Sneak Preview: Guidance Clarifies Eligibility for PHA Emergency Grants

(The following was excerpted from a recent Thompson Grants Compliance Expert article.) The Department of Housing and Urban Development (HUD) recently updated its guidance for public housing agencies (PHAs) applying for Emergency Safety and Security grants, providing more details on eligible and ineligible uses for the funds, as well as acceptable methods to resolve charges or lawsuits that had made a PHA ineligible to receive such funding.

Each year, Congress sets aside funds within the Public Housing Fund appropriation to create a reserve for emergencies and natural disasters. PHAs facing an emergency situation or a natural disaster are eligible to apply for and receive funds from the reserve under the Emergency Safety and Security grant program provided that they comply with certain requirements (e.g., funds provided because of a disaster are only available to the extent that needed repairs are in excess of reimbursement from insurance and other sources, such as other state and local funds). The intent of these grants is to provide one-time, project-specific assistance for emergency safety and security items that could not be absorbed within a PHA’s capital fund budget.

HUD “will fund expenses to address safety and security emergencies that pose an increased threat to the health and safety of PHA residents … until the set-aside funding is exhausted,” the updated guidance (PIH-2022-05) states. “PHAs must describe and explain how they have experienced an increased awareness of the immediate threat to the health and safety of their public housing residents in order to be considered for this funding.” Emergency Safety and Security grant funding is limited to a total of $250,000 per PHA per federal fiscal year.

The guidance, which supersedes guidance last issued in September 2020 (PIH-2020-25) states that recipients may use grant funds to purchase, install, repair or replace capital needs items including, but not limited to, fencing, lighting systems, emergency alarm systems, window bars, deadbolt locks and doors. While it also allows ― as it did in previous guidance ― funding for security systems and cameras, including digital video recorders and secure wi-fi transmission of video signals, the guidance now emphasizes that per provisions in §200.216 of the uniform guidance, grantees are prohibited from using grant funds to purchase, lease or renew or extend any contracts for security equipment produced by the Huawei Technologies Company or the ZTE Corporation (or any subsidiary or affiliate of such entities).

Another allowable use for these funds now includes salaries for maintenance staff conducting program-eligible activities (e.g., installing, replacing or repairing carbon monoxide detectors, security camera systems, fencing, lighting systems, emergency alarm systems, doors, locks or window bars). The guidance also notes that funds can be used for carbon monoxide alarms and carbon monoxide detectors.

(The full version of this story has now been made available to all for a limited time here.)

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