RAD for PRACs Notice available for Public Comments; NAHMA requests member feedback by March 8
Please see the below message from HUD, regarding their RAD for PRACs notice. The notice is available here on NAHMA’s website. NAHMA is requesting members provide feedback, byFriday, March 8. You can provide comments to me, at . NAHMA will also work with our Senior Housing Committee to draft comments.
RAD for PRACs Notice Published on the
Drafting Table for Public Feedback
The FY 18 Appropriations Act authorized the conversion of properties assisted by Section 202 Project Rental Assistance Contracts. HUD is in the process of revising the RAD Notice to include a new Section 4 that would provide implementation instructions for the conversion of Section 202 PRACs under RAD. Prior to implementation, a draft Section 4 has been posted to HUD’s Office of Multifamily Housing’s “Drafting Table” where HUD will be accepting public feedback for the next two weeks. Following consideration of public feedback received, the Office of Recap will proceed toward incorporation of the new Section 4 into a revised RAD Notice.
We encourage all interested parties to review and provide feedback on this draft, including on the following:
Is this document well organized?
Is the guidance set forth in this document clear? Are there sections that are unclear?
Are the proposed terms of the Use Agreement reasonable and adequate?
Are there unique features of 202 PRACs or the elderly population that the properties serve that HUD has not adequately accounted for in this Notice?
The draft Section describes an option to convert to Section 8 Project-Based Rental Assistance (PBRA) or to Project Based Vouchers (PBV) What is the degree of interest in PBV conversions? Please note that while HUD has developed the framework for a process for seamlessly funding a conversion from PRAC to PBRA, funding a conversion from PRAC to PBV is likely to be more complex.
Does HUD provide adequate avenues for stakeholders to provide feedback on the direction of the RAD program and, if not, what additional measures for public feedback should HUD consider?
Please send written comments via e-mail to by Tuesday, March 12th.