HUD’s Tenant Data Collection Initiative (2008 HERA)

Written by Paul Perpich, Director of Software Development

Greetings and welcome to my first blog entry on our updated web site! I’m excited to have an opportunity to communicate directly with you about our End of Year Reporting software as well as upcoming changes you can expect to see. I’ll also be providing tips on the use of our software as well as industry news regarding the data we need to collect as part of our compliance monitoring activities. Please stay tuned…

The 2008 Housing and Economic Recovery Act (HERA) included a provision directing state HFAs to collect and submit to HUD demographic and economic information on tenants living in LIHTC properties. The first set of tenant data was for 2009 and initially needed to be submitted to HUD by September 31, 2010. HUD first released it’s XML data specification documents and technical instructions in July of 2010 and continued to updated them until September. Consequently, they moved the deadline back to October 31st.

We were able to work closely with Mike Hollar at HUD on finalizing and testing our submissions to their new web site and were able to compile and successfully submit final tenant data for our client state FHAs by the deadline (HUD letter to Spectrum).

The two primary reasons we were able to meet this deadline for the 2009 data (as well as the upcoming 2010 submission) is that HUD relaxed some of the requirements regarding what was to be submitted in the first year(s) of the mandate and the reduced data they are accepting has been part of the data set we collect every year in our End of Year Status Report software that property managers use to report to Spectrum as part of their annual compliance requirements. Things will change for the 2011 data.

Starting with 2011 data HUD will be raising the bar regarding the data that needs to be collected. For example, for 2009/10 they didn’t specifically require demographic data (name, DOB, race, ethnicity, disability status, student status, and last four digits of the social security number) on each member of the household and only required a Head of Household name. For 2011 they will require demographic information on all household members.

Collection of this demographic data has become a sensitive issue for some states and consequently HUD has modified the options for some of the questions. For example, HUD’s original TIC form only included a Yes or No answer to the Disabled question and include the following instructions regarding identifying disability:

“The housing credit agency administering its low-income housing credit program must, to the best of its ability, provide this disability status information, pursuant to 42 U.S.C. 1437z-8. However, it is the tenant’s voluntary choice whether to provide such information, and questions to the tenant requesting the information must so state. If the tenant declines to provide the information, the housing credit agency shall use its best efforts to provide the information, such as by noting the appearance of a physical disability that is readily apparent and obvious, or by relying on a past year’s information. For purposes of gathering this information, no questions with respect to the nature or severity of the disability are appropriate.”

For 2011 and beyond HUD has modified the available answers to include ‘Did Not Respond’ to the Race, Ethnicity and Disability Status questions.

Consequently, our End of Year Reporting software will be updated to include these and other new requirements and will be released in the fourth quarter of 2011. Keep in mind that the data HUD is requesting is the status of the project as of December 31st. What this means to property mangers in Spectrum’s client states is that they’ll continue to enter and submit data with our End of Year software in their usual manner and on their same schedule during the first quarter of 2012 (either hand entering or importing XML files from their management software systems) only they’ll be using an updated version of the software.

Next time I’ll be covering changes to the NAHMA XML standard (to accommodate the new HUD data) used by  property management software systems to import data into our software.

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