Author: Kelli Sterling

Social Security benefits and Supplemental Security Income payments will increase by 3.2% in 2024.

Read more about the Social Security Cost-of-Living adjustment for 2024.

On February 14, 2023, a final rule was published that revises HUD regulations to implement parts of the Housing Opportunity Through Modernization Act of 2016 (HOTMA). The effective date of the HOTMA provisions is January 1, 2024. Owners may not implement these provisions prior to their effective dates. The Office of Multifamily Housing will be updating the Tenant Rental Assistance Certification System (TRACS) and HUD forms frequently used by owners/agents and HUD (e.g., Form HUD-50059, Form HUD-50059A, Form HUD-9887/9887A, Form HUD-9834, Model Leases, etc.), to conform with HOTMA’s requirements.

On September 29, 2023, HUD issued a Notice (H 2023-10) providing additional guidance to the implementation of HOTMA. In this notice, HUD indicated that, although the effective date remains January 1, 2024, implementation has been extended until December 31, 2024; however, certain policies must be updated by March 31, 2024. You may read this notice at the following link:

https://www.hud.gov/sites/dfiles/OCHCO/documents/2023-10hsgn.pdf

On May 15, 2023, HUD released the 2023 Income Limits for HUD programs.

To access the new income limits, visit the HUDUser website at:

https://www.huduser.gov/portal/datasets/il.html

For HUD’s Multifamily Housing program,the new 2023 Income limits are effective immediately.

All new certifications created and finalized on 5/15/2023 or later will include the new income limits.

Pursuant to HUD Notice H 2022-06, dated October 31, 2022, NHC has been assigned by HUD to process COVID-19 Supplemental Payment Requests (CSP Requests) – Round V. Below are instructions on how to submit your CSP Request to NHC to ensure timely processing.

**DEADLINE: CSP Requests are due by February 21, 2023. **

Highlights of the Notice for Round V Requests include:

1. Financial Eligibility for Round V Requests (expense incurred from November 1, 2021 through January 31, 2023): Properties projecting surplus cash are now eligible for amounts up to the Standard CSP cap for this operating period. Standard Requests are all CSP requests that fall at or below the $25,000 ceiling. Requests above $25,000 must meet all financial need criteria for Round IV and Round V.
2. New types of Eligible Expenses have been added: Resident training on use of technology to access on-line property management portals and supportive services; Expansion of Capital Expenses to include costs to enhance outdoor seating spaces that support gatherings in environments with relatively lower risk of virus transmission.
3. Claims can be made for all CSP Rounds if not previously submitted by a property – An owner can choose to submit a CSP request for previous rounds as well as the current Round V if applicable.

PROCESSSING INSTRUCTIONS:

Your Standard or Non-Standard CSP Request should be emailed to CSP@nhcinc.org. If eligible, an Owner can submit one CSP Request form for each operating period identified on the form (there are 5 operating periods) or combined periods on a single form, for Standard Requests only. When emailing your CSP Request, please use the following subject line and file naming convention to assist us in the appropriate identification and routing of your request – one request per email. Documentation to support all Non-Standard Request should be included in the same email as a separate PDF attachment and named in the manner shown below. Our system allows up to 30MB of information.

Standard Requests:

Email Subject Line: Contract Number only (e.g., IL06XXXXXXX)

File Name for HUD form 52671-E: Contract Number_Standard (e.g., IL06XXXXXXX_Standard)

Non-Standard (NS) Requests:

Email Subject Line: Contract Number only (e.g.IL06XXXXXXX)

Fine Name for HUD form 52671-E: Contract Number_NS (e.g., IL06XXXXXXX_NS)

File Name for Support Documentation – Contract Number_NS_Invoices (e.g., IL06XXXXXXX_NS_Invoices)

IMPORTANT EMPHASIS POINTS:

• Five distinct operating periods: Round 1) 3/27 – 7/31/20, Round 2) 8/1 – 11/30/20; Round 3) 12/1/20 – 3/31/21, Round 4) 4/1/21 thru 10/31/21 and Round 5) 11/1/21 – 1/31/2023;
• Complete the form as instructed, to include a correct Assistance Contract Number, e.g., IL06XXXXXXX;
• To the extent possible, submit your request on the fillable PDF format. If your system does not allow you to sign in PDF format, you can submit your format on a scanned format. However, you must also include a completed fillable PDF format without the Owner’s signature so that NHC can e-sign the form and forward to HUD in fillable PDF format – see also Tips for Completing HUD Form 52671-E;
• CSP Request forms must be signed by the Owner or as authorized (on file) by the Owner [INCLUDE Owner Typed Name];
• For those of you who submitted during Round 1, 2,3 or 4, do not submit reimbursement for any expenses incurred and previously paid for those operating periods;
• For Non-Standard Requests (requests greater than $25,000), supporting documentation must be clear, concise and orderly, i.e., clearly labeled by CSP form line-item. NOTE: Any “Yes” on Line 25 of the CSP Form indicates a Non-Standard Request.

NHC’s role is to review each request and ensure that it is accurate and complete. Therefore, for Standard Requests, you only need to submit a completed HUD Form 52671-E: Property/Owner Information, Parts I-III and Part V, sign and date. For Non-Standard Requests, you must submit HUD Form 52671-E, complete Property/Owner Information, and all applicable Parts I-V; sign and date; AND submit documentation to support all eligible expenses.

We are expecting a large volume of CSP Requests during this round; therefore, requests that are incomplete, inaccurate or lack proper documentation will be returned for correction. We ask in these cases, if any, that you respond back with the requested information within 2 business days to ensure timely processing. Further, our system does not allow for multiple CSP requests in a single email – ENSURE EACH REQUEST IS SENT SEPARATELY.

You should receive your payment from NHC, separate from your monthly Voucher Payment, and the final payment schedule is ultimately determined by HUD.

Thank you for your cooperation and we look forward to once again providing you these additional CARES funds. Please feel free to contact Kim Lance directly for any questions: Kim.lance@nhcinc.org.

NOTICE H 2023-01 – Unique Entity Identifier (UEI) Replaces Dun & Bradstreet Data Universal Numbering System for Identification of Federal Awards

Effective immediately for Contract Renewals, all entities will require a UEI number for renewal of their expiring HAP Contract. This number must be submitted to NHC with the Contract Renewal package for processing.

Greetings Georgia Owners and Agents:

This year, National Housing Compliance has partnered with SAHMA and will be participating in SAHMA’s full day Add-On Course on Tuesday, February 14, 2023. Please join our staff, along with Gwen Volk of INFOCUS, Inc. for an informative session on the Basics of HUD Occupancy during the morning session – as presented by Gwen; and PBRA Basics (MOR preparation, Special Claims, Resident Concerns and Utility Allowance Baselining) during the afternoon session – as presented by NHC staff.

If you haven’t already registered for this exciting event, February 14-16, 2023, you can do so at https://www.sahma.org/georgia. [NOTE: Registration is required!]

We look forward to seeing you in just a few short weeks!

HUD provides the following guidance in, Paragraph 9-6 of the Handbook 4350.3:

When processing certifications with an effective date of January 1, February 1, March 1, and April 1, in order to complete the Recertification Steps outlined in Chapter 7, Figure 7-3, and provide the tenant with the required 30-day notice of any increase in rent, the owner must use one of the methods below for determining the tenant’s income.

1. Use the benefit information reported in EIV that does not include the COLA as third-party verification as long as the tenant confirms that the income data in EIV is what he/she is receiving;
2. Use the SSA benefit, award letter or Proof of Income Letter provided by the tenant that includes the COLA adjustment if the date of the letter is within 120 days from the date of receipt by the owner;
3. Determine the tenant’s income by applying the COLA increase percentage to the current verified benefit amount and document the tenant file with how the tenant’s income was determined ; or
4. Request third-party verification directly from SSA when the income in EIV does not agree with the income the tenant reports he/she is receiving.
5. All recertifications effective after April 1 must reflect the SSA benefit that includes the COLA.

Social Security and Supplemental Security Income (SSI) benefits for approximately 70 million Americans will increase 8.7 percent in 2023.

The 8.7 percent cost-of-living adjustment (COLA) will begin with benefits payable to more than 65 million Social Security beneficiaries in January 2023. Increased payments to more than 7 million SSI beneficiaries will begin on December 30, 2022. (Note: some people receive both Social Security and SSI benefits)

Read more about the Social Security Cost-of-Living adjustment for 2023.