Many times when I teach one of our compliance courses, a student will ask why a particular regulation is what it is. My initial response is usually, “Ours is not to question why. Ours is just to certify!” After the laughter subsides, we examine the bit of truth in this statement: We are given a set of regulations to follow and sometimes we don’t agree with them, but what can we actually do? For example, I have never understood why only elderly and disabled families could claim medical expenses. Can’t a young family of five have medical expenses, too?
I explain that many of the regulations we use are as old as the programs themselves; however, our government is actively working to make changes to our affordable housing programs that benefit both residents and staff. Not only is change happening, but the government actively seeks your comments on its proposed changes!
On Jan. 6, 2015, Proposed Rule: Streamlining Administrative Regulations for Public Housing, Housing Choice Voucher, Multifamily Housing, and Community Planning and Development Programs was published in the Federal Register. Comments are being accepted until March 9, 2015. After the comment period closes and the comments are reviewed, a Final Rule will be published and regulatory guidance changed to reflect the new requirements. This means you do have an opportunity to weigh in and perhaps change the way we do things!
The Proposed Rule suggests changes to several of the HUD affordable housing programs. In my opinion, the one that will have the greatest impact on our customers is the change to the way we define Annual Income. Currently Annual Income is defined as income projected to be received in the 12-month period following the certification. Under the proposed rule, owners will have the option of defining Annual Income as the income received in the 12-month prior to certification or income projected to be received in the 12-months after certification. Whichever option the owner chooses, it must be applied to all households at that property (for MFH) or in the program (for PH and Vouchers). If the owner chooses past income, then the family can ask that their rent be calculated using projected income if they have experienced a decrease in income.
Remember, this rule is just proposed at this time! If you have an opinion on it, or any of the other changes in this proposed rule, take a moment to send in your comments. Now is the time that ours is to question why!