Ross Business Development

The Social Security Administration (SSA) announced the resumption of debt collection activities, through the Treasury Offset Program (TOP), for debts accrued prior to March 2020. This decision comes after a suspension of collections due to the economic challenges posed by the COVID-19 pandemic. The Treasury Offset Program (TOP) is a debt collection tool that intercepts federal and state payments to collect delinquent debts owed to federal and state agencies, including tax refunds and other payments. I some cases, SS benefits may be reduced to return overpayments to SSA. Please note that, HH 4350.3 Paragraph 5-6: J.??????Adjustments for Prior Overpayment of Benefits If an agency is reducing a family's benefits to adjust for a prior overpayment (e.g., Social Security, SSI, TANF, etc.), count the amount that is actually provided after the adjustment. Keep in mind that owner/agents should not immediately reduce income when SS is reduced. For example, if a resident's monthly SS payment is reduced to return "back" child support, the family's income would not be adjusted. Since this specific information is not available in EIV, we have created a Self-certification that can be used when a resident wants to disclose a reduction of SS income to return a prior overpayment (Self-certification Unexplained SS Deductions.?). https://lnkd.in/eayaSbVD ? A resident may, but is not required to, report any income decrease. As long as the resident reports the income change in compliance with owner/agent policies, any rent decrease takes effect the first of the month after the change. Refer to HH 4350.3 Paragraph 7-13 to determine the effective dates of certifications if the resident does not report an income decrease in a timely manner.

Starting February 25, 2025, The Social Security Administration is beginning to pay retroactive benefits and will increase monthly benefit payments to people whose benefits have been affected by the Windfall Elimination Provision (WEP) and Government Pension Offset (GPO). If a resident is due retroactive benefits as a result of the Act, they will receive a one-time retroactive payment (deposited into the bank account SSA has on file) by the end of March. This retroactive payment will cover the increase in their benefit amount?retroactive?to January 2024 (as applicable). Monthly benefits will be adjusted, as appropriate, and new amounts will start being paid on April 1. Anyone whose monthly benefit is adjusted, or who will get a retroactive payment, will receive a mailed notice from Social Security explaining the benefit change or retroactive payment. If you have questions about how to treat those payment when determining income for residents receiving benefits through HUD's MFH programs, check out our News page. https://lnkd.in/ebnDr2d

2025 COLA Announced Social Security benefits and Supplemental Security Income payments will increase by?2.5% in 2025, Social Security announced today. If owner/agents have not implemented new HOTMA requirements related to COLA increases, owner/agents will refer to HH 4350.3 Paragraph 9-6 when creating Annual Recertifications effective before 4/1/2025. 1. Use the current value shown on the EIV Income Report (which will be updated in December); or 2. Use a 2025 award letter showing the change (can be used for the entire year); or 3. Use Streamlined Verification of the new award amount by taking the 2024 award amount and applying the COLA. If you have adopted Streamlined Determination of Fixed Income, and if you are in Year 2 or Year 3 of Streamlining, you need only print the COLA Announcement, attach it to the EIV printout or last year's award letter and calculate the 2025 benefit amount. Remember, don't round until the end of the calculation. Example Streamlined Determination of Fixed Income: Resident’s February 2024 Annual?Recertification 2024 SSA Income Richard Resident $1214.00 * 12 = $14568.00 Raquel Resident???$1181.00 * 12 = $14172.00 ? New SSA Income with 2025 COLA (2.5%) Resident’s February 2025 Annual?Recertification Richard Resident??????? $1,214.00 + 2.5% ($30.35) = $1,244.35 $1,244.35 x 12 = $14,932.20 (2/1/2025 AR - SS Annual Income - $14,932) ? Raquel Resident??????? $1,181.00 + 2.5% ($29.53) = 1210.53 $1,210.53 * 12 = $14,526.36 (2/1/2025 AR - SS Annual Income - $14,526) ???? There is no requirement to correct completed 2025 Annual Recertifications to incorporate this change unless the household income increase equals at least $200 per month (Pre-HOTMA). Alternatively, owner/agents may implement the new HOTMA requirement to include the 2025 COLA the day after the COLA is announced - for any incomplete certifications effective in the new award year (2025). Remember, HUD has specified that, if an owner/agent has implemented a HOTMA change, the owner/agent must document the tenant file. See our free form Note To File for HOTMA Changes Implemented Before 203A Site Software available on our HOTMA Resources Page. For new Move-ins and Initial Certifications, effective after the COLA increase is announced, owner/agents should use the current SS income for the remainder of 2024 and should incorporate the COLA increase for the appropriate months in 2025. For example - using November 1, 2024 as the MI date when the current SS award is $1,115. $1,115.00 * 2 (November & December 2024) = $2,230.00 $1,115.00 + 2.5% = $1,142.88 $1,142.88 * 10 (Remaining Months in Certification Cycle) = $11,428.80 $2,230.00 + $11,428.80 = $13,658.80 SS Annual Income = $13,659 New training will be available soon.

As many of you know, last week, HUD released HSG Notice 2024-09 Revised Compliance Date: Implementation of Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA) extending the HOTMA compliance deadline from January 1, 2025 to July 1, 2025. RBD has received many inquiries as to what that really means for HUD MFH programs.?At this point, the following is our interpretation of instruction provided by HUD. Property Tenant Selection Plans and property EIV Policies must be updated to include HOTMA provisions.?However, owner/agents are not to implement those policies until new site software is available. If you have not updated EIV policies or TSP policies, check out our FASTForms Page and our HOTMA Resource Page to see the options available from RBD. HUD has clarified that owner/agents can receive Management & Occupancy Review (MOR) findings if they have made no attempt to update their TSP or EIV Policy.?However, if an owner/agent has updated policies, and a Reviewer feels that the change is not complete or compliant, the Reviewer should issue observations related to the policy edits (not findings). Once owner/agents have updated the TSP and the EIV policy, owner/agents are not required to address any other HOTMA changes until new HOTMA compliant site software is available and implemented. Many owner/agents have asked why software vendors have not released HOTMA compliant software.?To provide a little more insight, owner/agents and other industry stakeholders should understand that, until HUD provides additional information and new forms, software vendors are in a kind of “holding pattern." That’s not to say that the software vendors have done nothing.?HUD provided information about proposed requirements for TRACS 2.0.3.A from 2018 through most of 2023, but HOTMA requirements still need to be added or modified. Once that is done, vendors can complete programming, start testing and develop plans for site implementation.? Current HUD guidance specifically states that, aside from the TSP and EIV Policy updates, owner/agents may wait to implement all HOTMA changes until site software is available. But what if you want to implement some of the HOTMA changes now? If an owner/agent wishes to implement any HOTMA changes before site software is released, the tenant file must be documented to show which changes have been implemented and, if appropriate, what the TTP would have been if the changed had not been implemented.?Failure to document the tenant file when HOTMA changes have been implemented can result in MOR findings.?To assist, we have developed a new free Note to File which is designed to get you started as you create a standard form to attach to certifications in the tenant file. Questions related to HOTMA’s effect on HUD’s MFH programs should be directed to [email protected] #hudmultifamily #HOTMA #HUDcompliance #RossBusinessDevelopment

We know there has been a lot of HOTMA training out there, but we're getting more and more requests for training for new managers who need to know how to perform day-to-day functions using todays rules. Is there a need for a basic HUD site training explaining today's rules?

HUD requires that owner/agents update Tenant Selection Plans and EIV Policies to include HOTMA required language no later than May 31, 2024. Are you managing a HUD Multifamily Housing property? Do you still have questions about what needs to be included? We have received so many questions about what needs to be included in the TSP that we have designed class to provide an explanation of HUD's latest requirements for Multifamily Housing contracts. The class materials include a Word document providing sample language that can be copied and pasted into your current TSP. This live, online class -?HOTMA TSP Checkup?- will be held on Tuesday, May 21, 2024?from?2:00 PM EST to 3:30 PM EST. Registration is limited but there are still seats available.?Register now. https://lnkd.in/e4E7HQn

The first HOTMA deadline is fast approaching. HUD requires that owner/agents update Tenant Selection Plans and EIV Policies to include HOTMA required language no later than May 31, 2024. If you have not completed your updates, the time is now. We have received so many inquiries as to what needs to be included in the TSP that we have designed a live, online training class to provide an explanation of HUD's latest TSP requirements for Multifamily Housing contracts. And we added a bonus for those attending; a BIG bonus! Mary Ross will explain HUD’s TSP requirements AND provide you with sample language to easily incorporate into your existing TSP. The class -?HOTMA TSP Checkup?- will be held on?May 21, 2024?from?2:00 PM EST to 3:30 PM EST. Registration is limited and so is the time to sign up.?Register now. https://lnkd.in/e4E7HQn

On April 10, 2024, HUD released a Proposed Final Rule entitled, “Reducing Barriers to HUD-Assisted Housing.” https://lnkd.in/ed35EgTV. ? HUD’s rule proposes that owner/agents should not categorically deny access to HUD-assisted housing—including public housing, Housing Choice Vouchers, and HUD multifamily housing—simply for having a criminal record. HUD is proposing that PHAs and owner/agents be required to use more flexible standards when creating criminal screening criteria. Some of the rules described are already in effect, but there are some new suggestions that warrant comment from industry stakeholders. ? HUD seeks public comment on this proposed rule and invites all interested parties and members of the public to submit their views, comments, and recommendations for improvement on this proposal. Comments may be submitted electronically by June 10, 2024, through www.regulations.gov or through the methods described in the proposed rule.

HUD Southeast is offering a seminar on April 15, 2024, from 1:00pm - 3:00pm EST for a for anyone interested in their new Green and Resilient Retrofit Program (GRRP). Per HUD, this presentation will include Questions & Answers with program staff, and provide overview of the GRRP, a new source of federal funding available for affordable housing rehabilitations. Learn how you can take advantage of the largest climate investment in history, and other federal funding resources to protect your property from extreme weather-related events and improve energy efficiency. If you plan to attend, HUD requests that you register ahead of time. ? Date: April 15, 2024 Time: 1:00-3:00pm EST Registration: