Last month, in Set House Rules on Extended Absences and Abandonment, we discussed what may happen if an entire household leaves your site for an unexplained extended absence. This month, we’ll look at a situation in which an individual member of a household is absent. Oftentimes, these members are absent due to medical reasons.
Sometimes a household will disappear for weeks at a time. Signs may indicate the household may not come back. No one answers the household’s phone, their mail piles up, and their assigned parking space remains empty. When a unit is left unattended, health and safety hazards such as rotting food or frozen pipes can result. Plus, HUD frowns on wasted assistance if an assisted unit isn’t occupied. But often, when you think households are gone for good, they come back.
When a household member leaves, you need to take into consideration possible changes to the household's subsidy and the possibility of having to move the household to another appropriately sized apartment. For example, after a member moves out, the household could still be getting allowances that reduce its rent, but those allowances are attributable to the member who departed. Or after a household member moves out, the unit the family occupies may now be too big for the number of individuals who make up the “new” household.
If you work for a PHA or own a property that’s required by HUD to undergo physical property inspections with the Real Estate Assessment Center (REAC), it’s important to keep your property safe and sanitary. Doing so will maintain and increase federal funds for your site and reduce the frequency of future REAC inspections.
An applicant or household member may claim to get no income from any source. In these situations, it’s important to be skeptical. HUD management reviewers and auditors scrutinize these claims to keep HUD from overpaying assistance to household members. If it turns out that a household member made a mistake or even lied to you about having no income—and you did nothing to verify the claim—HUD could require your site to reimburse the agency for the excess assistance it paid to the household member based on the claim of no income.
If you’re like most managers, you probably follow up with a resident after an annual unit inspection only if you found serious housekeeping problems during the inspection. But by limiting your follow-up to this situation, you could be missing a great opportunity to head off maintenance problems and HUD violations at your site. Instead, follow up with all residents after annual unit inspections by telling them what you found during the inspection, what they did right and wrong, and what behavior needs to be changed.
By Carolyn E. Zezima, Esq.Controlling pests is an essential aspect of maintaining your site in a safe and healthy condition as well as complying with HUD physical inspection standards. Pest infestations create significant health risks for people and can result in a pretty big deduction from your REAC inspection score for a health and safety violation. For example, cockroaches and rodents are considered major public health risks to staff and residents, particularly children and the elderly, causing bacteria, viruses, and other diseases and triggering allergies and asthma.
Screening for credit and rental history are among the list of permitted screening criteria commonly used by owners [HUD Handbook 4350.3, par. 4-7(F)]. The Fair Trade Commission (FTC) recently issued new guidance for owners who use background checks to screen tenants to help them comply with the federal Fair Credit Reporting Act (FCRA), which the FTC helps enforce.
The Enterprise Income Verification (EIV) system was developed by HUD to verify income and employment information for applicants and tenants in all of the agency’s assisted housing programs. Information in EIV is derived from computer matching programs initiated by HUD with the Social Security Administration (SSA) and the U.S. Department of Health and Human Services (HHS), for all tenants with valid personal identifying information [name, date of birth (DOB), and Social Security number (SSN)] reported on the form HUD-50059.
HUD’s Enterprise Income Verification (EIV) system contains a number of reports used to verify employment and income of applicants and residents. HUD asks owners to use EIV to monitor compliance of existing residents. Every month, owners and agents are required to view and catalog certain reports periodically in a separate “Master File.” This file is separate from the tenant file, which contains detailed reports for members of that tenant’s household, copies of notices, verification documents, and new certifications.
