HUD answers COVID-19 Payment Request Questions
Regulation | August 03, 2020 | by Juliana Bilowich
HUD published a tip sheet for the funds request form and answered questions to provide clarity for affordable housing providers requesting reimbursement for COVID-19 expenses.
Following the July 23rd announcement of funds to reimburse Multifamily Housing providers for COVID-19 expenses, LeadingAge has continued to ask HUD for clarity as owners request funds under the tight deadline. HUD responded by answering member questions and providing a document of tips and explanations for the form.
HUD Document: Tips and Explanations for Completing the CSP Request Form
On August 3rd, HUD's Office of Housing provided a document with helpful tips as housing providers request COVID-19 Supplemental Payments (CSPs) under the CARES Act. The deadline for Section 8, Section 202, and Section 811 owners to submit the request form for each property is August 5th.
The document, titled "Tips for Completing Form 52670-E," covers both technical issues and content questions owners may have when completing their CSP requests. The document also reiterates the owner certification and acceptance of terms to recieve the funds, stating that "HUD anticipates post-approval compliance reviews and high likelihood of program audits.
Answers to LeadingAge Member Questions
HUD staff answered questions during a LeadingAge Housing Advisory Group call in late July and has followed up with the following additional answers to questions submitted by LeadingAge members:
- IT for resident use: "We opted to set up computer stations for residents so that we could also allow for IT support on three computers instead of trying to help 107 residents with their own. Is this something HUD would cover under the idea to keep the building safer? It is promoting social distancing by allowing residents to do on-line grocery shopping, access telehealth services, and connect remotely with friends and family."
Allowable reimbursements through CSP for IT purchases are generally limited to those related to property operations. Expenses incurred to establish one computer workstation to be used by residents to aid and assist residents with the recertification process, in conjunction with virtual office operations, i.e., obtaining electronic documents for verification, signing documents electronically, scanning of documents, etc. are allowed under CSP. In addition, properties with established Elderly Service Coordinator program may receive CSP for purchase of a secondary electronic device for the program that is made available to residents to assist with access to supportive services, including telehealth services.
- IT reimbursements for Service Coordinators: "Some Service Coordinators at our elderly properties had older computer equipment with limited memory and were without speakers, microphones, and cameras. To be able to hold virtual meetings we purchased new computers. Is this reimbursable?"
Where a property has an established service coordinator program funded through operational sources (not grant-funded), costs to upgrade the Service Coordinator’s work computer to facilitate virtual meetings would be eligible for CSP.
- Resident services: "Is there a way to offset the cost of delivering meals on weekends and activity packages delivered weekly for the well-being of the residents?"
CSPs are not a means to offset the cost of delivering meals on weekends and activity packages delivered weekly for the well-being of the residents. These services are not generally covered by project operations.
- Supporting documents and justification: "Does the applicant have to justify the critical funding needs before submitting the application, or can we supply it after the fact? Also, the date range per notice is from March 27 through July 31, but we do not have data up to July 31 yet since now is still July 27. Could we use an estimate based on recent expenses? Or does it have to be specific dollar amounts?"
The application should reflect actual costs incurred through 7/31/2020, not estimates. The supporting documentation must be provided at the time of application.
Application request forms for the COVID-19 Supplemental Payment (CSP) funds are due to HUD by August 5, and a recording of the call is here. More information about the Housing Notice and Request Form are available here.