The Public Housing Operating Fund is listed in the certification rule as a “HUD Program where Housing Counseling is funded under the HUD program.” Does that mean that all public housing agencies (PHAs) implementing the Public Housing Program have to become approved to participate in HUD’s Housing Counseling Program, and PHA staff working on the Public Housing Program have to become HUD certified housing counselors?
Date Published: December 2016
No, although there are certain circumstances in which certification is a requirement.
PHAs are allowed to use their Public Housing Operating Funds to provide housing counseling to Public Housing residents, but PHAs are not required to provide housing counseling to Public Housing residents. If a PHA does not directly provide housing counseling, as defined at 24 CFR Part 5.100, then the PHA staff do not have to become HUD certified housing counselors, and the PHA does not have to become approved to participate in HUD’s Housing Counseling Program. Please note that routine administrative activities of the Public Housing Program (e.g., program eligibility determinations, intake, case management, property management, collection of rent) are not housing counseling.
However, if the PHA is providing independent, expert advice customized to the need of the consumer to address the consumers’ housing barriers and achieve their housing goals (that includes an intake, financial and housing affordability analysis, an action plan, and a reasonable effort to have follow-up communication with the client when possible), then this is housing counseling as defined at 24 CFR Part 5.100, and the housing counseling must be provided by a HUD certified housing counselor and the PHA must become approved to participate in HUD’s Housing Counseling Program.