CLPHA | 04/30/08 Weekly Report -
[Cached Version]
Published on: 4/30/2008
Last Visited: 9/25/2009
Greg Byrne, director of HUD's Real Estate Assessment Center (REAC), said he was unsure whether this guidance will apply to stop-loss agencies, but indicated that HUD will make a final determination prior to releasing the supplemental guidance.
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Byrne provided the following example: a PHA has a [central] Manager shared by 2 Asset Management Projects (AMP).
The PHA determines that the proper ratio is 60 percent at AMP 1 and 40 percent at AMP 2.
Sixty percent of the costs for that manager shows up on the "allocated overhead" line item of the FDS for AMP 1, and 40 percent of the costs for that manager show up on the "allocated overhead" line item of the FDS for AMP 2.
There will be no separate column for "management," rather there will be an "allocated overhead" row on each operating statement.
Byrne indicated that program funds attributed to "allocated overhead" may be subject to A-87 reviews, and that HUD will create guidance on how HUD will determine reasonable costs under the cost allocation method.
Byrne also led a discussion regarding allowable expenditures under the capital fund.
He noted that PHAs opting to use labor paid by the force account for capital work would have to charge actual expenses rather than fees for service.
Byrne reiterated that housing authorities that opt to use any capital fund money for "management improvements" to the COCC must switch to the cost allocation system of accounting, even if the transfer occurs mid year.
Finally, participants discussed new FDS reporting requirements.
Byrne said that "HUD does not expect to change the currently available FDS, other than to add a line for 'allocated overhead.'" He went on to say that HUD has decided to allow PHAs to extend from 60 days to90 days to submit unaudited financials during the first year.
He was not sure, however, whether HUD will require that unaudited financials be submitted within 90-days of the end of the fiscal year, or within 90-days of the date that the submission system is made available.
One participant inquired about how PHAs can determine which projects should be reported, and which projects will get scored.
Byrne mentioned that in the transition year, PHAs will not be scored on financials, and reiterated that a proposed rule, subject to industry comments, will be published regarding these questions.
Byrne said that HUD will be holding training at headquarters once the FDS is finalized.
Byrne said that he will meet with staff, circulate notes from the call with participants, and that he hopes to hold another such call prior to publishing final guidance