The Berman Buzz

The BH Bulletin: April 2022


PIH Notice 2021-36 CARES Act Supplemental Operating Fund Closeout

It is important to note that HUD has extended the close-out from April 30, 2022, to May 31, 2022 (Form SF-425). Per Section 5 of the notice:


“CARES Act Close-Out: PHAs must incur all eligible CARES Act expenses (as described in PIH-2020-07) by the end of the Period of Performance (POP), December 31, 2021. Public Housing Authorities should liquidate all obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance (2 CFR § 200.344(b)). By May 31, 2022, PHAs must submit an SF-425 for each CARES Act grant via the Operating Funds Web Portal, reporting on the status of CARES Act Supplemental Operating Subsidy as of December 31, 2021.”

PHAs should draw down funds by April 30, 2022, or they will be locked in LOCCS (no pun intended).



Once you balance your entries for GASB 87 on Leases, it is time to get ahead of some of the other standards coming our way. Remember, PHAs follow the same government accounting framework as towns, cities, and counties. However, the good news is that not all new standards apply to PHAs. You should be aware of and discuss these new standards regularly with your auditors. Depending on how you wrote your software contract, here is one that may apply to PHAs.


GASB Update #1

GASB Statement No. 96

Subscription-Based Information Technology Arrangements (SBITA)


Issued May 20, 2022, effective for June 30, 2023, fiscal year-ends, with early application encouraged, due to its alignment with GASB No. 87.


This Statement guides the accounting and financial reporting for subscription-based information technology arrangements (SBITAs) for government end-users (governments). This Statement:

  1. Defines an SBITA

  2. Establishes that an SBITA results in a right-to-use subscription asset, an intangible asset, and a corresponding subscription liability

  3. Provides the capitalization criteria for outlays other than subscription payments, including implementation costs of an SBITA

  4. Requires note disclosures regarding an SBITA


To the extent relevant, the standards for SBITAs are based on the ones established in Statement No. 87, Leases, as amended.


Under this Statement, a government generally should recognize a right-to-use subscription asset, an intangible asset, and a corresponding subscription liability.

The good news is certain decisions made by the Board provide cost relief. For example, the scope of this Statement excludes contracts with stand-alone tangible capital assets and contracts with a combination of a tangible capital asset and an insignificant software component. In addition, this Statement includes an exception for short-term SBITAs. This Statement permits, but does not require, governments to include capitalized outlays associated with the initial implementation stage in the measurement of the subscription asset recognized at transition.


GASB Update #2

GASB Statement No. 90

Majority Equity Interests


This standard came out in 2018 and amended GASB Nos. 14 and GASB Nos. 61, regarding the financial reporting entity and component units. This Statement establishes that ownership of a majority equity interest in a legally separate organization results in the government (PHA) being financially accountable for the organization. Therefore, the government should report that organization as a component unit.

Real-World Application

If your PHA is buying out a private investor fund from your tax credit deal, it should now be a blended component unit since the Authority, or one of its entities, is now the new 99.9 percent owner.


Emergency Housing Vouchers

The latest guidance on EHV reporting came out in August 2021. (PIH Notice 2021-25, which updates PIH notices 2021-15 and 20). There are many nuances for accurate reporting on your FDS and VMS specific to EHV. Please ensure you have the most current guidance. The notice specifies new fields in VMS (in part 7), as well as identifies (in part 8b) a new reporting column “14.EHV” in the FASS-PH system (the FDS) under which PHAs will report their EHV program. In addition, the notice discusses the fees and proper reporting in the FDS. If you are voluntarily returning your EHV Award, refer to PIH Notice 2022-06, issued in March, for the most recent guidance.


Upcoming Dates

April 30

Deadline to Draw Down CARES Funds


May 15

12/31/21 FYE Nonprofit Tax Returns Due


May 31

3/31/22 FYE Unaudited REAC Due


SAVE THE DATE! May 17

Berman Hopkins PHA Webinar

More Info to Follow

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