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Project-Based Vouchers: Lessons from the Past to Guide Future Policy
July 30, 2024 @ 12:00 pm
ic integration in neighborhoods may be more beneficial than within a particular property, leading to better outcomes for children and lower crime rates.[59] Similar reasoning supported another change in the PBV cap for “small” properties.[60]
The revised Project Cap policy also recognizes that project-basing is an important strategy to make it easier for families to benefit from voucher subsidies in tight markets. The new policy allows up to 40 percent of units in a property to receive PBV assistance if it is located in a ZIP code area where the rental vacancy rate is less than 4 percent or rents are high relative to the surrounding metropolitan area or county.[61]
Innovative PBV Policies Should Be Maintained and Apply to Any Newly Funded Federal Project-Based Rental Subsidies
The major PBV policy innovations Congress enacted in 2000, with subsequent modifications, have stood the test of time. Rapid expansion of the PBV program by more than 700 percent from 2010 to 2022 demonstrates its real-world acceptance.[62] Despite initial concerns about whether PHAs would choose to operate a PBV program, and whether owners and developers would partner with them and accept the limitations on the share of units in a property that can have project-based assistance, and the possible turnover risks of the Resident Choice requirement, most medium- and large-sized PHAs now operate a PBV program. (See Appendix Table 3.) More than 1 out of 9 households receiving housing voucher subsidies live in PBV units, though that rate differs substantially by agency.[63] PHAs have also opted to shift more than 60 percent of public housing units to PBVs through the Rental Assistance Demonstration rather than direct PBRA contracts with HUD, despite the more stringent policies that apply to the Resident Choice requirement under a PBV contract.[64]
After operating for more than two decades, the revamped PBV program has become an effective tool to provide long-term rental subsidies for a wide variety of purposes, including providing rental homes for low-income families in tight markets,[65] making LIHTC units more affordable,[66] increasing service use in veterans’ supportive housing,[67] and preserving various types of HUD-assisted housing.
The two policies that most distinguish the PBV program from other federal project-based rental assistance programs are the requirements for Project Cap and Resident Choice, discussed in detail above. Together, these policies promote mixed-income properties and expand neighborhood choices by encouraging PHAs to select properties in lower-poverty areas to receive PBV contracts. The policies also allow access to tenant-based vouchers, which enable families to choose to live in neighborhoods with higher-performing schools, or are in closer proximity to well-paying jobs, rather than neighborhoods where HUD-subsidized properties are often located.[68] The policies also bring market-like discipline to property maintenance and management by ensuring that all residents — those receiving a federal rent subsidy as well as those paying market rents — can afford to move out of the property or neighborhood when it no longer meets their needs.
Even without an increase in housing vouchers, the PBV program likely will continue to grow and remain a key tool to secure affordable housing opportunities, particularly in markets that are challenging for use of tenant-based vouchers and for people who need supportive services to retain their housing, such as some individuals with disabilities or those who are experiencing homelessness, including veterans. Policymakers should retain the key innovations underlying the 2000 and later statutory changes in the PBV program — the Project Cap and Resident Choice policies — as well as the related rent and other incentives to locate properties in higher-opportunity neighborhoods, and not expand the current cap on the share of vouchers an agency may project-base. HUD should take steps to ensure key policies are being enforced and work with practitioners, residents, and other stakeholders to learn more about the operation and impact of key program features. These innovations should also be incorporated in any new investment in expansion or preservation of properties with project-based rental assistance, including public housing.
a Congress enacted the Project-Based Voucher (PBV) program in 1998, as section 8(o)(13) of the U.S. Housing Act (USHA) inserted by the Quality Housing and Work Responsibility Act (QHWRA), section 545 of the appropriations bill for the Departments of Veterans Affairs and Housing and Urban Development for fiscal year 1999, Pub. L. 105-276, October 21, 1998. QHWRA merged the housing certificate and voucher programs into a modified housing voucher program, including a project-based voucher option. The merger did not take full effect until 2001. As of 2000, HUD had not issued rules for the program, but had instructed PHAs to rely on the then-existing rules for the Project-Based Certificate (PBC) program, enacted in the Housing and Community Development Act of 1987, section 148, Pub. L. 100-242 (February 5, 1988). See 64 Fed. Reg. 56894 (October 21, 1999). This column relies on those rules and the U.S. Housing Act as amended by QHWRA.
b Department of Housing and Urban Development, “HUD: Back in Business, Fiscal Year 2001 Budget Summary,” https://archives.hud.gov/budget/fy01/backinbus01.pdf, p. 20; 2001 Budget Appendix, section 217. The Clinton Administration’s budget proposal did not include any changes in the 1998 statutory language for PBVs.
c H.R. 4635, as passed by the House of Representatives on June 21, 2000, and the Senate on October 2, 2000.
d Before the merger of the housing certificate and voucher programs took full effect in 2001, only housing certificates could be project-based.
e HUD’s 2005 final rule interpreted USHA section 8(o)(13)(B), 42 U.S.C. 1437f(o)(13)(B), concerning “available” tenant-based funding, to mean 20 percent of the new funding (budget authority) for the PHA’s HCV program committed by HUD for the year in which the PHA enters into a PBV contract with the owner. All prior-year PBV contracts still in effect counted towards the 20 percent cap, as well as any new commitments in the funding year. Future reductions in annual budget authority did not invalidate PHAs’ existing PBV commitments. 24 C.F.R. 983.6, 70 Fed. Reg. 59892, 59916 (October 13, 2005).
f HUD rules established the limitation on the duration of the contract. See 24 C.F.R. 983.151(b) and (c)(1995)(one to five years); 24 C.F.R. 983.3(d)(1998) (amount of committed assistance must be within available funds).
g HUD’s 2005 final rule imposed a five-year limit on the duration of any extension but allowed an unlimited number of extensions. PHAs were not permitted to offer an extension until the final year of the contract. 24 C.F.R. 983.205, 70 Fed. Reg. 59923.
h HUD had weak standards concerning neighborhood criteria applicable to properties selected for project-based certificate assistance due to rehabilitation. “Site and neighborhood standards,” 24 C.F.R. 983.6, 60 Fed. Reg. 34719, July 3, 1995. While the rule referenced applicable fair housing requirements, it was phrased broadly and allowed local interpretations and subjective judgments. The criteria that applied only to newly constructed properties (identical to current PBV policy at 24 C.F.R. 983.57(e)) were more specific and stronger.
i PHAs’ PBV program policies must be “consistent with” their PHA plans, a set of five-year and annual public documents describing local housing needs and agencies’ major discretionary policies to address them. Section 8(o)(13)(C), 42 U.S.C. 1437f(o)(13)(C). HUD’s authority to disapprove components of the PHA plan is limited by statute (U.S. Housing Act section 5A(i), 42 U.S.C. 1437c-1(i)), and over time HUD has substantially reduced its review of the plans.
j Congress did not define “existing” housing. In initially implementing some of the 2000 statutory changes, HUD defined the term as units that comply with HUD’s Housing Quality Standards (HQS) at the time of selection or need less than $1,000 of work per unit to qualify. “Revisions to PHA Project-Based Assistance Program; Initial Guidance,” 66 Fed. Reg. 3605, 3607 (January 16, 2001). In the final rule implementing the 2000 changes, HUD substituted the concept of units that “substantially comply” with HQS at the time of selection in place of any dollar threshold, but without defining the new concept. 24 C.F.R. 983.3, 70 Fed. Reg. 59892, 59914 (October 13, 2005).
k Families’ required rental contributions in PBV units is 30 percent of adjusted income, or the PHA’s required minimum rent, whichever is higher, similar to other HUD project-based rental assistance programs. 42 U.S.C. 1437f(o)(2)(C). This statutory limit was incorporated in the general policies governing the merged housing voucher program Congress enacted in 1998 and has remained unchanged. It means that the unit rent (including any allowance for tenant-paid utilities) can never exceed the applicable payment standard, and families are never required to pay the extra costs for rents above the payment standard, unlike the policies applicable to regular tenant-based vouchers.
l The 1998 PBV provision did not include language concerning maximum unit rents. The table assumes that the bill’s general provisions concerning maximum subsidies for housing vouchers would apply.
m Initial rents must also be “reasonable” under the same policy that applies to all housing vouchers. Section 8(o)(10)(A) of the U.S. Housing Act, 42 U.S.C. 1437f(o)(10)(A).
n 24 C.F.R. 983.203(c)(3)(1995).
a Public Law 106-377, 114 Stat. 1441, section 232 (October 27, 2000), amending U.S. Housing Act sec. 8(o)(13), 42 U.S.C. 1437f(o)(13). HUD implemented many of the statutory amendments shortly afterward by notice. See 66 Fed. Reg. 3605 (January 16, 2001). Comprehensive regulations for the revamped program took effect on November 14, 2005. See 70 Fed. Reg. 59892 (October 13, 2005).
b Most of the subsequent changes listed here were enacted by Section 106 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), Pub. L. 114-201 (July 29, 2016). HUD made most of the HOTMA changes effective by notice, see 81 Fed. Reg. 73030 (October 24, 2016), 82 Fed. Reg. 5458 (January 18, 2017), and 82 Fed. Reg. 32461 (July 14, 2017) (technical corrections), and issued substantial Implementation Guidance in Notice PIH 2017-21 (October 30, 2017). HUD published proposed rules to formally implement the statutory amendments and make other changes to the PBV regulations on October 8, 2020 (85 Fed. Reg. 63664) and published final regulatory revisions May 7, 2024 (89 Fed. Reg. 38224). Most of the final changes were effective June 6, 2024 (see PIH 2024-19, issued June 5, 2024), and generally did not alter current PBV contracts.
c 42 U.S.C. 1437f(o)(13)(E) includes an option for PHAs to provide “comparable tenant-based assistance” in lieu of a federal housing voucher, but it is unclear if any PHA has made use of this option. HUD substantially improved the definition of “comparable tenant-based assistance” in the May 2024 final rule (89 Fed. Reg. 38259, 38305).
d HUD’s 2005 final rule interpreted 42 U.S.C. 1437f(o)(13)(B) to mean 20 percent of the amount of budget authority committed by HUD for the PHA’s HCV program for the year in which the PHA enters into a PBV contract with the owner in addition to prior PBV contracts. Future reductions in budget authority did not invalidate existing commitments. 24 C.F.R. 983.6, 70 Fed. Reg. 59892, 59916 (October 13, 2005).
e Due to changes in voucher renewal funding policy, there were about 220,000 more vouchers authorized than funded in 2021. Using HUD data for 2021, CBPP estimates that 2.40 million vouchers were funded, compared to 2.62 million authorized vouchers. Twenty percent of the 220,000 difference increased the total national authorization of PBVs by about 44,000 units. PHAs can commit authorized but not funded vouchers to PBV contracts for occupancy in a subsequent year, and then receive supplemental funding for this purpose when the units are ready for occupancy under a long-standing policy in annual appropriations bills. PHAs that have a particularly large gap between authorized and funded vouchers are most affected by the 2016 statutory change.
f PHAs may designate PBVs as part of this additional 10 percent authority if they are part of a contract entered into on or after April 18, 2017, the effective date of the HOTMA provisions HUD put into effect by notice, or are added to a contract initially entered into prior to that date, and meet the revised criteria in 24 C.F.R. 983.6(d)(1). For PBV units reserved for certain foster youth, the relevant effective date is on or after December 27, 2020 (24 C.F.R. 983.6(d)(2)).
g The category of homeless individuals and families includes families with children or unaccompanied youth under age 25 and others who meet definitions of “homeless” under other federal statutes that are not directly applicable to HUD programs but are referenced in HUD’s continuum of care regulations, 24 C.F.R. 578.3.
h Supportive housing for disabled or elderly families counts toward the additional 10 percent authority for purposes of the Program Cap (see 42 U.S.C. 1437f(o)(13)(B)(ii)), but supportive housing for all types of households, including families with children, qualifies for an exception to the Project Cap (see 42 U.S.C. 1437f(o)(13)(D)(ii)(I)).
i In 2020, as part of the Fostering Stable Housing Opportunities (FSHO) amendments to the Family Unification Program (FUP) authorized under Section 8(x) of the U.S. Housing Act of 1937 (42 U.S.C. 1437f(x)), Congress amended the PBV section of the U.S. Housing Act to add PBVs reserved for certain foster youth aging out of foster care to the types of PBVs required to be excepted from the Program and Project Caps. Section 103 of division Q of the Consolidated Appropriations Act, 2021 (Pub. L. 116–260, 134 STAT. 2170, December 27, 2020).
j In the final rule implementing HOTMA PBV changes, HUD defined “Area where vouchers are difficult to use” as a census tract with a poverty rate of 20 percent or less, a ZIP code area where the rental vacancy rate is less than 4 percent, or a ZIP code area where 90 percent of the Small Area FMR is more than 110 percent of the metropolitan area or county FMR. 24 C.F.R. 983.3. This new definition likely will substantially increase the ability of many PHAs in tight markets, or that are seeking to expand housing opportunities in lower-poverty areas, to benefit from the additional 10 percent of PBV authority.
k HUD used its discretion under 42 U.S.C. 1437f(o)(13)(B)(ii) to include in the final rule eligibility of units replacing certain former public housing units off the original site for the additional 10 percent authority (see 24 C.F.R. 983.6(d)(1)(v)), explaining its rationale at 89 Fed. Reg. 38270.
l In the proposed rule to implement the 2000 amendments, HUD included units with other types of HUD project-based rental assistance toward the Project Cap. But the agency modified the 2005 final rule to comply with the statutory language that explicitly applies the Project Cap only to units assisted under the PBV paragraph of the housing voucher section of the U.S. Housing Act, 42 U.S.C. 1437f(o)(13). See discussion regarding final 24 C.F.R. 983.56 in 70 Fed. Reg. 59892, pp. 59893-4 and 59902-3 (October 13, 2005). It is not clear whether the negotiators involved in the final 2000 legislation intended to undermine the goal of income-mixing in this manner, or if the language was poorly drafted. The Conference Report implies an intent to impose a stricter Project Cap: “To promote mixed income developments, only 25 percent of the units in a multifamily building may have project-based assistance.” Conference Report 106-988, p. 114, October 18, 2000.
m The Housing and Economic Recovery Act of 2008 (HERA), Pub.L. 110-289. 122 STAT. 2871 (July 30, 2008), section 2835(a)(1)(A), changed the word “building” in the sub-paragraph of the PBV statute entitled “Income Mixing Requirement” to “project,” and defined “project” to include multiple contiguous buildings or buildings on contiguous parcels of land.
n The 2016 HOTMA amendments deleted the blanket exception from the Project Cap for disabled families and broadened the supportive services exception for purposes of the Project Cap to include all households “eligible for [as opposed to receiving] supportive services that are made available to the assisted residents of the project….”. Taken together, these changes were intended to minimize the use of PBVs to house people with disabilities in segregated settings without available services, reinforce the principle that participation in services should be voluntary, and facilitate funding of supportive services through Medicaid or other health care programs.
o New 42 U.S.C. 1437f(o)(13)(B)(ii) and (D)(ii)(IV), inserted by HOTMA. In addition to numerous HUD rental assistance programs, the excluded units for which replacement PBVs do not count toward either the Program or Project Cap include PBVs in units that previously were rent-restricted under two large non-HUD federal programs, LIHTC and rural housing loans. To be excluded, PBVs must replace units that received assistance or were subject to rent limitations under a program specified in 24 C.F.R. 983.59 within five years prior to PBV commitment.
p 24 C.F.R. 983.205, 70 Fed. Reg. 59923 (2005).
q In HERA, Congress overrode the regulatory limitations on the duration and timing of extensions that HUD imposed in the 2005 final rule. HOTMA lengthened the duration of initial contracts and extensions from 15 years specified in HERA to 20 years. HUD’s final HOTMA PBV rule allows PHAs and owners to agree to one or more extensions at any time, not to exceed a remaining term of 40 years. 24 C.F.R. 983.205(b).
r PHAs’ PBV program policies must be consistent with the PHA Plan. HUD’s authority to disapprove components of the PHA Plan is limited by statute, and over time HUD has further limited its review considerably. However, all PHAs must certify that they “will carry out their [public housing] agency plan in conformity with” civil rights laws and that they will affirmatively further fair housing. U.S. Housing Act section 5A(d)(15), 42 U.S.C. 1437c-1(d)(15). HUD’s May 2024 final PBV rule significantly expanded the importance of the PHA plan as a public repository of PHAs’ PBV-related discretionary policies. 24 C.F.R. 983.10.
s See 24 C.F.R. 983.57(e), 70 Fed. Reg. 59918 (October 13, 2005). While this change was intended to avoid the delays and uncertainty HUD inspection created for project-basing transactions, it also may have undermined other portions of the rule concerning adherence to fair housing requirements.
t These additional streamlining policies were primarily added by HERA, with further clarification in HOTMA to override HUD’s restrictive regulations. HUD’s May 2024 final rule also provided PHAs with additional flexibilities, particularly to encourage improvements in unit quality.
u This flexibility applies only as part of a public housing-related initiative. HOTMA also modified HUD’s regulatory definition of PHA-owned units by adding new section 8(o)(13)(N).
v HUD rules had prohibited PHAs from adding additional units to existing PBV contracts after the first three years without adhering to competitive selection procedures. HOTMA added new section 8(o)(13)(F)(ii) to override that restriction. HUD implemented the HOTMA change effective April 17, 2017 and made it permanent in the final rule (24 C.F.R. 983.207).
w HOTMA added new section 8(o)(13)(O), overriding HUD’s prior restrictions on how these two types of vouchers could be used.
x HOTMA added new section 8(o)(13)(F)(iv), providing flexibility to PHAs and owners to include additional provisions regarding PBV contract continuation, termination, or expiration. HUD’s May 2024 final rule restricts this flexibility to options specified in HUD forms.
y HUD has not established or proposed any such requirements, though HUD added 24 C.F.R. 983.54(f) to the PBV regulations allowing it to add oversight requirements for projects with PBVs in more than 40 percent of units at any time by notice subject to public comment (not formal rulemaking).
z Congress did not define “existing” housing. In its Initial Guidance implementing some of the 2000 statutory changes, HUD defined the term as units that comply with HUD’s Housing Quality Standards (HQS) at the time of selection,or need less than $1,000 of work per unit to qualify. 66 Fed. Reg. 3605, 3607 (January 16, 2001). In the final rule implementing the 2000 changes, HUD substituted the concept of units that “substantially comply” with HQS at the time of selection in place of any dollar threshold, but without defining the new concept. 24 C.F.R. 983.3, 70 Fed. Reg. 59892, 59914 (October 13, 2005).
aa HUD’s 2024 final PBV rule significantly altered the definition of “existing” housing. It clarified the meaning of units that “substantially comply” with HUD’s quality standards to include the objective standard that any repairs needed for all proposed PBV units in a project to fully comply with HQS will likely be completed within 30 days.
bb Families’ required rental contribution in PBV units is 30 percent of adjusted income, or the PHA’s required minimum rent, whichever is higher, similar to other HUD project-based rental assistance programs. 42 U.S.C. 1437f(o)(2)(C). This statutory limit was incorporated in the general policies governing the merged housing voucher program Congress enacted in 1998 and has remained unchanged. It means that the unit rent (including the allowance for tenant-paid utilities) can never exceed the applicable payment standard, and tenants are never required to pay the extra costs for rents above the payment standard, unlike the policies applicable to regular tenant-based vouchers.
cc HUD’s fiscal year 2024 budget request indicates HUD will seek a statutory amendment to increase the PBV rent cap to 120 percent of FMR, similar to the flexibility now available for HCVs. See HUD, Tenant-Based Rental Assistance Fiscal 2024 Congressional Justification, pp. 6-11, https://www.hud.gov/sites/dfiles/CFO/documents/2024_CJ_Program_Template_-_TBRA.pdf.
dd HUD’s 2024 final PBV rule gave PHAs and owners more flexibility about the timing of any agreement not to reduce PBV unit rent due to a substantial decrease in the applicable Fair Market Rent below the original rent, and included detailed policies on use of OCAF adjustments. 24 C.F.R. 983.302.
ee 24 C.F.R. 983.251(c)(7). Groups representing owners of PBV properties sought this change on the grounds that it would reduce the duration of vacancies.
ff HOTMA section 106(a)(7)(B) modified 42 U.S.C. 1437f(o)(13)(J) to allow this change in tenant selection preferences related to people with disabilities and supportive services, which are often subject to funding-related eligibility restrictions. HUD implemented the change subject to guidance on the interaction between this provision and other legal requirements. See 82 Fed. Reg. 5458, 5469-5471 (January 18, 2017). Final 24 C.F.R. 983.251(d) includes the option to have a selection preference for a PBV unit for “families who qualify for voluntary services, including disability-specific services, offered at a particular project,” while at the same time prohibiting preferences for persons with a specific disability unrelated to eligibility for offered services.
Note: This table only includes PHAs that administer the Housing Choice Voucher (HCV) program. Some PHAs only administer public housing units. PHAs with 550 or fewer HCVs, public housing, or a combination of the two are defined as “small” for purposes of most planning obligations. See Small Public Housing Authorities Paperwork Reduction Act, Title VII of the Housing and Recovery Act of 2008, Pub. L. 110-289, 122 STAT, 2863.
Sources: Department of Housing and Urban Development (HUD) authorized public housing unit data from 2021 Picture of Subsidized Households; HUD administrative project-based voucher data from January 2022; HUD January 2022 authorized voucher data from the Two-Year Projection Tool; MTW PHAs as of December 31, 2022.
Appendix: Methodology for Calculating Project-Based Vouchers Subject to the Statutory Cap
The paper includes an estimate of the share of authorized vouchers that are project-based at each PHA for purposes of determining whether PHAs are close to reaching the statutory cap on project-basing (known as the “Program Cap”). That cap permits agencies to project-base up to 20 percent of their authorized vouchers, plus another 10 percent if the added vouchers are used for units that house people experiencing homelessness or veterans, provide supportive housing for adults age 62 or older or people with disabilities, or are in areas where the poverty rate is 20 percent or less, or tenant-based vouchers are otherwise difficult to use, and are committed on or after April 18, 2017 — the effective date of most of the relevant HOTMA changes.
Units that were previously subject to federally required rent restrictions or received another type of long-term HUD subsidy (including all units converted to project-based vouchers under the Rental Assistance Demonstration, or RAD) and units awarded under HUD-Veterans Affairs Supportive Housing (VASH) project-based voucher set-asides are not counted when determining whether PHAs comply with the cap.[69]
Our estimate of the percentage of vouchers project-based at each PHA is based primarily on HUD administrative data as of January 1, 2022. Our calculation of the numerator — that is, the number of project-based vouchers counted against the cap — starts with the total number of PBVs at the agency, including (1) leased units, (2) units that are under a housing assistance payment (HAP) contract but not currently leased, and (3) units that are under an agreement to enter into housing assistance payment contracts (AHAP). The HUD administrative data we used did not include planned PBV units that are not yet covered by an AHAP or HAP, so those units are not included in our analysis.
Consistent with HUD policy in effect, we then subtracted from the numerator the number of VASH PBV units at the agency that resulted from special allocations by HUD and an estimate of the number of the agency’s PBVs that are part of RAD.[70] RAD units were all previously assisted through other long-term HUD subsidies (primarily public housing), and are excluded from the PBV cap calculation based on HUD’s implementation of 2016 amendments to the U.S. Housing Act or HUD’s RAD implementation policies. Our estimate of the number of RAD units includes units identified in the January 2022 HUD data as leased RAD PBV units. The RAD program does not use AHAPs, so none of the AHAP PBV units identified in HUD’s data should be RAD units.
Some of the unleased PBV units under HAP in the January 2022 HUD data are RAD units, but the data do not indicate how many. We estimated this figure using December 2021 HUD RAD program data on the total number of PBV units converted under the first component of RAD (which primarily consists of former public housing units). We assumed that the number of unleased RAD PBV units equaled the lower of (1) the total number of unleased PBV units in the January 2022 HUD data; or (2) the total number of RAD first component PBV units according to the December 2021 RAD data minus the number of leased first component units according to the January 2022 HUD PBV data.
The number of units we were able to subtract from the numerator misses some types of formerly assisted units that would be excluded from HUD’s program cap calculations. First, it misses unleased PBV units under the second component of RAD, which converts units from several small HUD rental assistance programs. The January 2022 HUD data identifies leased second component RAD PBV units, but we do not have PHA-level data on the total number of these units so we could not estimate how many of the unleased PBV units are second component RAD units. Second, and more significantly, we were not able to identify and subtract PBVs in any formerly assisted units that were not converted under RAD (including non-RAD units in “blended” conversions that include some RAD PBVs and some non-RAD PBVs). For these reasons, our estimates of the number of units that should be subtracted err on the low end, and our estimate of how many PBVs count against the cap (and how many PHAs are close to reaching the cap) should be viewed as conservatively high.
We were also not able to identify how many PBVs were committed on or after April 18, 2017, and how many fall into the categories that allow agencies to project base an added 10 percent of their vouchers.[71] Partly for this reason, this paper’s analysis focuses on how many PHAs have project-based 25 percent or fewer of their vouchers, which leaves them with capacity to project-base at least another 5 percent of their vouchers if the added PBVs are targeted on one of the categories that qualifies for the added 10 percent, or are excluded from the program cap calculation. Some of those PHAs, however, may not be able to add more vouchers that are not in those categories.
We calculated the denominator for the project-basing percentage starting with the number of authorized vouchers at each agency as of January 2022 (based on HUD’s Two-Year Projection Tool), and then subtracted the same VASH and RAD units we deducted from the numerator, consistent with HUD’s policy at Notice PIH 2017-21 (October 30, 2017), Attachment F and Appendix I (including the linked PBV Program Cap Calculation Worksheet, updated July 2022).
