TRACS 202D. Presented By Debbie Hanson

Transcription

1 TRACS 202D Presented By Debbie Hanson

2 Some changes to TRACS 202D are documentation edits clarifying HUD s guidance: How assistance is calculated How certifications are submitted When certifications must be signed Changes to Housing Notice requirements

3 As part of 202D, HUD is editing the error messages. Eliminating unnecessary and outdated errors Eliminating confirmation errors Re wording errors Re categorizing errors Adding 202D errors

4 HUD HUD form is used when creating or correcting full certifications also known as Mat 10 records. Move in MI, Initial IC, Annual AR, and Interim IR

5 HUD A HUD A is used when creating a partial certification. Move Out MO/Mat 40, Termination TM/Mat 65, Unit Transfer UT/MAT 70 and Gross rent GR/Mat 70 When the effective date of a full certification and a partial certification (UT or GR) are effective on the same day, only a full certification is created and includes the unit transfer or gross rent information as appropriate.

6 TRACS 202D Voucher and Voucher Process Changes 202D, the full HAP voucher can be transmitted to a contract administrator from an owner/agent eliminating the need for sending paper or ed copies of printed vouchers. The owner/agent must maintain the original signed voucher for at least five years in compliance with HH R1, C3, Paragraph 9 7.

7 During an initial transition period, HUD acknowledges that the contract administrator may need a paper voucher. In these cases, both paper voucher and full electronic ones may be required by the contract administrator. After the transition, only the electronic records will be required. The contract administrator is required to send an electronic version of the final approved voucher to the owner/agent.

8 DUNS Numbers and TIN Reporting of DUNS numbers is now mandatory for: Section 8 PRAC Rent Supplement RAP contracts DUNS number and Taxpayer Identification Number (TIN) must be transmitted to TRACS. A property will only get paid if the Duns number and TIN match HUD s records.

9 Anticipated Voucher Reported on Date The anticipated voucher date is based on a certification effective date. The major change for 202D is an adjustment for gross rent transactions effective on the first of any given month. In TRACS 202C, owner/agents could not enter the gross rent transactions before the effective date, and these gross rent changes could not be submitted or included on an earlier voucher.

10 Example: GR effective OA received approval on 10/15/2013 GR Transaction was not allowed to be entered prior to 1/1/2014 GR Transaction was submitted on the February voucher creating the need for adjustments

11 In 202D, GR transaction can be entered and submitted in advance of the effective date. Using the same scenario: GR effective OA receives approval on 10/15/2013 Most software will allow the transaction to be entered on 10/15/2013 with the requested voucher date as 1/1/2014 which is created in December. This should eliminated most of the adjustments

12 Gross rents effective after the 1 st of the month would be requested on the following voucher. Example: GR effective OA received approval on 10/15/2013 Entered on with the requested voucher date as 2/1/2014 which is created in January 2014

13 Signature Requirements The Owner/agent must sign and date all HUD 50059/50059 As. All adult household members listed on the HUD must sign and date the completed form. Signatures must be obtained before the certification(s) is transmitted to NDHFA. Special exceptions apply to gross rent transactions and mat10 corrections caused solely by the application of a rent change.

14 Signature dates do not have to match. The signature date is the date the owner/agent and each adult resident actually signs the HUD

15 The Head of Household signs and dates the completed HUD A when there is: A change in the amount of rent the household must pay A change in the utility reimbursement Unit transfer ( Signatures must be obtained before the certification is transmitted to NDHFA) When required by state or local law Move out and termination transactions do not need to be signed by the resident.

16 A copy of the HUD A must be retained in the tenant file for the term of tenancy and for three years after tenancy ends for any reason. Gross rent changes the property has 15 units occupied and all the tenants will be receiving a gross rent change, you must transmit a gross rent (Mat70) for all 15 units. Even if owner/agent does not have signatures. Owner/agent has 60 days to obtain signatures. The 60 days starts when the certifications are included on a voucher.

17 Extenuating Circumstances Code (Formerly Tenant Unable to Sign Indicator) The following codes must be used when a resident has not signed the certification but the owner/agent is allowed to collect subsidy. 1. Medical 2. Late annual certification due to accommodation or extenuating circumstances. 3. Late annual certification due to owner/agent delay 4. Late annual certification due to third party delay 5. Military Deployment 6. Eviction in Progress 7. Court Order 8. No Signature Required (Retroactive GR done after a MO no requirement for a tenant signature) 9. No signature required for 60 days (based on anticipated voucher reported on date). Example: would be a retroactive GR where the tenant rent changes. A signature is required but the cert may be transmitted immediately and the signature collected within 60 days 10. Other Note: This is not the same as refusal to sign. When the resident returns and is able to sign, submit a correction with the Tenant Signed Date populated and the Extenuating Circumstances field blank.

18 Household over Income at Move in Tenant moves in and for some reason(s) when everything is recalculated the tenant s results is $0 subsidy. Household is allowed to remain in the unit. The tenant is terminated effective on the move in date. Use the new NS termination code. Initial can be performed later if household s income drops and the tenant becomes eligible for subsidy. When a move in or initial certification is corrected, the security deposit must be recalculated. Change noted on the lease and both owner/agent and tenant(s) initial the change.

19 Unit Transfers with a Full Certification (AR, IR, IC) Annuals are always effective on the first of the month. If the annual and unit transfer are combined, the unit transfer must have occurred on the first of the month. Tenant s new rent must take effect when resident takes possession of the new unit. New lease is required and must be signed by all adult household members. Owner/agents have the choice of whether they want to transfer the current security deposit or charge a new deposit.

20 Unit Transfers & Interim Certification Tenant has a change in composition or income. This change occurred on or before the unit transfer date, and interim must be created with the unit transfer flag set to Yes. If the rent changes (up or down) the IR/UT will be effective the same date as the unit transfer. This means that a mid month, IR/UT is required when there is a change in household income and/or household composition and the transfer date is other than the first of the month.

21 Current Interim Effective Dates Normally, changes in household composition and/or household income owner/agent need to produce an interim certification and the effective date of the interim certification is: Increase first of the month after a 30 day notice is provided Decrease first of the month following the date of the action that caused the interim

22 Exception when an action that would normally drive an interim certification occurs: On or before the date of the unit transfer and before The anticipated effective date of the interim. Household circumstances changes are reported on the full certification UT. Same Day as Household Change Change happens on UT date Include new household information on full UT cert Do not submit a unit transfer followed by an interim

23 Example: Bob (HOH) and Sue (spouse) lives in unit 1 A Sue s 11 year old daughter, Betty, is moving in with them Unit 1 B becomes available Bob and Sue move into unit 1 B on January 14 and Betty moves in the same day (decreasing rent) An interim adding Betty is created with the unit transfer flag set at Yes The interim reflecting the decrease in rent and the unit transfer is effective on January 14 th.

24 Change Occurs Before Full Certification If the change of household composition/household income occurs prior to the UT date there are two cases. Change in household occurred before the unit transfer date If traditional interim rules applied, interim would be effective after the unit transfer date. 202D Change if unit transfer occurs after change but before the traditional interim effective date, mid month interim is created with the unit transfer flag set to Yes. Rent is effective the same date as the unit transfer.

25 Example: Mary (HOH), Sam (CO HOH) and Billy (dependent child) lives in unit A1. Mary gets a new job on Dec. 5 th and her income increases by $2,000 per year. Normally, an IR is completed increasing the household rent effective Feb. 1 st. However, Mary and Sam transfer to unit B1 on Dec. 30 th. An interim is created with the unit transfer flag set to yes. The IR/UT is effective December 30 th and includes the family s income increase.

26 Change in household occurs before Full Certification The change in household occurred before the Unit transfer date and the interim has been sent. Unit transfer occurs after the change but before the interim effective date. Mid month interim is created with the unit transfer flag set to yes. Change to rent effective same date as the unit transfer. Original interim corrected to reflect the new unit number.

27 Example: Tom (HOH), Sue (spouse) lives in unit B1. Tom starts receiving SSI on Feb 21 and his income increases by $6,000 per year. Interim is done increasing the household rent effective April 1 st. Tom and Sue transfer to unit C1 on March 15 th. An interim is created with the unit transfer flat set to yes. The interim/unit transfer is effective March 15 th and includes the family s income increase. A correction is made to the interim effective April 1 st to correct the unit number.

28 Miscellaneous Accounting Requests SERV Service Coordinators DRUG Drug Related Expenses FORQ Field Office initiated accounting adjustment OARQ Owner/Agent initiated accounting adjustment RGRC Adjustment for a Retroactive GRC that includes a UA decrease (new code) UUTL Unclaimed Utility Check (new code) RSPC Recouped Special Claims Funds (new code) CEAD Contract Expiration Adjustment (new code) EIVP EIV Penalty. 5% of the voucher is subtracted to cover EIV noncompliance when applicable (new code) RESR Residual Receipts. Used to offset part of the voucher billing (new code) INTA Interest adjustment submitted by PBCA

29 RGRC Retroactive Gross Rent Changes (Utility Allowance Reductions, Retroactive Rent Increase) Some cases where annual rent review results in reduction in utility allowance Resident rent payment will increase In accordance with the lease, the resident must be provided with 30 day notice This code can only be used for 75 days from the approval date of the schedule RGRC is used: Usually, GR is completed before the effective date Required notices are provided in compliance with lease In rare cases, formal approval may not be obtained in time for the owner/agent to provide notice Assuming complete owner/agent compliance with HUD s notice requirements, the owner/agent will remain whole until notice period is complete Retroactive adjustments caused by the UA decrease can be reversed

30 UUTL Unclaimed UA Payments If the utility reimbursement is not disburses to the tenant or utility provider (e.g., tenant never picks up the check, tenant never cashes the check or tenant moves out), the funds must be returned to HUD. Mat Guide RSPC Recouped Special Claims Funds Special claim has been paid to owner/agent and now resident returns to pay unpaid rent and/or damages EVIP EIV Penalty The amount of EIV penalty is to be calculated based on the total voucher amount before calculating the penalty and before applying any RESR transaction that may be needed. RESR Residual Receipts Prior to 202D, FORQ Miscellaneous Accounting Request Code was used to perform this task

31 HUD A Part 6 Repayment Agreements for Schedule of Tenant Assistance Payments Due When a resident or an owner/agent receives too much housing assistance, the overpayment must be returned to HUD. To allow for improved tracking and reporting, these repayment agreements will no longer be reported as OARQ Miscellaneous Accounting Request transactions. They will be accounted for with HUD A Part 6 Repayment Agreements for Schedule of Tenant Assistance Payments Due.

32 This form is to be used ONLY to return assistancepaid in error. If a resident enters into a repayment agreement to make payments for damages to the unit, these payments are handled in the traditional manner and this form is NOT used. There are three types of repayment agreements: Tenant Owner None

33 Tenant Repayment A tenant repayment agreement is in place to allow a resident to return any assistance paid in error. When a tenant fails to disclose income, then retroactive certifications are completed and assistance paid in error is returned to HUD.

34 Owner Repayment The owner must reimburse HUD for all overpayments of assistance where such over payments were due to the owner s error or the owner s failure to follow HUD s procedures. NDHFA may permit the owner to repay such overpayments in one lump sum or over a period of time through reduction of normal housing assistance (Monthly vouchers).

35 No Repayment Owner/agents may run into a situation where a resident receives assistance in error but the resident does not enter into a repayment agreement. This can occur when a resident has signed appropriate certifications (creating a retroactive adjustment) but the resident is unwilling to enter into repayment or the resident moves out/skips.

36 In this case the owner/agent is NOT responsible for returning assistance paid in error to HUD, the adjustment is reversed. With 202D, this is completed by creating a repayment agreement type None. If, at a later time, the resident pays any or all of the repayment amount the repayment agreement is converted from None to Tenant.

37 Owner/Agent may retain a portion of the repayments they actually collect from the tenants who have improperly reported their income at the time certification or recertification to help defray the cost of pursuing these cases. Owner/agents may only retain an amount to cover their actual costs, which is the lesser of: Their actual costs, or 20% of the amount received from the tenant

38 Amounts retained by owner/agents must be deposited into the project s operating account to offset the expenses incurred for these cases. Owner/agents must keep records of the receipt and disbursement of all amounts collected from the tenant for audit purposes

39 At a minimum, the owner/agent must record: Date and amount(s) received from the tenant; Expenses incurred; Examples of types of expenses incurred include staff time for verifying the unreported income; meeting with tenant; drafting repayment agreements; generating and sending monthly invoices to tenant; generating manual voucher adjustments; collection agency fees, if applicable; and, meeting state requirements Amount(s) retained; and Voucher date(s) and amount(s) of reimbursement made to HUD