How to Hold Effective Initial Certification Meetings
When applicants approach the top of the waiting list, you must meet with them to certify their eligibility for housing assistance. HUD requires managers to cover a long list of topics during the initial certification meeting. But site staff may be poorly prepared or may not cover all the required information. Also, site staff may not inform applicants about their responsibilities in the right way. As a result, you won’t get all the information you need to properly and accurately certify applicants, and applicants may not understand their duties.
We’ll cover all the topics required by HUD to discuss at the certification meeting and provide a Model Form: Initial Certification Meeting Checklist, that you can adapt for use at your site to ensure effective certification meetings. And we’ll give you a rundown on HUD’s requirements about who should attend the certification meeting, where to hold it, what to ask, and what forms applicants must sign.
Who Should Attend?
All household members age 18 and older must attend the certification meeting conducted by a staff member. This is because HUD says that all adult household members must sign the verification consent packet [HUD Handbook 4350.3, par. 4-24(B)(5)]. In addition, having all adult household members present is a good idea because the topics you’re required to cover are important fundamentals to assisted housing programs.
Where to Meet
Certification meetings should be held in a private location, such as behind closed doors in an office or conference room. Don’t hold certification meetings in open waiting areas because this may violate HUD’s requirement that you ensure the confidentiality of information that applicants and residents give you [Handbook 4350.3, par. 5-19].
What Documents Applicants Should Bring
It’s important that households bring certain key documents with them to the certification interview. These are documents containing the information you need to process the initial certification quickly and submit it to HUD on time. One good way to make sure the household brings these documents with it to the interview is to send the household a list ahead of time. You can find a list of documents suggested by HUD for households to bring at the end of this article. By sending the list beforehand to applicants, you’ll increase the chances that households won’t forget to bring important documents.
Checklist Ensures Consistent, Thorough Certifications
HUD requires managers to cover many topics with applicants at certification meetings [Handbook 4350.3, par. 4-24]. To ensure that site staff cover all these topics, use a certification checklist. Ask site staff to check off each topic in the box provided after they have gone over it with applicants. That way, you have a record that you can use to show what occurred in the certification meeting.
For example, in an eviction case against a household that concealed any income or assets, you could point to the checklist as evidence that you discussed with the household the duty to disclose income and assets and explained the penalties for not doing so. This could help you defeat the argument that the household didn’t know about or understand its duties.
Your checklist should also include scripts that tell site staff exactly what to say on the various topics that HUD says you must explain to applicants. Scripting the information ensures that all applicants get complete and accurate information, even if the site staff member doing the interview is inexperienced. A script also helps you reduce your exposure to fair housing complaints that might result from site staff describing the rights of residents and applicants differently to different applicants.
Ask Applicants About Eligibility, Income, and Assets
The first topic that you should cover in certification meetings is households’ eligibility, income, and assets. You’re likelier to get full and complete answers early in the meeting while applicants are feeling fresh, rather than later, when they may have become bored with the process.
Explain certification process. First, give applicants a brief overview of the certification process. Doing this before asking specific questions about eligibility, income, and assets emphasizes to applicants the importance of full, honest answers.
HUD says you must explain program requirements, including use of the information contained in the EIV system, verification procedures, and penalties for false information [Handbook 4350.3, par. 4-24(B)(2)]. To ensure that the information is conveyed fully and accurately, use scripts of what site staff must say, as set out in our Model Form: Initial Certification Meeting Checklist.
Also, if you haven’t already done so when taking the application, be sure to go over with applicants the selection criteria from your written resident selection plan including use of the Existing Tenant Search in EIV for determining if the applicant, or a member of the applicant’s family, is receiving HUD’s rental assistance at another location [Handbook 4350.3, par. 4-24(B)(7)].
For example, if you screen applicants for criminal backgrounds, tell them during the certification meeting. When applicants hear about screening criteria that their households won’t be able to meet, ineligible applicants may find ways to end the meeting and/or the application process, saving you a lot of time and trouble. If the owner performs screening activities, a consent to check landlord or credit history should also be obtained.
Ask applicants about eligibility factors. Ask applicants about the eligibility factors that apply at your site. For example, staff members at a Section 202 site should ask whether the household qualifies as an “elderly household,” as HUD defines this term.
Be sure site staff take careful notes on the answers to all of their questions. Your checklist, like ours, should provide space for site staff to write down applicants’ responses.
Ask applicants about income and assets. Next, ask applicants about income and assets. Don’t try to do this with broad yes or no questions such as, “Do you have any income?” or “Do you have any assets?” Broad questions won’t jog applicants’ memories in the way that more specific questions will, nor will they inform applicants about everything that HUD includes under those headings.
Instead, ask specifically about each different kind of income and asset, such as employment income, bank accounts, and welfare or work-related benefits.
Be sure to tie up loose ends by asking, “Does your household have any other sources of income?” and “Does your household have any other assets?” These questions can keep less honest households from later claiming that they would have told you about other income or assets if only you had asked them.
Get Verification Consents
Have all adult household members read and sign the consents to the release of information. All members of an applicant or tenant family who are at least 18 years of age and each family head, spouse, or co-head, regardless of age, must sign and date the HUD-required consent forms (Form HUD-9887, Notice and Consent for the Release of Information to HUD and to a PHA and Form HUD-9887-A, Applicant’s/Tenant’s Consent to the Release of Information Verification by Owners of Information Supplied by Individuals Who Apply for Housing Assistance) at the initial certification. All adults regardless of whether they report income must sign and date these forms and any other necessary verification requests [Handbook 4350.3, par. 4-24(B)(5)].
Obtain Declaration of Citizenship
All family members, regardless of age, must declare their citizenship or immigration status. Noncitizens (except those age 62 and older) must sign a Verification Consent Form and submit documentation of their status or sign a declaration that they do not claim to have eligible status.
Noncitizens age 62 and older must sign a declaration of eligible immigration status and provide a proof of age document. U.S. citizens must sign a declaration of citizenship. Owners may establish a policy of requiring additional proof of citizenship for those declaring to be U.S. citizens or nationals [Handbook 4350.3, par. 3-12(B)(3)].
Ask About Social Security Numbers
Next, obtain household members’ Social Security numbers (SSNs), except those who do not contend eligible immigration status, and tenants age 62 or older as of Jan. 31, 2010, whose initial determination of eligibility was begun before Jan. 31, 2010, and provide verification of the complete and accurate SSN assigned to them [Handbook 4350.3, par. 4-24(B)(9)].
Discuss Reasonable Accommodations
HUD says that you must inform applicants in the certification meeting about the site’s duty to accommodate the disabled. At the meeting, be sure to discuss with your applicants your commitment to fair housing goals, such as equal treatment without regard to race, color, national origin, religion, sex, familial status, or disability.
If your site is for elderly and/or disabled households, HUD says that you must also go over with applicants your rules regarding pets and your meals program, if any.
Provide Informative Documents
Provide each applicant with a copy of the appropriate HUD fact sheet, which describes how the tenant’s rent is calculated. In addition, also provide each household with copies of the EIV & You and the Resident Rights and Responsibilities brochures [Handbook 4350.3, par. 4-24(B)(12-13)] .
Records and Documents
Owners May Ask Applicants to Bring to Certification Meeting
> Records of Earned Income
Income tax return (state and/or federal)
Wage tax receipts
> Records of Other Income
Pensions and annuities – latest check stub from issuing institution
Social Security – current award letter, *benefit letter or Proof of Income Letter*
Unemployment compensation – determination letter Form 2000, Form UC 30, or latest check stub
SSI – award letter, *Proof of Income Letter*
TANF – award letter, recent check stub
Worker’s compensation – Form DOL 203, recent check stub
Alimony – copy of court order
Child support – copy of court order
Education scholarships/stipends – award letter
Trade union benefits – recent check stub
Other public assistance – award letter
Income from assets – credit union/bank/S&L statements, etc.
> Asset Information
Income tax return
Certificates of deposit
> Records of Family Circumstances/Family Composition/Allowances
Statement of disability
Social Security record
Income tax returns
Legal documents showing formal adoption being pursued
Copies of medical bills
Social Security cards/alternative documents
Payment receipts for dependent care, child care, etc.
See The Model Tools For This Article
|Initial Certification Meeting Checklist|