HUD Discusses CARES Act Payments on July LeadingAge Call

Regulation | July 28, 2020 | by Juliana Bilowich

On July 27, key HUD staff joined the LeadingAge Housing Advisory Group call to answer member questions about the COVID-19 Supplemental Payments, or CSPs. The HUD headquarters staff on the call are overseeing distribution of the CARES Act’s COVID-19 relief funds for Section 8, Section 202, and Section 811 programs.

On July 27, key HUD staff joined the LeadingAge Housing Advisory Group call to answer member questions about the COVID-19 Supplemental Payments, or CSPs. The HUD headquarters staff on the call are overseeing distribution of the CARES Act’s COVID-19 relief funds for Section 8, Section 202, and Section 811 programs.

Following HUD’s July 23 announcement of the process for owners to request reimbursement for COVID-19 costs, HUD staff answered advance questions from LeadingAge members during the call; HUD staff also responded to additional questions from LeadingAge members in the days following the call. On August 3rd, HUD made available a document with tips for completing the request form

Application request forms for the COVID-19 Supplemental Payment (CSP) funds are due to HUD by August 5, and a recording of the call is here. More information about the Housing Notice and Request Form are available here.

In response to questions about eligible purchases and activities for CSPs, HUD staff stated that they will not be accepting payment requests for hazard pay for frontline staff. The agency will, however, honor state or local overtime requirements, as well as requests for additional payroll costs related to contracted services for deep cleaning, sanitizing, processing interim recertification, and other pandemic-related activities. LeadingAge has followed up with the agency regarding the scope of IT reimbursements for technology purchased for virtual resident engagement and remote staff; we have also asked the agency about eligible reimbursements for meals and other resident services.

In response to questions regarding the application process, HUD staff stated that they anticipate receiving 20,000 requests from across the country, and that all applications received prior to the August 5th deadline will be given equal treatment. The agency expects to process most payments by late this federal fiscal year.

In response to questions about the request form, HUD staff stated that owners submit only one request under either Tier I or Tier II. Denied requests for reimbursement of exceptional costs under Tier II will automatically be considered for the Tier I standard payment based on property size, elderly status, and service coordinator expenses. We have followed up with the agency regarding the necessary documentation that is needed for justification.

In response to questions about other funds received under the CARES Act, including Payroll Protection Program (PPP) loans, HUD staff stated that they don’t exclude an owner from receiving CSPs. However, the CSPs cannot be used for the same activities as the other funds, meaning that an owner certification of receiving other funds may trigger more follow-up and documentation requests from HUD before processing the CSP application.

In response to questions about surplus cash, HUD stated that they are making an effort to approve CSPs only for communities in financial need; if a property has additional surplus cash than anticipated, HUD would require that Section 8 owners to place an amount at least equal to the CSP in a residual receipt account. HUD clarified that this requirement does not apply to all properties requesting payments, but only to properties with unanticipated surplus cash.