Understanding HUD Reporting: Due Dates and Key Points

02 Dec 2024 Understanding HUD Reporting: Due Dates and Key Points

Authored by H. Brent Stratton, CPA

Are you a Public Housing Agency (PHA) struggling to keep track of HUD reporting deadlines? Navigating the complexities of HUD reporting can be challenging. This comprehensive guide will provide you with a clear understanding of the due dates and key points for HUD reporting, specifically focusing on the Public Housing Assessment System (PHAS) submissions.

Key HUD Reporting Deadlines

• Unaudited Financial Data: Public Housing Agencies (PHAs) must submit unaudited financial data to HUD within two months after the end of their fiscal year. The Public Housing Assessment System (PHAS) scores these submissions nightly, allowing PHAs to view their FASS-PH (Financial Assessment Subsystem for Public Housing) score the following day.
• Audited Financial Data: Audited financial data must be submitted no later than nine months after the end of the fiscal year. Before submission, an Independent Public Accountant (IPA) must approve the data and mark it as “IPA Agree.” Once approved, the PHA can submit the audited data for scoring and review. If discrepancies arise between unaudited and audited data, HUD will prioritize the audited data for FASS score generation.

Important Considerations for HUD/LIHTC Compliance

• Submission Process: HUD evaluates PHAS submissions electronically through its PIH-REAC (Public and Indian Housing Real Estate Assessment Center) system, ensuring that all data meets HUD standards and compliance requirements.
• Scoring and Review: After receiving all necessary submissions, HUD posts the PHA’s composite score online within a month, assuming there are no issues with the submissions or completed physical inspections.

Consequences of Missing HUD Reporting Deadlines

Failure to meet HUD reporting deadlines can have significant consequences for PHAs. These penalties may include:

• FASS Score Deductions: Late submissions can result in deductions in a PHA’s FASS score, which can negatively impact funding and program eligibility.
• Financial Penalties: HUD may impose financial penalties on PHAs that consistently fail to meet reporting deadlines, impacting their financial standing.
• Program Restrictions: In severe cases, persistent non-compliance with reporting requirements could lead to restrictions on program participation or a reduction in funding.
• Loss of Trust: Consistently missing deadlines can erode trust between the PHA and HUD, potentially hindering future collaborations and support.

Strategies to Avoid HUD Reporting Penalties:

To prevent these consequences, PHAs should:

• Establish a Robust Reporting System: Implement processes to track HUD reporting deadlines and ensure timely submissions, avoiding potential penalties.
• Allocate Sufficient Resources: Ensure that staff have the necessary time, training, and tools to complete HUD reporting tasks accurately.
• Seek Professional Assistance: If a PHA is struggling to meet deadlines, it is advisable to seek professional assistance.

At Haynie & Company, we specialize in PHAs through the complexities of HUD reporting. Contact us today for expert help or to submit an RFP, or to schedule a free consultation.