Recertifcations are a time-consuming and very important part of managing a subsidized housing facility. No matter the regulatory body, recertifications are fairly similar: Interview the Resident, verify the information, and complete the necessary paperwork by the applicable deadline.
Sounds simple, doesn't it? However, delayed or incomplete verifications, Residents who are away, and other elements can complicate the process. All too often, these complications result in a delayed recertification. It's important to remember that a late recertification should be an extreme rarity. Managers should make every effort to ensure that recertifications are completed and submitted on time.
To review deadlines:
CT law requires that residents receive 30 days notice of a rent increase, as do most regulatory guidelines. With decreases in rent, or when the rent stays the same, regulatory guidelines and landlord-tenant law will permit the recert to be signed at any point up to the date the certification goes into effect.
Example:
A recert to be effective 10/01, with an increase in Tenant Rent, must be signed by 9/01.
A recert to be effective 10/01 with a decrease in Tenant Rent, can be signed at any point up to 10/01.
EHM / CHM policy is to have ALL recertifications signed a month in advance and to be submitted through the appropriate electronic platform as applicable (One Site, TRACs, MINC). This means that it is important to take all necessary steps to ensure that recertifications are completed on time. Be sure to send all necessary reminder notices, and keep a copy on file. Remember, it is the Resident's responsibility to respond on time, and to ensure that you have the information you require to complete the recertification. If they fail to comply, they risk losing their subsidy. In a HUD 202PRAC or HUD 811PRAC, they risk eviction.
Even when a Resident is away, either due to a planned absence or a medical issue, Administrators and Occupancy personnel must make an effort to complete the certification in a timely manner, and must document all steps taken. Steps which should be taken to avoid late certifications due to Resident absence include:
1. When Residents will be away during the recert period, either be sure to sign paperwork
before they leave, or be sure to obtain a mailing address so that needed paperwork can
be forwarded for signature. Be sure to also obtain a phone number, so that a phone interview
can be conducted, and the Resident can be contacted for any missing paperwork.
2. Check the Resident's file for any documentation of an individual with Power of Attorney
who may be able to assist with completion of paperwork.
3. Make contact with the individual noted on the Residents HUD-92006 or Personal
Contact form (if said individual is noted as the contact for certifications).
4. If the Resident is away due to a medical issue, enlist the help of the site's RSC,
if applicable, to make contact with the Resident or Resident's family in order to
ascertain whether the Resident is well enough to receive visitors, and conduct
the interview in the healthcare facility or wherever the Resident is recuperating
if feasible. In HUD sites, a certification that is complete and simply awaiting a
signature, can be noted on the 50059 as "Resident unable to sign," with the
signature obtained when possible.
Please note, if a Resident causes a recertification to be late, either by not reporting for an interview by the deadline, by failing to supply necessary paperwork, or by failing to sign the recert, they forfeit their right to a 30-day notice, and the recert should be implemented as normal.
If the delay is caused by Management or a third party, any decrease in subsidy must be implemented as of the effective date. The Resident must be given a 30-day notice of the increase. In HUD sites, the resulting gap in funding must be absorbed by the site. In USDA/RD sites, it is the Management company who must absorb that loss.
Missing Verifications:
Recertifications should never be delayed solely due to a missing third party verification. Acceptable methods of verification include:
1. Third party verification, including:
- Third party written
- Third party verbal / phone
- Third party obtained through fax or email.
NOTE: Third party verification is always the preferred method. Other methods
should be considered ONLY when third party verification is impossible, delayed
beyond two weeks, or when regulatory guidelines specifically indicate another
method for a particular item (ex., EIV for Social Security income in HUD sites).
You should always attempt to follow-up on third party verifications at least twice
(three total attempts) before considering them impossible.
Example:
Administrator Lynn Jones is completing the Annual Recertification for Joe Renter.
Joe receives a foreign pension, which he says will take weeks to get a response on.
He there provides Lynn with four copies of his most recent pension check stubs.
Lynn sends out the first verification. Two weeks later, she sends a second, marked
"2nd attempt." One week after that, she sends out another, and notes it as "3rd attempt."
She then uses the copies Joe provided in order to calculate the Recertification. If the
third-party verification comes back, she will check to make sure the amount she used is
correct, and will correct the certification as necessary.
2. Documents submitted by the tenant, including
- Copies of cancelled checks / receipts
- Statements showing payments made
NOTE: Bank statements are NOT acceptable proof of Social Security or
Pension income, as they do not show Gross amount; they show Net amount.
3. Signed statement by the Resident
Such statement should include the Resident's best recollection of the
amount paid to a particular provider, the amount earned from an
employer, or the appropriate bank balance, interest earned, etc., during
the previous twelve months, as well as the Resident's signature and the
date signed.
NOTE: A signed statement is a last resort, and should only be used when
other methods are impossible to obtain before the deadline. All verification
attempts, including third-party requests and requests for documents from the
Resident, should be documented in the file before accepting a signed statement
from the Resident.
from the Resident.
And remember, the only information a Resident is required to provide involves income and assets. Recerts awaiting only medical verifications should be completed using the methods above, or completed without the missing items and corrected later.
Any recertification which appears to be headed for late completion should be reviewed with your Regional Manager or your Property Manager in order to ascertain whether additional steps can be taken in order to ensure timely completion.
Please refer to additional guidelines here.
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