HUD amends definition of tuition; MORs to resume?
1/15/2016 4:10:27 AM

By Lisa Vercauteren, Vice President of Housing Programs

If you manage a Section 8 community or administer Section 8 Housing Choice vouchers, you are probably aware that HUD has a special rule on when we must count Student Financial Assistance as tenant income.

Here is the rule:

For students (full or part-time) receiving Section 8 assistance, the amount of Student Financial Assistance (scholarships, fellowships, grants, etc.) that a student receives in excess of tuition must be included in annual income unless the student is over the age of 23 with dependent children or living with his or her parents who are receiving Section 8 assistance (4350.3 Par. 5-6E, pg. 5-11).

Previously, HUD has told us that it was up to the institution of higher education to define the term "tuition," and this proved to vary greatly from institution to institution. Some universities strictly included the amount that was charged per course or credit and others included mandatory fees.

In HUD Notice H 2015-12 (PIH 2015-21), issued on Dec. 10, 2015, HUD has amended that definition of tuition to include "other required fees and charges." As of the publication of this notice, you can include any fees or charges that are required to be paid with the student's tuition. It is important to note, however, that any fees or charges that are NOT required cannot be included in this calculation. Examples of additional charges that are not required are room, board, books, parking, etc.

Please be sure to verify the amount of tuition and other required fees and charges when making this determination.

A copy of the HUD Notice can be found here.

Are you ready for your next MOR?

For many of us, management and occupancy reviews (MOR) have been on hold for the past four years as HUD awaits the outcome of a legal challenge. While some may view this as a good thing, it really isn't. Without regular reviews, it is challenging for an Owner/Management Agent to ensure that the project is following through with all the mandatory requirements. The MOR process keeps us on top of what we need to do!

HUD recently sent a letter to the Executive Directors of the Performance-Based Contract Administrators expressing a desire to start conducting MORs again and asking for their input. I believe it is safe to assume that we will see the MOR process start up again in all locations before the end of 2016. Are you ready?

NCHM can help. Our newly revised MOR Specialist (MORS) certification program is a three-day class that focuses on the MOR process and provides a thorough review of the HUD Form 9834. Learn more about the program here.

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