HUD HCV Guidebook § 7.4.2
Receipt of Payments for Billing Arrangements No Longer in Effect (HUD HCV Guidebook)
Operative Text
In all cases where the receiving PHA receives payments for billing arrangements no longer in effect, the
receiving PHA is responsible for returning the full amount of the overpayment (including HAP and
administrative fees) to the initial PHA.
If billing payments have continued for billing arrangements no longer in effect, HUD may take the following
actions:
1. Direct the receiving PHA not to utilize their administrative fee reserve account in accordance with
24 CFR 982.155(b)(3).
2. Reduce the receiving PHA’s administrative fees by up to 10 percent of the monthly billing amount
(HAP and Administrative Fee) in question for each month the payments continued after the billing
arrangement was terminated. The reduction would be applied to the PHA’s prorated administrative
fee (assuming that a pro-ration factor applies to the PHA administrative fees during this period).
HUD will consider the circumstances of the particular case in making this determination. For
example, if the receiving PHA was billing the initial PHA $600 a month on behalf of a family and
collected four monthly billing payments beyond the billing arrangement termination date (for a
total of $2,400), the receiving PHA is responsible for returning $2,400 to the initial PHA. In
addition, HUD may reduce the PHA’s administrative fee by up to $240 as sanction for failing to
terminate the billing arrangement in a timely manner.
If HUD decides to take any of the actions described above, the PIH field office with jurisdiction over the
receiving PHA will send a letter to the receiving PHA informing the receiving PHA of such action. The PIH field
office must98 send a copy of the letter to the HCV Financial Management Center (FMC) and the HCV Financial
Management Division (FMD). HUD may also further reduce the administrative fee if the receiving PHA does not
promptly return the overpayment to the initial PHA. This general policy does not in any way restrict the PIH
field office Director from exercising additional remedial action.
See Exhibit 3 for guidance on how to record refunded amounts in the financial records by both the initial PHA
and the receiving PHA.
98
PIH Notice 2016-09(16)(c)
Moves and Portability 26Under HUD Housing Choice Voucher Guidebook § 7.4.2, when a receiving Public Housing Authority (PHA) continues to collect billing payments after a portability billing arrangement has ended, it is required to return the full overpayment — covering both Housing Assistance Payments (HAP) and administrative fees — to the initial PHA. Beyond repayment, HUD retains authority to impose financial sanctions, including restricting use of the receiving PHA's administrative fee reserve account or reducing its administrative fees by up to 10 percent of the monthly billing amount for each month payments improperly continued. HUD evaluates the specific circumstances of each case before determining what corrective actions to apply, and further reductions may follow if repayment is not made promptly.
Plain English — not legal advice.
Section § 7.4.2 of the HUD Housing Choice Voucher Guidebook does not directly govern private landlord conduct, but it shapes the financial environment in which Housing Choice Voucher payments flow between PHAs. Landlords participating in the voucher program generally benefit from understanding that billing arrangements between PHAs have defined termination points, and that payment disruptions can arise when those arrangements lapse. Operators who receive HAP payments through portability arrangements may want to maintain clear communication with the relevant PHA to ensure payment continuity is not affected by inter-agency billing disputes governed by § 7.4.2.
General guidance for property managers — not legal advice for your specific situation. Consult an attorney for advice on your case.
For voucher holders who have moved under portability, § 7.4.2 establishes that the PHAs involved — not the tenant — bear responsibility for resolving overpayments when billing arrangements lapse. If a tenant believes their housing assistance has been disrupted due to a billing dispute between a receiving and initial PHA, they may contact their receiving PHA directly to inquire about the status of their billing arrangement. Tenant-rights organizations familiar with the Housing Choice Voucher program can help explain how inter-PHA billing issues under § 7.4.2 might affect a household's assistance and what general options exist for seeking clarification.
General guidance for tenants — not legal advice for your specific situation. Consult a tenant-rights organization or attorney for advice on your case.
Generated September 26, 2026 — auto-generated, not yet human-reviewed. See /transparency for methodology.
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