LeadingAge Comments on RAD for PRAC Draft

Regulation | March 15, 2019 | by Colleen Bloom

LeadingAge looks forward to the future implementation of RAD for PRAC authority upon publication of the final RAD Notice Revision 4, now one step closer to reality. Our comments on the draft chapter commended HUD for its support of our key objectives – protecting current residents, preserving the unique nature of the program, and ensuring the continuation of supports and services.

LeadingAge is enthusiastic about the future implementation of RAD for PRAC authority which will allow certain Section 202 PRAC senior housing providers a way to bring private financing to preserve their communities and pursue expansion of enriched affordable living opportunities for seniors by converting their PRAC subsidy to Section 8.

In early March, HUD posted for comment a draft 37-page document titled "[RAD] Section IV: Section 202 Project Rental Assistance Contract (PRAC) Projects." Because of the tight 10 day turn-around, LeadingAge was among numerous stakeholder groups rapidly seeking member feedback, connecting with coalition groups to discuss and ultimately providing LeadingAge-specific comments on the proposed chapter.

LeadingAge member feedback, provided during a call with the Housing Advisory Group, was instrumental in crafting the final comment letter submitted March 12.  In the letter, LeadingAge commended HUD on many excellent components in the draft, thanking the HUD Office of Recapitalization team for openness in the process of collecting stakeholder comments and suggestions, and the careful attention given to so many recommendations provided prior to creating this guidance. 

We particularly commended HUD for incorporating safeguards for the future sustainability of converting PRAC properties, ensuring continuation of the unique nature of the original program by retaining not-for-profit control, requiring details plans and formal commitments - even offering expanded funding – to sustain delivery of appropriate supports and services (including service coordination) for low-income older adult residents. 

LeadingAge also used this an opportunity to restate our commitment to addressing the long-term sustainability of all Section 202 PRAC properties and articulated specific hopes that HUD will support preservation of the non-RAD converting PRAC portfolio through enhanced guidance and standards related to PRAC contract renewals and rent adjustments (to include regular evaluation of the sufficiency of existing or future deposits to the reserve for replacement account and provision of services and service coordination) and potential future administration funding requests for emergency capital repair grants.