- Moving To Work (MTW) Agencies. If an MTW agency chooses to convert assistance to PBRA under this Demonstration, the Covered Project(s) will no longer be included as part of the PHA’s MTW program.
If an MTW agency chooses to convert assistance to PBV, the Covered Project(s) will continue to be included in the PHA’s MTW program. (See Section 1.6 for a discussion on provisions a MTW agency may not alter).
Further, prior to conversion, MTW agencies will be required to amend Attachment A of their MTW Agreement to the extent HUD determines is necessary to meet the statutory requirements of RAD. The PHA must request the amended Attachment A language from their MTW coordinator and follow provided instructions to return an executed Attachment A amendment to HUD no later than the Financing Plan submission.
Utilizing MTW Funds to Supplement Rents After ConversionIf an MTW Agency sets a rent for the HAP contract at the time of conversion, can the Agency go back at a future date (say, year 5) and increase the rent for the HAP contract beyond the standard OCAF adjustments?
No. The RAD Notice (Section 1.6.B.6) and the HAP contracts require that contract rents may only be adjusted by the OCAF. The RAD notice further specifies that MTW agencies may not alter this requirement.
MTW FungibilityThe Notice (REV-2, pages 48-49) specifies that "MTW Fungibility" (the ability of the MTW agency to use its block grant funds to set initial contract rents) is available only if the PHA has submitted RAD applications for two or more projects. Is OK if one project is the first phase and the second project is the second phase, of the same overall project?
Yes, that is OK so long as the two projects (phase one and phase two) are separate AMPs within PIC.
Submission of Amendment to MTW Plan for MTW PHAsI am an MTW PHA. What process should I follow for submitting and receiving approval of the amendment to my MTW Plan as required by the RAD Notice?
A RAD conversion, as noted in Section 1.5(E) of PIH Notice 2012-32, REV 2, requires an amendment to the MTW Plan for MTW agencies. The PHA's MTW representative should send the RAD MTW Plan revisions to the MTW Office and copy the Field Office. The PHA must also upload a memo noting their submission and date to the RAD Resource Desk. For MTW PHAs submitting a regularly scheduled MTW Plan, the Public Housing Field and MTW Offices should follow their regular Plan review and approval process. The MTW Office will send an approval letter, or comments that need to be addressed in the Plan, to the MTW PHA, with a copy to the appropriate Public housing Field Office director and RAD TM, within 75 days of submission. The MTW PHA will upload the approval letter to the RAD Resource Desk. Note that the RADPHAPlan@hud.gov inbox is no longer in service and should not be utilized.