1) Instituting a Regularly Scheduled NAHMA Member Call-in hour on Thursdays at 3:00 pm Eastern
The call will be held, starting on Thursday March 19, 2020, at 3:00 pm Eastern, and continuing every Thursday thereafter until further notice to hear member feedback on regulatory challenges/needs, legislative needs, and to facilitate member dialogue. Other topics can be addressed as well.
Dial-in information is below:
Topic: NAHMA Member Call-in Hour on COVID19
Time: Mar 19, 2020 3:00 PM Eastern Time (US & Canada)
Join from PC, Mac, Linux, iOS or Android: https://meetings.ringcentral.com/j/1482464871
iPhone one-tap: US: +1(773)2319226,,1482464871#
Dial +1 (773) 2319226
Meeting ID: 148 246 4871
2) Collecting and sharing NAHMA member questions and approaches to dealing with the coronavirus pandemic
In his Washington Update email to NAHMA Executive members last week, Director of Government Affairs Larry Keys invited Executive members to send in their questions to federal agencies or questions for other members to consider in dealing with the coronavirus pandemic. At this time we’d like to broaden the invitation to all members of NAHMA’s Executive Council (Executive, Associate and Affiliate members) and include an additional suggestion that members share their own company’s coronavirus pandemic response plans if they are willing.
Please address your coronavirus pandemic questions and related information to Larry at firstname.lastname@example.org, with the Subject: COVID19 Member Questions and Shared Resources. NAHMA will establish a central repository for members to view submitted questions and shared resources on the NAHMA Coronavirus Information and Resources website. In addition, NAHMA will forward questions for federal agencies to appropriate agency staff.
3) What we’ve been addressing related to the coronavirus pandemic to-date:
- Since late February, NAHMA has been sending email alerts whenever pertinent new information arises to all members regarding the latest news and guidance from federal agencies related to the coronavirus pandemic.
- Just prior to the NAHMA meeting, NAHMA published its Coronavirus Information and Resources website, which is being updated frequently with the latest federal agency information available.
- Subsequent to the NAHMA meeting (Mar.
7-10), we have advocated on specific key questions and issues brought to
our attention by members, primarily to HUD, and NAHMA has had a
significant role in achieving positive action by the agency, including but
not limited to:
- Postponing of all REAC inspections for all Multifamily properties. Per HUD: “Until further notice, Multifamily is postponing all REAC property inspections for all Multifamily properties. Where there is an exigent circumstance or reason to believe that there is a threat to life or property at a specific location, inspections will be conducted by HUD quality assurance inspectors in compliance with CDC guidelines.”
- Postponing MORs. Per HUD: “HUD recognizes that the President’s March 13, 2020, emergency determination related to COVID-19 constitutes a significant administrative action that could disrupt performance under the Annual Contributions Contracts (ACC). HUD is hereby relieving PBCAs operating under both ACCs from notifying HUD that the Presidential emergency determination either limits, or in some cases, prevents, PBCAs from carrying out MORs and related activities. HUD is therefore suspending standard MORs until the PBCA determines that local conditions no longer limit or prevent the PBCA from performing MORs safely. HUD is looking into a flexible model that would allow PBCAs to adapt to local conditions in a way that allows them to continue MORs on a modified basis to ensure acceptable conditions in HUD properties. Additional guidance and specifications will be forthcoming.”
- Requesting regulatory waivers. Per HUD: “HUD will consider policy, Handbook, and regulatory waivers on a case-by-case basis with the intention of providing flexibility to owners and agents to respond to unique needs.”
- Requesting financial statement filing extensions. Per HUD: “All audited financial statements that are due to HUD in March or April 2020 are provided with a 30-day extension. The Office of Multifamily Housing Programs will continue to monitor the situation and may provide additional extensions as warranted.”
- Conducting Recertifications. Owners/managers may invoke “extenuating circumstances” for not conducting Recertifications due to the coronavirus pandemic, which provides a 90-day extension of the Recertification due date. Per HUD: “The owner may consider extenuating circumstances (including COVID-19 considerations in the community) when the tenant is not available to attend the recertification interview, sign consent forms, or sign form HUD-50059. It is recommended the owner begin or accomplish the above actions within 90 days of being advised of the extenuating circumstance. When an extenuating circumstance is present, there is no change to the tenant’s recertification anniversary date. The Total Tenant Payment/Tenant Rent and the assistance payment are effective retroactively to the recertification anniversary date. The owner must document the file why the signature(s) was not obtained and, if applicable, when the signature(s) will be obtained.”
- Addressing other Recertification and tenant-related issues. Meanwhile, NAHMA is aware from additional member inquiries that there are a number of other major concerns regarding Recertifications, local activities prohibiting evictions, tenant payment of rents, etc. Please continue to call or email us your questions and concerns and we will follow up on them.
- Working with industry colleague organizations. NAHMA is in frequent, regular contact with our industry colleagues and we are working together to amplify messages on behalf of the multifamily affordable industry.
4) What NAHMA staff are doing to address the coronavirus pandemic at our headquarters building
At NAHMA headquarters, we have implemented the recommended guidance from CDC, and we are responding to directions from federal, state and local public health and other officials as they emerge. In addition to all of the obvious basics (social distancing, regular disinfecting, hand-washing, etc.), this week we have implemented a telework plan whereby NAHMA staff will only report to the office in teams of four on two days a week, and the rest of the week we will telework. Should directives or circumstances require us to telework completely, we are prepared to do so.