In dealing with clients on HUD-assisted properties that require annual reexaminations, we still find some confusion among managers relative to the cutoff date by which residents must report for the yearly reexamination interview.
Managers of HUD-assisted properties understand that the annual recertification process must begin at most 120 days before the annual reexamination anniversary date. Once managers have distributed the three required recertification reminder notices for the annual reexamination notice, HUD expects Section 8 residents to promptly report for the recertification interview, sign the required paperwork, and provide necessary documentation relating to income and assets.
Assuming the resident reports for the annual interview before the cutoff date, the manager must complete the recertification with enough time to provide 30 days’ notice of any resulting rent increase.
It’s crucial to note that if the resident misses the cutoff date, they lose the privilege of a 30-day notice of a rent increase. This underscores the significance of adhering to the timeline and the potential impact on Section 8 residents.
The Cutoff Date
HUD defines the cutoff date as the tenth day of the 11th month before the annual reexamination date. This cutoff date must be included in the initial 120-day notice to the resident and in the 90 and 60-day reminder notices.
Here are two simple methods for remembering the cutoff date. The first method involves starting with the month of the last annual reexamination and adding 11. The result is the 10th day of the 11th month. The second method is to count two months back from the annual recertification month, and the result is again the 10th day of that month.
Using the first method, if the last annual reexamination was November 1, 2023, count forward 11 months, including November. The 11th month is September 2024, so the cutoff date for the November 1, 2024 reexamination is September 11, 2024. If using the second method, count two months back from November (not including November), and the cutoff date remains September 21, 2024.
To avoid the counting requirement, I recommend that managers keep a chart showing the cutoff date for each recertification month. Here is an example of such a chart:
Recertification Month Cutoff Date
January 1 November 10
February 1 December 10
March 1 January 10
April 1 February 10
May 1 March 10
June 1 April 10
July 1 May 10
August 1 June 10
September 1 July 10
October 1 August 10
November 1 September 10
December 1 October 10