Changing Your PHA's Fiscal Year

March 2017

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Over the past several years, we have received inquiries on how to change a Public Housing Authority’s (PHA) fiscal year end (FYE). There seems to be heightened interest due to several RAD conversions and mixed finance transactions (which sometimes have a different year-end than the PHA). The ease of having the entire portfolio on the same year-end reduces several administrative and accounting burdens.

PIH Notice 2001-25 provides PHAs and HUD staff with guidelines to assure that all HUD management information, accounting, and payment systems are updated in a timely and coordinated manner when database changes are required due to PHA fiscal year end changes, forming a consortium and merging two PHAs together. Additionally, PIH Notice 2001-25 provides direction to establish a new HUD requirement that a PHA must use a common fiscal year end for its public housing program, its housing choice voucher (HCV) program and its Section 8 moderate rehabilitation (MOD Rehab) program.

The first step for PHAs is to submit a plan to the local field office. The PHA’s plan must include the cause to form a consortium, merge or consolidate into a single PHA, request a change in their fiscal year end, or assert that they are making other organizational changes that affect PHA project configurations, the funding process, or the reporting process. This is in addition to the specifics the PHA must supply the local HUD field office with the necessary information to update the HUD electronic data systems. When more than one PHA is party to the change, a single request for database changes should be submitted by the lead PHA. The request should reference all affected PHAs and contain applicable information for all affected PHAs.

If a fiscal year-end change is requested, the required information must be provided to the local HUD field office at least 90 calendar days prior to the current FYE of the PHA. For example: if the PHA wants a FYE change to 12/31 and the PHA’s current FYE is 6/30, the required information must be submitted by the PHA to the HUD field office by 3/1. The implementation of a FYE change must be prospective rather than retroactive.

The PHA should send the field office the following information from the executive director:
  • The reason for the database change request; i.e, the basic action being undertaken - an organizational change (such as consolidation, merger, consortium) and/or a change in FYE
  • The name(s) and the PHA code(s) of the PHAs involved in the requested action
  • The name of the new entity, if applicable
  • The name of the lead PHA that funding is to be directed to on behalf of participating PHAs in a consortium
  • The current FYE of each PHA
  • The requested FYE of each PHA 3
  • The program name and PHA PAS/eLOCCS or HUDCAPS project number for each program area that will be affected by the request, such as:
    • Public Housing Operating Fund (operating subsidy)
    • Public Housing Capital Fund (modernization)
    • Public Housing Grant Programs • Housing Choice Voucher Program
    • Section 8 Moderate Rehabilitation Program
    • Note: A FYE change affects all program areas of a PHA

The field office will review the information submitted by the PHA to assure receipt of the necessary information, including sufficient accounting information to identify the programs affected. The field office will obtain any missing information from the PHA before forwarding the database information change request to Headquarters. The field office will forward the PHA’s cover letter with the supporting documentation to, “Deputy Assistant Secretary, Public and Assisted Housing Delivery, Attention: Funding and Financial Management Division.”

The field office’s cover memorandum forwarding the PHA information should include: the recommendation of the field office for approval of the data base change(s), a statement indicating which, if any, of the PHAs involved in the request are troubled and the name and telephone number of a field office contact person. If the request includes a troubled PHA, a copy of the cover memorandum should be sent to the Office of Trouble Agency Recovery (OTAR) with jurisdiction over the PHA.

The PHA/field office/OTAR will be notified by letter from the Assistant Secretary of Public and Indian Housing that the required database changes have been approved. The Funding and Financial Management Division (FFMD), Office of Public & Assisted Housing Delivery, will be the lead office at Headquarters to coordinate the database change request with the HUD offices responsible for, or affected by, the various electronic data systems. FFMD will review the PHA request and information as submitted by the field office and contact the affected PIH program areas and HUD data systems offices in order to identify and resolve potential problems with the requested change. This coordination will include: offices within PIH and offices outside PIH, such as the Office of Capital Investment, and any troubled agency contacts (when troubled PHAs are involved), the Grants Management Center, the Section 8 Finance Division, the CFO Accounting Center, the Real Estate Assessment Center and the Section 8 Financial Management Center.

FFMD will notify the field office if additional information is required, or if for some reason the database changes cannot be approved as requested by the PHA. FFMD will prepare a response to the PHA/field office for the signature of the Assistant Secretary of the Office of Public and Indian Housing, approving the database changes. The response will be circulated, as necessary, for the prior concurrence of PIH program offices and HUD data systems offices affected by the changes. FFMD will notify the field office, OTAR and all offices that concurred in the response, when the Assistant Secretary signs the response.

If you have questions regarding matters discussed above, please contact Brian Alten.

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