The Habitat Group
www.thehabitatgroup.com/blogs/3-daniel-bagliore/post/2065-determining-the-annual-recertification-cutoff-date

Determining the Annual Recertification Cutoff Date

Mar 13, 2024

As you may know, the annual recertification process must commence within the 120-day period prior to the annual recertification anniversary date. Assuming the proper issuance of the Initial Notice during the prior (re)certification, and the timely distribution of the three recertification reminder notices for the forthcoming annual recertification, HUD expects Section 8 residents to report for their annual recertification interview in a timely fashion (i.e., prior to the cutoff date), sign paperwork, and provide documentation confirming all sources of income and assets during their recertification interview. 

When the resident reports for the annual recertification prior to the cutoff date, the manager is expected to complete the recertification with enough time to provide 30-days’ notice of any resulting rent increase.

When the resident reports on or after the cutoff date, the resident is considered late and loses their right to 30-days’ notice of any resulting rent increase. The recertification should still be completed by, and the tenant rent and assistance payment will be effective on, the anniversary date.

WHAT IS THE CUTOFF DATE?

HUD defines the cutoff date as the 10th day of the 11th month prior to the annual recertification date.  The cutoff date must be included in your Initial Notice and 120/90/60-day recertification reminder notices.

HOW TO DETERMINE THE CUTOFF DATE

To determine the cutoff date for the next annual recertification, count the next 11 months starting from and including the month of the last annual recertification; the cutoff date falls on the 10th day of that month.

For example, the resident’s last annual recertification was June 1, 2023. To determine the cutoff date for the June 1, 2024 annual recertification, count the next 11 months starting from and including the month of June 2023. As the 11th month is April 2024, the cutoff date for the June 1, 2024 annual recertification is April 10, 2024.

A quicker approach in thinking about the cutoff date is to count two months back from the annual recertification date and the cutoff date falls on the 10th day of that month.

For example, to determine the cutoff date for the Feb. 1, 2025 annual recertification using this method, count two months back, which, in this case, is the month of December. Therefore, the cutoff date for the Feb. 1, 2025 annual recertification is Dec. 10, 2024.

You may also wish to keep a list of the cutoff dates in your workspace for quick reference. The cutoff date for each recertification month is as follows (remember to use the correct year for each date):

Recertification MonthCutoff Date
January 1stNovember 10th
February 1stDecember 10th
March 1stJanuary 10th
April 1stFebruary 10th
May 1stMarch 10th
June 1stApril 10th
July 1stMay 10th
August 1stJune 10th
September 1stJuly 10th
October 1stAugust 10th
November 1stSeptember 10th
December 1stOctober 10th