Session 4: HCV and HCV-Related Programs

Transcription

1 FASS PH Session 4: HCV and HCV-Related Programs Summer 2014

2 Overview This session will: Provide an overview of the reporting requirements for the HCV program and HCV-related programs Clarify revenue recognition for HAP and Administrative Fees, taking into account the Cash Management Requirements Review the HAP disbursement process based on the Cash Management Requirements Review proper HCV program accounting and financial reporting including use of various FDS line items related to investment income, fraud recovery, FSS, and portability 2

3 General Reporting

4 HCV Program Guidance The HCV program is directed by laws, regulations, and notices PHAs can look to the following HUD website pages to find important program guidance: Office of Housing Choice Vouchers; HCV Financial Management Center (FMC); Housing Voucher Financial Management Division (FMD); HUD's web library 4

5 Revenue Recognition

6 Notice PIH : HAP Revenue Recognition 2012 & Forward With the implementation of the cash management requirements of Notice PIH , the full ABA will no longer be automatically disbursed to PHAs Disbursements of ABA will be based on need Undisbursed HAP funds will be available for future HAP payments Amounts not disbursed will be retained by HUD in a new Program Reserve 6

7 Notice PIH : HAP Revenue Recognition 2012 & Forward, continued HAP revenue recognition will now be based on disbursements from HUD + need Program reserves will not be presented or reflected in the PHA s financial statements The concept of Net Restricted Assets will still exist Existing NRA balances currently held by the PHA will be transitioned to program reserves 7

8 Cash Management HAP Funding Model 2012 ABA $1,260,000 Program Reserve 1/1/2012 $0 NRA -1/1/2012 $600,000 Month HAP Disbursement HAP Expense Net Income NRA Balance Jan-12 $100,000 $100,000 $0 $600,000 Feb-12 $100,000 $110,000 -$10,000 $590,000 Mar-12 $100,000 $90,000 $10,000 $600,000 Apr-12 $0 $100,000 -$100,000 $500,000 May-12 $0 $110,000 -$110,000 $390,000 Jun-12 $0 $100,000 -$100,000 $290,000 Jul-12 $0 $95,000 -$95,000 $195,000 Aug-12 $0 $95,000 -$95,000 $100,000 Sep-12 $0 $100,000 -$100,000 $0 Oct-12 $110,000 $110,000 $0 $0 Nov-12 $90,000 $90,000 $0 $0 Dec-12 $100,000 $100,000 $0 $0 Total $600,000 $1,200,000 -$600,000 Program Reserve 12/31/2012 $660,000 NRA 12/31/2012 $0 8

9 May 2014 Changes

10 May 2014 changes to FDS Restricted cash FDS line items with additional detail links: FDS Line 113, Cash other restricted FDS Line 115, Cash restricted for payment of current liability FDS Line 132, Investments - restricted FDS Line 135, Investments restricted for payment of current liability 10

11 May 2014 changes to FDS, continued Restricted cash and investment detail link information: Restricted for HAP Restricted for FSS escrow deposits Restricted for other uses 11

12 May 2014 changes to FDS, continued New detail inks have been added to account Management Fee Expense To PHA Administered Program (i.e., COCC) To 3 rd party / Outside entity 12

13 May 2014 changes to FDS, continued FDS Line Housing Assistance Payments will include additional details including the following: HAP costs related to portout vouchers HAP costs related to FSS escrow accounts HAP costs related to other special purpose vouchers 13

14 Program Specific Guidance for Revenue Recognition

15 HAP Revenue Recognition 2012 & Forward Using the disbursements + needs criteria: Generally HAP revenue will equal actual HAP disbursements received by the PHA There will be no accounts payable to HUD if the PHA received disbursements from HUD greater than need In this case, disbursements from HUD will equal HAP revenue for the year The difference will accrue to the PHA's NRA account 15

16 Example 1 HAP Revenue Equals HUD Disbursements 2012 Budget Authority $2,500,000 Program Reserve - 1/1/2012 $0 NRA - 12/31/2011 $200,000 Line # A B C D E F G H Actual HUD HAP Actual HAP Disbursement Expense Net HAP Fraud NRA Program Interest Time Period based on VMS (VMS) Activity Recovery Balance Reserve* Earned 1 Jan-12 $191,250 $190,000 $1,250 $2,000 $203,250 $2,308,750 $250 2 Feb-12 $193,250 $195,000 -$1,750 $0 $201,500 $2,115,500 $250 3 Mar-12 $195,250 $195,000 $250 $2,000 $203,750 $1,920,250 $255 4 Apr-12 $195,250 $195,000 $250 $3,000 $207,000 $1,725,000 $260 5 May-12 $194,250 $225,000 -$30,750 $0 $176,250 $1,530,750 $220 6 Jun-12 $193,250 $225,000 -$31,750 $0 $144,500 $1,337,500 $180 7 Jul-12 $196,250 $225,000 -$28,750 $2,000 $117,750 $1,141,250 $150 8 Aug-12 $201,250 $230,000 -$28,750 $1,000 $90,000 $940,000 $110 9 Sep-12 $201,250 $235,000 -$33,750 $300 $56,550 $738,750 $70 10 Oct-12 $201,250 $230,000 -$28,750 $0 $27,800 $537,500 $35 11 Nov-12 $231,250 $225,000 $6,250 $2,000 $36,050 $306,250 $45 12 Dec-12 $231,250 $220,000 $11,250 $0 $47,300 $75,000 $59 13 Total $2,425,000 $2,590,000 -$165,000 $12,300 $47,300 $1,884 Program Reserve - 12/31/2012 $75,000 16

17 PIH Notice Notice outlines a strict policy prohibiting the use of outside funding to augment the HCV program Congress does not necessarily use the HAP renewal formula when it makes its determination of annual budget authority Because of this, allowing an increase in HAP expense through outside sources could result in the need to increase the pro-ration percentage. 17

18 PIH Notice , continued The following sources of funds are always available to support the HAP costs of the program (current leasing and new leasing), assuming no over leasing: Current Year Annual Budget Authority (ABA) PHA held Net Restricted Position (NRP) HUD held Program Reserves Unrestricted Net Position (UNP) further clarification on next slide 18

19 PIH Notice , continued PHAs may not use current year admin fees to cover HAP expense. Only amounts in the UNP may be used or Excess admin fees that are earned in the current year and roll into the UNP at year-end may be used to pay HAP expense. Also, the cost of over leasing must be covered by either the UNP or outside sources. 19

20 PIH Notice , continued There is one exception where HUD will grant the use of outside funds to augment HCV HAP funding: Prevent the termination of assistance to current participants. 20

21 Investment Income

22 Investment Income Proper accounting for investment activity requires: Determination of the fair market value of an investment; Recording investment income as it is earned (accrued); and Allocating interest income to the proper equity type according to Accounting Brief #19. For PHAs, all investments are classified as current 22

23 Investment Income: FDS Lines Line Items to record transactions related to Investment Income: FDS Line Account Description 111 &/or 131 Cash Unrestricted &/or Investments Unrestricted (Admin Fees) 113 &/or 132 Cash Other Restricted &/or Investments Restricted (HAP) Investment Income Unrestricted - HAP (Typically not used) Investment Income Unrestricted - Admin Fees Investment Income Restricted - HAP Investment Income Restricted - Admin Fees (Typically not used) 23

24 Investment Income, continued Keep in mind the following when reporting investment income: Allocate based on asset type - i.e., if asset on which income is earned is unrestricted, income is unrestricted, etc. Allocate based on funding sources - i.e., HAP funds invested creates restricted investments and restricted interest income 24

25 Net Restricted Assets and Interest Income An example of interest earned shown on the table below on NRA balances In the above example, even though the PHA received $4,250 in interest, the NRA balance is not increased by the amount of interest earned as it is returned to the Treasury instead of being recorded as revenue 25

26 Interest Earned on Invested NRP and Excess HAP HUD Guidance on the subject was issued by the FMC on: March 19, 2014 Initial guidance was sent by to all EDs outlining requirements March 26, sent clarifying how to remit to treasury May 9, 2014 Revised guidance sent by 26

27 Interest Earned on Invested NRP and Excess HAP, continued Effective January 1, 2012, HUD implemented new cash management procedures to comply with Treasury s rules on cash advances to grantees. Major change interest earned on invested NRP balances and excess HAP will now be returned to the U.S. Treasury effective for interest earned beginning on 01/01/2012 and after. 27

28 Interest Earned on Invested NRP and Excess HAP, continued Other impacts of this policy change: Will not close to NRA account Will not become part of program reserve Will not be recognized as restricted interest income on the HCV income statement 28

29 Interest Earned on Invested NRP and Excess HAP, continued Initially HUD s guidance (the March 19, 2014 memo) was: PHAs could retain up to $100 per calendar year in interest earned on invested NRP balances and excess HAP funds Amounts over $100 had to remitted quarterly by check or EFT to the U.S. Treasury Revised guidance issued on May 9, 2014 indicated that after December 31, 2013: The limit is raised to $500 and remittance would be annually Due 30 days after the end of the PHAs fiscal year end 29

30 Interest Earned on Invested NRP and Excess HAP, continued VMS Reporting Although from the FDS reporting standpoint it will be shown as an AP HUD, it will still be reported in the VMS field Interest or other income earned this month from the investment of HAP funds and Net Restricted Assets Question posed to HUD should the PHA exclude the amounts they may retain for admin expenses from this VMS field? The FMC confirmed by phone call amounts the PHA is allowed to retain will not be reported on the VMS 30

31 Fraud Recovery Governing Regulations 24 CFR 792 PIH Notice (HA) PIH Notice (HA) PIH Notice (HA) The above referenced Housing Notices have expired. However, they are still used as general references. 31

32 Fraud Recovery, continued Where the PHA is the principle party initiating or sustaining an action to recover amounts from tenants that are due as a result of fraud and abuse, the PHA may retain the greater of: 32

33 Fraud Recovery Retention Options Option 1: Retain 50% of the amount actually collected from a judgment, litigation or repayment agreement Total Repayment Agreement Amounts Split 50/50 HAP Revenue Administrative Revenue OR 33

34 Fraud Recovery Retention Options, continued Option 2: Retain reasonable and necessary costs that the PHA incurs related to the collection from a judgment, litigation or repayment agreement Total Repayment Agreement Amounts less Direct Administrative Expenses Related to Collecting Fraud equals Administrative Revenue portion of collected amount ( ) Remainder = HAP Revenue ( ) 34

35 Fraud Recovery Line Items Line Items to record transactions related to Fraud Recovery: FDS Line Account Description 111 Cash Unrestricted 113 Cash - Other Restricted 128 Accounts Receivable - Fraud Recovery Allowance for Doubtful Accounts Fraud Fraud Recovery Bad Debt Expense - Other 35

36 Journal Entry: Booking Fraud Recovery Accounts Receivable To record fraud revenue: Description Debit Credit (128) Accounts Receivable - Fraud Recovery $2,000 ( ) Fraud Recovery Revenue - Admin Fees $1,000 ( ) Fraud Recovery Revenue - HAP $1,000 To set up an allowance for doubtful accounts and adjust the equity accounts: Description Debit Credit (96600) Bad Debt Expense - Other $1,000 (128.1) Allowance for Doubtful Accounts - Fraud $1,000 Description Debit Credit ( ) Other Expenses (HAP Equity) $500 ( ) Other Revenue (Admin Fee Equity) $500 36

37 Journal Entry: Booking Fraud Recovery Payments & Writing Off Uncollectible Account To record receipt of payments related to fraud recovery: Description Debit Credit (111) Cash - Unrestricted (Admin Fees) $500 (113) Cash - Other Restricted (HAP) $500 (128) Accounts Receivable - Fraud Recovery $1,000 To write-off uncollectible account: Description Debit Credit (128.1) Allowance for Doubtful Accounts - Fraud $1,000 (128) Accounts Receivable - Fraud Recovery $1,000 37

38 Journal Entry: Booking Collection of Accounts Receivable Previously Written Off To record collection of accounts receivables previously written off: Description Debit Credit (128) Accounts Receivable - Fraud Recovery $1,000 (128.1) Allowance for Doubtful Accounts - Fraud $1,000 (111) Cash - Unrestricted $500 (113) Cash - Other Restricted $500 (128) Accounts Receivable - Fraud Recovery $1,000 38

39 Journal Entry: Adjusting 50/50 Split Journal entries to switch to direct expense method of recording fraud recovery after the initial repayment agreement was booked under the 50/50 split option To record receipt of payments related to fraud recovery: Description Debit Credit (111) Cash - Unrestricted (Admin Fees) $1,600 (113) Cash - Other Restricted (HAP) $400 (128) Accounts Receivable - Fraud Recovery $2,000 To adjust fraud revenue: Description Debit Credit ( ) Fraud Recovery Revenue - HAP $600 ( ) Fraud Recovery Revenue - Admin Fees $600 39

40 Fraud Recovery: Port-In Vouchers PHAs administering a port-in family who recover amounts due to fraud in the program will be entitled to keep 50% of the amount they collect or the reasonable direct costs of collection The remaining amount will be refunded to the initial PHA where it will be treated as Fraud Recovery Revenue and accrue to the initial PHA s NRA account 40

41 Portability

42 Portability Governing Regulations 24 CFR CFR (Portability Administration) PIH Notice Terminology Initial PHA and Receiving PHA Port In and Port Out 42

43 Portability Billing Process 1 2 The Receiving PHA pays the landlord. The Receiving PHA bills Initial PHA for payment to the landlord and 80% of Initial PHA's admin fee rate. 3 The Initial PHA receives a bill from Receiving PHA. The first bill to the Initial PHA will establish a request for regular payment in the future. 4 The Initial PHA reimburses the Receiving PHA for the billed amount. 5 The Receiving PHA receives payment from the Initial PHA. This process is repeated once every month. 43

44 Portability: FDS Lines Line Items used to record transactions related to Portability: FDS Line Item Account Description 111 Cash Unrestricted 113 Cash Other Restricted 121 Accounts Receivable PHA Projects 332 Accounts Payable PHA Projects Other Revenue (HAP & 80% Admin Fees Receiving PHA) Other General Expenses (80% Admin Fees Initial PHA) Housing Assistance Payments (Initial PHA s payment to Receiving PHA) HAP Portability-in (Receiving PHA s payment to landlord) 44

45 Portability Journal Entry Receiving PHA, continued Example 1: The receiving PHA pays the $575 HAP payment for the portable voucher on behalf of the initial PHA. The following accounting entry would be made to book this activity: FDS Line Item Debit Credit HAP Portability-In $ Cash-Unrestricted $575 45

46 Portability Journal Entry Receiving PHA, continued Example 2: The receiving PHA bills the initial PHA for reimbursement of 100% of the HAP ($575), plus 80% of the initial PHA s posted Column B administrative fee rate of $45. Assume HUD initially paid PHAs at 98% of their eligible fee rates. The following accounting entry would be made to book this activity: FDS Line Item Debit Credit 121 Accounts Receivable-PHA Projects $ Other Revenue $

47 Portability Journal Entry Receiving PHA, continued Example 3: The receiving PHA receives payment in the amount of $ from the initial PHA. The following accounting entry would be made to book this activity: FDS Line Item Debit Credit 111 Cash-Unrestricted $ Accounts Receivable-PHA Projects $

48 Portability Journal Entry Initial PHA Example 1: The initial PHA receives the billing from the receiving PHA in the amount of $ which represents $575 for the HAP and $44.10 for the administrative fee. The following accounting entry would be made to book this activity: FDS Line Item Debit Credit HAP-All Other $ Other General Expenses $ Accounts Payable-PHA Projects $

49 Portability Journal Entry Initial PHA, continued Example 2: The initial PHA pays the receiving PHA the billed amount of $ The following accounting entry would be made to book this activity: FDS Line Item Debit Credit 332 Accounts Payable-PHA Projects $ Cash-Unrestricted $ Cash-Other Restricted $

50 Conclusion Learning Activity HCV and HCV-related Programs Thoughts Questions? Comments? 50