Date Published: July 2014
An agency can enlist the help of an industry expert in providing education. However, a housing counselor has to be primarily responsible and present for the provision of the education services. Further, the Dodd-Frank Act states that counselors must be HUD certified to provide these services, and HUD soon will publish a final rule implementing that requirement.
If an agency provides online education, then the counseling agency must be able to demonstrate that clients learned about and accessed the web-based education through the actions, for example marketing and outreach, of the counseling agency.
Additionally, one of the following bullets must apply:
The housing counseling regulations and handbook do not prohibit hiring counselors via the 1099 process to provide counseling services for participating agencies. As long as the counselor works for the agency, and the agency is required to exercise control/oversight over the counselor’s activities, then the agency is in compliance with HUD. The agency must not hand over entirely all of its housing counseling activities to be provided by another group.