HUD PIH Posts Work Requirement and Landlord Incentive Cohort MTW Notices

HUD’s Office of Public and Indian Housing (PIH) posted notices soliciting public housing agencies (PHAs) to apply for two Moving to Work (MTW) Demonstration cohorts. Notice PIH 2021-02 pertains to Cohort #3 (work requirements), and Notice PIH 2021-03 pertains to Cohort #4 (landlord incentives). PHAs that would like to be considered for either cohort must submit an MTW Plan and application package by August 8, 2021.

PIH had previously issued notices soliciting PHAs to apply to participate in Cohort #1 (see Memo, 10/22/18) and Cohort #2 (see Memo, 3/18/19). PIH announced on January 14, 2021 it has selected 30 small PHAs for Cohort #1 (MTW flexibilities) and indicated that it anticipated announcing PHAs for Cohort #2 (rent reform) in the spring. The list of the 30 small PHAs selected to participate in Cohort #1 does not reveal specific MTW flexibilities those PHAs will use; the brief descriptions merely present platitudes and generalities.

Notice PIH 2021-02: Cohort #3 – Work Requirements

This notice outlines the process by which 10 PHAs will be selected for the third cohort of the MTW Demonstration Expansion, which will test the impact of implementing a work-requirement policy on a PHA and the residents it serves, in particular whether work requirements will increase resident self-sufficiency. PHAs may choose to implement a work-requirement policy in the public housing program, the HCV program, or both programs.

Applicant PHAs will fully develop a work-requirement policy as detailed in the MTW Operations Notice (see Memo, 8/31/20) and vet that policy through a required resident engagement and public comment and review process. HUD will conduct a lottery of applicant PHAs to select 10 PHAs to be awarded MTW designation under Cohort #3.

The evaluation of the third cohort of the MTW Expansion will be conducted by an independent research team that will assess whether households subject to a work requirement earn more income than assisted households not subject to a work requirement. In addition to measuring changes in earned income and other key outcomes for households, the evaluation will document how PHAs design and implement a work-requirement policy.

NLIHC has prepared a summary of key provisions of the work requirement Notice.

Notice PIH 2021-03: Cohort #4 – Landlord Incentives

This notice lays out the process by which 30 PHAs will be selected for the fourth cohort of the MTW Demonstration Expansion, which will evaluate landlord incentives and their effect on landlord participation in the HCV program. PIH identified seven MTW activities in the MTW Operations Notice (see Memo, 8/31/20) that have the potential to act as landlord incentives. In addition, two Cohort Specific MTW Waivers are available for PHAs. Together, the MTW Operations Notice and Cohort Specific MTW Waivers are referred to as the “Cohort #4 MTW Activities List.” PHAs in the fourth cohort must implement at least two activities from the Cohort #4 MTW Activities List and vet those proposed waivers through a required resident engagement and public comment and review process.

PHAs seeking MTW designation in the fourth cohort must submit an MTW Plan and application package to HUD by August 8, 2021. HUD will conduct a lottery of applications, and those selected will be offered MTW designation under the fourth cohort. Evaluation of the fourth cohort will be conducted by an independent research team that will compare outcomes for the PHAs that were selected and the PHAs that were not selected through the lottery.

NLIHC has prepared a summary of key provisions of the landlord incentives Notice.

Brief Background on MTW Expansion

The “Consolidated Appropriations Act of 2016” authorized HUD to expand the MTW demonstration to an additional 100 high performing PHAs over a seven-year period to end in 2022. PHAs will be added to the MTW demonstration in groups (cohorts), each of which will be overseen by a research advisory committee to ensure the demonstrations are evaluated with rigorous research protocols, quantitative analysis, and comparisons to control groups. Each cohort of MTW sites will be directed by HUD to test one specific policy change.

The MTW statutory objectives are to reduce costs, give households incentives to achieve economic self-sufficiency, and increase housing choice. The statute requires MTW agencies to: 1) serve the same number of low-income families as they would without MTW funding flexibility; 2) serve a mix of families by size comparable to the mix they would have served if they were not in MTW; 3) ensure that 75% of the families they assist have income at or below 50% of area median income; 4) ensure that assisted units meet housing quality standards; and 5) establish a reasonable rent policy.

The effort now includes five cohorts:

  • Cohort 1 will evaluate the overall impact of MTW flexibilities on PHAs with fewer than 1,000 units.
  • Cohort 2 will evaluate the impacts of different rent structures.
  • Cohort 3 will evaluate the impacts of work requirements.
  • Cohort 4 will evaluate incentives to landlords to participate in the Housing Choice Voucher (HCV) program.
  • Cohort 5 will evaluate the overall impact of MTW flexibility on PHAs with fewer than 27,000 units.

PIH posted the final Operations Notice for the Expansion of the Moving to Work (MTW) Demonstration Program in the Federal Register on August 28 (see Memo, 8/31/20). This version of the notice establishes requirements for implementing the MTW demonstration for PHAs applying for one of 100 new MTW slots. The original Operations Notice was published on January 23, 2017 (see Memo, 1/23/17, 5/8/17). The final notice was effective immediately.

PIH issued notices soliciting PHAs to apply to participate in Cohort #1 (see Memo, 10/22/18) and Cohort #2 (see Memo, 3/18/19). PIH announced on January 14, 2021 that it has selected 30 small PHAs for Cohort #1 (MTW flexibilities) and that it anticipates announcing PHAs to undertake Cohort #2 (rent reform) in the spring. The list of the 30 small PHAs selected to participate in Cohort #1 does not reveal specific MTW flexibilities those PHAs will use.

The list of the 30 small PHAs to participate in Cohort #1 is at: https://bit.ly/2Kxrb6K 

Notice PIH 2021-02 (Cohort #3) is at: https://bit.ly/2KgEVm4

NLIHC’s Summary of PIH 2021-02 (Cohort #3) is at: https://bit.ly/3sM95zg

Notice PIH 2021-03 (Cohort #4) is at: https://bit.ly/38MiS09

NLIHC’s Summary of PIH 2021-03 (Cohort #4) is at: https://bit.ly/35YJR6Q

The Federal Register version of the Operations Notice is at: https://bit.ly/2ECV569

An easy-to-read version of the Operations Notice is at: https://bit.ly/3hCrqZf

The main MTW website is at: https://www.hud.gov/mtw

MTW Expansion webpage is at: https://bit.ly/39PEXdF

More about MTW is on page 4-57 of NLIHC’s 2020 Advocates’ Guide.

More information about public housing is on page 4-30 of NLIHC’s 2020 Advocates’ Guide.

More information about Housing Choice Vouchers is on page 4-1 of NLIHC’s 2020 Advocates’ Guide.

More information about the Annual PHA Plan is on page 7-61 of NLIHC’s 2020 Advocates’ Guide.