Q&A: When to make the Interim Recertification retroactively effective

Question If a tenant lost their job in October, but did not report it to management until January, am I required to make the Interim Recertification retroactively effective back to November 1st? ~ Bismark

Answer You are not. According to HUD Handbook 4350.3, Rev-1, Change 4, Section 7-13 D: If the tenant does notcomply with the interim reporting requirements (meaning they did not report the change to management in a “timely manner”), any resulting rent decrease must be implemented effective the first rent period following completion of the recertification. So as to consistently apply this rule to all residents, PMCS recommends owners clearly define “timely notification of income and family composition changes” in their House Rules. What does management consider to be timely? 2 weeks? 10 days? When defining the timeframe, PMCS recommends you build in ample time for residents that have obtained new employment to have received their first pay check.