Executive Compensation Reporting for CY 2016

August 2017

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HUD recently published PIH Notice 2017-11 to provide Public Housing Authorities (PHAs) guidance to report compensation for the three highest paid officials at the PHA. Reporting began July 24, 2017, and will remain open until August 11, 2017. 
 
Each PHA will have to submit, electronically, HUD Form 52725. This form will include salaries for the highest paid management official, financial official, and the next highest paid employee that is neither the highest paid management official nor financial official. 
 
To complete the HUD-52725 Form, each PHA will use the total compensation figure reported on the PHA employee’s IRS form W-2 for the PHA’s reporting year. The PHA will further break down the W-2 reported figure into six components for each executive: 
 
  1. Base salary from tenant-based section 8 and section 9 funds; 
  2. Bonus compensation from tenant-based section 8 and section 9 funds; 
  3. Incentive and other compensation from tenant-based section 8 and section 9 funds; 
  4. Base salary from non-section 8 (tenant-based) and non-section 9 funds; 
  5. Bonus compensation from non-section 8 (tenant-based) and non-section 9 
  6. funds; and 
  7. Incentive and other compensation from non-section 8 (tenant-based) and non-section 9 funds. 
Who Must Be Reported? All Covered Individuals

The term “covered individuals” includes the “chief executive officer” as well as “any other official or employee” of the PHA with an annual salary (including any bonus) greater than the prevailing salary for level IV of the Executive Schedule. 

The term “covered individuals” includes persons who are employed in a legally separate entity of the PHA but are reported in the PHA’s financial statement as a component unit in accordance with applicable accounting standards. 

The term “covered individuals” does not include persons who work on an hourly basis, as needed, and are paid an hourly rate. 

The term “chief executive officer” includes the chief operating officer, the executive director, or other similarly titled individuals. 

For PHAs that are divisions or departments of another entity such as a state, county, locality, or non-profit that administers the federal Section 8 HCV or 9 programs and receives federal funds under Section 8 or 9, the term “chief executive officer” includes similarly titled individuals at the PHA who are employees of that other entity. 

The phrase “any other official or employee” includes all officials or employees of the PHA within the ordinary understanding of those terms. 

The term “covered individuals” does not include independent contractors.

The PHA must still comply with the FFY 2016 Appropriations Act that states no tenant-based Section 8 or Section 9 funds “may be used by any public housing agency for any amount of salary, including bonuses, for the chief executive officer of which, or any other official or employee of which, that exceeds the annual rate of basic pay payable for a position at level IV of the Executive Schedule at any time during any public housing agency fiscal year 2016.” CY 2016 level IV salary is capped at $160,300 and CY 2017 salaries are capped to $161,900 for section 8 and section 9 funds. 

Take a look at the full notice for further details.

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

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