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HUD is seeking public comment regarding the burden faced when applying for or maintaining eligibility for HUD’s housing programs. The agency says that administrative hurdles and extensive paperwork weigh heavily on vulnerable populations and prevent people from accessing benefits they are eligible for. The request for comment was published in the Federal Register on July 13, 2023. The public comment period ends Aug. 14, 2023. This request for comment is in keeping with HUD’s recent efforts to simplify its processes. For example, HOTMA, which will soon go into full effect, aims to streamline aspects of HUD’s rental assistance programs — including making changes to resident income calculation and reviews.

HUD’s questions About Burdensome Paperwork

HUD is seeking input on the following questions and asks responders to identify the specific question number to which they are responding.

  1. How can HUD reduce its public program administrative burden across HUD’s public benefits programs? Specifically, is there information currently being collected by HUD or HUD program administrators ( e.g., Public Housing Authorities, State and local governments, non-profit recipients of CDBG programs, Multifamily Housing owners, FHA lenders) that have no apparent use or benefit or can be streamlined? Additional prompts commenters may wish to consider when developing their response to this question:
    1. Are there eligibility requirements or questions on a form for a specific benefit or program that are particularly difficult to understand, respond to effectively, demonstrate initial compliance with, or maintain compliance with?
    2. Does the form include documentation requirements that could be made simpler, less frequent, or more helpful or flexible to meet the ability of respondents to gather the documentation?
    3. Does completing the form involve multiple touchpoints with either agency or third-party personnel, such as through calls to helplines, in-person visits or consultations, or solicitation of help from other non-profit, legal aid, private legal counsel, or social service agencies?
    4. Are there significant discrepancies in how certain forms are implemented across States, localities, housing authorities, or other HUD program administrators responsible for collecting this information? Could HUD provide more standardized or template forms or web application tools to reduce the need for non-Federal program administrators to develop their own forms or web applications?
    5. Are there specific challenges that persons with physical, speech, other communication-related, or other disabilities face in these processes that HUD should further address? What strategies or tools might succeed in reducing the burden for these groups?
    6. Are there specific challenges that persons with limited English proficiency (LEP) face in these processes that HUD should further address? What strategies or tools might succeed in reducing the burden for these groups
    7. What specific challenges or barriers are experienced by other vulnerable sub-populations that may prevent individuals and entities from accessing benefits for which they are eligible? What strategies or tools might succeed in reducing the burden for these groups?
  2. Are there data currently collected by HUD or HUD program administrators that could be shared with other agencies or program administrators to reduce the information collection burden of those programs? Are there data currently collected by other programs or agencies that, if shared with HUD or HUD’s program administrators, could reduce the information collection burden of HUD’s programs? When responding, please be specific about HUD and other agency programs, including the form(s) used by HUD or the other agency and the specific data collected that could be leveraged.
  3. Are there data collected by HUD that are not currently aggregated and shared publicly that should be aggregated and shared publicly to increase the value of those data being collected? Please be specific about which data, the form number on which it is collected, and how HUD might aggregate the data to be useful for the public.
  4. How can HUD use artificial intelligence, machine learning, or other advanced data science tools to automate, augment, or otherwise streamline its various information collections and the processes they support? Please identify which collections or processes could be improved using these tools; how advanced data science tools could help to complete these forms or processes more quickly and without sacrificing accuracy or security or perpetuating bias against certain populations; and any estimated time or cost savings that could result from these improvements. Potential responses could include but are not limited to processes related to development approval, processing of multifamily mortgage insurance applications, and reviews of applications submitted in response to notices of funding opportunities.
  5. Please provide any other input relating to how HUD can better understand, identify, and reduce the public program administrative burden associated with HUD’s public benefits programs, including how HUD might better use technology to support data collection and data sharing.

How to Comment on HUD’s Requirements

There are three methods for submitting public comments. All submissions must refer to the docket number and title: [Docket No. FR-6381-N-01]; “Improving Access to Public Benefits Programs; Request for Comment.”

  1. Electronic Submission of Comments. Comments may be submitted electronically through the Federal eRulemaking Portal at www.regulations.gov. HUD strongly encourages commenters to submit comments electronically through www.regulations.gov.
  2. Submission of Comments by Mail. Comments may be submitted by mail to the Regulations Division, Office of General Counsel, Department of Housing and Urban Development, 451 7th Street SW, Room 10276, Washington, DC 20410–0500.
  3. Submission of Comments by Electronic Mail. Comments may be submitted by electronic mail to the Regulations Division, Office of General Counsel, Department of Housing and Urban Development at [email protected].

Joe Miksch is the Public Relations and Marketing Manager for US Housing Consultants.