HUD’s Office of Public and Indian Housing (PIH) issued Notice PIH 2024-17 on May 10. The Notice outlines a streamlined review process for regulatory waivers to expedite admission to the Housing Choice Voucher (HCV), Project-Based Voucher (PBV), and Public Housing programs for people experiencing homelessness.
The Notice provides a streamlined submission and review process for two regulatory waivers for verification requirements at admission to the HCV, PBV, or Public Housing programs: (1) third-party verification of date of birth and a person’s disability status, and (2) third-party verification of income and assets.
People experiencing homelessness may not have the documents typically required to establish their eligibility for housing assistance programs readily available. Because missing documents can significantly delay assistance and access to housing, the waivers announced by HUD will allow public housing authorities (PHAs) to house families experiencing homelessness more quickly by allowing self-certification of income, disability status, and date of birth.
Streamlined Waiver Process
Notice PIH 2024-17 outlines a streamlined waiver process to help PHAs more effectively serve people experiencing homelessness. HUD will review waiver requests on a case-by-case basis and consider specific circumstances identified by the PHA. The Notice lists several factors a PHA might want to consider when requesting a waiver, such as a significant population of unhoused people or significant increase in the population of people experiencing homelessness within the PHA’s jurisdiction, the length of time it takes to determine eligibility of applicants experiencing homelessness versus other applicants, the challenges applicants experiencing homelessness face when attempting to gather documentation, and other lessons learned from other programs or use of previous regulatory waivers, such as Emergency Housing Vouchers or CARES Act waivers, among other factors.
Available Waivers
Verification of Date of Birth and Disability Status: 24 CFR 982.201(e) and 960.259(a) and (c)(1)
For applicants experiencing homelessness, HUD may waive requirements to verify a family member’s date of birth and/or disability status at the time of admission for purposes of determining the family’s eligible expenses and deductions. For any applicant family experiencing homelessness, a PHA may accept a self-certification from the applicable family member if the family is unable to provide third-party verification of date of birth and/or disability status for any of its members due to loss or lack of documents. The PHA must verify the date of birth and/or disability status within 90 days after admission. The waiver will be granted for 12 months following the date of waiver approval.
Self-certification of date of birth and disability status cannot be used when related to the eligibility for a particular special purpose voucher or for public housing that has been officially designated, in whole or in part, for families whose head of household, co-head, or spouse is a person with disabilities or age 62 or older.
Eligibility Determination, Income Verification: 24 CFR 982.201(e) and 960.259(a)(1), (a)(2), and (c)
PHAs must verify a family’s income eligibility within 60 days before voucher issuance for the tenant-based voucher program and prior to admission for the PBV and Public Housing programs. HUD’s notice allows the department to waive these requirements if a family lacks income documentation because the family is experiencing homelessness.
If HUD approves the waiver request, the PHA must first request third-party documentation from the applicant family experiencing homelessness. However, if the family cannot provide third-party documentation, the PHA may immediately allow self-certification. The PHA is not required to first attempt to obtain documentation of income from the third-party source before proceeding to the family self-certification, despite the requirement in Notice PIH 2023-27 that PHAs must demonstrate efforts to do so.
Applicants must submit a self-certification declaration of income, assets, expenses, and other factors that would affect an income eligibility determination within 60 days before voucher issuances for the tenant-based HCV program and prior to admission for the Public Housing and PBV programs. The PHA must verify that the family is eligible within 90 days after the PHA enters into a Housing Assistance Payment contract on behalf of the family. For the PBV and Public Housing programs, the PHA must receive information verifying that the family is eligible 90 days following admission.
The waiver will be granted for a period of 12 months. The waiver does not relieve the PHA of its responsibilities to correct any overpayments or underpayments. The PHA must take steps to identify and address any income discrepancies.
Existing Verification Policies Available without a Waiver
The Notice also provides guidance on existing HUD policies that have been streamlined recently to help applicants more easily provide documentation. In June 2023, HUD published Notice PIH 2023-13, which highlighted ways PHAs could remove barriers for people experiencing homelessness using existing flexibilities (see Memo, 6/20/23). Additionally, HUD provided updated guidance through Notice PIH 2023-27, which was issued in September 2023 and updated in February 2024. Notice PIH 2023-27 provided guidance regarding implementation of Sections 102 and 104 of the “Housing Opportunity Through Modernization Act of 2016,” including verification policies available to PHAs related to Social Security Number verification; date of written, third-party verification; and self-certification of zero income.
Read Notice PIH 2024-17 at: https://tinyurl.com/82acdn59
Read HUD’s press release at: https://tinyurl.com/3xyhyu2c