COVID-19 suspension of periodic reporting and annual recertification

The California Department of Social Services (CDSS) has issued instructions implementing Executive Order N-29-20 regarding eligibility redeterminations for CalWORKs and CalFresh.  CalWORKs and CalFresh redeterminations are suspended for March, April, and May, 2020, and months or partial months of CalWORKs aid are exempt from being counted toward the 48-month time clock through June, 2020.

For March CalFresh and CalWORKs semi-annual reports (SAR 7s), as many discontinuances as as possible will be stopped using an automated process.  For March SAR 7s that have already been processed, counties must manually rescind any discontinuances as a result of information on the SAR 7.  Processing that resulted in a benefit increase will not be changed.  Counties must stop processing March SAR 7s.

Households will continue to receive benefits in the amount they were eligible for in the month the report was due.  That amount will continue unless the household completes a voluntary or mandatory report resulting in a benefits change.

For March CalFresh annual recertifications and CalWORKs annual redeterminations, households will be granted a new six-month certification period with a recertification due in September, 2020.  All CalFresh households granted a new six month certification period must be issued a notice informing of their new certification period and new recertification due date.  Otherwise, March annual recertifications and redeterminations are handled in the same way as the March SAR 7s.

For April and May CalFresh and CalWORKs SAR 7s, automated mailing of the April and May SAR 7 documents has stopped.  Households will continue to receive benefits in the amount they were eligible for in the month the report was due.  Households must continue to complete all mandatory reports. The waiver of the SAR 7 reporting requirement does not change the household’s originally assigned certification period.  That amount will continue unless the household completes a voluntary or mandatory report resulting in a benefits change.  Counties will disregard any April or May SAR 7s that are submitted.

For April and May CalFresh recertifications and CalFresh retedetminations, households will be granted a new six-month certification period with a recertification due in October or November, respectively.  Automated mailing of May recertification packets will stop.  April recertification packets have already been mailed.  Households will continue to receive benefits in the amount they were eligible for in the month the report was due.  That amount will continue unless the household completes a voluntary or mandatory report resulting in a benefits change.  Counties will disregard any April or May recertifictions or redeterminations that are submitted.

Transitional CalFresh households who have recertification due in March, April or May will need to complete recertification as originally scheduled.

The county welfare department computer systems have stopped all discontinuances set to occur in March, April, May or June for exceeding the 48-month time on aid limit.  Cases that have already been discontinued for exceeding the 48-month time on aid limit in March should be reinstated through June.  People who are on a time-limit extender must continue to meet the extender requirements to remain on aid.

Counties should implement mass informing practices to communicate this change such as a message on their websites, social media and interactive voice response systems. (All County Welfare Directors Letter, March 27, 2020.)

COVID-19 TCAC compliance monitoring and essential management operations

The California Tax Credit Allocation Committee (TCAC) has issued guidance for compliance monitoring and management functions because of COVID-19.  TCAC is cancelling all scheduled inspections until April 30, 2020.  Starting in May, 2020, TCAC will conduct desk audits with physical inspections to occur at a later date.

Day-to-day operation of a property is considered an essential business practice that must continue despite shelter in place and stay at home orders.  TCAC has several recommendations to perform essential business functions and protect the safety of on-site staff and residents including having an emergency protocol plan, limiting office hours and having a sign-up sheet, posting a sign on the window or door of the office about how to apply, and having an online application or drop box to pick up and drop off applications.  (Tax Credit Allocation Committee Memo, March 24, 2020.)

COVID-19 TCAC guidance for recertifications, services and work orders

The California Tax Credit Allocation Committee (TCAC) has issued guidance for recertifications, services and work orders because of COVID-19.  For households that start their 120 day certification/recertification period on or after March 20, 2020, management should provide households with a certification/recertification packet containing all TCAC required forms.  Third party verifications should be sent to employers directly.  Tenants should be able to return document via mail or drop box.  TCAC strongly suggests giving tenants 60 to 90 days to gather and return information.  Management agents can sign forms after the date the tenants signs and returns the forms if it is within the normal 120 day certification/recertification period.

For certifications and recertifications that were in process on March 19, 2020, management should provide households with a certification/recertification packet containing all TCAC required forms. Tenants should be able to return document via mail or drop box.  Management agents can sign forms after the date the tenants signs and returns the forms if it is within the normal 120 day certification/recertification period.

Initial tenant income certification meetings and other necessary meetings will continue in person.

Any documentation signed after the normal 120 day certification/recertification period must have  a statement in the tenant file stating why the recertification was completed late.

For work orders, management should notice tenants that any non-essential work order will be postponed.  Remaining work orders should be scheduled based on need and severity.

Service amenities including access to the community room and after school programs should be limited for social distancing.  All food-related programs should be suspended except for canned or prepackaged deliveries.  For properties that cancel or postpone required service amenities, required hours must be made up before the end of 2020.  (Tax Credit Allocation Committee Memo, March 19, 2020.)

COVID-19 reverification of employment and appraisals for FHA Single Family loans

The United States Department of Housing and Urban Development temporarily changed re-verification of employment and appraisal rules for FHA Single Family programs.  Until May 17, 2020 mortgagees do not need to re-verify employment within 10 days of the Note or within 10 days of loan disbursement if there is no loss of employment by the borrower.

Appraisers may do Exterior-only (viewing from the street) or Desktop-Only (relying on various documents and not viewing the property) appraisals for FHA Single Family loans.

There changes also apply to refinances and reverse mortgages.  (Mortgagee Letter 2020-05, March 27, 2020.)

COVID-19 foreclosure and eviction moratorium for Sections 184 and 184A loans

The United States Department of Housing and Urban Development has authorized a moratorium on foreclosures and evictions for loans guaranteed under the Section 184 Indian Home Loan Guarantee Program and Section 184A Native Hawaiian Housing Loan Guarantee Program for 60 days.

Properties secured by Section 184 or 184A guaranteed loans are subject to a moratorium on initiation of foreclosures and foreclosures in process for 60 days.  Eviction of people from properties previously secured by Section 184 or 184A guaranteed loans are suspended for 60 days.  (DLL -2020-04, March 20, 2020.)

COVID-19 suspension of foreclosures and evictions for Fannie Mae and Freddic Mac

The Federal Housing Finance Agency has directed Fannie Mae and Freddie Mac to suspend foreclosures for 60 days because of COVID-19.  This suspension applies to Fannie Mae and Freddie Mac backed single family mortgages.

Previously the Federal Housing Finance Agency announced that Fannie Mae and Freddie Mac would provide payment forbearance for borrowers impacted by COVID-19 for 12 months.  (News Release, March 18, 2020.)