QAP Racial Equity Impact Assessment

NEW: The public survey about affordable housing rental development and racial equity is now available.

Who should take the survey?
All are welcome to participate in the survey and we hope key partners will participate.

• People With Lived Experience
• Developers and Contractors
• Financial Partners
• Advocates and Community Organizations
• Service Providers
• Local leaders
• Tribal Nations
• Municipalities
Click here to access the survey.

The Authority is performing a Racial Equity Impact Assessment (REIA) on the Qualified Allocation Plan (QAP), known as “MSHDA QAP REIA,” and we want to hear your thoughts!

Why a REIA?

MSHDA, supported by Enterprise Community Partners, CEDAM and others, is exploring how the introduction of an equity lens, and potential changes to the 2024-2025 QAP, can garner opportunities for advancing equity in communities developed with Low-Income Housing Tax Credits (LIHTC). To understand how these changes may impact different communities we are performing a Racial Equity Impact Assessment, or REIA. This is only the first step in a process that MSHDA will continue long after this initial engagement.

What is a REIA?

A Racial Equity Impact Assessment, or a REIA, is a systematic examination of a proposed action or decision. REIAs are used to understand how different racial and ethnic groups are impacted by a specific policy, institutional practice, program, plan, or budgetary decision. REIAs ask a series of questions to various stakeholders to understand how the QAP currently impacts their lives; and understand how they would be impacted, by the proposed changes. REIAs also leverage both quantitative (numbers and statistics) and qualitative (experiences and narratives) information to understand the causes of inequality. Finally, the goal of this REIA wilsl be use all the collected information and research to develop recommendations for MSHDA to increase equity within the Qualified Allocation Plan.

The Qualified Allocation Plan (QAP) Qualified Allocation Plan (michigan.gov) is the document that sets policies and procedures for the administration of the Low-Income Housing Tax Credit (LIHTC) program; and the LIHTC program supports the construction and rehabilitation of affordable housing across Michigan.

Learn more about this REIA process

REIA Timeline: Due to timing constraints, and to ensure that the QAP Public Review process is not compromised, we have proposed the following process for the REIA:

Assess (Aug – Sept 2022)

Gain an understanding of the current QAP through research, MSHDA interviews and conversations.
Establish a path forward for the Racial Equity Impact Assessment.

Engage (Oct 2022)

Engage all stakeholders in conversations about the QAP and its impacts.
Continued research and analysis of data to inform recommendations.

Analyze (Mid-Oct – Nov 2022)

With the support of stakeholders, develop and refine preliminary draft recommendations.

Design (Dec 2022 – Feb 2023)

Finalize recommendations for QAP amendment.

Develop goals for implementation and evaluation.

We are currently ending the “Assess” portion of this process and gearing up for the “Engage” stage.

We understand that there will need to be more conversations than can be accomplished in the proposed timeline, we also understand that some folks may feel like the conversations are just the beginning, and that is correct. We see this as an initial step that will help MSHDA expand their understanding. This REIA will provide initial tools that will be used iteratively, over time, to get closer to an equitable future for all.

What happens after stakeholder engagement?

After engagement, the REIA team will collect and review all the information. This includes community engagement notes, historical research and data analysis, and a scan of national practices to understand what other states have tried. All of that information will be used to develop a report that outlines our process, what we heard and what we think would help increase equity. That report will include recommendations that will be shared with MSHDA at the end of this year. MSHDA will determine which recommendations will inform changes to the 2024-2025 QAP and create the Draft QAP. Public comments on those proposed changes will be collected during the standard QAP review process. After the standard QAP review process, the QAP will be voted on by the board and then reviewed by the governor.

More on the QAP Development Timeline

The standard review process gathers feedback on proposed QAP revisions from residents and stakeholders across the State of Michigan. It is an opportunity for you to share your thoughts on what we got right and what can still be improved. This process happens every two years, in alignment with QAP revisions, to allow public participation in shaping the QAP.

2024 – 2025 QAP Development Timeline

November 2022	Public Information Hearing
November 2022	Focus Groups, Open Agenda
December 2022/January 2023	REIA Recommendations to MSHDA
Ongoing	Stakeholder Meetings As Needed
February 2023	Draft QAP Sent to Focus Groups
February/March 2023	Focus Groups to Discuss Draft
March 2023	Draft QAP Release to General Public
April 2023	Public Hearings
May 2023	QAP Presented to the Board for Discussion Only
June 2023	QAP Presented to the Board for Voting Action
October 2023	First Round of Funding Under QAP

What is the Low-Income Housing Tax Credit Program and the Qualified Allocation Plan?

The Low-Income Housing Tax Credit (LIHTC) Low Income Housing Tax Credits (LIHTC) (michigan.gov) was created by the Federal Tax Reform Act of 1986. LIHTC is a federal tax credit used to acquire, build and/or rehabilitate income-restricted rental housing. The tax credit program is the largest federal source available to fund the creation or rehabilitation of affordable housing. The IRS grants each state housing or fiscal agency a set amount of credit per year, based on the state population. The Michigan State Housing Development Authority (MSHDA) is charged with appropriately administering the LIHTC program within the State of Michigan. For 2022, MSHDA received $26 million in 9% LIHTC to allocate to developments around the state. Because the tax credits are available for 10 years, this will provide around $234 million of housing investment in the State of Michigan. In order to be eligible for LIHTC, a development must agree to rent and income restrictions for at least 15 years. Additionally, the development must set aside at least 20% of its units for residents whose incomes do not exceed a 50% of area median income or 40% of its units for residents whose incomes do not exceed 60% of area median income or ensure that all affordable units are set-aside for residents whose average incomes do not exceed 60% of area median income.

Each state housing or fiscal agency is required to develop a Qualified Allocation Plan (QAP) that directs how the agency allocates credits. This allows each state to adjust their plan accordingly to the needs of their residents. The process used by MSHDA to evaluate applications and allocate credit is described in Michigan's Qualified Allocation Plan. An application including detailed financial information and various supporting documentation, must be submitted to MSHDA for review and evaluation. Each year, MSHDA receives applications for about four times as much 9% LIHTC credit as is received to allocate, making this credit a competitive resource. The process a development undergoes involves three stages - reservation, commitment, and allocation of credit. The final determination of how much credit will be awarded is made at the allocation stage. MSHDA usually revises the QAP every two years. This winter, MSHDA will consider the recommendations of the ongoing Racial Equity Impact Assessment when rewriting the 2024-2025 QAP.