Procedure: Annual and Mid-year review (using a fixed review date) May 29, 2006

Transcription

1 Procedure: Annual and Mid-year review (using a fixed review date) May 29, 2006 START MIDYEAR REVIEW START REGULAR ANNUAL REVIEW CYCLE 1 Tenant / Member (T/M) reports a change as required 2 N Is the reported change received during the annual review cycle 3? Y Was a FULL review package already sent to the T/M? Provider sends a FULL Annual Review Package 9 N Y Provider sends MINI review package 4 OPTIONAL: Provider sends a letter asking the T/M to include the reported change when completing the FULL package that was sent earlier T/M submits package for ANNUAL review T/M returns MINI package (capturing the verification of income change) Provider sends incomplete letter Provider sends incomplete letter Submission complete 10? Y N N Submission complete 5? Review (RGI and Eligibility) 11 Y Review (of reported change) 6 What is the outcome of the review? Subsidy decrease 7 (=rent increase) What is the outcome of the review? Subsidy decrease 12 (=rent increase) Subsidy increase 13 (=rent decrease) Subsidy increase 8 (=rent decrease) Notice 1 or Notice 2 14 Notice 3 or Notice 5A, Notice 4 14 Notice 5B or Notice 6 14 Notice 7 or Notice 8 14

2 Procedure: Annual and Mid-year review (using a fixed review date) May 29, Start regular annual review cycle The regular review cycle for a system based on a fixed annual review date ideally starts three (3) to four (4) months before the month that you targeted for the new rents to become effective. The timing of the review cycle has to be based on various factors: The time that is required to implement a rent increase (requires two months). 20-business day response window + an additional 10 business days (if submission is incomplete) The time it takes you to finalize a review. Please make sure that your approach allows you to complete a review within 30 calendar days after receipt of documentation. After that you will have to give the T/M an opportunity to comment ( 30 additional days lost in the process) Delivery time for notices. If notices are delivered via Canada Post you are required to anticipate a five (5) business-days delivery period. If you want all the new annual review rents to kick in November 1 st your ideal three (3) month review cycle could be as follows: MONTH 1 (August) MONTH 2 (September) MONTH 3 (October) Day 1 Day 2 - end Day 1-15 Day 15 23/25 (30 minus 5 business days) Day 1 24/26 (31 minus 5 business days) Start review cycle Send FULL Annual Review Package 20-business day response window. 10 additional business days (re: incomplete submissions) Review of early submissions. TIP (from Win West, Stoney Creek Non- Profit): Post several highly visible messages in your building between January and April, urging T/Ms to give you a copy of their tax return documents. This will help to reduce the number of incomplete submissions. Review (continued, particularly rent increase cases) + send notices only pertaining to RENT INCREASES. Regulations require the new increased rent to commence the 1 st day of the 2 nd month following the month the notice was given. So if you give notice of rent increase in September, the new rent will become effective on your target day of November 1 st. Review (continued regarding rent decrease cases) + send notices only pertaining to RENT DECREASES. Regulations require the new decreased rent to commence the 1st day of the month following the month the notice was given. So if you give notice of rent decrease in October, the new rent will become effective on your target day of November 1st. Alternatively you could send ALL notices in September, which would imply that the rent decreases become effective as of October 1st. You will then bring the household back to the regular November 1 st target date during the next review cycle. 2. Tenant/Member reports a change as required This pertains to any change that impacts the RGI and the eligibility. With regard to rent related changes: Income change is always household income change. That is why the provider has to review a household composition change to see if additional income has entered the household (or existing income has left the household). The provider has to ensure that the T/M knows when and how to report the change of income and/or household composition. A change (particularly a change that results in a rent increase or that impacts the eligibility) has to be reported within 20 business days of the change becoming effective. See also Halton Region Directives 4 and 5. This flowchart focuses on RGI changes in particular. 3. Is the reported change received DURING the annual review cycle? If you receive the reported change DURING the review cycle (between August 1 st and November 1 st in the example given in text box #1) you are advised to include the reported data in the impending annual review. If the income change was reported during the review cycle but you already completed the review, you may treat the reported change as if it were submitted outside the regular cycle (i.e. flowchart answer = NO follow the orange part of the flowchart). 2

3 Procedure: Annual and Mid-year review (using a fixed review date) May 29, Provider sends MINI review package The MINI review package consists of a Release & Consent Form and a limited Assisted Housing Form (or similar form as developed by the housing provider). The (limited) AHF when completed- provides detailed verification of the reported change ONLY. However, the form still has to be signed by ALL household members. See also Halton Region Document on Verification Requirements as well as Directives # 4 and Submission Complete? If the submission is not complete the provider sends an incomplete letter outlining the missing element(s). In case of an incomplete submission the provider allows the T/M an additional 10 business days to send the missing element(s). 6. Review (outside annual review) The provider uses review criteria as outlined in O. Reg. 298/01 and Halton Region Directives # 4, 5 and 10. For In-depth explanations on RGI regulations, eligibility requirements and how to do rent calculations providers are advised to use the provincial Guide to Rent-Geared-to-Income Assistance as a reference. If the T/M reported a change (that impacts the eligibility or results in a rent increase) more than 20 business days after the change became effective (text box #3) or if the T/M did not submit the MINI-package within 20 business days, the provider is instructed to follow the guidelines below: a) 1 st stage response after T/M fails to report or submit (on time): The provider has the discretion to deem the reported change or the submission of the MINI-package to have been received on time. The provider has to obtain a verbal or written explanation from the T/M. The notice, as outlined in text box # 8 (or a separate letter), has to include a statement that the provider may not use the same discretion the next time. This doesn t mean that the discretion can only be used once. When assessing an appropriate response (1 st or 2 nd stage) it is important to weigh the specific ins-and-outs of the situation (how many days late, reoccurring problem?) against the impact of the 2 nd stage response (loss of eligibility). An additional approach could be to propose an income averaging arrangement (if the T/M appears to have a fluctuating income). Overpaid subsidy has to be recovered. b) 2 nd stage response (Loss of eligibility): Providers are advised to follow the regulations and use their discretion to reverse the decision (as the outcome of an internal review) only when extenuating circumstances apply. The initial loss of eligibility decision means that this flow chart is no longer applicable. For more details see Process 1(B) in INDEPTH - Overpaid RGI Subsidy Procedures and Retroactive RGI Subsidy Process (available on Halton s website). Halton Region asks providers to deem notifications of income decreases to have been received on time and to communicate the T/M s benefit of reporting income decreases in a timely fashion. The provider will reimburse underpaid subsidies without interest, to the last review period. IMPORTANT ASPECT WITH REGARD TO WRITTEN NOTICES: Special treatment of recovery of overpaid and the reimbursement of underpaid subsidy Halton Region has decided that the treatment of retroactive RGI subsidy assistance is to be accounted for separately in the housing provider s financial records. Halton Region believes that it is counter-productive for housing providers to include over/underpayments of RGI subsidy assistance on their financial statements as a potential bad debt (when the household vacates) as the amounts involved could be very large and negatively impact the Housing Provider s operating budget. 3

4 Procedure: Annual and Mid-year review (using a fixed review date) May 29, 2006 IMPORTANT ASPECT WITH REGARD TO WRITTEN NOTICES (continued) Housing Providers are required to establish a sub-account of the tenant/member s Accounts Receivable account named the RGI Subsidy Assistance Account. This account will be used to record retroactive adjustments to household s RGI subsidy assistance. The balance in this account is to be identified on the Housing Provider s year-end financial statements. Housing Providers must record recoveries received from households for RGI subsidy assistance to the RGI Subsidy Assistance account. Housing Providers are therefore required to include a separate statement in the notice, specifying the amount that is considered a retroactive adjustment of the RGI subsidy. Where it is determined that a household owes a Housing Provider in excess of $5, in RGI Subsidy Assistance, the Housing Provider is required to contact the Housing Programs Administrator at the Region of Halton to review the case to determine if further legal action is warranted. In the event that a household vacates their unit and owes the housing provider money for overpaid RGI Subsidy Assistance, the housing provider is to follow Halton Directive #9 (Amended) issued in January Outcome of the review (outside annual review) is a subsidy decrease (i.e. rent increase) IMPORTANT: If the new rent is the equivalent of market rent, other rules and notices apply, governed by Halton Region Directive # Providers are advised to follow the flowchart that is developed in support of this directive. The flowchart is called Income Change and Rent-Geared-to-Income The month that the new non-annual review rent becomes effective is related to the month that the income change occurred (as opposed to the month the service manager / housing provider gives notice, as is the case with annual reviews). In this particular case we are looking at a rent increase, which implies that the new rent kicks in on the 1 st day of the 2 nd month following the month the income increase occurred. This means that no matter how much time the review process takes, the provider will always have to go back to that particular 2 nd month as the starting month for the new increased rent. Overpaid subsidy has to be recovered. 8. Outcome of the review (outside annual review) is a subsidy increase (i.e. rent decrease) Here we are looking at a rent decrease, which implies that the new rent kicks in on the 1 st day of the month following the month the income decrease occurred. This means that no matter how much time the review process takes, the provider will always have to go back to that particular month as the starting month for the new decreased rent. The provider will reimburse underpaid subsidy to the last annual review if the T/M continued to pay the original (higher) rent (see bottom of text box # 6). 9. Provider sends a FULL annual review package The FULL review package consists of the following documents: Release & Consent Form Assisted Housing Form (or similar form as developed by the housing provider). See also Halton Region Document on Verification Requirements as well as Directives # Submission Complete? If the submission is not complete the provider sends an incomplete letter outlining the missing element(s). In case of an incomplete submission the providers allows the T/M an additional 10 business days to send the missing element(s). Please note that if these extra 10 days result in the notice going out too late for a rent increase to take effect AS PLANNED, the T/M will have to pay back the related overpaid subsidy. 4

5 Procedure: Annual and Mid-year review (using a fixed review date) May 29, Review (RGI AND Eligibility) The provider uses review criteria as outlined in O. Reg. 298/01 and Halton Region Directives # 4, 5 and 10. Indepth explanations on RGI regulations, eligibility requirements and how to do rent calculations providers are provided in the provincial Guide to Rent-Geared-to-Income Assistance. If the T/M did not submit the FULL-package within 20 business days, the provider is instructed to follow the guidelines below: a) 1 st stage response after T/M fails to submit (on time): The provider has the discretion to deem the submission of the FULL-package to have been received on time. The provider has to obtain a verbal or written explanation from the T/M. The notice (or a separate letter), has to include a statement that the provider may not use the same discretion the next time. This doesn t mean that the discretion can only be used once. When assessing an appropriate response (1 st or 2 nd stage) it is important to weigh the specific ins-and-outs of the situation (how many days late, reoccurring problem?) against the impact of the 2 nd stage response (loss of eligibility). An additional approach could be to propose an income averaging arrangement (if the T/M appears to have a fluctuating income). Overpaid subsidy has to be recovered. b) 2 nd stage response (Loss of eligibility): Providers are advised to follow the regulations and use their discretion to reverse the decision (as the outcome of an internal review) only when extenuating circumstances apply. The initial loss of eligibility decision means that this flow chart is no longer applicable. For more details see Process 1(B) in INDEPTH - Overpaid RGI Subsidy Procedures and Retroactive RGI Subsidy Process (available on Halton s website). Please note that the occurrences referred to in text box # 6 and occurrences in this text box need to be compounded. If the outcome of the review shows that the T/M failed to report an earlier increase of income AND the provider has reason to believe that the T/M intentionally withheld this information in an attempt to avoid a rent increase, the provider is advised to follow up with a 2 nd stage response. 12. Outcome of the (annual) review is a subsidy decrease (i.e. rent increase) Please note that the special treatment with regard to the recovery of overpaid subsidy applies, as outlined in the text box below text box # 6. IMPORTANT: If the new rent is the equivalent of market rent, other rules and notices apply, governed by Halton Region Directive # Providers are advised to follow the flowchart that is developed in support of that directive. The flowchart is called Income Change and Rent-Geared-to-Income The month that the new rent becomes effective is related to the month that the service manager / housing provider gives notice. In this particular case we are looking at a rent increase, which implies that the new rent kicks in on the 1 st day of the 2 nd month following the month the notice was given. 5

6 Procedure: Annual and Mid-year review (using a fixed review date) May 29, (Continued) With regard to the question whether or not to recover overpaid subsidy, the following guidelines apply: a) If the submission was incomplete and the additional 10-business days granted to complete the submission leads to the notice being sent one month later, the provider will recover the overpaid subsidy; b) If the T/M returned the FULL review package AFTER the 20-business days expired (and it pertains to a 1 st occurrence), and this delay leads to the notice being sent one month later, the provider will recover the overpaid subsidy; c) Providers are NOT to retroactively adjust the rent subsidy if the T/M has complied with the deadline for receiving all of the required documentation (submission was complete and on time). 13. Outcome of the (annual) review is a subsidy increase (i.e. rent decrease) Please note that the special treatment with regard to the reimbursement of underpaid subsidy applies, as outlined in the text box below text box # 6. A rent decrease (as a result of an annual review) kicks in on the 1 st day of the month following the month the notice is given. The provider will reimburse underpaid subsidy up to the last review if the T/M continued to pay the original (higher) rent. 14. Notices As the recovery or reimbursement of RGI subsidy has to be kept separate from rent increases or decreases it is important that the notice is specified accordingly, along with an appropriate statement or warning that corresponds with the reason for recovery or reimbursement. The following standardized notices are available for the fixed annual review procedure: Notice 1: MIDYEAR review Rent increase WITH Retroactive recovery of overpaid RGI subsidy Notice 2: MIDYEAR review Rent increase WITHOUT a retroactive recovery arrangement Notice 3: MIDYEAR review Rent decrease WITH Retroactive reimbursement of underpaid RGI subsidy Notice 4: MIDYEAR review Rent decrease WITHOUT a retroactive reimbursement arrangement Notice 5A: ANNUAL review - Rent increase WITH Retroactive recovery of overpaid RGI subsidy due to a NON- REPORTED in come increase. Notice 5B: ANNUAL review - Rent increase WITH Retroactive recovery of overpaid RGI subsidy due to the T/M s LATE SUBMISSION of the review package. Notice 6: ANNUAL review - Rent increase WITHOUT a retroactive recovery arrangement Notice 7: ANNUAL review - Rent decrease WITH Retroactive reimbursement of underpaid RGI subsidy Notice 8: ANNUAL review - Rent decrease WITHOUT a retroactive reimbursement arrangement The retroactive determination is based on separately developed Halton Region Decision Tree sheets. Providers are advised to review the appropriate sheet when creating a notice. 6

7 DECISION TREE for retroactive subsidy recovery or reimbursement Mid-year Review May 29, 2006 START T/M reports an income change Does reported change Increase (1) pertain to an increase or a decrease of income? Decrease (2) Verification (MINI package) Verification (MINI package) Date increase of income occurred = A1 Date decrease of income occurred = A2 1 st day of 2 nd month following A1 = B1. This is the date the new rent should start 1 st day of the month following A2 = B2. This is the date the new rent should start Date that provider sends notice pertaining to this reported increase = C1 Date that provider sends notice pertaining to this reported decrease = C2 Y Is the notice sent (C1) BEFORE the date the new rent should start (B1) N Y Is the notice sent (C2) BEFORE the date the new rent should start (B2) N (Must be at least 5 B/D before) (Must be at least 5 B/D before) There is NO retroactive subsidy recovery Retroactive subsidy recovery Recovery period is the time period between (and including) the month of notice and the 2 nd month following the month the increase occurred There is NO retroactive subsidy reimbursement Retroactive subsidy reimbursement Reimbursement period is the time period between (and including) the month of notice and the month following the month the decrease of income occurred Example: T/M reports an income increase on June 12. The increase occurred on June 1 (=A1). This means that the rent increase SHOULD begin on August 1 (=B1). The provider sends notice on June 20 (=C1). In this situation notice (C1) is sent well BEFORE the day the new rent should begin (B1), meaning that there will not be any overpayment of subsidy.

8 DECISION TREE for retroactive subsidy recovery or reimbursement Annual review (using a fixed review date) June 2, 2006 START Provider initiates an annual review Date (FULL) package was sent to T/M (A) Date package was received from T/M Number of business days it took the T/M to return the package (B) A package is received late when it was received more than 25 B/Ds after it was sent ( days mail delivery) Provider reviews T/M documentation Retroactive subsidy reimbursement REQUIRED (if any) Reimbursement period is the time period between (and including) the month of notice (Y) and the month following the month the decrease of income occurred (X). Example of a reimbursement period of two months: Decrease Does the review show an increase or a decrease of income? Increase Rent should go down Income down Timeline Month of Notice (of annual review result) X Y 2 months New rent starts Y Did the increase of income occur BEFORE the date the package was sent (A)? N Note that a T/M has 20+5 B/D to report a change of income. If the review shows that the increase occurred less than 25 B/D before the package was sent, the T/M is still within the allowable time period. In that case the answer to this question is NO Retroactive subsidy recovery REQUIRED due to a NON-reported increase of income NOTE: This (along with the box above) is the most complex scenario as far as calculating the number of overpaid subsidy months is concerned, because two different rules must be combined: 1. The rule that says that a rent increase resulting from a reported income change should start on the 1 st day of the 2 nd month following the month the income change occurred and 2. The rule that says that a rent increase resulting from an annual review should start on the 1 st day of the 2 nd month following the month notice (of the annual review outcome) is given. Recovery period is the time period between (and including) the month after the month of notice (Y) and 2 nd month following the month the increase occurred (X). Will the notice go out later than planned? Y Was package received too late (see B) or incomplete? N NO Retroactive subsidy recovery N Example: Package was sent on June 1 st and returned on June 8 th (complete). Review indicates that an increase of income occurred in March. This means that a rent increase should have started on May 1 st (X) being the 2 nd month following the month the income change occurred. Review is completed on June 14 th. Notice will go out on June 15 th June is the month of notice. The new rent starts August 1 st being the 2 nd month after notice is given. July is therefore the last month for which overpaid subsidy needs to be recovered (Y). The recovery period is therefore three months. Income up March Rent should go up X Y Notice May June July Aug 3 months New rent starts Y Retroactive subsidy recovery REQUIRED Recovery period is the time period between the 2 nd month following the predetermined month of notice and the 2 nd month following the ACTUAL month of notice An annual review with a fixed review date requires a predetermined month of notice. For instance, if the new rent increase should start November 1 st, the notice should be sent in September (see box 1 of Procedure: Annual and Mid-year review (using a fixed review date)). In this scenario the issue is that the T/M returned the package too late (or incomplete), resulting in the notice going out later than planned, resulting in the rent increase starting later. The recovery period is typically the number of months the T/M was late returning the package. In practice this is usually one or two months.

9 Notice of Rent Increase and Subsidy Adjustment To: DATE: September 13, 2006 Ref. #: On I received your message about an increase of your household income*. In response I sent you an assisted housing package on and asked you to complete and return it. The completed package provides me with the required signatures and documents to review the reported change. *Your household income goes up if you or somebody else in your household gets an increase in income, or if a new person (with income) joins your household. WARNING: You should have reported this increase of your household income sooner! The documents that you provided show that your household income increased as of. This should have been reported within 20 business days after the increase occurred. I have accepted your explanation this time and will deem the increase to have been reported on time. Please be aware that I will keep a record of this notice. If you do not report your income change on time if the future you will lose your subsidy. As of your new rent is per month. Retroactive Change to RGI Subsidy Assistance Because you did not report the change of income sooner, your old rent of per month has been charged for month(s) where the new rent should have applied. This means that you received too much RGI subsidy. You have to reimburse this overpaid subsidy. Below I will explain how much money this is, and how we would will recover it. Old New Overpaid subsidy per month Your RENT + Your SUBSIDY = Market rent for your unit The total amount of overpaid subsidies owing is month(s) X =. This amount will be added to the charges for the first month your new rent is due. As a result we will charge you + = for the month of. Notice 1 1

10 Notice of Rent Increase and Subsidy Adjustment Please contact me at 905- extension if you have other questions about this notice. If you wish to appeal this decision you may do so by writing a letter to our office requesting an internal review within ten (10) days of the date you receive this letter. Someone who was not involved in the original decision will complete the review. IMPORTANT rules to remember 1. You must report to us in writing within 20 business days if your income changes, or if the income of somebody in your household changes, or if somebody joins or leaves your household. 2. An Assisted Housing Package must be completed in full with every rent calculation. Please contact our office should you require a package. Ensure the form is properly dated and all signatures witnessed. 3. A tenant who pays rent geared to income (RGI) may have his / her rent increased more than once in a 12 month period. 4. A tenant who pays RGI is exempt from the requirement to receive 90 days notice in writing before rent is increased Name reviewer: Position: Telephone: Signature: Notice 1 2

11 Notice of Rent Increase and Subsidy Adjustment To: DATE Ref. #: On I received your message about an increase of your household income. In response I sent you an assisted housing package on and asked you to complete and return it. The completed package provides me with the required signatures and documents to review the reported change. The documents you provided show that your household income increased as of. Your household income goes up if you or somebody else in your household gets an increase or if a new person (with income) joins your household. As of your new rent is per month. The chart below shows the changes in rent and subsidy: Old New Your RENT + Your SUBSIDY = Market rent for your unit Please contact me at 905- extension if you have other questions about this notice. If you wish to appeal this decision you may do so by writing a letter to our office requesting an internal review within ten (10) days of the date you receive this letter. Someone who was not involved in the original decision will complete the review. IMPORTANT rules to remember 1. You must report to us in writing within 20 business days if your income changes, or if the income of somebody in your household changes, or if somebody joins or leaves your household. 2. An Assisted Housing Package must be completed in full with every rent calculation. Please contact our office should you require a package. Ensure the form is properly dated and all signatures witnessed. 3. A tenant who pays rent geared to income (RGI) may have his / her rent increased more than once in a 12 month period. 4. A tenant who pays RGI is exempt from the requirement to receive 90 days notice in writing before rent is increased Name reviewer: Position: Telephone: Signature: Notice 2 1

12 Notice of Rent Decrease and Subsidy Adjustment To: DATE: Ref. #: On I received your message about a decrease of your household income*. In response I sent you an assisted housing package on and asked you to complete and return it. The completed package provides me with the required signatures and documents to review the reported change. *Your household income decreases if your income or the income of somebody else in your household goes down or if somebody (with income) leaves your household. TIP: Let us know ASAP when your household income decreases; it saves you money! The documents that you provided show that your household income decreased as of. This should be reported within 20 business days after the decrease occurs. The sooner you let me know (in writing) the sooner I can lower your rent. As of your new rent is per month. Retroactive Change to RGI Subsidy Assistance As you did not report the change of income, your old rent of per month has been charged for a period of month(s) where the new rent should apply. This means that you have received less RGI subsidy than you are entitled to. I will compensate you for that. Below I will explain how much money this is and how I will reimburse you. Old New Underpaid subsidy per month Your RENT + Your SUBSIDY = Market rent for your unit The total amount is month(s) X =. This amount will be deducted from your first decreased rent charge. As a result we will charge you - = for the month of. Notice 3 1

13 Notice of Rent Decrease and Subsidy Adjustment Please contact me at 905- extension if you have other questions about this notice. If you wish to appeal this decision you may do so by writing a letter to our office requesting an internal review within ten (10) days of the date you receive this letter. Someone who was not involved in the original decision will complete the review. IMPORTANT rules to remember 1. You must report to us in writing within 20 business days if your income changes, or if the income of somebody in your household changes, or if somebody joins or leaves your household. 2. An Assisted Housing Package must be completed in full with every rent calculation. Please contact our office should you require a package. Ensure the form is properly dated and all signatures witnessed. 3. A tenant who pays rent geared to income (RGI) may have his / her rent increased more than once in a 12 month period. 4. A tenant who pays RGI is exempt from the requirement to receive 90 days notice in writing before rent is increased Name reviewer: Position: Telephone: Signature: Notice 3 2

14 Notice of Rent Decrease and Subsidy Adjustment To: DATE: Ref. #: On I received your message about a decrease of your household income. In response I sent you an assisted housing package on and asked you to complete and return it. The completed package provides me with the required signatures and documents to review the reported change. The documents that you provided show that your household income decreased. Your household income goes down if you or somebody else in your household gets a decrease or if somebody (with income) leaves your household. As of your new rent is per month. The chart below shows the changes in rent and subsidy: Old New Your RENT + Your SUBSIDY = Market rent for your unit Please contact me at 905- extension if you have other questions about this notice. If you wish to appeal this decision you may do so by writing a letter to our office requesting an internal review within ten (10) days of the date you receive this letter. Someone who was not involved in the original decision will complete the review. IMPORTANT rules to remember 1. You must report to us in writing within 20 business days if your income changes, or if the income of somebody in your household changes, or if somebody joins or leaves your household. 2. An Assisted Housing Package must be completed in full with every rent calculation. Please contact our office should you require a package. Ensure the form is properly dated and all signatures witnessed. 3. A tenant who pays rent geared to income (RGI) may have his / her rent increased more than once in a 12 month period. 4. A tenant who pays RGI is exempt from the requirement to receive 90 days notice in writing before rent is increased Name reviewer: Position: Telephone: Signature: Notice 4 1

15 Notice of Rent Increase and Subsidy Adjustment To: DATE: Ref. #: On I sent you an assisted housing package and asked you to complete and return it. The completed package provides me with the required signatures and documents to review your eligibility and your rent. WARNING: You did not report an earlier increase of your household income! The documents that you provided show that your household income increased* as of. This should have been reported within 20 business days after the increase occurred. I have accepted your explanation about why the information was not submitted on time, this time, and will deem the increase to have been reported on time. Please be aware that I will keep a record of this notice. If you do not report your income change on time in the future, you will lose your subsidy. *Your household income goes up if you or somebody else in your household gets an increase in income or if a new person (with income) joins your household. As of your new rent is per month. Retroactive Change to RGI Subsidy Assistance Because you did not report the change of income your old rent of per month, has been charged for a period of month(s) where the new rent should apply. This means that you received too much RGI subsidy. You will have to reimburse this overpaid subsidy. Below I will explain how much money this is and how we would like to recover it. Old New Overpaid subsidy per month Your RENT + Your SUBSIDY = Market rent for your unit The total amount of overpaid subsidies owing is month(s) X =. This amount will be added to the charges of the first month your new rent is due. As a result we will charge you + = for the month of. Notice 5A 1

16 Notice of Rent Increase and Subsidy Adjustment Please contact me at 905- extension if you have other questions about this notice. If you wish to appeal this decision you may do so by writing a letter to our office requesting an internal review within ten (10) days of the date you receive this letter. Someone who was not involved in the original decision will complete the review. IMPORTANT rules to remember 1. You must report to us in writing within 20 business days if your income changes, or if the income of somebody in your household changes, or if somebody joins or leaves your household. 2. An Assisted Housing Package must be completed in full with every rent calculation. Please contact our office should you require a package. Ensure the form is properly dated and all signatures witnessed. 3. A tenant who pays rent geared to income (RGI) may have his / her rent increased more than once in a 12 month period. 4. A tenant who pays RGI is exempt from the requirement to receive 90 days notice in writing before rent is increased Name reviewer: Position: Telephone: Signature: Notice 5A 2

17 Notice of Rent Increase and Subsidy Adjustment To: DATE: Ref. #: On I sent you an assisted housing package and asked you to complete and return it. The completed package provides me with the required signatures and documents to review your eligibility and your rent. WARNING: You did not report an earlier increase of your household income! The documents that you provided show that your household income increased* as of. This should have been reported within 20 business days after the increase occurred. I have accepted your explanation about why the information was not submitted on time, this time, and will deem the increase to have been reported on time. Please be aware that I will keep a record of this notice. If you do not report your income change on time in the future, you will lose your subsidy. *Your household income goes up if you or somebody else in your household gets an increase in income or if a new person (with income) joins your household. As of your new rent is per month. Retroactive Change to RGI Subsidy Assistance Because you did not report the change of income your old rent of per month, has been charged for a period of month(s) where the new rent should apply. This means that you received too much RGI subsidy. You will have to reimburse this overpaid subsidy. Below I will explain how much money this is and how we would like to recover it. Old New Overpaid subsidy per month Your RENT + Your SUBSIDY = Market rent for your unit The total amount of overpaid subsidies owing is month(s) X =. This amount will be added to the charges of the first month your new rent is due. As a result we will charge you + = for the month of. Notice 5A 1

18 Notice of Rent Increase and Subsidy Adjustment Please contact me at 905- extension if you have other questions about this notice. If you wish to appeal this decision you may do so by writing a letter to our office requesting an internal review within ten (10) days of the date you receive this letter. Someone who was not involved in the original decision will complete the review. IMPORTANT rules to remember 1. You must report to us in writing within 20 business days if your income changes, or if the income of somebody in your household changes, or if somebody joins or leaves your household. 2. An Assisted Housing Package must be completed in full with every rent calculation. Please contact our office should you require a package. Ensure the form is properly dated and all signatures witnessed. 3. A tenant who pays rent geared to income (RGI) may have his / her rent increased more than once in a 12 month period. 4. A tenant who pays RGI is exempt from the requirement to receive 90 days notice in writing before rent is increased Name reviewer: Position: Telephone: Signature: Notice 5A 2

19 Notice of Rent Increase and Subsidy Adjustment To: DATE: Ref. #: On I sent you an assisted housing package and asked you to complete and return it. The completed package provides me with the required signatures and documents to review your eligibility and your rent. The documents that you provided show that your household income increased as of. Your household income goes up if you or somebody else in your household gets an increase or if a new person (with income) joins your household. As of your new rent is per month. The chart below shows the changes in rent and subsidy: Old New your RENT + your SUBSIDY = Market rent for your unit Please contact me at 905- extension if you have other questions about this notice. If you wish to appeal this decision you may do so by writing a letter to our office requesting an internal review within ten (10) days of the date you receive this letter. Someone who was not involved in the original decision will complete the review. IMPORTANT rules to remember 1. You must report to us in writing within 20 business days if your income changes, or if the income of somebody in your household changes, or if somebody joins or leaves your household. 2. An Assisted Housing Package must be completed in full with every rent calculation. Please contact our office should you require a package. Ensure the form is properly dated and all signatures witnessed. 3. A tenant who pays rent geared to income (RGI) may have his / her rent increased more than once in a 12 month period. 4. A tenant who pays RGI is exempt from the requirement to receive 90 days notice in writing before rent is increased Name reviewer: Position: Telephone: Signature: Notice 6 1

20 Notice of Rent Decrease and Subsidy Adjustment To: DATE: Ref. #: On I sent you an assisted housing package and asked you to complete and return it. The completed package provides me with the required signatures and documents to review your eligibility and your rent. TIP: Let us know ASAP when your household income decreases; it saves you money! The documents that you provided show that some time ago your household income decreased*. This should be reported within 20 business days after the decrease occurs. The sooner you let me know (in writing) the sooner I can lower your rent. * Your household income decreases if your income or the income of somebody else in your household goes down or if somebody (with income) leaves your household. As of your new rent is per month. Retroactive Change to RGI Subsidy Assistance As you did not report the change of income, your old rent of per month has been charged for a period of month(s) where the new rent should apply. This means that you have received less RGI subsidy than you are entitled to. I will compensate you for that. Below I will explain how much money this is and how I will reimburse you. Old New Underpaid subsidy per month Your RENT + Your SUBSIDY = Market rent for your unit The total amount is month(s) X =. This amount will be deducted from your first decreased rent charge. As a result we will charge you - = for the month of. Notice 7 1

21 Notice of Rent Decrease and Subsidy Adjustment Please contact me at 905- extension if you have other questions about this notice. If you wish to appeal this decision you may do so by writing a letter to our office requesting an internal review within ten (10) days of the date you receive this letter. Someone who was not involved in the original decision will complete the review. IMPORTANT rules to remember 1. You must report to us in writing within 20 business days if your income changes, or if the income of somebody in your household changes, or if somebody joins or leaves your household. 2. An Assisted Housing Package must be completed in full with every rent calculation. Please contact our office should you require a package. Ensure the form is properly dated and all signatures witnessed. 3. A tenant who pays rent geared to income (RGI) may have his / her rent increased more than once in a 12 month period. 4. A tenant who pays RGI is exempt from the requirement to receive 90 days notice in writing before rent is increased Name reviewer: Position: Telephone: Signature: Notice 7 2

22 Notice of Rent Decrease and Subsidy Adjustment To: DATE: Ref. #: On I sent you an assisted housing package and asked you to complete and return it. The completed package provides me with the required signatures and documents to review your eligibility and your rent. The documents you provided show that your household income decreased. Your household income decreases if your income or the income of somebody else in your household goes down or if somebody (with income) leaves your household. As of your new rent is per month. The chart below shows the changes in rent and subsidy: Old New Your RENT + Your SUBSIDY = Market rent for your unit Please contact me at 905- extension if you have other questions about this notice. If you wish to appeal this decision you may do so by writing a letter to our office requesting an internal review within ten (10) days of the date you receive this letter. Someone who was not involved in the original decision will complete the review. IMPORTANT rules to remember 1. You must report to us in writing within 20 business days if your income changes, or if the income of somebody in your household changes, or if somebody joins or leaves your household. 2. An Assisted Housing Package must be completed in full with every rent calculation. Please contact our office should you require a package. Ensure the form is properly dated and all signatures witnessed. 3. A tenant who pays rent geared to income (RGI) may have his / her rent increased more than once in a 12 month period. 4. A tenant who pays RGI is exempt from the requirement to receive 90 days notice in writing before rent is increased Name reviewer: Position: Telephone: Signature: Notice 8 1

23 Notice of Subsidy Adjustment and Loss of Eligibility To: DATE: Ref. #: Your eligibility for RGI Subsidy Assistance is terminated effective immediately because of your household s noncompliance with the Social Housing Reform Act 2000 and Regulations in the following area: (A) Failure to return requested information by specified date (O. Reg. 298/01 s.12(1)(h)&(l)). (B) Failure to inform of a change within 20 business days (O. Reg. 298/01 s. 12 (1)(h)). (C) Failure to pursue income (O. Reg. 298/01 12 (1)(c)). (D) Failure to sell residential property (O. Reg. 298/01 s. 12(1)(g)). (E) Failure to sign Declaration and Consent (O. Reg. 298/01 s. 12(1)(l). (F) Failure to meet eligibility requirements (O.Reg. 298/01 s. 12(1)(b)). (G) Sublet the unit to another person (O.Reg. 339/01 s. 21(1)(3)(iii)). As of (90 day notice) your new rent is per month (market rent). A separate notice about this is attached. <THIS SECTION ONLY APPLIES IF THE PROVIDER HAS INCOME DOCUMENTATION TO DETERMINE THE AMOUNT OF OVERPAID SUBSIDY. ITEMS C, D, E, F AND G TYPICALLY DO NOT RESULT IN RETROACTIVE RECOVERY OF OVERPAID SUBSIDY.> Due to the fact(s) listed above you have wrongfully received a certain amount of rent subsidy. You will have to reimburse this overpaid subsidy. Our information shows that your current rent of $ per month should have been $ as of (2 nd month following the change). This means that the amount of overpaid subsidy you have received is $ from to (date of this notice) and this same amount from (date of this notice) to (date market rent kicks in). The total number of months of overpaid subsidy is therefore The total amount of overpaid subsidy is $ X months = $ The legislated minimum monthly reimbursement amount is 10% of the rent. As of (date market rent kicks in) your rent is $ (market rent). 10% of this amount is $. This means that you will be charged $ until your subsidy debt is fully reimbursed. This will be the case after months. Notice 5A 1

24 Notice of Subsidy Adjustment and Loss of Eligibility Please contact me at 905- extension if you have other questions about this notice. If you wish to appeal this decision you may do so by writing a letter to our office requesting an internal review within ten (10) days of the date you receive this letter. Someone who was not involved in the original decision will complete the review. IMPORTANT INFORMATION 1. Loss of rent-geared-to-income subsidy assistance means that if the household requires rent-geared-to-income assistance in the future, the household must re-apply for a subsidy with the Region of Halton s centralized waiting list (HATCH at (905) or ). The household s position on the centralized waiting list will be based on the date of the new application. 2. If a household plans to move, the household must notify the landlord, in writing, at least 60 days before the end of a monthly or yearly rental period. Name reviewer: Position: Telephone: Signature: Notice 5A 2

25 Overpaid RGI Subsidy Procedures and Retroactive RGI Subsidy Process February 18, 2004 OPERATIONAL REQUIREMENTS Housing Providers have been delegated the administration of the RGI subsidy program by way of a signed Service Agreement with the Region of Halton. The Social Housing Reform Act (SHRA) allows for the retroactive adjustment of RGI subsidy assistance where a Housing Provider has determined that a household has received RGI subsidy assistance in a different amount than the household s entitlement O. Reg. 298/01 s. 54. As the Region of Halton is the agency that pays the RGI subsidy assistance, Halton Region requires that Housing Providers ensure that the amount of RGI subsidy assistance received by a household accurately reflects the household s entitlement. Housing Providers are therefore required to retroactively adjust household s RGI subsidy assistance and collect overpaid RGI subsidies from households. The Region of Halton has decided that the treatment of retroactive RGI subsidy assistance is to be accounted for separately in the housing provider s financial records. The Region of Halton believes that it is counter-productive for housing providers to include over/underpayments of RGI subsidy assistance on their financial statements as a potential bad debt (when the household vacates) as the amounts involved could be very large and negatively impact the Housing Provider s operating budget. Housing Providers are required to establish a sub account of the tenant/member s Accounts Receivable account named the RGI Subsidy Assistance Account. This account will be used to record retroactive adjustments to household s RGI subsidy assistance. The balance in this account is to be identified on the Housing Provider s year-end financial statements. Housing Providers must record recoveries received from households for RGI subsidy assistance to the RGI Subsidy Assistance account. Housing Providers are therefore required to include a separate statement in the notice, specifying the amount that is considered a retroactive adjustment of the RGI subsidy (see also flowchart called Annual and Mid-year review (using a fixed review date). Where it is determined that a household owes a Housing Provider in excess of $5, in RGI Subsidy Assistance, the Housing Provider is required to contact the Housing Programs Administrator at the Region of Halton to review the case to determine if further legal action is warranted. In the event that a household vacates their unit and owes the housing provider money for overpaid RGI Subsidy Assistance, the housing provider is to follow Halton Directive #9 (Amended) issued January

26 Overpaid RGI Subsidy Procedures and Retroactive RGI Subsidy Process February 18, 2004 Process #1 - Overpaid RGI Subsidy Assistance (A) Household continues to be eligible to receive RGI Subsidy Assistance If a household is required to reimburse a housing provider for overpaid subsidies and the housing provider has determined that the household will continue to be eligible to receive RGI subsidy assistance (i.e. a first stage response; a decision made at an Internal Review; mid-year change), the following process must be followed by the housing provider: 1. Complete the appropriate notice (see flowchart sheets), including a statement specifying the amount that is considered a retroactive adjustment of the RGI Subsidy Assistance (total RGI Subsidy Assistance owing). 2. To collect overpaid RGI subsidies, Housing Providers have the choice of increasing the household s rent/housing charge by 10% (O. Reg. 298/01 s. 54(2) or asking for payment in full (Halton Region s sample notices all assume payment in full) If the Housing Provider chooses to increase the RGI rent payable (the 10% approach), the Housing Provider must ensure that the notice must clearly identify the amount of the RGI Rent payable plus the amount of the 10% of the new RGI Rent Payable. The total of these two amounts is the new RGI rent payable. The notice must also clearly identify that the household has the right to an internal review of the amount of RGI rent payable. 3. Record the RGI Subsidy Assistance owing in the RGI Subsidy Assistance Account. 4. Record monthly recoveries received from the household for the RGI Subsidy Assistance overpayment to the RGI Subsidy Assistance Account. 5. In case of the 10% approach: When the household has paid the RGI Subsidy Assistance balance in full, the Housing Provider is required to issue the household with a Notice of Rent/Housing Charge Decrease to reduce the rent/housing charge to the RGI Rent Payable amount only. The household is not eligible to an internal review of this notice, as the RGI Rent Payable is not changing from the last Notice sent to the household. (NOTE: - if the household has provided updated income information and a new rent/housing charge calculation is completed, then the household is entitled to an Internal Review of the new rent/housing charge.). 6. The Housing Provider must ensure that the household continues to have their RGI rent/housing charge payable reviewed as required in accordance with their RGI subsidy review process. Should a household s RGI rent/housing charge change prior to the RGI subsidy assistance owing being paid in full, the Housing Provider has the option to either leave the 10% recovery amount as is or ensure that the 10% recovery amount is adjusted to reflect the new RGI rent payable. 2