Frequently Asked Questions
(And Answers)

These FAQs are meant to answer general questions for consumers and industry stakeholders who are directly impacted by COVID-19.

Human Rights Watch: “The CDC’s moratorium is just a national baseline. States are free to enact stronger tenant protections. However, many states do not currently have active eviction moratoriums. Among the states that do, the actual protections vary greatly. Some provide fairly robust protection, but other moratoriums have flaws similar to those in the CDC’s.”

Human Rights Watch: “The most obvious risk is homelessness, but the risks do not stop there. Eviction is always a public health problem, and this issue is especially relevant during a pandemic. Those facing homelessness often resort to sleeping outdoors or staying in overcrowded shelters. Others move in with family or friends, leading to more crowded dwellings, and consequently, a greater risk of transmitting or catching Covid-19.

Previous failures to adequately protect tenants have already had deadly consequences. According to a recent UCLA study, expiring state eviction moratoriums between March and September, when the national moratorium was issued, led to over 400,000 Covid-19 cases and nearly 11,000 excess deaths in the 27 states studied that allowed their protections to lapse.”

Congressional Research Service: “The COVID-19 pandemic is likely to affect states’ ability to meet their work participation standards. Employment losses, disruptions in education, and the inability of states to engage recipients in group activities could all result in lower participation in work or job preparation activities. Additionally, if the economic dislocation results in higher assistance caseloads, a state’s caseload reduction credit would be reduced, resulting in a higher effective (after-credit) participation standard for the state to meet. 

The rules governing the TANF work participation standards cannot be waived, other than through new legislation. However, the U.S. Department of Health and Human Services has the ability to reduce or waive the penalty on states for failing to meet the TANF work participation standard. HHS has said that it would exercise its authority to provide states with relief from the penalty for not meeting participation standards to the maximum extent possible.”

HUD: “Yes, those can be eligible expenses for preventing and responding to COVID-19, per PIH Notice 2020-07.”

Source | HUD

HUD: “For the HCV Program, in the recently published PIH Notice 2020-18, HUD has expanded the use of CARES Act HCV Administrative Fees to include as an eligible use of these funds: 

Costs to facilitate and coordinate with local schools and local governments receiving funds from the U.S. Department of Education for the education of students in the program. 

Costs for the technological needs of program participants with school aged children being homeschooled as a result of the pandemic that are not and will not be provided through other Federal, state, or local governments. 

For the public housing program, as provided in PIH Notice 2020-07, the PHA can use federal funds authorized under the CARES Act to facilitate and coordinate with local schools and local governments receiving funds from the Department of Education for the education of students in public housing households including internet connection infrastructure and tablets or other low- cost computers for students.”

Source | HUD

HUD: “As described in PIH Notice 2020-07, supplemental Operating Funds may be used to pay for regular operations of the public housing program. They can cover unexpected increases in operating costs or cover normal operating costs, whether or not there are unplanned reductions in revenues related to increased unemployment. 

For residents that experience a loss in income, the PHA is required to process requests for interim reexaminations commensurate with such lost income; therefore, PHAs should not have significant Tenant Accounts Receivable due to COVID-19. However, residents are still responsible for all rent charges. If residents still do not pay their rent, PHAs can set up repayment agreements to catch up on unpaid rent. The CARES Act eviction moratorium prohibited pursuing evictions or assessing fees for unpaid rent until July 24, 2020. 

Write-offs of tenant account receivables as bad debt is a separate issue. The allowance method is the prevailing method for writing off receivables pursuant to Generally Accepted Accounting Principles (GAAP). Using the allowance method, as long as there is still a possibility that a receivable could be collected, it would remain on the Balance Sheet. PHAs would normally write off the receivable only when the tenant moved and was no longer reachable.” 

Source | HUD

HUD: “If a resident has zero income but did not report the decrease of income in a timely manner due to COVID-19, HUD strongly encourages PHAs to consider extenuating circumstances in their interim reexamination policy to allow for retroactive adjustments. This PHA policy may reduce the potential hardship on families and eliminate or significantly reduce the amount a family may owe for back rent. See FAQ OC16 for further detail. 

PHAs have discretion to establish local policies for repayment agreements (e.g., the term of the monthly payment amount and length of agreements), including instances where a resident’s income may become zero. When setting the monthly repayment amount, PIH Notice-2018-18 recommends that the monthly retroactive rent payment plus the amount of rent the tenant pays at the time the agreement is executed should be affordable and not exceed 40 percent of the family’s monthly adjusted income. Per this Notice, the PHA has discretion to establish a different threshold in their policy. For example, if a family’s income decreased to zero income, the PHA would still execute a repayment agreement for both parties agreeing to the retroactive rent amount owed, but the PHA could (1) suspend the agreement for a set period of time, (2) schedule quarterly check-ins with the family to reevaluate circumstances, or (3) wait until the family reports an increase in income. The PHA could also execute a repayment agreement for an amount that does not exceed the PHA’s minimum rent or an amount that is determined affordable to the family per the 24 CFR Part 5. 

PHAs are reminded that the terms of the agreement may be renegotiated and the monthly payment amount for existing repayment agreements can be restructured if there are changes (decrease or increase) in the family’s income.” 

Source | HUD

HUD: “While this software would help the PHA maintain social distance, which prevents transmission of COVID-19, it also improves the operational efficiency of the Public Housing and HCV management and operations. As such, it is a normal Operating Fund and HCV Administrative fee expense, and eligible for CARES Act funds. See PIH Notice 2020-07 for public housing and PIH Notice 2020-18 for HCV Administrative fees.”

Source | HUD

HUD: “HUD is working on a CARES Act web portal that will be used for the required quarterly reporting to HUD based on Section 15011. Further guidance is in PIH Notice 2020-24. 

As described in PIH Notice 2020-07 and PIH Notice 2020-08 (later superseded by PIH Notice 2020-18), the CARES Act requires that recipients of $150,000 or more of CARES Act funding submit certain information regarding the use of CARES Act funds. Additional information is in PIH Notice 2020-24. 

This reporting is required for “covered recipients,” defined as any entity that receives covered funds that amount to more than $150,000. PHAs that receive CARES Act funds that amount to more than $150,000 will be subject to this additional reporting requirement based on the total amounts awarded, not each individual grant award. 

As outlined in the Office of Management and Budget (OMB) memorandum, M-20-21, existing reporting requirements are anticipated to meet the requirements of Section 15011, but the content and format for this reporting is still under development and will need to be reviewed against current program practices. The Department will work in coordination with OMB to ensure that this requirement can be fulfilled by recipients of CARES Act funding in a manner that utilizes to the greatest extent possible existing reporting streams, providing the necessary transparency and accountability with minimal additional burden.” 

Source | HUD

HUD: “Yes, as long as the funds are used by the applicable expiration dates. For public housing, funds must be expended by December 31, 2021 as described in PIH Notice 2020-24. For HCV Administrative fees, PIH Notice 2020-18 extends the period of availability for the CARES Act HCV Administrative fees through June 30 , 2021; and the CARES Act HAP funding for per unit cost (PUC) increases is likewise available through June 30 , 2021. The period of availability for supplemental HAP funding for shortfalls is December 31 , 2020, and for funds awarded for per unit cost increases is June 30 , 2021. This option is available for all PHAs, not just small PHAs. 

Source | HUD

HUD: “There is no requirement that PHAs target those who are directly affected by COVID-19. The funding is intended to support new Mainstream vouchers for eligible families— those that include a non-elderly person with a disability. PHAs will use their regular waiting list for these additional Mainstream vouchers just as PHAs do with their existing Mainstream vouchers. PHAs may add or modify preferences based on the needs in their community but it is not required. 

Source | HUD

BDO: “Even during times of significant uncertainty, nonprofit organizations must keep their mission as the North Star guiding their response. Many organizations may face interruptions to programming as a result of reduced travel and social distancing—but that doesn’t mean furthering your mission should take a backseat.

Organizations must be prepared for an extended crisis environment as a pandemic fuels significant threats including cyberattacks, fraud, regulatory changes, supply chain disruptions and bankruptcies. Organizations need to take a step back and put together a crisis management team and a response program that includes executive leaders, investment advisors and communications and program staff. This team should assess how to maintain as much normalcy as possible while limiting exposure risks to both their own employees and the constituencies they serve. With cashflows for many nonprofits significantly disrupted, liquidity and sustainability must also be a driving force of decision-making. Nonprofits should also view the crisis as a catalyst for needed change, as the sense of urgency, cooperation, need for innovation and decisiveness that emerges in crisis can also help secure viability for the organization. As organizations look to the future, they should apply lessons learned and update their risk program.”


Source | BDO

BerryDunn: “Many nonprofits with endowments are considering ways to balance an increased reliance on their investment portfolios with the responsibility to protect and preserve the spending power of donor-restricted gifts. Some things to think about include the existence (or absence) of true restrictions, spending variations under the Uniform Prudent Management of Institutional Funds Act (UPMIFA) applicable in your state, borrowing from an endowment, or requesting from the donor the release of restrictions. All need to be balanced with the intended duration and preservation of the endowment fund.” 

Source | BerryDunn

Michigan State University: “The first consideration regarding when employees can reasonably expect to go back to work is a scientific one. Not all employees will be willing to receive the vaccine, even though some employers may attempt to compel employees to take them. Also, two current vaccines approved in the U.S. require two doses and protection against COVID-19 is not immediate. Furthermore, no vaccine has been found to be 100% effective. Thus, even if every employee were to be vaccinated, there is no guarantee that they will all have immunity from the vaccine, particularly in light of the fact the coronavirus mutates.


What does it all mean? This means that the previous way of housing employees, doing work and interacting with customers may not return to how organizations conducted business pre-COVID-19 — if ever at all. 


Even if contagion from COVID-19 weren’t a concern, many employees have gotten accustomed to working from home. While working from home has its downsides, such as challenges surrounding separating work from home, working from home offers many conveniences, including eliminating the daily commute to and from work, not having to buy or dry clean work clothes and the ability to engage in family and personal demands like helping a child with schoolwork. Many employees may be reluctant to readily give up those cost savings and conveniences, and may feel as though it is a violation of the psychological contract (that is, the unspoken agreement between an employer and employee regarding how the employee will be treated) and resent or protest having to return to work on a full-time basis.

National Low Income Housing Coalition: “The EIDL program offers states and territories low-interest federal disaster loans through the SBA. These loans are distributed to small businesses and private, nonprofit organizations that have experienced a substantial economic impact due to the COVID-19 outbreak. 

Currently, small businesses and private, nonprofit organizations in all states and territories are eligible to apply for assistance through the EIDL program because of the COVID-19 outbreak. Typically, a state or territory’s governor must first work with SBA’s Office of Disaster Assistance to submit a request for EIDL assistance. SBA has the authority to approve the request and issue an EIDL declaration for the state or territory. Once an EIDL declaration is issued, EIDL loan applications are made available for small businesses and private, nonprofit organizations throughout the state or territory.”

FEMA: To be eligible for Public Assistance, a PNP applicant must show that it has:

  • A ruling letter from the Internal Revenue Service granting tax exemption under sections 501(c), (d), or (e) of the Internal Revenue Code of 1954; or
  • Documentation from the state substantiating that the non-revenue producing organization or entity is a nonprofit entity organized or doing business under state law.

Eligible PNPs must also own or operate an eligible facility.2 For PNPs, an eligible facility is one that provides an eligible service, which includes education, utilities, emergency, medical, custodial care, and other essential social services.

Private entities, including for profit hospitals or restaurants, are not eligible for assistance from FEMA under Public Assistance. However, state, local, tribal, and territorial government entities may contract with private entities to carry out eligible emergency protective measures. In these cases, FEMA will reimburse the eligible applicant for the cost of eligible work, and the applicant will then pay the private entity for the provision of services.

Source | FEMA

Community Foundation Public Awareness Initiative: “More than 325 U.S. community foundations in all 50 states, plus the District of Columbia, have created relief funds to support those affected by COVID-19 — directing critical relief to local nonprofits and partnering with local governments and health organizations to help contain its spread.

To date, these efforts have already mobilized $536.6 million to help those in need in every corner of the country. Announced grant making to date totals $175 million. (See the latest update.)

A full listing of verified funds, by state, is provided below.


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