HUD COVID-19 Waivers

April 30, 2020
  1. DELAYED ANNUAL EXAMINATIONS

 RULE:  PHAs are required to conduct a reexamination of family income and composition at least annually.

COVID-19 WAIVER:  Can delay recertifications however only have until December 31 2020 to complete annuals for year 2020.

*****  Period of Availability: All annual recertifications due in Calendar Year (CY) 2020 must be completed by December 31, 2020.

  1. ANNUAL EXAMINATION - INCOME VERIFICATION REQUIREMENTS

 

Rule:  24 CFR § 5.233(a)(2) requires PHAs to use EIV as a third-party source to verify tenant employment and income information during mandatory reexaminations or recertifications of family composition and income in accordance with §5.236 and administrative guidance issued by HUD. PIH Notice 2018-18 describes the required verification hierarchy process PHAs must follow.

 

COVID-19 WAIVER:   HUD is waiving the requirements to use the income hierarchy described by PIH Notice 2018-18 and will allow PHAs to forgo third-party income verification requirements for annual reexaminations, including the use of EIV, if the PHA wishes to conduct the annual recertification rather than delaying the family’s annual recertification

 

Self Certifications: 

  1. Over phone -but must be documented by PHA staff with a contemporaneous written record),
  2. email or
  3. postal mail with a self-certification form by the tenant, or
  4. through other electronic communications.

***** DISCREPANCIES:   PHAs that conduct annual examinations under this waiver/alternative requirement will be responsible for addressing any material discrepancies that may arise later.

For example, if a tenant self-certified that the tenant lost their job, but later the EIV Income Validation Tool (IVT) shows the tenant’s employment continued, the PHA must take enforcement action in accordance with their policies and procedures.

Period of Availability: The period of availability to conduct annual reexaminations using these modified verification requirements ends on July 31, 2020.

FAMILY INCOME AND COMPOSITION: INTERIM EXAMINATIONS

RULE:  PHAs are required to use EIV for verification of family income at interim reexamination. 24 CFR § 5.233(a)(2) requires PHAs to use EIV as a third-party source to verify tenant employment and income information during mandatory reexaminations or recertifications of family composition and income in accordance with §5.236 and administrative guidance issued by HUD. PIH Notice 2018-18 further describes the required verification hierarchy process PHAs must follow.

COVID-19 WAIVER:  HUD is waiving the requirements to use the income verification hierarchy as described by PIH Notice 2018-18. HUD will allow PHAs to forgo third-party income verification requirements for interim reexaminations, including the required use of EIV. During the allowable period of eligibility, PHAs may consider self-certification as the highest form of income verification to process interim reexaminations.

Self Certifications: 

Over phone -but must be documented by PHA staff with a contemporaneous written record),

  1. email or
  2. postal mail with a self-certification form by the tenant, or
  3. through other electronic communications.

***** DISCREPANCIES:   PHAs that conduct annual examinations under this waiver/alternative requirement will be responsible for addressing any material discrepancies that may arise later.

For example, if a tenant self-certified that the tenant lost their job, but later the EIV Income Validation Tool (IVT) shows the tenant’s employment continued, the PHA must take enforcement action in accordance with their policies and procedures.

Period of Availability: The period of availability to conduct annual reexaminations using these modified verification requirements ends on July 31, 2020.

Please see HUD Notice for other WAIVERS

PIH Notice 2020-05: COVID-19 Statutory and Regulatory Waivers (April 10, 2020)

 

Policy Notices