Reallocation of WtW Vouchers - Frequently Asked Questions

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	What WtW PHAs are subject to de-reservation?
	How will HUD calculate the number of units to be de-reserved?
	Are PHAs that are subject to dereservation eligible to apply for additional vouchers?
	How will HUD determine eligibility to apply for additional, reallocated WtW vouchers?
	Why did HUD consider RTAs in process when determining leasing rates for the de-reservation process but did not consider RTAs in process for determining eligibility for applying for additional WtW vouchers?
	Must the application to apply for reallocated WtW vouchers include the full narrative explanation generally required under other NOFAs?
	Will HUD give any special consideration to WtW PHAs with small WtW programs, where the loss of just a few units could take them below the eligibility threshold of 97% for applying for additional vouchers?
	Are there any special application procedures for sites that originally submitted joint applications? Do these sites need to apply together for the reallocated WtW units, or do they apply separately?
	Is a PHA that has expended more than 97% of its funds but less than 97% of its vouchers eligible to apply for reallocated baseline WtW vouchers?
	If a PHA discovers errors in the data contained in the March Leasing Report and believes it is eligible to apply for reallocated vouchers, can it correct the error and apply for more vouchers?
	Can a PHA apply for vouchers to cover the over-leasing it has already done, or must re-allocated vouchers go to new program participants?

• " Number of units that were under lease as of December 1, 2001, including the number of RTAs that were in process at that time, as reflected in the December Leasing Report ; or
• " Number of units that were currently under lease as of February 28, 2002, as reflected in the March Leasing Report.

Note: HUD has identified the WtW voucher units to be de-reserved. PHAs subject to de-reservation will receive a letter from HUD's Financial Management Center (FMC) that confirms the exact number of units de-reserved and the amount of the ACC renewal. Once de-reservation occurs, future WtW Leasing Reports will be updated to reflect the new baseline unit allocation for those PHAs that had units de-reserved.

Are PHAs that are subject to de-reservation eligible to apply for additional vouchers?

PHAs that are subject to de-reservation are NOT eligible to apply for additional vouchers.

How will HUD determine eligibility to apply for additional, reallocated WtW vouchers?

To determine eligibility to apply for additional vouchers (97 percent or higher leasing rate), HUD will use the leasing data (percentage of units currently under lease) shown on the March Leasing Report posted on the WtW Web site. HUD will NOT use earlier leasing data, i.e. December, January, or February Leasing Reports. In other words, eligibility will be based on a "point in time" measurement reflecting the most current leasing rate. For example, if a PHA achieved 97 percent or greater lease up in a previous month but reported to be less than 97 percent leased as of February 28, 2002, it is not eligible to apply.

Why did HUD consider RTAs in process when determining leasing rates for the de-reservation process but did not consider RTAs in process for determining eligibility for applying for additional WtW vouchers?

HUD, being sensitive to the fact that RTAs in process represented real commitments on behalf of the PHA to house a family, counted RTAs in process for determining the number of units to be de-reserved. It used the actual number leased, based on the most up-to-date leasing data, for determining eligibility to apply for additional vouchers.

Must the application to apply for reallocated WtW vouchers include the full narrative explanation generally required under other NOFAs?

No. PHAs are only required to complete form HUD-52515 and a leasing schedule.

Will HUD give any special consideration to WtW PHAs with small WtW programs, where the loss of just a few units could take them below the eligibility threshold of 97 percent for applying for additional vouchers?

In an effort to be as fair, objective, and consistent as possible, HUD made the decision to measure lease-up at a point in time and to use the most up-to-date leasing data available. HUD does not plan to change its procedure for determining eligibility to apply for additional vouchers and will not be giving special consideration to PHAs with small WtW voucher programs where the loss of a few units affects the PHA's eligibility to apply for additional vouchers.

Hopefully, PHAs that find themselves in this situation meet the 97 percent leasing requirement under HUD's Fair Share NOFA and can apply for additional vouchers through the Fair Share NOFA process. If such a PHA receives Fair Share funding, it can dedicate a portion of the slots to its WtW voucher program, if it wishes to do so.

Are there any special application procedures for sites that originally submitted joint applications? Do these sites need to apply together for the reallocated WtW units, or do they apply separately?

Two or more PHAs that originally submitted joint applications for WtW vouchers should apply separately for additional WtW vouchers. There are no special application procedures. Likewise, when determining eligibility to apply, HUD will be looking at individual PHA leasing rates.

Is a PHA that has expended more than 97 percent of its funds but less than 97 percent of its vouchers eligible to apply for reallocated baseline WtW vouchers?

No. Eligibility to apply for additional vouchers is based on the percentage of units leased, not funds expended. A PHA that finds itself in this situation must look at its WtW voucher costs within the context of all funds available. If it finds it is short due to extraordinary circumstances, it should request a cost amendment.

If a PHA discovers errors in the data contained in the March Leasing Report and believes it is eligible to apply for reallocated vouchers, can it correct the error and apply for more vouchers?

Yes. If a PHA believes that the March Leasing Report incorrectly shows its leasing to be below 97 percent, HUD will consider the PHA's application if the PHA submits with its application the following documentation that verifies that the PHA has met the leasing requirement: a complete listing of families under lease in the PHA's WtW voucher program as of February 28, 2002, including the name and Social Security number of the head of the household, the address of the assisted unit, and the effective date of the Housing Assistance Payments contract.

Can a PHA apply for vouchers to cover the over-leasing it has already assumed, or must re-allocated vouchers go to new program participants?

A WtW PHA may apply for additional vouchers to support/absorb over-leasing that has already occurred in its WtW program. In fact, a PHA that is over-leased in its WtW voucher program must first use any reallocated WtW vouchers that it receives to correct over-leasing. Once the PHA's WtW leasing rate has been normalized, any remaining reallocated WtW vouchers that the PHA receives may be used to bring new families onto the program.