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On Monday, night HUD posted their long awaited notice (PIH 2011-55) detailing the procedures to be utilized in calculating the 2012 public housing subsidy.  This notice provides PHAs with instructions for operating subsidy calculation submissions for calendar year 2012 as funded from Federal Fiscal Year 2012 appropriations. It also informs PHAs that in an effort to reduce their reporting burdens HUD will use information in its systems of record to determine operating subsidy eligibility. HUD is committed to providing eligibility information to PHAs prior to the start of calendar year 2012.

This notice also addresses the allocation adjustment to operating subsidy proposed in the President's FFY 2012 budget, the methodology for the adjustment, the allowable requests for exclusion from the reserve calculation, and the submission and processing of allowable reserve exclusion requests. Although this adjustment has not yet been enacted by Congress, HUD is providing PHAs with this information and the procedures for implementation so that PHAs are able to plan accordingly. As explained further in this Notice, any allocation adjustment to the operating subsidy is subject to the language in the FFY 2012 Appropriations Act.

Given the short time-frame for processing the subsidy calculation and the related potential decrease in subsidy, HUD is trying to ensure that all users have the ability to get the notice.  HUD has promised in the notice to have the Excel tool used to calculate the subsidy available by September 30.  Calculations must be completed by October 31.  Final notifications should be completed by HUD before year end.

Of course, most agencies are aware of the potential for recapture of reserve to be used in subsidy.  HUD has provided an attachment to the Notice outlining the calculations and potential subsidy adjustments that may arise during the calculation.  We encourage all auditors to visit with their clients regarding potential impacts as a result of this notice.

AHACPA is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org