Thanks to HUD for releasing an updated COVID-19 Questions and Answers for Multifamily Housing. We have also added the Q&A to our COVID-19 Resource Page.
New Questions and Answers address the CDC Moratorium on Evictions for Nonpayment of Rent. These questions and answers apply specifically to HUD's Multifamily programs.
HUD strongly encourages owners and agents to notify their residents that the CDC eviction moratorium is in place and that execution of the CDC Declaration referenced in the Order is necessary to be covered by the CDC order.
We have created a sample Notice of Termination of Tenancy - Nonpayment of Rent and made it available on our RBD COVID-19 Resource page.
HUD also provided an answer to the much-asked question about Hazard Pay or any extra pay essential employees receive for working during the pandemic. This income is not excluded. As explained by HUD...
Hazard pay has historically been included in income calculation and is not broadly excludable under 24 CFR § 5.609. Owners and agents should consider whether the pay increase is temporary or recurring in determining whether it will trigger an income reexamination in accordance with HUD Handbook 4350.3, REV-1 and their written recertification policies.
We are still waiting for HUD to provide clarification explaining whether Personal Protective Equipment (PPE) (e.g. face masks, gloves and sanitizing products) may be included as part of the Medical Expense Deduction for qualified households. At this time, we are recommending that owner/agents do not count these PPE expenses until HUD does provide such clarification.
If HUD will allow these expenses for Personal Protective Equipment (PPE) such as face masks, glove and sanitizing products, owner/agents may correct previously completed certifications for our elderly and disabled families. If HUD determines that these expenses are not allowed, then the current certification would remain in place.
We encourage owner/agents and their compliance teams to review the new Q&A to get the most up-to-date information.