As a Local Housing Counseling Agency (LHCA) we provide financial literacy workshops and counseling services to clients under the age of 18. How should we count these clients on our HUD 9902, and are we allowed to bill HUD for these clients?
Date Published: November 2017
HUD housing counseling regulations do not stipulate or restrict housing counseling activities based on client age. However, HUD does provide specific guidance on HUD approved housing counseling, education, and outreach topics in Section 3-6 (pg. 23) of the HUD Housing Counseling Handbook. If an agency wishes to seek reimbursement for group education sessions, the session content must meet the requirements outline in the handbook, and a group education file must be maintained, as defined in Section 5-8 (pg. 49) of the HUD Housing Counseling Handbook. A group education file must include a collection of demographic data for all education participants. HUD recommends the agency devise a simple, anonymous form for households to complete at the beginning of group education sessions.