HUD reopens applications for COVID-19 relief payments

Regulation | November 23, 2020 | by Juliana Bilowich

HUD announces second application period for COVID-19 Supplemental Payments from the CARES Act. The filing deadline for multifamily housing owners is December 11, 2020 for expenses incurred through November.

On November 23rd, HUD announced the continued availability of supplemental funds for HUD-assisted multifamily housing providers responding to COVID-19. In July, HUD had announced the initial request period for COVID-19 Supplemental Payments; the new HUD notice establishes a second request window and updates the submission requirements.

To the extent that rent receipts and other project funds are inadequate to address additional operation costs to maintain COVID-19-safe properties, HUD is continuing to make CARES Act funds available. Under the new HUD guidance (H 2020-11), owners of properties assisted under Section 8, Section 202, and Section 811 have a December 11, 2020 filing deadline to be considered for additional COVID-19 Supplemental Payments (CSPs). The request period covers expenses incurred through November 30; properties that did not receive payments for the earlier timeframe (March 27-July 31) may resubmit for that period as well.

Within the notice, HUD has made changes to include clarifications on the eligibility of RAD Section 8 properties, eligible activities for CSP funds, and allowable signatories for the request form. HUD has also updated their tips for filling out the request form.

Three main types of payment requests are discussed in the Notice:

  • Requests for COVID-19 expenses incurred from August 1 to November 30
  • Requests from owners who did not submit requests under the previous notice for expenses incurred from March 27 through July 31
  • Allowable re-submissions for previously disapproved CSP requests

Eligible Costs

COVID-19 Supplemental Payments (CSPs) for Section 8, Section 202, and Section 811 will supplemental regular HUD operating payments made to providers. Specific eligible operating costs that can be reimbursed through CSPs include the following; capital costs are excluded.
 

  • Increased cleaning and disinfecting as COVID-19 prevention
  • Intensive deep cleaning and sanitization in respond to COVID-19 exposure on site
  • Office technology and other equipment to facilitate social distancing
  • PPE for staff and residents
  • Facility and equipment for social distancing
  • Site control measures that support shelter-in-place or visitor-restriction policies
  • Temporary staffing, contract services, overtime pay, or enhanced budget-based or IWISH service coordination to support older adults or people with disabilities
  • Temporary staffing increases (includes new positions and overtime, but excludes hazard pay bonuses)

CSPs are not intended to receive funding for lower tenant rent contributions. Instead, CSPs are available to offset expenditures for COVID-19 related costs.

Time Frames and Amounts

HUD will consider costs incurred between March 27, 2020 and November 30, 2020. Owners may submit for a request for each of the following operation periods using Form HUD-52671-E.

  • March 27, 2020 – July 31, 2020 (Properties that already received a CSP for this period may not submit an addition request; however, properties that did not submit, missed the August 5th deadline, or submitted a request that was denied due to an incorrect signature or incomplete data field may resubmit)
  • August 1, 2020 – November 30, 2020

Once again, HUD is making two funding categories available: Tier I for standard payments, and Tier II for exceptional cost payments. In total, HUD is allocating up to $25 million for properties under the Section 202 program.

Under Tier I, properties can request a $2,000 base amount per property, plus $60 per assisted unit; $1,000 additional per property allowance for senior housing; and up to $3,000 additional allowance for budget-based service coordination costs. The payment caps are calculated per property, not per contract.

Owners can request larger sums under Tier II Exceptional Cost Payments, in particular for costs occurred due to COVID-19 outbreaks at the property, or in response to extensive community exposure. Tier II requests must be substantiated by supporting documentation, but there is no cap on Tier II payments. If there are shortfalls within the funding pool, HUD will first consider property-level characteristics, like an elderly designation, to set funding priorities.

Submission Process

For both Tier I and Tier II CSP requests, owners should submit form HUD-52671-E to their contract administrator, field office, or PBCA. The form must be signed by the property owner or their authorized signatory. All requests received by 11:59 local time on December 11 will be given equal consideration. Submissions for Tier II should include supporting documentation, including receipts, payroll, or other records for line-items exceeding $500, as well as a narrative description. Reach out to jbilowich@leadingage.org with questions.