Updating AR’s with New Income Limits

HUD has been great about getting the income limits out on time in most recent years.  With the government shutdown they were still able to get those income limits posted prior to the commencement of the New Year.  Questions always arise as to “when do I implement the income limits?” and “what about Applicants who were on the Waiting List but are now ready to Move-In?”  and lastly, “what about the Annual Re-certification’s I have already processed in advance?” i.e. AR’s. In the affordable housing industry we process AR’s in advance of the tenant’s anniversary date. So for example we have properties that have already completed their 02/14, 03/14 and 04/14 Annuals. The updated income limits have been entered into the software. The “problem” is that the NEW limits will not be pickup up on the certifications that have already been completed. Do we have to go back and undo the annual and re-run them before they are reported on any future Housing Assistance Payments (HAP’s)?  This is being posed because a CA made our client rerun annuals that were already completed when last year’s income limits came out, so they reflected the new amounts.

What the CA didn’t realize is that the Income limits should not matter for Annual Recertifications – they are only used for new move in’s. One of the resources that are afforded to us in this industry is the RHIIP Listserv.  The posting #293 should really help explain things further; Timing of Income Eligibility Determinations – Clarification to Existing Policy Timing of Income Eligibility Determinations Clarification to Existing Policy Subsequent to the publication of RHIIP Listserv #292FY2013 Income Limit Implementation Policy, several individuals have requested clarification on the general policy relating to the timing of determining income eligibility. Specifically, is an applicant eligible to be housed from the waiting list if they have been determined to be eligible based on the prior year’s income limits and, just prior to the applicant being housed, new income limits are published which would make the applicant ineligible? HUD Handbook 4350.3 REV-1 Change 4, paragraph 3-6.C.2 states “Owners determine income eligibility prior to approving applicants for tenancy. Owners compare the family’s annual income to the appropriate income limit prior to placing an applicant on the waiting list. However, owners may wait until a unit is available to verify the applicant’s income eligibility.” Following this guidance in the Handbook, if a unit becomes available and an applicant is selected from the waiting list, is processed for eligibility, and meets all eligibility requirements at the time of processing, the applicant is eligible to move-in to the project even if new income limits have been published.