Guidance to PBCA Properties: Treatment of CARES Act Household Stimulus Payments
During the COVID-19 Pandemic
Many property owners/agents have contacted Kentucky Housing Corporation (KHC) requesting information on how to handle stimulus payment their tenants expect to receive. The U.S. Department for Housing and Urban Development (HUD) recently provided guidance on this topic, updating its
Q&A for Office of Multifamily Housing Stakeholders on April 16, 2020, as follows:
Household Stimulus Payments
Q4: Are household payments under the CARES Act reportable as tenant income?
A: Household stimulus payments of up to $1,200 (which is technically an advance tax credit) and the temporary $600 per week federal enhancement to unemployment insurance provided by the CARES Act
are not to be included in calculations of income.
However, HUD notes that regular payments of unemployment insurance (issued by the state) are treated as income, as is customary under program rules.
Resident Income Reductions
If a Project-Based Contract Administration (PBCA) property resident reports a reduction to income, owners/managers should complete an IR reducing income and increasing the assistance payment. Assuming the resident reported in a timely manner, the effective date of the IR is the first of the month after the reduction. Please refer to the
HUD Handbook 4350.3, Paragraph 7-13 for more information.
This is addressed further in the
HUD Q&A document under Asset Management, Question 8, page 15.
Additional Guidance from HUD
KHC encourages PBCA property owners and managers to regularly review
HUD's Q&A for Office of Multifamily Housing Stakeholders. HUD has provided additional updates on the CARES Act, forbearance guidelines, recertifications, evictions, electronic signatures and more. Therefore, it is very import for you to review the information provided in the Q and A document.
HUD's two-page memo titled
Annual and Interim Recertifications Protocol During COVID-19 offers succinct guidance on conducting recertifications during the COVID-19 pandemic.
For ongoing updates, check
KHC's COVID-19 Response web page and subscribe to KHC eGrams for updates.
