Use Checklist to Ensure Efficient and Complete Interim Recertification Meetings

Households often report changes in their composition, employment status, income, or allowances. As a result of such changes, a household may have to move to a smaller or larger unit or pay a higher or lower share of the rent. To determine what effect the reported changes will have on the household, HUD rules require you to perform an interim recertification whenever a household reports any of the following [Handbook 4350.3, par. 7-10]:

• A change in family composition;
• An increase in a family's cumulative income of $200 or more a month;
• An increase in allowances such as an increase in the number of dependents or a new disability assistance expense;
• Most decreases in income except in cases where the resident took deliberate action to avoid paying rent, such as by quitting a job to qualify for lower rent, or if the owner determines that the decrease in income will last less than one month; or
• A change in citizenship or eligible immigration status of any family members.

To perform the recertification correctly, it's important that you meet with the household to get complete and accurate information and cover certain topics required by HUD. However, site staff may not be adequately prepared to cover all the required topics. They may be wasting time on unnecessary information by covering the same material covered in the last annual recertification meeting. As a result, you don't get all the information you need to recertify households properly.

We'll give you an overview of the best way to prepare for and conduct an interim recertification meeting, what topics to cover, and what forms to get household members to sign. And we'll give you a Model Form: Interim Recertification Meeting Checklist that you can adapt for use at your site to ensure effective interim recertification meetings.

Tell Households What Information to Bring

Households may report interim changes by phone, written notice, or coming into the management office to report the changes. Upon receiving a resident's request for an interim recertification, owners must process a recertification of household income and composition within a reasonable time, which is only the amount of time needed to verify the information provided by the resident. Generally, this should not exceed four weeks [Handbook 4350.3, par. 7-11].

When setting up the meeting within four weeks of the request, you should tell the household head what documentation to bring, including addresses and other contact information for all income sources, banks, and doctors, plus records of expenses. And ask the resident to make sure not only that the household head or co-head attends the meeting, but that any new adult household members and any members whose change in circumstances triggered the recertification also attend.

What to Cover at Meeting

To ensure that site staff cover all the topics HUD requires at interim recertification meetings, use an interim recertification meeting checklist, suggests management expert Pam Roberts, Director of Training for the Gene B. Glick Company. Ask site staff to check off each topic in the box provided after they've gone over it with households. This way, you have a record to show that you've covered all required topics for interim certification.

For example, if you're evicting a household for concealing new income, you can point to the checklist to show that you discussed the duty to disclose income with household members and explained the penalties for not doing so. This could help you defeat a claim by household members that they didn't know about or understand their duty to disclose.

Here's what you need to cover during an interim recertification meeting:

Explain recertification process. Give the household a brief overview of the interim recertification process. Let them know that based on their report of certain changes, you must recalculate their household income and rent and, if necessary, reevaluate whether their unit is the right size for them.

Also, remind the household about the verification process and the penalties for giving false information in recertification meetings, says management expert Mark Alper, senior trainer for the National Center for Housing Management.

Review reported changes. Ask the household about the specific changes in composition, employment, income, and allowances. Be sure to ask the household directly about each change.

If household reports new or departing members. HUD requires households to get your approval before new members move in and to report move-outs to you when they happen. Get the names and dates of birth of any household members who have moved in or out since the last certification or recertification. If the household head is departing, HUD requires that the household name a new household head.

If there are new household members, you must get their birth dates and Social Security numbers. Have households document or certify the Social Security numbers of all new members over age 6 [Handbook 4350.3, par. 3-9]. Also, have new members sign a declaration certifying citizenship. And find out the amount and sources of income and assets for all new household members.

It's important to keep in mind that the addition or departure of a member may change household income or allowances. For instance, if an elderly member dies or leaves the unit, the household may stop getting that member's income and it will no longer be permitted to claim an elderly allowance for that member. Or a new household member may have income from employment or from assets that you'll need to count. Therefore, you'll need to ask them about these other following factors.

If household reports change in employment status. HUD rules require households to report whenever an adult household member who was reported as unemployed on the most recent recertification becomes employed. And households may choose to report that a household member no longer works. If a household member has a new job, get the employer's name and contact information, the date the job started or will start, and the monthly pay.

If you are told that a household member no longer works, be sure to confirm the address and contact information of the former employer so you can verify that the household member doesn't work there anymore. Remember that HUD rules say that you don't have to recertify these households if the household member deliberately quit the job to qualify for lower rent or if the decrease in income will last less than one month.

If household reports change in income. HUD rules require households to notify you if the household's income cumulatively increases by $200 or more per month. And they may choose to report any decreases in income. If they report an increase or decrease, check the appropriate box on the checklist and find out the amount of the increase or decrease, the date it took effect, the reason for the increase or decrease, and the name and contact information of the income source.

You can delay interim recertification if you have verification that the household's income will be partially or fully restored within two months. For example, a resident reports to the owner that he was laid off from his job last week. The owner verifies that the resident lost his job and has filed for unemployment benefits. The processing of his application for unemployment benefits hasn't yet been completed. The owner may wait until the processing of the unemployment claim has been completed. But while you wait, you may require the resident to pay the current amount of rent until the interim recertification is complete.

If household reports changes in expenses and allowances. Households may report that their allowance information such as the amount of medical or child care expenses and the age, dependence, or student status of household members has changed. Or the household may report the addition or departure of household members, which may change the type and amount of allowances they are entitled to. Review the types and amounts of any expense and allowance changes, and get names and contact information for verification sources such as doctors and social service agencies.

Have household members sign individual verification forms. Have household members sign all the third-party verification forms required to verify any of the reported changes.

Reevaluate unit size. If the household reports a change in household composition, evaluate whether the current unit is still appropriate for the new household or whether the household must transfer to a different unit. If the household must transfer to a different unit, tell the household that the lease requires the household to move to a unit of appropriate size within 30 days, unless they decide to remain in the same unit and pay market rent.

Complete Form HUD-50059. This is the form you submit to HUD to calculate the housing assistance and the household's share of the rent. Input any changes to the household's income or other characteristics in the owner's software program and print out the form. HUD requires you to fill out this form and the accompanying worksheet to reflect the changes to household composition or income, then have the household head and co-head sign the form. After obtaining household and owner representative signatures, electronically transmit the interim recertification to the contract administrator or HUD to update the tenant information in TRACS. Maintain a copy with original signatures in the household file. And provide the household with a separate copy.

Other topics to cover, if relevant. You also should use the meeting to go over the following topics:

• Notice of rent increase or decrease. If the household's share of the rent has increased or decreased as a result of changes in household composition or income, you must notify the household in writing of the amount [Handbook 4350.3, par. 7-13].
• Have new household head sign the lease. If the household head has moved out or died, have the new household head sign the lease.
• Changes to house rules, regulations. Use this opportunity to review any changes to house rules and unit inspection procedures since the last annual recertification, says Roberts. Also, tell households of any new regulations that affect them and give them any other notices required by law, she adds.

Insider Sources

Mark S. Alper: Vice President for Compliance, National Center for Housing Management, Orange Park, FL; www.nchm.org.

Pam Roberts: Director of Training, Gene B. Glick Co., 8425 Woodfield Crossing, Ste. 300, Indianapolis, IN 46240; www.genebglick.com.