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  1. HUD RHIIP Training – PH/HCV Chapter 6: Introduction to Case Studies Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  2. Certification Process Opening Question: • Remembering the overview of the housing process yesterday, at what point would the rent calculation process be used? Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  3. BackgroundOverview of the Housing Process Intake Initial Lease-Up Annual Activities Interim Activities Terminations Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  4. Primary Types of Certifications • Initial Certification • Annual Recertification • Interim Recertification • They all follow a basic process Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  5. Certification Process • Family completes paperwork documenting their family composition, income, assets, and allowances and deductions • PHA reviews paperwork and interviews family (UIV) • PHA has family sign verification release forms Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  6. Certification Process • PHA photocopies documents provided by family which prove family statements • PHA sends out verification forms or communicates directly with third party • PHA compares verification forms, when returned, with family statements and documents Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  7. Certification Process • PHA resolves differences in documents by calling third party source and/or family • PHA enters information into computer and/or calculates manually • PHA prints out documents for file • PHA transmits data to PIC monthly Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  8. Training Format • We have reviewed the program basics • Next, we have to focus on the difficult areas of rent calculation • Case studies focus on rent calculation problem areas and simulate the process a reviewer would undertake at the PHA Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  9. The HUD Reviewer • The HUD Reviewer’s role for RHIIP is to see that the steps in the process that affect rent calculation have been done correctly in order to identify errors. • In this training program, we will: • Show you typical documents • Focus on the difficult areas to calculate • Simulate what you will do in the field Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  10. Training Format • In each case study, we will: • Lecture on the regulations as they pertain to the individual topic(s) we will be emphasizing • Perform a calculation on the part of the case relevant to that topic on the HUD Appendix C worksheets Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  11. RHIIP Training – PH/HCV Chapter 7: Case Study 1: Alexander Family Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  12. Alexander Case Study:Process Overview • Topic presentation • Students complete case study • Using Appendix C, File Review Checklist Worksheets • Students review PHA’s HUD 50058 • Students complete Appendix A, Tenant File Review Checklist • Review correct checklist and HUD 50058 Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  13. Alexander Case Study: Topics • Annual Income • Sporadic Income • Earned Income Disallowance (PH) • Earned Income Disallowance for Persons with Disabilities (HCV) Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  14. Alexander Case Study: Topics • Adjusted Income • Elderly/Disability Allowance • Dependent Allowance • Child Care Allowance Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  15. Alexander Case Study: Topics • Total Tenant Payment • Minimum Rent Hardship Exemptions • Rent Calculation (PH Only) • Income Based Rents • Flat Rents Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  16. Annual Income Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  17. Annual Income • All amounts, monetary or not, that go to or are received on behalf of any family member • From sources outside the family • Anticipated during the next 12 months • All amounts not specifically excluded by regulation Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  18. Regular Employment • Annual income includes employment income • Full amount before payroll deductions • Overtime, commissions, fees, tips and bonuses • Other compensation for personal services Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  19. Regular Employment • Reported income will usually be in amounts over a period of time that are less than annual (hourly, weekly, bi-weekly, etc) • Convert reported amounts to annual income Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  20. Sporadic Income • Temporary, nonrecurring, or sporadic income (including gifts) are excluded from annual income • Sporadic income is income that is not reliable nor periodic Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  21. Sporadic Income Example 1 • Justine Cowan – typist with temp agency • Is not always well enough to work full-time • Last year worked 6 months • This year has more medical problems • Doesn’t know how much will work this year • Not working at time of recertification • How do we treat this income? Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  22. Sporadic Income Example 1 • Since not working now, do not count employment income • Must return for an interim when she resumes work • Unless PHA’s policy does not require interim recertifications for income increases • (think UIV!) Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  23. Sporadic Income Example 2 • Sam Daniels – receives Social Security Disability plus works as handyman occasionally. • Claims only worked a couple times last year (no documentation) Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  24. Sporadic Income Example 2 • Does this fit description of sporadic income? • Yes, his earnings fit the category of nonrecurring, sporadic income • How do you handle his working income? • Don’t include in annual income • Tell Mr. Daniels he must report any regular work or steady jobs he takes Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  25. Mandatory Earned Income Disallowance (PH) • CFR 960.255 (please note) • Developed to encourage economic self-sufficiency • A family’s rent will not increase for a period of time if, under certain circumstances, someone in the family begins work or has an increase in earned income • The increase in rent will be phased-in Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  26. Earned Income Disallowance for Persons w/Disabilities (HCV) • CFR 5.617 • Same concept as MEID in PH but for Section 8 it applies to an adult family member who is a person with disabilities and begins work or has an increase in earned income Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  27. Mandatory Earned Income Disallowance • Certain increases in earned income are “disallowed” • An income exclusion • Reported, then subtracted from total earnings • Not all earned income increases are disallowed – family has to qualify Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  28. MEID - Qualified Family (PH) • Family qualifies for the disallowance if: • Adult family member begins employment or has an increase in earned income AND Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  29. MEID - Qualified Family (PH) • Has been previously unemployed for 1 or more years • Is currently involved in an economic self-sufficiency or job training program • Has, within the past 6 months, received TANF or TANF related benefits and services Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  30. MEID - Qualified Family (HCV) • Family qualifies for the disallowance if: • A disabled adult family member begins employment or has an increase in earned income AND Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  31. MEID - Qualified Family (HCV) • Has been previously unemployed for 1 or more years • Is currently involved in an economic self-sufficiency or job training program • Has, within the past 6 months, received TANF or TANF related benefits and services Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  32. Previously Unemployed Includes • Those unemployed for 1 or more years • Those who have worked in the past year but earned less than they would have earned at the prevailing minimum wage, 10 hours per week, for 50 weeks • “Prevailing minimum wage” is the Federal, State, or Local minimum wage, whichever is greater Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  33. During Economic Self-Sufficiency • Family member must obtain employment or experience increase in earnings during economic self-sufficiency • for HCV, family member must also be disabled Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  34. During Economic Self-Sufficiency • Example • While participating in a job training program an individual gets a job. This qualifies the family for the disallowance • Would not qualify if the training program had ended before the individual became employed Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  35. During Economic Self-Sufficiency • Still considered “during” if training ended but certain services, such as a mentoring program, began when the person became employed Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  36. Economic Self-Sufficiency • Definition • CFR 5.603 (please note) • Program designed to encourage, train, assist or facilitate economic independence or to provide work Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  37. Job training Employment counseling Work placement Basic skills training Any program necessary to ready a person for work, including substance abuse or mental health treatment English proficiency Workfare Financial/household mgt Apprenticeship Economic Self-Sufficiency Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  38. TANF In Past 6 Months • Qualifies if: • Received any amount of regular TANF monthly maintenance income in the past 6 months Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  39. TANF In Past 6 Months • Qualifies if… • Received TANF-related benefits or services totaling at least $500 in past 6 months • Includes such benefits and services as one-time payments, wage subsidies and transportation assistance Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  40. Initial Exclusion • Exclude (disallow) any increase in income of the family member as a result of employment over prior income of that family member • For cumulative 12 month period beginning on the date the member qualifies • Breaks in employment will not count toward the 12 months Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  41. Second Exclusion and Phase-in • Begins after 12 cumulative months of full exclusion • Exclude 50 percent of any increase in family member’s income as a result of employment over income of that family member prior to the beginning of employment • employment income is phased-in • For 12 cumulative months • breaks in employment won’t count toward exclusion Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  42. Maximum 4 Year Disallowance • Individual has 4 years to receive: • 12 cumulative months of full exclusion • 12 cumulative months of phase-in exclusion • This is a lifetime exclusion benefit per family member • Could have more than one family member receiving the disallowance at the same time Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  43. Earned Income Disallowance and Interims • HUD Guidance: • For tracking and administrative purposes, PHAs can begin the EID on the on the 1st day of the month following the eff. date of employment • At the onset of the 50% phase-in period and throughout, HUD strongly recommends that PHAs conduct interim reexams to better ensure accuracy in income and rent determination Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  44. Disallowance Example (PH) • James Stewart reports new job - $9000/year • Quit old job earning $2000 annually • Qualifying minimum wage is $6.00 per hr • Was not in economic self-sufficiency program • Was not receiving TANF Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  45. Disallowance Example (PH) • Does James qualify the Stewart family for the disallowance? • Why or why not? Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  46. Disallowance Example (PH) • Answer: • Yes. Because he is considered previously unemployed $6.00 x 10 hrs x 50 weeks = $3,000 James’ previous annual income was $2,000 Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  47. Disallowance Example • James’ previous annual income was $2,000 • James is now earning $9,000 • How much is excluded during initial exclusion? Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  48. Disallowance Example • James’ previous annual income was $2,000 • James is now earning $9,000 • How much is excluded during initial exclusion? • $7,000 is excluded during the initial full exclusion period. Only count $2,000 Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  49. Disallowance Example • James’ previous annual income was $2,000 • James is now earning $9,000 • With everything the same, how much is excluded during the phase-in? Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1

  50. Disallowance Example • James’ previous annual income was $2,000 • James is now earning $9,000 • With everything the same, how much is excluded during the phase-in? • $3,500 is excluded during the second exclusion period. $5,500 is now counted as income Chapter 6: Intro to Case Studies / Chapter 7: Case Study 1