COVID RRP – Case Curing Flags and Denial Codes

COVID RRP – Case Curing Flags and Denial Codes
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Overview

The guidance below is advisory only and is subject to change. Each COVIDRRP application is evaluated based on the data provided by the applicant as well as third party data sources.  Circumstances may vary. HCR may at its discretion perform further due diligence, require additional documentation, and take other reasonable precautions not described here when reviewing an application to ensure compliance with federal and state requirements. 

Explanation of Case Curing Flags

Flag 1: Pre-COVID Income – The applicant must document their total household income prior to March 1. Where Third-Party data does not exist, and where the income documents provided by the applicant are incomplete or inconclusive, the CM will require the applicant to provide at least one of the following during case curing.

  • Form W-2, Wage and Tax Statement.
  • A paystub.
  • Salary letter signed by an authorized representative of the Applicant’s employer.
  • Most recent (2019) Federal or New York State tax return.
  • Completed employment attestation signed by the Applicant; or
  • Another form of evidence satisfactory to the Administering Agency.

Flag 2: Post-COVID Income – The applicant must document their income for at least one point in time between April 1 and the time of application. Where Third-Party data does not exist, and where the income documents provided by the applicant are incomplete or inconclusive, the CM will require the applicant to provide at least one of the following during case curing.

  • A paystub.
  • Salary letter signed by an authorized representative of the Applicant’s employer.
  • Completed tenant income attestation signed by the Applicant; or
  • Another form of evidence satisfactory to the Administering Agency.

Flag 3: Loss of Income Not Evident – Documentation provided for flags 1 and 2 (Pre-COVID Income and Post- COVID Income) should be used to confirm loss of income during the coverage period.

Flag 4: Identification – COVIDRRP will accept current and valid government-issued identification. If an applicant states that their identification has expired, the CM should accept it assuming the identification has expired after March 1, 2020. Identification that expired prior to March 1, 2020 will not be accepted. Where the applicant states that their identification expired prior to March 1, 2020, the CM should utilize the threshold test provided by the NYS Dept. of Motor Vehicles; please note however that identification is being collected to verify identity only. For this reason, CM should disregard the DMV initial part of the DMV threshold test that requires an applicant submit a Social Security Number, a Social Security Ineligibility Letter or an affidavit confirming they have never been issued a Social Security Number.

http://nysdmv.standard-license-and-permit-document-guide.sgizmo.com/s3

Flag 5: Primary Residence in NY – The following documentation can be used to prove Primary Residency in NY:

  • Government issued ID that matches address on application
  • Current Lease
  • Federal/NYS Tax Returns
  • Rent attestation
  • Receipts of government benefits for at least 1 month prior to 3/1/20
  • Additional combination of Utility Bills, Bills/Bank Statements/Insurance documentation

Flags 6 and 7: Proof of Lease/Rent – The applicant must document that they are a tenant and the amount of rent paid with at least one of the following:

  • Copy of the Applicant Household’s signed lease.
  • Evidence of payment of monthly contractual rent obligations, such as a canceled check, prior to March 1, 2020; and
  • Completed rent attestation signed by the Applicant.

Flag 8: Evidence of Pre-COVID Rent Burden – Documentation provided for flags 1, 6, and 7 (Pre-COVID Income and Proof of Lease/Rent) should be used to confirm the monthly rent exceeded 30% of the monthly income prior to COVID.

Flag 9: Evidence of Post-COVID Rent Burden – Documentation provided for flags 2, 6, and 7 (Post-COVID Income and Proof of Lease/Rent) should be used to confirm the monthly rent exceeded 30% of their monthly income after 3/1/20 and that the rental burden had increased from the Pre-COVID period.

Flag 10: Landlord Address – Presence of Application Landlord Details is required.

Flag 11: Unemployment Benefits Disclosed – Applicant household members must disclose any unemployment they have received during the coverage period. If you received unemployment, including the additional funds related to Pandemic Relief, the program has updated your file with that information.
 

Explanation of Denial Codes

1 – The documentation provided by the applicant was insufficient.

The documentation provided by the applicant at the time of application was not sufficient to determine income eligibility or rent burden, and the applicant did not provide clarifying documentation upon request during application review within the required timeframe.


POSSIBLE EXPLANATION

Did you submit documents related to the following eligibility requirements in your original application: 
1. Have a primary residence in New York State. 

2. Before March 1, 2020 and when a resident applies, your household income must be below 80% of the area median income for your county and household size. Applicants can find your county’s area median income, based on household size: https://www.hcr.ny.gov/eligible-income-limits-80-ami-county 

Example: In Clinton County, the area median family income is $76,800. If you are a family of four, and your household income is below $58,950, your household would meet these criteria. 

3. Before March 1, 2020 and at the time of application, your household must pay more than 30% of your gross monthly income for rent. 

Example: Your monthly household income is $2,000. Thirty percent of your monthly household income would be $600, but you pay $700 a month in rent. Your household would meet these criteria. 

4. Have less monthly income in any month between April 2020 and July 2020 than prior to March 1, 2020 due to the COVID pandemic. 

Example: If you are paid hourly and have had your hours reduced since April 1, 2020, or have lost employment, you would meet these criteria. 

5. Received $600.00 a week in Pandemic Unemployment Assistance, which may mean that there was no loss in income.

2 – The documentation provided by the applicant was missing one or more required items.

The Applicant failed to answer questions or provide adequate supporting documentation at the time of application, and did not provide the required documentation upon request during application review within the required timeframe.

POSSIBLE EXPLANATION

Check that you answered all questions and provided all supporting documents.

 

1. Pre‐COVID Income Eligibility requirements not met – 

Before March 1, 2020, the applicant’s household income must be below 80% of the area median 

income for their county and household size. To see what 80% of area median income is in your 

county, please go to 

https://hcr.ny.gov/system/files/documents/2020/07/crrp2020_eligible_income_80ami.pdf 

2. Post‐COVID Income Eligibility requirements not met – 

At the time of application, the household income must be below 80% of the area median income for their county and household size. To see what 80% of area median income is in your county, please 

go to https://hcr.ny.gov/system/files/documents/2020/07/crrp2020_eligible_income_80ami.pdf 

3. Loss of Income not evident – 

The Covid Rent Relief Program required applicants to have less monthly income in any month between April 2020 and July 2020 than prior to March 1, 2020. 

4. ID verification cannot be completed – 

Applicant was unable to provide a current driver’s license or provide documents that add up to 6 points as per DMV requirements. http://nysdmv.standard‐license‐and‐permit‐documentguide. 

sgizmo.com/s3 

5. Household documentation is insufficient – 

Applicants must have provided and submitted information and documents for verification of them eligibility, including, but not limited to: 

  • household size and composition; and 
  • proof of the household’s gross income prior to March 1, 2020 and at time of application. 

6. Proof of rent not sufficient – 

Applicants must have submitted a copy of a lease, other proof of monthly rental amount; or the Tenant Rent Attestation (available on the portal) if a lease or other proof was unavailable 

7. Evidence of Pre‐COVID Rental Burden not sufficient – 

Before March 1, 2020, the applicant’s household must pay more than 30% of their gross monthly income for rent. 

8. Evidence of Post‐COVID Rental Burden not sufficient – 

At the time of application, the household must pay more than 30% of their gross monthly income for rent. 

9. Landlord Information is not complete/cannot be verified – 

Submitted landlord name and/or contact information must allow for verification of unit ownership and collection of relevant tax information. Please note any suggested documents are just suggestions and may or may not lead to successful appeals

10. Household is in receipt of Section 8 Housing Choice Voucher or resides in Public Housing – 

Applicant household is in receipt of Section 8 Housing Choice Voucher or resides in public housing and is therefore ineligible for COVID RRP. 

  

Remember this is just a suggested list and may or may not be one of the reasons you were denied.

3 – The income eligibility requirements for the program were not met.

Before March 1, 2020 and at the time of application, the Applicant’s household income must be below 80% of the area median income for their county and household size. To see what 80% of area median income is in your county, please go to: https://hcr.ny.gov/system/files/documents/2020/07/crrp2020_eligible_income_80ami.pdf


POSSIBLE EXPLANATION

This means your application did not show your income was less than 80% of Area Median Income for your county and household size. Your household is determined by how many people live their full time. Such documentation might have included:

 -2020 Tax Returns
-W2’s
-1099’s
-Unemployment documentation

4 – The applicant appears to be a beneficiary of tenant or project-based Section 8 or another federal or state rental subsidy, or resides in a Mitchel Lama co-op.

Applicant household appears to be a beneficiary of tenant or project-based Section 8 or another federal or state rental subsidy where the applicant’s rent can be no more than 30% of the household income and is therefore ineligible for the COVID Rent Relief Program. Applicants must rent their housing in order to be eligible.
 

POSSIBLE EXPLANATION
The rent relief program only provides assistance to people who have a rent burden above 30% of their income. Those who receive rent subsidies such as Section 8, or who live in subsidized housing that limits the rent they need to pay, are ineligible. 

5 – The applicant did not demonstrate that their household lost income during the coverage period.

The COVID Rent Relief Program required applicants to have less monthly income in the months between April 2020 and July 2020 that they are seeking assistance for than prior to March 1, 2020.
 

POSSIBLE EXPLANATION

This means the COVID Rent Relief Program required applicants to have less monthly income in any month between April 2020 and July 2020 than prior to March 1, 2020You were not able to demonstrate loss during the coverage period or your income did not decrease pre-covid to post covid. This could be due to retroactive Unemployment benefits, including the $600.00/week Pandemic Unemployment Assistance, or found wages as provided by search with the Department of Labor. 

6 – The applicant did not demonstrate the high rent burden required for the program.

Before March 1, 2020 and at the time of application, the Applicant’s household must pay more than 30% of their gross monthly income for rent.

 

POSSIBLE EXPLANATION
This means you did not demonstrate a high rent burden, in other words you failed to show your rent was greater than 30% of your income. Rent burden is the amount of monthly contractual rent that exceeds 30% of gross household income.  

 

Example: Prior to the COVID pandemic, your monthly household income was $2,000.  Your monthly rent is $700.  This means that on March 1, 2020, your rent burden was 35%.  Today, due to a reduction in hours, your monthly income has decreased to $1,400 and your rent remains the same.  You are now paying 50% of your monthly income toward rent.  You would be eligible for a subsidy that covers the 15% (50% - 35%) increase in your rent burden, or $210. This subsidy would get you back to your pre-March 1, 2020 rent burden of 35%. 
To calculate your rent burden, divide your rent by your income and multiply by 100.  
If your rent burden is 30% or below you are unfortunately not eligible for the program. If your rent burden is 30% or higher submit supporting documents showing your lease and your income showing the rent burden. 

 

7 – The Household’s unemployment benefits data conflicts with the application.

Applicant was in receipt of unemployment benefits that were not included in the household income and places household above income eligibility threshold.

POSSIBLE EXPLANATION
Unemployment benefits were not reported in your initial application. Review of data maintained on the State database and provided by the New York State Department of Labor shows that you may have received Unemployment benefits (including Pandemic Unemployment Assistance) either at the time and/or retroactively. These unemployment benefits increased the applicant’s post-COVID income, meaning that the applicant was not able to demonstrate income loss during the period of coverage. As a result, the applicant is no longer eligible based on the program’s eligibility requirements. 

8 – ID verification cannot be completed.

Applicant was unable to provide a government issued ID that was valid as of March 1, 2020, or if this form of identification was unavailable, applicant was unable to provide documents that add up to 6 points as per DMV requirements. http://nysdmv.standard-license-and-permit-document-guide.sgizmo.com/s3
 

POSSIBLE EXPLANATION 
This may mean that the applicant’s name did not match the name on your identification Document or that your government issued identification is not currently valid or expired prior to March 1, 2020.  Valid documentation can be   

  1. Birth Certificate 
  1. Driver’s License 
  1. Passport 
  1. documents that add up to 6 points as per DMV requirements. http://nysdmv.standard-license-and-permit-document-guide.sgizmo.com/s3 
    (this can be used to support expired id documentation)  
9 – The Applicant did not demonstrate that they are a tenant with a primary residence in New York State.

Applicant must have submitted a copy of a lease, other proof of monthly rental amount, or the Tenant Rent Attestation if a lease or other proof was unavailable, evidencing a rental obligation for a residence within New York State.
 

POSSIBLE EXPLANATION

This means the applicant failed to prove their primary residence is a rental in New York State. This could mean the applicant uses the rental as a secondary address, with the primary residence in another state and/or the primary residence is owned by the applicant. The applicant would need to submit documentation indicating that the residence is a rental by providing a lease, a rental agreement or evidence of monthly rental obligations, or complete the Tenant Rent Attestation. Documents that might evidence primary residence include government issued ID with address that matches; current lease; federal/state tax return; government benefit documents for at least 1 month prior to March 1 or additional combination of utility bills, bank statements and insurance documents satisfactory to NYSHCR. 

10 – Landlord information is not complete/cannot be verified.

Submitted landlord name and/or contact information must allow for verification of unit ownership and collection of relevant tax information.

POSSIBLE EXPLANATION
The landlord failed to sign the requested DocuSign or send tax information and/or provide a TIN or SSN for taxation. The applicant would need to request this information from the Landlord, get an email address and request a W9, or email a W9, please ask your landlord to include your confirmation number on any correspondence. https://www.irs.gov/pub/irs-pdf/fw9.pdf

11 – Application was withdrawn.

Applicant withdrew application for COVID Rent Relief Program

POSSIBLE EXPLANATION

This means the applicant requested the application to be withdrawn, either by written or phone request. This can also mean an applicant requested to edit their application and failed to resubmit a new application after deletion. No applications were withdrawn with an explicit request from the applicant.
 

12 - Based on program calculations using a variety of factors associated with the application the subsidy amount is zero, the applicant does not qualify for a payment.

The application was determined to be eligible, however based on program calculations using information provided in the application or obtained from other state agencies, the subsidy amount was calculated to be zero and the applicant does not qualify for payment.
This means the applicant was awarded a zero-dollar amount for their subsidy based on system calculations and review. The applicant can attempt an appeal by showing income or rent burden differs from the originally submitted application for a new calculation. For document details please return to Denial Code-01
Please note any suggested documents are just suggestions and may or may not lead to successful appeals.

13 – Applicant awarded under prior COVID Rent Relief Program

The application was determined to be eligible, and an award was generated under the original COVID Rent Relief Program.  The applicant is not entitled to additional funds under the expanded COVID Rent Relief Program.


This Denial Reason is not eligible for appeal.

14 – The Applicant submitted a duplicate application or applications

The Applicant submitted more than one application to the COVID Rent Relief Program.  Only one application will be reviewed.  If the Applicant submitted an application under both the original COVID Rent Relief Program and the extended COVID Rent Relief Program or else submitted multiple applications under the extended COVID Rent Relief Program, the information provided in the first application will be reviewed.

This Denial Reason is not eligible for appeal.