COVID-19 affordable housing updates: For rental property managers and owners

VHFA has suspended its physical inspections of properties and apartments until further notice. Property managers should contact VHFA with questions about compliance and asset management practices. Residents should continue to contact the organization responsible for property management with any questions or concerns.

To minimize health risks for building occupants, property managers should monitor guidance about COVID‐19 and provide up-to-date information to residents and staff.

Best practices for property managers

Example best practice responses:

Prevention measures:

Take common sense precautions to limit the spread of the virus

Cover mouth and nose with the inside of the arm or with a tissue when coughing or sneezing. Throw the tissue away immediately. Wash hands as soon as possible afterward.
Avoid close contact with people who are sick.
Avoid touching of eyes, nose, and mouth with hands.
Wash hands regularly for at least 20 seconds using soap and water.
Evaluate need for travel and provide safe travel information, such as the CDC's Travelers Health Notices.
Stay home if you are exhibiting cold or flu‐like symptoms or feel sick.
Ensure employees are aware of sick leave policies.

Inform tenants about preventing the spread of infection

Inform residents about ways to communicate with management (phone, e‐mail, mail) instead of office visits
Post visible, large print signage encouraging proper handwashing and discouraging unnecessary visitors, especially those who are showing cold or flu-like symptoms. The Centers for Disease Control (CDC) and the Institute for Real Estate Managment have materials available for print.

Consider limiting or restricting visitors

Housing operators are encouraged to limit or restrict non-essential visitors.
Some social service staff will still have to continue visiting to provide critical nutritional, medical, and personal care services, especially in senior housing. If appropriate, housing operators should discourage other service providers from physically visiting developments, directing them towards remote communications with residents.
Housing operators can also create a Visitor Log at common lobbies that will enable future contact tracing through the Vermont Department of Health in the event a resident, staff or visitor tests positive for COVID-19.
In all circumstances, housing operators must ensure that critical nutritional and medical services continue for residents and cannot lock all doors.

Perform additional cleaning of office work‐spaces and public access areas

Ensure repeatedly touched surfaces in the workplace, such as workstations, counter‐ tops and doorknobs are cleaned thoroughly and frequently.
Provide employees with cleaning products and encourage routine cleaning. See the CDC's guidance on effective cleaning and disinfecting products.
Make sure soap and hand sanitizer are available in rest rooms, kitchen and other high traffic areas.
If possible, install handwashing stations and/or sanitizer stations at common lobbies that serve multiple housing units.
Consider increasing outside air intake to the building to promote higher amounts of fresh air, or other similar measures as appropriate for property HVAC systems.

Plan for emergency or alternative office operations

Prepare a continuity/emergency operations plan for your business if you don't already have one in place. Make sure employees have reviewed and understand the plan.
Prepare to conduct some in‐person transactions (such as lease renewals, recertifications, rent payments, work orders) by phone, e‐mail, or other alternative methods.

Use screening questions to determine if appointments or maintenance requests should be rescheduled

Many management companies are limiting maintenance and other in-person interactions with tenants to only emergency or life-threatening issues. Although it is not possible to establish a comprehensive definition of what constitutes an emergency maintenance request; here is a list of possible scenarios:

1. Heating problems

3. Flooding or unstoppable leaks

4. Plumbing stoppage in a residence with one bathroom

5. Fire (the Fire Department should be called first)

Leases or management policies may provide further guidance as to what constitutes an emergency. Please exercise good judgment and apply reasonable standards when evaluating work orders. It may be appropriate for non-emergency work orders to be postponed. Managers are expected to log these requests and respond appropriately once it is safe to do so. Managers should screen residents prior to entering their homes.

The screening procedure is as follows:

Ask the individual if they have any of the following:
1. Respiratory symptoms
2. Fever
3. Sore throat
4. Cough
5. Shortness of breath
Ask the individual if they have:
1. Traveled internationally within the last 14 days to areas where COVID-19 cases have been confirmed. 
2. Worked in a health care setting that has confirmed COVID-19 cases
3. Had close contact with a person known to have Coronavirus (COVID-19)

If residents or staff answer yes to any of the following questions prior to an in‐person meeting or in‐unit non‐emergency maintenance request, reschedule the appointment (or attempt to conduct in an alternative way). If the request is an emergency, take additional safety measures:

Treat each unit as if it is an isolated positive case, and follow CDC social distancing and hygiene protocols at all times.<
Use Personal Protective Equipment (PPE), if available, disposable gloves at a minimum.
Keep at least 6-8 feet of space from other persons in unit
Wash hands thoroughly before and after entering unit.
Keep time in the unit as short as possible without compromising the required emergency repairs.

Please be aware that maintenance requests may be governed by the terms of your lease, Vermont Code, local codes, or other regulation. The above is general guidance and does not constitute legal advice. Please consult your legal counsel if you have any questions concerning your legal obligations.

Special guidance for senior housing:

Vermont Department of Disabilities, Aging and Independent Living (DAIL):
- Coronavirus Disease Recommended Precautions for Caregivers
Support & Services at Home (SASH):
- Tackling the COVID-19 Pandemic Statewide (4/20/20)
Centers for Disease Control (CDC):

What to do if there is a confirmed or suspected COVID case in your building

Anyone who has had close contact with someone who has the virus should monitor their health; they should call their healthcare provider right away if they develop symptoms suggestive of COVID-19 (e.g., fever, cough, shortness of breath)
If the tenant has their own apartment and bathroom, and does not need to be hospitalized, the tenant should follow the isolation orders of their medical provider.
If the Vermont Department of Health (VDH) determines through tracing procedures that others in the building have likely been exposed, they will contact those individuals directly and instruct them on what to do. VDH will ask them what their needs are for obtaining essential goods and services and help them identify resources that will help them stay isolated.
If someone is suspected of having COVID 19 and the individual cannot isolate/quarantine in place because the setting does not allow for it (for example, in buildings with shared bathrooms), the housing operator can help the tenant apply for isolation and quarantine housing at Harbor Place. The Vermont Agency of Human Services has more information on how to apply.

Resources for tenants

The Internal Revenue Service (IRS) has prepared a new web tool to help people who normally don't file tax returns receive their stimulus payments. A second tool to be released soon will provide taxpayers with payment delivery date and provide direct deposit information.
The Vermont Department of Labor has information on how to file for unemployment assistance, including an FAQ section with details on who is eligible to apply as a result of COVID-19.
The federal Consumer Financial Protection Bureau (CFPB) has a list of resources for consumers, including advice on how to navigate student loan, auto loan, and credit card payments during this time.

Who to call?

If you have questions about COVID-19: Dial 2-1-1
If you are returning from China, Italy, Iran, South Korea or Japan: Call Health Department Epidemiology at 802-863-7240
If you are ill, have symptoms, or concerned about your health: Call your health care provider, or Vermont 2-1-1 if you do not have a provider.

VHFA updates and temporary guidance

Housing displaced individuals under disaster declaration

As of April 8, 2020, the Federal Emergency Management Agency (FEMA) has designated Vermont as a major disaster area due to the impact of COVID-19. Under this declaration, some displaced individuals and households are eligible for emergency housing in tax credit properties, allowing housing tax credit owners temporary relief from income requirements. To request permission to house displaced households, review the memo below with further instructions, then complete and submit the forms below:

Documenting financial hardship

As the impacts of COVID-19 are being felt in your communities, we know you are also feeling the impact in the management of your multi-family housing portfolio. VHFA understands that as we move further away from April 1st your organization is likely getting a better sense of your potential concerns around revenues and expenses for each of your properties. VHFA will consider a number of options based upon demonstration of documented financial hardship for individual properties. To document your financial hardship, review the memo below with further instructions, then complete and submit the spreadsheet below:

Delayed Tenant Income Certifications

In an effort to respond to questions regarding delayed Tenant Income Certifications and third party verifications due to COVID-19, VHFA suggests that you add documentation to each tenant file that states “Due to the COVID-19 pandemic, Tenant Income Certifications and verifications are delayed “. Be sure include a date and an electronic signature to this documentation.

Delayed Capital Needs Assessments

Any properties with capital needs assessments due to VHFA in 2020 can postpone these until 2021.

Updates from other state agencies

Updates from federal agencies

HUD and USDA RD have provided COVID-related guidance to multifamily managers and property owners. Frequently asked questions pertaining to both agencies are listed below:

Q: Are household payments under the CARES Act reportable as tenant income?

A: Household stimulus payments and the temporary $600 per week federal enhancement to unemployment insurance provided by the CARES Act are not to be included in calculations of income. However, HUD notes that regular payments of unemployment insurance (issued by the state) are treated as income, as is customary under program rules.

For further details, review the FAQ links and agency memos linked below:

U.S. Department of Housing & Urban Development (HUD):

USDA Rural Development (RD):

Main COVID-19 affordable housing updates page