HUD HCV Guidebook § 2.1.1

PHAs are permitted to implement streamlined requirements for verifying and adjusting fixed income sources
over a three-year cycle for families with an unadjusted income consisting of 90 percent or more from fixed
income sources as defined in section 2.2.1. PHAs must also establish policies regarding whether and how to
adjust any non-fixed income sources in the second and third years of a three year cycle. If PHAs choose to
implement this streamlined type of income determination at annual reexamination, they must9 fully reverify
and recalculate the income every 3 years. PHAs must10 adopt these policies in their administrative plan.

In the initial year of a three-year cycle, PHAs complete an annual income determination consistent with all
applicable HUD regulations and guidance. In the second and third year of the three-year cycle, PHAs obtain
from the family a certification that their fixed income sources have not changed, and that the family’s income
is still made of at least 90 percent from fixed income sources. If the family provides that certification in years
two and three, the PHA will adjust the family’s fixed income sources by the Cost of Living Adjustment (COLA)
that is applicable to that fixed income source instead of fully reverifying and recalculating the income
source.11

PHAs must also provide a reexamination of non-fixed incomes sources. PHAs may choose whether to fully
verify non-fixed sources of income or adjust non-fixed sources of income by applying an inflation factor, but
this policy must be included in the Administrative Plan. Applying a mandatory inflation factor may result in an
increase in requests for interim reexaminations if they family did not actually receive an increase in non-fixed
income.

Table 2 demonstrates how the streamlined income determination in years 2 and 3 would differ from the
regular full income determination in year 1.

9
    24 CFR § 982.516(b)(5)
10 24 CFR § 982.54
11
  24 CFR § 982.516(b)(3)(ii); Streamlining Administrative Regulations for Multifamily Housing Programs and
Implementing Family Income Reviews Under the Fixing America’s Surface Transportation (FAST) Act, 82 Federal
Reg. 58335 (December 12, 2017)

Table 2: PHA Initial Adoption of Streamlined Income Determinations Reexamination Timeline
 Year 1                 PHA completes an annual reexamination with a full income determination
                        (including third party verification) of all income sources
 Years 2 & 3           PHA completes an annual reexamination with the following streamlined income
                       determination for each type of source:
                          Fixed Income – Applies inflation adjustment factor; does not collect third party
                           verification
                          Non-fixed Income – PHA has discretion to either adjust or use previous year’s
                           calculation. PHAs are still responsible for reviewing and following up on
                           discrepancies regarding income sources in EIV.
                          Assets and Deductions – Completes verification and calculation of assets and
                           deductions
 Year 4                Cycle begins again. PHA completes an annual reexamination with a full income
                       determination (including third party verification) of all income sources, assets, and
                       deductions

PHAs are still required12 to follow-up on any discrepancies or new sources of income reported in HUD’s
Enterprise Income Verification system. All income sources must13 be fully reverified and recalculated every 3
years.