Can a person receiving CDBG funded public services self-certify income?
Date Published: May 2015
CDBG regulations permit self-certification of income for public service activities as referenced in 24 CFR 570.506(b) It is important to note that grantees should develop their own policies and procedures relating to a self-certification program. These policies and procedures would include such items as the definition of income, income verification (third party verification or review of documents provided by the applicant) what activities will be allowed to use self-certification, monitoring requirements and training of grantee and subrecipient staff. We recommend that you request source documentation for 20% of the certifications and inform the beneficiary that all sources of income and assets must be included when calculating annual income. Depending on your policies and procedures, you would verify income through third party verification or review of documents. In the CDBG program a grantee or subrecipient need only document that the beneficiary is low-and moderate-income at the time CDBG assistance is provided. There is no re-qualification of income once assistance has been provided. There is no need to collect annual income information on existing clients that have been previously qualified and continue to be assisted.
HUD recommends using the Self Certification of Annual Income by Beneficiary Form contained in the CPD Income Eligibility Calculator. This form contains all the required certifications and warnings. It should be noted that using a self-certification approach to income documentation can put an activity at possible risk if the beneficiary is later audited and determined to be over the applicable income limit.