Using HOME for Rehabilitation. January 13, 2015

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Joy Barbara Dalton
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1 Using HOME for Rehabilitation January 13, 2015

2 Sponsored by HUD s Office of Affordable Housing Programs & NCSHA Speakers Phil Jones, ICF International Steve Lathom, TDA

3 Goals & Context Focus on HOME-funded single and multi-family rehab projects Emphasis on recent/pending rule changes: Written Rehabilitation Standards Capital Needs Assessments Enhanced Inspection Standards Framework for planning, but more detail to come Reconciling state/local standards, proactive tips Questions welcome throughout

Needs Assessments Enhanced Inspection Standards Framework for planning, but more

4 Rule re-emphasizes requirement for written rehabilitation standards HQS/UPCS are not rehab standards Building code is not a rehab standard Local codes Housing, habitability, property maintenance, fire, health enforcement action Building code sets standard for how work must be done, triggered by voluntary decision to undertake work

habitability, property maintenance, fire, health enforcement action Building code

5 Inspectable Items Rehabilitation Standards Condition Requiring Intervention Methods & Materials

6 Deciding to intervene, standards must integrate several requirements Condition Requiring Action State & Local Codes HUD Specified UPCS Deficiencies Other Federal Req: LBP, 504, etc Local Program Design Useful Life

& Local Codes HUD Specified UPCS Deficiencies Other

7 Useful life Part of 2013 Rule s emphasis on sustainability Homeownership housing under If rehab, at project completion major systems must have remaining useful life of 5 years Major systems include structural supports, roofing, exterior envelope (e.g. windows, siding, etc.), plumbing, electrical, and HVAC

254 If rehab, at project completion major systems must have remaining useful

8 Rental housing under For all projects, if a major system s useful life is less than the affordability period repair/replace or ensure sufficient reserves Projects w/26+ total units A Capital Needs Assessment (CNA) must support analysis and address long term physical needs

the affordability period repair/replace or ensure sufficient reserves

9 Capital Needs Assessment Required for underwriting if 26+ total units Recommended for smaller projects and as ongoing asset management tool (e.g., every 5 th year) Use in Underwriting Model interaction between scope of work & reserves Evaluate life-cycle costs of alternative rehab options

g., every 5 th year) Use in Underwriting Model interaction between scope

10 CNA etool Rental Policy Alignment Working Group initiative Standardize CNA format across HUD & USDA Build dataset on portfolio performance over time HUD will require for FHA, RAD, M2M, etc. Flexibility Direct use Data protocol/map allowing Business to Government transmission from existing CNA providers

HUD will require for FHA, RAD, M2M, etc.

11 CNA etool & HOME Free resource available for public use PJs allowed to accept/use other formats Anyone can use data validation feature Not planning submission to HUD database HUD Developing training options mostly remote Targeted to required etool users HOME training will incl. general CNA evaluation

planning submission to HUD database HUD Developing training options mostly

12 Methods & Materials Define preferred manner of repair or replacement, including product standards Provide basis for project specific plans/specifications or work write-up

13 Inspectable Items Rehabilitation Standards Condition Requiring Intervention Methods & Materials

14 PJ must inspect Who? Policies & procedures must define inspectors qualifications and skills, which might vary between SF & MF, such as: Knowledge of applicable codes and PJ s rehab standards Evaluation of remaining useful life, CNA review Ability to develop scope of work (or assess developer s proposal), estimate costs Can use staff, subrecipient staff, or contracted professional Must be contractually obligated to PJ via written agreement Accountable to PJ s rehab standards and policies

Knowledge of applicable codes and PJ s rehab standards Evaluation of remaining useful life, CNA review Ability to develop

15 Inspectors cont. Coordinating w/other funders to jointly engage contracted inspectors Lenders & public funders (e.g. State & local HOME) Must be independent of owner Cannot use owner s architect Equity investor is an owner, not another lender/funder Inspector/inspections must still meet PJs standards Evaluate standards to ensure all funders needs are met

16 PJ must inspect When? Initial inspection -- prior to commitment Determine necessary scope of work Progress inspections during rehab PJ must conduct even if HOME not paying for construction (e.g. HOME used for acquisition cost) Variation in number, timing, & frequency by project type, program design Final inspection Confirm work write-up and property standards met

17 State perspectives & challenges Rehab standards Specified by state PJ vs. developed by state/subrecipients subject to PJ review, esp. for HO programs Reconciling and incorporating varying local code requirements Incorporate into application processes Differences between MF and HO programs?

for HO programs Reconciling and incorporating varying local code

18 What to watch for Technical corrections & technical amendments Guidance on Property Standards and Rehab Standards, including applicability of UPCS Additional resources, sample rehab standards, HUD CNA e-tool

Standards, including applicability of UPCS

Matrix of Alignment Proposals

Matrix of Alignment Proposals Pilot Proposals ID Title and Lead Agency Summary Direct 1 Physical Inspection Pilot (6 States) One federally-sponsored visit to each property with standard sampling size,