On Wednesday, October 14, 2020, HUD’s Office of Multifamily Housing released an update to its COVID-19 Questions and Answers. The complete document can be found here.
The following is a summary of the major changes and additions:
CDC Eviction Moratorium
The Office of Multifamily Housing added an entire section devoted to the Centers for Disease Control and Prevention (CDC) Eviction Moratorium Order that became effective on September 4, 2020 and remains in effect through the end of calendar year 2020. NCHM explained the CDC Eviction Moratorium in detail in an article posted on September 16, 2020. You can find that article here.
On pages 17-20 of the October 14th Q&A document, HUD reiterates that the CDC eviction moratorium applies to HUD-assisted residents who have signed and submitted a declaration as a “covered person” to the Owner/Agent at their respective property.
Even though the Order does not require it, HUD strongly encourages Owner/Agents to proactively notify resident of their rights under the Order and the requirement to submit a declaration that is compliant with the Order. In addition, Owner/Agents should notify residents that the Order does not prevent termination of tenancy for reasons other than non-payment of rent.
Question #1 on page 21 of the Q&A document also reiterates the status of Real Estate Assessment Center (REAC) Inspections. HUD resumed physical inspections at the beginning of October 2020 under a plan to prioritize inspections based on the Harvard Global Health Institute’s health risk scoring methodology. REAC has categorized states and localities into four risk groupings:
- Low Risk: Green
- Moderately Low Risk: Yellow
- Moderately High Risk: Orange
- High Risk: Red
Properties considered for inspection will be defined as those in critical or emergency need of inspection but located in low risk localities. Inspections will be deferred at properties with elderly, disabled, or other health compromised populations unless there are known life-threatening and health concerns.
Hazard Pay Clarification
In Q #11 on page 27, HUD clarifies that any additional income that residents receive for working during the pandemic (e.g. hazard pay) is counted when calculating the household’s annual income. If the household’s monthly income increases by $200 or more, the Interim Recertification rules will apply.
Questions about the Q&A document may be direction to NCHM’s Senior Vice President for Compliance, Ms. Lisa Vercauteren.