**This article was updated on October 5 to reflect additional information from HUD. Updates are found in italics throughout.**

During a special edition of LeadingAge’s regular Housing Advisory Group call on October 4, HUD staff reviewed details of COVID-19 Supplemental Payments, or CSPs, which provide a mechanism for housing providers to receive reimbursement for COVID-19 related expenses. Throughout the call, agency staff responded to advance LeadingAge member questions as HUD-assisted housing communities complete purchases by October 31 for reimbursement requests by November 19. 

Key Questions asked by LeadingAge Members

• When will HUD’s request form be available?
  • HUD is planning to published the CSP request form during the week of October 4. All forms submitted prior to the November 19 deadline will be given equal consideration.
• When can providers expect reimbursement payments?
  • The process will take longer this round; payment is expected by mid- to late-February 2022.
• How sure are housing providers that they will receive reimbursement?
  • During this round, HUD is guaranteeing that providers will receive reimbursement up to the eligible standard payment amount (as derived by a property-specific formula) for costs incurred. This amount is dependent on funds availability and may result in Section 8 properties receiving 100% of the standard payment amount, while PRAC properties may receive 70%. Requests that are larger than the standard payment amount will undergo additional review and may not receive the full requested amount. 
• What is the reimbursable period?
  • Providers can request reimbursement for eligible expenses between March 27, 2020 and October 31, 2021. Previously submitted requests can be amended to reflect new eligible categories.
• What capital costs related to internet installation can be included in requests?
  • A property can seek reimbursement for installation costs related to wiring a property, including in resident units. The property can also seek reimbursement for installation equipment costs, such as routers and signal boosters. Properties cannot receive reimbursement for resident devices, with the exception of one terminal per property accessed by residents for the purposes of completing housing management-type activities, such as scanning materials for a recertification or accessing a lease document online. Properties also cannot be reimbursed for internet installation overlays in parts of the property that already have internet installed; this includes for upgrades or improvements to existing internet infrastructure.
• Can technology costs be included for reimbursement?
  • While the capital cost category of the Notice does not permit the actual cost of devices, the operating cost category of the Notice permits reimbursement for webcams, zoom licenses, and laptops necessary to facilitate physically-distanced property management. Properties with a budget-driven Service Coordination program can request reimbursement for a laptop or tablet device for resident use (one device per 100 residents) for COVID-19 related purposes, such as leveraging telehealth services or accessing virtual programming; the device should be maintained and managed by the Service Coordinator as opposed to distributed to residents. 
• How can a property demonstrate that they are serving a “vulnerable elderly population” for the purposes of the back-up generator reimbursement, as required by the Notice?
  • Properties designated as “elderly” do not have to provide additional documentation of serving “vulnerable elderly;” family properties would need to include documentation showing that the property serves an elderly population.
• Can permitting costs be included in capital costs?
  • Yes, local building inspections and other inspections related to the installation of back-up generators and HVAC improvements are allowable reimbursement costs under the Notice.
• What kinds of ventilation system upgrades can be included for reimbursement?
  • ​​​​​​​System upgrades to commons areas or other frequently-trafficked areas such as elevators can be covered by CSP reimbursements, in conjunction with Reserve for Replacement releases. “Air Scrubbers” and UV light air purifiers, for example, can be included for reimbursement. 
• What vaccine clinic costs can be reimbursed?
  • ​​​​​​​Under the CSPs, HUD will offer reimbursement for extra staff time associated with hosting a vaccine clinic. HUD will also provide reimbursement for chair, table, and tent rental s to facilitate the clinic. Costs associated with food, water, and vaccine incentives are not eligible for reimbursement.
• Can properties undergoing a rehab request reimbursement for eligible capital expenses incurred during the rehab process?
  • ​​​​​​​Yes, properties undergoing rehab can request reimbursement for eligible capital expenses, but the properties should be sensitive to sources of fundung in order to avoid duplication of funds.
• Many housing providers with a meal program closed down the service during the pandemic due to the risk associated with dining (without a mask) in a group setting. Instead, housing staff often provided meals to the doors of residents; this required the temporary purchase of plastic ware and other meal ware. Are these (and other similar costs associated with altering a meal program) eligible for reimbursement through CSPs?
  • ​​​​​​​No, these are not eligible costs.

HUD staff will soon be issuing written responses to these and other LeadingAge questions.

Timing Update for Eligible Capital Costs

The Notice allows reimbursement for COVID-19 related capital costs for three categories: Wall-to-wall internet installation, emergency back-up generators, and ventilation system upgrades. However, with less than six weeks to complete the purchases since release of the Notice, completing eligible capital expenses has been near to impossible.

LeadingAge has advocated strongly for additional time to complete capital expenses, or for the ability to demonstrate “reasonable intent” to complete expenses after the October 31 expenditure deadline. However, during the October 4 call, HUD staff were not able to assure LeadingAge of an extended timeframe to complete the expenses related to capital improvements at the property. LeadingAge will continue to advocate with HUD for an extended timeframe or other flexibility to allow reimbursement options for eligible capital expenses.