Managing Certification After the Final Compliance Date

This page assists housing counseling agencies (HCAs) to manage certification for their housing counseling program after the final compliance date.

Are you a counselor who is employed with a HUD Participating Housing Counseling Agency and are not yet HUD certified?

View the Six-Step Training Plan

Agency Status After August 1, 2021

Housing counseling agencies must have a sufficient number of HUD certified housing counselors to implement their housing counseling work plans as of August 1, 2021, to remain active in HUD’s housing counseling program. The “sufficient number” of counselors needed to carry out the agency’s work plan is determined by the HCA. HUD Points of Contact (POCs) will work with HCAs on an as-needed basis to understand if the organization has enough certified counselors.

View common questions about the housing counselor Certification after the Final Compliance Date.

housing counseling agency meeting

HCAs should create a plan to maintain enough certified counselors to support HCA capacity. This is essential to the success of HCAs after the compliance date.

When a HUD certified housing counselor is no longer employed by a participating HCA, the HCA must notify their HUD POC within 15 days of the change in staffing. If this is the sole counselor for the HCA, the HCA will be made inactive.

The HCA’s FHA Connection application coordinator must also validate the end of the HUD certified housing counselor's employment by signing into FHAC and complete the steps in the instructions on the HUD Exchange.

New counselors hired after August 1, 2021, or counselors who are not certified as of August 1, 2021, may only perform administrative duties until they are HUD certified.

HUD has contacted HCA leadership to inactivate HCAs who do not have any HUD certified housing counselors as of August 1, 2021. HUD may change an HCA’s status to inactive, in lieu of termination, consistent with 24 CFR 214.200.

Expenses incurred during the period an HCA is placed on inactive status are not eligible for reimbursement. Clients counseled and activities performed while an HCA is in inactive status may not be reported on the HUD-form 9902.

Inactivation vs. Termination

HCAs will be inactive for 90 days or until cured. After 90 days in inactive status, HCAs will be terminated.

  • Inactivated: HCAs have an opportunity to cure the deficiency and become active again, without re-applying to HUD
  • Terminated: HCAs must re-apply to HUD to participate in HUD’s program in the future

System Maintenance

HCAs need to maintain counselor information in the following systems:

  • FHA Connection: this is where agencies keep a record of their certified counselors on staff.
  • HCS: this is where agencies report activities from HUD certified counselors on form HUD-9902.

Person entering information into computer

Every housing counseling agency requires an FHAC Application Coordinator. The coordinator validates employment of counselors who pass exam. It is recommended that HCAs have at least two application coordinators. Counselors that act as coordinators cannot validate their own employment status in FHAC. Intermediaries can act as the FHAC Application Coordinator for their sub-grantees, affiliates, and branches.

HCAs are responsible for removing certified housing counselors when they leave. The HCA’s FHAC application coordinator must validate the end of the HUD certified housing counselor's employment by signing into FHAC and complete the steps in the instructions on the HUD Exchange.

HUD certified housing counselors and coordinators should maintain data in FHAC by updating personal information, email addresses, etc. Please note the following recommendations for HUD certified housing counselors and FHAC Application Coordinators:

  • Use a personal email address so that if counselors or coordinators move to a new HCA are still able to access the system
  • Create calendar reminders to log in at least once every 90 days to change passwords in order to remain active in the system

Access the full instructions for FHAC application coordinators.

Access the FHAC tip sheet.

The final compliance date for housing counselor certification affects the way that agencies must report counselors on form HUD-9902.

Starting August 1, 2021, the final rule requires HUD participating HCAs only report clients receiving one-on-one counseling by a HUD certified housing counselor. HCAs may only report one-on-one counseling activities conducted by a HUD certified housing counselor.

Starting August 1, 2021, HCAs must only report one-on-one counseling activities conducted by HUD certified housing counselor(s) in their client management system (CMS). A CMS update is not required for FY 2021 reporting. Agencies should use a comment field to record the HUD certified housing counselor 6-digit alpha-numeric identifier (ID), if they do not have an updated CMS. Starting October 1, 2021, CMS systems must have a new data field to record the HUD certified housing counselor ID for FY 2022. Agencies who do not yet have an updated CMS can use a comment field to record the HUD certified housing counselor 6-digit alpha-numeric identifier (ID).

Support for Non-Certified Counselors

Counselors hired after August 1, 2021, may only perform administrative duties until they are HUD certified.

Certification resources will continue to be available for new hires and agency staff to access. You can support your new hires in their efforts to take and pass the certification exam with these resources.

View the Six Steps for Supporting Non-Certified Counselors Training Plan. This is a resource for counselors who are employed with a HUD Participating Housing Counseling Agency and are not yet HUD certified.

woman smiling in group of counselors