HUD Program Compliance

Format: On-Site: 1½ - 3 hours or Virtual: 2 - 3 hours
Focus: Once Owner Software is HOTMA compliant (sometime in 2024), HUD will implement the most comprehensive changes to the way HUD properties determine eligibility and calculate income and rent since 1981 when Congress raised the rent cap from 25% to 30% of Adjusted Income. The changes are expected to have a ripple effect on other affordable housing programs including Rural Development and the Low-Income Housing Tax Credit and HOME programs. Find out the most significant changes, what guidance HUD has provided to date, and when you will need to start following the new rules.

Format: On-Site: 8 hours or Virtual: two 4-hour sessions or three 3-hour sessions
Focus: On 9/29/23, HUD issued the long-awaited policy guidance on implementing HOTMA. Additional guidance is promised by the end of 2023. The course will include everything that is known about what, how and when to implement the numerous HOTMA changes, helpful resources and tools, so that, regardless of what HUD does or does not do, after completing the course, you will be ready for HOTMA.
Topic 1: Income and Income from Assets – including fosters not counted in the income limit, new income exclusions, methods of calculation – means tested, streamlined, traditional, student financial aid – new definitions, changes to Section 8 exceptions, how to calculate for both Section 8 and other HUD programs)
Topic 2: Assets and Income from Assets- including new asset exceptions, asset threshold, non-necessary personal property, and method to calculate income from assets
Topic 3: The Section 8 Asset cap - including two types, when and how to apply to residents and new applicants, exceptions, owner hardship policies
Topic 4: Deductions and Allowances - including CPI adjustment, 10% medical and disability “deductible” – new tenants and existing tenant phase-in, owner hardship policies
Topic 5: Annual Recertification – including new methods to do annuals, owner option for retroactive rent decreases, other issues regarding when rent and HAP increase or decrease
Topic 6: Interim Recertification – including lease requirements, increases based on 10% change in adjusted income, how to determine, owner option on % change for decreased income, owner option on using EIV, changes and owner options regarding increasing rent when earned income increases
Topic 7: Miscellaneous – New forms – leases, 50059, 9887 and 9887A, how and when to implement, De minimum errors – impact on owner, impact on tenants, suspension of EIV Income Discrepancy reports, new ways to verify SSN’s.

Format: On-Site: 4-hour Workshop
Virtual: One 4-hour session or two 2-hour sessions

Focus: For newly hired managers or those with no HUD Multifamily experience as well as those needing a refresher course. This course highlights three key requirements of the 4350.3 Rev 1 Chg. 4 essential to the work of the property manager. Chapter 3 - Eligibility for Assistance and Occupancy, Chapter 4 – Waiting List and Tenant Selection, and Chapter 5 – Determining Income and Calculating rent. Mini-quizzes and case studies are included to reinforce the learning. Students will need a calculator.

Format: On-Site: 6-hour Workshop
Virtual: One 6-hour session (30 min lunch) or two 2 3/4-hour sessions

Focus: For newly hired managers or those with no HUD Multifamily experience as well as those needing a refresher. This course highlights 5 key requirements of the 4350.3 Rev 1 Chg. 4 that are vital to the day-to-day work of the property manager. Chapter 3 - Eligibility for Assistance and Occupancy, Chapter 4 – Waiting List and Tenant Selection, Chapter 5 – Determining Income and Calculating rent, Chapter 7 – Recertification, Unit Transfers, and Gross Rent Changes, and Chapter 8 – Termination.
Mini-quizzes and case studies are included to reinforce the learning. Students will need a calculator.

Format: On-Site: 4-hour Workshop or Virtual: One 4-hour session or two 2-hour sessions

Focus: A deep dive into some of the more challenging aspects of HUD Occupancy including how to know your project type and why it matters, why 2-persons per bedroom is not always a “safe harbor”, applying the Section 8 student rule after move-in, the non-citizen rule, Gig income and New Age assets, verifying and calculating allowances, new guidance on fair housing issues related to criminal screening, application intake and managing the waiting list. Mini-quizzes and case studies are included to reinforce the learning. Students will need a calculator.

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes
Focus: The requirement to do Annual and Interim Recertifications on a HUD property can feel like being chased by a freight train. The course will include:
• Annual Recertification basics including timing, procedures, notices to residents, and effective dates of changes in rent and HAP based on the resident’s cooperation or non-cooperation, the amount of time the owner has to process, owner caused delays, and the cooperation of verifiers, .
• Interim Recertification basics when tenants must report, owner’s responsibilities, effective dates of rent and HAP changes when tenant does and does not report timely.
• Current HUD guidance on COVID and recertification.
• Tips on how to stay on top of the situation and drive your own train.

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes

Focus: For subsidized tenants, there are three types of termination: termination of housing assistance, termination of tenancy, and termination of tenancy by the tenant. HUD devotes an entire chapter of the 4350.3 Rev 1 (Chapter 8) to this complex topic and understanding when and how to apply the rules can be confusing. This session clearly explains the differences between the grounds, procedures, and timelines for each type of termination and includes a discussion of how EIV discrepancies and repayment agreements come into play for both termination of assistance and termination of tenancy. Includes HUD’s December 1, 2023 proposed rule on 30-day notice for non-payment of rent.

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes

Focus: Learn or refresh on how HUD’s Utility Analysis base-line analysis works, how to calculate and apply a factor-based analysis in year’s 2 and 3, and when and how-to phase-in decreases. Understand the significance of the tenant comment period for both base-line and factor-based analyses. Learn what HUD expects, what you are and are not required to provide to HUD or the PBCA, and how to determine if the factor-based analysis is sufficient. NEW: On 7/15/22 HUD issued Treatment of Solar Community Credits on Tenant Utility Bill. This course will include the impact on when and how a Base-Line Analysis is required.

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes

Focus: If I buy my medications in Mexico, can I deduct the trip as a medical expense? Using the handbook language, numerous examples and a case study, this course covers the who, what, why and how of the medical deduction. who qualifies, what does, does not, and/or sometimes counts, how to verify, how to calculate expense and the final deduction.

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes

Focus: :Knowing the regulations and processes for managing a HUD property waiting list are put to the test in an MOR. More importantly, they are key to staying in compliance with Fair Housing laws. This webinar will review creating and maintaining, opening, and closing, placing families with disabled members, documenting changes, updating waiting list information, removing names from the waiting list, reinstating applicants to the list, and record-keeping. This course will reference the 4350.3 as well as HUD’s Notice H 2014-16 Waiting List Administration and FHEO’s April 2022 Guidance on Application Processing and Marketing. HOTMA changes will require notifying the applicants on your waiting list about new requirements. When should you do that and what should you say?

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes

Focus: This course focuses on the requirements of Chapter 4 of the 4350.3 as well as updated HUD requirements since issuance of the handbook in 2013. We will cover required, allowed, and prohibited screening practices, income targeting, preferences, implementing your occupancy standards when placing tenants, accepting applicants for the waiting list, approval for occupancy, rejecting applicants, assigning accessible units, and making sure tenant selection plan is in compliance with current HUD requirements. Handout includes a TSP checklist.

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes

Focus: Learn how to effectively and efficiently conduct the all-important (and HUD-required) applicant interview to ensure that assistance goes to families who are qualified. Includes tips on how to conduct interviews in safe and compliant manner face to face, by telephone and via a virtual app. This course covers how to establish rapport, gain trust, and ask the right questions in the right way while ensuring a consistent scripted approach to prevent costly fair housing mistakes. Includes valuable tips on interviewing persons with various types of disabilities and how to respond to situations and conversations that commonly occur.

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes
Focus: Adjusted income is the basis for rent calculations for most tenants in HUD assisted housing. To get there, we must know the ins and outs of allowable deductions: the dependent deduction, the elderly/disabled Household deduction, and allowable expenses for childcare, disability, and medical. What counts, when and why and how do we calculate them? Participants will have the chance to calculate each of the deductions through several mini case studies.

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes

Focus: The Management and Occupancy Review (MOR) is how HUD proves to taxpayers and to Congress that subsidy dollars are being wisely spent. So, whether performed by HUD, the PBCA, or CA, owners and managers are held to a high standard before, during and after the review. This course is an overview of what to expect, how to prepare, what to do at “zero hour” and how to respond when it is over. We will also review HUD’s new method for establishing MOR schedules and how HOTMA will affect your MOR scores in 2024.

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes

Focus: An introduction to the EIV income discrepancies. Simplifies what at first glance is very complicated. Shows participants how to “read” an Income Discrepancy Report – the Period of Income, Effective Date of Action, Actuals vs. Annualized Last Quarter, and how EIV comes up with those negative and positive numbers. Participants will learn the causes of false and true discrepancies and the basics of how to investigate and resolve them. Once the Owner’s software is HOTMA compliant (sometime in 2024), HUD says the use of EIV Income Discrepancy Reports will be suspended until HUD can make the logic of the reports work with HOTMA reporting rules. This course will be revised when that happens.

Format: On-Site: Two-Day Workshop – 12 hours of training or
Virtual: two 6 – 6½ hour sessions or four 3 – 3½ hour sessions

Focus: This two-part course is essential for property management professionals who work with the tenant certification and recertification process on HUD properties. After completing both parts of the course, you will have the information needed to master the HUD Enterprise Income Verification system. Students will need a calculator. Mini-quizzes, case studies and whiteboarding activities are included to reinforce the learning. The use of EIV will change after the Owner’s software is HOTMA compliant. This course will be revised as needed to be compliant with HOTMA.

EIV Basics: History and purpose of EIV, how to gain access, responsibilities of EIV Coordinators, EIV Users and EIV non-users, security requirements, use of the reports in annual and interim recertifications, and the purpose, use, retention and how to read each of the nine EIV reports.
EIV Advanced: Starting with a Pretest/review of EIV Basics followed by investigating and resolving tenant income discrepancies and resident repayment agreements. Students will practice reconciling the EIV Income Discrepancy Report, identifying overpayments and underpayments of subsidy, and using third party verification to calculate what the tenant owes or has overpaid in rent.

Format: On-Site: 6 Hour Workshop or Virtual: 6 Hour session or 2-3 hour sessions

Focus: Students will learn what EIV does and does not report, refresh and data match schedules EIV follows, how to read the EIV Income Report and Income Discrepancy Report, what HUD requires, how to investigate and resolve tenant income discrepancies – both valid and invalid, and the rules of resident repayment agreements. Students will practice reconciling the EIV Income Discrepancy Report, identifying overpayments and underpayments of subsidy, and using third party verification to calculate what the tenant owes or has overpaid in rent. Students will need a calculator. Mini-quizzes and case studies are included to reinforce the learning. Once the Owner’s software is HOTMA compliant (sometime in 2024), HUD says the use of EIV Income Discrepancy Reports will be suspended until HUD can make the logic of the reports work with HOTMA reporting rules. This course will be revised when that happens.

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes

Focus: The EIV Master File / Binder is reviewed in your Management and Occupancy Review (MOR) and failure to maintain each required document for the required period of time will be a finding cited on the MOR report. The course will cover the documents that must be maintained for Owner/Coordinators, Secure Systems/EIV Users, Secure Systems/EIV Non-Users, Independent Public Accountants (IPAs), and the EIV Reports required to be maintained as well as EIV reports we recommend be retained as a Best Practice. We will discuss acceptable ways to organize the binder, which documents are never destroyed, and which documents must be destroyed and how often. The slides will include samples and/or screenshots of each document and report we discuss.

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes

Focus: There is more to owning or managing a HUD financed or subsidized property than knowing the 4350.3. This course highlights the key requirements of the “other” handbooks: HUD 4381.5 The Management Agent Handbook, 4350.1 Multifamily Asset Management and Project Servicing, 4370.2 Finance Operations and Accounting Procedures for Insured Properties, 4370.1 Reviewing Annual and Monthly Financial Reports. A must for owners and management agents who are new to HUD programs and a valuable refresher for those who are not.

Format: On-Site: 6-hour Workshop or Virtual: One 6-hour session or two 3-hour sessions

Focus: Whether the property is a Section 8, Rent Supplement, 236, 202, 202/8, 202 PAC, 202/811 PRAC, 231, 221(d)3 or 221(d)3 BMIR, having an income stream that keeps pace with operating costs is key to ensuring the present and future viability of the property and its ability to provide the facilities and services the residents need. Takes an in-depth look at the various rent increase methods available to housing providers, which ones apply to which type of property, when and how the Owner can choose their method, what to submit with the request, and how to justify line-item increases over 5%. The course will be based on the current Section 8 Renewal Guide, Chapter 7 of the 4350.1 - – Processing Budget-Based Rent Increases, and proposed guidance from the Draft Revised 4350.1 Chapter 2.06 – Budget-Based Rent Adjustments. Participants will need a calculator.

Format: On-Site: 2 hours or Virtual: 2 hours
Focus: Budget-Based Rent Increase submissions are often delayed or denied due to the Owner submitting an incomplete package. In this course you will learn what, when and how to submit your package, how to respond to follow-up questions and requests from HUD, and when and how you can appeal a denial or partial denial of your request. The course is applicable to Section 8 projects who have renewed under Options 2 and 4, or Option 3 Lite are eligible as are some Option 5 projects. It is also applicable to 202 PACs, 202 PRACs, 811 PRACs and HUD-insured projects where a budget is usually the only way to obtain a rent increase.

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes
Focus: Are you leaving money on the table when you could be processing a special claim? HUD allows Section 8, 202/8, 202 PAC and 202/811 PRAC properties to submit requests for reimbursement of losses due to unpaid rent by the tenant, tenant damages or vacancy when the losses exceed the limited security deposits HUD allows owners to collect.

This course will cover:

• How to make a Vacancy Claim for time lost between tenants.
• How to make a claim for Unpaid Rent, Tenant Damages and Other Charges left at move out.
• The difference between normal wear and tear and damages.
• How to calculate "life expectancy" of replaceable items and determine what can be billed to HUD
• What forms and documentation are required.

Format: On-Site: 1 – 1½ hours or Virtual: 90 minutes

Focus: PRACs provide supportive housing for the elderly and for persons with disabilities. While many of the PRAC program rules resemble those of Section 8, there are many important differences. This course covers PRAC basics and shows to how to apply the special rules that govern them including income limits, eligibility rules, rules about adding an adult child, eligibility of a remaining family member, admitting over-income or non-elderly applicants, rent calculations, charges in addition to rent, marketing requirements, the 202 and 811 PRAC leases, security deposits, and termination. Citations from the 4350.3 Rev 1 are included for later reference.