PBV Info collection chart PDF Attachment to PHADA Comments on PBV Info collection

Proposed PBV Information collection

Attachment to comments from PHADA on Proposed Information Collection: Project Based Vouchers (PBV) Online Form Docket No. FR-7051-N-10

Fields

Notes from HUD definitions

Already Provided to HUD?*

HAP Contract Number

Form HUD 52530 A or B (HAP Contract)

No

Name of Project

Determined by PHA as used in public or property
records, or commonly used name.
No

Address of Building(s) and Units
Number of units under AHAP
Number of units under HAP Contract by bedroom size

Yes
No
No**

Number of Total Units at the Project

No

Structure Type (Elevator, Mixed, Row or townhouse, Semidetached, Detached/single family, Walkup/multi-family)
Type (Existing, re-hab, new construction)

Most closely matching from the list.

Yes

If PHA Owned: Name of Independent Entity or Entities

Other Related Programs (Tax Credit, RAD, HUD-insured, VASH,
Other)

Entities which perform the following functions
consistent with 24 CFR 983: 1. Review the PHAs
PBV selection process; 2. Establish PBV contract
rents; 3. Determine rent reasonableness; 4.
Provide the rent reasonableness determination
to the PHA and HUD field office; 5. Establish
term of initial and any renewal HAP as per
983.205; 6. Inspect units; 7. Provide a copy of
the inspection report to PHA and HUD field
office.

Can cause confusion, multiple names may be in
place. 'Project" as defined in CFR 983.3(b)

Pull and review HAP contract and possibly other documents;
discuss internally which name to use.

10

How will this be entered, if it must include
address for each individual unit?
(From AHAP)
(From HAP)

Identify address from HAP or AHAP; confirm for individual
units via system search; enter address for each unit.
Pull AHAP, review, enter numbers.
Enter number
Contact owner or manager, or pull original application
documents to identify the total number of units.

Including non-contract units

PIC 50058

112
10
1

Identify address 2; system search to identify
all unit addresses 10; enter address for each
unit - 2 minutes per unit. For 50 units 100
minutes
VMS collects totals, not by property
VMS collects totals, not by property

15

Additional time if multi-stage

Enter info from HAP

1

Additional time if multi-stage

Enter info based on HAP
Enter info from HAP
Enter info from HAP
Review records to identify management entity

2
1
1
2

No

Review ownership Entity legal documents and 24 CFR 983 to
determine category

1

No

Pull agreements and other documents to identify the relevant
entities, enter information

10

No

No
Yes, but not contact info.
Yes
No

Include any HUD special purpose vouchers; and
any other federal, state or local assistance
including tax credits and other tax incentives.
No

Population Served (General, Homeless, Veterans, Families Eligible
for Supportive Services, Families receiving supportive services,
Elderly Family, Disabled Family)
Definitions at PIH Notice 2017-21, or CFR 5.403.

5

1

From HAP Part 1(d). For multi-stage projects,
include dates and units covered in each stage.

PHA Owned, PHA Ownership interest but not PHA owned, No PHA
Ownership Interest
Determined based on 24 CFR 983 as amended.

Pull HAP contract

Minutes Breakdown

Enter info from AHAP

Effective Date(s) of HAP

Inc. contact information

Steps PHAs may need to take to gather and enter info

1
1

From AHAP Part 1.4. May include multiple dates
for phased projects.
No

Based on HAP contract term (initial and any
extensions)
From HAP Part 1(a) including contact info.

PIC 50058

Initial comments

Estimated Number of
minutes to complete Total

Enter type selection
Enter type selection

Effective Date(s) of AHAP

Expiration Date
owner Name
Owner Tax ID
Management Entity

Method of info
provision to HUD

No

PIC 50058
PIC 50058

What if HAP contract only has an option to
extend and it is not required as under RAD?

Need to calculate end date based on start
date and term.

1 minute assumes no PHA ownership
interest. Significantly more if there is a PHA
ownership interest to review docs and
determine category.

Review original application documents, other agreements,
and perhaps contact manager/owner to determine what, if
any, other assistance is provided.

15

15 minutes estimate assumes information is
included in documents, or manager/owner
is available and able to provide information
accurately. Tax incentives other than LIHTCs
will be especially difficult to identify.

Review notice if needed, enter result

1

Assumes no review of notice is necessary

Does an Exception to the Income Mixing Requirement Apply?
If yes, which exception(s)?

Y/n, as per 983.56 as amended.
Exception categories from the Regs, and PIH
Notice 2017-21.

Supportive services available (Y/N)?
Vacancy Payments Permitted (Y/N)?

"If the project has supportive services available
to residents so as to qualify for an exception to
24 CFR 983.56.
Y/N, from HUD 52530

Enter result

1

Assumes no review of agreements,
procurement, HAP or Regs is needed.

Enter result

1

Assumes exception, if applicable, is known.

No
No

Great risk here that if services are available on or
near site, that PHAs will enter Y even if it does
Review HAP and/or AHAP, review regs, determine accurate
not qualify under regs.
reporting.
Review HAP, enter data

5
1

Assumes some research needed.

The PHA must submit information to HUD on the
exception, but the required submission does not Review procurement or other docs (annual Plan?) to
require detailed property-level information.
determine if a program cap exception applies.

10

Assumes some research needed.
Assumes some research needed, but
documents already pulled and review for
answer to prior question.

Yes
No

Program Cap Exception (Y/N)?

Y/N, as per 983.56 as amended.

Yes and No

Program Cap Exception Category
Unique Project building Code ***
HAP Contract Code ***

Exception categories from the Regs, and PIH
Notice 2017-21.
***
***

Yes**
No
No

Number of RAD PBVs

Number of PBVs that converted under RAD

No*

Use Restriction End Date

Year Built
Number and Bedroom Distribution of PBV-assisted Section 504
Mobility units at the Project
Number and Bedroom Distribution of PBV-assisted Section 504
Hearing/Vision Units at the Project

*** The unique project building code and HAP contract code may
be produced by the system or a protocol for numbering may be
established by HUD.

HUD 50058

Review regs, notice, project docs, etc. following on previous
question.

Badly worded, as PBVs don't convert, but LIPH is
converted to PBVs.
Review initial docs, enter number.

** Only units under lease are reported via 50058.
VMS record of HAP numbers is aggregate, not
property specific.

2

Review property documents, perhaps including closing
binder, to determine if restriction in place, and the timing of
such restriction.

15

No

For rehab or existing units, may require information from
owner or other records, may not be readily available.

10

No

Review AHAP and HAP and enter number.

5

No

Review AHAP and HAP and enter number.

5

Y/N if HUD use restriction in place; if yes include
end date.
No*

Year construction was first completed.
Units must meet either UFAS, or 2010 ADA
standards, as per 'HUD's Deeming Notice" from
Fed Register May 23,2014.

5

* Does not consider information provided for environmental, civil rights, or RAD reviews, as this
information is not systematically gathered and reported in a database and any aggregation or reporting
would be a manual process.

Assumes relevant documents must be
located, perhaps in another department,
and reviewed. Location of such information
is not obvious or uniform.

Estimated Burden Hours
Total Estimated Minutes

250

4.166666667

Rough estimate is that collecting and entering data will take about one half of a normal work day.