Interesting tidbit from (pg.81) the State of Oregon Single Audit (of federal spending) illustrates the games that grantees play to cleverly stay within the law. This relates to Maintenance of Effort requirements similar to those likely found in the Recovery Act.
Oregon Office of Private Health Partnerships State Children’s Insurance Program, CFDA 93.767 Maintenance of Effort & Eligibility – Advanced Subsidy Payments Questioned Costs $4.6 Million
In 2002 the Centers for Medicare and Medicaid Services (CMS) authorized a five-year waiver, expiring October 31, 2007, that allowed eligible uninsured children and adults to receive insurance premium subsidies for the purchase of private health insurance. The waiver also included a maintenance of effort requirement that the amount of state funds expended for the program be maintained or increased above the state fiscal year 2002 level.
To meet the maintenance of effort requirement as of October 31, 2007, the Office of Private Health Partnerships (department) made advanced subsidy payments to three private insurance carriers for the periods of December 2007 through February 2008. The department had not incurred an obligation to pay the insurance premium subsidies. If the department had not paid the insurance premium subsidy payments in advance, it would not have met the required maintenance of effort by approximately $2 million.
In addition, effective November 1, 2007, adults became ineligible for State Children’s Insurance Program (SCHIP) funding as the waiver that allowed it had expired. The department used $4.6 million of SCHIP funding to prepay for insurance premium subsidies for adults from November 2007 through February 2008. If the prepayment had not occurred, the department would have paid the subsidies with either Medicaid funds, if eligible, or state funds.....
We recommend department management consult with CMS to determine whether subsidy prepayments are allowed to be counted toward maintenance of effort, and whether prepayments made for adults were allowable since the adults were ineligible for SCHIP funding for the time period prepaid.
AGENCY’S RESPONSE: The agency believes it operated within its contractual obligation with the Centers for Medicare and Medicaid Services (CMS). Prior to making advance subsidy payments, the agency worked with the Department of Human Services (DHS) and the Department of Administrative Services (DAS) to discuss the appropriateness of the payment. Notwithstanding our disagreement with this finding, the agency agrees to consult with the Department of Human Services (DHS) to raise the issue with CMS.
Saturday, April 4, 2009
State Recovery Websites from ProPublica.
Nice listing of state recovery websites HERE , along with short summary/evaluation.
A couple of examples of what is posted:
Oregon Tracking the dollars website HERE; pretty lame as of the moment.
A couple of examples of what is posted:
- Washington State has a nice table HERE showing deadlines for key actions , including those required for federal agencies.
- Missouri has a transparency website HERE showing Recovery Act $$ as they are received by State Treasury AND a RSS feed that allows subscribers to receive updates as they occur. These examples shows state level receipts information is very current, as recent as a couple of days ago [May only capture state $$, not $$ being received by others within state]:
| Apr 2, 2009 | Unemployed Missourians received $179,125 in additional unemployment benefits |
| Apr 1, 2009 | Unemployed Missourians received $300,375 in additional unemployment benefits |
| March 2009 | Unemployed Missourians received $15,304,025 in additional unemployment benefits |
Oregon Tracking the dollars website HERE; pretty lame as of the moment.
Friday, April 3, 2009
OHC Meeting: SF Bond Loan Program Suspended; 09-11 OHCS Budget Reduction of $9 Million Eliminates GF Funding for Some Programs, Cuts Others.
From my notes at of the Oregon Housing Council meeting held this morning:
6. NSP 2: $9-11 Million target. Not a formula grant, a national competition that should be announced in next month. Organizations other than states can apply directly. Program requirements may differ from NSP 1 (NOT clear if NSP $$ are included in governors estimate of "fair share" target for Oregon).
7, Latest legislative update is HERE.
8. Council took under advisement my recommendation during public comment period to issue a proclamation recognizing FHA 75th Anniversary.
- Governor’s rep discussed Oregon Way Advisory Group, hoping to get competitive grants in excess of what might be a $370 million “fair share” amount for Oregon.
- Budget cut data will be released from Legislative Fiscal Office this afternoon. OHCS had to take a deeper cut in general fund, as lottery funds backed bonds and could not be cut. Results is that this would eliminate any general funds for homeowners assistance, homeless assistance, and 1/3 of funding for emergency housing. OHCS table of options is HERE; on last page of the OHCS table the 30% cut looks like a reduction of $9 Million+ for the next biennium (no dollar figure was mentioned in meeting before I had to leave after 3 hours). No additional staff cuts (I recall FTE had been cut in Governor's budget already)."Cuts" (presumably from Governor's previously proposed budget) for other agencies can be found HERE.
- OHCS staff said SF bond program was "suspended"as of March 17th. Still taking names for wait list, but no immediate plans to issue bonds.
- Considered three specific Permanently Supportive Housing projects whose applications followed a request for applications. Approved two projects, the third was tabled until next month. [No project details made available to public, these are my notes from discussion].
- Columbia County in St. Helens: 2 unit project. Francisco Lopez, Council Member asked about Immigration ordinance passed last year, Response was that Community Action and others did not support, and county officials were looking into legality of the ordinance.
- Rogue Retreat in Medford : 11 unit rehab.
- The Glade in Warrenton: 12 unit CMI, new construction, Previously approved, this was request for increase based on subsequent cost increases. Only project in County for CMI population. Council push back was that in this legislative climate did not believe that cost escalation was fully warranted and especially so for single source contract. Council required that cost estimates be scrubbed to look carefully at increased site improvement costs and construction costs and tabled consideration until next Council meeting.
6. NSP 2: $9-11 Million target. Not a formula grant, a national competition that should be announced in next month. Organizations other than states can apply directly. Program requirements may differ from NSP 1 (NOT clear if NSP $$ are included in governors estimate of "fair share" target for Oregon).
7, Latest legislative update is HERE.
8. Council took under advisement my recommendation during public comment period to issue a proclamation recognizing FHA 75th Anniversary.
HUD Projected NOFA Dates for Recovery Act Programs; NOFA for NSP Program Either Next Week or NLT Month From Now.
Looks like HUD is announcing some planned dates for competitive Recovery Act Grant Programs and perhaps shifting an announcement date.
In March 27 Report (#4) HUD said it planned to
In March 20 Report (#3) HUD said it planned to
However on the HUD Recovery Act webpage for that Neighborhood Stabilization Program HUD says: "HUD must issue Notices of Funding Availability (NOFA) with application requirements no later than May 3, 2009. "
I checked this AM and there is no advance Federal Register NSP publication currently scheduled for Monday, April 6th. Bottom line, either the NSP grant NOFA will be announced next week, or no later than a month from next week.
HUD's Recovery Act website is HERE.
In March 27 Report (#4) HUD said it planned to
- "Publish Public Housing Capital Fund (competitive) NOFA by April 27th."
- "Publish Assisted Housing Retrofit NOFA by April 17th."
In March 20 Report (#3) HUD said it planned to
- "Publish NSP NOFA on April 6th."
However on the HUD Recovery Act webpage for that Neighborhood Stabilization Program HUD says: "HUD must issue Notices of Funding Availability (NOFA) with application requirements no later than May 3, 2009. "
I checked this AM and there is no advance Federal Register NSP publication currently scheduled for Monday, April 6th. Bottom line, either the NSP grant NOFA will be announced next week, or no later than a month from next week.
HUD's Recovery Act website is HERE.
Thursday, April 2, 2009
As I Projected Last Month, A Private Mortgage Insurer is Stiffing Fannie/Freddie.
First Lady at London Event Today.
A touching moment from an event today with British schoolgirls:
"Whether you come from a council estate or a country estate, your success will be determined by your own confidence and fortitude. "
"Whether you come from a council estate or a country estate, your success will be determined by your own confidence and fortitude. "
Visit msnbc.com for Breaking News, World News, and News about the Economy
Washington County Hearing on Housing Authority Annual Plan.
Scheduled for April 8th, at 10 AM.
Agenda is HERE.
Agenda is HERE.
Wednesday, April 1, 2009
Seattle Study on $4 Million in Savings from Housing First Model for Homeless Alcoholics.
Update of My Internet Archive Review of 1935 FHA Short Film.
In advance of the June 75th anniversary of FHA, I just did an update of my review from 5 years ago of this 1935 film that highlights the start of FHA.You can see the review as well as choose from lots of different options to view the film online or to download HERE.
[Apologies in advance, the film includes clear sex role stereotypes, and the absence of minorities, representing the realities of 1930's America].
BIG, BIG PLUG for Internet Archive. The scope of information on this site continues to amaze me. Whether it's video, audio, or text can't imagine many other sites that match the reach of the Internet Archive. Check out The Day Called X to see what I am talking about.
PMI Group Says Portland Has 2/3rds Chance of Having Lower Price Index Two Years Out; That's Double the Probability for Seattle.
PMI Group has issued a new metro market assessment HERE.
In looking at the table on pages 6 and 7 you will see that Portland metro area has a "U.S. Market Risk index" of 66.4, vs a risk index of 30.3 for Seattle for the 4th Quarter 2008. [ .." a Risk Index score of 100 means there is a 100 percent chance that the Loan Performance All Transactions House Price Index for that MSA will be lower two years from the date of the data"].
Translation: According to PMI Group, there is a two thirds chance that the Portland home price index will be lower in two years [4th quarter 2010], while the chance for Seattle having a lower home price index at that time is less than 1/3rd.
In both cases the risk index for 4th Quarter 2008 has increased significantly compared to 3rd quarter of 2008. Portland's risk index increased by 199% (66.4 vs 22.2) while the risk index for Seattle increased by 189% ( 30.3 vs. 10.5).
In looking at the table on pages 6 and 7 you will see that Portland metro area has a "U.S. Market Risk index" of 66.4, vs a risk index of 30.3 for Seattle for the 4th Quarter 2008. [ .." a Risk Index score of 100 means there is a 100 percent chance that the Loan Performance All Transactions House Price Index for that MSA will be lower two years from the date of the data"].
Translation: According to PMI Group, there is a two thirds chance that the Portland home price index will be lower in two years [4th quarter 2010], while the chance for Seattle having a lower home price index at that time is less than 1/3rd.
In both cases the risk index for 4th Quarter 2008 has increased significantly compared to 3rd quarter of 2008. Portland's risk index increased by 199% (66.4 vs 22.2) while the risk index for Seattle increased by 189% ( 30.3 vs. 10.5).
Tuesday, March 31, 2009
Wed. April 8th HAP Hearing on Recovery Act Spending; "Sweet 16" Get Top Priority.
The Housing Authority of Portland is amending it's Moving to Work Annual Plan, and is holding a hearing on the plan on April 8th. Primary purpose of amendment and hearing is discussion of changes in its capital improvements spending plans to incorporate $6.3 million in funds received from HUD under the Recovery Act.With apologies to the NCAA, HAP's "Sweet 16" projects will receive top priority. The "Sweet 16" (pg.3) and other priorities can be found in the proposed plan amendment HERE.
Hearing and Public Comments:
- A public hearing will be held on Wednesday, April 8, 2009 @ 4:00 pm at HAP, 135 SW Ash Street, 6th Floor, Portland, OR.
- HAP will be accepting written comments regarding the proposed amendment from March 29, 2009 – April 7, 2009. Please submit written comments to the following address: Housing Authority of Portland, Attn: Michael Buonocore, 135 SW Ash Street, Portland, OR 97204. Comments can also be emailed to michaelb@hapdx.org.
Portland Suffers Worst Ever Declines in Case Shiller Price Index; But It Moves UP in Metro Rankings.
Ouch!
The monthly December-January decline in the Portland Case-Shiller index was 3%, the greatest Portland decline in the 20+ year history of the index, as was the Year to Year decline from Jan 09-Jan 08.
(In fact, each of the last 3 monthly Portland declines have been the worst in the history of the index, and each of the last 12 months have seen the highest year to year declines on record).
The year to year decline was 14%, and the decline since the peak month of July 2007 was 17.5% . The national press release is HERE.
..But Less Ouchy on a Relative Basis
As bad as those declines are, I constructed a table HERE that shows that Portland moved UP in the rankings by metro area, compared to December.
Month to Month Metro Ranking (20 Metro Areas)
The monthly December-January decline in the Portland Case-Shiller index was 3%, the greatest Portland decline in the 20+ year history of the index, as was the Year to Year decline from Jan 09-Jan 08.
(In fact, each of the last 3 monthly Portland declines have been the worst in the history of the index, and each of the last 12 months have seen the highest year to year declines on record).
The year to year decline was 14%, and the decline since the peak month of July 2007 was 17.5% . The national press release is HERE.
..But Less Ouchy on a Relative Basis
As bad as those declines are, I constructed a table HERE that shows that Portland moved UP in the rankings by metro area, compared to December.
Month to Month Metro Ranking (20 Metro Areas)
- Portland ranked 10th. best in December, the January ranking improved to 6th. best.
- Portland ranked 8th. best in December, the January ranking improved to 7th. best.
Monday, March 30, 2009
CBO on Federal Budget: COLA's Will Cost 1/2 Trillion LESS Over Next 10 Years ; No COLA's at ALL for 2010-2012.
Yeah, I know this is NOT exactly a housing post, but it's a weird factoid related to deflation that I picked up looking at the most recent CBO budget projection HERE and it will impact future rent affordability for seniors with fixed incomes.
CBO report says (pg.20 ):
" CBO has reduced estimated outlays by $500 billion for federal retirement and benefit
programs, including Social Security, because projected cost-of-living adjustments (COLAs) have fallen since January. No COLA's are currently projected for such programs from 2010 through 2012; the COLA would amount to less than 2 percent in all future years (an average of 0.8 percentage points below CBO’s previous projections for years after 2011). "
This all is triggered by some good or bad timing for the 2009 COLA's (depending on whether you are receiving or paying), which were computed based on summer 08 quarter when gas prices spiked. The resulting 5.8% COLA increase was the largest since early 1980's.
In re lack of future COLA's for 2010-2012, idea is that future adjustments will not occur until costs exceed summer 08 levels, which CBO apparently projects will not happen until summer of 2012 (resulting in a modest 2013 increase).
CBO report says (pg.20 ):
" CBO has reduced estimated outlays by $500 billion for federal retirement and benefit
programs, including Social Security, because projected cost-of-living adjustments (COLAs) have fallen since January. No COLA's are currently projected for such programs from 2010 through 2012; the COLA would amount to less than 2 percent in all future years (an average of 0.8 percentage points below CBO’s previous projections for years after 2011). "
This all is triggered by some good or bad timing for the 2009 COLA's (depending on whether you are receiving or paying), which were computed based on summer 08 quarter when gas prices spiked. The resulting 5.8% COLA increase was the largest since early 1980's.
In re lack of future COLA's for 2010-2012, idea is that future adjustments will not occur until costs exceed summer 08 levels, which CBO apparently projects will not happen until summer of 2012 (resulting in a modest 2013 increase).
Sunday, March 29, 2009
Interview with New HUD DAS for Multifamily Nominee; She Talks About New Programs.
San Jose Mercury News interview is HERE.
She describes a new "Choice Neighborhoods" program that will apparently appear in the budget:
She describes a new "Choice Neighborhoods" program that will apparently appear in the budget:
"A The other major program that is not part of the stimulus bill but is part of the new congressional budget proposal is to re-do troubled housing, both public housing and HUD-assisted. Among those 1.4 million units, there are some that are not in good shape and, frankly, are creating some negative environments.
Q What's that program called? It sounds very broad.
A It's called Choice Neighborhoods — the idea being you want to take neighborhoods that are troubled and change them into neighborhoods of choice."
HUD Starts Long Process to Establish System to Collect Annual Data on LIHTC Tenants.
An advance of a Notice that will appear in Monday's Federal Register is HERE.
Excerpt:
"Section 2835(d) of HERA (Public Law 110-289, approved July 30, 2008) amends Title I
of the U.S. Housing Act of 1937 (42 U.S.C. 1437 et seq.) (1937 Act) to add a new section 36 (to be codified as 42 U.S.C. 1437z-8) that requires each state agency administering tax credits under section 42 of the Internal Revenue Code of 1986 (low-income housing tax credits or LIHTC) to furnish HUD, not less than annually, information concerning the race, ethnicity, family composition, age, income, use of rental assistance under section 8(o) of the U.S. Housing of 1937 or other similar assistance, disability status, and monthly rental payments of households residing in each property receiving such credits through such agency. "
Excerpt:
"Section 2835(d) of HERA (Public Law 110-289, approved July 30, 2008) amends Title I
of the U.S. Housing Act of 1937 (42 U.S.C. 1437 et seq.) (1937 Act) to add a new section 36 (to be codified as 42 U.S.C. 1437z-8) that requires each state agency administering tax credits under section 42 of the Internal Revenue Code of 1986 (low-income housing tax credits or LIHTC) to furnish HUD, not less than annually, information concerning the race, ethnicity, family composition, age, income, use of rental assistance under section 8(o) of the U.S. Housing of 1937 or other similar assistance, disability status, and monthly rental payments of households residing in each property receiving such credits through such agency. "
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