Ann Hittner

SHCC

Janet Miller

Miland Services, Inc.

Karon Arnold

Arnold Grounds Apartment Management

Voucher Submission Errors and TRACS 2.0.3.A

Miscellaneous Requests (OARQ, UUTL, etc.) missing an explanation – Include Unit #, Household Name

Negative Balance listed for a Repayment Agreement – This is a fatal error.

Adjustments that don’t total properly – This is a fatal error caused by a software issue.

EIV 5% Penalties – Make SURE you have access to EIV and are using it properly to avoid having voucher penalties.

Common Voucher Errors # 1

Per a HUD Memorandum dated June 2, 2017, all vouchers submitted 12/1/2017 or later MUST have the DUNS Number and TIN Number fields filled or the voucher will receive a Fatal Error.

SHCC has been seeing lots of incorrect numbers-XXXXX1234, 000000000, 9999999.

If you don’t already have a DUNS number, you must register your information in the System for Award Management (SAM) to receive financial assistance from the government.

Work with your software vendor to get these fields updated with the correct information as soon as possible or we may not be able to process your voucher.

Common Voucher Errors - DUNS Numbers # 1

Overdue Annual Recertifications – these will hold up your voucher submission.

Move Ins for households that are established at another subsidized property. Make sure you have proper documentation before moving them in.

Income Exception Codes – Household only need to qualify for subsidy at Move In or Initial. Annuals and Interims that show a household over income do not need a new Income Exception Code.

Common Tenant Data Errors # 1

Gross Rent certifications do not need to be signed by the tenant if the tenant rent isn’t changing.

If the tenant rent does change, you can still transmit the cert without the tenant signature and can have the cert signed within the next 60 days.

Make sure to apply the Gross Rent to all units whenever possible. In many cases, the rent doesn’t get applied to a particular unit.

When you apply a retroactive Gross Rent change, make sure to apply the new rents to any subsequent certifications, as well.

Common Tenant Data Errors – Gross Rent

# 1

TRACS Release 2.0.3.A Industry Specifications is the primary resource managers

must use to research the changes incorporated into this release. This document includes the TRACS 2.0.3.A MAT

User Guide and is available at:

https://www.hud.gov/program_offices/housing/mfh/trx/trxsum

Key Regulatory Resources

Conversion Timeframe

• TRACS 2.0.3.A goes live on ???

• Possibly late 2018, or early 2019 • There will be a 4–month

transition period during which CAs/HUD systems will accept either TRACS 2.0.2.D or 2.0.3.A files.

• We will let you know when the final deadline is approaching.

SSN Requirement Update

The original regulation required all members of an applicant household that had an

assigned social security number to provide acceptable documentation of that number

prior to move in. In the absence of verification of an SSN for any of the members that

had one, the entire household was not permitted to move in.

As of April 7, 2016, via this new Final Rule, owners can now accept applicant

households which include an applicant family member who is under the age of 6 and

who cannot provide a Social Security Number (SSN), provided the child was added

to the household within the last six months prior to the date of move in. The

households will have 90 days and one additional 90-day extension to provide the SSN.

Children Under 6 at MI or IC

SSN Requirement Update

Eligible minors will be identified on HUD Form 50059s by 999-99-0000 as the SSN with no SSN exception code (this is a temporary work around procedure for TRACS 202D). Once the property converts to TRACS 2.0.3.A, entries will appear as: all 9’s for the SSN, and the SSN Exception Code listed as “M”).

Once the SSN is received, the OA should submit an IR (or AR if appropriate) with the correct SSN and remove the SSN Exception Code.

If the SSN is not reported within the 90- or 180-day allotted timeframe, the OA must terminate the tenancy of the household. Note: The OA may continue to receive subsidy during the time they are in pursuit of eviction.

Software Implications

Many agencies will not disclose the SSN of a Foster to either the foster family or to the OA. In those instances, the OA must request a HUD waiver from their Account Executive.

On the certification, the OA should use all 9’s for the SSN of the foster, and submit an SSN Exception Code of F.

Foster SSNs will not be displayed on the printed form 50059.

Additionally, the Birth Date field will display on the form as “00/00/YYYY” for any fosters.

Foster Children Foster Adults

Previous Housing Code 2 – Without or soon to be without housing, should not be used on any certifications effective October 1, 2015 or later. Any certifications that include this code will receive a Fatal Error. This code has been replaced by codes 5 and 6.

• Previous Housing Code 5 – Lacking a Fixed Nighttime Residence

• Previous Housing Code 6 – Fleeing/Attempting to Flee Violence

Previous Housing Code Retired

Expanded Race and Ethnicity Reporting (HUD Form 27061H)

Expanded via Executive Order

New Hispanic Sub-Types

Puerto Rican Mexican, Mexican American, Chicano/a

Cuban Another Hispanic, Latino/a, or Spanish Origin

New Asian Sub-Types

Asian India Filipino

Japanese Vietnamese

Chinese Other Asian

Korean

New Native Hawaiian or Other Pacific Islander Sub-Types

Native Hawaiian Guamanian, Chamorro

Samoan Other Pacific Islander

When owners convert to TRACS 2.0.3.A, they will be required to begin using the updated Race and Ethnic Data Reporting Form (HUD Form 27061H).

Please note, the current version expired

6/30/2017. As of the date of this training, the updated version of this form is not yet publicly available.

Expanded Race and Ethnicity Reporting (HUD Form 27061H)

Differentiates between Termination of Assistance and Suspension of Assistance.

Subsidy suspensions are defined as temporary, and unrelated to any tenant action and tenant maintains right to return.

New Suspension Codes are:

ND – Natural Disaster or Uninhabitable Unit or Presidentially Declared Disaster.

RR – Substantial Rehab or repair –tenant expected to return.

Important Note: Any time there is a rehab, natural disaster, or major repair

that would temporarily displace residents (to include tax credit rehabs),

owners should notify their local HUD office and PBCA to coordinate plans and

ensure appropriate vouchering tasks are completed.

Clarification on Suspension of Subsidy

HUD wants to see a Repayment Agreement any time subsidy was overpaid due to tenant misreporting.

Requirements:

Re-calculate HAP based on new information.

Have the resident sign new or corrected certifications retroactive to the date the subsidy was overpaid.

Have the resident sign the Repayment Agreement.

To set the Repayment up with HUD, you need to submit the new certifications, with a “wash” adjustment in the Repayment Agreements section of the MAT30.

Email a copy of the signed Repayment Agreement to SHCC.

As the resident repays the subsidy, post payments to the voucher.

Repayment Agreement Basics

Owner and PBCA status records for ongoing Subsidy Repayment Agreements have been challenging to reconcile during the monthly voucher cycle.

To better inform HUD of the status of each repayment instance, new fields are being added to the Repayment Agreement section of the voucher.

This change will have a significant impact on the vouchers and the procedures site staff must follow to track the status of all agreements.

Reporting Fields on Subsidy Repayment Agreements

NEW 2.0.3.A Version of the Repayment Agreement Schedule

New Fields Circled

Repayment Agreement Status Codes

AV Active The household is a current resident and is making regular payments.

IA Inactive Agreement

Current resident has missed 3 (or more) consecutive payments. If the resident then makes a payment, their status is returned to Active.

SU Suspended Agreement

Current resident has reduced income and cannot make regular payments. Repayment is temporarily suspended.

TE Terminated Agreement

The OA cannot enforce the agreement terms due to outside influences, including court orders. The Ending Balance should display so HUD knows this was due to a judgment.

CO Completed Agreement

All assistance overpayments have been returned to HUD.

RV Reversed Agreement

The household should not have been subject to a repayment. The agreement is now cancelled.

MA Moved out Active

Former household is making periodic payments. (If 3 or more consecutive missed, use the MO code).

MO Moved out Inactive

Former house hold is not making periodic payments.

Any record with the Status set to AV, SU, MA, or IA must show on the voucher monthly, even if there has been no change. All other Statuses may or may not only be on the voucher once.

Clarifying Repay Field Meaning Beginning Agreement Amount

If this is the first time this Agreement ID is on the voucher, this should be $0. Otherwise, it should equal the Ending Agreement Amount from the prior voucher submission.

Agreement Change Amount

This is the amount that the agreement is changing. On the first submission, it is the total amount of the Agreement. On subsequent submissions, this should be $0 unless the Beginning Agreement Amount was incorrect on a prior submission. Do NOT use this field if the family enters into an additional agreement. In that instance, create a new agreement with a new Agreement ID.

Ending Agreement Amount

If there is a Change Amount, then this field will be the new Repay total, but if there is no Change Amount, then this is the same as the Beginning Agreement Amount field.

Initial 203A Implementation: On the first 2.0.3.A voucher, O/As must transmit the current status of all repayment agreements that have not been paid off for any current residents, whether a payment has been made or not.

Clarifying Repay Field Meanings

Beginning Balance

The amount the household owed prior to any payments that may have been made on the current voucher. This should be $0 on the first submission, then each month after that this field should equal the Ending Balance field from the previous submission.

(Recently added!) Head of Household ID Code

The SSN or TRACS ID of the head of household. This is required for Repayment Agreement transactions that are coded Tenant or None. Never use all 9’s.

Agreement Change Amount and Total Payment

fields may be negative

Ending Agreement Amount =

Beginning Agreement Amount + Agreement Change Amount

Ending Balance =

Beginning Balance + Agreement Change Amount – Total Payment

Amount Requested =

Agreement Change Amount –Total Payment + Amount Retained

New Repayment Calculation Formulas

• The Beginning Agreement Amount must equal the Ending Agreement Amount submitted on the previous record.

• The Beginning Balance must equal the Ending Balance from the previous record. If more than one payment is reported on a voucher, then the payments must display in order so the Beginning Balance makes sense with the previous Ending Balance.

Important Note: TRACS will issue fatal errors for any

incorrect calculations, and the Voucher will be rejected.

New Repayment Calculation Formulas

If a household signs certifications relating to an overpayment of assistance and then agrees to pay the amount in full, you must still submit a Repayment Agreement record via TRACS. HUD has not established a minimum threshold for completing this requirement.

This would display with a Status of CO.

Immediate Payoff Repayments

In TRACS 2.0.3.A, new fatal voucher errors will be generated when submitted repayment agreement records do not adhere to the new repayment calculation formulas. To avoid these fatal errors resulting in payment delays after conversion, you should take the following preparatory steps now:

Ensure you have accounted for a complete inventory of all current subsidy repayments.

For each repayment on that list, Owners that report to a PBCA must ensure both parties reconcile on the original agreement amount and the current ending balance prior to submitting the baseline repayment agreements on the first 2.0.3.A voucher.

Pre-Implementation Steps Owners Must Take Now

# 1

Note: This reconciliation step is not possible for those properties

that do not report to a PBCA. In these instances, it will be crucial

that those owners ensure their ending balances are accurate on the

first 2.0.3.A voucher.

Questions?

Thanks for participating!

Ann Hittner, Director of HAP Southwest Housing Compliance Corporation

1124 S. IH 35, Austin, Texas 78704 Email: annh@shccnet.org

Web: www.shccnet.org