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Guidance on Navigating CARES Act Waiver Expiration
--CARES Act: Coronavirus Aid, Relief, and Economic Security (CARES) Act (Public Law 116-136)

 

The guidance documents on this page outline planning considerations available to PHAs as they evaluate how to effectively and efficiently navigate the CARES Act Waivers expiration. These documents detail various options available as waivers conclude, presenting them in an accessible format to PHA staff, residents, community members, and governing bodies. Each guide focuses on specific aspects of PHA operations impacted by the CARES Act waiver and provides direction to PHAs on how they may (or must proceed, in some instances) to ensure compliance with regulations and federal housing policy upon expiration of the waivers. HUD did not issue guides for waivers that were either already expired, or where it was not necessary to do so because sufficient information was included in Notice PIH 2021-14 entitled COVID-19 Statutory and Regulatory Waivers and Alternative Requirements for the Public Housing, Housing Choice Voucher (including Mainstream and Mod Rehab), Indian Housing Block Grant and Indian Community Development Block Grant programs, Suspension of Public Housing Assessment System and Section Eight Management Assessment Program, Revision 3.  There will be separate guidance issued for the Section Eight Management Assessment Program (SEMAP) and Public Housing Assessment System (PHAS) waivers at a later date and this site will be updated once the information becomes available. 

 

  • PH and HCV-3: Family Income and Composition: Annual Examination: Income Verification Requirements 
  • PH and HCV-5: Enterprise Income Verification (EIV Monitoring) 
  • PH and HCV-8: Eligibility Determination: Income Verification 
  • PH and HCV-9: Eligibility Determination: Social Security Number and Citizenship Verification 
  • MR-0: Family Income and Composition: Annual Examination: Income Verification Requirements
  • MR-4: Enterprise Income Verification Monitoring 
  • PH-12: Public Housing Agency Annual Self-Inspections 
  • HQS-1: Initial Inspection Requirements 
  • HQS-2: PBV Pre-HAP Contract Inspections: PHA Acceptance of Completed Units 
  • HQS-3: Initial Inspection: Non-Life-Threatening Deficiencies (NLT) Options 
  • HQS-4: HQS Initial Inspection Requirements: Alternative Inspection Option 
  • HQS-5: HQS Inspection Requirement: Biennial Inspections 
  • HQS-6: HQS Interim Inspections 
  • HQS-7: PBV Turnover Unit Inspections  
  • HQS-8: PBV HAP Contract: HQS Inspections to Add or Substitute Units 
  • HQS-9: HQS Quality Control Inspections 
  • HQS-10: HQS: Space and Security 
  • HQS-11: Homeownership Option: Initial HQS Inspection 
  • MR-5: PHA Inspection Requirement: Annual Inspections 
  • HCV-5: Absence from Unit 
  • HCV-6: Automatic Termination of HAP Contract 
  • HCV-14: Mandatory Removal of Unit from PBV HAP Contract 
  • PH-7: Over-Income Families 
  • PH-13: Over-Income Limit: Termination Requirement 
  • HCV-15: PBV and Enhanced Voucher Provisions on Under-Occupied Units

  • PH-1: Fiscal Closeout of Capital Grant Funds
  • PH-2: Total Development Costs
  • PH-3: Costs and Other Limitations
  • 12.c: Extension of Deadline for Programmatic Obligation and Expenditure of Capital Funds
  • 12.d: Section (j) 1-and 2-Year Substantial Improvement Requirements 
  • Flexibility in the Use of Public Housing Operating Funds and Capital Funds
  • Capital Fund Administration
  • 11.c: Uniform Financial Reporting Standards: Filing of Financial Reports: Reporting Compliance Dates.
  • 12.e: Community Service and Self-Sufficiency Requirement (CSSR) Suspension

 

Crosswalk of Waivers from Notice 2021-14 and Associated Guidance

 

Waiver No.

Name

Guidance

Waiver Expiration Date

PH and HCV-1

PHA 5-Year and Annual Plan Submission: Significant Amendment Requirements

No New Guidance – Reference Notice PIH 2021-14

  • Varies based on FYE
  • 12/31/20

PH and HCV-2

Family Income and Composition: Delayed Annual Reexamination

No New Guidance Reference Notice PIH 2021-14

  • 6/30/21
  • All reexams due in CY20 must be completed by 12/31/20. Reexams due between 1/1/21 and 12/31/21 would need to be completed by 12/31/21.

PH and HCV-3

Family Income and Composition: Annual Examination: Income Verification Requirements

Verifications

  • 12/31/21

PH and HCV-4

Family Income and Composition: Interim Examinations

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

PH and HCV-5

Enterprise Income Verification (EIV Monitoring)

Verifications

  • 12/31/21

PH and HCV-6

Family Self-Sufficiency (FSS) Contract of Participation: Contract Extension

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

PH and HCV-7

Waiting List: Opening and Closing: Public Notice

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

PH and HCV-8

Eligibility Determination: Income Verification

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

PH and HCV-9

Eligibility Determination: Social Security Number and Citizenship Verification

Verifications

  • 12/31/21

HQS-1

Initial Inspection Requirements

Inspections

  • 12/31/21
  • Where self-certification was used, PHA must inspect the unit no later than 6/30/22

HQS-2

PBV Pre-HAP Contract Inspections: PHA Acceptance of Completed Units

Inspections

  • 12/31/21
  • Where self-certification was used, PHA must inspect the unit no later than 6/30/22

HQS-3

Initial Inspection: Non-Life-Threatening Deficiencies (NLT) Options

Inspections

  • 12/31/21

HQS-4

HQS Initial Inspection Requirements: Alternative Inspection Option

Inspections

  • 12/31/21
  • Where self-certification was used, PHA must inspect the unit no later than 6/30/22

HQS-5

HQS Inspection Requirement: Biennial Inspections

Inspections

  • 12/31/21
  • PHAs must conduct all delayed biennial inspections from CY 2020 as soon as reasonably possible but no later than 6/20/22 and must conduct all delayed biennial inspections from CY 2021 as soon as reasonably possible but no later than 12/31/22.

HQS-6

HQS Interim Inspections

Inspections

  • 12/31/21

HQS-7

PBV Turnover Unit Inspections

Inspections

  • 12/31/21
  • Allows for delayed full HQS inspection NLT than 6/30/22

HQS-8

PBV HAP Contract: HQS Inspections to Add or Substitute Units

Inspections

  • 12/31/21
  • Allows for delayed full HQS inspection NLT 6/30/22

HQS-9

HQS Quality Control Inspections

Inspections

  • 12/31/21

HQS-10

HQS: Space and Security

Inspections

  • Remains in effect one year from lease term or date of this Notice, whichever is longer

HQS-11

Homeownership Option: Initial HQS Inspection

Inspections

  • 12/31/21

HCV-1

Administrative Plan

No New Guidance – Reference Notice PIH 2021-14

  • 9/30/21
  • Any provisions adopted informally must be adopted formally by 12/31/21

HCV-2

Information When Family is Selected: PHA Oral Briefing

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

HCV-3

Term of Voucher: Extension of Term

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

HCV-4

PHA Approval of Assisted Tenancy: When HAP Contract is Executed

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

HCV-5

Absence from Unit

Occupancy Policies

  • 12/31/21

HCV-6

Automatic Termination of HAP Contract

Occupancy Policies

  • 12/31/21

HCV-7

Increase in Payment Standard During HAP Contract Term

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

HCV-8

Utility Allowance Schedule: Required Review and Revision

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

HCV-9

Homeownership Option: Homeownership Counseling

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

HCV-10

Family Unification Program: FUP Youth Age Eligibility to Enter HAP Contract

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

HCV-11

Family Unification Program: Length of Assistance for Youth

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

HCV-12

Family Unification Program: Timeframe for Referral

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

HCV-13

Homeownership: Maximum Term of Assistance

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

HCV-14

Mandatory Removal of Unit from PBV HAP Contract

Occupancy Policies

  • 12/31/21

HCV-15

PBV and Enhanced Voucher Provisions on Under-Occupied Units

PBV and Enhanced Voucher Provisions on Under-Occupied Units

  • See Guidance

PH-1

Fiscal Closeout of Capital Grant Funds

Capital Programs

  • Varies by PHA’s grant closeout date.

PH-2

Total Development Costs

Capital Programs

  • Applies to development proposals submitted to HUD no later than December 31, 2021

PH-3

Costs and Other Limitations

Capital Programs

12/31/21

PH-4

ACOP: Adoption of Tenant Selection Policies

No New Guidance – Reference Notice PIH 2021-14

  • 9/30/21
  • Any provisions adopted informally must be adopted formally by 12/31/21

PH-5

Community Service and Self-Sufficiency Requirement (CSSR)

Superseded by 12.e

PH-6

Energy Audits

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

PH-7

Over-Income Families

Occupancy Policies

  • 12/31/21

PH-8

Resident Council Elections

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

PH-9

Review and Revision of Utility Allowance

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

PH-10

Tenant Notifications for Changes to Project Rules and Regulations

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

PH-11

Designated Housing Plan Renewals

No New Guidance – Reference Notice PIH 2021-14

  • 6/30/2021

PH-12

Public Housing Agency Annual Self-Inspections

Inspections

  • 12/31/21

PH-13

Over-Income Limit: Termination Requirement

Occupancy Policies

  • 12/31/21

PH-14

Annual Choice of Rent

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

11.a.

PHAS-Public Housing Assessment System

Separate guidance is forthcoming

11.b.

SEMAP-Section 8 Management Assessment Program

Separate guidance is forthcoming

11.b.1

SEMAP Field Office Confirmatory Review

Separate guidance is forthcoming

11.b.2.

SEMAP Certification Timing

Separate guidance is forthcoming

11.c

Uniform Financial Reporting Standards: Filing of Financial Reports: Reporting Compliance Dates

Uniform Financial Reporting Standards

  • Varies by PHA FYE

12.a

PHA Reporting Requirements on HUD Form 50058

No New Guidance – Reference Notice PIH 2021-14

  • PH/HCV: December 31, 2020
  • MR: June 30, 2021 

12.b

Designated Housing Plans: HUD 60-Day Notification

No New Guidance – Reference Notice PIH 2021-14

  • July 31, 2020

12.c

Extension of Deadline for Programmatic Obligation and Expenditure of Capital Funds

Capital Programs

  • All Capital Fund grants open on April 10, 2020, and for new grants opened between April 11, 2020, and December 31, 2020.

12.d

Section (6j) 1-and 2-Year Substantial Improvement Requirements

No New Guidance – Reference Notice PIH 2021-14

  • March 31, 2023

12.e

Community Service and Self-Sufficiency Requirement (CSSR) Suspension

Community Service and Self-Sufficiency Requirement (CSSR)

  • 4/30/2022

MR-1

Family Income and Composition: Delayed Annual Examinations

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

MR-0

Family Income and Composition: Annual Examination: Income Verification Requirements

Verifications

  • 12/31/21

MR-3

Family Income and Composition: Interim Examination

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

MR-4

Enterprise Income Verification Monitoring

Verifications

  • 12/31/21

MR-5

PHA Inspection Requirement: Annual Inspections

Inspections

  • 12/31/21

MR-6

Adjustment of Utility Allowance

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

MS-1

Initial Lease Term

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

MS-2

Criminal Background Screening

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21

MS-3

Mainstream Age Eligibility to Enter HAP Contract Statutory Authority

No New Guidance – Reference Notice PIH 2021-14

  • 12/31/21