Killeen staff propose reprogramming HOME funds, drop HUD-certified counseling requirement for TBRA

KILLEEN, Texas — City staff opened a public hearing June 3 to inform residents of a proposed substantial amendment to reprogram leftover HOME Investment Partnerships (HOME) funds toward tenant-based rental assistance (TBRA) and to remove the city's local requirement that TBRA beneficiaries complete HUD-certified housing counseling.

The change would be part of the city's consolidated plan cycle and is intended to speed assistance to eligible households, city staff said. "The substantial amendment occurs when there is a change in the purpose, scope, location, or beneficiaries of an activity or project," said Ms. McNair, a Community Development staff member leading the presentation. She said the amendments would open a 30-day public comment period from June 9 through July 15 and that council would be asked to take action at a July 15 meeting if the drafts are finalized.

The nut of the staff recommendation is to move previously allocated HOME funds into TBRA to meet HUD's timing and expenditure rules and to remove a local counseling prerequisite that staff said is not required by HUD. "At the time this consolidated plan was put together, there was no HUD-certified housing counselor in the city of Killeen," Ms. McNair said. She told the council that because Killeen now has a HUD-certified counseling agency, the local requirement can be a barrier: "The number of persons expected to experience an undue burden with the requirement of attending housing counseling prior to receiving rental assistance will increase the wait period and likelihood that the household will experience housing instability and or eviction."

Ms. McNair also listed the specific funds staff proposed to reprogram: entitlement funds from 2017 of $1,573.80; conversions for 2021 and 2022 (as stated in the presentation) of $703,680.33 and $88,376.25, respectively; and an award to Fort Hood Habitat for Humanity of $456,007.68 that was never executed. She said those figures "bring us to a total of $619,641.03 for reprogramming." (The numbers were presented by staff as reported; the arithmetic was reported in the presentation as stated above.)

Public commenters urged careful oversight if the city expands TBRA. Michael Perino said HUD involvement does not make local oversight unnecessary and asked for stronger accountability: "I would ask and appreciate some answers ... that this program be administered and overseen very, very carefully," Perino said. He added that the city should ensure the program demonstrates measurable progress.

Alyssa Brown questioned why the Fort Hood Habitat for Humanity award was not executed and asked whether the city could instead reallocate funds back to Habitat: "How is it that there was never an agreement signed with Habitat for Humanity for half a million dollars for FY23?" she asked. Brown also urged the council to consider keeping some form of counseling requirement, suggesting an alternative such as requiring counseling within 30 days of receiving funds to reduce repeat need for assistance.

Sean Price sought clarity on what types of rental units TBRA would cover and whether it would apply to single-family rentals under homeowners associations as well as apartments. Ms. McNair responded that TBRA is an eligible HOME activity for any rental unit chosen by the household and that the city, not the Killeen Housing Authority, would provide oversight of these HOME funds.

The public hearing was informational; no vote was taken. Staff said that if the council approves the substantial amendment at a future meeting, staff will submit the amendment to HUD on or before Aug. 15.

The city accepted comments in person at Killeen City Hall and at several public locations and online at KilleenTexas.gov/289/community-development during the June 9'July 15 comment period. The council will consider any recommended changes at its July 15 meeting before any submission to HUD.