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Michael Petruzzelli

, National Council for Behavioral Health

National Council Submits Comments on Supportive Housing Regulations

December 11, 2014 | Uncategorized | Comments
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Last week, the National Council submitted comments to the Department of Housing and Urban Development (HUD) commending its efforts to fully implement two supportive housing statutes. The comments, written in conjunction with the Corporation for Supportive Housing, urged HUD to issue further clarification on multiple fronts, clarifying the scope and depth of the proposed rule. The comments also recommended changes throughout, ensuring affordable housing options for individuals with mental health conditions and addictions disorders.   

The Section 202 Supportive Housing for the Elderly Act of 2010 and the Frank Melville Supportive Housing Investment Act of 2010 were critical pieces of legislation to help preserve existing supportive housing and create additional new units that tap into services provided through Medicaid. While HUD has moved forward on implementing some pieces of the enacted legislation, the proposed rule will make permanent some of those program requirements HUD has already implemented and implement several other changes that were made by the two statutes.

Highlights of the comments include:

  • Support for a new section that would make “debt-service” an eligible expense for units that are covered by the Enhanced Project Rental Assistance.
  • A recommendation to add language into the proposed definition of “frail elderly person” to include an older adult individual (50 years or older) who has experienced chronic homelessness.
  • A recommendation to align the Project Rental Assistance Program with other capital programs such as Low-Income Housing Tax Credits and HOME funds.
  • A recommendation to offer an uncomplicated waiver process for small buildings with 4-25 units that cannot meet the 25% cap for individuals with disabilities.

Click to read our full comments.