Things to Consider When Preparing and Reviewing
First Increment RHF Plans
1) Is the PHA required to submit an RHF Plan, or is submission
optional because they intend to directly 1) proceed with the submission
of a development proposal and 2) obligate 90 percent of the RHF
grant within 24 months from the date the funds were made available
and expend 100 percent of the RHF grant within 48 months from when
the funds were made available?
2) Is the PHA intending to accumulate its RHF grants for several
years and delay the obligation start date? If so, how many years
of grants are they accumulating? Which grants (by fiscal year) are
they accumulating? What is the total amount of the grants being
3) Was the Plan submitted in accordance with the schedule posted
on the OCI website?
4) Is the PHA planning to develop public housing rental units,
either through construction or acquisition? What is the total number
of units to be developed? What type of units will be developed?
Through what method will the units be developed?
5) Is the plan for development using first increment RHF funds
discrete, e.g. in no way reliant on funding of the second increment
of RHF funds (years 6-10) in order to be completed?
6) Is the PHA plan for development consistent with Section (9)(g)(3)
of the Act, which limits the number of new units a PHA may construct
as public housing?
7) Has the PHA provided a schedule of major development milestones?
If the PHA is planning more than one development/development proposal,
are multiple schedules included?
8) When is the PHA planning to submit a development proposal(s)?
Is the date of submission of the development proposal consistent
with the requirement that the development proposal be submitted
NO LATER than 90 days after execution of the RHF ACC by the HUD
Field Office, or the due date of the PHA's Annual Plan for the last
fiscal year the PHA intends to accumulate its RHF funds (no later
than the fifth year of RHF funding)?
9) What other sources of funding (if any) does the PHA intend to
use to develop the replacement housing? Have the costs been analyzed
against the applicable TDC limits?
10) Is the PHA proposing something inconsistent with the current
RHF guidelines and asking for an exception of waiver of program
requirements? What specifically are they requesting?
11) Has the PHA submitted an electronic copy of its RHF Plan to
the Office of Capital Improvements?
Additional Things to Consider When Reviewing
and Preparing Second Increment RHF Plans
In addition to the items above, please consider the following when
reviewing and preparing second increment RHF Plans:
1) Does the Plan include a statement addressing: the approval status
of the Five Year PHA Plan; the approval status of all Annual Plans
(FYs 1998-2005); and compliance with obligation and expenditure
deadlines in FYs 1998-2004 for all Capital Fund grants?
2) Does the PHA have firm commitments for substantial additional
funds, other than public housing funds, equaling one-third of the
total RHF funds it received in the first five-year increment? What
resources is the PHA proposing to use as leverage? What commitment
document was provided?
3) Is the PHA planning to submit the development proposal NO LATER
than 90 days after execution of the ACC by the HUD Field Office,
or the due date of the PHA's Annual Plan for the seventh year of
4) Is the PHA planning to FULLY EXPEND its second increment RHF
funds no later than the end of the tenth year of RHF funding?
Note: If the PHA requests an additional five years of funding,
it must proceed with the development of the first five-year increment
and submit a second, discrete, RHF Plan based on the funding provided
in years 6 - 10. In no case should the development or developments
planned with first increment RHF funding be planned in such a way
that completion of that development or developments relies on HUD
funding of the second increment of RHF. PIH Notice 2004-15 provided
guidance on RHF grant calculation and other related topics. The
Office of Capital Improvements will also provide additional guidance
on RHF on this website, so keep checking back.