Last week, Navigate’s own Voucher Specialist, DeAnna Baker, spoke at the SAHMA Mississippi State Meeting on the TRACS Update.
One of the talking points she brought up were common discrepancies in voucher processing. The differences among Move In certifications, Initial certifications, and Interim recertifications.
- Move In (MI) is used only when a new tenant moves into the property.
- Initial (IC) is used only when an in-place tenant begins receiving a subsidy.
- Interim (IR) is used only when reporting a change in family circumstances (i.e. income, deductions, or composition) effective any time other than Annual Recertification (AR). Interim recertifications (IR) must be effective on the first day of the month unless tied to a Unit Transfer (UT).
DeAnna also distinguished between a Move In/Out and a Unit Transfer (UT): If a resident is moving to another unit within the same building, it must be handled as a Unit Transfer.
MAT User Guide, Chapter 4, 4.1, page 4-6 :
- Tax credit rules for unit transfers depend on whether the transfer is within a building or between buildings. Between building, transfers may be handled differently depending on whether the two buildings are part of a tax credit multiple building projects. In some cases, tax credit rules require a requalification event instead of a UT. This is often implemented as a MO/MI on the tax credit side.
- HUD does NOT want to see a MO/MI in those situations. HUD rules prevail for HUD transactions and a UT must always be implemented as a UT. From a HUD point of view, the household is not requalifying, they are just changing units. Also, keep in mind that it could happen that the tax credit MI will have income that does not have to be reported to HUD because the change is less than the $200 per month threshold.
Another reminder that was mentioned: In the case of the death of a resident, DO NOT TERMINATE subsidy on the tenant. Instead, submit a Move Out (MO) using code 4 (death) with the date of death.
Included in the presentation was a reference to guide to five of the topics discussed in the session:
- Move Outs (MAT40)
- Terminations (MAT65)
- Full Certifications (MAT10)
- Unit Transfers (MAT70)
- Gross Rents (MAT70)
Baker also covered TRACS 203A even though the release date of it seems to be still up in the air since its announcement in 2017. Once 203A goes live, there’s a 5-month transition period where both 202D and 203A will be acceptable for submission. After this transition period, the 6th month after the live date, only TRACS 203A will be acceptable.
