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Key Compliance Tip
HOTMA requires that, “effective the day after the Social Security Administration has announced the COLA, owners/management agents are required to factor in the COLA when determining SS and SSI annual income for all initial certifications and recertifications that have not been completed and will be effective January 1 or later of the upcoming year.”
NOTE: If owners/management agents are having problems obtaining the SS or SSI benefit letter due to the federal government shutdown, they may use the older benefit letter and add the COLA when the new letter is obtained. Management agents must put a clarification record in tenant files fully explaining why the older benefit letter was used. When a new letter is obtained, owners/management agents must ensure the amounts on the TIC and the new award letter match. If they do not, correct the OHFA TIC with both the management agents and tenants initialing and dating the corrections and place a clarification record in the file explaining why the TIC was manually corrected.
How to Calculate a COLA Increase Example
Sally applied for a unit and will move in December 1, 2025. Her current SS benefit amount is $1,256/month. In this example, the management agent will count:
- 1 month at $1,256
- $1,256 x .028 = $35.17
- $1,256 + $35.17 = $1,291.17
- 11 months x $1291.17 = $14,202.87
- $1,256 + $14,402.87 = $15,458.87 Total projected income from Social Security
Be sure to include a copy of the SS/SSI COLA press release in the tenant/applicant file where the COLA has been applied (imputed) in the income calculation.
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