RHF Plan Preparation and Guidance

Highlights

	Changes to establishing the obligation start and obligation end dates for first and second increment RHF grants
	RHF Plans due: Public Housing Agencies (PHAs) that received Replacement Housing Factor funding (RHF) for the first time in FY 2006 and wish to accumulate up to five years of RHF grant funding in order to fund replacement public housing rental units must submit a first increment RHF Plan to the local HUD office no later than January 30, 2007. See the elements to be included in a first increment RHF Plan.
	PHAs that are eligible to receive a new tier of second increment RHF in FY 2007 must submit a second increment RHF plan to the local HUD office no later than January 30, 2007. See the elements to be included in a second increment RHF Plan. If a second increment plan is not submitted by the deadline and/or disapproved then the PHA is no longer eligible for second increment RHF for that particular tier.   Field Offices are to review and approve or disapprove these plans within 30 days of the application deadline. Field Offices are to notify the Office of Capital Improvements in Headquarters within 45 days of the application deadline of PHAs with :   Approved second increment RHF Plans.   Disapproved Second Increment Plans.   PHAs that did not submit required second increment plans.
	2007 second increment RHF eligibility lists (MS-Excel): A complete listing of PHAs that have units that are eligible for second increment RHF grants in FY 2007

Things to Consider When Preparing and Reviewing First Increment RHF Plans

1) Is the PHA required to submit an RHF Plan, or is submission optional because they intend to directly 1) proceed with the submission of a development proposal and 2) obligate 90 percent of the RHF grant within 24 months from the date the funds were made available and expend 100 percent of the RHF grant within 48 months from when the funds were made available?

2) Is the PHA intending to accumulate its RHF grants for several years and delay the obligation start date? If so, how many years of grants are they accumulating? Which grants (by fiscal year) are they accumulating? What is the total amount of the grants being accumulated?

3) Was the Plan submitted in accordance with the schedule posted on the OCI website?

4) Is the PHA planning to develop public housing rental units, either through construction or acquisition? What is the total number of units to be developed? What type of units will be developed? Through what method will the units be developed?

5) Is the plan for development using first increment RHF funds discrete, e.g. in no way reliant on funding of the second increment of RHF funds (years 6-10) in order to be completed?

6) Is the PHA plan for development consistent with Section (9)(g)(3) of the Act, which limits the number of new units a PHA may construct as public housing?

7) Has the PHA provided a schedule of major development milestones? If the PHA is planning more than one development/development proposal, are multiple schedules included?

8) When is the PHA planning to submit a development proposal(s)? Is the date of submission of the development proposal consistent with the requirement that the development proposal be submitted NO LATER than 90 days after execution of the RHF ACC by the HUD Field Office, or the due date of the PHA's Annual Plan for the last fiscal year the PHA intends to accumulate its RHF funds (no later than the fifth year of RHF funding)?

9) What other sources of funding (if any) does the PHA intend to use to develop the replacement housing? Have the costs been analyzed against the applicable TDC limits?

10) Is the PHA proposing something inconsistent with the current RHF guidelines and asking for an exception of waiver of program requirements? What specifically are they requesting?

11) Has the PHA submitted an electronic copy of its RHF Plan to the Office of Capital Improvements?

Additional Things to Consider When Reviewing and Preparing Second Increment RHF Plans

In addition to the items above, please consider the following when reviewing and preparing second increment RHF Plans:

1) Does the Plan include a statement addressing: the approval status of the Five Year PHA Plan; the approval status of all Annual Plans (FYs 1998-2005); and compliance with obligation and expenditure deadlines in FYs 1998-2004 for all Capital Fund grants?

2) Does the PHA have firm commitments for substantial additional funds, other than public housing funds, equaling one-third of the total RHF funds it received in the first five-year increment? What resources is the PHA proposing to use as leverage? What commitment document was provided?

3) Is the PHA planning to submit the development proposal NO LATER than 90 days after execution of the ACC by the HUD Field Office, or the due date of the PHA's Annual Plan for the seventh year of RHF funding?

4) Is the PHA planning to FULLY EXPEND its second increment RHF funds no later than the end of the tenth year of RHF funding?

Note: If the PHA requests an additional five years of funding, it must proceed with the development of the first five-year increment and submit a second, discrete, RHF Plan based on the funding provided in years 6 - 10. In no case should the development or developments planned with first increment RHF funding be planned in such a way that completion of that development or developments relies on HUD funding of the second increment of RHF. PIH Notice 2004-15 provided guidance on RHF grant calculation and other related topics. The Office of Capital Improvements will also provide additional guidance on RHF on this website, so keep checking back.