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HUD Publishes Additional Guidance on COVID-19

On March 16, 2020, HUD published another updated COVID-19 Q&A for HUD Multifamily professionals.

This is the third update to the Q&A, as HUD continues to address the mounting concerns of property management professionals who are concerned for the safety of site staff and, most importantly, the safety of their residents.

Much of the Q&A directs owners to refer to current guidelines recommended by the CDC, as it relates to hygiene and social distancing. In relation to disaster preparedness, much of the Q&A refers to Chapter 38 of the HUD Handbook 4350.1. In this blog, we will highlight a few of the areas in the Q&A that we think would be of most interest to our clients.

Resident Health Issues Related to COVID-19

Vacant Unit Utilization

One of the questioned addressed is in relation to using vacant units to separate households who have a COVID-19 positive household member.

Question: If a person under quarantine has additional family members who need to be kept separate, what are a property manager’s options for meeting those needs? What if managers are being asked to use vacant units for quarantine?

Answer: Resident requests to occupy vacant units or temporarily relocate should be verified before being granted. Verification could include written communication from a medical health professional or through communication with the local health department. Managers may use electronic and telephonic communication to perform verification.

Although HUD indicates that utilizing vacant units to separate household members is allowable, they are not mandating it. HUD does not address whether or not these temporary relocations into vacant units would supersede existing transfer priorities related to:

  • Accessible units
  • Reasonable Accommodation Transfers
  • Emergency transfers under VAWA
  • Transferring over-housed and underutilized households to appropriate-sized unit

Policy and Operations During COVID-19 Outbreak

In the policy and operations section, HUD addresses the questions and concerns related to the impact of COVID-19 on day-to-day operations.

Unpaid Rent for Impacted Residents

HUD advises owners to work with impacted households, which can include entering into a forbearance agreement.

A forbearance agreement is an agreement where the owner/agent agrees to reduce or delay rent payments for a certain period and agrees not to initiate eviction proceedings during the forbearance period. Such an agreement would require that the tenant resume the full payment at the end of the period, plus pay an additional amount to get current on the missed payments

Income Reduction for Impacted Residents

HUD also reminds owners/agents in the Q&A that if a household experiences a decrease in income, that will last for more than one month. Keep in mind, that If the owner determines that the decrease in income will last less than one month, the owner may choose, but is not obligated, to process an interim recertification.

Extenuating Circumstances – Inability to Sign Certification or Consent Forms

If a tenant is not available to sign the HUD-50059, consent forms or attend the recertification,

HUD states that the owner/agent may treat COVID-19 considerations in the community as an extenuating circumstance if the tenant is not available to attend the recertification interview, sign consent forms, or sign form HUD-50059.

HUD further reminds owners/agents that when an extenuating circumstance is present, the household’s recertification date does not change. The Total Tenant Payment/Tenant Rent and the subsidy payment are retroactive to the recertification effective date. The tenant file must be documented as to why the signature of the tenant(s) was not obtained, and when the signature(s) will be obtained.

Property Reviews and Inspections

Management & Occupancy Reviews

HUD is suspending standard Management and Occupancy Reviews (MORs) until the Performance-Based Contract Administrator (PBCA) determines that local conditions no longer limit or prevent the PBCA from performing MORs safely.

REAC Inspections

All REAC property inspections for all Multifamily properties are being postponed until further notice. However, if there is an exigent circumstance or reason to believe that there is a threat to life or property at a specific location, inspections will be conducted by HUD quality assurance inspectors in compliance with CDC guidelines.

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