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OHFA (is) was PBCA, maybe again soon?

Performance Based Contract Administration is responsible for making payments under a HAP contract, overseeing tenant recertifications, conducting annual management occupancy reviews (MOR), and resolving tenant issues in project based Section 8 housing

 Ohio Housing Finance Agency (OHFA) was awarded the Performance Based Contract Administration (PBCA) contract from HUD for Ohio beginning on October 1, 2011.
Tenants in HUD assisted buildings which are administered under the PBCA should be receiving letters about the change soon.  At that time, tenants and advocates made recommendations on how OHFA can use tenant input to improve the quality of HUD housing in Ohio. 

Here's our July 27, 2011 comments.


In 2011, HUD stopped the bidding process and issued a NOFA (what's that?) was issued.  OHFA re-applied for the NOFA competition, but before an announcement of "winners" could be made...a court temporarily blocked implementation.

At the Ohio Preservation Network meeting on 7/25/13, OHFA reported that HUD is planning to release the announcement of PBCA winners on August 1, 2013.  Stay tuned for details!

It is unclear what scope of work may be assigned to the PBCAs as the HUD Multifamily Reorganization is implemented.  Stay tuned for details.

PBCA Implementation: COHHIO concerns and recommendations

(some discussed at 7/19 meeting, others new.


1. Handling tenant complaints

    • accept tenant questions and complaints from in writing, by toll free phone number and by email. Respond in the same format unless tenant requests a different form of response.

    • permit 3rd party complaints from stakeholders (family members, health and social service providers). Probably need to require some kind of tenant authorization before accepting a 3rd party complaint.

    • accept "tenant on tenant complaints" and reviewed later with manager to determine how manager dealt with the problem.

    • post OHFA contact info on site and monitor posting when conducting a site visit.

    • follow up with tenant complainant after management provides self certification of resolution of the complaint. Was the problem resolved to the tenants satisfaction?

    • use tenant complaints in planning Management Review site visits.

    • give tenants referrals to 3rd parties for problems which cannot be addressed by OHFA, eg.

      • Legal Aid Society for legal questions.

      • COHHIO for questions about tenants organizations and assistance finding 'stabilizing' services.

      • Local fair housing agency and/or COHHIO for fair housing questions, complaints

2. Conducting Management Operations Review (MOR) site visits.

    • notice to the tenants one month before site visit to submit comments, questions, concerns.  In particular ask tenants to provide information about conditions which the reviewer would be unlikely to observe, eg.  parking lot lighting, standing water after a rain, etc.

    • provide a questionnaire to tenants prior to MOR so that tenants can comment on "the landlord tenant relationship" portion of the MOR.  Two suits and the property manager walking up to a tenant at random in a common area and asking "how do you like living here?" is unlikely to yield useful responses.

    • When units are inspected, the reviewer, not manager, should select  units at random on the day of the inspection.  Presumably manager has sent out a 24 hour notice to tenants in advance of the MOR site visit so that there are no
      access issues.

    • Ask to see  the written grievance procedure and other mandatory documents.  Don't just ask if it is on site.  Ask for documentation of how grievances have been addressed.

    3. Using MOR reports to identify Preservation risks

    • Need a system for reviewer to flag risk factors up to the OHFA level, not wait for a random review.

    • OHFA should develop a policy on when and how to share risk indications with OPC, other preservation advocates?

 Notes & Links

HUD explains

Spencer Wells,
Jul 27, 2011, 1:08 PM