Substantially the Same Assessment

Each calendar year, HUD will advise the MTW agency of its compliance with the public housing and HCV STS requirements for the prior calendar year. This information will also be made available on HUD’s website.

However, MTW agencies may benefit from tracking their compliance in order to spot potential problems early. The calculations for assessing compliance with the STS requirements for the public housing and HCV programs are detailed below.

The formula used to determine whether an MTW agency has achieved the 96 percent occupancy rate required to remain compliant with the public housing STS requirement is:

 
Total Occupied Units
Total Standing Units

Occupancy Rate

 

Data for the public housing STS analysis is taken from monthly reports pulled from the PIH Information Center (PIC).

HUD will review occupancy for each month and make notations if occupancy drops below 96 percent in any month. MTW Agencies are expected to address any such dips throughout the year; however, an Occupancy Action Plan will only be required if the dip below 96 percent is present at the end of the calendar year.

PIC data is the basis for this calculation, which relies on data from the following categories.*

Public Housing Unit Category/Sub-Category

Total Occupied Units (Numerator)

Total Standing Units
(Denominator)

Occupied – Assisted Tenant

X

X

Occupied – Employee

X

X

Occupied – Non-Assisted Tenant Over Income

X

X

Occupied – Police Officer

X

X

Occupied – Unauthorized

 

X

Vacant – Undergoing Modernization

 

X

Vacant – Court Litigation

 

X

Vacant – Natural Disaster

 

X

Vacant – Casualty Loss

 

X

Vacant – Market Conditions

 

X

Non-Dwelling – Anti-Drug Crime

X

X

Non-Dwelling – Self-Sufficiency Activities

X

X

Non-Dwelling – Other Resident Activities

X

X

Non-Dwelling – Moving to Work

X

X

Non-Dwelling – Administrative

 

X

Non-Dwelling – Resident Amenities

 

X

Non-Dwelling – Authorized

 

X

Demo-Dispo (Approved and Vacant)

 

 

Vacant – Vacant

 

X

* These categories are based on the HUD Agency Priority Goal (APG) reporting categories current at the time of publication. Should the categories change in the future, MTW agencies would be subject to the same changes as non-MTW agencies.

 

Example

The Hilltop Housing Authority reviewed its PIC data and determined that its occupancy information is as follows:

Public Housing Unit Category/Sub-Category Total Occupied Units
(Numerator)
Total Standing Units
(Denominator)
Occupied – Assisted Tenant 225 225
Vacant – Undergoing Modernization   4
Non-Dwelling – Other Resident Activities 1 1
Non-Dwelling – Moving to Work 1 1
Non-Dwelling – Resident Amenities   1
Vacant – Vacant   5
TOTAL 227 237

 

Hilltop Housing Authority calculated its public housing occupancy rate as:

 

 
227
237

96%

 

 

With an occupancy rate of 96 percent, Hilltop Housing Authority is meeting the 96 percent occupancy rate required to comply with the MTW Substantially the Same requirement for public housing.

In concept, the STS calculation for HCV and local, non-traditional units is straightforward: determine whether the number of families housed in the HCV program (plus any local, non-traditional programs) is equal to or greater than the STS target of 90 percent of the MTW agency’s “annual HCV capacity,” as described in HCV STS Target Calculation.

In practice, the HCV and local, non-traditional STS calculation requires a multi-step calculation in order to account for factors like annual inflation and funds invested in development. The steps include:

No STS Assessment for Year 1

The HCV STS assessment is only conducted for full calendar years in the program. Unless MTW Participation begins on January 1, no HCV STS assessment will be required during the first and partial calendar year of participation in MTW.

  • Calculate the number of families housed in the calendar year, including both HCV and local, non-traditional households.
  • Calculate the STS target as described in HCV STS Target Calculation.
  • Determine whether the number of families housed meets or exceeds the STS target.

HUD will assess HCV compliance with the HCV STS requirement once annually. Most of the data for the calculations will come from HUD-published data sources (inflation factor; total development costs factor) or HUD’s systems of record. However, some information about local, non-traditional units will only be available to HUD through the MTW agency’s annual MTW Supplement. This means that the timing of the STS calculation will be dependent on the MTW agency’s MTW Supplement submission date.