HUD declines to take action preventing immediate rent increase on older adults in affordable housing
Following the historic Social Security Cost of Living Adjustment (COLA) of 8.7% announced earlier this year for 2023, some HUD-assisted residents will see their rents increase. In HUD’s Multifamily Housing programs, HUD residents generally certify income levels annually to determine their tenant rent contribution, set at 30% of their adjusted income, while HUD subsidies cover the rest of the rent .
However, HUD’s Occupancy Handbook (4350.3, Rev-1; Chapter 7-11) states that if a HUD-assisted household’s income increases more than $200 per month at any point within their annual cycle, the housing provider must conduct an off-cycle income recertification, called an interim recertification (IR), which results in an immediate rent increase for the resident.
With a Social Security increase for 2023 of 8.7%, some residents of HUD-assisted housing will have Social Security benefit increases of more than $200 a month and will need to undergo interim recertifications as the COLA takes effect. The 2023 increase is the highest since 1981, and the third highest increase in the nation’s history. The Social Security increase is designed to protect Social Security beneficiaries from inflation; in announcing the COLA for 2023, the Social Security Administration stated that the historic increase was meant to “give seniors peace of mind and breathing room,” in particular by helping older adults on fixed incomes offset the increased cost of gasoline and food. In fact, research shows that the Social Security increase fell short of the high rates of inflation seen for most of 2022.
While the average monthly Social Security increase is projected to reach $140, some LeadingAge members will see higher increases that trigger HUD’s interim recertification limits. LeadingAge members report that essentially all households will dual Social Security incomes will see interim rent increases, because HUD’s $200 threshold is cumulative per household, not per person.
To protect households impacted by the Social Security increase, the Rural Housing Service (RHS), an agency within the United States Department of Agriculture that administers rental assistance programs similar to HUD’s Multifamily Housing programs, recently announced a temporary adjustment of the RHS interim recertification thresholds. For all of calendar year 2023, the RHS threshold has temporarily been raised from 100$ to 200$ monthly to align with HUD rules. RHS’s December 8th announcement applies only to interim recertification (off-cycle, income increase-driven rent increases), not to regular, annual recertifications to adjust rent to a resident’s annual income.
LeadingAge has advocated with HUD to implement a similar temporary waiver, either for some number above $200, for all recipients of Social Security benefits, or to adjust the $200 limit to be per person, not per household. Despite advocacy from LeadingAge and other housing stakeholders, HUD has declined to take action to protect older adults from immediate rent increases, and has instructed housing providers to continue following regular HUD requirements related to interim recertifications and rent increases on older adults.