HTC Improvement Initiative Updates - June 20, 2024
Agenda includes review of original initiative goals, updates on proposed rule changes, and stakeholder themes. Goal updates focus on reducing cycle times and increasing customer satisfaction. Recommendations are made for efficiency and consistency in project phases.
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Presentation Transcript
HTC Improvement Initiative Updates June 20, 2024
Agenda Introductions Review original initiative goals and the new turn around times. Discuss original primary recurring themes from stakeholders. Discuss the updates on the original proposed rule changes and process changes. DED DNR
Initiative Goals and End Results Implement improvements aimed at: 1. Reducing application cycle times by at least 20%. Update: DNR review time has decreased from 9 months to 30 days. DED cost certification review time decreased from 4 months to less than 30 days. 2. Increasing customer satisfaction. Update: Have received positive feedback from customers regarding the rule and process changes. Have received positive feedback from customers regarding quick review times and quicker turnaround times.
Primary Recurring Themes: Efficiency Consistency Transparency Time to authorization & issuance With statutory intent About determinations Between State & NPS Redundant Work Between State reviewers About status, backlogs and processing times Use of the Cap In our process
1. Hard cost stabilization (Rule) Theme: Efficiency Agency: DED Recommendation(s): Allow hard cost stabilization to coincide with Soft Cost (1 year before approval). Must be approval by DED before costs will be allowed. Update: Change to submission from approval and has been added to the new rules. 4 CSR 85-5.020 (2)(G)1 Will allow up to 10% of the hard cost QRE for stabilization. This will be up to the applicant what is needed for stabilization. The applicant will be required to sign an attestation at the time they submit cost certifications stating the hard cost QRE s paid 1 year prior to applying are for stabilization.
2. One application for phased projects (Rule) Theme: Efficiency Agency: DED Recommendation(s): Allow applicants to submit one preliminary application in Submittable for all phases of a project. Update: This has been added to the new rules. 4 CSR 85-5.080 (1)(B) Submittable has been updated and will be available July 1 to allow one preliminary application for all phases.
3. Property eligibility Theme: Consistency Agency: DED Recommendation(s): Require National Register listing before final issuance rather than prior to preliminary approval. Update: This requires a statute change and is in the new HB2062 that is waiting on the Governor s signature.
4. Occupancy scoring Theme: Consistency Agency: DED Recommendation(s): Revise scoring around occupancy to allow more points for partially occupied buildings. Update: New administration would like more information and is asking for stakeholders to collect data for costs associated with the loss from being vacant. Will revisit in FY25
5. Distressed area scoring (Rule) Theme: Consistency Agency: DED Recommendation(s): Revise scoring to award more points to projects located with in a locally designated EEZ. Update: EEZ location has been added into the rules and maximum amount of 22 points will be awarded. 4 CSR 85-5.050 (1)(E) Scorecard has been updated on the HTC website.
6. Local impact analysis (Rule) Theme: Efficiency Agency: DED Recommendation(s): Applicants perform and supply local impact analysis, reducing process time spent by state team. Update: This has been added to the new rules and the redevelopment team has built a new template that provides guidance for the local fiscal impact. 4 CSR 85-5.020 (1)(E)5
7. Scoring tiers (Rule) Theme: Consistency Agency: DED Recommendation(s): Simplify to a pass/fail system, declining applications that score below 70 points. Update: This has been added to the new rules and have updated the scorecard as well to provide guidance. 4 CSR 85-5.020 (1)(J)
8. Batching applications Theme: Efficiency Agency: DED Recommendation(s): With pass/fail scoring, DED will no longer need to send applications in batches. Any application scoring above 70 points will automatically be sent to SHPO for preliminary review. Update: Submittable, Guidelines, and Forms and have been updated on the HTC website or when submitting new applications. 4 CSR 85- 5.020 (1)(J)
9. Conditional authorization (Rule) Theme: Consistency Agency: DED Recommendation(s): Allow conditional SHPO approval of projects. Once conditionally approved, authorize cap and begin commencement of rehabilitation. Prior to final application, conditions must be met to be issued credits. Update: This has been added to the new rules. 4 CSR 85-5.020 (1)(K)
10. Electronic submission (Rule) Theme: Efficiency Agency: DED Recommendation(s): Require that all applications be submitted electronically. Update: This has been added to the new rules. 4 CSR 85-5.010 (2)(S)
11. Postmark date (Rule) Theme: Consistency Agency: DED Recommendation(s): Allow electronic timestamp to be used as postmark when determining authorization order. Update: This has been added to the new rules. 4 CSR 85-5.010 (2)(R) & 4 CSR 85-5.020 (1)(H)
12. Lottery process (Rule) Theme: Consistency Agency: DED Recommendation(s): Applications will be reviewed in the order submitted, as determined by the digital timestamp on the application. Update: This has been added to the new rules. 4 CSR 85-5.010 (2)(R) & 4 CSR 85-5.020 (1)(H)
13. Cycle dates (Rule) Theme: Consistency Agency: DED Recommendation(s): Set cycle start date to July 1. Update: This has been added to the new rules. 4 CSR 85-5.020 (2)(C)
14. Cycle structure (Rule) Theme: Efficiency Agency: DED Recommendation(s): Shift to an open cycle structure that closes December 31 or when requests received equal the cap amount. At cycle close, allow individuals to sign up to be notified should cap come available that fiscal year due to a rescission. Update: The cycle will stay open year-round and has been added to the rules. 4 CSR 85-5.020 (2)(C) N/A
15. Concurrent cap authorization (Rule) Theme: Efficiency Agency: DED Recommendation(s): Authorize QCT projects first from the QCT cap, until it is exhausted. Update: This has been added to the new rules. 4 CSR 85-5.020 (1)(L)
16. SHPO consultation (large projects) Theme: Efficiency Agency: DNR Recommendation(s): Require that all preliminary applications for projects over $275,000 participate in a consultation with SHPO prior to submitting a preliminary application. Update: SHPO strongly suggests participation in a consultation prior to submitting preliminary applications to expedite the review process.
17. SHPO consultation (small projects) Theme: Efficiency Agency: DNR Recommendation(s): Recommend that all preliminary applications for projects under $275,000 participate in a consultation with SHPO prior to submitting a preliminary application. Update: SHPO strongly suggests participation in a consultation prior to submitting preliminary applications to expedite the review process.
18. Consultation opportunities Theme: Efficiency Agency: DNR Recommendation(s): SHPO will offer more timeslots weekly for consultation visits. Advertise this availability on the SHPO website. Update: SHPO has doubled available timeslots offered for consultations from 3 hours to 6 hours per staff member per week. Consultations are advertised on the site visit handout and mentioned in all emails to potential applicants and are advertised on the Historic Preservation Tax Credit Programs website.
19. Amendment procedures Theme: Consistency Agency: DED Recommendation(s): Develop a clear process for amendments. Utilize federal amendment forms for projects that have a federal component and apply NPS reviews to them. Update: DED and DNR have worked collaboratively to streamline the process to expedite amendments. If applying for federal credits, then you will no longer provide an amendment for the state.
20. Amendment form Theme: Efficiency Agency: DED Recommendation(s): Create a new simplified amendment form. Update: DED team has created a new simplified amendment form in our Submittable program and in the process of training consultants and stakeholders
21. Federal/State combined review process Theme: Efficiency Agency: DNR Recommendation(s): When SHPO receives a preliminary application with information that is unclear or incomplete, SHPO will allow the applicant an opportunity to amend the application. After receiving and reviewing the amendment, SHPO will send the application and SHPO's recommendation on to NPS for review. Update: SHPO allows applicants numerous opportunities to amend an application and sends regular email reminders until requested information is received. After SHPO s review, all federal applications, as per federal law, are forwarded to NPS for review.
22. State only review process Theme: Efficiency Agency: DNR Recommendation(s): SHPO will limit review to new information and previously undisclosed information. Information that was already reviewed will not result in an amendment request. Update: SHPO only reviews new information and previously undisclosed information. Once something has been reviewed and approved, it remains approved.
23. Final application checklist Theme: Efficiency Agency: DED Recommendation(s): Create a final application checklist. Update: The final application checklist has been updated and is available on DED s website.
24. Developer fee form (Rule) Theme: Efficiency Agency: DED Recommendation(s): Rather than requiring our form, specify what must be included in a developer fee agreement. Update: This has been added to the new rules. 4 CSR 85-5.020 (1)(G)
25. Cost certification auditing Theme: Efficiency Agency: DED Recommendation(s): Spot check cost certification, rather than matching up every line item and invoice. If issues are found, send back to CPA for correction. Update: DED has implemented a new process that has cost certification review in less than 30 days of receiving.
26. 3rdparty CPA review (Rule) Theme: Efficiency Agency: DED Recommendation(s): Revise rule to remove DED as party to the 3rd party CPA contract. Remove language around related party and business relationship. Update: This has been added to the new rules. 4 CSR 85-5.020 (2)(E)
27. Overhead & profit fees (Rule) Theme: Efficiency Agency: DED Recommendation(s): Create one 10% cap. Update: This has been added to the new rules, and the redevelopment team has built out a new cost certification spreadsheet that includes a built-in cap calculator tool to help with these calculations. 4 CSR 85-5.020 (2)(G)
28. Excess credit application checklist Theme: Efficiency Agency: DED Recommendation(s): Create an excess credit application checklist. Update: The redevelopment team has been working on this checklist and it is on the HTC website.
29. Rescoring excess credit applications (Rule) Theme: Consistency Agency: DED Recommendation(s): If an application was previously scored, it would not be scored again. If it was not previously scored, it would be scored using current criteria. Update: This has been added to the new rules and the redevelopment team has updated the Excess Tax Credit request in Submittable. 4 CSR 85- 5.020 (3)(G)
30. Excess credit priority (Rule) Theme: Consistency Agency: DED Recommendation(s): All applications will be reviewed and cap reserved in the order timestamped by the digital application system. Cap will be held for new projects until they are scored and approved by SHPO. Update: This has been added to the new rules. 4 CSR 85-5.020 (1)(H)
31. Federal/State combined applications Theme: Consistency Agency: DED Recommendation(s): Allow applicants to submit federal forms in lieu of state forms if they are also applying for the Federal program. Create a condensed State application form for the upload of State materials. Update: Submittable has been updated to only require a full state application if no federal application was submitted. Submittable has been updated to a condensed state application if there is a federal application submitted.
32. State forms consistency with Federal Theme: Consistency Agency: DED Recommendation(s): Adjust state forms to mirror federal part 2 and 3 data fields for consistency, where possible. Update: DED is still working on future updates on this to insure consistency of these forms.
33. Denial of incomplete applications (Rule) Theme: Consistency Agency: DED Recommendation(s): DED will provide 15 calendar days for applicants to cure incomplete applications. Applicants have one opportunity to cure. Update: This has been added to the new rules. 4 CSR 85-5.020 (1)(B)
34. Authorization/Issuance clarity (Rule) Theme: Transparency Agency: DED Recommendation(s): Create clear delineation between authorization and issuance, as well as between the preliminary, final, and excess credit stages of the application lifecycle. Update: This has been added to the new rules. Multiple places throughout the rules.
35. DED HTC webpage Theme: Transparency Agency: DED Recommendation(s): Update the HTC website and forms for a better customer experience. Update: The redevelopment team has been working on new forms and are on the HTC website.
36. State vs. Federal determinations Theme: Efficiency Agency: DNR Recommendation(s): DED will accept Federal NPS part 2 and part 3 approval or SHPO approval where applicable. Update: When SHPO receives a Federal approval, either conditional or unconditional, SHPO will forward a state review sheet to DED recommending approval. SHPO will also forward the Federal conditions sheet for any NPS conditional approvals.
37. NPS review sheets Theme: Transparency Agency: DNR Recommendation(s): Send copies of the review sheets to applicants at the same time the review sheets are sent to NPS. Update: SHPO review and condition sheets are sent to applicants at the same time the review sheets are sent to NPS.
38. Synchronize Federal & State review sheets Theme: Efficiency Agency: DNR Recommendation(s): Utilize the NPS review and review sheet for projects that have a federal component and eliminate the need for SHPO to fill out a separate review form. SHPO will upload Federal or State review sheet into Submittable. Update: Beginning on July 1, 2024, SHPO will forward NPS determinations (both conditional and unconditional) to DED for corresponding state applications. NPS condition sheets will also be forwarded to DED.
39. SHPO review order Theme: Consistency Agency: DNR Recommendation(s): SHPO will continue to triage application review, picking up partially completed reviews when requested information is submitted by the applicant. Update: SHPO continues to triage application review, picking up partially completed reviews when requested information is submitted by the applicant.
40. Consistency among reviewers Theme: Consistency Agency: DNR Recommendation(s): SHPO currently assigns the same reviewer to each project for consistency and simplicity. This can sometimes cause additional delays as projects wait for the existing reviewer in order to maintain reviewer assignment consistency, but saves time a new reviewer would need to get familiar with the project. Update: Whenever possible, SHPO assigns the same reviewer to every project submission to maintain consistency. If that reviewer is not available, even temporarily, a new reviewer will be assigned.
41. Incomplete applications Theme: Efficiency Agency: DNR Recommendation(s): Develop a checklist to be posted on the website for applicants for intake purposes. Update: For federal applications, NPS provides a submission checklist (the Transmittal Log), and applicants are required to include one with every submission. For state applications, DED provides a Preliminary Application Checklist.
