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WyoNAHRO Positions on the Constraints of Relying on Federal Grants WyoNAHRO members realize that federal budget cuts will constrain spending for the programs we administer. Therefore we are proposing that Congress consider the following suggestions that would assist us to continue to effectively administer the programs given funding constraints. WyoNAHRO positions and suggestions regarding the federal budget: Eliminate the uncertainty that has negatively impacted all aspects of the programs we administer, from funding levels to arbitrary, inconsistent and delayed regulation changes. We have struggled to continue to effectively administer our programs, with ever-declining funding, and ever-increasing regulation that is often not made available in a timely manner and yet has great impact on our agencies and programs. Address the inherent inequity in the Voucher portability regulations that permit certain populations to shop waiting lists with the intent of utilizing the Voucher assistance outside of the issuing housing authority’s jurisdiction after the tenant has met the one year residency requirement. For example the Cheyenne Housing Authority is experiencing a significant exodus of Vouchers to other jurisdictions from a specific population that has organized this effort in various HA’s within our region. Consequently assistance that was allocated to address the rental housing needs in Wyoming will be benefiting households in other, often more expensive jurisdictions that had longer or closed waiting lists. Portability exposure should be limited or capped in order to avoid this situation. Another option would be for HUD to manage a portability pool that enables families to port, but with vouchers that are provided by HUD to the receiving housing authority so that the originating housing authority’s programs cannot be unduly depleted. Ensure continued exemptions for small housing authorities (less than 400 public housing units) from having to convert to HUD’s mandated project-based asset management model; Provide more specific dictates to HUD regarding the recapture or offset of reserves, both Operating Reserves and Voucher Reserves, so that responsible agencies are not penalized unfairly for maintaining sufficient reserves so that poor performers can be fully funded; The recapture of reserves has had an even greater negative impact on the ability of agencies to administer their programs when compounded by ongoing funding cuts to Voucher administrative fees, which declined 10% in 2011 and 32% in 2012. We understand that the recently passed continuing resolution provides some relief to a 24% cut. These funding cuts, and reserve recaptures, have not been accompanied by any regulatory relief. Therefore we are again being asked to do more with less, and it will be reflected in lower scores and impacts on service delivery. Our frustration is amplified by the fact that the administration continues to propose new programs, rather than provide regulatory relief within existing programs. We propose that all or portions of the Section Eight Management Assessment Program (SEMAP) be waived or suspended until funding can be restored for Voucher administrative fees. Reduce the regulatory burden of federal housing programs.  One method would be to consolidate all federal rental housing subsidy programs so that the regulations conform.  Currently the regulations and compliance requirements of each program are somewhat similar, but different enough different to require special software and other administrative burdens to assure compliance unique to each program.  Because of the regulatory similarity, it seems they could be relatively easily conformed to eliminate unnecessary duplication, reduce administrative burden and costs, enhance compliance, and improve programmatic outcomes. Encourage permanently financed affordable housing development by fixing Low Income Housing Tax Credits at 4% and 9% respectively. This would encourage equity investment and help reduce the demand for HOME funding. To reduce the home loan default rate and related costs, require the successful completion of homebuyer education prior to the purchase of any home financed with federal funding.
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