Santa Ana City Council
July 15, 2025

6-I.K. STATE PAYMENTS TO ALLOW INDIVIDUALS WITH DISABILITIES TO LIVE AT HOME [24 CFR 5.609(b)(19)]
Payments made by or authorized by a state Medicaid agency (including through a managed care entity) or other state or federal agency to an assisted family to enable a member of the assisted family who has a disability to reside in the family’s assisted unit are excluded.

Authorized payments may include payments to a member of the assisted family through state Medicaid-managed care systems, other state agencies, federal agencies or other authorized entities.

The payments must be received for caregiving services a family member provides to enable another member of the assisted family who has a disability to reside in the family’s assisted unit.

Payments to a family member for caregiving services for someone who is not a member of the assisted family (such as for a relative that resides elsewhere) are not excluded from income.

Furthermore, if the agency is making payments for caregiving services to the family member for an assisted family member and for a person outside of the assisted family, only the payments attributable to the caregiving services for the caregiver’s assisted family member would be excluded from income.
6-I.L. CIVIL RIGHTS SETTLEMENTS [24 CFR 5.609(b)(25); FR Notice 2/14/23] Regardless of how the settlement or judgment is structured, civil rights settlements or judgments, including settlements or judgments for back pay, are excluded from annual income. This may include amounts received because of litigation or other actions, such as conciliation agreements, voluntary compliance agreements, consent orders, other forms of settlement agreements, or administrative or judicial orders under the Fair Housing Act, Title VI of the Civil Rights Act, Section 504 of the Rehabilitation Act (Section 504), the Americans with Disabilities Act, or any other civil rights or fair housing statute or requirement.

While these civil rights settlement or judgment amounts are excluded from income, the settlement or judgment amounts will generally be counted toward the family’s net family assets (e.g., if the funds are deposited into the family’s savings account or a revocable trust under the control of the family or some other asset that is not excluded from the definition of net family assets). Income generated on the settlement or judgment amount after it has become a net family asset is not excluded from income. For example, if the family received a settlement or back pay and deposited the money in an interest-bearing savings account, the interest from that account would be income at the time the interest is received.

Furthermore, if a civil rights settlement or judgment increases the family’s net family assets such that they exceed the HUD-published threshold amount ($50,000 for 2024, and $51,600 for 2025), then income will be imputed on the net family assets pursuant to 24 CFR 5.609(a)(2). If the imputed income, which HUD considers unearned income, increases the family’s annual adjusted income by 10 percent or more, then an interim reexamination of income will be required unless the addition to the family’s net family assets occurs within the last three months of the family’s income certification period and the PHA or owner chooses not to conduct the examination.

EXHIBIT 1
City Council 5 – 267 7/15/2025

6-I.M. ADDITIONAL EXCLUSIONS FROM ANNUAL INCOME [24 CFR 5.609(b); FR Notice 1/31/2024]
Other exclusions contained in 24 CFR 5.609(b) and FR Notice 1/31/24 that have not been discussed earlier in this chapter include the following:
 Payments received for the care of foster children or foster adults or state or tribal kinship or guardianship care payments [24 CFR 5.609(b)(4)].
 Insurance payments and settlements for personal or property losses, including but not limited to payments through health insurance, motor vehicle insurance, and workers’ compensation [24 CFR 5.609(b)(5)]. However, periodic payments paid at regular intervals (such as weekly, monthly, or yearly) for a period of greater than one year that are received in lieu of wages are included in annual income [Notice PIH 2023-27].
 Amounts received by the family that are specifically for, or in reimbursement of, the cost of health and medical care expenses for any family member [24 CFR 5.609(b)(6)].  Any amounts recovered in any civil action or settlement based on a claim of malpractice, negligence, or other breach of duty owed to a family member arising out of law, that resulted in a member of the family becoming disabled [24 CFR 5.609(b)(7)].  Income and distributions from any Coverdell education savings account under Section 530 of the Internal Revenue Code of 1986 or any qualified tuition program under Section 529 of such Code [24 CFR 5.609(b)(10)].
 Income earned by government contributions to, and distributions from, “baby bond” accounts created, authorized, or funded by federal, state, or local government [24 CFR 5.609(b)(10)].  The special pay to a family member serving in the Armed Forces who is exposed to hostile fire [24 CFR 5.609(b)(11)].
 Payments related to aid and attendance under 38 U.S.C. 1521 to veterans in need of regular aid and attendance [24 CFR 5.609(b)(17)]. This income exclusion applies only to veterans in need of regular aid and attendance and not to other beneficiaries of the payments, such as a surviving spouse [Notice PIH 2023-27].
 Loan proceeds (the net amount disbursed by a lender to or on behalf of a borrower, under the terms of a loan agreement) received by the family or a third party (e.g., proceeds received by the family from a private loan to enable attendance at an educational institution or to finance the purchase of a car) [24 CFR 5.609(b)(20)]. The loan borrower or co-borrower must be a member of the family for this income exclusion to be applicable [Notice PIH 2023-27].

EXHIBIT 1
City Council 5 – 268 7/15/2025

 Payments received by tribal members as a result of claims relating to the mismanagement of assets held in trust by the United States, to the extent such payments are also excluded from gross income under the Internal Revenue Code or other federal law [24 CFR 5.609(b)(21)].

Generally, payments received by tribal members in excess of the first $2,000 of per capita shares are included in a family’s annual income for purposes of determining eligibility.

However, as explained in Notice PIH 2023-27, payments made under the Cobell Settlement, and certain per capita payments under the recent Tribal Trust Settlements, must be excluded from annual income.
 Replacement housing “gap” payments made in accordance with 49 CFR Part 24 that offset increased out of pocket costs of displaced persons that move from one federally subsidized housing unit to another federally subsidized housing unit. Such replacement housing “gap” payments are not excluded from annual income if the increased cost of rent and utilities is subsequently reduced or eliminated, and the displaced person retains or continues to receive the replacement housing “gap” payments [24 CFR 5.609(b)(23)].  Income earned on amounts placed in a family’s Family Self-Sufficiency account [24 CFR

5.609(b)(27)].
 Amounts received by participants in other publicly assisted programs which are specifically for or in reimbursement of out-of-pocket expenses incurred e.g., special equipment, clothing, transportation, childcare, etc.) and which are made solely to allow participation in a specific program [24 CFR 5.609(i)(12)(ii)].
 Amounts received by a person with a disability that are disregarded for a limited time for purposes of Supplemental Security Income eligibility and benefits because they are set aside for use under a Plan to Attain Self-Sufficiency (PASS) [(24 CFR 5.609(b)(12)(i)].  Amounts received under a resident service stipend not to exceed $200 per month. A resident service stipend is a modest amount received by a resident for performing a service for the PHA or owner, on a part-time basis, that enhances the quality of life in the development [24 CFR 5.609 I(12)(ii)].

EXHIBIT 1
City Council 5 – 269 7/15/2025

Incremental earnings and benefits to any family member resulting from participation in qualifying training program funded by HUD or in qualifying federal, state, tribal, or local employment training programs (including training programs not affiliated with a local government) and training of a family member as resident management staff are excluded from annual income. Amounts excluded by this provision must be received under employment training programs with clearly defined goals and objectives and are excluded only for the period during which the family member participates in the training program unless those amounts are excluded under 24 CFR 5.609(b)(9)(i) [24 CFR 5.609(b)(12)(iv)].

SAHA Policy
SAHA defines training program as “a learning process with goals and objectives, generally having a variety of components, and taking place in a series of sessions over a period of time. It is designed to lead to a higher level of proficiency, and it enhances the individual’s ability to obtain employment. It may have performance standards to measure proficiency. Training may include but is not limited to: (1) classroom training in a specific occupational skill, (2) on-the-job training with wages subsidized by the program, or (3) basic education” [expired Notice PIH 98-2, p. 3].

SAHA defines incremental earnings and benefits as the difference between (1) the total amount of welfare assistance and earnings of a family member prior to enrollment in a training program and (2) the total amount of welfare assistance and earnings of the family member after enrollment in the program [expired Notice PIH 98-2, pp. 3–4].

In calculating the incremental difference, SAHA will use as the pre-enrollment income the total annualized amount of the family member’s welfare assistance and earnings reported on the family’s most recently completed HUD-50058.

End of participation in a training program must be reported in accordance with SAHA’s interim reporting requirements (see Chapter 11).  Reparation payments paid by a foreign government pursuant to claims filed under the laws of that government by persons who were persecuted during the Nazi era [24 CFR 5.609(b)(13)].  Adoption assistance payments for a child in excess of the amount of the dependent deduction per adopted child [24 CFR 5.609(b)(15)].
 Refunds or rebates on property taxes paid on the dwelling unit [24 CFR 5.609(b)(20)].  Amounts that HUD is required by federal statute to exclude from consideration as income for purposes of determining eligibility or benefits under a category of assistance programs that includes assistance under any program to which the exclusions set forth in 24 CFR 5.609(b) apply. HUD will publish a notice in the Federal Register to identify the benefits that qualify for this exclusion. Updates will be published when necessary.

EXHIBIT 1
City Council 5 – 270 7/15/2025

HUD publishes an updated list of these exclusions periodically. The most recent list of exclusions was published in the Federal Register on January 31, 2024. It includes:
(a) The value of the allotment provided to an eligible household under the Food Stamp Act of 1977 (7 U.S.C. 2017 (b)). This exclusion also applies to assets. (b) Benefits under Section 1780 of the Richard B. Russell School Lunch Act and Child Nutrition Act of 1966, including WIC and reduced-price lunches. (c) Payments, including for supportive services and reimbursement of out-of-pocket expenses, to volunteers under the Domestic Volunteer Services Act of 1973 (42 U.S.C. 5044(g), 5058). The exclusion also applies to assets.
- Except, the exclusion does not apply when the Chief Executive Officer of the Corporation for National and Community Service determines that the value of all such payments, adjusted to reflect the number of hours such volunteers are serving, is equivalent to or greater than the minimum wage then in effect under the Fair Labor Standards Act of 1938 (29 U.S.C. 201 et seq.) or the minimum wage, under the laws of the State where such volunteers are serving, whichever is the greater (42 U.S.C. 5044(f)(1)).
(d) Certain payments received under the Alaska Native Claims Settlement Act (43 U.S.C. 1626(c)).
(e) Income derived from certain submarginal land of the United States that is held in trust for certain Indian tribes (25 U.S.C. 5506).
(f) Payments or allowances made under the Department of Health and Human Services’ Low-Income Home Energy Assistance Program (42 U.S.C. 8624(f)(1)). (g) Allowances, earnings, and payments to individuals participating in programs under the Workforce Investment Act of 1998 which was reauthorized as the Workforce Innovation and Opportunity Act of 2014 (29 U.S.C. 3241(a)(2)). (h) Deferred disability benefits from the Department of Veterans Affairs, whether received as a lump sum or in monthly prospective amounts.
(i) Income derived from the disposition of funds to the Grand River Band of Ottawa Indians (Pub. L. 94-540, 90 Section 6).
(j) Payments, funds, or distributions authorized, established, or directed by the Seneca Nation Settlement Act of 1990 (25 U.S.C. 1774f(b)).
(k) A lump sum or periodic payment received by an individual Indian pursuant to the Class Action Settlement Agreement in the United States District Court case entitled Elouise Cobell et al. v. Ken Salazar et al., for a period of one year from the time of receipt of that payment as provided in the Claims Resolution Act of 2010.

EXHIBIT 1
City Council 5 – 271 7/15/2025

(l) The first $2,000 of per capita shares received from judgment funds awarded by the Indian Claims Commission or the U. S. Claims Court, the interests of individual Indians in trust or restricted lands, including the first $2,000 per year of income received by individual Indians from funds derived from interests held in such trust or restricted lands (25 U.S.C. 1407-1408). This exclusion does not include proceeds of gaming operations regulated by the Commission (25 U.S.C. 1407–1408).
(m) Payments received from programs funded under Title V of the Older Americans Act of 1965 (42 U.S.C. 3056(f)).
(n) Payments received on or after January 1, 1989, from the Agent Orange Settlement Fund or any other fund established pursuant to the settlement in In Re Agent Orange product liability litigation, M.D.L. No. 381 (E.D.N.Y.). This exclusion also applies to assets. (o) Payments received under 38 U.S.C. 1833(c) to children of Vietnam veterans born with spinal bifida, children of women Vietnam veterans born with certain birth defects, and children of certain Korean and Thailand service veterans born with spinal bifida (42 U.S.C. 12637(d)).
(p) Payments received under the Maine Indian Claims Settlement Act of 1980 (25 U.S.C. 1721). This exclusion also applies to assets.
(q) The value of any childcare provided or arranged (or any amount received as payment for such care or reimbursement for costs incurred for such care) under the Childcare and Development Block Grant Act of 1990 (42 U.S.C. 9858q).
(r) Earned income tax credit (EITC) refund payments received on or after January 1, 1991 (26 U.S.C. 32(j)). This exclusion also applies to assets. (s) Payments by the Indian Claims Commission to the Confederated Tribes and Bands of Yakima Indian Nation or the Apache Tribe of Mescalero Reservation (Pub. L. 95-433) This exclusion also applies to assets.
(t) Amounts of student financial assistance funded under Title IV of the Higher Education Act of 1965j, including awards under federal work-study programs or under the Bureau of Indian Affairs student assistance programs (20 U.S.C. 1087uu). For Section 8 programs, only, any financial assistance in excess of amounts received by an individual for tuition and any other required fees and charges under the Higher Education Act of 1965 (20 U.S.C. 1001 et seq.), from private sources, or an institution of higher education (as defined under the Higher Education Act of 1965 (20 U.S.C. 1002)), shall be considered income if the individual is over the age of 23 with dependent children (Pub. L. 109–115, section 327 (as amended)).
(u) Allowances, earnings, and payments to AmeriCorps participants under the National and Community Service Act of 1990 (42 U.S.C. 12637(d)).
(v) Any amount of crime victim compensation that provides medical or other assistance (or payment or reimbursement of the cost of such assistance) under the Victims of Crime Act of 1984 received through a crime victim assistance program, unless the total amount of assistance that the applicant receives from all such programs is sufficient to fully compensate the applicant for losses suffered as a result of the crime (34 U.S.C. 20102(c)).

EXHIBIT 1
City Council 5 – 272 7/15/2025

(w) Any amounts in an “individual development account” are excluded from assets and any assistance, benefit, or amounts earned by or provided to the individual development account are excluded from income, as provided by the Assets for Independence Act, as amended (42 U.S.C. 604(h)(4)).
(x) Major disaster and emergency assistance received under the Robert T. Stafford Disaster Relief and Emergency Assistance Act and comparable disaster assistance provided by states, local governments, and disaster assistance organizations. This exclusion also applies to assets.
(y) Distributions from an ABLE account, distributions from and certain contributions to an ABLE account established under the ABLE Act of 2014 (Pub. L. 113–295.), as described in Notice PIH 2019–09 or subsequent or superseding notice is excluded from income and assets.
(z) The amount of any refund (or advance payment with respect to a refundable credit) issued under the Internal Revenue Code is excluded from income and assets for a period of 12 months from receipt (26 U.S.C. 6409).
(aa) Assistance received by a household under the Emergency Rental Assistance Program pursuant to the Consolidated Appropriations Act, 2021 (Pub. L. 116–260, section 501(j)), and the American Rescue Plan Act of 2021.
(ab) Per capita payments made from the proceeds of Indian Tribal Trust Settlements listed in IRS Notice 2013-1 and 2013-55 must be excluded from annual income unless the per capita payments exceed the amount of the original Tribal Trust Settlement proceeds and are made from a Tribe’s private bank account in which the Tribe has deposited the settlement proceeds. Such amounts received in excess of the Tribal Trust Settlement are included in the gross income of the members of the Tribe receiving the per capita payments as described in IRS Notice 2013-1. The first $2,000 of per capita payments are also excluded from assets unless the per capita payments exceed the amount of the original Tribal Trust Settlement proceeds and are made from a Tribe’s private bank account in which the Tribe has deposited the settlement proceeds (25 U.S.C. 117b(a), 25 U.S.C. 1407).
(ac) Any amounts (i) not actually received by the family, (ii) that would be eligible for exclusion under 42 U.S.C. 1382b(a)(7), and (iii) received for service-connected disability under 38 U.S.C. Chapter 11 or dependency and indemnity compensation under 38 U.S.C. Chapter 13 (25 U.S.C. 4103(9)(C)) as provided by an amendment by the Indian Veterans Housing Opportunity Act of 2010 (Pub. L. 111–269 section 2) to the definition of income applicable to programs under the Native American Housing Assistance and Self-Determination Act (NAHASDA) (25 U.S.C. 4101 et seq.).

EXHIBIT 1
City Council 5 – 273 7/15/2025

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City Council 5 – 274 7/15/2025

PART II: ASSETS
6-II.A. OVERVIEW
Annual income includes all actual anticipated income from assets (unless otherwise excluded by the regulations) even if the asset itself is excluded from net family assets [Notice PIH 2023-27].

The regulation at 24 CFR 5.603(b)(3) provides a list of items that are excluded from the calculation of net family assets. Note, unlike previous versions of the regulations, the current regulations do not list types of assets that are included in annual income. Instead, HUD relies on the definition of items excluded from assets to provide the scope of what is included. Exhibit 6-2 provides the regulatory definition of net family assets.

Optional policies for family self-certification of assets are found in Chapter 7. Policies related to the asset limitation may be found in Chapters 3 and 12.

Income from assets is always anticipated, irrespective of the income examination type.

SAHA Policy
SAHA generally will use current circumstances to determine both the value of an asset and the anticipated income from the asset. SAHA will use other than current circumstances to anticipate income when (1) an imminent change in circumstances is expected, (2) it is not feasible to anticipate a level of income over 12 months, or (3) SAHA believes that past income is the best indicator of anticipated income. For example, if a family member owns real property that typically receives rental income, but the property is currently vacant, SAHA can take into consideration past rental income along with the prospects of obtaining a new tenant.

Any time current circumstances are not used to determine asset income, a clear rationale for the decision will be documented in the file. In such cases the family may present information and documentation to SAHA to show why the asset income determination does not represent the family’s anticipated asset income.

EXHIBIT 1
City Council 5 – 275 7/15/2025

6-II.B. ASSETS DISPOSED OF FOR LESS THAN FAIR MARKET VALUE [24 CFR 5.603(b)(2)]
PHAs must include the value of any business or family assets disposed of by an applicant or participant for less than fair market value (including a disposition in trust, but not in a foreclosure or bankruptcy sale) during the two years preceding the date of application or reexamination, as applicable, in excess of the consideration received for the asset. An asset moved to a retirement account held by a member of the family is not considered to be an asset disposed of for less than fair market value [Notice PIH 2023-27].

The family must certify whether any assets have been disposed of for less than fair market value in the preceding two years.

Minimum Threshold
The HCV Guidebook permits the PHA to set a threshold below which assets disposed of for less than fair market value will not be counted [HCV GB, p. 5-27].

SAHA Policy
SAHA will not include the value of assets disposed of for less than fair market value unless the cumulative fair market value of all assets disposed of during the past two years exceeds the gross amount received for the assets by more than $1,000.

Separation or Divorce
The regulation also specifies that assets are not considered disposed of for less than fair market value if they are disposed of as part of a separation or divorce settlement and the applicant or tenant receives important consideration not measurable in dollar terms.

SAHA Policy
All assets disposed of as part of a separation or divorce settlement will be considered assets for which important consideration not measurable in monetary terms has been received. In order to qualify for this exemption, a family member must be subject to a formal separation or divorce settlement agreement established through arbitration, mediation, or court order.

Foreclosure or Bankruptcy
Assets are not considered disposed of for less than fair market value when the disposition is the result of a foreclosure or bankruptcy sale. Negative equity in real property or other investments does not prohibit the owner from selling the property or other investments, so negative equity alone would not justify excluding the property or other investments from family assets.

Family Declaration
SAHA Policy
Families must sign a declaration form at initial certification and each annual recertification identifying all assets that have been disposed of for less than fair market value or declaring that no assets have been disposed of for less than fair market value.

SAHA may verify the value of the assets disposed of if other information available to SAHA does not appear to agree with the information reported by the family.

EXHIBIT 1
City Council 5 – 276 7/15/2025

6-II.C. ASSET INCLUSIONS AND EXCLUSIONS
Necessary and Non-Necessary Personal Property [24 CFR 5.603(b)(3)(i)] All assets are categorized as either real property (e.g., land, a home) or personal property.

Personal property includes tangible items, like boats, as well as intangible items, like bank accounts.

The value of necessary items of personal property is excluded from the calculation of net family assets. Necessary items of personal property include a car used for commuting or medical devices.

HUD defines necessary personal property as items essential to the family for the maintenance, use, and occupancy of the premises as a home; or they are necessary for employment, education, or health and wellness. Necessary personal property includes more than merely items that are indispensable to the bare existence of the family. It may include personal effects (such as items that are ordinarily worn or utilized by the individual), items that are convenient or useful to a reasonable existence, and items that support and facilitate daily life within the family’s home.

Necessary personal property also includes items that assist a household member with a disability, including any items related to disability-related needs, or that may be required for a reasonable accommodation for a person with a disability. Necessary personal property does not include bank accounts, other financial investments, or luxury items. Items of personal property that do not qualify as necessary personal property are classified as non-necessary personal property.

The combined value of all non-necessary items of personal property is only included in annual income when the combined total value exceeds the HUD-published threshold amount (adjusted annually and published in HUD’s current year Inflation-Adjusted Values tables). When the combined value of all non-necessary personal property does not exceed the HUD-published threshold amount, all non-necessary personal property is excluded from net family assets.  The threshold amount is $50,000 for 2024, and $51,600 for 2025.

While not an exhaustive list, the following table from Notice PIH 2023-27 provides examples of necessary and non-necessary personal property.

EXHIBIT 1
City Council 5 – 277 7/15/2025

Necessary Personal Property Non-Necessary Personal Property Car(s)/vehicle(s) that a family relies on for
transportation for personal or business use
(e.g., bike, motorcycle, skateboard, scooter)
Furniture, carpets, linens, kitchenware
Common appliances
Common electronics (e.g., radio, television,
DVD player, gaming system)
Clothing
Personal effects that are not luxury items
(e.g., toys, books)
Wedding and engagement rings
Jewelry used in religious/cultural celebrations
and ceremonies
Religious and cultural items
Medical equipment and supplies
Health care–related supplies
Musical instruments used by the family
Personal computers, phones, tablets, and
related equipment
Professional tools of trade of the family, for
example professional books
Educational materials and equipment used by
the family, including equipment to
accommodate persons with disabilities
Equipment used for exercising (e.g., treadmill,
stationary bike, kayak, paddleboard, ski
equipment)
Recreational car/vehicle not needed for day-today transportation for personal or business use (campers, motorhomes, traveling trailers, allterrain vehicles (ATVs)) Bank accounts or other financial investments
(e.g., checking account, savings account,
stocks/bonds)
Recreational boat/watercraft
Expensive jewelry without religious or cultural
value, or which does not hold family
significance
Collectibles (e.g., coins/stamps)
Equipment/machinery that is not used to
generate income for a business
Items such as gems/precious metals, antique
cars, artwork, etc.

SAHA Policy
In determining the value of non-necessary, non-financial personal property, SAHA will use the family’s estimate of the value. SAHA may obtain an appraisal if there is reason to believe that the family’s estimated value is off. The family must cooperate with the appraiser but cannot be charged any costs related to the appraisal.

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City Council 5 – 278 7/15/2025

Checking and Savings Accounts [Notice PIH 2023-27]
HUD considers bank accounts as non-necessary items of personal property. Whether or not non-necessary personal property is counted toward net family assets depends on the combined value of all of the family’s assets.
 When the combined value of net family assets is greater than the HUD-published threshold amount, which is adjusted annually and listed in HUD’s current year Inflation Adjusted Values tables ($50,000 for 2024, and $51,600 for 2025), checking and/or savings accounts would be counted toward net family assets.
 When the combined value of all non-necessary personal property does not exceed the HUDpublished threshold amount, all non-necessary personal property is excluded from net family assets. In this case, the value of the family’s checking and/or savings accounts would not be considered when calculating net family assets.

However, actual income from checking and savings accounts is always included in a family’s annual income, regardless of the total value of net family assets or whether the asset itself is included or excluded from net family assets, unless that income is specifically excluded.

ABLE Accounts [24 CFR 5.609(b)(10); Notice PIH 2019-09] An Achieving a Better Life Experience (ABLE) account is a type of tax-advantaged savings account that an eligible individual can use to pay for qualified disability expenses. Section 103 of the ABLE Act mandates that an individual’s ABLE account (specifically, its account balance, contributions to the account, and distributions from the account) is excluded when determining the designated beneficiary’s eligibility and continued occupancy under certain federal meanstested programs. The PHA must exclude the entire value of the individual’s ABLE account from the household’s assets. Distributions from the ABLE account are also not considered income.

However, all wage income received, regardless of which account the money is paid to, is included as income.

EXHIBIT 1
City Council 5 – 279 7/15/2025

Investment Accounts Such as Stocks, Bonds, Saving Certificates, and Money Market Funds [24 CFR 5.603(b)(1)]
HUD considers financial investments such as stocks and bonds non-necessary items of personal property. Whether non-necessary personal property is counted toward net family assets depends on the combined value of all of the family’s assets.
 When the combined value of net family assets is greater than the HUD-published threshold amount, which is adjusted annually and listed in HUD’s Inflation Adjusted Values tables ($50,000 for 2024, and $51,600 for 2025), financial investments such as stocks and bonds are considered part of net family assets. In this case, the value of the family’s financial investments such as stocks and bonds would be counted toward net family assets.  When the combined value of all non-necessary personal property does not exceed the HUDpublished threshold amount, all non-necessary personal property is excluded from net family assets. In this case, the value of the family’s financial investments such as stocks and bonds would not be considered when calculating net family assets.

However, actual income from financial accounts is always included in a family’s annual income, regardless of the total value of net family assets or whether the asset itself is included or excluded from net family assets, unless that income is specifically excluded. When a stock issues dividends in some years but not others (e.g., due to market performance), the dividend is counted as the actual return when it is issued, but when no dividend is issued, the actual return is $0.

When the stock never issues dividends, the actual return is $0.

SAHA Policy
SAHA will include interest or dividends earned by investment accounts as actual income from assets even when the earnings are reinvested.

The cash value of such an asset is determined by deducting from the market value any broker fees, penalties for early withdrawal, or other costs of converting the asset to cash.

In determining the market value of an investment account, SAHA will use the value of the account on the most recent investment report dated within 120-days from the recertification date.

EXHIBIT 1
City Council 5 – 280 7/15/2025

Lump-Sum Additions to Net Family Assets [24 CFR 5.609(b)(24(viii); Notice PIH 2023-27] The regulations exclude income from lump-sum additions to family assets, including lottery or other contest winnings as a type of nonrecurring income.

In addition, lump sums from insurance payments, settlements for personal or property losses, and recoveries from civil actions or settlements based on claims of malpractice, negligence, or other breach of duty owed to a family member arising out of law that resulted in a member of the family becoming a family member with a disability are excluded from income.

Further, deferred periodic amounts from Supplemental Security Income (SSI) and Social Security benefits that are received in a lump sum amount or in prospective monthly amounts, or any deferred Department of Veterans Affairs disability benefits that are received in a lump sum amount or in prospective monthly amounts are also excluded from income.

However, these amounts may count toward net family assets. The PHA must consider any actual or imputed returns from assets as income at the next applicable income examination. In the case where the lump sum addition to assets would lead to imputed income, which is unearned income, that increases the family’s annual adjusted income by 10 percent or more, then the addition of the lump sum to the family’s assets will trigger an immediate interim reexamination of income in accordance with Chapter 11. This reexamination of income must take place as soon as the lump sum is added to the family’s net family assets unless the addition takes place in the last three months of family’s income certification period and the PHA chooses not to conduct the examination.

For a discussion of lump-sum payments that represent the delayed start of a periodic payment, most of which are counted as income, see sections 6-I.H and 6-I.I.

SAHA Policy
Any lump-sum receipts are only counted as assets if they are retained by a family in a form recognizable as an asset. [RHIIP FAQs]. For example, if the family receives a $1,000 lump sum for lottery winnings, and the family immediately spends the entire amount, the lump sum will not be counted toward net family assets.

EXHIBIT 1
City Council 5 – 281 7/15/2025

Jointly Owned Assets [Notice PIH 2023-27]
For assets owned jointly by the family and one or more individuals outside of the assisted family, the PHA must include the total value of the asset in the calculation of net family assets, unless:
 The asset is otherwise excluded;
 The family can demonstrate that the asset is inaccessible to them; or  The family cannot dispose of any portion of the asset without the consent of another owner who refuses to comply.

If the family demonstrates that they can only access a portion of an asset, then only that portion’s value is included in the calculation of net family assets for the family.

Any income from a jointly owned asset must be included in annual income, unless:
 The income is specifically excluded;
 The family demonstrates that they do not have access to the income from that asset; or  The family only has access to a portion of the income from that asset.

If the family demonstrates that they can only access a portion of the income from an asset, then only that portion’s value is included in the calculation of income from assets.

If an individual is a beneficiary who is entitled to access the account’s funds only upon the death of the account’s owner, and may not otherwise withdraw funds from an account, then the account is not an asset to the assisted family, and the family should provide proper documentation demonstrating that they are only a beneficiary on the account.

Trusts [24 CFR 5.609(b)(2) and 5.603(b)(4)]
A trust is a legal arrangement generally regulated by state law in which one party (the creator or grantor) transfers property to a second party (the trustee) who holds the property for the benefit of one or more third parties (the beneficiaries).

The basis for determining how to treat trusts relies on information about who has access to either the principal in the account or the income from the account. There are two types of trusts, revocable and irrevocable.

When the creator sets up an irrevocable trust, the creator has no access to the funds in the account. Typically, special needs trusts are considered irrevocable. Irrevocable trusts not under the control of any member of the family are excluded from net family assets. The value of the trust continues to be excluded from net family assets, so long as the fund continues to be held in a trust that is not revocable by, or under the control of, any member of the family or household [24 CFR 5.603(b)(4)]. Further, where an irrevocable trust is excluded from net family assets, the PHA must not consider actual income earned by the trust (e.g., interest earned, rental income if property is held in the trust) for so long as the income from the trust is not distributed.

EXHIBIT 1
City Council 5 – 282 7/15/2025

A revocable trust is a trust that the creator of the trust may amend or end (revoke). When there is a revocable trust, the creator has access to the funds in the trust account.  A revocable trust that is under the control of the family is included in net family assets when the grantor is a member of the assisted family. If a revocable trust is included in the calculation of net family assets, then the actual income earned by the revocable trust is also included in the family’s income. For example, interest earned or rental income if the property is held in the trust. The PHA must calculate imputed income on the revocable trust if net family assets are more than the HUD-published threshold amount, which is adjusted annually and listed in HUD’s Inflation Adjusted Values tables ($50,000 for 2024, and $51,600 for 2025), and actual income from the trust cannot be calculated (e.g., if the trust is comprised of farmland that is not in use).
 A revocable trust that is not under the control of the family is excluded from net family assets. This happens when a member of the assisted family is the beneficiary of a revocable trust, but the grantor is not a member of the assisted family. In this case the beneficiary does not “own” the revocable trust, and the value of the trust is excluded from net family assets.

For the revocable trust to be considered excluded from net family assets, no family or household member may be the account’s trustee.

For both irrevocable and revocable trusts, if the value of the trust is not considered part of net family assets, then distributions from the trust are treated as follows:
 All distributions from the trust’s principal are excluded from income.  Distributions of income earned by the trust (i.e., interest, dividends, realized gains, or other earnings on the trust’s principal), are included as income unless the distribution is used to pay for the health and medical expenses for a minor.

Life Insurance [FR Notice 2/14/23 and Notice PIH 2023-27] Net family assets do not include the value of term life insurance, which has no cash value to the individual before death.

The cash value of a life insurance policy available to a family member before death, such as a whole life or universal life policy, is included in the calculation of the value of the family’s assets. The cash value is the surrender value. While the cash value of an insurance policy is considered an asset, the face value of any policy is not. If such a policy earns dividends or interest that the family could elect to receive, the amount of dividends or interest is counted as income from the asset whether or not the family actually receives it.

Tax Refunds [24 CFR 5.603(b)(3)(xi) and Notice PIH 2023-27] All amounts received by a family in the form of federal tax refunds or refundable tax credits are excluded from a family’s net family assets for a period of 12 months after receipt by the family.

At the time of an annual or interim reexamination of income, if the federal tax refund was received during the 12 months preceding the effective date of the reexamination, then the amount of the refund that was received by the family is subtracted from the total value of net family assets. When the subtraction results in a negative number, then net family assets are considered $0.

EXHIBIT 1
City Council 5 – 283 7/15/2025

Asset Exclusions [24 CFR 5.603(b)]
The following are excluded from the calculations of net family assets:
 The value of any account under a retirement plan recognized as such by the IRS, including individual retirement arrangements (IRAs), employer retirement plans, and retirement plans for self-employed individuals [24 CFR 5.603(b)(3)(iii)].  The value of real property that the family does not have the effective legal authority to sell in the jurisdiction in which the property is located [24 CFR 5.603(b)(3)(iv)]. - Real property as used in this part has the same meaning as that provided under the law of the state in which the property is located [24 CFR 5.100]. - Examples of this include but are not limited to co-ownership situations (including situations where one owner is a victim of domestic violence), where one party cannot unilaterally sell the real property; property that is tied up in litigation; and inherited property in dispute [Notice PIH 2023-27].
 Any amounts recovered in any civil action or settlement based on a claim of malpractice, negligence, or other breach of duty owed to a family member arising out of law, that resulted in a family member being a person with a disability [24 CFR 5.603(b)(3)(v)];  The value of any Coverdell education savings account under section 530 of the Internal Revenue Code of 1986 [24 CFR 5.603(b)(3)(vi)];
 The value of any qualified tuition program under Section 529 of such Code [24 CFR

5.603(b)(3)(vi)];
 The value of any “baby bond” account created, authorized, or funded by federal, state, or local government [24 CFR 5.603(b)(3)(vi)];
 Interests in Indian trust land [24 CFR 5.603(b)(3)(vii)];  Equity in a manufactured home where the family receives assistance under 24 CFR part 982 [24 CFR 5.603(b)(3)(viii)];
 Equity in property under the Homeownership Option for which a family receives assistance under 24 CFR part 982 [24 CFR 5.603(b)(3)(ix)];
 Family Self-Sufficiency accounts [24 CFR 5.603(b)(3)(x)];  Federal tax refunds or refundable tax credits for a period of 12 months after receipt by the family [24 CFR 5.603(b)(3)(xi)].
 The full amount of assets held in an irrevocable trust [Notice PIH 2023-27]; and  The full amount of assets held in a revocable trust where a member of the family is the beneficiary, but the grantor/owner and trustee of the trust is not a member of the participant family or household [Notice PIH 2023-27].

EXHIBIT 1
City Council 5 – 284 7/15/2025

6-II.D. DETERMINING INCOME FROM ASSETS
In some cases, amounts that are excluded from net family assets may be included as annual income when disbursements are made to a family from an asset. In other cases, amounts are excluded from annual income as a lump-sum addition to net family assets, but those funds are then considered a net family asset if held in an account or other investment that is considered part of net family assets [Notice PIH 2023-27].

Net Family Assets
Net family assets are defined as the net cash value of all assets owned by the family, after deducting reasonable costs that would be incurred in disposing real property, savings, stocks, bonds, and other forms of capital investment.

SAHA Policy
Reasonable costs that would be incurred when disposing of an asset include, but are not limited to, penalties for premature withdrawal, broker and legal fees, and settlement costs incurred in real estate transactions such as settlement costs and transfer taxes [New PH OCC GB, Income Determinations, p. 24].

The calculation of asset income sometimes requires the PHA to make a distinction between an asset’s market value and its cash value.
 The market value of an asset is its worth in the market (e.g., the amount a buyer would pay for real estate or the total value of an investment account).  The cash value of an asset is its market value less all reasonable amounts that would be incurred when converting the asset to cash.

The cash value of real property or other assets with negative equity would be considered $0 for the purposes of calculating net family assets. Negative equity in real property or other investments does not prohibit the family from selling the property or other investments, so negative equity alone would not justify excluding the property or other investments from family assets [Notice PIH 2023-27].

EXHIBIT 1
City Council 5 – 285 7/15/2025

Actual Income from Assets
Income from assets must be included on the Form HUD-50058 regardless of the amount of income. Actual income from assets is always included in a family’s annual income, regardless of the total value of net family assets or whether the asset itself is included or excluded from net family assets, unless that income is specifically excluded by 24 CFR 5.609(b).

Income or returns from assets are generally considered to be interest, dividend payments, and other actual income earned on the asset, and not the increase in market value of the asset. The increase in market value is relevant to the cash value of the asset for the purpose of determining total net family assets and imputing income.

The PHA may determine the net assets of a family based on a self-certification by the family that the net family assets do not exceed the HUD-published threshold amount, which is adjusted annually and listed in HUD’s Inflation Adjusted Values tables, without taking additional steps to verify the accuracy of the declaration [24 CFR 5.618(b)]. Policies related to verification of assets are found in Chapter 7 of this policy.
 The threshold amount is $50,000 for 2024, and $51,600 for 2025.

The PHA may not calculate or include any imputed income from assets when net family assets are less than or equal to the HUD-published threshold amount [24 CFR 5.609(b)(1)]. The actual income from assets must be included on the Form HUD-50058.

Imputed Income from Assets
When net family assets exceed the HUD-published threshold amount, which is adjusted annually and listed in HUD’s Inflation Adjusted Values tables, the PHA may not rely on self-certification.

If actual returns can be calculated, the PHA must include actual income from the asset on the Form HUD-50058 (for example, a savings account or CD where the rate of return is known). If actual returns cannot be calculated, the PHA must calculate imputed returns using the HUDdetermined passbook rate (for example, real property or a non-necessary item of personal property such as a recreational boat). Imputed income is calculated by multiplying the net cash value of the asset (found by deducting reasonable costs that would be incurred in disposing of the asset from the market value) by the HUD-published passbook rate. If the PHA can compute actual income from some but not all assets, the PHA must compute actual returns where possible and use the HUD-determined passbook rate for assets where actual income cannot be calculated [24 CFR 5.609(a)(2)].

An asset with an actual return of $0 (such as a non-interest-bearing checking account), is not the same as an asset for which an actual return cannot be computed (such as non-necessary personal property). If the asset is a financial asset and there is no income generated (for example, a bank account with a zero percent interest rate or a stock that does not issue cash dividends), then the asset generates zero actual asset income, and imputed income is not calculated. When a stock issues dividends in some years but not others (e.g., due to market performance), the dividend is counted as the actual return when it is issued, and when no dividend is issued, the actual return is $0. When the stock never issues dividends, the actual return is consistently $0.

EXHIBIT 1
City Council 5 – 286 7/15/2025

PART III: ADJUSTED INCOME
6-III.A. INTRODUCTION
Overview
HUD regulations require PHAs to deduct from annual income any of five mandatory deductions for which a family qualifies and allow the PHA to deduct other permissive deductions in accordance with PHA policy. The resulting amount is the family’s adjusted income. Mandatory deductions are found in 24 CFR 5.611.

5.611 Adjusted income means annual income (as determined under § 5.609) of the members of the family residing or intending to reside in the dwelling unit, after making the following deductions:
(a) Mandatory deductions
(1) $480 for each dependent (adjusted annually by HUD, rounded to the next lowest multiple of $25);
(2) $525 for any elderly family or disabled family (adjusted annually by HUD, rounded to the next lowest multiple of $25);
(3) The sum of the following, to the extent the sum exceeds ten percent of annual income:
(i) Unreimbursed health and medical care expenses of any elderly family or disabled family; (ii) Unreimbursed reasonable attendant care and auxiliary apparatus expenses for each member of the family who is a person with disabilities, to the extent necessary to enable any member of the family (including the member who is a person with disabilities) to be employed; and (4) Any reasonable childcare expenses necessary to enable a member of the family to be employed or to further his or her education.

This part covers policies related to these mandatory deductions. Verification requirements related to these deductions are found in Chapter 7.

EXHIBIT 1
City Council 5 – 287 7/15/2025

Anticipating Expenses
SAHA Policy
Generally, SAHA will use current circumstances to anticipate expenses. When possible, for costs that are expected to fluctuate during the year (e.g., childcare during school and non-school periods and cyclical medical expenses), SAHA will estimate costs based on historic data and known future costs.

If a family has an accumulated debt for medical or disability assistance expenses, SAHA will include as an eligible expense the portion of the debt that the family expects to pay during the period for which the income determination is being made. However, amounts previously deducted will not be allowed even if the amounts were not paid as expected in a preceding period. SAHA may require the family to provide documentation of payments made in the preceding year.

When calculating health and medical care expenses, SAHA will include those expenses anticipated to be incurred during the 12 months following the certification date which are not covered by an outside source, such as insurance. The allowance is not intended to give a family an allowance equal to last year’s expenses, but to anticipate regular ongoing and anticipated expenses during the coming year. Since these expenses are anticipated, the PH Occupancy Guidebook states “it is likely that actual expenses will not match what was anticipated. Typically, this would not be considered an underpayment as long as at the time of the annual reexamination, the expenses were calculated based on the appropriate verification” [New PH OCC GB, Income Determinations, p. 30]. For annual reexaminations, SAHA will use information for the previous 12-month period. 6-III.B. DEPENDENT DEDUCTION
An allowance of $480 is deducted from annual income for each dependent (which amount will be adjusted by HUD annually in accordance with the Consumer Price Index for Urban Wage Earners and Clerical Workers, rounded to the next lowest multiple of $25) [24 CFR 5.611(a)(1)].

Dependent is defined as any family member other than the head, spouse, or cohead who is under the age of 18 or who is 18 or older and is a person with disabilities or a full-time student. Foster children, foster adults, and live-in aides are never considered dependents [24 CFR 5.603(b)]. 6-III.C. ELDERLY OR DISABLED FAMILY DEDUCTION
A single deduction of $525 is taken for any elderly or disabled family (which amount will be adjusted by HUD annually in accordance with the Consumer Price Index for Urban Wage Earners and Clerical Workers, rounded to the next lowest multiple of $25) [24 CFR 5.611(a)(2)].

An elderly family is a family whose head, spouse, cohead, or sole member is 62 years of age or older, and a disabled family is a family whose head, spouse, cohead, or sole member is a person with disabilities [24 CFR 5.403].

EXHIBIT 1
City Council 5 – 288 7/15/2025

6-III.D. HEALTH AND MEDICAL CARE EXPENSES DEDUCTION [24 CFR

5.611(a)(3)(i) and 5.603(b)]
Unreimbursed health and medical care expenses may be deducted to the extent that, in combination with any disability assistance expenses, they exceed ten percent of annual income.

This deduction is permitted only for families in which the head, spouse, or cohead is at least 62 or is a person with disabilities. If a family is eligible for a health and medical care expense deduction, the unreimbursed health and medical care expenses of all family members are included. The PHA calculates health and medical care expenses based on the family’s past expenses, but accounting for any anticipated changes in expenses during the certification period.

Definition of Medical Expenses
HUD regulations define health and medical care expenses at 24 CFR 5.603(b) to mean “any costs incurred in the diagnosis, cure, mitigation, treatment, or prevention of disease or payments for treatments affecting any structure or function of the body. Health and medical care expenses include medical insurance premiums and long-term care premiums that are paid or anticipated during the period for which annual income is computed.” Health and medical care expenses may be deducted from annual income only if they are eligible under this definition and not otherwise reimbursed.

Although HUD revised the definition of health and medical care expenses to reflect the Internal Revenue Service (IRS) general definition of medical expenses, HUD is not permitting PHAs to specifically align their policies to IRS Publication 502. PHAs must review each expense to determine whether it is eligible in accordance with HUD’s definition.

While PHA policies may not specifically align with IRS Publication 502, HUD recommends PHAs use it as a standard for determining allowable expenses, and the PHA may list examples of allowable expenses in their policy provided they comply with HUD’s definition at 24 CFR

5.603. The PHA may not define health and medical care expenses more narrowly than the regulation.

SAHA Policy
SAHA will use the most current IRS Publication 502 as a standard for determining if expenses claimed by eligible families qualify as health and medical care expenses.

However, under no circumstances will SAHA deduct any expenses listed in IRS Publication 502 that do not conform with HUD’s definition of health and medical care expenses.

EXHIBIT 1
City Council 5 – 289 7/15/2025

Summary of Typical Allowable Health and Medical Care Expenses Services of medical professionals
Surgery and medical procedures that are
necessary, legal, and non-cosmetic
Services of medical facilities
Hospitalization, long-term care, and inhome nursing services Prescription medicines and insulin, but
not nonprescription medicines even if
recommended by a doctor
Improvements to housing directly related
to medical needs (e.g., ramps for a
wheelchair, handrails)
Medical insurance premiums or the cost
of a health maintenance organization
(HMO)
Medicare Part B and Part D premiums
Substance abuse treatment programs
Psychiatric treatment
Ambulance services and some costs of
transportation related to medical
expenses. The PHA will use the most
current medical mileage rate listed in
IRS Publication 502.

The cost and care of necessary
equipment related to a medical
condition (e.g., eyeglasses/lenses,
hearing aids, crutches, and artificial
teeth)
The costs of buying, training, and
maintaining a guide dog or other service
animal to assist a visually impaired or
hearing disabled person, or a person
with other physical disabilities. In
general, this includes any costs, such as
food, grooming, and veterinary care,
incurred in maintaining the health and
vitality of the service animal so that it
may perform its duties.

Note: This chart provides a summary of eligible health and medical care expenses only. In all cases, the PHA will consider whether health and medical expenses care expenses claimed by the family are eligible under HUD’s definition.

Families That Qualify for Both Health and Medical and Disability Assistance Expenses SAHA Policy
This policy applies only to families in which the head, spouse, or cohead is 62 or older or is a person with disabilities.

When expenses anticipated by a family could be defined as either a health and medical care or disability assistance expenses, SAHA will consider them health and medical care expenses unless it is clear that the expenses are incurred exclusively to enable a person with disabilities to work.

EXHIBIT 1
City Council 5 – 290 7/15/2025

6-III.E. DISABILITY ASSISTANCE EXPENSES DEDUCTION [24 CFR 5.603(b) and 24 CFR 5.611(a)(3)(ii)]
Unreimbursed reasonable expenses for attendant care and auxiliary apparatus for each member of the family who is a person with disabilities may be deducted if they: (1) are necessary to enable a family member 18 years or older to work, (2) are not paid to a family member or reimbursed by an outside source, (3) in combination with any medical expenses, exceed ten percent of annual income, and (4) do not exceed the earned income received by the family member who is enabled to work.

Earned Income Limit on the Disability Assistance Expense Deduction A family can qualify for the disability assistance expense deduction only if at least one family member (who may be the person with disabilities) is enabled to work [24 CFR 5.603(b)].

The disability expense deduction is capped by the amount of “earned income received by family members who are 18 years of age or older and who are able to work” because of the expense [24 CFR 5.611(a)(3)(ii)]. The earned income used for this purpose is the amount verified before any earned income disallowances or income exclusions are applied.

SAHA Policy
The family must identify the family members enabled to work as a result of the disability assistance expenses. In evaluating the family’s request, SAHA will consider factors such as how the work schedule of the relevant family members relates to the hours of care provided, the time required for transportation, the relationship of the family members to the person with disabilities, and any special needs of the person with disabilities that might determine which family members are enabled to work.

When SAHA determines that the disability assistance expenses enable more than one family member to work, the expenses will be capped by the sum of the family members’ incomes.

Eligible Auxiliary Apparatus [Notice PIH 2023-27]
Auxiliary apparatus items may include expenses for wheelchairs, ramps, adaptations to vehicles, guide dogs, assistance animals, or special equipment to enable a person who is blind or has low vision to read or type or special equipment to assist a person who is deaf or hard of hearing.

EXHIBIT 1
City Council 5 – 291 7/15/2025

Eligible Attendant Care [Notice PIH 2023-27]
Examples of attendant care expenses can include teaching a person with disabilities how to perform day-to-day tasks independently like cleaning, bathing, doing laundry, and cooking.

Attendant care can be 24-hour care, or care during sporadic periods throughout the day. The family determines the type of attendant care that is appropriate for the person with disabilities.

SAHA Policy
Attendant care expenses will be included for the period that the person enabled to work is employed plus reasonable transportation time. The cost of general housekeeping and personal services is not an eligible attendant care expense. However, if the person enabled to work is the person with disabilities, personal services necessary to enable the person with disabilities to work are eligible.

If the care attendant also provides other services to the family, SAHA will prorate the cost and allow only that portion of the expenses attributable to attendant care that enables a family member to work. For example, if the care provider also cares for a child who is not the person with disabilities, the cost of care must be prorated. Unless otherwise specified by the care provider, the calculation will be based upon the number of hours spent in each activity and/or the number of persons under care.

Payments to Family Members
No disability assistance expenses may be deducted for payments to a member of an assisted family [24 CFR 5.603(b)]. However, expenses paid to a relative who is not a member of the assisted family may be deducted if they are not reimbursed by an outside source.

Necessary and Reasonable Expenses
The family determines the type of care or auxiliary apparatus to be provided and must describe how the expenses enable a family member to work. The family must certify that the disability assistance expenses are necessary and are not paid or reimbursed by any other source.

SAHA Policy
SAHA determines the reasonableness of the expenses based on typical costs of care or apparatus in the locality. To establish typical costs, SAHA will collect information from organizations that provide services and support to persons with disabilities. A family may present, and SAHA will consider, the family’s justification for costs that exceed typical costs in the area.

Families That Qualify for Both Health and Medical and Disability Assistance Expenses SAHA Policy
This policy applies only to families in which the head or spouse is 62 or older or is a person with disabilities.

When expenses anticipated by a family could be defined as either health and medical care or disability assistance expenses, SAHA will consider them health and medical care expenses unless it is clear that the expenses are incurred exclusively to enable a person with disabilities to work.

EXHIBIT 1
City Council 5 – 292 7/15/2025

6-III.F. CHILDCARE EXPENSE DEDUCTION
HUD defines childcare expenses at 24 CFR 5.603(b) as “amounts anticipated to be paid by the family for the care of children under 13 years of age (age 12 and younger) (including foster children) during the period for which annual income is computed, but only where such care is necessary to enable a family member to actively seek employment, be gainfully employed, or to further his or her education and only to the extent such amounts are not reimbursed. The amount deducted shall reflect reasonable charges for childcare. In the case of childcare necessary to permit employment, the amount deducted shall not exceed the amount of employment income that is included in annual income.”
Clarifying the Meaning of Child for This Deduction
Childcare expenses do not include child support payments made to another on behalf of a minor who is not living in an assisted family’s household [VG, p. 26]. However, childcare expenses for foster children that are living in the assisted family’s household are included when determining the family’s childcare expenses [HCV GB, p. 5-29].

Qualifying for the Deduction
Determining Who Is Enabled to Pursue an Eligible Activity SAHA Policy
The family must identify the family member(s) enabled to pursue an eligible activity. The term eligible activity in this section means any of the activities that may make the family eligible for a childcare deduction (seeking work, pursuing an education, or being gainfully employed).

In evaluating the family’s request, SAHA will consider factors such as how the schedule for the claimed activity relates to the hours of care provided, the time required for transportation, the relationship of the family member(s) to the child, and any special needs of the child that might help determine which family member is enabled to pursue an eligible activity.

Seeking Work
SAHA Policy
If the childcare expense being claimed is to enable a family member to seek employment, the family must provide evidence of the family member’s efforts to obtain employment at each reexamination. The deduction may be reduced or denied if the family member’s job search efforts are not commensurate with the childcare expense being allowed by SAHA.

EXHIBIT 1
City Council 5 – 293 7/15/2025

Furthering Education
SAHA Policy
If the childcare expense being claimed is to enable a family member to further their education, the member must be enrolled in school (academic or vocational) or participating in a formal training program. The family member is not required to be a full-time student, but the time spent in educational activities must be commensurate with the childcare claimed.

Being Gainfully Employed
SAHA Policy
If the childcare expense being claimed is to enable a family member to be gainfully employed, the family must provide evidence of the family member’s employment during the time that childcare is being provided. Gainful employment is any legal work activity (full- or part-time) for which a family member is compensated.

Earned Income Limit on Childcare Expense Deduction
When a family member looks for work or furthers their education, there is no cap on the amount that may be deducted for childcare – although the care must still be necessary and reasonable.

However, when childcare enables a family member to work, the deduction is capped by “the amount of employment income that is included in annual income” [24 CFR 5.603(b)].

The earned income used for this purpose is the amount of earned income verified after any earned income disallowances or income exclusions are applied.

The PHA must not limit the deduction to the least expensive type of childcare. If the care allows the family to pursue more than one eligible activity, including work, the cap is calculated in proportion to the amount of time spent working [HCV GB, p. 5-30].

SAHA Policy
When the childcare expense being claimed is to enable a family member to work, only one family member’s income will be considered for a given period of time. When more than one family member works during a given period, SAHA generally will limit allowable childcare expenses to the earned income of the lowest-paid member. The family may provide information that supports a request to designate another family member as the person enabled to work.

EXHIBIT 1
City Council 5 – 294 7/15/2025

Eligible Childcare Expenses
The type of care to be provided is determined by the assisted family. The PHA may not refuse to give a family the childcare expense deduction because there is an adult family member in the household that may be available to provide childcare [VG, p. 26].

Allowable Childcare Activities
SAHA Policy
For school-age children, costs attributable to public or private school activities during standard school hours are not considered. Expenses incurred for supervised activities after school or during school holidays (e.g., summer day camp, after-school sports league) are allowable forms of childcare.

The costs of general housekeeping and personal services are not eligible. Likewise, childcare expenses paid to a family member who lives in the family’s unit are not eligible; however, payments for childcare to relatives who do not live in the unit are eligible.

If a childcare provider also renders other services to a family or childcare is used to enable a family member to conduct activities that are not eligible for consideration, SAHA will prorate the costs and allow only that portion of the expenses that is attributable to childcare for eligible activities. For example, if the care provider also cares for a child with disabilities who is 13 or older, the cost of care will be prorated. Unless otherwise specified by the childcare provider, the calculation will be based upon the number of hours spent in each activity and/or the number of persons under care.

Necessary and Reasonable Costs
Childcare expenses will be considered necessary if: (1) a family adequately explains how the care enables a family member to work, actively seek employment, or further their education, and (2) the family certifies, and the childcare provider verifies, that the expenses are not paid or reimbursed by any other source.

SAHA Policy
Childcare expenses will be considered for the time required for the eligible activity plus reasonable transportation time. For childcare that enables a family member to go to school, the time allowed may include not more than one study hour for each hour spent in class.

To establish the reasonableness of childcare costs, SAHA will use the schedule of childcare costs from a qualified local entity that either subsidizes childcare costs or licenses childcare providers. Families may present, and SAHA will consider, justification for costs that exceed typical costs in the area.

EXHIBIT 1
City Council 5 – 295 7/15/2025

6-III.G. HARDSHIP EXEMPTIONS [24 CFR 5.611(c), (d), and (e)] Health and Medical Care and Disability Assistance Expenses [24 CFR 5.611(c); Notice PIH 2023-27]
The regulations provide for two types of hardship exemption categories for families that qualify for unreimbursed health and medical care expenses and/or disability assistance expenses. A family will benefit from this hardship exemption only if the family has eligible expenses that can be deducted in excess of five percent of annual income. In order to claim unreimbursed health and medical care expenses, the family must have a head, cohead, or spouse that is elderly or a person with a disability. In order to claim unreimbursed reasonable attendant care and auxiliary apparatus expenses, the family must include a person with a disability, and the expenses must enable any member of the family (including the member who is a person with a disability) to be employed.

Families may be eligible for relief under one of two categories; phased-in relief or general relief, as defined below.

Phased-In Relief
The first category is applicable to all families who received a deduction for unreimbursed health and medical care and/or reasonable attendant care or auxiliary apparatus expenses based on their most recent income review prior to January 1, 2024. The family must receive phased-in relief if they are determined to be eligible. These families will begin receiving a 24-month phased-in relief at their next annual or interim reexamination, whichever occurs first, after the date on which the PHA implements phased-in relief.

For these families, the threshold amount is phased-in as follows:
 The family is eligible for a deduction totaling the sum of expenses that exceeds 5 percent of annual income for the first 12 months.
 At the conclusion of 12 months, the family is eligible for a deduction totaling the sum of their expenses that exceed 7.5 percent of annual income for another 12 months.  At the conclusion of 24 months, the standard threshold amount of 10 percent would be used, unless the family qualifies for relief under the general hardship relief category.

When an eligible family’s phased-in relief begins at an interim reexamination, the PHA must process another transaction (either an interim reexamination or non-interim transaction, as applicable) one year later to move the family to the next phase.

Prior to the end of the 24-month period, the family may request a hardship exemption under the second category as described below. If the family is found eligible under the second category, the hardship exemption under the first category ends, and the family’s hardship is administered in accordance with the requirements listed below. Once a family requests general relief, the family may no longer receive phased-in relief.

EXHIBIT 1
City Council 5 – 296 7/15/2025

PHAs must track the 24-month phase-period for each eligible family, even if a family’s expenses go below the appropriate phase-in percentage, during the first or second 12-month phase-in period. The phase-in must continue for families who move to another housing unit at the same PHA. When the family is treated as a new admission under a different property/program (e.g., the family moves from public housing to the HCV program), unless the PHA has a written policy to continue the phased-in relief upon admission, the family’s expense deduction will be calculated using the 10-percent threshold unless request for general relief is approved by the PHA. When a family moves with continued assistance or ports to a new PHA, the family must continue to receive the phased-in relief. The family must receive the remaining calendar months of the percentage phase-in. The PHA must use the existing phase-in documentation to determine the remaining calendar months and the percentage phase-in.

SAHA Policy
SAHA will not continue the phased-in relief for families who move from public housing to HCV. These families will be treated as new admissions and the sum of expenses that exceeds 10 percent of annual income will be used to calculate their adjusted income.

General Relief
The second category is for families that can demonstrate:
 Their health and medical and/or disability assistance expenses increased (other than the transition to the higher threshold); or
 The family’s financial hardship is a result of a change in circumstances (as defined in PHA policy) that would not otherwise trigger an interim reexamination.

The family may request a hardship exemption under the second category regardless of whether the family previously received the health and medical and/or disability assistance deductions or are currently or were previously receiving relief under the phased-in relief category above. HUD requires that PHAs develop policies defining what constitutes a hardship for purposes of this exemption.

EXHIBIT 1
City Council 5 – 297 7/15/2025

The PHA must obtain third-party verification of the hardship or must document in the file the reason third-party verification was not available. PHAs must attempt to obtain third-party verification prior to the end of the 90-day hardship exemption period.

SAHA Policy
To qualify for a hardship exemption, a family must submit a request in writing. The request must show that the family’s health and medical and/or disability assistance expenses have increased (other than the transition to the higher threshold) and that the family’s financial hardship is a result of a change in circumstances. SAHA defines a change in circumstances as a decrease in income or increase in other expenses that has resulted in the family’s financial hardship but does not, on its own, trigger an interim reexamination in accordance with SAHA policies.

Examples of circumstances constituting a financial hardship may include the following situations:

The family is awaiting an eligibility determination for a federal, state, or local assistance program, such as a determination for unemployment compensation or disability benefits;
The family’s income decreased because of a loss of employment, death of a family member, or due to a natural or federal/state declared disaster; or Other circumstances as determined by SAHA.

The family must provide third-party verification of the hardship with the request. If thirdparty verification is not available, SAHA will document the file with the reason and will attempt to obtain third-party verification prior to the end of the 90-day hardship exemption period.

The PHA must promptly notify the family in writing of the change in the determination of adjusted income and the family’s rent resulting from hardship exemptions. The notice must inform the family of when the hardship exemption will begin and expire [24 CFR 5.611(e)(2)].

SAHA Policy
SAHA will make a determination of whether the family qualifies within 30 calendar days and will notify the family in writing of the result within 14 calendar days of the determination.

If SAHA denies the hardship exemption request, SAHA notice will also state that if the family does not agree with SAHA determination, the family may request a hearing.

If the family qualifies for an exemption, SAHA will include the date the hardship exemption will begin and the date it will expire as well as information on how to request a 90-day extension based on family circumstances.

If the family qualifies, the family will receive a deduction for the sum of eligible expenses that exceed five percent of annual income.

EXHIBIT 1
City Council 5 – 298 7/15/2025

The family’s hardship relief ends when the circumstances that made the family eligible for the relief are no longer applicable or after 90 days, whichever is earlier. However, the PHA may, at its discretion, extend the relief for one or more additional 90-day periods while the family’s hardship condition continues. PHAs are not limited to a maximum number of 90-day extensions.

PHAs must establish written policies regarding the types of circumstances that will allow a family to qualify for a financial hardship and when such deductions may be eligible for additional 90-day extensions. PHAs must develop policies requiring families to report if the circumstances that made the family eligible for the hardship exemption are no longer applicable.

SAHA Policy
The family may request an extension either orally or in writing prior to the end of the hardship exemption period. SAHA will extend relief for an additional 90-days if the family demonstrates to SAHA’s satisfaction that the family continues to qualify for the hardship exemption based on circumstances described above. SAHA will require updated verification based on the family’s current circumstances. Additional extension(s) may be granted on a case-by-case basis provided the family continues to request extensions prior to the end of each hardship exemption period. Families must report if the circumstances that made the family eligible for the hardship exemption are no longer applicable. At any time, SAHA may terminate the hardship exemption if SAHA determines that the family no longer qualifies for the exemption.

Childcare Expense Hardship Exemption [24 CFR 5.611(d) and Notice PIH 2023-27] A family whose eligibility for the childcare expense deduction is ending may request a financial hardship exemption to continue receiving the deduction. If the family demonstrates to the PHA’s satisfaction that the family is unable to pay their rent because of the loss of the childcare expense deduction, and that the childcare expense is still necessary even though the family member is not working, looking for work, or seeking to further their education, the PHA must recalculate the family’s adjusted income and continue the childcare deduction.

The PHA must develop a policy to define what constitutes a hardship, which includes the family’s inability to pay rent. The PHA must obtain third-party verification of the hardship or must document in the file the reason third-party verification was not available. PHAs must attempt to obtain third-party verification prior to the end of the 90-day hardship exemption period.

EXHIBIT 1
City Council 5 – 299 7/15/2025

SAHA Policy
For a family to qualify, they must demonstrate that their inability to pay rent would be as a result of the loss of this deduction. SAHA defines this hardship as a potential decrease in income or increase in other expenses that would result from the loss of the childcare expense and such loss would impact the family’s ability to pay their rent.

Some factors to consider when determining if the family is unable to pay rent may include determining that the rent, utility payment, and applicable expenses (childcare expenses or health and medical expenses) are more than 40 percent of the family’s adjusted income, or verifying whether the family has experienced unanticipated expenses, such as large medical bills, that have affected their ability to pay their rent.

The family must also demonstrate that the childcare expense is still necessary even though the family member is no longer employed or furthering their education. SAHA will consider qualification under this criterion on a case-by case basis.

The family must provide third-party verification of the hardship with the request. If thirdparty verification is not available, SAHA will document the file with the reason and will attempt to obtain third-party verification prior to the end of the 90-day hardship exemption period.

The PHA must promptly notify the family in writing of the change in the determination of adjusted income and the family’s rent resulting from hardship exemptions.

If the PHA denies the request, the notice must specifically state the reason for the denial. PHAs must provide families 30 days’ notice of any increase in rent.

If the PHA approves the request, the notice must inform the family of when the hardship exemption will begin and expire [24 CFR 5.611(e)(2)]. The notice must also state the requirement for the family to report to the PHA if the circumstances that made the family eligible for relief are no longer applicable and that the family’s adjusted income and tenant rent will be recalculated upon expiration of the hardship exemption [Notice PIH 2023-27].

SAHA Policy
SAHA will make a determination of whether the family qualifies within 30 calendar days and will notify the family in writing of the result.

If SAHA denies the hardship exemption request, SAHA notice will also state that if the family does not agree with SAHA determination, the family may request an informal hearing.

EXHIBIT 1
City Council 5 – 300 7/15/2025

If the family qualifies, the hardship exemption and the resulting alternative adjusted income calculation must remain in place for a period of up to 90 days.

The PHA may, at its discretion, extend the hardship exemptions for additional 90-day periods based on family circumstances and as stated in PHA policies. PHAs are not limited to a maximum number of 90-day extensions. PHAs must develop policies requiring families to report if the circumstances that made the family eligible for the hardship exemption are no longer applicable.

PHAs must promptly notify families in writing if they are denied either an initial hardship exemption or an additional 90-day extension of the exemption. If the PHA denies the request, the notice must specifically state the reason for the denial.

PHAs must notify the family if the hardship exemption is no longer necessary and the hardship exemption will be terminated because the circumstances that made the family eligible for the exemption are no longer applicable. The notice must state the termination date and provide 30 days’ notice of rent increase, if applicable.

SAHA Policy
SAHA will not offer an additional 90-day extension of the Childcare Expense Hardship Exemption.

EXHIBIT 1
City Council 5 – 301 7/15/2025

6-III.H. PERMISSIVE DEDUCTIONS [24 CFR 5.611(b)(1)(ii)] The PHA may adopt additional permissive deductions from annual income if they establish a policy in the administrative plan. Permissive deductions are additional, optional deductions that may be applied to annual income. As with mandatory deductions, permissive deductions must be based on need or family circumstance and deductions must be designed to encourage selfsufficiency or other economic purpose. If the PHA offers permissive deductions, they must be granted to all families that qualify for them and should complement existing income exclusions and deductions [PH Occ GB, p. 128]. Permissive deductions may be used to incentivize or encourage self-sufficiency and economic mobility.

A PHA that adopts such deductions must have sufficient funding to cover the increased housing assistance payment cost of the deductions. A PHA will not be eligible for an increase in HCV renewal funding for subsidy costs resulting from such deductions.

SAHA Policy
SAHA has opted not to use permissive deductions.

EXHIBIT 1
City Council 5 – 302 7/15/2025

PART IV: CALCULATING FAMILY SHARE AND PHA SUBSIDY
6-IV.A. OVERVIEW OF RENT AND SUBSIDY CALCULATIONS
TTP Formula [24 CFR 5.628]
HUD regulations specify the formula for calculating the total tenant payment (TTP) for an assisted family. TTP is the highest of the following amounts, rounded to the nearest dollar:
 30 percent of the family’s monthly adjusted income (adjusted income is defined in Part II)  10 percent of the family’s monthly gross income (annual income, as defined in Part I, divided by 12)
 The welfare rent (in as-paid states only)
 A minimum rent between $0 and $50 that is established by the PHA The PHA has authority to suspend and exempt families from minimum rent when a financial hardship exists, as defined in section 6-IV.B.

The amount that a family pays for rent and utilities (the family share) will never be less than the family’s TTP but may be greater than the TTP depending on the rent charged for the unit the family selects.

Welfare Rent [24 CFR 5.628]
SAHA Policy
Welfare rent does not apply in this locality.

Minimum Rent [24 CFR 5.630]
SAHA Policy
The minimum rent established by SAHA is $50.

Family Share [24 CFR 982.305(a)(5)]
If a family chooses a unit with a gross rent (rent to owner plus an allowance for tenant-paid utilities) that exceeds the PHA’s applicable payment standard: (1) the family will pay more than the TTP, and (2) at initial occupancy the PHA may not approve the tenancy if it would require the family share to exceed 40 percent of the family’s monthly adjusted income. (For a discussion of the application of payment standards, see section 6-IV.C.) EXHIBIT 1
City Council 5 – 303 7/15/2025

PHA Subsidy [24 CFR 982.505(b)]
The PHA will pay a monthly housing assistance payment (HAP) for a family that is equal to the lower of (1) the applicable payment standard for the family minus the family’s TTP or (2) the gross rent for the family’s unit minus the TTP. (For a discussion of the application of payment standards, see section 6-IV.C.)
Utility Reimbursement [24 CFR 982.514(b); 982.514(c)]
When the PHA subsidy for a family exceeds the rent to owner, the family is due a utility reimbursement. HUD permits the PHA to pay the reimbursement to the family or directly to the utility provider.

SAHA Policy
SAHA will make utility reimbursements to the family.

The PHA may make all utility reimbursement payments to qualifying families on a monthly basis or may make quarterly payments when the monthly reimbursement amount is $15.00 or less. Reimbursements must be made once per calendar-year quarter and must be prorated if the family leaves the program in advance of its next quarterly reimbursement. The PHA must also adopt hardship policies for families for whom receiving quarterly reimbursement would create a financial hardship.

SAHA Policy
SAHA will issue all utility reimbursements monthly. SAHA reserves the right to issue utility reimbursements quarterly.

EXHIBIT 1
City Council 5 – 304 7/15/2025

6-IV.B. FINANCIAL HARDSHIPS AFFECTING MINIMUM RENT [24 CFR 5.630] SAHA Policy
The financial hardship rules described below apply because SAHA has established a minimum rent of $50.

Overview
If the PHA establishes a minimum rent greater than zero, the PHA must grant an exemption from the minimum rent if a family is unable to pay the minimum rent because of financial hardship.

The financial hardship exemption applies only to families required to pay the minimum rent. If a family’s TTP is higher than the minimum rent, the family is not eligible for a hardship exemption. If the PHA determines that a hardship exists, the family share is the highest of the remaining components of the family’s calculated TTP.

HUD-Defined Financial Hardship
Financial hardship includes the following situations:
(1) The family has lost eligibility for or is awaiting an eligibility determination for a federal, state, or local assistance program. This includes a family member who is a noncitizen lawfully admitted for permanent residence under the Immigration and Nationality Act who would be entitled to public benefits but for Title IV of the Personal Responsibility and Work Opportunity Act of 1996.

SAHA Policy
A hardship will be considered to exist only if the loss of eligibility has an impact on the family’s ability to pay the minimum rent.

For a family waiting for a determination of eligibility, the hardship period will end as of the first of the month following: (1) implementation of assistance, if approved, or (2) the decision to deny assistance. A family whose request for assistance is denied may request a hardship exemption based upon one of the other allowable hardship circumstances. (2) The family would be evicted because it is unable to pay the minimum rent.

SAHA Policy
For a family to qualify under this provision, the cause of the potential eviction must be the family’s failure to pay rent to the owner or tenant-paid utilities. (3) Family income has decreased because of changed family circumstances, including the loss of employment.

EXHIBIT 1
City Council 5 – 305 7/15/2025

(4) A death has occurred in the family.

SAHA Policy
In order to qualify under this provision, a family must describe how the death has created a financial hardship (e.g., because of funeral-related expenses or the loss of the family member’s income).
(5) The family has experienced other circumstances determined by the PHA.

SAHA Policy
SAHA has not established any additional hardship criteria.

Implementation of Hardship Exemption
Determination of Hardship
When a family requests a financial hardship exemption, the PHA must suspend the minimum rent requirement beginning the first of the month following the family’s request.

The PHA then determines whether the financial hardship exists and whether the hardship is temporary or long-term.

SAHA Policy
SAHA defines temporary hardship as a hardship expected to last 90 days or less. Longterm hardship is defined as a hardship expected to last more than 90 days.

When the minimum rent is suspended, the family share reverts to the highest of the remaining components of the calculated TTP. The example below demonstrates the effect of the minimum rent exemption.

Example: Impact of Minimum Rent Exemption
Assume the PHA has established a minimum rent of $50.

Family Share – No Hardship Family Share – With Hardship $0
$15
N/A
$50
30% of monthly adjusted income
10% of monthly gross income
Welfare rent
Minimum rent
$0
$15
N/A
$50
30% of monthly adjusted income
10% of monthly gross income
Welfare rent
Minimum rent
Minimum rent applies.

TTP = $50
Hardship exemption granted.

TTP = $15
SAHA Policy
To qualify for a hardship exemption, a family must submit a request for a hardship exemption in writing. The request must explain the nature of the hardship and how the hardship has affected the family’s ability to pay the minimum rent.

SAHA will make the determination of hardship within 30 calendar days.

EXHIBIT 1
City Council 5 – 306 7/15/2025

No Financial Hardship
If the PHA determines there is no financial hardship, the PHA will reinstate the minimum rent and require the family to repay the amounts suspended.

SAHA Policy
SAHA will require the family to repay the suspended amount within 30 calendar days of SAHA’s notice that a hardship exemption has not been granted.

Temporary Hardship
If the PHA determines that a qualifying financial hardship is temporary, the PHA must suspend the minimum rent for the 90-day period beginning the first of the month following the date of the family’s request for a hardship exemption.

At the end of the 90-day suspension period, the family must resume payment of the minimum rent and must repay the PHA the amounts suspended. HUD requires the PHA to offer a reasonable repayment agreement, on terms and conditions established by the PHA. The PHA also may determine that circumstances have changed and the hardship is now a long-term hardship.

SAHA Policy
SAHA will enter into a repayment agreement in accordance with the procedures found in Chapter 16 of this plan.

Long-Term Hardship
If the PHA determines that the financial hardship is long-term, the PHA must exempt the family from the minimum rent requirement for so long as the hardship continues. The exemption will apply from the first of the month following the family’s request until the end of the qualifying hardship. When the financial hardship has been determined to be long-term, the family is not required to repay the minimum rent.

SAHA Policy
The hardship period ends when any of the following circumstances apply:
(1) At an interim or annual reexamination, the family’s calculated TTP is greater than the minimum rent.
(2) For hardship conditions based on loss of income, the hardship condition will continue to be recognized until new sources of income are received that are at least equal to the amount lost. For example, if a hardship is approved because a family no longer receives a $60/month child support payment, the hardship will continue to exist until the family receives at least $60/month in income from another source or once again begins to receive the child support.
(3) For hardship conditions based upon hardship-related expenses, the minimum rent exemption will continue to be recognized until the cumulative amount exempted is equal to the expense incurred.

EXHIBIT 1
City Council 5 – 307 7/15/2025

6-IV.C. APPLYING PAYMENT STANDARDS [24 CFR 982.505(c) and Notice PIH 2024-34]
Overview
The PHA’s schedule of payment standards is used to calculate housing assistance payments for HCV families. This section covers the application of the PHA’s payment standards. The establishment and revision of the PHA’s payment standard schedule are covered in Chapter 16.

Payment standard is defined as “the maximum monthly assistance payment for a family assisted in the voucher program (before deducting the total tenant payment by the family)” [24 CFR 982.4(b)].

The payment standard for a family is the lower of (1) the payment standard for the family unit size, which is defined as the appropriate number of bedrooms for the family under the PHA’s subsidy standards [24 CFR 982.4(b)], or (2) the payment standard for the size of the dwelling unit rented by the family [24 CFR 982.505(c)(1)].

If the PHA has established an exception payment standard for a designated part of a an FMR area in accordance with 24 CFR 982.503 and a family’s unit is located in the designated area, the PHA must use the appropriate payment standard for the exception area [24 CFR 982.505(c)(2)].

The PHA is required to pay a monthly housing assistance payment (HAP) for a family that is the lower of (1) the payment standard for the family minus the family’s TTP or (2) the gross rent for the family’s unit minus the TTP.

If during the term of the HAP contract for a family’s unit, the owner lowers the rent, the PHA will recalculate the HAP using the lower of the initial payment standard or the gross rent for the unit [HCV GB, p. 7-8].

Changes in Payment Standards
When the PHA revises its payment standards during the term of the HAP contract for a family’s unit, it will apply the new payment standards in accordance with HUD regulations. Regulations governing increases and decreases in the payment standard have changed, with a required compliance date of December 3, 2024.

Decreases [24 CFR 982.505(c)(3) and Notice PIH 2024-34] For new HAP contracts, the PHA applies the payment standard in effect at the time of HAP contract execution.

The PHA must administer decreases in the payment standard amount for the family in accordance with the PHA policy as described in the administrative plan and apply the policy consistently to all families.

If a PHA changes its payment standard schedule, resulting in a lower payment standard amount, during the term of a HAP contract, the PHA is not required to reduce the payment standard used to calculate subsidy for families under HAP contract as long as the HAP contract remains in effect. The PHA must administer decreases in the payment standard amount for the family in accordance with the PHA policy as described in the administrative plan.

EXHIBIT 1
City Council 5 – 308 7/15/2025

Changes effective 12/2/24 and earlier: If the PHA does choose to reduce the payment standard for families currently under HAP contract, the initial reduction to the payment standard may not be applied any earlier than the effective date of the family’s second regular reexamination following the effective date of the decrease in the payment standard amount.

Changes effective 12/3/24 and later: If the PHA does choose to reduce the payment standard for families currently under HAP contract, the initial reduction to the payment standard may not be applied any earlier than two years following the effective date of the decrease in the payment standard and only with proper written notice to the family in accordance with 24 CFR 982.505(c)(3)(iii).

At that point, the PHA may either reduce the payment standard to the current amount in effect on the PHA’s payment standard schedule or may reduce the payment standard to another amount that is higher than the normally applicable amount on the schedule. The PHA may also establish different policies for designated areas within their jurisdiction (e.g., different zip code areas). In any case, the PHA must provide the family with at least 12 months’ notice that the payment standard is being reduced before the effective date of the change. In the written notice, the PHA must state the new payment standard amount, explain that the family’s new payment standard amount will be the greater of the amount listed in the current written notice or the new amount (if any) on the PHA’s payment standard schedule at the end of the 12-month period, and make clear where the family will find the PHA’s payment standard schedule. The PHA’s policy on decreases in the payment standard during the term of the HAP contract apply to all families under HAP contract at the time of the effective date of the decrease in the payment standard within the designated area.

SAHA Policy
If SAHA changes its payment standard schedule resulting in a lower payment standard amount, during the term of a HAP contract, SAHA will apply the reduced payment standard at the family’s second regular reexamination following the reduction in the payment standard amount..

Increases [24 CFR 982.505(c)(4) and Notice PIH 2024-34] For new HAP contracts, the PHA applies the payment standard in effect at the time of HAP contract execution.

Changes effective 12/2/24 and earlier: If the payment standard is increased during the term of the HAP contract, the increased payment standard will be used to calculate the monthly housing assistance payment for the family beginning on the effective date of the family’s first regular reexamination on or after the effective date of the increase in the payment standard.

Families requiring or requesting interim reexaminations will not have their HAP payments calculated using the higher payment standard until their next annual reexamination [HCV GB, p. 7-8].

EXHIBIT 1
City Council 5 – 309 7/15/2025

Changes effective 12/3/24 and later: If the payment standard is increased during the term of the HAP contract, the increased payment standard will be applied no later than the earliest of:
 The effective date of an increase in the gross rent that would result in an increase in the family share;
 The family’s first regular or interim reexamination; or  One year following the effective date of the increase in the payment standard amount.

The PHA may adopt a policy to apply a payment standard increase at any time earlier than the date calculated above as long as the policy is included in the administrative plan and applied consistently to all families [24 CFR 982.505(c)(5)].

SAHA Policy
SAHA will not adopt payment standard increases earlier than the date required by the regulations.

Changes in Family Unit Size (Voucher Size) [24 CFR 982.505(c)(6) and Notice PIH 2024-34] Changes effective 12/2/24 and earlier: Irrespective of any increase or decrease in the payment standard, if the family unit size increases or decreases during the HAP contract term, the new family unit size must be used to determine the payment standard for the family beginning at the family’s first regular reexamination following the change in family unit size.

Changes effective 12/3/24 and later: Irrespective of any increase or decrease in the payment standard, if the family unit size increases or decreases during the HAP contract term, the new family unit size may be used to determine the payment standard immediately but no later than the family’s first regular reexamination following the change in family unit size.

SAHA Policy
If the family unit size (voucher size) changes during the term of a HAP contract, the new family unit size will be used to determine the payment standard at the family’s first regular reexamination following the change in family unit size.

Moves
If the family moves to a new unit, or a new HAP contract is executed due to changes in the lease (even if the family remains in place) the current payment standard applicable to the family will be used when the new HAP contract is processed.

Reasonable Accommodation [24 CFR 982.503(d)(5)]
If a family requires a higher payment standard as a reasonable accommodation for a family member who is a person with disabilities, the PHA is allowed to establish a higher payment standard for the family of not more than 120 percent of the published FMR without HUD approval or prior notification to HUD. A PHA may establish a payment standard greater than 120 percent of the applicable FMR as a reasonable accommodation in accordance with 24 CFR part 8, after requesting and receiving HUD approval. See Chapter 16 for more information.

EXHIBIT 1
City Council 5 – 310 7/15/2025

6-IV.D. APPLYING UTILITY ALLOWANCES [24 CFR 982.517]
Overview
A PHA-established utility allowance schedule is used in determining family share and PHA subsidy. A family’s utility allowance is determined by the size of dwelling unit leased by a family or the voucher unit size for which the family qualifies using PHA subsidy standards, whichever is the lowest of the two. See Chapter 5 for information on the PHA’s subsidy standards.

For policies on establishing and updating utility allowances, see Chapter 16.

Flat Fees [24 CFR 982.517(b)(2)(iii)]
The PHA may base its utility allowance payments on actual flat fees charged by an owner for utilities that are billed directly by the owner, but only if the flat fee charged by the owner is no greater than the PHA’s applicable utility allowance for the utilities covered by the fee. If the owner charges a flat fee for some but not all utilities, the PHA must pay a separate allowance for any tenant-paid utilities not covered in the flat fee.

SAHA Policy
SAHA will not base utility allowance payments on flat fees charged by the owner.

PBV Developments [24 CFR 982.517(b)(2)(iv)]
If a tenant-based voucher holder resides in a project with project-based voucher (PBV) units and the PBV units use a site-specific utility allowance in accordance with PBV regulations, the PHA must use the project-specific utility allowance schedule.

Reasonable Accommodation and Individual Relief
On request from a family that includes a person with disabilities, the PHA must approve a utility allowance which is higher than the applicable amount on the utility allowance schedule if a higher utility allowance is needed as a reasonable accommodation to make the program accessible and usable by the family member with a disability [24 CFR 982.517(e)]. (See Chapter 2 for policies regarding the request and approval of reasonable accommodations.) Further, the PHA may grant requests for individual relief from charges in excess of the utility allowance on reasonable grounds, such as special factors not within control of the resident, as the PHA deems appropriate. The family must request the higher allowance and provide the PHA an explanation of the need for individual relief and an explanation about the amount of additional allowance required [see HCV GB, p. 18-8].

PHAs should develop criteria for granting individual relief, notify residents about the availability of individual relief, and notify participants about the availability of individual relief programs (sometimes referred to as “Medical Baseline discounts”) offered by the local utility company.

EXHIBIT 1
City Council 5 – 311 7/15/2025

SAHA Policy
The family must request the higher allowance and provide SAHA with information about the amount of additional allowance required.

SAHA will consider the following criteria as valid reasons for granting individual relief:

The family’s consumption was mistakenly portrayed as excessive due to defects in the meter or errors in the meter reading.

The excessive consumption is caused by a characteristic of the unit or ownersupplied equipment that is beyond the family’s control, such as a particularly inefficient refrigerator or inadequate insulation. The allowance should be adjusted to reflect the higher consumption needs associated with the unit until the situation is remedied. The resident should be granted individual relief until the allowance is adjusted.

The excessive consumption is due to special needs of the family that are beyond their control, such as the need for specialized equipment in the case of a family member who is ill, elderly, or who has a disability.

In determining the amount of the reasonable accommodation or individual relief, SAHA will allow a reasonable measure of additional usage as necessary. To arrive at the amount of additional utility cost of specific equipment, the family may provide information from the manufacturer of the equipment, or the family or SAHA may conduct an internet search for an estimate of usage or additional monthly cost.

Information on reasonable accommodation and individual relief for charges in excess of the utility allowance will be provided to all families at admission as part of the information on payment standards and utility allowances in the briefing packet. SAHA will also provide information on utility relief programs or medical discounts (sometimes referred to as “Medical Baseline discounts”) that may be available through local utility providers.

At its discretion, SAHA may reevaluate the need for the increased utility allowance at any regular reexamination.

If the excessive consumption is caused by a characteristic of the unit or SAHA-supplied equipment that is beyond the family’s control, such as a particularly inefficient refrigerator or inadequate insulation, the individual relief to the resident will cease when the situation is remedied.

Utility Allowance Revisions
At reexamination, the PHA must use the current utility allowance schedule [HCV GB, p. 18-8].

SAHA Policy
Revised utility allowances will be applied to a family’s rent and subsidy calculations at the first annual reexamination that is effective after the allowance is adopted.

EXHIBIT 1
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6-IV.E. PRORATED ASSISTANCE FOR MIXED FAMILIES [24 CFR 5.520] HUD regulations prohibit assistance to ineligible family members. A mixed family is one that includes at least one U.S. citizen or eligible immigrant and any number of ineligible family members. The PHA must prorate the assistance provided to a mixed family. The PHA will first determine assistance as if all family members were eligible and then prorate the assistance based upon the percentage of family members that actually are eligible. For example, if the PHA subsidy for a family is calculated at $500 and two of four family members are ineligible, the PHA subsidy would be reduced to $250.

EXHIBIT 1
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EXHIBIT 1
City Council 5 – 314 7/15/2025

EXHIBIT 6-1: ANNUAL INCOME FULL DEFINITION
24 CFR 5.609
(a) Annual income includes, with respect to
the family:
(1) All amounts, not specifically excluded in
paragraph (b) of this section, received from all
sources by each member of the family who is
18 years of age or older or is the head of
household or spouse of the head of household,
plus unearned income by or on behalf of each
dependent who is under 18 years of age, and
(2) When the value of net family assets
exceeds the HUD-published threshold amount
(which amount HUD will adjust annually in
accordance with the Consumer Price Index for
Urban Wage Earners and Clerical Workers)
and the actual returns from a given asset
cannot be calculated, imputed returns on the
asset based on the current passbook savings
rate, as determined by HUD.
(b)Annual income does not include the following:
(1) Any imputed return on an asset when net
family assets are less than or equal to the
HUD-published threshold amount (which
amount HUD will adjust annually in
accordance with the Consumer Price Index for
Urban Wage Earners and Clerical Workers)
and no actual income from the net family
assets can be determined.
(2) The following types of trust distributions:
(i) For an irrevocable trust or a revocable trust
outside the control of the family or household
excluded from the definition of net family
assets under § 5.603(b):
(A) Distributions of the principal or corpus of
the trust; and
(B) Distributions of income from the trust
when the distributions are used to pay the costs
of health and medical care expenses for a
minor.
(ii) For a revocable trust under the control of
the family or household, any distributions
from the trust; except that any actual income
earned by the trust, regardless of whether it is
distributed, shall be considered income to the
family at the time it is received by the trust.
(3) Earned income of children under the 18
years of age.
(4) Payments received for the care of foster
children or foster adults, or State or Tribal
kinship or guardianship care payments.
(5) Insurance payments and settlements for
personal or property losses, including but not
limited to payments through health insurance,
motor vehicle insurance, and workers’
compensation.
(6) Amounts received by the family that are
specifically for, or in reimbursement of, the
cost of health and medical care expenses for
any family member.
(7) Any amounts recovered in any civil action
or settlement based on a claim of malpractice,
negligence, or other breach of duty owed to a
family member arising out of law, that resulted
in a member of the family becoming disabled.
(8) Income of a live-in aide, foster child, or
foster adult as defined in §§ 5.403 and 5.603,
respectively.
(9)
(i) Any assistance that section 479B of the
Higher Education Act of 1965, as amended (20
U.S.C. 1087uu), requires be excluded from a
family’s income; and
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(ii) Student financial assistance for tuition,
books, and supplies (including supplies and
equipment to support students with learning
disabilities or other disabilities), room and
board, and other fees required and charged to a
student by an institution of higher education
(as defined under Section 102 of the Higher
Education Act of 1965 (20 U.S.C. 1002)) and,
for a student who is not the head of household
or spouse, the reasonable and actual costs of
housing while attending the institution of
higher education and not residing in an
assisted unit.
(A) Student financial assistance, for purposes
of this paragraph (9)(ii), means a grant or
scholarship received from— (
1) The Federal government;
(2) A State, Tribe, or local government;
(3) A private foundation registered as a
nonprofit under 26 U.S.C. 501(c)(3);
(4) A business entity (such as corporation,
general partnership, limited liability company,
limited partnership, joint venture, business
trust, public benefit corporation, or nonprofit
entity); or
(5) An institution of higher education.
(B) Student financial assistance, for purposes
of this paragraph (9)(ii), does not include—
(1) Any assistance that is excluded pursuant to
paragraph (b)(9)(i) of this section;
(2) Financial support provided to the student in
the form of a fee for services performed (e.g.,
a work study or teaching fellowship that is not
excluded pursuant to paragraph (b)(9)(i) of this
section); (
3) Gifts, including gifts from family or friends;
or
(4) Any amount of the scholarship or grant
that, either by itself or in combination with
assistance excluded under this paragraph or
paragraph (b)(9)(i), exceeds the actual covered
costs of the student. The actual covered costs
of the student are the actual costs of tuition,
books and supplies (including supplies and
equipment to support students with learning
disabilities or other disabilities), room and
board, or other fees required and charged to a
student by the education institution, and, for a
student who is not the head of household or
spouse, the reasonable and actual costs of
housing while attending the institution of
higher education and not residing in an
assisted unit. This calculation is described
further in paragraph (b)(9)(ii)€ of this section.
(C) Student financial assistance, for purposes
of this paragraph (b)(9)(ii) must be:
(1) Expressly for tuition, books, room and
board, or other fees required and charged to a
student by the education institution;
(2) Expressly to assist a student with the costs
of higher education; or
(3) Expressly to assist a student who is not the
head of household or spouse with the
reasonable and actual costs of housing while
attending the education institution and not
residing in an assisted unit.
(D) Student financial assistance, for purposes
of this paragraph (b)(9)(ii), may be paid
directly to the student or to the educational
institution on the student’s behalf. Student
financial assistance paid to the student must be
verified by the responsible entity as student
financial assistance consistent with this
paragraph (b)(9)(ii).
(E) When the student is also receiving
assistance excluded under paragraph (b)(9)(i)
of this section, the amount of student financial
assistance under this paragraph (b)(9)(ii) is
determined as follows:

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(1) If the amount of assistance excluded under
paragraph (b)(9)(i) of this section is equal to or
exceeds the actual covered costs under
paragraph (b)(9)(ii)(B)(4) of this section, none
of the assistance described in this paragraph
(b)(9)(ii) of this section is considered student
financial assistance excluded from income
under this paragraph (b)(9)(ii)(E).
(2) If the amount of assistance excluded under
paragraph (b)(9)(i) of this section is less than
the actual covered costs under paragraph
(b)(9)(ii)(B)(4) of this section, the amount of
assistance described in paragraph (b)(9)(ii) of
this section that is considered student financial
assistance excluded under this paragraph is the
lower of:
(i) the total amount of student financial
assistance received under this paragraph
(b)(9)(ii) of this section, or
(ii) the amount by which the actual covered
costs under paragraph (b)(9)(ii)(B)(4) of this
section exceeds the assistance excluded under
paragraph (b)(9)(i) of this section.
(10) Income and distributions from any
Coverdell education savings account under
section 530 of the Internal Revenue Code of
1986 or any qualified tuition program under
section 529 of such Code; and income earned
by government contributions to, and
distributions from, “baby bond” accounts
created, authorized, or funded by Federal,
State, or local government.
(11) The special pay to a family member
serving in the Armed Forces who is exposed to
hostile fire.
(12)
(i) Amounts received by a person with a
disability that are disregarded for a limited
time for purposes of Supplemental Security
Income eligibility and benefits because they
are set aside for use under a Plan to Attain
Self-Sufficiency (PASS);
(ii) Amounts received by a participant in other
publicly assisted programs which are
specifically for or in reimbursement of out-ofpocket expenses incurred (e.g., special equipment, clothing, transportation, childcare,
etc.) and which are made solely to allow
participation in a specific program;
(iii) Amounts received under a resident service
stipend not to exceed $200 per month. A
resident service stipend is a modest amount
received by a resident for performing a service
for the PHA or owner, on a part-time basis,
that enhances the quality of life in the
development.
(iv) Incremental earnings and benefits
resulting to any family member from
participation in training programs funded by
HUD or in qualifying Federal, State, Tribal, or
local employment training programs
(including training programs not affiliated
with a local government) and training of a
family member as resident management staff.

Amounts excluded by this provision must be
received under employment training programs
with clearly defined goals and objectives and
are excluded only for the period during which
the family member participates in the
employment training program unless those
amounts are excluded under paragraph
(b)(9)(i) of this section.
(13) Reparation payments paid by a foreign
government pursuant to claims filed under the
laws of that government by persons who were
persecuted during the Nazi era.
(14) Earned income of dependent fulltime
students in excess of the amount of the
deduction for a dependent in § 5.611.
(15) Adoption assistance payments for a child
in excess of the amount of the deduction for a
dependent in § 5.611.

EXHIBIT 1
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(16) Deferred periodic amounts from
Supplemental Security Income and Social
Security benefits that are received in a lump
sum amount or in prospective monthly
amounts, or any deferred Department of
Veterans Affairs disability benefits that are
received in a lump sum amount or in
prospective monthly amounts.
(17) Payments related to aid and attendance
under 38 U.S.C. 1521 to veterans in need of
regular aid and attendance.
(18) Amounts received by the family in the
form of refunds or rebates under State or local
law for property taxes paid on the dwelling
unit.
(19) Payments made by or authorized by a
State Medicaid agency (including through a
managed care entity) or other State or Federal
agency to a family to enable a family member
who has a disability to reside in the family’s
assisted unit. Authorized payments may
include payments to a member of the assisted
family through the State Medicaid agency
(including through a managed care entity) or
other State or Federal agency for caregiving
services the family member provides to enable
a family member who has a disability to reside
in the family’s assisted unit.
(20) Loan proceeds (the net amount disbursed
by a lender to or on behalf of a borrower,
under the terms of a loan agreement) received
by the family or a third party (e.g., proceeds
received by the family from a private loan to
enable attendance at an educational institution
or to finance the purchase of a car).
(21) Payments received by Tribal members as
a result of claims relating to the
mismanagement of assets held in trust by the
United States, to the extent such payments are
also excluded from gross income under the
Internal Revenue Code or other Federal law.
(22) Amounts that HUD is required by Federal
statute to exclude from consideration as
income for purposes of determining eligibility
or benefits under a category of assistance
programs that includes assistance under any
program to which the exclusions set forth in
paragraph (b) of this section apply. HUD will
publish a notice in the Federal Register to
identify the benefits that qualify for this
exclusion. Updates will be published when
necessary.
(23) Replacement housing “gap” payments
made in accordance with 49 CFR part 24 that
offset increased out of pocket costs of
displaced persons that move from one
federally subsidized housing unit to another
Federally subsidized housing unit. Such
replacement housing “gap” payments are not
excluded from annual income if the increased
cost of rent and utilities is subsequently
reduced or eliminated, and the displaced
person retains or continues to receive the
replacement housing “gap” payments.
(24) Nonrecurring income, which is income
that will not be repeated in the coming year
based on information provided by the family.

Income received as an independent contractor,
day laborer, or seasonal worker is not excluded
from income under this paragraph, even if the
source, date, or amount of the income varies.

Nonrecurring income includes:
(i) Payments from the U.S. Census Bureau for
employment (relating to decennial census or
the American Community Survey) lasting no
longer than 180 days and not culminating in
permanent employment.
(ii) Direct Federal or State payments intended
for economic stimulus or recovery.
(iii) Amounts directly received by the family
as a result of State refundable tax credits or
State tax refunds at the time they are received.

EXHIBIT 1
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(iv) Amounts directly received by the family
as a result of Federal refundable tax credits
and Federal tax refunds at the time they are
received.
(v) Gifts for holidays, birthdays, or other
significant life events or milestones (e.g.,
wedding gifts, baby showers, anniversaries).
(vi) Non-monetary, in-kind donations, such as
food, clothing, or toiletries, received from a
food bank or similar organization.
(vii) Lump-sum additions to net family assets,
including but not limited to lottery or other
contest winnings.
(25) Civil rights settlements or judgments,
including settlements or judgments for back
pay.
(26) Income received from any account under
a retirement plan recognized as such by the
Internal Revenue Service, including individual
retirement arrangements (IRAs), employer
retirement plans, and retirement plans for selfemployed individuals; except that any distribution of periodic payments from such
accounts shall be income at the time they are
received by the family.
(27) Income earned on amounts placed in a
family’s Family Self Sufficiency Account.
(28) Gross income a family member receives
through self-employment or operation of a
business; except that the following shall be
considered income to a family member:
(i) Net income from the operation of a
business or profession. Expenditures for
business expansion or amortization of capital
indebtedness shall not be used as deductions in
determining net income. An allowance for
depreciation of assets used in a business or
profession may be deducted, based on straight
line depreciation, as provided in Internal
Revenue Service regulations; and
(ii) Any withdrawal of cash or assets from the
operation of a business or profession will be
included in income, except to the extent the
withdrawal is reimbursement of cash or assets
invested in the operation by the family.

EXHIBIT 1
City Council 5 – 319 7/15/2025

EXHIBIT 6-2: TREATMENT OF FAMILY ASSETS
24 CFR 5.603(b) Net Family Assets
(1) Net family assets is the net cash value of
all assets owned by the family, after
deducting reasonable costs that would be
incurred in disposing real property, savings,
stocks, bonds, and other forms of capital
investment.
(2) In determining net family assets, PHAs
or owners, as applicable, must include the
value of any business or family assets
disposed of by an applicant or tenant for less
than fair market value (including a
disposition in trust, but not in a foreclosure
or bankruptcy sale) during the two years
preceding the date of application for the
program or reexamination, as applicable, in
excess of the consideration received
therefor. In the case of a disposition as part
of a separation or divorce settlement, the
disposition will not be considered to be for
less than fair market value if the applicant or
tenant receives consideration not measurable
in dollar terms. Negative equity in real
property or other investments does not
prohibit the owner from selling the property
or other investments, so negative equity
alone would not justify excluding the
property or other investments from family
assets.
(3) Excluded from the calculation of net
family assets are: (i) The value of necessary
items of personal property; (ii) The
combined value of all nonnecessary items of
personal property if the combined total value
does not exceed the HUD-published
threshold amount (which amount will be
adjusted by HUD in accordance with the
Consumer Price Index for Urban Wage
Earners and Clerical Workers); (iii) The
value of any account under a retirement plan
recognized as such by the Internal Revenue
Service, including individual retirement
arrangements (IRAs), employer retirement
plans, and retirement plans for selfemployed individuals; (iv) The value of real property that the family does not have the
effective legal authority to sell in the
jurisdiction in which the property is located;
(v) Any amounts recovered in any civil
action or settlement based on a claim of
malpractice, negligence, or other breach of
duty owed to a family member arising out of
law, that resulted in a family member being
a person with a disability; (vi) The value of
any Coverdell education savings account
under section 530 of the Internal Revenue
Code of 1986, the value of any qualified
tuition program under section 529 of such
Code, the value of any Achieving a Better
Life Experience (ABLE) account authorized
under Section 529A of such Code, and the
value of any “baby bond” account created,
authorized, or funded by Federal, State, or
local government. (vii) Interests in Indian
trust land; (viii) Equity in a manufactured
home where the family receives assistance
under 24 CFR part 982; (ix) Equity in
property under the Homeownership Option
for which a family receives assistance under
24 CFR part 982; (x) Family SelfSufficiency Accounts; and (xi) Federal tax refunds or refundable tax credits for a period
of 12 months after receipt by the family.
(4) In cases where a trust fund has been
established and the trust is not revocable by,
or under the control of, any member of the
family or household, the trust fund is not a
family asset and the value of the trust is not
included in the calculation of net family
assets, so long as the fund continues to be
held in a trust that is not revocable by, or
under the control of, any member of the
family or household.

EXHIBIT 1
City Council 5 – 320 7/15/2025

EXHIBIT 6-3: THE EFFECT OF WELFARE BENEFIT REDUCTION
24 CFR 5.615
Public housing program and Section 8 tenant-based assistance program: How welfare benefit reduction affects family income.
(a) Applicability. This section applies to
covered families who reside in public housing
(part 960 of this title) or receive Section 8
tenant-based assistance (part 982 of this title).
(b) Definitions. The following definitions
apply for purposes of this section:

Covered families. Families who receive
welfare assistance or other public assistance
benefits (“welfare benefits”) from a State or
other public agency (“welfare agency”) under
a program for which Federal, State, or local
law requires that a member of the family must
participate in an economic self-sufficiency
program as a condition for such assistance.

Economic self-sufficiency program. See
definition at Sec. 5.603.

Imputed welfare income. The amount of
annual income not actually received by a
family, as a result of a specified welfare
benefit reduction, that is nonetheless included
in the family's annual income for purposes of
determining rent.

Specified welfare benefit reduction.
(1) A reduction of welfare benefits by the
welfare agency, in whole or in part, for a
family member, as determined by the welfare
agency, because of fraud by a family member
in connection with the welfare program; or
because of welfare agency sanction against a
family member for noncompliance with a
welfare agency requirement to participate in an
economic self-sufficiency program.
(2) “Specified welfare benefit reduction” does
not include a reduction or termination of
welfare benefits by the welfare agency:
(i) at expiration of a lifetime or other time
limit on the payment of welfare benefits;
(ii) because a family member is not able to
obtain employment, even though the family
member has complied with welfare agency
economic self-sufficiency or work activities
requirements; or
(iii) because a family member has not
complied with other welfare agency
requirements.
(c) Imputed welfare income.
(1) A family's annual income includes the
amount of imputed welfare income (because of
a specified welfare benefits reduction, as
specified in notice to the PHA by the welfare
agency), plus the total amount of other annual
income as determined in accordance with Sec.

5.609.
(2) At the request of the PHA, the welfare
agency will inform the PHA in writing of the
amount and term of any specified welfare
benefit reduction for a family member, and the
reason for such reduction, and will also inform
the PHA of any subsequent changes in the
term or amount of such specified welfare
benefit reduction. The PHA will use this
information to determine the amount of
imputed welfare income for a family.
(3) A family’s annual income includes
imputed welfare income in family annual
income, as determined at the PHA's interim or
regular reexamination of family income and
composition, during the term of the welfare
benefits reduction (as specified in information
provided to the PHA by the welfare agency).

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(4) The amount of the imputed welfare income
is offset by the amount of additional income a
family receives that commences after the time
the sanction was imposed. When such
additional income from other sources is at
least equal to the imputed
(5) The PHA may not include imputed welfare
income in annual income if the family was not
an assisted resident at the time of sanction.
(d) Review of PHA decision.
(1) Public housing. If a public housing tenant
claims that the PHA has not correctly
calculated the amount of imputed welfare
income in accordance with HUD requirements,
and if the PHA denies the family's request to
modify such amount, the PHA shall give the
tenant written notice of such denial, with a
brief explanation of the basis for the PHA
determination of the amount of imputed
welfare income. The PHA notice shall also
state that if the tenant does not agree with the
PHA determination, the tenant may request a
grievance hearing in accordance with part 966,
subpart B of this title to review the PHA
determination. The tenant is not required to
pay an escrow deposit pursuant to Sec.
966.55(e) for the portion of tenant rent
attributable to the imputed welfare income in
order to obtain a grievance hearing on the
PHA determination.
(2) Section 8 participant. A participant in the
Section 8 tenant-based assistance program
may request an informal hearing, in
accordance with Sec. 982.555 of this title, to
review the PHA determination of the amount
of imputed welfare income that must be
included in the family's annual income in
accordance with this section. If the family
claims that such amount is not correctly
calculated in accordance with HUD
requirements, and if the PHA denies the
family's request to modify such amount, the
PHA shall give the family written notice of
such denial, with a brief explanation of the
basis for the PHA determination of the amount
of imputed welfare income. Such notice shall
also state that if the family does not agree with
the PHA determination, the family may
request an informal hearing on the
determination under the PHA hearing
procedure.
(e) PHA relation with welfare agency.
(1) The PHA must ask welfare agencies to
inform the PHA of any specified welfare
benefits reduction for a family member, the
reason for such reduction, the term of any such
reduction, and any subsequent welfare agency
determination affecting the amount or term of
a specified welfare benefits reduction. If the
welfare agency determines a specified welfare
benefits reduction for a family member, and
gives the PHA written notice of such
reduction, the family's annual incomes shall
include the imputed welfare income because of
the specified welfare benefits reduction.
(2) The PHA is responsible for determining
the amount of imputed welfare income that is
included in the family's annual income as a
result of a specified welfare benefits reduction
as determined by the welfare agency, and
specified in the notice by the welfare agency to
the PHA. However, the PHA is not responsible
for determining whether a reduction of welfare
benefits by the welfare agency was correctly
determined by the welfare agency in
accordance with welfare program requirements
and procedures, nor for providing the
opportunity for review or hearing on such
welfare agency determinations.
(3) Such welfare agency determinations are
the responsibility of the welfare agency, and
the family may seek appeal of such
determinations through the welfare agency's
normal due process procedures. The PHA shall
be entitled to rely on the welfare agency notice
to the PHA of the welfare agency's
determination of a specified welfare benefits
reduction.

EXHIBIT 1
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. Page 7-1 Administrative Plan 7/1/2025
Chapter 7.A.

VERIFICATION
[24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18]

INTRODUCTION
Prior to the PHA’s HOTMA compliance date, the PHA will follow policies as outlined in this chapter. Upon the PHA’s HOTMA compliance date, the PHA will follow policies as outlined in Chapter 7.B.

The PHA must verify all information that is used to establish the family’s eligibility and level of assistance and is required to obtain written authorization from the family in order to collect the information. Applicants and program participants must cooperate with the verification process as a condition of receiving assistance. The PHA must not pass on the cost of verification to the family.

The PHA will follow the verification guidance provided by HUD in Notice PIH 2018-18 and any subsequent guidance issued by HUD. This chapter summarizes those requirements and provides supplementary PHA policies.

Part I describes the general verification process. Part II provides more detailed requirements related to family information. Part III provides information on income and assets, and Part IV covers mandatory deductions.

Verification policies, rules and procedures will be modified as needed to accommodate persons with disabilities. All information obtained through the verification process will be handled in accordance with the records management policies of the PHA.

PART I: GENERAL VERIFICATION REQUIREMENTS
7-I.A. FAMILY CONSENT TO RELEASE OF INFORMATION [24 CFR 982.516; 24 CFR 982.551; 24 CFR 5.230; and Notice PIH 2023-27]
Consent Forms
The family must supply any information that the PHA or HUD determines is necessary to the administration of the program and must consent to PHA verification of that information [24 CFR 982.551]. All adult family members must sign consent forms as needed to collect information relevant to the family’s eligibility and level of assistance. While PHAs must use form HUD9886-A, this form does not release all the information necessary to the administration of the program. The PHA must also develop its own release forms to cover all other necessary information.

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Form HUD-9886-A [24 CFR 5.230(b)(1), b(2), (c)(4), and (c)(5); and Notice PIH 2023-27] All adult applicants and participants sign form HUD-9886-A, Authorization for Release of Information. All adult family members (and the head and spouse/cohead, regardless of age) are required to sign the Form HUD-9886-A at admission. Participants, prior to January 1, 2024, signed and submitted Form HUD-9886 at each annual reexamination. HOTMA eliminated this requirement and instead required that the Form HUD-9886-A be signed only once. On or after January 1, 2024 (regardless of the PHA’s HOTMA compliance date), current program participants must sign and submit a new Form HUD-9886-A at their next interim or annual reexamination. This form will only be signed once. Another Form HUD-9886-A will not be submitted to the PHA except under the following circumstances:
 When any person 18 years or older becomes a member of the family;  When a current member of the family turns 18; or
 As required by HUD or the PHA in administrative instructions.

The PHA has the discretion to establish policies around when family members must sign consent forms when they turn 18. PHAs must establish these policies stating when family members will be required to sign consent forms at intervals other than at reexamination.

SAHA Policy
Family members turning 18 years of age between annual recertifications will be notified in writing that they are required to sign the required Consent to the Release of Information Form HUD-9886-A at the family’s next annual or interim reexamination, whichever is sooner.

The purpose of form HUD-9886-A is to facilitate automated data collection and computer matching from specific sources and provides the family's consent only for the specific purposes listed on the form. HUD and the PHA may collect information from State Wage Information Collection Agencies (SWICAs) and current and former employers of adult family members.

Only HUD is authorized to collect information directly from the Internal Revenue Service (IRS) and the Social Security Administration (SSA).

The PHA may obtain any financial record from any financial institution, as the terms financial record and financial institution are defined in the Right to Financial Privacy Act (12 U.S.C. 3401), whenever the PHA determines the record is needed to determine an applicant’s or participant’s eligibility for assistance or level of benefits [24 CFR 5.230(c)(4)].

The executed form will remain effective until the family is denied assistance, assistance is terminated, or the family provides written notification to the PHA to revoke consent.

Penalties for Failing to Consent [24 CFR 5.232]
If any family member who is required to sign a consent form fails to do so, the PHA will deny admission to applicants and terminate assistance of participants. The family may request an informal review (applicants) or informal hearing (participants) in accordance with PHA procedures.

However, this does not apply if the applicant, participant, or any member of their family, revokes their consent with respect to the ability of the PHA to access financial records from financial EXHIBIT 1
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institutions, unless the PHA establishes a policy that revocation of consent to access financial records will result in denial of admission or termination of assistance [24 CFR 5.232(c)]. PHAs may not process interim or annual reexaminations of income without the family’s executed consent forms.

SAHA Policy
SAHA has established a policy that revocation of consent to access financial records will result in denial of admission or termination of assistance in accordance with SAHA policy.

In order for a family to revoke their consent, the family must provide written notice to SAHA.

Within 14 calendar days of the date the family provides written notice, SAHA will send the family a notice acknowledging receipt of the request and explaining that revocation of consent will result in denial or termination of assistance, as applicable. At the same time, SAHA will notify their local HUD office.

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7-I.B. OVERVIEW OF VERIFICATION REQUIREMENTS
Use of Other Programs’ Income Determinations [24 CFR 5.609(c)(3) and Notice PIH 2023-27]
PHAs may, but are not required to, determine a family’s annual income, including income from assets, prior to the application of any deductions, based on income determinations made within the previous 12-month period, using income determinations from means-tested federal public assistance programs. PHAs are not required to accept or use determinations of income from other federal means-tested forms of assistance. If the PHA adopts a policy to accept this type of verification, the PHA must establish in policy when they will accept Safe Harbor income determinations and from which programs. PHAs must also create policies that outline the course of action when families present multiple verifications from the same or different acceptable Safe Harbor programs.

Means-tested federal public assistance programs include:
 Temporary Assistance for Needy Families (TANF) (42 U.S.C. 601, et seq.);  Medicaid (42 U.S.C. 1396 et seq.);
 Supplemental Nutrition Assistance Program (SNAP) (42 U.S.C. 2011 et seq.);  Earned Income Tax Credit (EITC) (26 U.S.C. 32);
 Low-Income Housing Tax Credit (LIHTC) program (26 U.S.C. 42);  Special Supplemental Nutrition Program for Woman, Infants, and Children (WIC) (42 U.S.C. 1786);
 Supplemental Security Income (SSI) (42 U.S.C. 1381 et seq.);  Other programs administered by the HUD Secretary;
 Other means-tested forms of federal public assistance for which HUD has established a memorandum of understanding; and
 Other federal benefit determinations made in other forms of means-tested federal public assistance that the Secretary determines to have comparable reliability and announces through the Federal Register.

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If the PHA elects to use the annual income determination from one of the above-listed forms of means-tested federal public assistance, then they must obtain the income information by means of a third-party verification. The third-party verification must state the family size, must be for the entire family, and must state the amount of the family’s annual income. The annual income need not be broken down by family member or income type. Annual income includes income earned from assets, therefore when using Safe Harbor to verify a family’s income, PHAs will neither further inquire about a family’s net family assets, nor about the income earned from those assets, except with respect to whether or not the family owns assets that exceed the asset limitation in 24 CFR 5.618. The Safe Harbor documentation will be considered acceptable if any of the following dates fall into the 12-month period prior to the receipt of the documentation by the PHA:
 Income determination effective date;
 Program administrator’s signature date;
 Family’s signature date;
 Report effective date; or
 Other report-specific dates that verify the income determination date.

The only information that PHAs are permitted to use to determine income under this method is the total income determination made by the federal means-tested program administrator. Other federal programs may provide additional information about income inclusions and exclusions in their award letters; however, these determinations and any other information must not be considered by the PHA. PHAs are not permitted to mix and match Safe Harbor income determinations and other income verifications.

If the PHA is unable to obtain Safe Harbor documentation or if the family disputes the other program’s income determination, the PHA must calculate the family’s annual income using traditional methods as outlined in Notice PIH 2023-27 and this chapter.

If the PHA uses a Safe Harbor determination to determine the family’s income, the family is obligated to report changes in income that meet the PHA’s reporting requirement and occur after the effective date of the transaction.

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The amounts of unreimbursed reasonable attendant care expenses and childcare expenses deducted from a family’s annual income, except for when a family is approved for a childcare expense hardship exemption, must still be capped by the amount earned by any family member who is enabled to work as a result of the expense. PHAs are therefore required to obtain thirdparty verification of the applicable employment income and cap the respective expense deductions accordingly.

SAHA Policy
SAHA will not accept verification from other federal assistance programs. All income will be verified in accordance with the requirements of HUD’s verification hierarchy and SAHA policies in this chapter.

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HUD’s Verification Hierarchy [Notice PIH 2018-18]
HUD mandates the use of the EIV system and offers administrative guidance on the use of other methods to verify family information and specifies the circumstances in which each method will be used. In general HUD requires the PHA to use the most reliable form of verification that is available and to document the reasons when the PHA uses a lesser form of verification.

In order of priority, the forms of verification that the PHA will use are:
 Up-front Income Verification (UIV) using HUD’s Enterprise Income Verification (EIV) system
 Up-front Income Verification (UIV) using a non-HUD system  Written Third-Party Verification (may be provided by applicant or participant)  Written Third-party Verification Form
 Oral Third-party Verification
 Self-Certification
Each of the verification methods is discussed in subsequent sections below.

Requirements for Acceptable Documents
SAHA Policy
Any documents used for verification must be the original (not photocopies) and generally must be dated within 120 days of receipt by SAHA. Statements dated within the appropriate benefit year are acceptable for fixed sources of income. The documents must not be damaged, altered or in any way illegible.

Printouts from webpages are considered original documents.

SAHA staff member who views the original document must make a photocopy.

Any family self-certifications must be made in a format acceptable to SAHA and must be signed by the family member whose information or status is being verified.

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File Documentation
The PHA must document in the file how the figures used in income and rent calculations were determined. All verification attempts, information obtained, and decisions reached during the verification process will be recorded in the family’s file in sufficient detail to demonstrate that the PHA has followed all of the verification policies set forth in this plan. The record should be sufficient to enable a staff member or HUD reviewer to understand the process followed and conclusions reached.

SAHA Policy
SAHA will document, in the family file, the following:

Reported family annual income
Value of assets
Expenses related to deductions from annual income
Other factors influencing adjusted income
When the PHA is unable to obtain third-party verification, the PHA will document in the family file the reason that third-party verification was not available [24 CFR 982.516(a)(2); Notice PIH 2018-18].
7-I.C. UP-FRONT INCOME VERIFICATION (UIV)
Up-front income verification (UIV) refers to the PHA’s use of the verification tools available from independent sources that maintain computerized information about earnings and benefits.

UIV will be used to the extent that these systems are available to the PHA.

There may be legitimate differences between the information provided by the family and UIVgenerated information. If the family disputes the accuracy of UIV data, no adverse action can be taken until the PHA has independently verified the UIV information and the family has been granted an opportunity to contest any adverse findings through the informal review/hearing process of the PHA.

See Chapter 6 for the PHA’s policy on the use of UIV/EIV to project annual income.

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Upfront Income Verification Using HUD’s Enterprise Income Verification (EIV) System (Mandatory)
PHAs must use HUD’s EIV system in its entirety as a third-party source to verify tenant employment and income information during mandatory reexaminations or recertifications of family composition and income in accordance with 24 CFR 5.236 and administrative guidance issued by HUD. However, the PHA is not required to verify income information in EIV at annual reexam when Safe Harbor verification is used to determine a family’s income [Notice PIH 2023- 27]. The EIV system contains data showing earned income, unemployment benefits, social security benefits, and SSI benefits for participant families. The following policies apply to the use of HUD’s EIV system.

EIV Income and IVT Reports
The data shown on income and income validation tool (IVT) reports is updated quarterly. Data may be between 3 and 6 months old at the time reports are generated.

SAHA Policy
SAHA will obtain income and IVT reports for annual reexaminations on a monthly basis.

Reports will be generated as part of the regular reexamination process.

Income and IVT reports will be compared to family-provided information as part of the annual reexamination process. Income reports may be used in the calculation of annual income, as described in Chapter 6-I.C. Income reports may also be used to meet the regulatory requirement for third party verification, as described above. Policies for resolving discrepancies between income reports and family-provided information will be resolved as described in Chapter 6-I.C. and in this chapter.

Income and IVT reports will be used in interim reexaminations to identify any discrepancies between reported income and income shown in the EIV system, and as necessary to verify earned income, and to verify and calculate unemployment benefits, Social Security and/or SSI benefits. EIV will also be used to verify that families claiming zero income are not receiving income from any of these sources.

Income and IVT reports will be retained in participant files with the applicable annual or interim reexamination documents.

When SAHA determines through EIV reports and third-party verification that a family has concealed or under-reported income, corrective action will be taken pursuant to the policies in Chapter 14, Program Integrity.

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EIV Identity Verification
The EIV system verifies tenant identities against SSA records. These records are compared to PIC data for a match on social security number, name, and date of birth.

PHAs are required to use EIV’s Identity Verification Report on a monthly basis to improve the availability of income information in EIV [Notice PIH 2018-18].

When identity verification for a participant fails, a message will be displayed within the EIV system and no income information will be displayed.

SAHA Policy
SAHA will identify participants whose identity verification has failed by reviewing EIV’s Identity Verification Report on a monthly basis.

SAHA will attempt to resolve PIC/SSA discrepancies by obtaining appropriate documentation from the participant. When SAHA determines that discrepancies exist due to SAHA errors such as spelling errors or incorrect birth dates, the errors will be corrected promptly.

Upfront Income Verification Using Non-HUD Systems (Optional) In addition to mandatory use of the EIV system, HUD encourages PHAs to utilize other upfront verification sources.

SAHA Policy
SAHA will inform all applicants and participants of its use of other up-front income verification sources, such as The Work Number (an automated verification system) and state government databases, to validate tenant-reported income.

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7-I.D. THIRD-PARTY WRITTEN AND ORAL VERIFICATION
HUD’s current verification hierarchy defines two types of written third-party verification. The more preferable form, “written third-party verification,” consists of an original document generated by a third-party source, which may be received directly from a third-party source or provided to the PHA by the family. If written third-party verification is not available, the PHA must attempt to obtain a “written third-party verification form.” This is a standardized form used to collect information from a third party.

Written Third-Party Verification [Notice PIH 2018-18]
Written third-party verification documents must be original and authentic and may be supplied by the family or received from a third-party source.

Examples of acceptable tenant-provided documents include, but are not limited to: pay stubs, payroll summary reports, employer notice or letters of hire and termination, SSA benefit verification letters, bank statements, child support payment stubs, welfare benefit letters and/or printouts, and unemployment monetary benefit notices.

The PHA is required to obtain, at minimum, two current and consecutive pay stubs for determining annual income from wages.

The PHA may reject documentation provided by the family if the document is not an original, if the document appears to be forged, or if the document is altered, mutilated, or illegible.

Written, third-party verification includes an original or authentic document generated by a thirdparty source dated within 120 days of the date received by the PHA [Notice PIH 2023-27].

PHAs may accept a statement dated within the appropriate benefit year for fixed income sources [Notice PIH 2023-27].

SAHA Policy
Third-party documents provided by the family must be dated within 120 days of receipt by SAHA. SAHA will accept a statement dated within the appropriate benefit year for fixed income sources.

If SAHA determines that third-party documents provided by the family are not acceptable, SAHA will explain the reason to the family and request additional documentation.

As verification of earned income, SAHA will require the family to provide the two most current, consecutive pay stubs. At SAHA’s discretion, if additional paystubs are needed due to the family’s circumstances (e.g., sporadic income, fluctuating schedule, etc.), SAHA may request additional paystubs or a payroll record.

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Written Third-Party Verification Form
When upfront verification is not available and the family is unable to provide written third-party documents, the PHA must request a written third-party verification form. HUD’s position is that this traditional third-party verification method presents administrative burdens and risks which may be reduced through the use of family-provided third-party documents.

PHAs may mail or email third-party written verification form requests to third-party sources.

SAHA Policy
SAHA may mail, fax, e-mail third-party written verification requests and will accept third-party responses using any of these methods. SAHA will send a written request for verification as needed to each required source within 7 days of securing a family’s authorization for the release of the information. If a response has not been received by the 15th day, SAHA will request third-party oral verification.

Oral Third-Party Verification [Notice PIH 2018-18]
For third-party oral verification, PHAs contact sources, identified by UIV techniques or by the family, by telephone or in person.

Oral third-party verification is mandatory if neither form of written third-party verification is available.

Third-party oral verification may be used when requests for written third-party verification forms have not been returned within a reasonable time—e.g., 10 business days.

PHAs should document in the file the date and time of the telephone call or visit, the name of the person contacted, the telephone number, as well as the information confirmed.

SAHA Policy
In collecting third-party oral verification, SAHA staff will record in the family’s file the name and title of the person contacted, the date and time of the conversation (or attempt), the telephone number used, and the facts provided.

When any source responds verbally to the initial written request for verification SAHA will accept the verbal response as oral verification but will also request that the source complete and return any verification forms that were provided.

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When Third-Party Verification is Not Required [Notice PIH 2018-18] Third-party verification may not be available in all situations. HUD has acknowledged that it may not be cost-effective or reasonable to obtain third-party verification of income, assets, or expenses when these items would have a minimal impact on the family’s total tenant payment.

SAHA Policy
If the family cannot provide original documents, SAHA will pay the service charge required to obtain third-party verification, unless it is not cost effective in which case a self-certification will be acceptable as the only means of verification. The cost of verification will not be passed on to the family.

The cost of postage and envelopes to obtain third-party verification of income, assets, and expenses is not an unreasonable cost [VG, p. 18].

Primary Documents
Third-party verification is not required when legal documents are the primary source, such as a birth certificate or other legal documentation of birth.

Imputed Assets
HUD permits PHAs to accept a self-certification from a family as verification of assets disposed of for less than fair market value [HCV GB, p. 5-28].

SAHA Policy
SAHA will not accept a self-certification from a family as verification of assets disposed of for less than fair market value.

Value of Assets and Asset Income [24 CFR 982.516(a)]
For families with net assets totaling $5,000 or less, the PHA may accept the family’s declaration of asset value and anticipated asset income. However, the PHA is required to obtain third-party verification of all assets regardless of the amount during the intake process and at least every three years thereafter.

SAHA Policy
SAHA will not accept family’s self-certification for assets. SAHA will require thirdparty verification regardless of value of asset.

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7-I.E. SELF-CERTIFICATION
When HUD requires third-party verification, self-certification or “tenant declaration,” is used as a last resort when the PHA is unable to obtain third-party verification.

Self-certification, however, is an acceptable form of verification when:
 A source of income is fully excluded
 Net family assets total $5,000 or less and the PHA has adopted a policy to accept self certification at annual recertification, when applicable  The PHA has adopted a policy to implement streamlined annual recertifications for fixed sources of income (See Chapter 11)
When the PHA was required to obtain third-party verification but instead relies on a tenant declaration for verification of income, assets, or expenses, the family’s file must be documented to explain why third-party verification was not available.

SAHA Policy
When information cannot be verified by a third party or by review of documents, family members will be required to submit self-certifications attesting to the accuracy of the information they have provided to SAHA. SAHA staff must document the family’s file to explain why third-party verification was not available when SAHA relies on tenant declaration for verification of income, assets, or expenses SAHA may require a family to certify that a family member does not receive a particular type of income or benefit.

The self-certification must be made in a format acceptable to SAHA and must be signed by the family member whose information or status is being verified.

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PART II: VERIFYING FAMILY INFORMATION
7-II.A. VERIFICATION OF LEGAL IDENTITY
SAHA Policy
SAHA will require families to furnish verification of legal identity for each household member.

Verification of Legal Identity for Adults Verification of Legal Identity for Children
Certificate of birth, naturalization papers
Church issued baptismal certificate
Current, valid driver's license or
Department of Motor Vehicles
identification card
U.S. military discharge (DD 214)
Current U.S. passport
Current government employer
identification card with picture
Certificate of birth
Adoption papers
Custody agreement
Health and Human Services ID
Certified school records
If a document submitted by a family is illegible for any reason or otherwise questionable, more than one of these documents may be required.

If none of these documents can be provided and at SAHA’s discretion, a third party who knows the person may attest to the person’s identity. The certification must be provided in a format acceptable to SAHA and must be signed by the family member whose information or status is being verified.

Legal identity will be verified for all applicants at the time of eligibility determination and in cases where SAHA has reason to doubt the identity of a person representing themselves to be a participant.

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7-II.B. SOCIAL SECURITY NUMBERS [24 CFR 5.216, Notice PIH 2018-24] The family must provide documentation of a valid social security number (SSN) for each member of the household, with the exception of individuals who do not contend eligible immigration status. Exemptions also include existing program participants who were at least 62 years of age as of January 31, 2010, and had not previously disclosed an SSN.

Note that an individual who previously declared to have eligible immigration status may not change their declaration for the purpose of avoiding compliance with the SSN disclosure and documentation requirements or penalties associated with noncompliance with these requirements. Nor may the head of household opt to remove a household member from the family composition for this purpose.

The PHA must accept the following documentation as acceptable evidence of the social security number:
 An original SSN card issued by the Social Security Administration (SSA)  An original SSA-issued document, which contains the name and SSN of the individual  An original document issued by a federal, state, or local government agency, which contains the name and SSN of the individual
While PHAs must attempt to gather third-party verification of SSNs prior to admission as listed above, PHAs also have the option of accepting a self-certification and a third-party document (such as a bank statement, utility or cell phone bill, or benefit letter) with the applicant’s name printed on it to satisfy the SSN disclosure requirement if the PHA has exhausted all other attempts to obtain the required documentation. If verifying an individual’s SSN using this method, the PHA must document why the other SSN documentation was not available [Notice PIH 2023-27].

SAHA Policy
SAHA will verify an individual’s SSN in the situations described above using the method described above as a last resort when no other forms of verification of the individual’s SSN are available.

The PHA may only reject documentation of an SSN provided by an applicant or participant if the document is not an original document or if the original document has been altered, mutilated, is illegible, or appears to be forged.

SAHA Policy
SAHA will explain to the applicant or participant the reasons the document is not acceptable and request that the individual obtain and submit acceptable documentation of the SSN to SAHA within 90 days.

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In the case of Moderate Rehabilitation Single Room Occupancy (SRO) individuals, the required documentation must be provided within 90 calendar days from the date of admission into the program. The PHA must grant one additional 90-day extension if it determines that the applicant’s failure to comply was due to circumstances that were beyond the applicant’s control and could not have been reasonably foreseen.

SAHA Policy
SAHA will grant one additional 90-day extension if needed for reasons beyond the participant’s control such as delayed processing of the SSN application by the SSA, natural disaster, fire, death in the family, or other emergency. If the individual fails to comply with SSN disclosure and documentation requirements upon expiration of the provided time period, SAHA will terminate the individual’s assistance.

If an applicant family includes a child under 6 years of age who joined the household within the 6 months prior to the date of voucher issuance, an otherwise eligible family may be admitted to the program and the family must provide documentation of the child’s SSN within 90 days of the effective date of the initial HAP contract. A 90-day extension will be granted if the PHA determines that the participant’s failure to comply was due to unforeseen circumstances and was outside of the participant’s control.

SAHA Policy
SAHA will grant one additional 90-day extension if needed for reasons beyond the applicant’s control, such as delayed processing of the SSN application by the SSA, natural disaster, fire, death in the family, or other emergency.

When a participant requests to add a new household member who is at least 6 years of age, or who is under the age of 6 and has an SSN, the participant must provide the complete and accurate SSN assigned to each new member at the time of reexamination or recertification, in addition to the documentation required to verify it. The PHA may not add the new household member until such documentation is provided.

When a participant requests to add a new household member who is under the age of 6 and has not been assigned an SSN, the participant must provide the SSN assigned to each new child and the required documentation within 90 calendar days of the child being added to the household. A 90-day extension will be granted if the PHA determines that the participant’s failure to comply was due to unforeseen circumstances and was outside of the participant’s control. During the period the PHA is awaiting documentation of the SSN, the child will be counted as part of the assisted household.

SAHA Policy
SAHA will grant one additional 90-day extension if needed for reasons beyond the participant’s control such as delayed processing of the SSN application by the SSA, natural disaster, fire, death in the family, or other emergency.

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Social security numbers must be verified only once during continuously-assisted occupancy.

SAHA Policy
SAHA will verify each disclosed SSN by:

Obtaining documentation from applicants and participants that is acceptable as evidence of social security numbers
Making a copy of the original documentation submitted, returning it to the individual, and retaining a copy in the file folder
Once the individual’s verification status is classified as “verified,” the PHA may, at its discretion, remove and destroy copies of documentation accepted as evidence of social security numbers. The retention of the EIV Summary Report or Income Report is adequate documentation of an individual’s SSN.

SAHA Policy
Once an individual’s status is classified as “verified” in HUD’s EIV system, SAHA will remove and destroy copies of documentation accepted as evidence of social security numbers.
7-II.C. DOCUMENTATION OF AGE
A birth certificate or other official record of birth is the preferred form of age verification for all family members. For elderly family members an original document that provides evidence of the receipt of social security retirement benefits is acceptable.

SAHA Policy
If an official record of birth or evidence of social security retirement benefits cannot be provided, SAHA will require the family to submit other documents that support the reported age of the family member (e.g., school records, driver's license if birth year is recorded) and to provide a self-certification.

Age must be verified only once during continuously assisted occupancy. 7-II.D. FAMILY RELATIONSHIPS
Applicants and program participants are required to identify the relationship of each household member to the head of household. Definitions of the primary household relationships are provided in the Eligibility chapter.

SAHA Policy
Family relationships are verified only to the extent necessary to determine a family’s eligibility and level of assistance. Certification by the head of household normally is sufficient verification of family relationships.

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Marriage
SAHA Policy
Certification by the head of household is normally sufficient verification. If SAHA has reasonable doubts about a marital relationship, SAHA will require the family to document the marriage.

A marriage certificate generally is required to verify that a couple is married.

In the case of a common law marriage, the couple must demonstrate that they hold themselves to be married (e.g., by telling the community they are married, calling each other husband and wife, using the same last name, filing joint income tax returns).

Separation or Divorce
SAHA Policy
Certification by the head of household is normally sufficient verification. If SAHA has reasonable doubts about a separation or divorce, SAHA will require the family to provide documentation of the divorce or separation.

A certified copy of a divorce decree, signed by a court officer, is required to document that a couple is divorced.

A copy of a court-ordered maintenance or other court record is required to document a separation.

If no court document is available, documentation from a community-based agency will be accepted.

Absence of Adult Member
SAHA Policy
If an adult member who was formerly a member of the household is reported to be permanently absent, the family must provide evidence to support that the person is no longer a member of the family (e.g., documentation of another address at which the person resides such as a lease or utility bill), if SAHA so requests.

Foster Children and Foster Adults
SAHA Policy
Third-party verification from the state or local government agency responsible for the placement of the individual with the family is required.

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7-II.E. VERIFICATION OF STUDENT STATUS
General Requirements
SAHA Policy
SAHA requires families to provide information about the student status of all students who are 18 years of age or older. This information will be verified only if:

The family reports full-time student status for an adult other than the head, spouse, or cohead.

The family reports childcare expenses to enable a family member to further their education.

The family includes a student enrolled in an institution of higher education.

Verification of full-time student status includes all of the following:

Written verification from the registrar’s office or other school official School records indicating enrolment in sufficient credits to qualify as full-time by the educational institution
Final report of units completed will be required at the family’s annual reexamination or as requested by SAHA staff.

Full-time students that are eighteen (18) years of age or older and are employed are required to provide an unofficial transcript from each institution of higher education at the time of the family’s annual reexamination or as requested by SAHA staff.

Restrictions on Assistance to Students Enrolled in Institutions of Higher Education This section applies only to students who are seeking assistance on their own, separately from their parents. It does not apply to students residing with parents who are seeking or receiving HCV assistance.

SAHA Policy
In accordance with the verification hierarchy described in section 7-1.B, SAHA will determine whether the student is exempt from the restrictions in 24 CFR 5.612 by verifying any one of the following exemption criteria:

The student is enrolled at an educational institution that does not meet the definition of institution of higher education in the Higher Education Act of 1965 (see section Exhibit 3-2).

The student is at least 24 years old.

The student is a veteran, as defined in section 3-II.E.

The student is married.

The student has at least one dependent child, as defined in section 3-II.E.

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The student is a person with disabilities, as defined in section 3-II.E, and was receiving assistance prior to November 30, 2005.

If SAHA cannot verify at least one of these exemption criteria, SAHA will conclude that the student is subject to the restrictions on assistance at 24 CFR 5.612. In addition to verifying the student’s income eligibility, SAHA will then proceed to verify either the student’s parents’ income eligibility (see section 7-III.J) or the student’s independence from their parents (see below).

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Independent Student
SAHA Policy
SAHA will verify a student’s independence from their parents to determine that the student’s parents’ income is not relevant for determining the student’s eligibility by doing all of the following:

Either reviewing and verifying previous address information to determine whether the student has established a household separate from their parents for at least one year, or reviewing and verifying documentation relevant to determining whether the student meets the U.S. Department of Education’s definition of independent student (see section 3-II.E)
Reviewing the student’s prior year income tax returns to verify the student is independent or verifying the student meets the U.S. Department of Education’s definition of independent student (see section 3-II.E)
Requesting and obtaining written certification directly from the student’s parents identifying the amount of support they will be providing to the student, even if the amount of support is $0, except in cases in which SAHA determines that the student is a vulnerable youth (see section 3-II.E)
7-II.F. DOCUMENTATION OF DISABILITY
The PHA must verify the existence of a disability in order to allow certain income disallowances and deductions from income. The PHA is not permitted to inquire about the nature or extent of a person’s disability [24 CFR 100.202(c)]. The PHA may not inquire about a person’s diagnosis or details of treatment for a disability or medical condition. If the PHA receives a verification document that provides such information, the PHA will not place this information in the tenant file. Under no circumstances will the PHA request a participant’s medical record(s). For more information on health care privacy laws, see the Department of Health and Human Services’ website at http://www.hhs.gov/ocr/privacy/.

The above cited regulation does not prohibit the following inquiries, provided these inquiries are made of all applicants, whether or not they are persons with disabilities [VG, p. 24]:
 Inquiry into an applicant’s ability to meet the requirements of ownership or tenancy  Inquiry to determine whether an applicant is qualified for a dwelling available only to persons with disabilities or to persons with a particular type of disability  Inquiry to determine whether an applicant for a dwelling is qualified for a priority available to persons with disabilities or to persons with a particular type of disability  Inquiring whether an applicant for a dwelling is a current illegal abuser or addict of a controlled substance
 Inquiring whether an applicant has been convicted of the illegal manufacture or distribution of a controlled substance
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Family Members Receiving SSA Disability Benefits
Verification of the receipt of disability benefits from the Social Security Administration (SSA) is sufficient verification of disability for the purpose of qualifying for waiting list preferences (if applicable) or certain income disallowances and deductions [VG, p. 23].

SAHA Policy
For family members claiming disability who receive disability benefits from the SSA, SAHA will attempt to obtain information about disability benefits through the HUD Enterprise Income Verification (EIV) system. If documentation from HUD’s EIV System is not available, SAHA will request a current (dated within the appropriate benefit year) SSA benefit verification letter from each family member claiming disability status. If the family is unable to provide the document(s), SAHA will ask the family to request a benefit verification letter by either calling SSA at 1-800-772-1213, or by requesting it from www.ssa.gov. Once the applicant or participant receives the benefit verification letter they will be required to provide it to SAHA.

Family Members Not Receiving SSA Disability Benefits
Receipt of veteran’s disability benefits, worker’s compensation, or other non-SSA benefits based on the individual’s claimed disability are not sufficient verification that the individual meets HUD’s definition of disability in 24 CFR 5.403.

SAHA Policy
For family members claiming disability who do not receive disability benefits from the SSA, a knowledgeable professional must provide third-party verification that the family member meets the HUD definition of disability. See the Eligibility chapter for the HUD definition of disability. The knowledgeable professional will verify whether the family member does or does not meet the HUD definition.

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City Council 5 – 345 7/15/2025
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7-II.G. CITIZENSHIP OR ELIGIBLE IMMIGRATION STATUS [24 CFR 5.508] Overview
Housing assistance is not available to persons who are not citizens, nationals, or eligible immigrants. Prorated assistance is provided for "mixed families" containing both eligible and ineligible persons. A detailed discussion of eligibility requirements is in the Eligibility chapter.

This verifications chapter discusses HUD and PHA verification requirements related to citizenship status.

The family must provide a certification that identifies each family member as a U.S. citizen, a U.S. national, an eligible noncitizen or an ineligible noncitizen and submit the documents discussed below for each family member. Once eligibility to receive assistance has been verified for an individual it need not be collected or verified again during continuously assisted occupancy. [24 CFR 5.508(g)(5)]
U.S. Citizens and Nationals
HUD requires a declaration for each family member who claims to be a U.S. citizen or national.

The declaration must be signed personally by any family member 18 or older and by a guardian for minors.

The PHA may request verification of the declaration by requiring presentation of a birth certificate, United States passport or other appropriate documentation.

SAHA Policy
Family members who claim U.S. citizenship or national status will not be required to provide additional documentation unless SAHA receives information indicating that an individual’s declaration may not be accurate.

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. Page 7-25 Administrative Plan 7/1/2025
Eligible Immigrants
Documents Required
All family members claiming eligible immigration status must declare their status in the same manner as U.S. citizens and nationals.

The documentation required for eligible noncitizens varies depending upon factors such as the date the person entered the U.S., the conditions under which eligible immigration status has been granted, age, and the date on which the family began receiving HUD-funded assistance. Exhibit 7-1 at the end of this chapter summarizes documents family members must provide.

PHA Verification [HCV GB, pp. 5-3 and 5-7]
For family members age 62 or older who claim to be eligible immigrants, proof of age is required in the manner described in 7-II.C. of this plan. No further verification of eligible immigration status is required.

For family members under the age of 62 who claim to be eligible immigrants, the PHA must verify immigration status with the United States Citizenship and Immigration Services (USCIS).

The PHA will follow all USCIS protocols for verification of eligible immigration status. 7-II.H. VERIFICATION OF PREFERENCE STATUS
The PHA must verify any preferences claimed by an applicant that determined placement on the waiting list.

SAHA Policy

1. United States Military Veteran Preference: A veteran is a person who served in the active military, naval, or air service and who was discharged or released from such service under conditions other than dishonorable. Form DD-214 with a discharge status of other than dishonorable, or equivalent verification, must be provided at their eligibility interview appointment.

2. Residency Preference: Residency preference for applicants who live or work in the City of Santa Ana at the time of application. At least two pieces of evidence must be provided for applicants who live or work in the City of Santa Ana including but not limited to a lease, utility bills, bank statements, or paycheck stubs (“proof of the residency preference”). The residency preference claimed at the time of the applicant applied for the program will be verified when the applicant is selected off of the waiting list. Applicants who are unable to provide proof of the residency preference will be removed from the waiting list. Applicants who live or work in the unincorporated areas of Santa Ana will not receive the residency preference.
a. Mainstream vouchers are intended to facilitate access to housing for individuals with disabilities, including for individuals who reside in institutional or other segregated settings that may not be located in the geographic area that is typically served by a PHA. Consequently, HUD waived 24 CFR 982.207(b)(1) and established an alternative EXHIBIT 1
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requirement under which a PHA cannot apply a residency preference to Mainstream voucher applicants (excluding project-based vouchers). b. A PHA also cannot apply a resident preference to VASH voucher applicants.

Families who have been terminated due to insufficient funding SAHA will offer an absolute preference to any family that has been terminated from its HCV program due to insufficient program funding. Special Purpose Vouchers will be the last to be terminated due to insufficient funding and first to be re-instated.

Homeless Individuals and Families Set-Aside Preference
In accordance with PIH Notice 2023-13, SAHA will accept direct referrals to the HCV program for the following target population:

Homeless Individuals and Families: The number of homeless individuals and families who can qualify for this preference and successfully lease a unit with their voucher will be limited to 50% of the total number of vouchers that become available through annual turnover in the previous calendar year. To qualify for this preference, homeless individuals and families must be referred by agencies with a contract or Memorandum of Understanding (MOU) in place with the Housing Authority or City of Santa Ana. The referring agency must provide a certification of the family’s homeless status. Additionally, families already registered on the Waiting List who declare themselves as homeless, but are not referred by a CBO must provide a certification of their homeless status from an agency that has an MOU in place with the Housing Authority. This set-aside preference has been documented by SAHA using generally accepted data sources. All homeless individuals and families must qualify for the Residency Preference.

Families who have been involuntarily displaced:

Families who have been involuntarily displaced due to a disaster (e.g., fire, flood, earthquake) or eminent domain. The preference depends on funding availability. If insufficient funds are available, then applicants will be prioritized based upon elderly and disabled families first.

Foster Youth to Independence (FYI) Vouchers
The waiting list for FYI vouchers is continually open for referrals from the Orange County Social Services Agency (Santa Ana’s Public Child Welfare Agency) as long as there are FYI vouchers available.

PHAs may choose to create a preference in their regular HCV program for persons whose FYI assistance is expiring and will lack adequate housing as a result of their termination from the program, or other similar category.

As required by statute, an FYI voucher may only be used to provide housing assistance for youth for a maximum of 36 months. However, youth who first lease a unit with an FYI voucher after the date of enactment of the Fostering Stable Housing Opportunities (FSHO) amendments may receive an extension EXHIBIT 1
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of the 36-month time limit of assistance for up to an additional 24 months if they meet the requirements of FSHO. FSHO applies to eligible youth who first leased or leases a unit after the date of enactment of FSHO, December 27, 2020, which includes youth who will be assisted with funding under this Notice. See HUD’s FSHO implementation notice published in the Federal Register on January 24, 2022 (87 FR 3570).

SAHA will provide a selection preference for FYI voucher holders who are terminated due to the time limit on assistance in accordance with this policy.

Emergency Housing Vouchers (EHV)
In March 2025, HUD notified PHAs of their final allocation to obligate all EHV HAP funds that remain available to HUD under the American Rescue Plan Act of 2021 (P.L. 117-2). According to the notice: “After this final allocation, the Department will provide no additional EHV CY HAP Renewal funding allocations to PHAs.”
Therefore, SAHA is making the waiting list continually open for EHV vouchers that are subject to termination due to this final funding allocation by HUD. Specifically, SAHA will provide a preference in the regular HCV program for persons whose EHV assistance is expiring and will lack adequate housing as a result of their termination from the program. In accordance with this policy, SAHA will provide a selection preference for EHV voucher holders who are terminated due to the lack of renewal funding from HUD.

This preference is allowed under Question # 45 of the Emergency Housing Vouchers Frequently Asked Questions (FAQs) v.9 which states, “Funds appropriated for the EHV program are available for obligation by HUD until September 30, 2030. These funds will be cancelled as a matter of law on September 30, 2035, per 31 U.S.C 1552. Prior to 2030, PHAs may consider options to ensure continued assistance to EHV families including but not limited to issuing regular Housing Choice Vouchers (HCV) to the affected EHV households. Such families would need to be pulled from the waiting list. to facilitate this process, PHAs may choose to create a preference in their regular HCV program for persons whose EHV assistance is expiring and will lack adequate housing as a result of their termination from the program, or other similar category.”
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City Council 5 – 349 7/15/2025
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PART III: VERIFYING INCOME AND ASSETS
Chapter 6, Part I of this plan describes in detail the types of income that are included and excluded and how assets and income from assets are handled. Any assets and income reported by the family must be verified. This part provides PHA policies that supplement the general verification procedures specified in Part I of this chapter. 7-III.A. EARNED INCOME
Tips
SAHA Policy
Unless tip income is included in a family member’s W-2 by the employer, persons who work in industries where tips are standard will be required to sign a certified estimate of tips received for the previous two pay periods and tips anticipated to be received in the coming year.

Wages
SAHA Policy
For wages other than tips, the family must provide originals for the past three months of consecutive pay stubs for initial eligibility and two most recent consecutive pay stubs for reexaminations. SAHA may request additional verification as needed. 7-III.B. BUSINESS AND SELF EMPLOYMENT INCOME
SAHA Policy
Business owners and self-employed persons will be required to provide:
 A statement of income and expenses must be submitted and the business owner or self-employed person must certify to its accuracy.
 All schedules completed for filing federal and local taxes in the preceding year.  If accelerated depreciation was used on the tax return or financial statement, an accountant's calculation of depreciation expense, computed using straight-line depreciation rules.
 SAHA will provide a format for any person who is unable to provide such a statement to record income and expenses for the coming year. The business owner/self-employed person will be required to submit the information requested and to certify to its accuracy at all future reexaminations.  At any reexamination, SAHA may request documents that support submitted financial statements such as manifests, appointment books, cash books, or bank statements.
 If the family member has been self-employed for three (3) to twelve (12) months SAHA will require the family to provide documentation of income and expenses for this period and use that information to project income.

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7-III.C. PERIODIC PAYMENTS AND PAYMENTS IN LIEU OF EARNINGS For policies governing streamlined income determinations for fixed sources of income, please see Chapter 11.

Social Security/SSI Benefits
Verification requirements for Social Security (SS) and Supplemental Security Income (SSI) benefits differ for applicants and participants.

For applicants, since EIV does not contain SS or SSI benefit information, the PHA must ask applicants to provide a copy of their current SS and/or SSI benefit letter (dated within the appropriate benefit year) for each family member that receives SS and/or SSI benefits. If the family is unable to provide the document or documents, the PHA should help the applicant request a benefit verification letter from SSA’s website at www.ssa.gov or ask the family to request one by calling SSA at 1-800-772-1213. The PHA must obtain the original benefit letter from the applicant, make a photocopy of the document for the file, and return the original to the family.

For participants, the PHA must obtain information through the HUD EIV system and confirm with the participants that the current listed benefit amount is correct.  If the participant agrees with the amount reported in EIV, the PHA must use the EIVreported gross benefit amount to calculate annual income from Social Security. PHAs are required to use the EIV-reported SS and SSI benefit amounts when calculating income unless the tenant disputes the EIV-reported amount. For example, an SSA benefit letter may list the monthly benefit amount as $450.80 and EIV displays the amount as $450.00. The PHA must use the EIV-reported amount unless the participant disputes the amount.  If the participant disputes the EIV-reported benefit amount, or if benefit information is not available in EIV, the PHA must request a current SSA benefit verification letter (dated within the appropriate benefit year) from each family member that receives SS and/or SSI benefits.

If the family is unable to provide the document or documents, the PHA should help the participant request a benefit verification letter from SSA’s website at www.ssa.gov or ask the family to request one by calling SSA at 1-800-772-1213. The PHA must obtain the original benefit letter from the participant, make a photocopy of the document for the file, and return the original to the family.

Photocopies of social security checks or bank statements are not acceptable forms of verification for SS/SSI benefits.

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7-III.D. ALIMONY OR CHILD SUPPORT
SAHA Policy
The methods SAHA will use to verify alimony and child support payments differ depending on whether the family declares that it receives regular payments.

If the family declares that it receives regular payments, verification will be obtained in the following order of priority:

Copies of the receipts and/or payment stubs for the 60 days prior to PHA request
Third-party verification form from the state or local child support enforcement agency for payment record for the last 12 months and requests that the entity disclose any known information about the likelihood of future payments.

Third-party verification form from the person paying the support Family's self-certification of amount received and the likelihood of support payments being received in the future, or that support payments are not being received.

A separation or settlement agreement or a divorce decree stating the amount and type of support and payment schedules.

Note: Families are not required to undertake independent enforcement action.

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7-III.E. ASSETS AND INCOME FROM ASSETS
Assets Disposed of for Less than Fair Market Value
The family must certify whether any assets have been disposed of for less than fair market value in the preceding two years. The PHA needs to verify only those certifications that warrant documentation [HCV GB, p. 5-28].

SAHA Policy
SAHA will verify the value of assets disposed of only if:

SAHA does not already have a reasonable estimation of its value from previously collected information, or
The amount reported by the family in the certification appears obviously in error.

Example 1: An elderly participant reported a $10,000 certificate of deposit at the last annual reexamination and the PHA verified this amount. Now the person reports that she has given this $10,000 to her son. The PHA has a reasonable estimate of the value of the asset; therefore, reverification of the value of the asset is not necessary.

Example 2: A family member has disposed of its 1/4 share of real property located in a desirable area and has valued her share at approximately $5,000. Based upon market conditions, this declaration does not seem realistic. Therefore, the PHA will verify the value of this asset.
7-III.F. NET INCOME FROM RENTAL PROPERTY
SAHA Policy
The family must provide:

A current executed lease for the property that shows the rental amount or certification from the current tenant
A self-certification from the family members engaged in the rental of property providing an estimate of expenses for the coming year and the most recent IRS Form 1040 with Schedule E (Rental Income).

If Schedule E was not prepared, SAHA will require the family members involved in the rental of property to provide a self-certification of income and expenses for the previous year and may request documentation to support the statement including: tax statements, insurance invoices, bills for reasonable maintenance and utilities, and bank statements or amortization schedules showing monthly interest expense.

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7-III.G. RETIREMENT ACCOUNTS
SAHA Policy
SAHA will accept written third-party documents supplied by the family as evidence of the status of retirement accounts.

The type of original document that will be accepted depends upon the family member’s retirement status.

Before retirement, SAHA will accept a copy of document provided from the entity holding the account with a date that shows it is the most recently scheduled statement for the account but in no case earlier than 120 days from the effective date of the re-examination.

SAHA will send third party verification to determine if family has access to the account to determine penalties, early withdrawal fees, and any related fees.

SAHA will consider limited access as having no access.

Upon retirement, SAHA will accept a copy of document provided from the entity holding the account that reflects any distributions of the account balance, any lump sums taken and any regular payments. After retirement, SAHA will accept a copy of document provided from the entity holding the account dated no earlier than 120 days from the effective date of the reexamination that reflects any distributions of the account balance, any lump sums taken and any regular payments.

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7-III.H. INCOME FROM EXCLUDED SOURCES
A detailed discussion of excluded income is provided in Chapter 6, Part I.

HUD guidance on verification of excluded income draws a distinction between income which is fully excluded and income which is only partially excluded.

For fully excluded income, the PHA is not required to follow the verification hierarchy, document why third-party verification is not available, or report the income on the 50058. Fully excluded income is defined as income that is entirely excluded from the annual income determination (for example, food stamps, earned income of a minor, or foster care funds) [Notice PIH 2013-04].

PHAs may accept a family’s signed application or reexamination form as self-certification of fully excluded income. They do not have to require additional documentation. However, if there is any doubt that a source of income qualifies for full exclusion, PHAs have the option of requiring additional verification.

For partially excluded income, the PHA is required to follow the verification hierarchy and all applicable regulations, and to report the income on the 50058. Partially excluded income is defined as income where only a certain portion of what is reported by the family qualifies to be excluded and the remainder is included in annual income (for example, the income of an adult full-time student).

SAHA Policy
SAHA will accept the family’s self-certification as verification of fully excluded income.

SAHA may request additional documentation if necessary to document the income source.

SAHA will verify the source and amount of partially excluded income as described in Part 1 of this chapter.

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7-III.I. ZERO INCOME FAMILIES [Notice PIH 2023-27]
PHAs have discretion to establish reasonable procedures to manage the risk of unreported income, such as asking families to complete a zero-income worksheet at admission or periodically after admission to determine if they have any sources of unreported income or searching any UIV sources for unreported income.

In calculating annual income, PHAs must not assign monetary value to nonmonetary in-kind donations from a food bank or similar organization received by the family [24 CFR

5.609(b)(24)(vi)].

PHAs may accept a self-certification of zero income from the family without taking any additional steps to verify zero reported income. HUD does not require such self-certifications be notarized.

PHAs that perform zero income reviews must update local discretionary policies, procedures, and forms. Families who begin receiving income which does not trigger an interim reexamination should no longer be considered zero income even though the family’s income is not reflected on the Form HUD-50058.

SAHA Policy
SAHA will require a self-certification statement of zero income from all adult family members that are not attending school or any type of training.

For zero income families SAHA requires these families to undergo a file review every 90 days.

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City Council 5 – 356 7/15/2025
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7-III.J. STUDENT FINANCIAL ASSISTANCE [24 CFR 5.609(b)(9) as updated for HOTMA]
The regulations under HOTMA distinguish between two categories of student financial assistance paid to both full-time and part-time students. Any other grant-in-aid, scholarship, or other assistance amounts an individual receives for the actual covered costs charged by the institute of higher education not otherwise excluded by the federally mandated income exclusions are included [24 CFR 5.609(b)(9)(ii)].

SAHA Policy
SAHA will request written third-party verification of both the source and the amount of student financial assistance. Family-provided documents from the educational institution attended by the student will be requested, as well as documents generated by any other person or entity providing such assistance, as reported by the student.

In addition, unless the student’s only source of assistance is assistance under Title IV of the HEA, SAHA will request written verification of the cost of the student’s tuition, books, supplies, room and board, and other required fees and charges to the student from the educational institution.

If SAHA is unable to obtain third-party written verification of the requested information, SAHA will pursue other forms of verification following the verification hierarchy in section 7-I.B.

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7-III.K. PARENTAL INCOME OF STUDENTS SUBJECT TO ELIGIBILITY

RESTRICTIONS
If a student enrolled at an institution of higher education is under the age of 24, is not a veteran, is not married, does not have a dependent child, and is not a person with disabilities receiving HCV assistance as of November 30, 2005, the income of the student’s parents must be considered when determining income eligibility, unless the student is determined independent from their parents or a vulnerable youth in accordance with PHA policy [24 CFR 5.612, FR Notice 4/10/06, p. 18146, and FR Notice 9/21/16].

This provision does not apply to students residing with parents who are seeking or receiving HCV assistance. It is limited to students who are seeking or receiving assistance on their own, separately from their parents.

SAHA Policy
If SAHA is required to determine the income eligibility of a student’s parents, SAHA will request an income declaration and certification of income from the appropriate parent(s) (as determined in section 3-II.E). SAHA will send the request directly to the parents, who will be required to certify to their income under penalty of perjury. The parents will be required to submit the information directly to SAHA. The required information must be submitted (postmarked) within 14 calendar days of the date of SAHA’s request or within any extended timeframe approved by SAHA.

SAHA reserves the right to request and review supporting documentation at any time if it questions the declaration or certification. Supporting documentation may include, but is not limited to, Internal Revenue Service (IRS) tax returns, consecutive and original pay stubs, bank statements, pension benefit statements, benefit award letters, and other official and authentic documents from a federal, state, or local agency.

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PART IV: VERIFYING MANDATORY DEDUCTIONS
7-IV.A. DEPENDENT AND ELDERLY/DISABLED HOUSEHOLD DEDUCTIONS The dependent and elderly/disabled family deductions require only that the PHA verify that the family members identified as dependents or elderly/disabled persons meet the statutory definitions. No further verifications are required.

Dependent Deduction
See Chapter 6 (6-II.B.) for a full discussion of this deduction. The PHA must verify that:
 Any person under the age of 18 for whom the dependent deduction is claimed is not the head, spouse, or cohead of the family and is not a foster child  Any person age 18 or older for whom the dependent deduction is claimed is not a foster adult or live-in aide, and is a person with a disability or a full time student Elderly/Disabled Family Deduction
See Eligibility chapter for a definition of elderly and disabled families and Chapter 6 (6-II.C.) for a discussion of the deduction. The PHA must verify that the head, spouse, or cohead is 62 years of age or older or a person with disabilities.

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7-IV.B. HEALTH AND MEDICAL CARE EXPENSE DEDUCTION
Policies related to health and medical care expenses are found in 6-II.D. The amount of the deduction will be verified following the standard verification procedures described in Part I.

Amount of Expense
SAHA Policy
Health and medical care expenses will be verified through:

Written third-party documents provided by the family, such as pharmacy printouts or receipts.

SAHA will make a best effort to determine what expenses from the past are likely to continue to occur in the future. SAHA will also accept evidence of monthly payments or total payments that will be due for health and medical care expenses during the upcoming 12 months. SAHA will use monthly payments or total balance, whichever is less.

In addition, the PHA must verify that:
 The household is eligible for the deduction.
 The costs to be deducted are qualified medical expenses.  The expenses are not paid for or reimbursed by any other source.  Costs incurred in past years are counted only once.

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Eligible Household
The health and medical care expense deduction is permitted only for households in which the head, spouse, or cohead is at least 62, or a person with disabilities. The PHA must verify that the family meets the definition of an elderly or disabled family provided in the Eligibility chapter and as described in Chapter 7 (7-IV.A.) of this plan.

Qualified Expenses
To be eligible for the health and medical care expenses deduction, the costs must qualify as health and medical care expenses. See Chapter 6 (6-II.D.) for the PHA’s policy on what counts as a health and medical care expense.

Unreimbursed Expenses
To be eligible for the health and medical care expenses deduction, the costs must not be reimbursed by another source.

SAHA Policy
The family will be required to certify that the health and medical care expenses are not paid or reimbursed to the family from any source. If health and medical care are verified through a third party, the third party must certify that the expenses are not paid or reimbursed from any other source.

Expenses Incurred in Past Years
SAHA Policy
When anticipated costs are related to on-going payment of medical bills incurred in past years, SAHA will verify:

The anticipated repayment schedule
The amounts paid in the past, and
Whether the amounts to be repaid have been deducted from the family’s annual income in past years
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7-IV.C. DISABILITY ASSISTANCE EXPENSES
Policies related to disability assistance expenses are found in 6-II.E. The amount of the deduction will be verified following the standard verification procedures described in Part I.

Amount of Expense
Attendant Care
SAHA Policy
SAHA will accept written third-party documents provided by the family.

If family-provided documents are not available, SAHA will provide a third-party verification form directly to the care provider requesting the needed information.

Expenses for attendant care will be verified through:

Written third-party documents provided by the family, such as receipts or cancelled checks.

Third-party verification form signed by the provider, if family-provided documents are not available.

Auxiliary Apparatus
SAHA Policy
Expenses for auxiliary apparatus will be verified through:

Written third-party documents provided by the family, such as billing statements for purchase of auxiliary apparatus, or other evidence of monthly payments or total payments that will be due for the apparatus during the upcoming 12 months.

Third-party verification form signed by the provider, if family-provided documents are not available.

In addition, the PHA must verify that:
 The family member for whom the expense is incurred is a person with disabilities (as described in 7-II.F above).
 The expense permits a family member, or members, to work (as described in 6-II.E.).  The expense is not reimbursed from another source (as described in 6-II.E.).

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Family Member is a Person with Disabilities
To be eligible for the disability assistance expense deduction, the costs must be incurred for attendant care or auxiliary apparatus expense associated with a person with disabilities. The PHA will verify that the expense is incurred for a person with disabilities (See 7-II.F.).

Family Member(s) Permitted to Work
The PHA must verify that the expenses claimed actually enable a family member, or members, (including the person with disabilities) to work.

SAHA Policy
SAHA will request third-party verification from a rehabilitation agency or knowledgeable medical professional indicating that the person with disabilities requires attendant care or an auxiliary apparatus to be employed, or that the attendant care or auxiliary apparatus enables another family member, or members, to work (See 6-II.E.). This documentation may be provided by the family.

If third-party verification has been attempted and is either unavailable or proves unsuccessful, the family must certify that the disability assistance expense frees a family member, or members (possibly including the family member receiving the assistance), to work.

Unreimbursed Expenses
To be eligible for the disability expenses deduction, the costs must not be reimbursed by another source.

SAHA Policy
The family will be required to certify that attendant care or auxiliary apparatus expenses are not paid by or reimbursed to the family from any source.

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. Page 7-42 Administrative Plan 7/1/2025
7-IV.D. CHILDCARE EXPENSES
Policies related to childcare expenses are found in Chapter 6 (6-II.F). The amount of the deduction will be verified following the standard verification procedures described in Part I of this chapter. In addition, the PHA must verify that:
 The child is eligible for care (12 or younger).
 The costs claimed are not reimbursed.
 The costs enable a family member to work, actively seek work, or further their education.  The costs are for an allowable type of childcare.
 The costs are reasonable.

Eligible Child
To be eligible for the childcare deduction, the costs must be incurred for the care of a child under the age of 13. The PHA will verify that the child being cared for (including foster children) is under the age of 13 (See 7-II.C.).

Unreimbursed Expense
To be eligible for the childcare deduction, the costs must not be reimbursed by another source.

SAHA Policy
The family (and the care provider) will be required to certify that the childcare expenses are not paid or reimbursed to the family from any source.

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. Page 7-43 Administrative Plan 7/1/2025
Pursuing an Eligible Activity
The PHA must verify that the family member(s) that the family has identified as being enabled to seek work, pursue education, or be gainfully employed, are actually pursuing those activities.

SAHA Policy
Information to be Gathered
SAHA will verify information about how the schedule for the claimed activity relates to the hours of care provided, the time required for transportation, the time required for study (for students), the relationship of the family member(s) to the child, and any special needs of the child that might help determine which family member is enabled to pursue an eligible activity.

Seeking Work
Whenever possible SAHA will use documentation from a state or local agency that monitors work-related requirements (e.g., welfare or unemployment). In such cases SAHA will request family-provided verification from the agency of the member’s job seeking efforts to date, and require the family to submit to SAHA any reports provided to the other agency.

In the event third-party verification is not available, SAHA will provide the family with a form on which the family member must record job search efforts. SAHA will review this information at each subsequent reexamination for which this deduction is claimed.

Furthering Education
SAHA will request third-party documentation to verify that the person permitted to further their education by the childcare is enrolled and provide information about the timing of classes for which the person is registered. The documentation may be provided by the family.

Gainful Employment
SAHA will seek third-party verification of the work schedule of the person who is permitted to work by the childcare. In cases in which two or more family members could be permitted to work, the work schedules for all relevant family members may be verified. The documentation may be provided by the family.

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. Page 7-44 Administrative Plan 7/1/2025
Allowable Type of Childcare
The type of care to be provided is determined by the family, but must fall within certain guidelines, as discussed in Chapter 6.

SAHA Policy
SAHA will verify that the type of childcare selected by the family is allowable, as described in Chapter 6 (6-II.F).

SAHA will verify that the fees paid to the childcare provider cover only childcare costs (e.g., no housekeeping services or personal services) and are paid only for the care of an eligible child (e.g., prorate costs if some of the care is provided for ineligible family members).

SAHA will verify that the childcare provider is not an assisted family member.

Verification will be made through the head of household’s declaration of family members who are expected to reside in the unit.

Reasonableness of Expenses
Only reasonable childcare costs can be deducted.

SAHA Policy
The actual costs the family incurs will be compared with SAHA’s established standards of reasonableness for the type of care in the locality to ensure that the costs are reasonable.

If the family presents a justification for costs that exceed typical costs in the area, SAHA will request additional documentation, as required, to support a determination that the higher cost is appropriate.

EXHIBIT 1
City Council 5 – 366 7/15/2025
. Page 7-45 Administrative Plan 7/1/2025
EXHIBIT 7-1: SUMMARY OF DOCUMENTATION REQUIREMENTS
FOR NONCITIZENS [HCV GB, pp. 5-9 and 5-10]
 All noncitizens claiming eligible status must sign a declaration of eligible immigrant status on a form acceptable to the PHA.
 Except for persons 62 or older, all noncitizens must sign a verification consent form  Additional documents are required based upon the person's status.

Elderly Noncitizens
 A person 62 years of age or older who claims eligible immigration status also must provide proof of age such as birth certificate, passport, or documents showing receipt of SS old-age benefits.

All other Noncitizens
 Noncitizens that claim eligible immigration status also must present the applicable USCIS document. Acceptable USCIS documents are listed below.
 Form I-551 Alien Registration Receipt
Card (for permanent resident aliens)
 Form I-94 Arrival-Departure Record
annotated with one of the following:
 “Admitted as a Refugee Pursuant to
Section 207”
 “Section 208” or “Asylum”
 “Section 243(h)” or “Deportation
stayed by Attorney General”
 “Paroled Pursuant to Section 221 (d)(5)
of the USCIS”
 Form I-94 Arrival-Departure Record with
no annotation accompanied by:
 A final court decision granting asylum
(but only if no appeal is taken);
 A letter from a USCIS asylum officer
granting asylum (if application is filed
on or after 10/1/90) or from a USCIS
district director granting asylum
(application filed before 10/1/90);
 A court decision granting withholding
of deportation; or
 A letter from an asylum officer granting
withholding or deportation (if
application filed on or after 10/1/90).
 Form I-688 Temporary Resident Card
annotated “Section 245A” or Section 210”.

Form I-688B Employment Authorization Card
annotated “Provision of Law 274a. 12(11)” or
“Provision of Law 274a.12”.
 A receipt issued by the USCIS indicating that an application for issuance of a replacement document in one of the above listed categories has been made and the applicant’s entitlement to the document has been verified; or
 Other acceptable evidence. If other documents are determined by the USCIS to constitute acceptable evidence of eligible immigration status, they will be announced by notice published in the Federal Register
EXHIBIT 1
City Council 5 – 367 7/15/2025

Chapter 7.B.

VERIFICATION UNDER HOTMA 102/104
[24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2023-27]

INTRODUCTION
This chapter is applicable upon the PHA’s HOTMA 102/104 compliance date. Prior to this date, the PHA will follow policies as outlined in Chapter 7.A.

The PHA must verify all information that is used to establish the family’s eligibility and level of assistance and is required to obtain written authorization from the family in order to collect the information. Applicants and program participants must cooperate with the verification process as a condition of receiving assistance. The PHA must not pass on the cost of verification to the family.

The PHA must follow the verification guidance provided by HUD in Notice PIH 2023-27 and any subsequent guidance issued by HUD. This chapter summarizes those requirements and provides supplementary PHA policies.

Part I describes the general verification process. Part II provides more detailed requirements related to family information. Part III provides information on income and assets, and Part IV covers mandatory deductions.

Verification policies, rules and procedures will be modified as needed to accommodate persons with disabilities. All information obtained through the verification process will be handled in accordance with the records management policies of the PHA.

PART I: GENERAL VERIFICATION REQUIREMENTS
7-I.A. FAMILY CONSENT TO RELEASE OF INFORMATION [24 CFR 982.516; 24 CFR 982.551; 24 CFR 5.230; and Notice PIH 2023-27]
Consent Forms
The family must supply any information that the PHA or HUD determines is necessary to the administration of the program and must consent to PHA verification of that information [24 CFR 982.551]. All adult family members must sign consent forms as needed to collect information relevant to the family’s eligibility and level of assistance. While PHAs must use form HUD9886-A, this form does not release all the information necessary to the administration of the program. The PHA must also develop its own release forms to cover all other necessary information.

EXHIBIT 1
City Council 5 – 368 7/15/2025

Form HUD-9886-A [24 CFR 5.230(b)(1), b(2), (c)(4), and (c)(5); and Notice PIH 2023-27] All adult applicants and participants sign form HUD-9886-A, Authorization for Release of Information. All adult family members (and the head and spouse/cohead, regardless of age) are required to sign the Form HUD-9886-A at admission. Participants, prior to January 1, 2024, signed and submitted Form HUD-9886 at each annual reexamination. HOTMA eliminated this requirement and instead required that the Form HUD-9886-A be signed only once. On or after January 1, 2024 (regardless of the PHA’s HOTMA compliance date), current program participants must sign and submit a new Form HUD-9886-A at their next interim or annual reexamination. This form will only be signed once. Another Form HUD-9886-A will not be submitted to the PHA except under the following circumstances:
 When any person 18 years or older becomes a member of the family;  When a current member of the family turns 18; or
 As required by HUD or the PHA in administrative instructions.

The PHA has the discretion to establish policies around when family members must sign consent forms when they turn 18. PHAs must establish these policies stating when family members will be required to sign consent forms at intervals other than at reexamination.

SAHA Policy
Family members turning 18 years of age between annual recertifications will be notified in writing that they are required to sign the required Consent to the Release of Information Form HUD-9886-A
The purpose of form HUD-9886-A is to facilitate automated data collection and computer matching from specific sources and provides the family's consent only for the specific purposes listed on the form. HUD and the PHA may collect information from State Wage Information Collection Agencies (SWICAs) and current and former employers of adult family members.

Only HUD is authorized to collect information directly from the Internal Revenue Service (IRS) and the Social Security Administration (SSA).

The PHA may obtain any financial record from any financial institution, as the terms financial record and financial institution are defined in the Right to Financial Privacy Act (12 U.S.C. 3401), whenever the PHA determines the record is needed to determine an applicant’s or participant’s eligibility for assistance or level of benefits [24 CFR 5.230(c)(4)].

The executed form will remain effective until the family is denied assistance, assistance is terminated, or the family provides written notification to the PHA to revoke consent.

EXHIBIT 1
City Council 5 – 369 7/15/2025

Penalties for Failing to Consent [24 CFR 5.232]
If any family member who is required to sign a consent form fails to do so, the PHA must deny admission to applicants and terminate assistance of participants. The family may request an informal review (applicants) or informal hearing (participants) in accordance with PHA procedures.

However, this does not apply if the applicant, participant, or any member of their family, revokes their consent with respect to the ability of the PHA to access financial records from financial institutions, unless the PHA establishes a policy that revocation of consent to access financial records will result in denial of admission or termination of assistance [24 CFR 5.232(c)]. PHAs may not process interim or annual reexaminations of income without the family’s executed consent forms.

SAHA Policy
SAHA has established a policy that revocation of consent to access financial records will result in denial of admission or termination of assistance in accordance with SAHA policy.

In order for a family to revoke their consent, the family must provide written notice to SAHA.

Within 14 calendar days of the date the family provides written notice, SAHA will send the family a notice acknowledging receipt of the request and explaining that revocation of consent will result in denial or termination of assistance, as applicable. At the same time, SAHA will notify their local HUD office.

EXHIBIT 1
City Council 5 – 370 7/15/2025

7-I.B. USE OF OTHER PROGRAMS’ INCOME DETERMINATIONS
[24 CFR 5.609(c)(3) and Notice PIH 2023-27]
PHAs may, but are not required to, determine a family’s annual income, including income from assets, prior to the application of any deductions, based on income determinations made within the previous 12-month period, using income determinations from means-tested federal public assistance programs. PHAs are not required to accept or use determinations of income from other federal means-tested forms of assistance. If the PHA adopts a policy to accept this type of verification, the PHA must establish in policy when they will accept Safe Harbor income determinations and from which programs. PHAs must also create policies that outline the course of action when families present multiple verifications from the same or different acceptable Safe Harbor programs.

Means-tested federal public assistance programs include:
 Temporary Assistance for Needy Families (TANF) (42 U.S.C. 601, et seq.);  Medicaid (42 U.S.C. 1396 et seq.);
 Supplemental Nutrition Assistance Program (SNAP) (42 U.S.C. 2011 et seq.);  Earned Income Tax Credit (EITC) (26 U.S.C. 32);
 Low-Income Housing Tax Credit (LIHTC) program (26 U.S.C. 42);  Special Supplemental Nutrition Program for Woman, Infants, and Children (WIC) (42 U.S.C. 1786);
 Supplemental Security Income (SSI) (42 U.S.C. 1381 et seq.);  Other programs administered by the HUD Secretary;
 Other means-tested forms of federal public assistance for which HUD has established a memorandum of understanding; and
 Other federal benefit determinations made in other forms of means-tested federal public assistance that the Secretary determines to have comparable reliability and announces through the Federal Register.

EXHIBIT 1
City Council 5 – 371 7/15/2025

If the PHA elects to use the annual income determination from one of the above-listed forms of means-tested federal public assistance, then they must obtain the income information by means of a third-party verification. The third-party verification must state the family size, must be for the entire family, and must state the amount of the family’s annual income. The annual income need not be broken down by family member or income type. Annual income includes income earned from assets, therefore when using Safe Harbor to verify a family’s income, PHAs will neither further inquire about a family’s net family assets, nor about the income earned from those assets, except with respect to whether or not the family owns assets that exceed the asset limitation in 24 CFR 5.618. The Safe Harbor documentation will be considered acceptable if any of the following dates fall into the 12-month period prior to the receipt of the documentation by the PHA:
 Income determination effective date;
 Program administrator’s signature date;
 Family’s signature date;
 Report effective date; or
 Other report-specific dates that verify the income determination date.

The only information that PHAs are permitted to use to determine income under this method is the total income determination made by the federal means-tested program administrator. Other federal programs may provide additional information about income inclusions and exclusions in their award letters; however, these determinations and any other information must not be considered by the PHA. PHAs are not permitted to mix and match Safe Harbor income determinations and other income verifications.

If the PHA is unable to obtain Safe Harbor documentation or if the family disputes the other program’s income determination, the PHA must calculate the family’s annual income using traditional methods as outlined in Notice PIH 2023-27 and this chapter.

If the PHA uses a Safe Harbor determination to determine the family’s income, the family is obligated to report changes in income that meet the PHA’s reporting requirement and occur after the effective date of the transaction.

EXHIBIT 1
City Council 5 – 372 7/15/2025

The amounts of unreimbursed reasonable attendant care expenses and childcare expenses deducted from a family’s annual income, except for when a family is approved for a childcare expense hardship exemption, must still be capped by the amount earned by any family member who is enabled to work as a result of the expense. PHAs are therefore required to obtain thirdparty verification of the applicable employment income and cap the respective expense deductions accordingly.

SAHA Policy
SAHA will not accept verification from other federal assistance programs. All income will be verified in accordance with the requirements of HUD’s verification hierarchy and PHA policies in this chapter.

EXHIBIT 1
City Council 5 – 373 7/15/2025

7-I.C. STREAMLINED INCOME DETERMINATIONS [24 CFR 960.257(c); Notice PIH 2023-27]
HUD permits PHAs to streamline the income determination process for family members with fixed sources of income. While third-party verification of all income sources must be obtained during the intake process and every three years thereafter, in the intervening years, the PHA may determine income from fixed sources by applying a verified cost of living adjustment (COLA) or other inflationary adjustment factor. Streamlining policies are optional. The PHA may, however, obtain third-party verification of all income, regardless of the source. Further, upon request of the family, the PHA must perform third-party verification of all income sources.

Fixed sources of income include Social Security and SSI benefits, pensions, annuities, disability or death benefits, and other sources of income subject to a COLA or rate of interest. The determination of fixed income may be streamlined even if the family also receives income from other non-fixed sources.

Two streamlining options are available, depending upon the percentage of the family’s income that is received from fixed sources.

When 90 percent or more of a family’s unadjusted income is from fixed sources, the PHA may apply the inflationary adjustment factor to the family’s fixed-income sources, provided that the family certifies both that 90 percent or more of their unadjusted income is fixed and that their sources of fixed income have not changed from the previous year. Sources of non-fixed income are not required to be adjusted and must not be adjusted by a COLA, but PHAs may choose to adjust sources of non-fixed income based on third-party verification. PHAs have the discretion to either adjust the non-fixed income or carry over the calculation of non-fixed income from the first year to years two and three.

EXHIBIT 1
City Council 5 – 374 7/15/2025

When less than 90 percent of a family’s unadjusted income consists of fixed income, PHAs may apply a COLA to each of the family’s sources of fixed income. PHAs must determine all other income using standard verification requirements as outlined in Notice PIH 2023-27.

SAHA Policy
SAHA chooses not to streamline the annual reexamination process for fixed-income sources. The PHA will obtain third-party verification, where applicable, of all sources of income annually in accordance with PHA policies in the chapter and HUD regulations.

EXHIBIT 1
City Council 5 – 375 7/15/2025

7-I.D. VERIFICATION HIERARCHY [Notice PIH 2023-27]
When the PHA does not use a streamlined determination of income or an income determination from a means-tested federal assistance program, HUD requires the PHA to obtain third-party verification of:
 Reported family annual income;
 The value of net family assets when the net value exceeds the HUD-published threshold, as listed in HUD’s Inflation-Adjusted Values tables ($50,000 for 2024, and $51,600 for 2025);  Expenses related to deductions from annual income; and  Other factors that affect the determination of adjusted income.

HUD mandates the use of the EIV system and offers administrative guidance on the use of other methods to verify family information and specifies the circumstances in which each method will be used. In general HUD requires the PHA to use the most reliable form of verification that is available and to document the reasons when the PHA uses a lesser form of verification.

In order of priority, the forms of verification that the PHA will use are:

HUD developed a hierarchy that described verification documentation from most acceptable to least acceptable. The PHA must demonstrate efforts to obtain third party verification prior to accepting self-certification except instances when self-certification is explicitly allowed.

In order of priority, the hierarchy is:
 Highest: Level 6: Up-front Income Verification (UIV) using HUD’s Enterprise Income Verification (EIV) system
 Highest: Level 5: Up-front Income Verification (UIV) using a non-EIV system  High: Level 4:
- Written third-party verification from the source, also known as “family-provided verification”
- Or EIV plus self-certification
 Medium: Level 3: Written third-party verification form  Medium: Level 2: Oral third-party verification
 Low: Level 1: Self-certification (not third-party verification) Each of the verification methods is discussed in subsequent sections below.

File Documentation
The PHA must document in the file how the figures used in income and rent calculations were determined. All verification attempts, information obtained, and decisions reached during the verification process will be recorded in the family’s file in sufficient detail to demonstrate that the PHA has followed all of the verification policies set forth in this plan. The record should be sufficient to enable a staff member or HUD reviewer to understand the process followed and conclusions reached.

EXHIBIT 1
City Council 5 – 376 7/15/2025

7-I.E. LEVEL 5 AND 6 VERIFICATIONS: UP-FRONT INCOME VERIFICATION (UIV) Up-front income verification (UIV) refers to the PHA’s use of the verification tools available from independent sources that maintain computerized information about earnings and benefits for a number of individuals. PHAs may use UIV sources before or during a family reexamination.

UIV will be used to the extent that these systems are available to the PHA.

There may be legitimate differences between the information provided by the family and UIVgenerated information. If the family disputes the accuracy of UIV data, no adverse action can be taken until the PHA has independently verified the UIV information and the family has been granted an opportunity to contest any adverse findings through the informal review/hearing process of the PHA.

HUD’s Enterprise Income Verification (EIV) System (Mandatory) PHAs must use HUD’s EIV system in its entirety as a third-party source to verify tenant employment and income information during annual and streamlined reexaminations of family composition and income in accordance with 24 CFR 5.236 and Notice PIH 2023-27.

HUD’s EIV system contains data showing earned income, unemployment benefits, social security benefits, and SSI benefits for participant families.

The income validation tool (IVT) in EIV provides projections of discrepant income for wages, unemployment compensation, and SSA benefits pursuant to HUD’s data sharing agreements with other departments.

The following policies apply to the use of HUD’s EIV system.

EIV Income Report
PHAs are required to obtain an EIV Income Report for each family any time the PHA conducts an annual reexamination. However, PHAs are not required to use the EIV Income Report:
 At annual reexamination if the PHA used Safe Harbor verification from another means-tested federal assistance program to determine the family’s income; or  During any interim reexaminations.

The EIV Income Report is also not available for program applicants at admission.

When required to use the EIV Income Report, in order for the report to be considered current, the PHA must pull the report within 120 days of the effective date of the annual reexamination.

EXHIBIT 1
City Council 5 – 377 7/15/2025

The EIV Income Report may be used to verify and calculate income at annual reexamination if the family self-certifies that the amount is accurate and representative of current income. The family must be provided with the information in EIV.

SAHA Policy
SAHA will obtain an EIV Income Report for all annual reexaminations for all families on a monthly basis. Reports will be generated as part of the regular reexamination process.

SAHA will ensure that all EIV Income Reports are pulled within 120 days of the effective date of the annual reexamination.

Income reports will only be used for interim reexaminations as necessary. EIV may be used to verify that families claiming zero income are not receiving income from any of these sources listed in EIV.

Income reports will be retained in participant files with the applicable annual documents or interim reexamination documents (if applicable) for the duration of tenancy.

When SAHA determines through EIV reports and third-party verification that a family has concealed or under-reported income, corrective action will be taken pursuant to the policies in Chapter 14, Program Integrity.

New Hires Report [Notice PIH 2023-27]
The New Hires Report identifies participant families who have new employment within the last six months. The report is updated monthly.

PHAs must review this information at annual reexamination except when the PHA uses Safe Harbor verification from another means-tested federal assistance program to determine the family’s income.

PHAs that do not require families to undergo interim reexaminations for earned income increases after an interim decrease are not required to review this report between a family’s annual reexamination. If the PHA requires an interim for increases in earned income after an interim decrease, then the PHA must review the report quarterly after the family’s interim decrease.

SAHA Policy
All families must report all changes in family and household composition that occur between annual reexaminations within 14 calendar days of the change.

In accordance with SAHA policies in Chapter 11, SAHA does not process interim reexaminations for families who have increases in earned income. SAHA will only review the New Hires Report at annual reexamination.

EXHIBIT 1
City Council 5 – 378 7/15/2025

No Income Reported by HHS or SSA Report
This report is a tool for PHAs to identify participants who passed the SSA identity test, but no income information was reported by either HHS or SSA records. This scenario does not mean that the participant does not have any income. PHAs obtain written, third-party verification of any income reported by the participant. The PHA must identify in its policies and procedures when this report will be pulled [Notice PIH 2023-27].

SAHA Policy
SAHA will generate the No Income Reported by HHS or SSA Report quarterly and will retain the report.

SAHA will re-verify the status of participants identified on the report quarterly. Based on the information provided by the family and in EIV, SAHA may require that family members provide verifications or sign release forms in order to obtain additional verification.

When SAHA determines through this report and third-party verification that a family has concealed or under-reported income, corrective action will be taken pursuant to the policies in Chapter 14, Program Integrity
EIV Identity Verification Report
The EIV system verifies tenant identities against SSA records. These records are compared to HUD data for a match on social security number, name, and date of birth.

PHAs are required to use EIV’s Identity Verification Report on a monthly basis to improve the availability of income information in EIV [Notice PIH 2023-27].

When identity verification for a participant fails, a message will be displayed within the EIV system and no income information will be displayed.

SAHA Policy
SAHA will identify participants whose identity verification has failed by reviewing EIV’s Identity Verification Report on a monthly basis.

SAHA will attempt to resolve discrepancies by obtaining appropriate documentation from the participant. When SAHA determines that discrepancies exist as a result of PHA errors such as spelling errors or incorrect birth dates, it will correct the errors promptly.

EXHIBIT 1
City Council 5 – 379 7/15/2025

Deceased Tenants Reports [Notice PIH 2012-4 and Notice PIH 2023-27] The Deceased Tenant Report identifies residents that have been reported by the SSA as deceased. SAHA is required to review the report at least quarterly.

SAHA Policy
SAHA will review the Deceased Tenants Report on a monthly basis.

When the Deceased Tenants Report identifies an individual as being deceased, PHAs must immediately send a letter to the head of household or emergency contact person (if the head of household is deceased and there is no other adult household member) to confirm the death of the listed household member. The PHA must notify the owner in writing of the deceased head of household.

PHAs may list the EOP as the last day of the month in which the death occurred. The landlord is entitled to receive the full HAP amount for the month in which the tenant death occurred.

SAHA Policy
SAHA will list the EOP as the last day of the month in which the death occurred. The landlord is entitled to receive the full HAP amount for the month in which the tenant death occurred.

When the only remaining household member is the live-in aide, the live-in aide is not entitled or eligible for any rental assistance or continued occupancy. The PHA may not designate the live-in aide as the new head of household or change the relation code on the Form HUD-50058.

Other EIV Reports [Notice PIH 2023-27]
The PHA is required to review the Multiple Subsidy Report at least quarterly and the Failed EIV Pre-Screening and Failed Verification (Failed SSA Identity Test) reports at least monthly.

Upfront Income Verification Using Non-HUD Systems
In addition to mandatory use of the EIV system, HUD encourages PHAs to utilize other upfront verification sources.

SAHA Policy
SAHA will inform all applicants and participants of its use of other up-front income verification sources, such as The Work Number (an automated verification system) and state government databases, to validate tenant-reported income.

EXHIBIT 1
City Council 5 – 380 7/15/2025

7-I.F. LEVEL 4 VERIFICATION [Notice PIH 2023-27]
HUD identifies two types of Level 4 verification: written-third party verification from the source and EIV + self-certification.

EIV + Self-Certification
EIV may be used as written third-party verification and may be used to calculate income if the family agrees with the information in EIV and self-certifies that the amount is accurate and representative of current income. This practice is known as EIV + self-certification. When calculating income using this method, the PHA may use its discretion to determine which method of calculation is reasonable: the last four quarters combined or an average of any number of quarters. The family must be provided with the information from EIV.

SAHA Policy
If there are no reported changes to an income source, SAHA may use EIV + selfcertification as verification of employment income, provided the family agrees with the amounts listed in EIV.

SAHA will use an average of the last two quarters of income listed in EIV to determine income from employment. SAHA will provide the family with the information in EIV.

The family will be required to sign a self-certification stating that the amount listed in EIV is accurate and representative of current income. If the family disagrees with using only the last two quarters of income listed in EIV, because of the seasonal or otherwise fluctuating nature of a particular family member’s employment, SAHA will permit the family to sign a self-certification stating that the average of all four quarters of income listed in EIV is accurate and representative of current annual income and use that amount for calculating annual income. If the family disagrees and contends that the amount listed in EIV is not reflective of current income, or if less than two quarters are available in EIV, SAHA will use written third-party verification from the source as outlined below.

SAHA will not use this method of verification at new admission since EIV is not available for applicant families or at interim reexamination since the income information in EIV is not current.

Written Third-Party Verification from the Source
Written, third-party verification from the source is also known as “tenant-provided verification.” In order to qualify as written-third party verification from the source, the documents must be original or authentic and (generally) dated within 120 days of the date received by the PHA. For fixed-income sources, a statement dated within the appropriate benefit year is acceptable documentation. The PHA may use the verification obtained during an interim reexamination for an annual reexamination if there have been no other changes to annual income since the interim reexamination. Documents may be supplied by the family or received from a third-party source.

EXHIBIT 1
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Examples of acceptable tenant-provided documents include, but are not limited to pay stubs, payroll summary reports, employer notice or letters of hire and termination, SSA benefit verification letters, bank statements, child support payment stubs, welfare benefit letters and/or printouts, and unemployment monetary benefit notices. Income tax returns with corresponding official tax forms and schedules attached and including third-party receipt of transmission for income tax return filed (i.e., tax preparer’s transmittal receipt, summary of transmittal from online source, etc.) are an acceptable form of written, third-party verification.

The PHA is required to obtain, at minimum, two current and consecutive pay stubs when calculating income using third-party verification from the source. For new income sources or when two pay stubs are not available, the PHA should determine income based on the information from a traditional written, third-party verification form or the best available information.

When the family disputes EIV-reported employment income, the PHA uses written third-party verification.

When verification of assets is required, PHAs are required to obtain a minimum of one statement that reflects the current balance of banking/financial accounts.

SAHA Policy
In general, SAHA will use third-party verification from the source in the following circumstances:

At annual reexamination when EIV + self-certification is not used; For all new admissions; and
For all interim reexaminations.

SAHA will not use this method if SAHA is able to use an income determination from a means-tested federal assistance program or if SAHA uses EIV + self-certification as outlined above.

In general, third-party documents provided by the family or the source must be dated within 120 days of the date received by SAHA. However, for fixed-income sources, a statement dated within the appropriate benefit year is acceptable documentation.

SAHA may reject documentation provided by the family if the document is not an original, if the document appears to be forged, or if the document is altered, mutilated, or illegible. If SAHA determines that third-party documents provided by the family are not acceptable, SAHA will explain the reason to the family and request additional documentation from the family or will use a lower form of verification such as a written third-party verification form.

When verification of assets held by a banking or financial institution is required, SAHA will obtain the three most current, consecutive months statements that reflect the current balance of the account.

When pay stubs are used, SAHA will require the family to provide the two most current, consecutive pay stubs. At SAHA’s discretion, if additional paystubs are needed due to the EXHIBIT 1
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family’s circumstances (e.g., sporadic income, fluctuating schedule, etc.), SAHA may request additional paystubs or a payroll record.

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7-I.G. LEVEL 3 VERIFICATION: WRITTEN, THIRD-PARTY FORM
[Notice PIH 2023 -27]
This type of verification is a form developed by the PHA and used uniformly for all families when needed to collect information from a third-party source. This is known as “traditional thirdparty verification.” PHAs send a PHA-developed form directly to the third-party source by mail, fax, or email and the source completes the form by hand (in writing or typeset).

The PHA may use this method when higher forms are unavailable or are rejected by the PHA or when the family is unable to provide acceptable verification. The PHA may skip this level of verification and may instead substitute oral third-party verification before moving to selfcertification.

SAHA Policy
Typically, SAHA will attempt to send written third-party verification forms to the verification source whenever higher forms of verification are unavailable.

However, on a case-by-case basis, SAHA may choose to obtain oral third-party verification without first attempting, and in lieu of, a written-third party verification form.

7.I.H. LEVEL 2: ORAL THIRD-PARTY VERIFICATION [Notice PIH 2023-27] For third-party oral verification, PHAs contact sources, identified by UIV techniques or by the family, by telephone or in person.

Third-party oral verification may be used when requests for written third-party verification forms have not been returned within a reasonable time—e.g., 10 business days.

PHAs must document in the file the date and time of the telephone call or visit, the name of the person contacted, the telephone number, as well as the information confirmed.

The PHA may skip this level of verification if they attempted written third-party verification via a form and the source did not respond and move directly to self-certification.

SAHA Policy
In general, SAHA will attempt to obtain written third-party verification via a form from the verification source. If written third-party verification forms are not returned within 14 calendar days, SAHA will accept self-certification from the family without attempting to obtain oral third-party verification.

However, if SAHA chooses to obtain oral third-party verification, SAHA will document in the file the date and time of the telephone call or visit, the name of the person contacted and the telephone number, as well as the information confirmed.

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When Third-Party Verification is Not Required [Notice PIH 2023-27] Third-party verification may not be available in all situations. HUD has acknowledged that it may not be cost-effective or reasonable to obtain third-party verification of income, assets, or expenses when these items would have a minimal impact on the family’s total tenant payment.

SAHA Policy
If the family cannot provide original documents, SAHA will pay the service charge required to obtain third-party verification, unless it is not cost effective in which case a self-certification will be acceptable as the only means of verification. The cost of verification will not be passed on to the family.

The cost of postage and envelopes to obtain third-party verification of income, assets, and expenses is not an unreasonable cost [VG, p. 18].

Primary Documents
Third-party verification is not required when legal documents are the primary source, such as a birth certificate or other legal documentation of birth.

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7-I.I. LEVEL 1: NON-THIRD-PARTY VERIFICATION: SELF-CERTIFICATION [Notice PIH 2023-27]
Non-third-party verification consists of a signed statement of reported income and/or expenses.

This verification method should be used as a last resort when the PHA has not been successful in obtaining information via all other required verification techniques.

Self-certification, however, is an acceptable form of verification when:
 A source of income is fully excluded
 Net family assets are less than or equal to the HUD-published threshold ($50,000 for 2024, and $51,600 for 2025) and the PHA has adopted a policy to accept self certification  The family declares that they do not have any present ownership in any real property  A family reports zero income;
 A family states that they have non-recurring income that will not be repeated in the coming year; and/or
 The PHA has adopted a policy to implement streamlined verification for fixed sources of income (See Chapter 11)
When the PHA was required to obtain third-party verification but instead relies on selfcertification, the family’s file must be documented to explain why third-party verification was not available.

HUD does not require that a self-certification be notarized; however, HUD recommends including language on any self-certification to ensure the certifier understands the consequences of knowingly providing false information.

SAHA Policy
When information cannot be verified by a third party or by review of documents, family members will be required to submit self-certifications attesting to the accuracy of the information they have provided to SAHA.

SAHA may require a family to certify that a family member does not receive a particular type of income or benefit.

The self-certification must be made in a format acceptable to SAHA and must be signed by the family member whose information or status is being verified. SAHA will not adopt self-certification of assets.

All self-certifications will include the following language:
“I/We, the undersigned, certify under penalty of perjury that the information provided here is true and correct, to the best of my knowledge and recollection. WARNING:

Anyone who knowingly submits a false claim or knowingly makes a false statement is subject to criminal and/or civil penalties, including confinement for up to five years, fines, and civil and administrative penalties (18 U.S.C. 287, 1001, 1010, 1012; 31 U.S.C. 3279, 3802).”
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PART II: VERIFYING FAMILY INFORMATION
7-II.A. VERIFICATION OF LEGAL IDENTITY
SAHA Policy
SAHA will require families to furnish verification of legal identity for each household member.

Verification of Legal Identity for Adults Verification of Legal Identity for Children
Certificate of birth, naturalization papers
Church issued baptismal certificate
Current, valid driver’s license or
Department of Motor Vehicles
identification card
U.S. military discharge (DD 214)
Current U.S. passport
Current government employer
identification card with picture
Certificate of birth
Adoption papers
Custody agreement
Health and Human Services ID
Certified school records
If a document submitted by a family is illegible for any reason or otherwise questionable, more than one of these documents may be required.

If none of these documents can be provided and at SAHA’s discretion, a third party who knows the person may attest to the person’s identity. The certification must be provided in a format acceptable to SAHA and must be signed by the family member whose information or status is being verified.

Legal identity will be verified for all applicants at the time of eligibility determination and in cases where SAHA has reason to doubt the identity of a person representing themselves to be a participant.

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7-II.B. SOCIAL SECURITY NUMBERS [24 CFR 5.216, Notice PIH 2023-27] The family must provide documentation of a valid Social Security number (SSN) for each member of the household, with the exception of individuals who do not contend eligible immigration status. Exemptions also include existing program participants who were at least 62 years of age as of January 31, 2010, and had not previously disclosed an SSN.

Note that an individual who previously declared to have eligible immigration status may not change their declaration for the purpose of avoiding compliance with the SSN disclosure and documentation requirements or penalties associated with noncompliance with these requirements. Nor may the head of household opt to remove a household member from the family composition for this purpose.

The PHA must accept the following documentation as acceptable evidence of the social security number:
 An original SSN card issued by the Social Security Administration (SSA)  An original SSA-issued document, which contains the name and SSN of the individual  An original document issued by a federal, state, or local government agency, which contains the name and SSN of the individual
While PHAs must attempt to gather third-party verification of SSNs prior to admission as listed above, PHAs also have the option of accepting a self-certification and a third-party document (such as a bank statement, utility or cell phone bill, or benefit letter) with the applicant’s name printed on it to satisfy the SSN disclosure requirement if the PHA has exhausted all other attempts to obtain the required documentation. If verifying an individual’s SSN using this method, the PHA must document why the other SSN documentation was not available.

If the tenant’s SSN becomes verified in EIV, then no further verification is required. If the tenant’s SSN fails the SSA identity match, then the PHA must obtain a valid SSN card issued by the SSA or an original document issued by a federal or state government agency that contains the name of the individual and the SSN of the individual, along with other identifying information of the individual. The tenant’s assistance must be terminated if they fail to provide the required documentation.

SAHA Policy
SAHA will verify an individual’s SSN in the situations described above using the method described above as a last resort when no other forms of verification of the individual’s SSN are available.

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The PHA may only reject documentation of an SSN provided by an applicant or participant if the document is not an original document or if the original document has been altered, mutilated, is illegible, or appears to be forged.

SAHA Policy
SAHA will explain to the applicant or participant the reasons the document is not acceptable and request that the individual obtain and submit acceptable documentation of the SSN to SAHA within 90 days.

In the case of Moderate Rehabilitation Single Room Occupancy (SRO) individuals, the required documentation must be provided within 90 calendar days from the date of admission into the program. The PHA must grant one additional 90-day extension if it determines that the applicant’s failure to comply was due to circumstances that were beyond the applicant’s control and could not have been reasonably foreseen.

SAHA Policy
SAHA does not operate Moderate Rehabilitation Single Room Occupancy (SRO).

If an applicant family includes a child under 6 years of age who joined the household within the 6 months prior to the date of voucher issuance, an otherwise eligible family may be admitted to the program and the family must provide documentation of the child’s SSN within 90 days of the effective date of the initial HAP contract. A 90-day extension will be granted if the PHA determines that the participant’s failure to comply was due to unforeseen circumstances and was outside of the participant’s control.

SAHA Policy
SAHA will grant one additional 90-day extension if needed for reasons beyond the applicant’s control, such as delayed processing of the SSN application by the SSA, natural disaster, fire, death in the family, or other emergency.

When a participant requests to add a new household member who is at least 6 years of age, or who is under the age of 6 and has an SSN, the participant must provide the complete and accurate SSN assigned to each new member at the time of reexamination or recertification, in addition to the documentation required to verify it. The PHA may not add the new household member until such documentation is provided.

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When a participant requests to add a new household member who is under the age of 6 and has not been assigned an SSN, the participant must provide the SSN assigned to each new child and the required documentation within 90 calendar days of the child being added to the household. A 90-day extension will be granted if the PHA determines that the participant’s failure to comply was due to unforeseen circumstances and was outside of the participant’s control. During the period the PHA is awaiting documentation of the SSN, the child will be counted as part of the assisted household.

SAHA Policy
SAHA will grant one additional 90-day extension if needed for reasons beyond the participant’s control such as delayed processing of the SSN application by the SSA, natural disaster, fire, death in the family, or other emergency.

Social security numbers must be verified only once during continuously assisted occupancy.

SAHA Policy
SAHA will verify each disclosed SSN by:

Obtaining documentation from applicants and participants that is acceptable as evidence of social security numbers
Making a copy of the original documentation submitted, returning it to the individual, and retaining a copy in the file folder
Once the individual’s verification status is classified as “verified,” the PHA may, at its discretion, remove and destroy copies of documentation accepted as evidence of social security numbers. The retention of the EIV Summary Report or Income Report is adequate documentation of an individual’s SSN.

SAHA Policy
Once an individual’s status is classified as “verified” in HUD’s EIV system, SAHA will remove and destroy copies of documentation accepted as evidence of social security numbers.
7-II.C. DOCUMENTATION OF AGE
A birth certificate or other official record of birth is the preferred form of age verification for all family members. For elderly family members an original document that provides evidence of the receipt of social security retirement benefits is acceptable.

SAHA Policy
If an official record of birth or evidence of social security retirement benefits cannot be provided, SAHA will require the family to submit other documents that support the reported age of the family member (e.g., school records, driver's license if birth year is recorded) and to provide a self-certification.

Age must be verified only once during continuously assisted occupancy.

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7-II.D. FAMILY RELATIONSHIPS
Applicants and program participants are required to identify the relationship of each household member to the head of household. Definitions of the primary household relationships are provided in the Eligibility chapter.

SAHA Policy
Family relationships are verified only to the extent necessary to determine a family’s eligibility and level of assistance. Certification by the head of household normally is sufficient verification of family relationships.

Marriage
SAHA Policy
Certification by the head of household is normally sufficient verification. If SAHA has reasonable doubts about a marital relationship, SAHA will require the family to document the marriage.

A marriage certificate generally is required to verify that a couple is married.

In the case of a common law marriage, the couple must demonstrate that they hold themselves to be married (e.g., by telling the community they are married, calling each other husband and wife, using the same last name, filing joint income tax returns).

Separation or Divorce
SAHA Policy
Certification by the head of household is normally sufficient verification. If SAHA has reasonable doubts about a separation or divorce, SAHA will require the family to provide documentation of the divorce or separation.

A certified copy of a divorce decree, signed by a court officer, is required to document that a couple is divorced.

A copy of a court-ordered maintenance or other court record is required to document a separation.

If no court document is available, documentation from a community-based agency will be accepted.

Absence of Adult Member
SAHA Policy
If an adult member who was formerly a member of the household is reported to be permanently absent, the family must provide evidence to support that the person is no longer a member of the family (e.g., documentation of another address at which the person resides such as a lease or utility bill), if SAHA so requests.

Foster Children and Foster Adults
SAHA Policy
Third-party verification from the state or local government agency responsible for the placement of the individual with the family is required.

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7-II.E. VERIFICATION OF STUDENT STATUS
General Requirements
SAHA Policy
SAHA requires families to provide information about the student status of all students who are 18 years of age or older. This information will be verified only if:

The family reports full-time student status for an adult other than the head, spouse, or cohead.

The family reports childcare expenses to enable a family member to further their education.

The family includes a student enrolled in an institution of higher education.

Verification of full-time student status includes all of the following:

Written verification from the registrar’s office or other school official.

School records indicating enrollment in sufficient credits to qualify as full-time by the educational institution (e.g. class schedule).

Full-time students that are eighteen (18) years of age or older are required to provide an unofficial transcript from each institution of higher education at the time of the family’s annual reexamination or as requested by SAHA staff.

Final report of units completed will be required at the family’s annual reexamination or as requested by SAHA staff.

Full-time students that are eighteen (18) years of age or older and are employed are required to provide an unofficial transcript from each institution of higher education at the time of the family’s annual reexamination or as requested by SAHA staff.

Restrictions on Assistance to Students Enrolled in Institutions of Higher Education This section applies only to students who are seeking assistance on their own, separately from their parents. It does not apply to students residing with parents who are seeking or receiving HCV assistance.

SAHA Policy
In accordance with the verification hierarchy described in section 7-I.B, SAHA will determine whether the student is exempt from the restrictions in 24 CFR 5.612 by verifying any one of the following exemption criteria:

The student is enrolled at an educational institution that does not meet the definition of institution of higher education in the Higher Education Act of 1965 (see section Exhibit 3-2).

The student is at least 24 years old.

The student is a veteran, as defined in section 3-II.E.

The student is married.

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The student has at least one dependent child, as defined in section 3-II.E.

The student is a person with disabilities, as defined in section 3-II.E, and was receiving assistance prior to November 30, 2005.

If SAHA cannot verify at least one of these exemption criteria, SAHA will conclude that the student is subject to the restrictions on assistance at 24 CFR 5.612. In addition to verifying the student’s income eligibility, SAHA will then proceed to verify either the student’s parents’ income eligibility (see section 7-III.M) or the student’s independence from their parents (see below).

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Independent Student
SAHA Policy
SAHA will verify a student’s independence from their parents to determine that the student’s parents’ income is not relevant for determining the student’s eligibility by doing all of the following:

Either reviewing and verifying previous address information to determine whether the student has established a household separate from their parents for at least one year, or reviewing and verifying documentation relevant to determining whether the student meets the U.S. Department of Education’s definition of independent student (see section 3-II.E)
Reviewing the student’s prior year income tax returns to verify the student is independent or verifying the student meets the U.S. Department of Education’s definition of independent student (see section 3-II.E)
Requesting and obtaining written certification directly from the student’s parents identifying the amount of support they will be providing to the student, even if the amount of support is $0, except in cases in which SAHA determines that the student is a vulnerable youth (see section 3-II.E)
7-II.F. DOCUMENTATION OF DISABILITY
The PHA must verify the existence of a disability in order to allow certain income disallowances and deductions from income. The PHA is not permitted to inquire about the nature or extent of a person’s disability [24 CFR 100.202(c)]. The PHA may not inquire about a person’s diagnosis or details of treatment for a disability or medical condition. If the PHA receives a verification document that provides such information, the PHA will not place this information in the tenant file. Under no circumstances will the PHA request a participant’s medical record(s). For more information on health care privacy laws, see the Department of Health and Human Services’ website at http://www.hhs.gov/ocr/privacy/.

The above cited regulation does not prohibit the following inquiries, provided these inquiries are made of all applicants, whether or not they are persons with disabilities [VG, p. 24]:

Inquiry into an applicant’s ability to meet the requirements of ownership or tenancy Inquiry to determine whether an applicant is qualified for a dwelling available only to persons with disabilities or to persons with a particular type of disability Inquiry to determine whether an applicant for a dwelling is qualified for a priority available to persons with disabilities or to persons with a particular type of disability Inquiring whether an applicant for a dwelling is a current illegal abuser or addict of a controlled substance
Inquiring whether an applicant has been convicted of the illegal manufacture or distribution of a controlled substance
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Family Members Receiving SSA Disability Benefits
Verification of the receipt of disability benefits from the Social Security Administration (SSA) is sufficient verification of disability for the purpose of qualifying for waiting list preferences (if applicable) or certain income disallowances and deductions [VG, p. 23].

SAHA Policy
For family members claiming disability who receive disability benefits from the SSA, SAHA will attempt to obtain information about disability benefits through the HUD Enterprise Income Verification (EIV) system. If documentation from HUD’s EIV System is not available, SAHA will request a current (dated within the same benefit year) SSA benefit verification letter from each family member claiming disability status. If the family is unable to provide the document(s), SAHA will ask the family to request a benefit verification letter by either calling SSA at 1-800-772-1213, or by requesting it from www.ssa.gov. Once the applicant or participant receives the benefit verification letter they will be required to provide it to SAHA.

Family Members Not Receiving SSA Disability Benefits
Receipt of veteran’s disability benefits, worker’s compensation, or other non-SSA benefits based on the individual’s claimed disability are not sufficient verification that the individual meets HUD’s definition of disability in 24 CFR 5.403.

SAHA Policy
For family members claiming disability who do not receive disability benefits from the SSA, a knowledgeable professional must provide third-party verification that the family member meets the HUD definition of disability. See the Eligibility chapter for the HUD definition of disability. The knowledgeable professional will verify whether the family member does or does not meet the HUD definition.

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7-II.G. CITIZENSHIP OR ELIGIBLE IMMIGRATION STATUS [24 CFR 5.508] Overview
Housing assistance is not available to persons who are not citizens, nationals, or eligible immigrants. Prorated assistance is provided for "mixed families" containing both eligible and ineligible persons. A detailed discussion of eligibility requirements is in the Eligibility chapter.

This verifications chapter discusses HUD and PHA verification requirements related to citizenship status.

The family must provide a certification that identifies each family member as a U.S. citizen, a U.S. national, an eligible noncitizen or an ineligible noncitizen and submit the documents discussed below for each family member. Once eligibility to receive assistance has been verified for an individual it need not be collected or verified again during continuously-assisted occupancy. [24 CFR 5.508(g)(5)]
U.S. Citizens and Nationals
HUD requires a declaration for each family member who claims to be a U.S. citizen or national.

The declaration must be signed personally by any family member 18 or older and by a guardian for minors.

The PHA may request verification of the declaration by requiring presentation of a birth certificate, United States passport or other appropriate documentation.

SAHA Policy
Family members who claim U.S. citizenship or national status will not be required to provide additional documentation unless SAHA receives information indicating that an individual’s declaration may not be accurate.

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Eligible Immigrants
Documents Required
All family members claiming eligible immigration status must declare their status in the same manner as U.S. citizens and nationals.

The documentation required for eligible noncitizens varies depending upon factors such as the date the person entered the U.S., the conditions under which eligible immigration status has been granted, age, and the date on which the family began receiving HUD-funded assistance. Exhibit 7-1 at the end of this chapter summarizes documents family members must provide.

PHA Verification [HCV GB, pp. 5-3 and 5-7]
For family members age 62 or older who claim to be eligible immigrants, proof of age is required in the manner described in 7-II.C. of this plan. No further verification of eligible immigration status is required.

For family members under the age of 62 who claim to be eligible immigrants, the PHA must verify immigration status with the United States Citizenship and Immigration Services (USCIS).

The PHA will follow all USCIS protocols for verification of eligible immigration status. 7-II.H. VERIFICATION OF PREFERENCE STATUS
The PHA must verify any preferences claimed by an applicant that determined placement on the waiting list.

SAHA Policy

1. United States Military Veteran Preference: A veteran is a person who served in the active military, naval, or air service and who was discharged or released from such service under conditions other than dishonorable. Form DD-214 with a discharge status of other than dishonorable, or equivalent verification, must be provided at their eligibility interview appointment.

2. Residency Preference: Residency preference for applicants who live or work in the City of Santa Ana at the time of application. At least two pieces of evidence must be provided for applicants who live or work in the City of Santa Ana including but not limited to a lease, utility bills, bank statements, or paycheck stubs (“proof of the residency preference”). The residency preference claimed at the time of the applicant applied for the program will be verified when the applicant is selected off of the waiting list. Applicants who are unable to provide proof of the residency preference will be removed from the waiting list. Applicants who live or work in the unincorporated areas of Santa Ana will not receive the residency preference.
a. Mainstream vouchers are intended to facilitate access to housing for individuals with disabilities, including for individuals who reside in institutional or other segregated settings that may not be located in the geographic area that is typically served by a PHA. Consequently, HUD waived 24 CFR 982.207(b)(1) and established an alternative EXHIBIT 1
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requirement under which a PHA cannot apply a residency preference to Mainstream voucher applicants (excluding project-based vouchers). b. A PHA also cannot apply a resident preference to VASH voucher applicants.

Families who have been terminated due to insufficient funding SAHA will offer an absolute preference to any family that has been terminated from its HCV program due to insufficient program funding. Special Purpose Vouchers will be the last to be terminated due to insufficient funding and first to be re-instated.

Homeless Individuals and Families Set-Aside Preference
In accordance with PIH Notice 2023-13, SAHA will accept direct referrals to the HCV program for the following target population:

Homeless Individuals and Families: The number of homeless individuals and families who can qualify for this preference and successfully lease a unit with their voucher will be limited to 50% of the total number of vouchers that become available through annual turnover in the previous calendar year. To qualify for this preference, homeless individuals and families must be referred by agencies with a contract or Memorandum of Understanding (MOU) in place with the Housing Authority or City of Santa Ana. The referring agency must provide a certification of the family’s homeless status. Additionally, families already registered on the Waiting List who declare themselves as homeless, but are not referred by a CBO must provide a certification of their homeless status from an agency that has an MOU in place with the Housing Authority. This set-aside preference has been documented by SAHA using generally accepted data sources. All homeless individuals and families must qualify for the Residency Preference.

Families who have been involuntarily displaced:

Families who have been involuntarily displaced due to a disaster (e.g., fire, flood, earthquake) or eminent domain. The preference depends on funding availability. If insufficient funds are available, then applicants will be prioritized based upon elderly and disabled families first.

Foster Youth to Independence (FYI) Vouchers
The waiting list for FYI vouchers is continually open for referrals from the Orange County Social Services Agency (Santa Ana’s Public Child Welfare Agency) as long as there are FYI vouchers available.

PHAs may choose to create a preference in their regular HCV program for persons whose FYI assistance is expiring and will lack adequate housing as a result of their termination from the program, or other similar category.

As required by statute, an FYI voucher may only be used to provide housing assistance for youth for a maximum of 36 months. However, youth who first lease a unit with an FYI voucher after the date of enactment of the Fostering Stable Housing Opportunities (FSHO) amendments may receive an extension EXHIBIT 1
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of the 36-month time limit of assistance for up to an additional 24 months if they meet the requirements of FSHO. FSHO applies to eligible youth who first leased or leases a unit after the date of enactment of FSHO, December 27, 2020, which includes youth who will be assisted with funding under this Notice. See HUD’s FSHO implementation notice published in the Federal Register on January 24, 2022 (87 FR 3570).

SAHA will provide a selection preference for FYI voucher holders who are terminated due to the time limit on assistance in accordance with this policy.

Emergency Housing Vouchers (EHV)
In March 2025, HUD notified PHAs of their final allocation to obligate all EHV HAP funds that remain available to HUD under the American Rescue Plan Act of 2021 (P.L. 117-2). According to the notice: “After this final allocation, the Department will provide no additional EHV CY HAP Renewal funding allocations to PHAs.”
Therefore, SAHA is making the waiting list continually open for EHV vouchers that are subject to termination due to this final funding allocation by HUD. Specifically, SAHA will provide a preference in the regular HCV program for persons whose EHV assistance is expiring and will lack adequate housing as a result of their termination from the program. In accordance with this policy, SAHA will provide a selection preference for EHV voucher holders who are terminated due to the lack of renewal funding from HUD.

This preference is allowed under Question # 45 of the Emergency Housing Vouchers Frequently Asked Questions (FAQs) v.9 which states, “Funds appropriated for the EHV program are available for obligation by HUD until September 30, 2030. These funds will be cancelled as a matter of law on September 30, 2035, per 31 U.S.C 1552. Prior to 2030, PHAs may consider options to ensure continued assistance to EHV families including but not limited to issuing regular Housing Choice Vouchers (HCV) to the affected EHV households. Such families would need to be pulled from the waiting list. to facilitate this process, PHAs may choose to create a preference in their regular HCV program for persons whose EHV assistance is expiring and will lack adequate housing as a result of their termination from the program, or other similar category.”
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PART III: VERIFYING INCOME AND ASSETS
Chapter 6 of this plan describes in detail the types of income that are included and excluded and how assets and income from assets are handled. Any income reported by the family must be verified. This part provides PHA policies that supplement the general verification procedures specified in Part I of this chapter.
7-III.A. EARNED INCOME
Tips
SAHA Policy
Unless tip income is included in a family member’s W-2 by the employer or in UIV verification sources, persons who work in industries where tips are standard will be required to sign a certified form of tips received for the previous two pay periods to anticipate tips in the coming year.

Wages
SAHA Policy
When SAHA requires third-party verification of wages, for wages other than tips, the family must provide originals of the two most current, consecutive pay stubs.

EXHIBIT 1
City Council 5 – 400 7/15/2025

7-III.B. BUSINESS AND SELF EMPLOYMENT INCOME
The PHA must obtain written, third-party verification when the income type is not available in EIV. This includes income from self-employment.

SAHA Policy
Business owners and self-employed persons will be required to provide one or more of the following forms of verification:

A statement of business income and expenses verified for accuracy by the business owner(s) or self-employed person(s).

SAHA will provide a format for any person who is unable to provide such a statement to record income and expenses for at least the last three months – including receipts, or other approved verification of the expense.

The business owner/self-employed person will be required to submit the information requested and to certify to its accuracy at all future reexaminations.

If the receipts or other approved verification of the expense is not provided, then SAHA will not allow the expense deduction.

Income tax returns with corresponding official tax forms and schedules attached and including third-party receipt of transmission for income tax return filed (i.e., tax preparer’s transmittal receipt, summary of transmittal from online source, etc.).

If accelerated depreciation was used on the tax return or financial statement, an accountant's calculation of depreciation expense, computed using straight-line depreciation rules.

IRS Transcript
For self-employed individuals who claim they do not have to file tax returns, SAHA will obtain a completed copy of IRS Form 4506-T to verify that no return has been filed.

For those employed in “gig employment” (i.e., those in formal agreements with ondemand companies such as Uber, Lyft, or DoorDash), SAHA will review the printed statement of monthly income from the applicable app for all hours worked and pay received as well as the Schedule C of the individual’s tax return and the corresponding IRS Form 1099 or 1099k. SAHA may also provide a format for the individual to declare their income and expenses for at least the last three months, including receipts or verification of the expenses. If the receipts or verification of the expenses is not provided, then SAHA will not allow the expense deduction.

SAHA will provide a format for any person who is unable to provide such a statement to record income and expenses for the coming year. The business owner/self-employed person will be required to submit the information requested and to certify to its accuracy at all future reexaminations. At any reexamination SAHA may request documents that support submitted financial statements such as manifests, appointment books, cash books, or bank statements.

EXHIBIT 1
City Council 5 – 401 7/15/2025

If a family member has been self-employed less than three (3) months, SAHA will accept the family member's certified estimate of income and schedule an interim reexamination in three (3) months. If the family member has been self-employed for three (3) to twelve (12) months SAHA will require the family to provide documentation of income and expenses for this period and use that information to project income.

EXHIBIT 1
City Council 5 – 402 7/15/2025

7-III.C. PERIODIC PAYMENTS AND PAYMENTS IN LIEU OF EARNINGS For policies governing streamlined income determinations for fixed sources of income, please see Chapter 11.

Social Security/SSI Benefits [Notice PIH 2023-27]
Verification requirements for Social Security (SS) and Supplemental Security Income (SSI) benefits differ for applicants and participants.

For applicants, since EIV does not contain SS or SSI benefit information, the PHA must ask applicants to provide a copy of their current SS and/or SSI benefit letter (dated within the appropriate benefit year) for each family member that receives SS and/or SSI benefits. If the family is unable to provide the document or documents, the PHA should help the applicant request a benefit verification letter from SSA’s website at www.ssa.gov or ask the family to request one by calling SSA at 1-800-772-1213. The PHA must obtain the original benefit letter from the applicant, make a photocopy of the document for the file, and return the original to the family.

For participants, the PHA must obtain information through the HUD EIV system and confirm with the participants that the current listed benefit amount is correct.  If the participant agrees with the amount reported in EIV, the PHA must use the EIVreported gross benefit amount to calculate annual income from Social Security. PHAs are required to use the EIV-reported SS and SSI benefit amounts when calculating income unless the tenant disputes the EIV-reported amount. For example, an SSA benefit letter may list the monthly benefit amount as $450.80 and EIV displays the amount as $450.00. The PHA must use the EIV-reported amount unless the participant disputes the amount.  If the participant disputes the EIV-reported benefit amount, or if benefit information is not available in EIV, the PHA must request a current SSA benefit verification letter (dated within the appropriate benefit year) from each family member that receives SS and/or SSI benefits.

If the family is unable to provide the document or documents, the PHA should help the participant request a benefit verification letter from SSA’s website at www.ssa.gov or ask the family to request one by calling SSA at 1-800-772-1213. The PHA must obtain the original benefit letter from the participant, make a photocopy of the document for the file, and return the original to the family.

Photocopies of social security checks or bank statements are not acceptable forms of verification for SS/SSI benefits.

EXHIBIT 1
City Council 5 – 403 7/15/2025