A number of people have asked about completing end of year reporting for 2020 in light of the IRS ruling exempting owners from completing recertifications between 4/1/20 and 12/31/20.
Q: We’re still expected to complete initial move-in certifications?
A: Yes.
Q: What should we put in our report if we didn’t complete a recertification in 2020?
A: Nothing. The Report should reflect what really happened. If you didn’t complete a recert between those dates then nothing should be listed.
Q: Do we still have to document Student Status for recerts?
A: No. The ruling was intended to protect tenants and managers/owners/staff from unnecessary interaction. Documenting anything related to eligibility between 4/1/20 and 12/31/20 is unnecessary.
Q: What if a household moved in 6/1/19, isn’t recertified in 2020, and is found to be over the income limit in 2021? Will we be cited for an over income household?
A: It depends on how thorough you were at move in, and how thorough you are at the 2021 recert when you discover they went over income. We recommend you immediately compare the 6/1/19 move in documentation against the 6/1/21 recert. See what changed and try to determine when it changed. You might need to contact income sources and ask them for more details. If you can show the change occurred substantially after move-in, or was truly not anticipated, then no, you will not get cited for an over income household.
Q: What if a household moved in 6/1/19, doesn’t get recertified in 2020, and is over 140% at their recert on 6/121?
A: The 140% rule kicks in on 6/1/21. Just follow the rule starting then.
Q: Do the recerts that weren’t done between 4/1/20 and 12/31/20 need to be completed “retro-actively at a later date?
A: No.
If you have any other questions, please reach out to us.
Ed Clark
Dir. MA monitoring
