In December, HUD posted two draft Requests for Proposals (RFPs) on the Federal Business Opportunities website, fedbizopps.gov, related to the oversight of the physical and financial condition of the portfolio of privately-owned properties with Section 8 project-based rental assistance (PBRA). HUD provides monthly rental assistance payments to PBRA properties on behalf of 1.2 million low- and very-low income households throughout the United States.
The notices will bifurcate the PBRA scope of work between national and regional entities. The first draft RFP for national support services includes HAP renewals, rent adjustments, and risk assessment for the entire national portfolio. The second draft RFP for regional support services largely mirrors the current PBRA scope of work. Under this posting, HUD intends to award 15 sub-regional contracts, three per each of HUD’s five regions: Region 1/Southwest, Region 2/Midwest, Region 3/Southeast, Region 4/Northeast, and Region 5/West.
Since 1999, the majority of PBRAs have been state Housing Finance Agencies (HFAs), which are publicly accountable entities with a public purpose mission to finance and preserve affordable housing. State HFAs have vast housing finance expertise, as well as local knowledge of the properties, market and stakeholders. HUD’s plan could possibly place contracts with one or more private entities and could place the oversight of public rental subsidies with an entity with little or no public purpose, based in a geographic location remote from the properties in its purview. The Department has initiated this dramatic step without any in-depth discussion with property owners, residents, community leaders, or other stakeholders. Further, we are deeply concerned that HUD would contract with just one entity to annually process over 16,000 contract renewals and rent adjustments. To have one entity oversee the entire portfolio is ill-advised. The sheer magnitude of the workload, as well as the local knowledge required for timely renewals, rent setting and other analyses, requires a focused, local approach.
NHT and the National Preservation Working Group will submit comments to HUD on these RFPs. We will urge the Department to withdraw these proposals and work with stakeholders to develop a better framework for HAP contract administration, that will ensure a commitment to long-term preservation and affordability for the entire PBRA portfolio and continued stability for low-income residents. We strongly encourage our partners to join us in voicing opposition to these proposals to HUD by January 31. Send your comments to the procurement website (fedbizopps.gov) and copy HUD officials to draw attention to this important issue. With federal rental assistance only serving 25 percent of the low-income Americans who are eligible, we cannot afford to lose a single assisted property due to insufficient oversight.
For more information, please contact NHT Federal Policy Director Ellen Lurie Hoffman.