In April, HUD issued the 2024 income limits for HUD programs and Low-Income Housing Tax Credit Property, as well as an individual Fair Market Rent annual increase and income limit cap of 10%. As you become acquainted with the new limits, it’s also a good idea to review recertification requirements to ensure compliance.
Recertification helps protect the interests of property owners, tenants, and public housing programs by promoting fairness, transparency, and sustainability. To ensure an eligible household receives the appropriate level of assistance, a recertification takes place every 12 months. It involves a review of income, assets, expenses, and family composition.
For multi-family housing programs, owners are responsible for facilitating annual recertification; reviewing and verifying tenant information, and adjusting assistance payments or rent as required. For the Section 8 Housing Choice Voucher Program, overall responsibility for recertification rests with the local Public Housing Authority (PHA). Owners and tenants are responsible for providing timely information as required.
In addition to annual recertifications, there are interim recertifications. These occur to help adjust rent and subsidy amounts quickly if there’s a sudden change in income or household composition. So, if a tenant loses or gets a job, work hours are reduced, a tenant is injured and their ability to work is impacted, or a household member is added or removed, an interim recertification can occur.
Per the Housing Opportunity Through Modernization Act (HOTMA), owners must have policies detailing when a household must report a family income or compensation change. Any resulting interim recertification should occur within 30 days of an income decrease.
PHAs may consider establishing a checklist for Tenant Relations Assistants to ensure all recertification compliance requirements are met. The checklist should be signed or initialed by the representative and kept in the tenant’s file, serving as documentation that all compliance requirements were verified for the tenant.
Other ways to help promote compliance include conducting regular training on HUD requirements; conducting internal audits to review recertification processes and fix issues before they escalate; and considering whether compliance software can help manage recertifications by issuing alerts for upcoming recertifications, tracking key dates, automating calculations, and more.
Should you need assistance or have questions about conducting an internal audit of the recertification process, RBT CPAs can help. We can also support your accounting, tax, audit, and advisory needs. To learn how we can be better together, give us a call today.
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Please Note: RBT CPAs is an accounting, audit, tax, and advisory services firm. Should you need legal advice on the recertification process, it is in your best interest to contact legal counsel.