Date Published: July 2014
The Handbook 7610.1 REV-5, Chapter 5-7 does not require a separate “HUD” file, distinct from files utilizing other funding sources. HUD expects that counseling agencies will keep a file for each “unique, distinct provision of counseling services provided to a client”; not based on funding source. Nevertheless, agencies have the option of keeping separate files if they choose to do so.
HUD does require that agencies meet the Office of Management and Budget (OMB) regulations by ensuring that within each client file, the funding sources are clearly identified and are detailed on a time sheet, personnel activity report (PAR), client notes, or all the above. For instance, if half of the hours billed to a client file are for HUD and half of the hours are billed to another allowable source, then the hours must be correctly identified on the invoices and PARS/Time sheets for agencies to be in compliance.
Note: Current NOFAs and grant agreements prohibit grantees and sub-grantees from using HUD Housing Counseling grant funds to reimburse housing counseling activity costs for any counseling recipient for which the specific grantee or sub-grantee received National Foreclosure Mitigation Counseling (NFMC) reimbursement.