2577-0083 Family Report, MTW Family Report and MTW Expansion Family Report Supporting Statement 5-30-23

2577-0083 Family Report, MTW Family Report and MTW Expansion Family Report Supporting Statement 5-30-23.docx

Family Report, MTW Family Report, MTW Expansion Family Report

OMB: 2577-0083

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Department of Housing and Urban Development (HUD)

Supporting Statement for Paperwork Reduction Act Submissions

Family Report, MTW Family Report and MTW Expansion Family Report

2577-0083



A. Justification


1. Why is this information necessary? Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating/authorizing the collection of information.

This Paperwork Reduction Act submission describes the addition to this collection, the Form HUD-50058.


The Office of Public and Indian Housing of the Department of Housing and Urban Development (HUD) provides funding to Public Housing Agencies (PHAs) to administer assisted housing programs. The Form HUD-50058, Form HUD-50058 MTW Family Report, and Form HUD-50058 MTW Expansion Family Report solicit demographic, family profile, income, and housing information on the entire nationwide population of tenants residing in assisted housing. This information allows HUD to monitor and evaluate its programs as required under the following:


  • The United States Housing Act of 1937 (42 U.S.C 1437 et seq.)

  • Housing and Community Development Act of 1987 (42 U.S.C. 3543(a) – authorizes PHAs to collect social security data)

  • Title VI of the Civil Rights Act of 1964 (42 U. S. C. 2000d);

  • The Fair Housing Act (42 U. S. C. 3601-19)

  • Quality Housing and Work Responsibility Act of 1998 (Public Law 105-276 Title V)

  • Economic Growth, Regulatory Relief, and Consumer Protection Act (Public Law 115-174, Title III)

  • Housing Opportunity Through Modernization Act of 2016 (Public Law 114-201, 130 Stat. 782)

  • HUD Appropriations Act of 1996 (Public Law 104-134 Section 204)

  • Electronic Transmission of Required Family Data for Public Housing, Indian Housing, and the Section 8 Rental Certificate, Rental Voucher, and Moderate Rehabilitation Programs” (24 CFR Part 908)

  • 24 CFR Part 5 (5.210 through 5.240)


The HUD-50058, HUD-50058 MTW, and HUD-50058 MTW Expansion provide information about program participants at the time of an action that can affect program participation and rental subsidy calculation. Actions include admittance to the program, annual reexamination of income, change of unit, and end of program participation.


For all household members, the HUD-50058, HUD-50058 MTW, and HUD-50058 MTW Expansion collects name, address, social security number, ethnicity, race, citizenship, gender, assets, income, and expected income. Additional data is collected on employment status, assistance received under other federal assistance programs (TANF, Medicaid, etc.). For programmatic headsheads of household, benefits such as health insurance provided by employers are reported for households participating in the Family Self-Sufficiency (FSS) and/or MTW Self-Sufficiency program. Finally, the form also shows the Total Tenant Payment each household contributes towards rent, and other information about rental subsidy calculations.



This version of the forms contains updates required via the Housing Opportunity Through Modernization Act of 2016 (HOTMA) and the Economic Growth, Regulatory Relief, and Consumer Protection Act (Economic Growth Act). These changes include the addition of data fields for hardship exemptions, permissible deductions, and reporting of over-income families. Updates will also be made to thresholds for deductions, income, assets and expenses to comport with HOTMA. Economic Growth Act changes will be made for the FSS response


2. How is the information collected and how is the information to be used?


This information is collected from participants in the Office of Public and Indian Housing’s public housing and housing choice voucher (HCV programs). It is collected from program participants by Public Housing Agencies (PHAs), who in turn submit the data to HUD using form HUD-50058, HUD-50058 MTW, and HUD-50058 MTW Expansion. PHAs are typically chartered independent entities established by the state legislature to administer affordable housing programs in a jurisdiction. Some are units of local government.


The information is collected from tenants any time there is a change in circumstances or an event that can affect the calculation of rental subsidy to a participating household. This includes annual re-examinations of households to determine if there have been any changes that can affect participation in the program or rental subsidy calculation. This information is collected from residents in a variety of formats. PHAs typically hold face-to-face interviews with adult household members to discuss any changes of circumstances. This information is then used by PHA staff to fill out the Form HUD-50058, HUD-50058 MTW, or HUD-50058 MTW Expansion. Some PHAs allow program participants to provide the information to PHA staff via telephone or written communication; however, this is a matter of PHA policy.


PHAs are required to submit any revised HUD-50058s, HUD-50058 MTWs, HUD-50058 MTW Expansion forms to HUD monthly, and to provide at least one HUD-50058, HUD-50058 MTW, or HUD-50058 MTW Expansion for each household annually.


This information is utilized for the following purposes:


  • Analyze assisted housing programs;

  • Determine the occupancy level of public housing and calculate the operating subsidy in accordance with 24 CFR 990;

  • Permit PHAs to monitor their own reporting to identify favorable and unfavorable trends;

  • Monitor PHAs and participants for compliance with program regulations and requirements;

  • Fraud detection and prevention via rent/income monitoring;

  • Housing inventory and development of program initiatives with emphasis on the housing of special needs groups; and

  • Make available accurate demographic information depicting tenant characteristics to Congress and other interested parties (however this data is typically scrubbed of any personally identifiable information).


Occasionally, this data is used for research purposes, such as modeling the effect of proposed rent reforms. Research may be conducted by research firms under contract to HUD. However, this data is always scrubbed of personally identifiable information such as social security numbers and names before it is used for this purpose, and all procedures for handling of confidential information, such as restricted access by contractors and secure facilities, are followed.


3. Describe whether, and to what extent, the collection of information is automated (item 13b1 of OMB form 83-i). If it’s not automated, explain why not. Also describe any other efforts to reduce burden.


Several vendors offer Housing Agency management software, including creation/submission of 50058s.

HUD offers a free software program called Family Reporting Software (FRS) to all PHAs. Data collected via Form HUD-50058, Form HUD-50058 MTW, and Form HUD-50058 MTW Expansion Family reports is electronically submitted by the PHAs into the Inventory Management System/PIH Information Center (IMS/PIC) on a monthly basis. IMS/PIC is an automated database system which exchanges this data between Housing Authorities and Local HUD Offices. This data repository is also accessible to HUD Headquarters and field offices.


In 2023, HUD projects the Housing Information Portal (HIP) system will replace IMS/PIC to store data from the Family Report, MTW Family Report and MTW Expansion Family Report. The HIP system will connect to external partner systems, which includes Public Housing Agency (PHA) software systems, in order to transmit data between the two systems. An Interconnection Security Agreement (ISA)/Memorandum of Understanding (MOU) will be required for these system connections, with the purpose of establishing a management agreement regarding the development, management, operation, and security of the connection between the HIP system and the connecting system.


The MOU/ISA for the system connection will have no significant impact on the information collection burden.


4. Is this information collected elsewhere? If so, why cannot any similar information already available be used or modified.


Tenant Characteristics directly impact the amount of subsidy for which a household is eligible under HUD’s programs. HUD’s eligibility requirements are distinct from any other federal program requirements, such as TANF, WIC, or SNAP. Different programs use distinct household composition data to determine program eligibility. Therefore, while program participants may be reporting some of this information to other federal agencies, they are not reporting all this data and it cannot be obtained through any other agency. Further, HUD requires a participant’s social security number to verify tenant income, which affects rental subsidy calculation. This is necessary to ensure that the maximum number of families can be served in the public housing and housing choice voucher programs.


5. Does the collection of information impact small businesses or other small entities (item 5 of OMB form 83-i)? Describe any methods used to minimize burden.


This information collection has no impact on small businesses or other small entities.


6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.


Failure to collect this data at least annually would impede HUD’s ability to provide accurate subsidy to PHAs, to create effective program polices, to measure the impact of these program policies and funding, and to provide accurate information to OMB, Congress and the public.


  1. Explain any special circumstances that would cause an information to be collected in a manner:

  • requiring respondents to report information to the agency more than quarterly;

Although public housing agencies are only required to submit data annually for each participating household, families move into and out of subsidized units throughout the year. Therefore, the agencies complete Form HUD-50058, Form HUD-50058 MTW, and Form HUD-50058 MTW Expansion Family Reports for individual families at different times during the year. HUD requires all agencies to electronically submit the forms that they have completed to HUD at least monthly. The Department received OMB approval on September 6, 2006, to require PHAs with less than 100 units to submit Form HUD-50058, Form HUD-50058 MTW, and Form HUD-50058 MTW Expansion Family Reports data monthly as opposed to quarterly.


  • requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

Not Applicable


  • requiring respondents to submit more than an original and two copies of any document;

Not Applicable


  • requiring respondents to retain records other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

Not Applicable


  • in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of the study;

Not Applicable


  • requiring the use of statistical data classification that has not been reviewed and approved by OMB;

Not Applicable


  • that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

Not Applicable


  • requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.

Not Applicable


8. Identify the date and page number of the Federal Register notice (and provide a copy) soliciting comments on the information. Summarize public comments and describe actions taken by the agency in response to these comments. Describe all efforts to consult with persons outside the agency to obtain them.


For the Form HUD-50058, Form HUD-50058 MTW, and Form HUD-50058 MTW Expansion, HUD published a Notice of Proposed Information Collection for Public Comments in the Federal Register, 88 FR 8301, dated February 8, 2023. The public was given until April 10, 2023 to submit comments on the proposed information collection. HUD received 19 comments on this proposed collection. Comments for which HUD asked specific questions or made changes in response to are addressed in HUD’s 30-day Notice of Proposed Information Collection for Public Comments in the Federal Register. All other comments are discussed here:

Accessible Unit

Comments: Commenters asked for clarification on the type of accessible unit information that will be collected, how HUD will use the data, and whether the data will be consistently reported by PHAs. One commenter asked for more information to be collected. Another commenter asked HUD to further define what it means by accessible unit.

HUD response: HUD proposes to make minor revisions to Section 5, and only Public Housing and Project-Based Vouchers will be affected. The question whether the PHA identified the unit as an accessible unit was formerly asked only for Public Housing submissions. That question will now be asked for Project-Based Vouchers submissions only. A follow-up question will ask respondents to classify the unit into one of three categories—Hearing/Visual Impairment, Mobility Impairment, or Partially Accessible. These terms will match the definitions outlined in Notice PIH 2022-03, which are currently in use for Public Housing Units.

The question whether the family requested accessibility features will now be asked of Public Housing and Project-Based Voucher submissions. If the family did request accessibility features, PHAs will be asked to answer a follow-up question that classifies the type of unit that would satisfy that request, in terms of the three categories described above—Hearing/Visual Impairment, Mobility Impairment, or Partially Accessible.

The accessible-unit questions will not be asked for tenant-based vouchers.

Additional Payments

Comments: One commenter asked why HUD is collecting additional payment types.

HUD response: The proposed questions would ask the PHA to report total financial assistance provided by the PHA to a household when the household is leasing a new Tenant-Based Vouchertenant-based voucher (TBV) ) unit, and the total financial assistance provided by the PHA to the landlord when a household is leasing a new TBV unit. The intent is to better understand the scope and frequency of such additional incentives.

Allowances and Expenses

Comments: One commenter suggested a change to the name “Deductions and Allowances” to “Adjusted Income.”

HUD response: HUD proposes to maintain the proposal in the 60-day notice to change to “Deductions and Allowances.” This name change follows an identical proposal already made on the HUD-50058 MTW Expansion form. HUD believes that this term accurately reflects the content of the section and clearly delineates it from the preceding section.

Codes

Comments: One commenter supported additional End of Participation codes but suggested HUD be mindful on how many codes are listed. Another commenter asked HUD to clarify what code PHAs use for “Non-Public Housing Over-Income (NPHOI)” status. Commenters asked HUD about the addition of the action code for “Household Composition Change Only” and “Other Change” and the action type for “Project-Based Voucher (PBV) to TBV Transfer.” Another commenter suggested HUD add action types for “HCV Non-EOP/Transfer Tenant Move Out” and for “Project Based Voucher Vacancy Payment Request.”

HUD response: HUD agrees that the list of response options for a question concerning “End of Participation reasons” or “Interim Reexamination reasons” needs to be concise to be manageable. The intent of such questions is to better understand positive and negative exits from HUD programs and the contexts for interim reexaminations.

As for the question about NPHOI families, those individuals are no longer program participants and will be on a separate, non-public housing lease. As such, PHAs will not file 50058 submissions for such families once they become NPHOI. When a family that is a public housing participant exceeds the 24 consecutive month grace period and assistance must be ended, the PHA will file an End of Participation to note the family has left the Public Housing program. If the family stays in the unit as an NPHOI family, the PHA will need to change the unit tenant status in HIP to note it is occupied by an NPHOI family. At this time, PHAs will categorize units occupied by NPHOI families as ‘Non-Assisted Tenant Over Income’ in IMS/PIC. However, a new sub-category will be created in HIP. When this system is ready, PHAs will categorize units occupied by NPHOI families as “NPHOI Tenant.”

As for the addition of a different code for household composition changes, HOTMA requires that interim reexaminations be conducted in specific, delimited circumstances. For example, an interim reexamination may not be conducted when a family’s adjusted income has increased by less than 10 percent, barring some other qualifications. A PHA may need to record other changes in circumstances where an interim reexamination may not be performed, such as changes to household composition. In order to clearly distinguish interim reexaminations from other transactions that do not constitute an interim reexamination, these action types are being added as alternatives to transactions that would have often been filed using the Interim Reexamination action type. The Interim Reexamination action type will be reserved for interim reexaminations.

As for the PBV action type, the “PBV Transfer to TBV” action type is being added to better track the number of families with project-based voucher assistance who exercise their right to a tenant-based voucher. HUD does not want to require EOPs for families who are transferring between vouchers and who remain voucher program participants.

As for the addition of “HCV Non-EOP/Transfer Tenant Move Out,” HUD does not propose to add a code and advises that a PHA file an “Other Change, Non-Income Threshold” and enter the date the family vacated the unit in Section 2. This will minimize the need for new action types.

Date Vacate HCV

Comments: One commenter requested HUD remove the date a participant vacated an HCV unit because it is captured elsewhere and would increase administrative burden.

HUD response: The information in “Date participant vacated unit” is not collected elsewhere for HCV, and this information is needed to ensure accurate information about occupancy in eVMS.

Dates

Comments: One commenter recommended in Section 5 with question 5q to add a line 3 on requested lease state date and line 8 on date unit available for inspection of the Request for Tenancy Approval.

HUD response: In the aim of minimizing the increase in the administrative burden of the form, HUD will not be making this change.

Definitions

Comments: Commenters asked HUD to provide more detailed definitions for PHAs to review, especially for new terminology like “supportive service program” or “institutional setting.”

HUD response: HUD agrees that the full publication of the proposed form will make review easier and welcomes additional comments. Definitions of these terms are provided in a supplemental document enclosed with the publication of the proposed form. Additional details will be provided in a forthcoming update to the full 50058 Instruction Booklet.

End of Participation

Comments: Commenters asked for clarification on the purpose of the end of participation codes. Commenters also asked HUD to explain when a family who is over income would end participation or graduate, and what the PHA should report. One commenter also suggested HUD provide additional codes for tracking other categories and guidance on how to code different PHAs’ existing end of participation lists with these new codes so as to ensure data integrity.

HUD response: HUD proposed additional codes for end of participation to better understand the nature of exits from HUD programs. As for the comments requesting more codes, any list of response options will need to balance the aims of providing an exhaustive list of reasons with providing a manageable form. In some instances (e.g., over-income public housing families), other fields on the form will contribute to that picture. HUD believes the current list of reasons will clarify the reasons for end of participation without presenting an excessive burden, but future amendments to the list of reasons may be considered.

As for when a family is over-income, a family in public housing who exceeds the 24 consecutive month grace period must exit the public housing program and will require an end of participation filing. Please see PIH-2023-03 guidance on Section 103 of HOTMA for PHA options regarding NPHOI families. When NPHOI families stay in a unit after the end of participation is filed, the PHA will need to adjust the unit tenant status in the Building and Unit module of HIP to indicate that the unit will remain occupied. More information on end of participation reasons will be provided in the Instruction Booklet, as will further guidance on how to choose a response.

Historical

Comments: Commenters requested that HUD not remove the historical adjustment because it allowed them to make corrections. Commenters also asked whether HUD would provide an alternative code and the reasons behind such change.

HUD response: The Historical Adjustment action code was used in the transition from Multifamily Tenant Characteristic System (MTCS) to IMS/PIC, because there were many records that were not migrated, for various reasons, to IMS/PIC. Historical Adjustment allowed PHAs to submit a baseline record so subsequent HUD-50058 information could be submitted. HIP will allow PHAs to make corrections to most forms, not just to the most recently submitted form. Additional information on corrections is provided in the Technical Reference Guide (TRG) and will be provided in other documentation made available to PHAs. To protect the data integrity of submissions, HUD plans to maintain the removal of this action code.

Homelessness

Comments: Commenters requested HUD clarify the “homeless at admission” and “Family is formerly homeless” fields and how PHAs should report this information. One commenter suggested that HUD revise the existing “homeless at admission” definition rather than add a new definition so that the responses were more accurate and consistent and less burdensome.

HUD response: HUD is proposing two homelessness status questions in order to be able to collect more information without conflating these statuses. The new question on homelessness would identify when families had experienced homelessness at some point earlier than immediately prior to admission. HUD will provide definitions and guidance on when to select these codes in the Instruction Booklet.

Interim Reexaminations

Comments: Commenters support the list of interim reexaminations but asked for guidance on selecting from the list, requested the option to select more than one, and how to handle unlisted reasons like utility adjustments.

HUD response: HUD intends to provide guidance on selecting among response options in the Instruction Booklet. Support for combining mandatory fields on the 50058 with additional data that PHAs track may vary with the use of third-party vendor software. The intention for the interim reexaminations reason question will be to allow PHAs to select all applicable reasons. While HUD recognizes that many reasons will not appear on the list, other changes will be performed using the new action code “Other Change, Non-Income Threshold.”

HOTMA

Comments: One commenter suggested that HUD not go forward with including a code for when families will not receive an interim income reexam due to a HOTMA threshold because it would increase administrative burden for some PHAs. Commenters were unclear how the HOTMA hardship questions would impact MTW agencies, especially given the three-year grace period for implementation. One commenter asked why HUD is adding the over-income questions at all to the 50058 and thought it should be verified in audits rather than by the form.

Commenters also noted that HUD would need to provide both software updates and training for PHAs and staff on changes to Section 6 because of HOTMA. Another commenter asked HUD for guidance on producing the $50,000 threshold number, and when to start the 24-month grace period.

HUD response: If the commenter is asking whether PHAs will be asked to submit a transaction in any situation where a family will not receive an interim reexamination (e.g., they report an income change that does not qualify for an interim reexamination), the answer is no—there will be no additional burden to report that the PHA received information but did not conduct an interim reexamination. What is being added instead are action codes that will allow PHAs to file transactions noting changes that need to be noted, in situations where HOTMA does not permit a full interim reexamination. For instance, if household composition changes but there is only a 5 percent increase in unearned income, the PHA will not conduct an interim reexamination. The new action code will allow them to note the new household member. Please see the copies of the proposed forms in this 30-day publication. The question about hardship eligibility has not been added to the Form HUD-50058-MTW. It has been added to the Form HUD-50058 MTW Expansion, in Section 8.

HUD is adding public housing over-income questions to the form to prompt PHAs to check over-income status when calculating a family’s income. (Because the over-income limit will be compared to a family’s annual income, not their adjusted income, the questions are being moved to the end of Section 7.) These answers will fulfill PHAs’ requirement to report the number of over-income families residing in public housing, as described in Notice PIH 2023-03. HUD agrees that software updates and trainings will be necessary, and HUD will work to ensure as smooth a transition as possible. . Regardless of the over-income questions, software data will already need to be updated on a regular basis, as several deductions will now be annually adjusted for inflation. Additional guidance on the implementation of Sections 102 and 104 of HOTMA is forthcoming. Please see Notice PIH-2023-03 for supplemental guidance on Section 103 of HOTMA.

Income-based ceiling rent

Comments: Some commenters opposed removing the “income-based ceiling rent” question because some PHAs have legacied in the ceiling rent and it still applies, and it is used to address tax credit maximum rents. One commenter requested in addition that HUD add a field to capture LIHTC maximum rents.

HUD response: Since 2017, HUD has advised PHAs not to use line 10c: “In accordance with 42 U.S.C. 1437a(a)(2)(A)(ii), PHAs that established and were administering ceiling rents prior to October 1, 1999, are authorized to continue to administer ceiling rents in lieu of flat rents, provided such ceiling rents are set at the level required for flat rents as required by 24 CFR 960.253(d). Further, such PHAs must follow the requirements for calculating, adjusting, and reporting flat rents when calculating and adjusting ceiling rents. To improve transparency and accuracy of reporting, PHAs administering ceiling rents may no longer use line 10c (income-based ceiling rent) on the HUD Form-50058 to report ceiling rents for any household. Instead, PHAs must use line 10b (flat rent) to report the applicable maximum rental amount.” The revisions to line 10d were proposed with these properties in mind. When authorized to administer ceiling rents, PHAs must set ceiling rents at the level required for flat rents and put them on line 10b. Line 10d will allow PHAs in this situation to make the appropriate comparison. HUD is not adding a field to capture LIHTC maximum rents. Notice PIH 2022-23 indicates that when the flat rent amount exceeds the LIHTC maximum rent, PHAs should set flat rents so as not to exceed the LIHTC maximum rent. In the situation the commenter describes, the PHA should enter the amount of the LIHTC maximum rent as the applicable maximum rental amount on line 10b, and then make the appropriate comparison on line 10d.

Inspection

Comments: Commenters requested HUD clarify the intended use of the last inspection passed or the alternative inspection questions, and noted the additional burden associated with the collection.

HUD response: The questions on lines 5h and 5i have been altered so that they are no longer specific to HQS inspections, in virtue of the availability of alternative inspections. HUD believes that these questions, including asking whether the last passed inspection was an alternative inspection, will provide greater insight into inspection patterns.

Institutional Setting

Comments: Commenters requested more information and a definition for “institutional setting.” One commenter noted such a setting should not include incarceration, behavioral health, substance abuse or medical setting. The commenter also noted concerns about stigma, judgment, and violation of privacy for participants.

HUD response: The current intention is to use the definition of “institutional setting” in use for Mainstream vouchers. Institutional or other segregated settings include, but are not limited to: Congregate settings populated exclusively or primarily with individuals with disabilities; Congregate settings characterized by regimentation in daily activities, lack of privacy or autonomy, policies limiting visitors, or limits on individuals’ ability to engage freely in community activities and to manage their own activities of daily living; or Settings that provide for daytime activities primarily with other individuals with disabilities. HUD intends to provide additional guidance in the Instruction Booklet.

Mobility Related Services

Comments: Commenters both supported and opposed the addition of mobility-related service questions and payment standards for a reasonable accommodation. Comments requested HUD provide additional guidance and definitions, and asked how HUD will ensure accuracy in data. Some commenters noted that collecting the data would be difficult because it could come from third parties unaffiliated with an agency and would be administratively burdensome. One commenter asked HUD to explain the reasons behind asking for the data and how HUD plans to use the data.

HUD response: “Mobility-related services” is defined broadly, to include services provided by or funded by the PHA that are intended to help access lower-poverty, opportunity neighborhoods. Navigation services could be an example of mobility-related services. If the PHA neither provides nor funds the services, they should answer “No” to this question. The intention is to better understand the services that PHAs are helping to provide.

The purpose of collecting security deposit information is to better understand how many PHAs are providing this kind of assistance and how much is provided. As will be clarified in the Instruction Booklet, PHAs will only be asked to report when the PHA itself pays a security deposit on behalf of the family. They will not be required to track and report when third parties provide such assistance.

MTW

Comments: Commenters raised concerns about HUD’s creating a universal 50058 and its impact on MTW agencies. Commenters also noted that some changes were unclear on how they apply to the MTW forms and could add additional administrative burden to MTWs.

HUD response: There is no intention to create a universal 50058. HUD hopes that the proposed changes to all three forms will be clearer with the publication of this 30-day notice. The current proposal is to add a field in Section 21 of the Form HUD-50058-MTW for “HAP contract ID number,” for Project-Based Vouchers only. HUD is aiming to make the “End of Participation reason” questions on the Form HUD-50058, Form HUD-50058 MTW, and Form HUD-50058 MTW-Expansion as parallel as possible, including making the response options overlap where possible. HUD is removing the “Over-Income Rent" at 10u on the Form-50058 MTW Expansion. HUD is also deleting the “Date Correction Transmitted,” “Repayment Agreement,” and “Monthly Amount of Repayment” from the MTW 50058. For the HUD-50058-MTW, the “Local, Non-Traditional Assistance” program code has been removed. “Local, Non-Traditional Assistance” remains an option on the HUD-50058 MTW Expansion.

PIC/HIP

Comments: One commenter requested HUD provide more information on how PHAs will update errors in the system of record. Commenters asked about updates to HIP to accept new values, how fields in PIC will transition to HIP, and updates to the technical reference guide. One commenter suggested HUD delay changes until HIP is rolled out and tested. Another commenter noted that HIP is not available to MTW agencies and asked how linking software to HIP would work.

HUD response: The 50058 form will not be updated in PIC and no further PIC updates are planned. HUD agrees that additional information will be required to avoid encountering errors when submitting forms to HIP, and technical requirements will be specified in the Technical Reference Guide. Further guidance will be supplied as needed in the Instruction Booklet. As for the question on the new inflation-adjusted values, a function has been added to HIP to allow for different allowance values based on effective date. The validations that confirm allowances will be updated, including inflation-adjusted value on the effective date of the submission. HUD acknowledges that the transition to HIP will require significant effort and is working to ensure as smooth a transition as possible.

Proposed Change

Comments: Commenters suggested additional information about a participants entry into housing assistance programs, a participant’s exit from housing assistance, and accommodations for participants. One commenter suggested HUD replacing the 4b zip code with prior address. Another commenter requested HUD accommodate RAD regulatory requirements and zero-HAP families that convert from Public Housing to PBV

HUD response: HUD appreciates this feedback and will consider more changes in the future. For this current revision, HUD believes that the current changes are necessary for implementing HOTMA while not adding additional burden to PHAs during this transition. HUD will address RAD in future guidance or the 50058 Instruction Booklet.

Waiting Lists

Comments: Commenters asked HUD for a definition, guidance, and examples on admissions from a special, non-waiting list. One commenter requested guidance on the date the family was selected from the waitlist should be done and raised the potential for data error.

HUD response: Special admissions may occur when HUD allocates funding for families residing in specific housing. In these cases, the funding is intended for families in specifically identified circumstances without regard to waiting list status; the families are not required to be on the PHA waiting list at all. For example, PHAs may receive allocations of housing choice voucher funding to be used for families who will be displaced as a result of public housing demolition, disposition, or vacancy consolidation actions. The housing choice vouchers must be issued to these families to find alternative housing before the displacement is required. HUD will provide additional details in the 50058 Instruction Booklet and response requirements relevant to HIP errors will be provided in the Technical Reference Guide. If PHAs have specific concerns about situations in which this information would be unavailable, HUD would welcome additional feedback.

Real Estate ID

Comments: One commenter requested clarification on whether the Real Estate ID should be used by MTWs and for TBVs that have been project based. In addition, commenters asked for clarity about how to use the entry, and where to get the real estate ID number.

HUD response: The Unit Real Estate ID number (or RID) is a unique identifier that will be generated for units by the HIP system. This will apply only to Public Housing units at present. HUD may shift from conventional composite keys to RIDs in the future.

Supportive Services

Comments: Commenters requested HUD provide a definition of “Supportive Services” and “Supportive Service Program Participation.” Commenters also requested clarification around what exiting the FSS program means, and one commenter suggested it should not be limited to success at homeownership. Commenters requested clarification about when to report services, what counts as PHA delivered services such as external providers, and the definition for successfully receiving the services. Other commenters noted that the additional request could be burdensome and requested clarification around the purpose of collecting this additional information.

HUD response: At this time, the Supportive Services Section of the 50058 will be reserved for the HUD programs specified in field 17a—Family Self-Sufficiency (FSS), Resident Opportunity and Supportive Services (ROSS), and Jobs Plus. HUD intends to add collection of data on participation in ROSS and Jobs Plus and services provided (by the PHA or partners) in order to consolidate the collection of data on such programs and align the data collected on these programs with the data collected on FSS. PHAs will not be required or permitted to enter responses for programs other than those specified in field 17a of the Supportive Services Programs section. The question in Section 2, which formerly asked only about FSS participation, will ask whether the family participated in any of these three programs.

The definition of exiting the FSS program has not changed – it is not, nor has it been, limited to tracking homeownership. HUD proposes to add additional options to the question on reasons for exit to conform to changes in the re-authorized FSS statute.

HUD does not believe these changes will add additional burden and believes it will reduce burden while still maintaining the necessary information for HUD to determine what resources are being provided to tenants. HUDsuggests that those with questions review the proposed forms to see the suggested changes in context.

Timing

Comments: Commenters raised concerns about the time needed for revisions and the inability to see sample form instructions or technical reference guide to outline changes to the forms. Commenters also requested a red-line of the forms to see the changes and guidance on how to catch up existing households in PHA’s inventory. Commenters especially noted timing concerns about the need to make system changes and requested HUD collaborate with industry to ensure a smooth rollout. One commenter noted that they would need a minimum of 120 days from finalization to deliver a product to customers and another 30 days to test and train. Another commenter noted concerns about helping train staff to use the new form, and the impact that might have on data.

HUD response: HUD provided in the 60-day notice a line-by-line explanation of the changes. During the 30-day review period, HUD will make publicly available to the new forms for individuals to see the changes. As for timing, HUD will work closely with providers to ensure a smooth transition. HUD acknowledges the concerns about the timeline for revision to the form, migration to HIP, vendor systems changes, and implementation for all PHAs. HUD will continue to monitor the development to ensure that PHAs have adequate time to make necessary transitions.


Vouchers – Date Participant Vacated Unit

Comments: Commenters requested clarification in when to use “Date Participant Vacated Unit.” Some commenters noted the data would be burdensome and unnecessary. One commenter asked if they could opt out of reporting the data. Another commenter requested clarification on how HUD would use the data, and how to treat a family that remained in unit but exited the program.

HUD response: The “Date Participant Vacated Unit” field will be used when a family vacates a unit but remains an HCV program participant. This field will be used for funding calculations, so PHAs must submit this information when a program participant vacates their unit. PHAs should file an “Other Change, Non-Income Threshold” action type to submit this information. Since the date the participant vacated the unit is important for funding calculations, it will be important to obtain as precise a date as possible in this field. HUD recognizes that in some situations the precise date may be difficult to obtain. If the family remained in the unit but ended participation in the HCV program, PHAs would instead file an End of Participation submission.

Vouchers – Type of Voucher Issuance

Comments: Commenters requested guidance on how to code “Type of Voucher Issuance,” especially in line with existing PHA lists. Another commenter requested additional fields to capture new voucher recipients.

HUD response: HUD has added a new field, “Type of Voucher Issuance,” for when a PHA uses the “Voucher Issuance” action type. The “Type of Voucher Issuance” field will specify the type of voucher issuance—for example, whether it is a voucher issued for a new participant or for a move. HUD agrees with commenters that additional guidance will be required for all new fields. Further information will be provided in the 500058 Instruction Booklet.


9. Explain any payments or gifts to respondents, other than remuneration of contractors or grantees.


No payment or gift will be granted to the respondents.


10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation or agency policy.


In accordance with the Federal Privacy Act of 1974, 5 U.S.C. 552a, public housing agencies must inform applicants and resident families about possible Federal Government uses of information contained on Form HUD-50058, Form HUD-50058 MTW, and Form HUD-50058 MTW Expansion Family Reports and the systems to monitor reductions in subsidy payment errors. Form HUD-9886 Authorization for the Release of Information/Privacy Act Notice, is used to inform residents of the authority for the collection of information, the purpose of the data collection, and the uses of the information collected by the PHAs pursuant to the agencies’ obligation to submit information to HUD. Tenants give consent for the collection and use of information by signing Form HUD-9886 upon admission.


Access to the collection of 50058 information is highly restricted. HUD staff seeking access must request access through HUD’s Digital Identity and Access Management System (DIAMS) and be approved for such access by their immediate supervisor. The request must be specific as to the nature of the access (view only, submissions, etc.) to ensure integrity. PHA access must be requested through the agency’s respective field office. Access is time-limited and must be renewed periodically.


Demographic data provided to Congress and other interested parties is scrubbed of any personally identifiable information. In instances where research may be conducted by research firms under contract to HUD, this data is scrubbed of personally identifiable information and all procedures for handling of confidential information, such as restricted access by contractors and secure facilities, are followed.


11. Justify any questions of a sensitive nature, such as sexual, religious beliefs, and other matters that are commonly considered private


Form HUD-50058, Form HUD-50058 MTW, and Form HUD-50058 MTW Expansion Family Reports do not collect information of a sensitive nature such as sexual behavior and attitudes or religious beliefs. Private information such as income, social security numbers and public benefits, however, is required. This information is required for proper administration of the assisted housing programs and for monitoring program performance. This information is used to determine the amount of subsidy for which each participant household is eligible. Without this information, HUD and PHAs cannot determine program eligibility and the amount of federal subsidy each PHA is to receive in order to continue to operate the public housing and housing choice voucher programs. Please refer to section ten for steps taken to attain the consent of residents to collect such information.


12. Estimate public burden: number of respondents, frequency of response, annual hour burden. Read the complete instructions on the form 83i. Explain how the burden was estimated. Generally, estimates should not include burden hours for customary and usual business practices. Provide a table to describe the elements of the burden. Break out each form used.

  • if this collection uses more than one form, provide separate estimates for each form and aggregate the hour burdens in item 13 of OMB Form 83i; and

  • provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

  • The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead this cost should be included in Item 13.


Summary:


Estimate of the Hour Burden of the Collection of Information

Number of responses

2,933,713.00

Frequency of Response

Annually

Annual Hour Burden

1,593,039.50

Estimated Annual Cost to Respondents

$27,878,191.25


It takes approximately 50 minutes for PHA staff to collect and input new admission data into each Form HUD-50058, Form HUD-50058 MTW, and Form HUD-50058 MTW Expansion Family Reports record. Only a portion of the data fields are filled out each time the form is completed. The fields that are filled are dependent upon the action type or reason for the form’s completion. After the initial year of the forms’ use, the action type for the form will be recertification rather than new submission. The time it takes to complete a recertification is approximately half that of a new submission. Pre-entry of key information from the previous year is responsible for this time reduction.


Through consultation with financial experts in HUD-HHQ Office Field Operations, an amount of $17.50 has been approximated to represent the national average as well as the average of the hourly rate for a clerical data entry as well as quality control on the entries.


Detailed:


Information Collection

Number of Respondents

(PHAs with Responses)

*Average Number of Reponses per Respondent

Total Annual Responses

Burden Hours per Response

Total Hours

Hourly Cost

Total Annual Cost

Form HUD-50058
New Admission

4,014

87

349,218.00

0.83333

291,015.00

$17.50

$5,092,762.50

Form HUD-50058
Recertification

4,014

583

2,340,162.00

0.5

1,170,081.00

$17.50

$20,476,417.50

Form HUD-50058 MTW
New Admission

39

529

20,631.00

0.83333

17,192.50

$17.50

$300,868.75

Form HUD-50058 MTW
Recertification

39

4,018

156,702.00

0.5

78,351.00

$17.50

$1,371,142.50

Form HUD-50058
MTW Expansion
New Admission

100

87

8,700.00

0.83333

7,250.00

$17.50

$126,875.00

Form HUD-50058
MTW Expansion
Recertification

100

583

58,300.00

0.5

29,150.00

$17.50

$510,125.00

Totals

4,153


2,933,713.00


1,593,039.50


27,878,191.25


*Average Number of Responses per Respondent = Total Annual Responses / Number of Respondents



Estimated annualized hourly cost to respondents (PHA); Form HUD-50058: To report using Form HUD-50058 Family Report, it will cost the average PHA $1,268.75 annually to enter and submit all data for New Admission and $5.101.25 annually for Recertification.



  • Total Cost for all PHAs; Form HUD-50058 Family Report New Admissions =

    • 291,015.00 Total Hours X $17.50/hour = $5,092,762.50

  • Cost per PHA = $5,092,762.50 Total cost for all PHAs ÷ 4,014 PHAs (with responses) = $1,268.75 per PHA annually

  • Total Cost for all PHAs; Form HUD -50058 Family Report Recertification =

    • 1,170,081.00 Total Hours X $17.50/hour = $20,476,417.50

  • Cost per PHA = $20,476,417.50 Total cost for all PHAs ÷ 4,014 PHAs (with responses) = $5,101.25 per PHA annually



Estimated annualized hourly cost to respondents (PHA); Form HUD-50058 MTW: To report using Form HUD-50058 MTW Family Report, it will cost the average PHA $7,714.58 annually to enter and submit all data for New Admissions and $35,157.50 annually for Recertification.

The annual burden is calculated by determining the following:


  • Total Cost for all PHAs; Form HUD-50058 MTW Family Report New Admission =

    • 17,192.50 Total Hours X $17.50/hour= $300,868.75

  • Cost per PHA = $300,868.75 Total cost for all PHAs ÷ 39 PHAs (with responses) = $ 7,714.58 per PHA annually

  • Total Cost for all PHAs; Form HUD-50058 MTW Family Report Recertification =

    • 78,351.00 Total Hours X $17.50/hour= $1,371,142.50

  • Cost per PHA = $1,371,142.50 Total cost for all PHAs ÷ 39 PHAs (with responses) = $35,157.50 per PHA annually


Estimated annualized hourly cost to respondents (PHA); Form HUD-50058 MTW Expansion: To report using Form HUD-50058 MTW Expansion Family Report, it will cost the average PHA $1,268.75 annually to enter and submit all data for New Admissions and $5,101.25 annually for Recertification.

The annual burden is calculated by determining the following:


  • Total Cost for all PHAs; Form HUD-50058 MTW Expansion Family Report New Admission =

    • 7,250.00 Total Hours X $17.50/hour= $126,875.00

  • Cost per PHA = $126,875.00 Total cost for all PHAs ÷ 100 PHAs (with responses) = $1,268.75 per PHA annually

  • Total Cost for all PHAs; Form HUD-50058 MTW Expansion Family Report Recertification =

    • 29,150.00 Total Hours X $17.50/hour= $510,125.00

  • Cost per PHA = $510,125.00 Total cost for all PHAs ÷ 100 PHAs (with responses) = $5,101.25 per PHA annually


13. Estimate of the annual cost to respondents or recordkeepers (do not include the cost of hour burden shown in Items 12 and 14). Read the complete instructions on the form 83i.


Total annual capital and startup cost burden to PHA:


Estimating annual capital and startup cost burdens to PHAs is difficult to determine. Most respondents (PHAs) utilize automated software for the collection, transmission and storage of Form HUD-50058, Form HUD-50058 MTW, and Form HUD-50058 MTW Expansion Family Reports. Several vendors provide software services to PHAs, however the software is used for several day-to-day business functions, not exclusively form reporting.


Additionally, HUD provides all PHAs with free Family Reporting Software (FRS). PHAs can use this software to electronically submit Form HUD-50058 Report data. This software is not used for the Form HUD-50058 MTW and Form HUD-50058 MTW Expansion Family Reports.


Total operation and maintenance of services components:


Estimating the cost to PHAs for the transmission of the Family Reports is difficult to do because of the difference in PHA, size, organization structure and administrative capability. A significant cost factor that can be tracked is the time involved to collect the datadata, fill out the form and electronically submit the data. This information is provided in section 12.


14. Estimate annualized costs to the Federal government.


The estimated annualized cost to the Federal government is $3,143,000. Based on the most recent data available, the total annual cost to maintain HUD’s system, which includes the modules for the Form HUD-50058, Form HUD-50058 MTW, and Form HUD-50058 MTW Expansion Family Reports, is $893,000. The developmental cost is $1,700,000. The cost to HUD headquarters staff to monitor the system is $150,000 (5%-6% of contractor cost). HUD estimates that contractors and HUD staff spend 40 percent of their time on maintenance and monitoring the modules. The annual cost of HUD headquarters staff labor to monitor the module is approximately $100,000. The annual cost of HUD headquarters staff to maintain the module is $300,000.


15. Explain any program changes or adjustments reported in items 13 and 14 of the OMB Form 83i.


The Form HUD-50058 and Form HUD-50058 MTW continue to be submitted in the IMS/PIC system in its existing modules. The HUD-50058 MTW Expansion is submitted in the HIP system.


16. If the information will be published, outline plans for tabulation and publication.


HUD’s systems capture the information from Form HUD-50058, Form HUD-50058 MTW, and Form HUD-50058 MTW Expansion and create monthly reports such as the Resident Characteristics Report (RCR) which is available to the public on the HUD website. It provides demographic and income statistics about tenant families that participate in the Housing Programs.


17. Explain any request to not display the expiration date.


Not applicable. HUD will display the OMB control number and expiration date on the form.


18. Explain each exception to the certification statement identified in item 19.


There are no exceptions to the certification statement.


B. Collections of Information Employing Statistical Methods


This collection of information does not employ statistical methods.


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