HUD
Notice 2015-04 outlined a new methodology for owners/agents on completion
of a Utility Allowance. If your property
as a Utility Allowance, you will want to be sure that you understand the
requirements so that you can submit a compliant baseline submission to AHSC
during the contract renewal or rent adjustment process. It is important to note that the information included
in this publication is not all encompassing.
Refer to the notice and subsequent HUD
published FAQ’s for completion HUD guidance regarding utility allowance
baseline requirements.
Step
One: Determine the required sample
size. HUD outlines the minimum sample
size in Figure 1 of HUD notice 2015-04. This
chart shows the minimum sample size per unit type. You must include an explanation if you are
unable to meet the minimum sample size requirements (i.e. high vacancy
turnover). It is your responsibility to demonstrate
that every effort has been made to meet the requirements of the notice.
|
Number of Units
|
Minimum
Sample
|
|
1
– 20
|
All
|
|
21
– 61
|
20
|
|
62
– 71
|
21
|
|
72
– 83
|
22
|
|
84
– 99
|
23
|
|
100
– 120
|
24
|
|
121
– 149
|
25
|
|
150
– 191
|
26
|
|
192
– 259
|
27
|
|
260
– 388
|
28
|
|
389
and above
|
29
|
Step Two: Obtain your samples.
It is acceptable for you to receive and utilize multiple forms of
documentation to support the baseline analysis.
You can obtain data from the resident, the utility company, a third
party provider, or a combination of the three.
You must submit all of the backup documentation to support how the new
UA was calculated, this includes:
-
Copies of the tenant
data received from utility providers, usually in summary format
-
Copies of
printouts indicating a summary of monthly data if there tenant was able to
obtain the data online or from the utility provider
-
You can
submit a spreadsheet summarizing the average of the monthly utility bills. The actual utility bill will not need to be
submitted to the CA, but must be retained in the tenant files for the term of
tenancy plus three years and will be subject to HUD/CA review
-
A combination
of the above may be submitted
Step Three: Determine if your samples are compliant. Certain units should be excluded from your
sample:
-
Those units
receiving a UA as part of a reasonable accommodation.
-
Those units having
been vacant for 2 or more months. Units
included in the sample should have at
least ten months of occupancy.
-
Those units
receiving a flat utility rate as part of a low-income rate assistance
program. An exception to this would be
if all tenants at the property were receiving flat rate utility assistance.
Step Four: Use HUD’s sample UA worksheet or other calculation
worksheet that uses HUD’s formulas for calculating the averages. Attachment
A of HUD notice 2015-04 is HUD’s sample UA worksheet. The password to unlock this excel worksheet
is Sharkey. AHSC recommends that
owners/agents unlock the excel worksheet in order to rename the unit numbers
going vertically down the spreadsheet to match the units in your submission,
and rename the months listed horizontally to correspond with the data that you
collected.
Step Five: Submit your Baseline to AHSC. When AHSC receives a baseline Utility
Allowance, we complete a preliminary compliance check using the following
criteria:
-
The baseline
methodology utilized did not eliminate the highest and lowest averages per unit
-
There are at least
ten months of data included in the average(s).
An explanation must be provided if there is not at least ten months of
data provided
-
The required minimum
number of samples is included in the baseline submission.
-
If the required
minimum is not included in the baseline submission, the owner/agent has
provided an adequate explanation as to why the sample size is deficient
-
The data included in
the baseline analysis is not greater than 18 months from the contract
anniversary date
When reviewing your baseline submission for
compliance, if AHSC is unable to answer the questions listed above, you may be
asked to provide further clarification and/or documentation. You can work directly with your CCS if you
have any questions over what should be submitted to fulfill your baseline
requirement.
Remember, if there is a decrease to the Utility
Allowance, owners/agents must follow the requirements of 24 CFR Part 245.405(a)
and 245.410 regarding notice to tenants.
AHSC will require both a copy of the notice provided to the tenants as
well as the owner/agent certification of compliance with the tenant comment
period.