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

Example best practice responses:

• Summit Properties modified operations policy in response to COVID-19
• Response to Loss of Employment due to COVID-19

Inform tenants about prevention measures:

• Property managers should take common sense steps to help prevent spread of the virus at their place of work and at their properties. Those steps include: 
  • Wash hands regularly for at least 20 seconds using soap and water.
  • Avoid touching of eyes, nose, and mouth with hands.
  • Avoid close contact with people who are sick.
  • Stay home if you are exhibiting cold or flu‐like symptoms or feel sick.
  • 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.
• The Institute for Real Estate Managment has prepared fact sheet templates to inform tenants about preventing the spread of infection.

Encourage employees and residents to stay at home when sick, and travel safely

• Ensure employees are aware of sick leave policies.
• Inform residents about ways to communicate with management (phone, e‐mail, mail) instead of office visits.
• Evaluate need for travel and provide safe travel information, such as the CDC's Travelers Health Notices.

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.
• 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:

1. Ask the individual if they have any of the following:
   1. Respiratory symptoms                                                         
   2. Fever                                                                                    
   3. Sore throat                                                                            
   4. Cough                                                                                   
   5. Shortness of breath                                                          
2. 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 as recommended by a health professional. Call Vermont 2-1-1 for assistance.

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.

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

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:

• Impact of COVID-19 – Request for Assistance
• Loan Assistance Survey Request Form

Short-term housing

In an attempt to meet immediate short-term housing needs as a result of COVID-19, VHFA is aware property owners and managers are working with service providers seeking temporary shelter options for Vermonters. VHFA has received inquiries as to whether it is acceptable to use vacant units in multi-family housing properties to house those who may be displaced by COVID-19, and specifically those from over-crowded shelters.

• Tax Credit Properties in Extended Use: At this time, properties that were funded by the Low-Income Housing Tax Credit program and are in the extended use period (year 15-30) may use vacant units to temporarily house displaced individuals or families for the duration of the National Emergency
• Tax Credit Properties in Initial Compliance Period: The Internal Revenue Services (IRS) and Treasury have not issued guidance that suspend compliance requirements for Tax Credit properties that are in their initial 15 year compliance period. As such, VHFA is acknowledging that providing temporary housing in vacant units would likely trigger a 8823 for noncompliance without further guidance from the IRS.

VHFA will be advocating to the IRS and Treasury for there to be guidance issued for LIHTC properties to be as flexible as possible to meet the changing needs of Vermont communities during the COVID-19.

At the time of this issuance we remain in a National Emergency and not a Federal Disaster. At times, declarations have been accompanied by a lifting of regulatory requirements like natural disasters (hurricanes). As of this time, there is no similar lifting of regulations as a result of COVID-19.

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.​

• HUD: Public and Indian Housing COVID-19 resources
• USDA Rural Development (RD):
  • USDA Implements Immediate Measures to Help Rural Residents, Businesses and Communities Affected by COVID-19
  • Guidance for Multifamily Housing Partners