Determining the Annual Recertification Cutoff Date
By Daniel Bagliore
As you may know, the annual recertification process must commence within the 120-day period prior to the annual recertification anniversary date. Assuming the proper issuance of the Initial Notice during the prior (re)certification, and the timely distribution of the three recertification reminder notices for the forthcoming annual recertification, HUD expects Section 8 residents to report for their annual recertification interview in a timely fashion (i.e., prior to the cutoff date), sign paperwork, and provide documentation confirming all sources of income and assets during their recertification interview.
When the resident reports for the annual recertification prior to the cutoff date, the manager is expected to complete the recertification with enough time to provide 30-days’ notice of any resulting rent increase.
When the resident reports on or after the cutoff date, the resident is considered late and loses their right to 30-days’ notice of any resulting rent increase. The recertification should still be completed by, and the tenant rent and assistance payment will be effective on, the anniversary date.
WHAT IS THE CUTOFF DATE?
HUD defines the cutoff date as the 10th day of the 11th month prior to the annual recertification date. The cutoff date must be included in your Initial Notice and 120/90/60-day recertification reminder notices.
HOW TO DETERMINE THE CUTOFF DATE
To determine the cutoff date for the next annual recertification, count the next 11 months starting from and including the month of the last annual recertification; the cutoff date falls on the 10th day of that month.
For example, the resident’s last annual recertification was June 1, 2023. To determine the cutoff date for the June 1, 2024 annual recertification, count the next 11 months starting from and including the month of June 2023. As the 11th month is April 2024, the cutoff date for the June 1, 2024 annual recertification is April 10, 2024.
A quicker approach in thinking about the cutoff date is to count two months back from the annual recertification date and the cutoff date falls on the 10th day of that month.
For example, to determine the cutoff date for the Feb. 1, 2025 annual recertification using this method, count two months back, which, in this case, is the month of December. Therefore, the cutoff date for the Feb. 1, 2025 annual recertification is Dec. 10, 2024.
You may also wish to keep a list of the cutoff dates in your workspace for quick reference. The cutoff date for each recertification month is as follows (remember to use the correct year for each date):
| Recertification Month | Cutoff Date |
| January 1st | November 10th |
| February 1st | December 10th |
| March 1st | January 10th |
| April 1st | February 10th |
| May 1st | March 10th |
| June 1st | April 10th |
| July 1st | May 10th |
| August 1st | June 10th |
| September 1st | July 10th |
| October 1st | August 10th |
| November 1st | September 10th |
| December 1st | October 10th |