Client Follow-Up and Termination Guide

HUD requires that housing counseling agencies record the frequency and method of follow-up. This guide provides guidance on the purpose of follow-up and helps intermediaries and housing counseling agencies ensure that client files do not remain open indefinitely.


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Follow-up consists of the following elements:

  • Participating agencies must make a reasonable effort to have follow-up communication with the client to ensure that the client is progressing toward his or her housing goal, to modify or terminate housing counseling, and to learn and report outcomes.
  • Client follow-up should be conducted by a HUD certified housing counselor. The counselor should make reasonable efforts to conduct a verbal (in person or via phone) follow-up session, within the first 60 days of no client contact.
  • If unsuccessful, after two attempts to conduct a verbal follow-up session, the counselor must write a letter or send an email to the client stating that such efforts have been made and inform the client that there is a need for follow-up communication.
  • The letter must request that the client contact the housing counseling agency no later than 30 days from the date of the letter, to help the agency assess if there is a need for follow-up communication.

Checking in with Clients

Counseling services continue after the initial session. Periodically, counselors should ask their clients:

  • Have next steps in the Client Action Plan been accomplished?
  • Should the Client Action Plan be modified?
  • Have obstacles been resolved, outcomes achieved, and/or services terminated?


  • Many clients need encouragement to continue saving for a home, or support in dealing with a bank or a landlord. Clients may also face new obstacles to realizing their housing goals and need help in understanding how to deal with this new situation.
  • The initial counseling session provides a good base from which the client action plan can be launched, but it may also require modifications or adjustments. Follow-up by the counselor allows for a check-in on progress, identification of outcomes for the HUD Form 9902, and the opportunity to provide advice and information.
  • When following up with a client, the counselor should seek to understand what progress has been made since the initial counseling session such as asking if any steps in the Client Action Plan have been accomplished. Remember, the plan can be modified if need be and the counselor should discuss the usefulness of the plan with the client, particularly if circumstances have changed.
  • Counselors may also find that clients have achieved reportable impacts that should be included in the agency’s 9902 Agency Activity Report. For example, after talking to the client after the initial counseling session, the counselor may discover that the client hoping to purchase a home has improved their financial capacity by eliminating some debt or improving their credit score.
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Helpful Resource

See the Capacity Building Toolkit on Client Action Plan: Required Elements and Best Practices for additional information on follow-up and the Client Action Plan.


  • Counselors should attempt to contact client by email, phone, or letter no later than 60 days from initial session.
  • Written communication should state that contact has been attempted and there is a need for communication from them within 30 days.
  • After two unsuccessful attempts, counselors should contact via email or letter.
  • All attempts at contact should be documented and included in the client file.


Termination consists of the following elements:

  • The housing counseling agency must document in the client’s file when housing counseling services are terminated.
  • The housing counselor must notate the client’s file with the date and cause/explanation of termination. Client files must not remain open indefinitely.
  • If the agency does not have any client contact within a 90-day period, the agency must not bill or count that client as an active file against any future billing periods unless client contact is reinitiated.
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Helpful Resource

See the Housing Counseling 9902 Online Toolkit for additional information on completing federal grant requirements and reporting.


  • Client files must eventually be closed, whether housing goals are met or not.
  • When termination occurs, the counselor must describe the resolution of client’s case, such as:
    • Successful attainment of housing goals
    • Inability to make contact with the client
    • Lack of progress toward goals over time


There can be various reasons why counseling services are terminated, including the following:

  • Termination of counseling may be due to the client being successful in meeting their housing goals, such as purchasing a new home or avoiding foreclosure. However, there may be other reasons for termination, such as the client being non-responsive to the counselor during follow-up.
  • Termination may be warranted, if the agency determines that further counseling will not help the client meet their housing goals or solve their problems, even after the initial session. If there is a lack of progress, whether because the client does not follow the Client Action Plan or circumstances prevent progress, the agency should decide at some point that counseling should be terminated, even if they are in contact with the client.
  • The client may also choose to terminate counseling or other circumstances could require termination such as the inability to contact a client impacted by a natural or man-made disaster.


Termination is a formal process, meaning it must be documented fully.

  • The documentation of the initial session and causes for termination and the date it occurred must be contained in the files. It may also be helpful to document all other dates involved, such as successful and unsuccessful follow-up attempts.
  • Paper and/or electronic documentation is sufficient. If outcomes are realized that may be reported in the 9902, they must be documented there as well.
  • These client records must be retained for a period of 3 years from the date the case file was terminated for housing counseling.
  • If the housing counseling agency is a recipient of a HUD housing counseling grant, then the client files for the housing counseling grant year must be retained for 3 years from the date the final grant invoice was paid by HUD.

Billing Documentation

  • Follow-up and termination also affect how a HUD grant is billed. Keeping a client file open without activity does not mean the grant can be billed.
  • A HUD grant should only be billed when there is activity, either the initial counseling or follow-up activity. If the counselor has been attempting unsuccessfully to contact the client over the 90-day period—60 days of attempting verbal communication and 30 days after a letter or email has been sent—that file should not be considered active at this point and no billing should take place.
  • Any follow-up activities should be documented in the client’s file. The agency can bill for any follow-up activity in the quarter in which it occurred.

Quality Control

Intermediary Roles and Responsibilities

  • Intermediaries need to be sure that network housing counseling staff are aware of the rules regarding follow-up and termination.
  • HUD requirements for follow-up and termination should be written into their agreements with local agencies to reinforce their understanding, including the need for supervisory monitoring of files to check for proper documentation.
  • Intermediaries may also have their own preference for how follow-up and termination should be handled by the local agency and should include such guidance in their agreements.
  • To help agencies implement proper procedures, they may provide templates and checklists that can be used by counselors.


Intermediary Roles and Responsibilities

Intermediaries are responsible for ensuring that subgrantees and affiliates conduct proper follow-up, terminate inactive or completed files, and document activities in the file throughout the counseling process.

Intermediaries should sample subgrantee and affiliate files to see that follow-up is being conducted and recorded properly as required in the Handbook, with notes on discussions that include dates and any decisions made, such as changes to the Client Action Plan. Intermediaries should also check to see if subgrantees and affiliates are properly reporting progress made by clients on 9902s.

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Helpful Resource

Use the Oversight Agency Orientation Toolkit to ensure proper quality control.

Local Housing Counseling Agency Roles and Responsibilities

Housing counseling agencies need to have quality control practices in place that reinforce follow-up and termination practices and should have:

  • Managers regularly check files for evidence of follow-up and to determine if inactive cases are being terminated in a timely manner.
  • Monitoring functions should be described in the quality control plan or supervisory monitoring plan and made available to all housing counselors.
  • The agency provides templates and automated calendar reminders, to help staff adhere to follow-up and termination requirements.