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Interim Recertifications for HUD Section 8 programs

Interim Recertifications for HUD Section 8 programs – Part 1

Determining when an Interim Recertification (IR) is warranted and what effective date to utilize is often challenging. This portion of our three-part series will provide guidance on reporting requirements and optional changes, processing IRs, refusing IRs and the all-important question of what effective date to utilize.

This information applies to HUD Project-Based Section 8 properties only, as IR never apply to the LIHTC program

What are tenants required to report?

All tenants must notify the owner when:

  • A family member moves out of the unit;
  • The family proposes to move a new member into the unit;
    NOTE: At a minimum, owners must apply screening criteria for drug abuse and other criminal activity, *including State sex offender registration, and use of the EIV Existing Tenant Search to persons proposed to be added to the household, including live-in aides. The owner must make sure that the person also discloses and provides verification of his or her SSN.
  • An adult member of the family who was reported as unemployed on the most recent certification or recertification obtains employment; or
  • The family’s income cumulatively increases by $200 or more per month.

What are optional reporting requirements?

Tenants may request an IR due to any changes occurring since the last recertification that may affect the total tenant payment or tenant rent and assistance payment for the tenant. Changes a tenant may report include the following:

  • Decreases in income including, but not limited to, loss of employment, reduction in number of hours worked by an employed family member, and loss or reduction of welfare income;
  • Increases in allowances including, but not limited to, increased medical expenses, and higher child care costs; and
  • Other changes affecting the calculation of a family’s annual or adjusted income including, but are not limited to, a family member turning 62 years old, becoming a full-time student, or becoming a person with a disability.

Tenants are not required to report when a family member turns 18 years of age between annual recertifications. However, tenants must follow the requirements in their lease for reporting changes in the household income. However, if a tenant turns 18 and has not signed the form HUD-9887, the owner must not use the EIV income reports until the form is signed. Owners must address in their policies and procedures notification requirements and timeframes for tenants who turn 18 between annual recertifications to sign the consent forms HUD-9887 and HUD-9887-A and/or lease. If the tenant fails to sign the consent form(s) the household is in non-compliance with their lease and assistance to, and the tenancy of, the household may be terminated.

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