HUD and VA Secretaries Announce Housing Initiatives to Support Homeless Veterans
HUD-VASH vouchers to provide housing for over 4,000 veterans**
WASHINGTON – U.S. Department of Housing and Urban Development (HUD) Secretary Ben Carson and U.S. Department of Veterans Affairs (VA) Secretary Robert Wilkie today joined together at the VA Community Resource and Referral Center to announce $35 million in grants to combat veteran homelessness. The funding will be provided through the HUD-Veterans Affairs Supportive Housing (HUD-VASH) Program to 212 public housing agencies across the country to provide a permanent home for over 4,000 homeless veterans.
The Secretaries also announced an additional $7.4 million through the Veterans Housing Rehabilitation and Modification Pilot (VHRMP) Program to assist disabled veterans with modifying or rehabilitating their homes, making them more accessible.
“We have few responsibilities greater than making sure those who have sacrificed so much in service to their country have a home they can call their own,” said HUD Secretary Carson. “The housing vouchers awarded today ensure homeless veterans nationwide have access to affordable housing and the critical support services from the VA.”
“Assisting homeless Veterans to gain access to housing helps them in every aspect of their lives,” said VA Secretary Wilkie. “This joint effort ensures that the federal government’s efforts are aligned in reducing homelessness and aiding veterans. VA and HUD are proud to be teammates in a program that makes a tangible improvement in the lives of the nation’s Veterans.”
The HUD-VASH program combines rental assistance vouchers from HUD with case management and clinical services provided by VA. Since 2008, more than 93,000 vouchers have been awarded and approximately 150,000 homeless veterans have been served through the HUD-VASH program. More than 600 public housing authorities (PHAs) administer the HUD-VASH program, and this most recent award includes 22 additional PHAs, increasing HUD-VASH coverage to more communities. See the local impact of the housing assistance announced today.
In the HUD-VASH program, VA Medical Centers (VAMCs) assess veterans experiencing homelessness before referring them to local housing agencies for these vouchers. Decisions are based on a variety of factors, most importantly the duration of homelessness and the need for long-term, intensive support in obtaining and maintaining permanent housing. The HUD-VASH program includes both the rental assistance the voucher provides and the comprehensive case management that VAMC staff offers.
Veterans participating in the HUD-VASH program rent privately owned housing and generally contribute no more than 30 percent of their income toward rent. VA offers eligible homeless veterans clinical and supportive services through its medical centers across the U.S., Guam, Puerto Rico and the Virgin Islands. Read more about the HUD-VASH program.
Through the VHRMP program, grantees will make necessary physical modifications to address the adaptive housing needs of eligible veterans, including wheelchair ramps, widening exterior and interior doors, reconfiguring and reequipping bathrooms, or adding a bedroom or bathroom for the veteran’s caregiver to the home.
The purpose of this pilot program is to assist our nation’s low-income veterans living with disabilities who are in need of adaptive housing to help them regain or maintain their independence. By partnering with the VA, HUD is addressing these challenges by awarding competitive grants to organizations that primarily serve veterans and low-income people.
Tips to Maximize Bang for the Buck in Affordable Senior Housing Design***
Affordable senior housing may not carry a reputation as the flashiest property type, but it plays a vital role in serving low-income seniors.
And while developing or designing the property type can require a different mentality than traditional senior housing—as evidenced when The Shelter Group bowed out of the affordable-housing sector to focus on its Brightview Senior Living portfolio last year—there are actually many parallels between the two property types.
To learn more about designing and developing affordable senior housing, we reached out to three previous Senior Housing News Architecture & Design Award winners in the “Best Affordable Housing” category.
Here’s some of the advice they had to offer:
How do you make an affordable senior housing property look stylish without breaking the bank?
“The first thing to know is that affordable housing doesn’t have to look like affordable housing. It takes a little more elbow grease, time and thought to figure out how to bring an aesthetically pleasing property to market [while] spending a reasonable amount of money.
There are a lot of building products available that bring the look of high cost without the pinch to the wallet. Color goes a long way, and judicious use of higher-cost materials can accent and complement the lower-cost materials. Use cast stone rather than real stone, use cultured stone rather than real.
Know that whatever you pay to put in up front, it had better be reasonable to operate for 10-15-20 years. Sometimes you have to spend a bit more up front to get reasonable operating costs. Many architects, engineers and [general contractors] do not always think of this until reminded.” —Jeanmarie Kapp, COO of The Renaissance Companies, winner in 2015
“We spend a lot of time figuring out ways to get the most ‘bang for our buck’ on design. For example, in apartments, we will use very standard fixtures throughout most of the unit and put in one or two outstanding light fixtures that really catch peoples’ attention. We included glass tile backsplash in the kitchens, which was a relatively inexpensive addition but that adds a nice look and feel.
We put a lot of effort into the common area furnishings and finishes. Again, one or two light fixtures that stand out. Multiple colors of paint. Bright colors for furniture. We include as much natural daylight as possible.” —Brendalee Connors, director of development at Metro West Housing Solutions, winner in 2016.
“Style comes and goes. Simplicity and ease of use never wear out. Having said that, it would be almost impossible for a person driving by to identify one of our properties as affordable because they are often more attractive than comparable market rate communities. This is true for our new construction, rehabilitated properties, and adaptive reuse developments.” —Andrew Cohen, senior vice president of development at Woda Cooper Companies, winner in 2017.
What are some basic tips a firm might need to know when developing or designing an affordable senior housing property?
“The market study obviously tells us what rents are achievable in a given area. We have to work backward from there, to confirm the debt the revenue can support. So it’s absolutely key that a developer sit down with the architect and the general contractor in the very beginning.
It doesn’t pay to design something you can’t afford to build. The programming needs of the building are often driven by the state and city requirements, which can be exorbitantly expensive to achieve (green energy systems [solar, geothermal, green roof], washer/dryer in unit, fitness centers, community gardens, outdoor space, the list goes on and on). We have to be practical at what the revenue can support, yet deliver a property that is desirable and marketable. Seniors want to live in secured buildings that offer quality of life, with activities and social programing that keep life interesting. They also like to drive their own programming, which is important yet must be moderated by what the property can afford to support.” —Jeanmarie Kapp
“We hired a senior housing consultant for our first two senior developments. She helped us learn design ideas that help with safety and enjoyability for the residents. I would recommend that.
We conduct focus groups with our current senior residents when we’re designing our next building and ask them what they like and what they don’t like, what they would recommend or would like to see in a new development.
We include balconies/patios for our senior apartments. The folks really use them as an extension of their living space and it allows them to get a little fresh air when they might not be able to get out and about. We include a lot of common areas and have them available to residents 24/7. They use them for all sorts of things, [such as] crafting, meditation, games, socializing. We strongly encourage people to come out of their apartments and use the common areas.” —Brendalee Connors
“It is important to spend time in the local community and get to know the demographics to understand the age spread of the senior population and details such as the percentage of home owners that may convert to renters.” —Andrew Cohen
What are the biggest challenges to developing or designing an affordable senior housing property? How do you overcome those challenges?
“Usually the competitive nature of funding sources [such as] LIHTC, HAP. In addition, the out-of-control demands by state and local funding agencies have increased the cost to build far past market-rate housing costs.” —Jeanmarie Kapp
“Funding is the biggest challenge. Construction costs have been going up 10% per year, which has made developments more difficult if not impossible in some cases. In addition, the pricing that we are able to get in equity for the low income housing tax credits has dropped by 20%-25%, adding to the challenge of making deals work.
We are actually still trying to figure out how to be able to build another property like CityScape and were not able to make it work this year to apply for tax credits. I believe the answer is going to be that we’ll build smaller developments and continue to find ways to streamline construction.” —Brendalee Connors
“With a typical 12-month construction period, we must work hard to hold onto prospective residents that express interest at construction commencement so they are still ready to move in when the property is complete. Early on, we set up email and phone communication systems so we can establish a dialogue with those prospects. At first, we provide basic project description and qualification information, and then provide updates as the project proceeds.” —Andrew Cohen
GROWTH (2017 - Highlights):
Gill Group has published the following:
Cash Gill, MAI has had the opportunity to speak on the following topics:
*As seen on housingonline.com
**As seen on hud.gov
***As seen by Tim Regan on seniorhousingnews.com