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Are you dealing with unusual long-term management problems or extra administrative burdens at your site? For instance, do you have unusually high maintenance and security costs because you’re managing a site in a deteriorated area with a high incidence of crime and vandalism? Or are you managing a site with a complicated structure of financing and subsidies, which requires sophisticated—and expensive—oversight?

HUD requires you to offer to meet with applicants and residents in specific circumstances. These meetings let applicants and residents dispute important decisions that you’ve made about their housing assistance. We’ll describe three situations you’ll most likely deal with in which you must offer to meet with applicants and residents.

HUD’s noncitizen rule says that only households made up entirely of U.S. citizens and/or certain eligible noncitizens (such as a permanent resident alien) can benefit from federal rental assistance [HUD Handbook 4350.3, par. 3-12 (A)]. To ensure that an ineligible noncitizen doesn’t get assistance, HUD requires you to verify the immigration status of most applicants who declare that they’re eligible noncitizens.

A household may report to you that its members include children who are part of a joint custody arrangement. That is, the children live part of the time with the household and part of the time with their other parent, who doesn’t live in the unit. For example, a household head may report that she has two sons who will be living in the unit during the week and with their father on weekends. When certifying or recertifying these households, you need to know whether to count the children as household members for purposes of determining eligibility, unit size, and household income.

Occasionally, you may need to perform an interim recertification for a household. This means that you must recalculate the household’s income and assistance before the household’s scheduled recertification date based on a change in the household’s situation. For example, when a household tells you that its income has increased you may need to initiate an interim recertification. But not every change warrants an interim recertification. HUD requires you to perform them only after you’re notified of five types of household changes [HUD Handbook 4350.3, par.

By Carolyn E. Zezima, Esq.

HUD recently posted Notice H 2015-01 regarding program eligibility for HUD-assisted sites for all people regardless of sexual orientation, gender identity, or marital status. The notice’s intent is to increase program participants’ awareness of HUD’s Equal Access Rule for actual or perceived discrimination based on these characteristics.

Do you have households at your site that were eligible for housing assistance when they moved in but aren’t anymore? These are households whose income has increased enough that they’re no longer eligible for assistance because they can now afford to pay the gross rent. The HUD Handbook dictates specific steps you must take in this situation. By taking these simple steps, you can avoid doing any further recertifications for over-income households.

As an owner or manager of a HUD assisted site, you probably know that you must use one of HUD’s model leases for all your assisted residents. But are you certain which model lease applies to your site? Appendix 4 of HUD Handbook 4350.3 contains four different model leases. Which version you use depends on which program your site falls under.

Last month, we discussed renting units to police or security officers as a potential method of deterring crime at your site. Whether your site houses security officers or other types of live-in employees who enhance services provided to households, you need to be mindful of the safety of your household members. In most states and jurisdictions, owner responsibilities cover, at least to some degree, protection of their residents.