Stimulus cash won't raise the rent

Emergency payments are temporary—so they don't count as income

FRIDAY, APRIL 17—James R. Grow, National Housing Law Project (NHLP), writes: "With stimulus payments beginning to flow, HUD tenants will be undergoing interim recertifications." In general, HUD has advised housing authorities and managers to exclude Federal COVID emergency payments in determining tenant income.

Here is how NHLP interprets the HUD guidance:

1) The $1200 individual stimulus payments have already been excluded from calculations of household income in both public housing (PIH) and multifamily (MF) programs.

2) For the MF programs, the extra $600 weekly Unemployment Insurance Benefits are also excluded from income because they are considered to be “temporary." This is an exclusion of $2400/mo. for recipients—it means they save $720 a month in rent.

However, regular unemployment benefits are still included as income. This difference may cause some confusion for tenants and managers.  [updated 4-16-20 HUD MF FAQs]

3) NHLP expects that HUD will issue similar guidance for the public housing and voucher programs soon (though this had not yet happened as of April 17).

4) The rules on the effective date of any rent reduction from decreased incomes pursuant to an interim recertification vary by program:

  • For HUD Multifamily (MF) tenants, the new rent is effective the first of the month following loss of income (not when tenants report it);
  • For public housing and voucher tenants, there is no uniform rule:  the effective date is set by the policy of the local Housing Authority.
thanks to Susan Hegel, CASLS