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Housing and Homelessness

Directive # 2004 - 04

Date: July 6, 2004

The policies, procedures and Service Manager Requirements in this Directive are to be implemented by the Housing Access Centre (Durham Region) Co-operative Inc. and all housing providers in the Region of Durham included under the provisions of the Social Housing Reform Act and its associated Regulations.

Please note: If your housing corporation is not covered by the Social Housing Reform Act, this Directive is for information purposes only.

Subject

Quarterly Reporting Reviews

Background

Subsection 50(13) of Ontario Regulation 298/01 of the Social Housing Reform Act allows for income averaging when calculating rent-geared-to-income (RGI) assistance if the service manager has reason to believe that the income fluctuates from month to month.

Housing providers in the Region of Durham perform RGI calculations on behalf of the service manager. However, housing providers average income in different ways resulting in discrepancies in the way that RGI is calculated for households with fluctuating income. Standards are required to ensure that RGI calculations are performed consistently across the Region of Durham.

Quarterly Reporting Reviews are required for all RGI households with fluctuating earnings. Designated households are required to report income every three months. The housing provider will use this information to determine average monthly income and to recalculate the amount of RGI assistance as required.

Quarterly Reporting Reviews do not replace the requirement for an Annual Review of RGI eligibility.

Action Required

Quarterly Reporting Reviews are a means of both reporting income and determining a monthly average for fluctuating income. They replace all current methods used by housing providers to average income.

Households with fluctuating earnings must be notified of their responsibility to report their income every three months. Once the household provides this information, the housing provider will verify the income, re-determine the average amount of earnings and recalculate RGI as required.

Quarterly reporting periods may be different for each household with fluctuating earnings depending on when the household's earnings started or when Quarterly Reporting Reviews were first introduced by the housing provider.

Households with Quarterly Reporting Reviews

Only households with regular but fluctuating earnings will be required to complete Quarterly Reporting Reviews. This includes households with:

  • Employees who are paid at an hourly rate and who do not work the same number of hours from week to week
  • Salaried employees who receive frequent bonuses or gratuities
  • Temporary employees that work regularly with the same or different employers

It is anticipated that most households with earnings will be required to complete Quarterly Reporting Reviews.

Quarterly Reporting Reviews are not required for:

  • Households with only fixed income (e.g. Old Age Security)
  • Ontario Works or ODSP households with non-benefit income that is well below threshold
  • Seasonal employees that do not have earnings in the off season

Income for these households will continue to be reviewed annually. Fluctuating income from the previous year (e.g. seasonal earnings) is averaged over the entire year to determine a monthly amount.

Initial Monthly Estimate of Earnings

Once the housing provider has determined that a household is subject to Quarterly Reporting Reviews, it will estimate the monthly earnings that will be used for the calculation of RGI during the first quarter. The initial estimate should reflect the monthly earnings that are likely to be received by the household over the next three months. Extra payments, such as vacation pay, are not to be included in determining this initial estimate.

Wherever possible the housing provider should base the initial estimate of earnings on actual earnings. All income used in determining the initial monthly estimate must be verified.

Earnings are only estimated for the first quarterly reporting period.

Quarterly Reporting Statement (QRS)

The household must submit a Quarterly Reporting Statement (QRS) every three months. The QRS is used to determine the average monthly income for the calculation of RGI. A sample QRS is provided in Appendix A: Quarterly Reporting Statement (QRS) (PDF). An electronic version can also be requested from the Housing Services Division.

Quarterly reporting periods will begin on the first day of the month and end on the last day of the third month. Households with fluctuating earnings must submit verification of actual income received during this period. Money that is earned or owing to the household is not reported on the QRS until it is received.

The QRS and verification of income are due on the first day of the month following the end of the quarterly reporting period. For example, a household will submit verification of income received between January 1 and March 31 on April 1.

If the household does not submit the QRS and income verification by the 16th of the month, the housing provider will notify the household that:

  • The QRS is overdue; and
  • Failure to provide the QRS by the last day of the current month may result in ineligibility for RGI assistance

If the QRS is not returned by month end, the housing provider will notify the household that it is ineligible for RGI assistance and is responsible for the full market rent upon 90 days notice. The household may request a Regional Review of a decision of ineligibility within 10 days.

The decision of ineligibility may be reversed by the housing provider in the event that the QRS is received.

Verification of Income

Once the QRS is returned, the housing provider will verify the earnings that were declared. The housing provider is not required to re-verify or re-assess fixed income or assets at the time of the Quarterly Reporting Review. This will be done at the time of the Annual Review.

Acceptable forms of earnings verification include:

  • Pay stubs; or
  • A signed letter from an employer that includes:
    • Name of employer
    • Gross amount of each payment received for the period
    • Dates of payments
    • Total gross year-to-date payments received
    • A contact name and telephone number

Averaging Earnings

Housing providers will average the earnings declared on the QRS. In determining average earnings, the housing provider will:

  • Total all payments received during the quarterly reporting period
  • Divide by the number of pay weeks in the period even if a payment was not received for every week
  • Multiply by 4.333

Recalculation of RGI

Housing providers will use the average amount of earnings to re-calculate RGI. Fixed income, imputed income and interest income amounts will not change.

RGI changes as a result of a Quarterly Reporting Review will be implemented as follows:

  • All RGI decreases will take effect on the first day of the month following the due date for the QRS
  • RGI increases of $10 or more will take effect on the first day of the second month following the due date for the QRS
  • RGI increases of less than $10 will not be implemented

Housing providers will give households written notice of any RGI changes within 7 business days of making such decisions. Notice must include the household's right to request a Regional Review of the RGI change per Directive 2004-01 Regional Review Process.

The housing provider should also send the household a new QRS for the household to complete for the next quarterly reporting period at this time.

Other Changes

Households with fluctuating earnings will not normally have their rent re-calculated midway through the quarterly reporting period. Income is expected to fluctuate during this period and is averaged accordingly. Temporary shifts in the number of hours worked do not warrant adjustments outside of the regular Quarterly Reporting Reviews.

However, where there has been a change to a fixed income source, the RGI may be re-calculated using the new fixed income amount and the existing average earnings amount. The average earnings are not adjusted until the end of the next quarterly period despite the change to the fixed income amount. The housing provider is only required to verify the change to the fixed income amount.

Additionally, adjustments can be made for tenants who have significant and permanent changes to their earnings part way through the quarterly reporting period. Significant and permanent changes may include:

  • A new employment source that significantly changes the monthly average earnings
  • Cessation of employment
  • A permanent move from part-time to full-time hours or vice versa that significantly changes the monthly average earnings

Annual Review of RGI Eligibility

Housing providers will make all attempts to synchronize changes as a result of the Annual Review of RGI Eligibility with the nearest quarterly reporting change. This will avoid multiple changes within a short time frame and reduce administration.

If you have any questions please contact your Housing Co-ordinator.


Shirley Van Steen
Director of Housing Services