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HUD - VA Supportive Housing Program

 The VA’s Role in HUD-VASH
 HUD-VASH Operating Requirements
 HUD-VASH Reporting Requirements
 Project-Based Voucher (PBV) Requirements

         VA and HUD Commitment

• VA is committed to the Federal Plan to Prevent and
End Homelessness and is implementing a Five-Year
Plan to Eliminate Homelessness among Veterans, which
calls for coordinated strategic cooperation with our
community partners
• VA and HUD have established the nation’s largest
supported permanent housing initiative
• HUD and VA work together on the U.S.
Interagency Council on Homelessness

The HUD-VASH Program combines:

 • 30,000 Housing Choice vouchers to PHAs
    Have 301 participating PHAs
 • Case management and supportive services to
   promote housing stability and recovery
    Almost 1,000 case managers
    In 2010, over 100 Substance Use Disorder
    Specialists on VA case management teams


VA HUD-VASH Case Managers
 determine clinical eligibility and
 homeless status
PHAs determine if the Veteran meets
 HUD criteria for income and is not a
 lifetime registered sex offender under a
 State sex offender registration program.

         VA Eligibility Criteria
Eligible for VA Health Care
Homeless per McKinney Vento definition
Needs, and agrees to participate in, case management

Does NOT include the following:
   Prior treatment or other homeless programs
   Treatment compliance
   Period of sobriety
   Income verification by VA
   Criminal Background Check
               McKinney Vento
 Definition of Chronic Homelessness

A chronically homeless Veteran is:
 • A VA healthcare eligible person who has been
 • Continuously homeless for 1 year or more,
 • At least four episodes of homelessness in the
   past 3 years

              HEARTH Act
The HEARTH Act amends McKinney Vento
• Changes include defining:
  – Prevention and re-housing
  – Homelessness for families
  – Allows specific doubled up housing situations
  – Changes time-frame for transitional housing
  situations from 30 days to 90 days
  VA and HUD are working towards implementing
   the HEARTH Act in HUD-VASH

Promoting a low barrier, engaging approach
• Veteran assessed using standardized assessment
   o New HOMES template will be piloted soon
• Veteran to obtain Vesting physical, if needed
• Focus on issues related to housing stability
   o Employment, income and legal assistance
   o Family/Social concerns
• Seek mental health and/ or Substance Use
  disorder evaluations, if Veteran agrees

       “Housing First” Approach
 Offers permanent housing with treatment & supportive
  services to homeless individuals
 Early engagement/low demand model
 Few requirements for treatment participation prior to
 A model that allows us to target and assist the most
  chronically homeless
 Priority and focus is on housing

       Housing Recovery Plan
 This plan reflects the goals of the Veteran, identifying
   o Strengths
   o Barriers to maintaining housing placement
 Establish a process to monitor the progress of the plan
   o Housing stability (rent paid, following rules, etc)
   o Employment and income needs met
   o Legal and financial issues (credit history) resolved
   o Physical, mental, social and substance
     use health supported

     PHA and Housing Process
 Referral is made in writing to the PHA from the VA
 Case manager assistance (if needed):
  o Complete forms
  o Work out transportation issues
  o Locate suitable housing following PHA guidelines
  o Request PHA inspection and approval of selected unit
  o Address obstacles and barriers
  o Facilitate communication between PHA and Veteran

          Housing Placement
• Housing Assistance Payments (HAP) Contract
  issued by PHA to the landlord following passing
  unit inspection
• If indicated, case manager assists the Veteran and
  landlord to complete the lease
• Prepare for the move by helping Veteran
  – Turn on utilities
  – Obtain furnishings and supplies
  – Plan and arrange move in

Case manager and Veteran meet with PHA to discuss
successful graduation from case management
 If PHA has a regular Housing Choice Voucher (HCV)
  available for the Veteran, then the veteran will convert
  to the HCV program, and the HUD-VASH voucher will
  become available for another eligible homeless Veteran

 If PHA does not have a regular voucher available, the
  Veteran continues using the HUD-VASH voucher until it
  is no longer needed

      HUD-VA High Priority Goal
Place 30,000 Veterans in HUD-VASH permanent
 Time period: October 1, 2009 – June 30, 2012
 Report to Office of Management and Budget on a
  quarterly basis – FY 11 metrics expected to stay
  the same
   • # of referrals from VAMCs to PHAs
   • # of vouchers issued to families
   • # of units leased

  HUD-VA High Priority Goals
Strategies for meeting High Priority Goals
  Improve reporting tools
  Produce monthly reports on progress
  Monitor PHA and VA progress toward goals
  Conduct on-site reviews for high and low performers
  Establish action plans for improvement
  Determine best practices in use
  Involve multiple training strategies and opportunities
  Improve evaluation tool
                                                FY 2008 - FY 2010
                                       Total Allocated Vouchers: 29,500

                                MT                                                                                                   ME
                                95                                                                                                   95
                                                 95                                                                                              NH
       OR                                                                                                                     VT                 95
                                                               250                                                            70
       550           ID
                     90                         SD                           WI                                        NY
                                                155                          285                                      2,505
                                     WY                                                   MI                                                     RI
                                     95                                                  655                                                     95
                                                                 IA                                                                       CT
                                                NE              200                                                                NJ     315
              NV                                                                                              1,020
                                                145                                               OH                               500
              585                                                               IL     IN
                          UT                                                                      750                                      MD
                                                                               580    370
                          155          CO                                                               WV                      DE        405
                                       690            KS              MO                                215                      60
  CA                                                                                          KY                  475
 4,680                                                285             370                                                      DC
                                                                                                                  NC           490
                                                                                      TN                          560
                                                         OK                           605
                      670            NM                               AR                                    SC
                                     215                              185                                   320
                                                                               MS       AL           GA
                                                                               180      440         1,075
                                                  TX                   LA
                                                 2,005                 420

   95                                                                                                          FL
                                                                                     AWARDS                                   Puerto Rico
                                                                                       30 - 95

                HI                                                                    145 - 200
Guam           145
                                                                                      215 - 370
                                                                                      405 - 585

                                                                                      605 - 4,680

                                              HUD-VASH National Utilization
                                                    September 2008 - August 2010
 Veterans Screened         Veterans Receiving Case Management            Veterans Referred to PHA           Vouchers Issued       Veterans Housed


         Veterans Screened: 42,963
         Veterans Receiving Case Management:
         Veterans Referred to PHA: 25,995







         Oct   Nov   Dec    Jan   Feb   Mar   Apr    May   Jun   Jul   Aug   Sept   Oct   Nov   Dec   Jan    Feb   Mar     Apr   May   Jun   Jul    Aug
                                         FY 09                                                                     FY 10

          HUD-VASH Operating
Published in the Federal Register on May 6, 2008,
  but part of the section on portability/mobility was
  not included.
The missing section was published in the Federal
  Register on May 19, 2008.
The complete text can be found at:

   Operating Requirements

• Normal HCV requirements at 24 CFR 982 apply
  to HUD-VASH vouchers unless they are waived
  or an alternative requirement has been specified,
  as discussed in this presentation.

        HUD-VASH Eligibility
• The VA first identifies homeless veterans and
  determines initial eligibility.
• Unlike the earlier HUD-VASH program from the
  1990s, veterans are not required to be
  chronically mentally ill or have chronic substance
  abuse disorders.
• All eligibility screening is conducted by the
  VAMC, except for income eligibility and sex
  offender status.
       HUD-VASH Eligibility
• Homeless veterans must agree to participate in
  case management in order to receive a HUD-
  VASH voucher.
• After VAMC screening determines a veteran is
  initially eligible, the veteran is referred to the
• Written documentation of the referrals must be
  maintained in the tenant file at the PHA.

       HUD-VASH Eligibility

• Veterans found eligible by the PHA will be
  issued a voucher.

        Denial of Assistance
• If assistance is denied, the PHA must promptly
  send the denial notice that states the reason and
  provides for an informal review.
• A copy of this notice must be sent to the
  veteran’s VAMC case manager.

               PHA Screening

• PHA screening limited to:
   – Income eligibility
   – Lifetime registration under a state sex offender
     registration program.
• Under portability, the receiving PHA must also
  comply with the HUD-VASH screening

 Prohibited Screening Criteria

 At the time of admission, PHAs may not determine
  eligibility or deny assistance for the following:
• Homeless status
• Money owed to the PHA
• Criminal or drug activity
(This prohibition applies to all family members at
  the time of admission.)
            Income Eligibility

• The PHA determines eligibility in accordance
   with 24 CFR 982.201.
• Income targeting requirements do not apply to
   HUD-VASH vouchers.
  (However, PHAs may choose to include the
   admission of extremely low income HUD-VASH
   families in their income targeting numbers for the
   year the family admitted to HUD-VASH.)
  Lifetime Sex-Offender Status

• If the homeless veteran is subject to a lifetime-
  sex offender registration requirement under a
  state program, the PHA cannot issue a voucher.
• If another family member is the lifetime
  registrant, the family may be eligible if that family
  member is removed from the household.

          Initial Search Time

• HUD-VASH families must have a housing search
  term of at least 120 days.
• Any extensions, suspensions and progress
  reports will remain under policies in the PHA’s
  administrative plan, but will apply only after 120

           Initial Lease Term

• The initial lease term may be less than 12
  months, even if this is not the prevailing market
  practice .

         Eligible Housing

• All housing types eligible in the regular HCV
  program including special housing types such as
  SROs, congregate housing and group homes.
• Standard HCV requirements regarding unit size,
  HQS and payment standards apply.

         Eligible Housing

• Unlike regular HCV participants, HUD-VASH
  families may live on the grounds of a VAMC in
  units owned by the VA.

          Case Management

• Participation in case management is an
  eligibility requirement of the HUD-VASH
• HUD-VASH assistance may be terminated if the
  family refuses, without good cause, to participate
  in required case management as verified by the

 When Case Management is no
       longer required:
• However, a VAMC’s determination that case
  management is no longer needed is not grounds
  for termination of HCV assistance.
• When such a determination occurs, a family may
  be offered a regular voucher to free up the HUD-
  VASH voucher for another eligible homeless

       Turnover of HUD-VASH
• Upon turnover, HUD-VASH vouchers must
  continue to be issued to eligible veteran families
  referred by the VAMC.


• Since leasing of HUD-VASH vouchers will be
  dependent on referrals from the VAMC, the unit
  months and budget authority associated with the
  vouchers will NOT be included in the SEMAP
  leasing indicator.
• Utilization of HUD-VASH vouchers will be
  monitored separately.

   Mobility/Portability Policies

• Are dependent on whether the family moves
  within or outside of the referring VAMC’s
  catchment area.

       Move Within a VAMC’s
         Catchment Area
• The HUD-VASH family can move under
  portability within the referring VAMC’s catchment
  area if the same VAMC continues to provide
  case management.
• Some VAMCs have more than one partner PHA.
• If the receiving PHA did not have its own
  allocation of HUD-VASH vouchers, the receiving
  PHA MUST BILL the initial PHA.
       Move Within a VAMC’s
         Catchment Area
• If the receiving PHA has its own allocation of
  HUD-VASH vouchers, the receiving PHA may
  either absorb the family or bill the initial PHA.
• In either case, the VA must be consulted prior to
  the move and agree that case management
  services will be provided.

      Move Within a VAMC’s
        Catchment Area

• Non-VASH PHAs should be advised of program
  requirements including using the HUD-VASH
  code when preparing the form HUD-50058 for
  the family.
• They should also be given the name and
  contact information for the veteran’s VA case
 Move OUTSIDE the catchment
  area of the referring VAMC
• A HUD-VASH family can move to another HUD-
  VASH catchment area, if the referring VAMC
  confirms that the new HUD-VASH VAMC has an
  available case management slot and the new
  VAMC’s partner PHA has an available HUD-
  VASH voucher.

Move OUTSIDE the catchment
 area of the referring VAMC

• HOWEVER, the receiving HUD-VASH PHA must
  use one of its HUD-VASH vouchers to absorb
  the family.

             MTW Agencies

• HUD-VASH vouchers must be administered in
  accordance with HUD-VASH notices.
• Not eligible for fungibility under an agency’s
  MTW agreement.
• Must be reported separately from MTW
  vouchers, using the regular form HUD-50058.

     HUD-VASH HAP Funding

• HUD-VASH Housing Assistance Payments
  (HAP) funds may not be used to support a
  greater number of unit months than have been
  awarded for the PHA’s HUD VASH program
  under the PHA’s ACC.
• PHAs must track HUD-VASH HAP funding
  separately from other HCV HAP funding.

 Voucher Management System
      (VMS) Reporting

• HUD-VASH vouchers leased and HUD-VASH
  HAP expenses are to be reported to VMS
  monthly using the appropriate VMS fields.

VMS Records & Quality Review

• Each PHA must retain appropriate records to
  support VMS submissions as they are subject o
  on-site review by HUD.
• VMS data are subject to review by our Quality
  Assurance Division (QAD).

         VMS Quality Review

• Recalculation will occur if a QAD review
  demonstrates that costs were incorrectly
  reported resulting in excess funding.

  HUD-VASH Renewal Funding
    For Existing Programs

Renewals are based on leasing and cost data.
The FY’08 HUD-VASH vouchers have been
The FY’09 HUD-VASH vouchers will be renewed in
  Calendar Year 2011.

 HUD-VASH Renewal Funding
   For Existing Programs

HUD will schedule a separate broadcast on HUD-
 VASH funding renewal issues.

         Administrative Fees

• Administrative fees are based on the unit months
  leased as reported in VMS.
• Administrative fees are advanced on a monthly
• The amount advanced is based on the most
  recent validated month of VMS data.

        Administrative Fees

• HUD-VASH administrative fees are included with
  the HCV fees that are sent out monthly.

      HUD-VASH and FSS

• HUD-VASH participants may benefit from
  participation in the HCV/FSS program.
• FSS coordinators should coordinate with VA
  case managers to obtain appropriate training
  and services for the HUD-VASH participant.

    Voucher Homeownership

• HUD-VASH participants may participate in the
  HCV Homeownership option.

   Frequently Asked Questions
 If a veteran is interested in participating in the
  HUD-VASH program, who should he or she
   Any interested homeless veterans should
    contact their local VAMC directly. HUD has
    posted a list of VAMCs and participating PHAs
    on the HUD-VASH website.

   Frequently Asked Questions

 Is it acceptable for the VA case managers to
  review original documents on the PHA's behalf?
   The PHA is responsible for income and citizenship
    verifications. The case manager may compile the
    documents and look them over, but the PHA has the
    final say regarding their appropriateness.

 Frequently Asked Questions

Can the PHA deny admission to an adult
 family member, other than the veteran, based
 on the previous behavior of that family?
   No. The prohibition against screening families
    for anything other than lifetime sex offender
    status applies to all family members, not just the

  Frequently Asked Questions
 Can a veteran receive assistance through both the
  HUD-VASH program and the Homelessness
  Prevention and Rapid Re-housing Program (HPRP)?
   Six types of HPRP assistance are available for
    eligible families or individuals: security deposits,
    utility deposits, rental assistance, utility
    assistance, moving cost assistance,
    and hotel/motel vouchers.

 Frequently Asked Questions

● Families or individuals cannot receive duplicative
  forms of assistance from Federal, state or local
  subsidy programs.
● Therefore, families participating in the HUD-VASH
  program cannot receive HPRP rental or utility
  assistance, but they are eligible to receive HPRP
  assistance for security deposits, utility deposits, and
  moving costs.

 Frequently Asked Questions

 While HUD-VASH families cannot receive HPRP
  rental or utility assistance, HPRP can be used to help
  the household pay for up to 6 months of back
  payments on rent or utilities owed from previous
  housing situations.
 For more information on HPRP and local agencies
  that administer the program, visit the HPRP website

   Frequently Asked Questions
 What procedures must the PHA follow when adding a
  member to the assisted HUD-VASH family?
   The provisions of 24 CFR 982.551(h)(2) apply
    when a family member is added after occupancy.
   Other than the birth, adoption, or court-awarded
    custody of a child, any other family member must
    be approved in accordance with the PHA’s policies.

  Frequently Asked Questions
 What happens when a veteran, as the head of
  household of a family with a HUD-VASH voucher,
  commits an act of domestic violence?
   The Department is currently developing guidance
    that will provide PHAs with further guidance on the
    implementation of VAWA protections under 24 CFR
    part 5, subpart L.
   Until such guidance is available, PHAs should keep
    in mind the following points:

  Frequently Asked Questions

● When a veteran’s family member is receiving
  protection as a victim of domestic violence, dating
  violence, or stalking, and the veteran is the
  perpetrator of such violence, the victim must
  continue to be assisted.
● Dating violence, domestic violence, and stalking are
  each violations of the family obligations under 24
  CFR 982.551(l). Therefore, the perpetrator may be
  terminated from assistance for committing such acts.

 Frequently Asked Questions
● Upon termination of a perpetrator’s HUD-VASH
  voucher due to the perpetrator’s acts of domestic
  violence, the victim receiving protections should be
  given a regular HCV if one is available.
● The perpetrator’s HUD-VASH voucher should be
  used to serve another eligible veteran family.
● If a regular HCV is not available for the victim, the
  victim will continue to utilize the HUD-VASH

Frequently Asked Questions

● In the case of the victim utilizing the HUD-
  VASH voucher upon termination of the
  perpetrator, this HUD-VASH voucher must be
  issued to another eligible veteran family upon
  the voucher’s turnover.

  Frequently Asked Questions
 Can a participant use a HUD-VASH voucher to move
  long distance? For example, a HUD-VASH voucher
  wants to move from California to Florida.
   This type of move is permissible if the Florida
    VAMC can serve the family and its partnering
    PHA has an available HUD-VASH voucher. The
    receiving PHA in Florida must absorb the family.

  Frequently Asked Questions
 When a HUD-VASH family no longer needs case
  management and can convert to the regular HCV
  program, is the family subject to the PHA’s
  waiting list?
  No, the family is not subject to the PHA’s waiting list,
   because the family is already a participant in the
   PHA’s HCV program.

   Frequently Asked Questions
 If a HUD-VASH family is denied assistance or has its
  assistance terminated, is it entitled to an informal review
  and informal hearing, respectively?
    Yes. Families are entitled to an informal review or
     hearing in accordance with the PHA’s administrative
     policies, and in accordance with 24 CFR 982.554 or
     982.555, as applicable.

   Frequently Asked Questions
 What happens to the voucher if the homeless veteran
   The PHA could use one of its own vouchers, if
    available, to continue assisting this family and free up
    the HUD-VASH voucher for another veteran family.
   If a regular voucher is not available, the family would
    continue utilizing the HUD-VASH voucher.
   Once the HUD-VASH voucher turns over, however,
    it must go to a homeless veteran family.

  Frequently Asked Questions

 What happens to the voucher if there is a divorce?
    Since the set-aside of HUD-VASH voucher is for
     veterans, the voucher must remain with the
     veteran in the case of a separation of divorce.

  Frequently Asked Questions

 Can a PHA terminate a family at the time of a
  reexamination for a violation that occurred before the
  HUD-VASH program?
  Example: The family owes money to the PHA. The
  PHA cannot deny admission for that reason, but
  would like to terminate the family at reexam time.
    A PHA cannot terminate a family for a reason that
     cannot be used for denying admission.

 Frequently Asked Questions
 However, a HUD-VASH family can be terminated for
  program violations that occur after the family is
  admitted to the HUD-VASH program.
 Prior to any termination action, the PHA is strongly
  encouraged to contact the VA case manager to
  determine if there are extenuating circumstances
  that should be considered to avoid the termination.

  Frequently Asked Questions

 Can a PHA refuse to readmit veterans that have been
  terminated from the HUD-VASH program due to
  serious lease violations, program fraud, criminal
  activity, etc?
   In accordance with the HUD-VASH Operating
    Requirements, a PHA cannot deny HUD-VASH
    assistance to a veteran for any grounds under 24
    CFR 982.552 and 982.553.

  Frequently Asked Questions
 Therefore, for any reason other than a member of the
  household being subject to a state lifetime registration
  requirement, the PHA may not deny HUD-VASH
  assistance to a veteran that is re-referred by the VA
  case manager.
 In order to avoid such cases, prior to the PHA’s
  termination of the veteran, HUD recommends that the
  PHA contact the VA case manager to discuss the
  reasons for the veteran’s potential termination.

 Frequently Asked Questions
 PHA and VA case manager should work together to
  agree on the appropriate action and determine if
  termination of the veteran’s assistance can be
 If it is decided that termination is the appropriate
  action, the PHA staff and VA case manager should
  discuss the circumstances under which, if any, the
  VA may choose to re-refer the veteran family.

  Frequently Asked Questions
 What safeguards has HUD put in place to ensure
  VASH funding continues to be available to homeless
  veterans upon turnover of a HUD-VASH voucher?
   HUD will track these vouchers in the Public and
    Indian Housing Information Center (PIC) system,
    through an additional code (VASH) on the family
    report (Form HUD- 50058).

  Frequently Asked Questions

 Will HUD-VASH vouchers be fully renewed?
   It is the Department’s intent to fully renew all HUD-
    VASH vouchers. However, such renewals are
    always subject to Congressional appropriations.

          HUD-VASH Reporting

• HUD issued PIH Notice 2010-12 on April 13,
• The notice has been posted to the website for

                  Initial PHA

• The initial PHA is the PHA that partners with the
  VA Medical Center and issues vouchers when a
  homeless veteran family is referred

• The initial PHA will either deny the family
  assistance or issue a voucher.

         Issuance of Voucher
• If the PHA issues a voucher to the family, the
  PHA must enter a 50058 report into PIC where
  line 2a=10 (Issuance of Voucher) and VASH is
  recorded on line 2n.
• In cases of portability, a receiving PHA must
  issue a voucher of its own and is required to
  enter a 50058 report into PIC for action code 10.

      Leasing by Initial PHA
• When the family is leased by the Initial PHA, a
  50058 must be entered into PIC with action code
• The VASH code must be maintained on line 2n
  throughout the participation of the family.

     Leasing by Receiving PHA
• In cases of portability, the receiving PHA must enter action
  code 2a=1 (new admission) if this is the initial lease-up or
  2a=4 (port-in).
• The receiving PHA must continue to enter VASH on line 2n.
• The receiving PHA MUST always bill the initial PHA for
  tracking purposes.
• If the receiving PHA also has been awarded HUD-VASH
  vouchers , it can absorb the family if case management can
  be provided.

     Long Distance Portability

• Applies to families that move out of the
  catchment area of the original VAMC

  Reporting requirements for the receiving PHA
  are the same.

• However, these families must be absorbed
       Portability Attachment

• There is an Attachment to Portability form for the
  HUD-VASH program also available on the
  HUD-VASH website with reporting and
  alternative requirements for the receiving PHA

       Project-Based Vouchers

• HUD published PIH 2010-23 on this subject
  effective June 25, 2010

    Limits on HUD-VASH PBV
• No more than 50 percent of a PHA’s HUD-VASH
  allocation of tenant-based vouchers may be
  project based.

• HUD-VASH PBV units are counted in the
  maximum 20 percent of voucher budget
  authority that may be project based.

   HUD-VASH PBV Proposals

• Headquarters must approve a PHA’s proposal to
  project base HUD-VASH voucher units.
• Proposals may be for existing, new construction
  and substantially rehabilitated units.
• PHA PBV proposals must be supported by the

        Proposal Information
• Why the PHA wants to project-base these
  vouchers rather than providing tenant-based

• Success rate of HUD-VASH voucher holders
  and other voucher holders

• Utilization rate in SEMAP
 Proposal Information cont’d
• Amount of time, if any, HUD-VASH vouchers
  would be shelved for development

• A description of the project (details in notice)

     Continued Assistance for
       Families that Move
• PBV regulations provide that a family may
  terminate the lease anytime after the first year of

• Also, the PHA must offer the family continued
  tenant-based assistance in the form of a voucher
  or comparable tenant-based rental assistance.

     Continued Assistance - 2

• A HUD-VASH family that no longer requires
  case management cannot be terminated for this
• The PHA may offer the family a regular voucher
  to free up the HUD-VASH voucher.
• If there is no regular voucher available, the
  family retains its HUD-VASH voucher.

 Continued Assistance - 3
a. If a HUD-VASH voucher is not available at the time
the family wants to move, the PHA could require the
family to wait 180 days for a HUD-VASH voucher.
b. If a HUD-VASH voucher is still not available, the
family must be allowed to move and the PBV
assistance would be replaced with a regular voucher
assistance unless the unit is taken out of the PBV

  Continued Assistance - 4

c. If after 180 days, a HUD-VASH voucher does
not become available and the PHA does not
have sufficient funding to attach assistance to
the PBV unit, the family may be required to
remain in its PBV unit until such funding
becomes available.

    HUD-VASH PBV Set Aside
• HUD will make available approximately 500
  PBVs for HUD-VASH families
• Funding will be competitive
• PHAs can request no more than 50 PBVs
• These PBVs will not count against the 50% limit
  that a PHA can project-base now.




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