COVID-19 (Coronavirus) Resources

News regarding the COVID-19 (Coronavirus) in the United States has spurred many questions within the affordable housing industry about steps that owner/agents can take to reduce the risk of spreading the infection.  Below are links to various COVID-19 resources.

We are committed to supporting our customers’ efforts to manage their properties as the nation reacts to guidance provided by various federal and local agencies.  We know you have had to change the way you handle annual and interim certifications.  We have created new forms to assist you with incorporating these new changes while still maintaining compliance with HUD’s requirements.

HUD COVID-19 (Coronavirus) Resources

Centers for Disease Control and Prevention Coronavirus

ResourcesThe President's Coronavirus Guidelines for America

COVID-19 Cases in the U.S.

HUD’s COVID-19 Questions and Answers for Multifamily Housing
HUD’s latest Questions and Answers Document responding to questions from owner/agents specific to COVID-19. This will be updated as HUD releases new versions.  Updated July 31, 2020.

HUD Housing Notice, H-2020-08
HUD is making CARES Act funds available to offset property expenditures to combat the effects of COVID-19. The Notice provides a method for owners to receive payments beyond the amounts available under the terms of their current rental assistance contracts.

HUD Memo - Status of Management and Occupancy Reviews performed by PBCAs

HUD Memo - Special Claims for Vacancy Loss During COVID-19

HUD Memo - Annual and Interim Recertification Protocol during COVID-19

Multifamily Tenant Concerns COVID-19 Brochure May 2020 
HUD’s Office of Multifamily Housing published a COVID-19 resource brochure for residents and families living in multifamily properties.  The document addresses which steps residents can take in case of lost income during the COVID-19 national emergency, provides local contact information, and explains the eviction moratorium in the CARES Act. HUD’s Office of Multifamily Housing has requested that you please distribute this information widely by sending the brochure directly to residents via email, and posting it in public areas of apartment buildings (lobby, laundry, and meeting rooms for example).  The Multifamily Tenant Concerns COVID-19 brochure is attached.

Federal Register Notice explaining CDC Order providing a moratorium on evictions for non-payment of rent and other fees

CDC Eviction Moratorium Declaration

Basically, the draft of the CDC Order indicates that a resident family may be exempt from eviction, for non-payment of rent and other fees.  To invoke the CDC’s Order, residents must provide an executed copy of the Declaration Form (or a similar declaration under penalty of perjury) to their landlord, owner of the residential property where they live, or other person who has a right to have them evicted or removed from where they live.  The CDC provides a form, but owner/agents may create their own form.  If you use the CDC version, please keep in mind that this is an OMB form and should not be modified.  Each adult listed on the lease, rental agreement, or housing contract should complete and provide a Declaration.

Notice Termination of Tenancy Failure to Pay Rent COVID19 CDC
This is a sample notice of Termination of Tenancy that advises residents that they may invoke the CDC Moratorium on Eviction for Nonpayment of Rent.

Notice CDC Eviction Moratorium Denial
This is a sample notice of denial to be used when a resident attempts to invoke the CDC Moratorium but the resident does not appear to qualify based on CDC requirements.

Notice CDC Eviction Moratorium Approval
This is a sample notice of approval to be used when a resident attempts to invoke the CDC Moratorium but the resident appears to qualify based on CDC requirements.  This sample explains that residents should meet with the owner/agent to discuss repayment options.  This notice also advises residents that they must notify the owner/agent if income is fully or partially restored.

TSP Temporary Change COVID-19
This is a sample illustrating how you may want to document changes to your Tenant Selection Process during COVID-19.  Other policies should be evaluated and updated as appropriate.
This is NOT a HUD requirement but will assist in explaining inconsistent practices in the future.
Multifamily Housing brochure provided by HUD on July 1, 2020.  This brochure discusses restrictions on evicting for non-payment of rent and forbearance.  The brochure also provides best practice suggestions from HUD.

AR Steps COVID-19
Attached is a brief summary of a modified AR process that you may want to consider when completing ARs during the COVID-19 Pandemic.  This also includes a form that you can use when you complete the AR that provides a checklist of tasks that will be required when shelter in place orders are lifted. 

AR Steps COVID-19 - Outstanding Items Checklist
We have also separated the checklist from the main document and provided it in Word for your convenience.  Property managers can use this checklist when they initially complete the AR so they do not forget to complete tasks that were skipped when shelter in place orders were in effect.

Recertification File Analysis
This document may help property managers identify the most efficient verification method to use for each recertification.  Property managers should be familiar with Streamlining requirements.

Notice – Termination – Failure to Report for AR
This notice can be used to notify residents that their housing assistance will be terminated in 30 days if they do not respond, in some way, to property manager’s requests to recertify.  COVID-19 language has been added.

Notice – AR – Requirement to Sign – Extenuating Circumstances
This document can be used to advise residents of their requirement to meet and provide required signatures.  This is a sample and should be modified based on your own policies.

Notice AR 120Day NoFTFMeeting - Notice AR 90Day NoFTFMeeting - Notice AR 60Day NoFTFMeeting
These AR Reminder Notices have been modified - providing multiple options reducing the need for face-to-face meetings.  
While we included most of HUD’s requirements outlined in HH 4350.3 Paragraph 7-7, these notices have been modified to limit face-to face meetings.

Notice AR UnsignedCertSubmitted - Notice IR UnsignedCertSubmitted
These sample notices can be modified and used to notify residents that you submitted a certification without signature.  Owner/agents will have to modify this sample before using.  These notices give residents the option to let you know if they do not want you to send the certification. These notices also advise residents that you will notify them when they are required to meet to sign the certification.  See HH 4350.3 R1, C4 Paragraph 5-31 and HUD’s MAT Guide Chapter 7.

Required DocsPRAC AR - RequiredDocsS8 AR
These two documents include Jpeg versions of required forms so that they may be provided electronically or emailed to residents.  These documents also contain an Acknowledgement of Receipt of documents for use at AR.  These documents were created specifically for the AR process and do not include VAWA forms since HUD does not require distribution of VAWA forms at AR.  If your management company requires distribution of VAWA forms at AR, these documents will have to be modified or you will have to create your own document.

FAQ's from our OTW Recertification in a Changing Environment COVID-19
This is a compilation of questions and answers collected during the RBD Online Training Workshop – Recertifications in a Changing Environment COVID-19.
RBD FASTFacts - Temporary GR Signature Practices COVID-19
This document explains the process for submitting Gross Rent Changes to HUD using Extenuating Circumstances Codes.

RBD FASTFacts - Temporary IR Practices COVID-19
This RBD FASTFact explains how owner/agents may want to modify their Interim Recertification processes to address residents’ loss of income.

Notice IR NewProcess - Notice IR NoFTFMeeting
We have created two different sample IR notices.  They both have been modified to allow for submission of the IR Questionnaire, a phone meeting or use of a resident portal.  Owner/agents will have to modify this sample before using.  The notices specifically state that the owner/agent will make certain changes to normal certification processes based on the resident need and in response to the CDC guidance.  HUD does not require that you send an IR notice unless a resident fails to report.  This notice was created assuming that the resident reported.  For IR, the owner/agent need only address information that has changed since the last AR.  See HH 4350.3 R1, C4, Paragraph 7-11.

Notice AR UnsignedCertSubmitted - Notice IR UnsignedCertSubmitted
These sample notices can be modified and used to notify residents that you submitted a certification without signature.  Owner/agents will have to modify this sample before using.  These notices give residents the option to let you know if they do not want you to send the certification. These notices also advise residents that you will notify them when they are required to meet to sign the certification.  See HH 4350.3 R1, C4 Paragraph 5-31 and HUD’s MAT Guide Chapter 7.

SelfCert Income ExtenCircumstance
This sample document can be modified and used to provide a resident with a form to self-certify income.  An owner/agent must first attempt third party verification.  See HH 4350.3 R1, C4 Paragraph 5-13.  An owner/agent must also document the file and explain why he/she is accepting self-certification.

SelfCert IncomeExpense ExtenCircumstance
This second sample document can be modified and used to provide a resident with a form to self-certify income and expenses.  An owner/agent must first attempt third party verification.  See HH 4350.3 R1, C4 Paragraph 5-13.  An owner/agent must also document the file and explain why he/she is accepting self-certification.

NoteToFile No3rdParty ExtenCircumstance
This is a sample standardized note to the tenant file explaining why the resident file does not contain 3rd party verification.  OAs must attempt 3rd party verification before accepting family self-certification.  See HH 4350.3 R1, C4 Paragraph 5-13.  Rather than write a note every time, property managers can attach this note to the certification.

NoteToFile NoTenantSignatureExtenCircumstance
This is a sample standardized note to the tenant file explaining why the 50059 was submitted without a resident signature.  See HH 4350.3 R1, C4 Paragraph 5-31 and HUD’s MAT Guide Chapter 7.  You must, at some point, get the tenant signature.

Notice Repayment SuspendExtenCircumstance
If you choose, you can modify and use this sample notice to let residents know that you are temporarily suspending their requirement to make repayment agreement payments.
Verif OralPhone
Use this sample form to document phone (oral) verification as required in HH 4350.3 Paragraph 5-18.
Disclaimer
The materials provided are not comprehensive of the continually emerging issues surrounding policies in HUD’s multi-family housing program. Handbook guidance is derived from new guidance from HUD on their HUD/Coronavirus web site, the HUD Handbook 4350.3 Rev 1 Change 4 released in 2013 and other subsequent notices, and the TRACS MAT Guide. RBD makes no warranty to the usability, compliance or legality of these documents. All documents should be reviewed and edited by management staff and legal counsel as appropriate. Implementation of these documents usually requires edits to other policies and documents as well. Examples include House Rules and Applications. The forms provided are samples.
Copyright
The content and samples available from RBD is the sole property of Ross Business Development or its licensors and is protected by copyright, trademark and other intellectual property laws. Except as otherwise explicitly agreed in writing, Ross Business Development-owned content received from RBD may be downloaded, displayed, reformatted and printed for your organization/personal, non-commercial use only.