HUD Revises HUD-VASH Implementation Guidance

HUD’s Office of Public and Indian Housing (PIH) published a Federal Register notice on September 27 setting forth policies and procedures for administering the HUD-Veterans Affairs Supportive Housing (HUD-VASH) program. The notice, which replaces special rules published in the Federal Register on March 23, 2012, includes provisions addressing family eligibility, portability, case management, and the turnover of HUD-VASH vouchers. It also outlines waivers or alternative requirements that are exemptions to the regular Housing Choice Voucher (HCV) tenant-based or project-based requirements that otherwise govern HUD-VASH assistance.

The HUD-VASH program combines HCV rental assistance for veterans experiencing homelessness with case management and clinical services provided at Department of Veterans Affairs (VA) Medical Centers (VAMCs) and community-based outpatient clinics, or through a designated service provider (DSP) approved by the VA. Public housing agencies (PHAs) administer HUD-VASH vouchers.

New waivers and program flexibilities in the notice include:

  1. Allowing a PHA to act in the role of the VAMC or DSP for the purposes of family selection in cases where a PHA has been previously approved for this authority
  2. Allowing a PHA and owner to agree to amend a project-based voucher (PBV) Housing Assistance Payment (HAP) contract to re-designate a regular PBV unit as a unit specifically designated for HUD-VASH families
  3. Authorizing PHAs to apply separate voucher payment standards for HUD-VASH families without additional PIH approval
  4. Requiring PHAs to allow Special Housing Types, such as single-room occupancy (SRO) units, congregate housing, group homes, shared housing, and cooperative housing)

The notice also makes updates to existing requirements, including:

  1. Allowing PHAs to house HUD-VASH veterans referred by the VA in a project-based voucher unit without selecting from a PHA’s waiting lists or applying local preferences
  2. Providing an additional explanation regarding the process for portability moves for victims of domestic violence, dating violence, sexual assault, and stalking
  3. Adding details regarding case management requirements from the VAMC or DSP
  4. Explaining that, in the case of a family break-up, the HUD-VASH assistance must stay with the HUD-VASH veteran; however, in the case of domestic violence, dating violence, sexual assault, or stalking, if the HUD-VASH veteran is the perpetrator the victim must continue to be assisted
  5. Explaining that a Moving to Work (MTW) PHA can apply their approved MTW provisions to their HUD-VASH program if approved by PIH’s Housing Choice Voucher office
  6. Explaining how HUD-VASH waivers and flexibilities apply to HUD-VASH PBVs
  7. Explaining HUD-VASH PBV exceptions under the Housing Opportunities Through Modernization Act (HOTMA). One example is that HUD-VASH PBVs are not subject to the PBV income-mixing cap that would otherwise limit the number of PBV units in a property to the greater of 25 units or 25% of all units. In other words, all units in a property could be PBVs if they are HUD-VASH PBVs
  8. Explaining that when a HUD-VASH family is eligible to move from its PBV unit, the family must be able to move with a HUD-VASH tenant-based voucher
  9. Adding an explanation of the HUD-VASH reallocation process through voluntary moves between PHAs and voucher recapture for future reallocation

The Federal Register notice is at: https://bit.ly/3CVCNpu

More information about the HUD-VASH program is on page 4-26 of NLIHC’s 2021 Advocates’ Guide.

More information about the regular Housing Choice Voucher (HCV) program is on page 4-1 of NLIHC’s 2021 Advocates’ Guide.

More information about the regular Project-Based Voucher (PBV) program is on page 4-8 of NLIHC’s 2021 Advocates’ Guide.