TRACS 202D Nuts and Bolts: New Move-Out and Termination Codes

Editor’s note: Jed Graef, Bostonpost Product Manager, provides the latest information on the upcoming TRACS 202D affordable housing industry specification update. For more on the pending TRACS 202D changes, read Jed’s previous post or you can click here for a complete list of Jed’s continuing TRACS 202D coverage.

TRACS 202D greatly expands the set of reasons that can be assigned to a move-out (MO) or termination (TM). These additions allow for more flexibility and give HUD more precise data as to why these transactions are happening. For now, it is worth studying the additions and deciding whether any revisions are needed to your policy and procedures manuals.

For the Move-Out Code we currently have these values:

1 = Owner initiated for nonpayment of rent

2 = Owner initiated–other

3 = Tenant initiated–other

4 = Death of sole family member

In 202D, there are seven new codes:

5 = Unit Transfer between two projects

6 = Reserved for TRACS use only (HQ Move Outs)

7 = Abandoned Unit – PDD (PDD stands for Presidentially Declared Disaster)

8 = Failure to submit SSN

9 = Uninhabitable unit – Abated

10 = Substantial Rehab or Repair – Tenant Expected to Return

11 = RAD to Housing Choice Voucher-Choice Mobility Option Exercised

Note for code 11: Used only for a RAD tenant accepting a housing choice voucher.

Code 5 is for a legal but rare situation.  The handbook specifically allows for a unit transfer between projects as a reasonable accommodation where the owner/agent controls multiple projects. There are TM codes similar to 7, 9 and 10.  Whether a MO or a TM is done in response to these situations will often depend on where the tenant will be living after the event and whether or not they will be returning.  If the household is going to be living in other subsidized housing temporarily, a MO is needed to prevent double subsidy reports.  If they will not be in subsidized housing then a TM is often the best course of action.  When in doubt, consult with your asset manager.  Code 11 is only applicable for those with a Section 8 RAD contract.  The existing codes 2 and 3 can be looked at as “none-of-the-above” values and should be used only when one of the others does not apply.

On the Termination side, the current codes are:

TI = TTP Equals/Exceeds Gross Rent or moving to market rent

TC = Did not supply citizenship documentation

TR = Did not re-certify on time

TF = Tenant refused to transfer or submitted false data

CE = Subsidy contract expired-not renewed

ST = Ineligible Student

DS = Double subsidy at move-in

There are two current TM values that are reserved for HUD use:

EN = Contract terminated for enforcement action

HQ = TRACS generated termination for failure to recertify

The new TM codes are:

ND = Natural Disaster or Uninhabitable Unit or Presidentially Declared Disaster

AB = HUD abated unit.

RR = Substantial rehab or repair – Tenant expected to return.

NS = Resident did not qualify for subsidy at MI or IC –Not Double Subsidy.

OT = Other.  A reason not covered by any of the other codes.

NS is similar to the DS code in that it changes how a TM subsidy adjustment is calculated—subsidy is returned for the day of the TM.  Other TMs retain subsidy for the TM effective date.  An example of when this code might be used is on a correction to a move-in (MI) or initial certification (IC) where the tenant ends up with zero-subsidy, thereby triggering a TM.  The tenant did not qualify for subsidy on the MI or IC date and the subsidy must be returned to HUD.

The OT addition is one that has been requested for many years.  Some owners have found themselves in a position where a HUD office instructed them to terminate a household after a natural disaster, rendering a unit uninhabitable,  however there was no code applicable to that situation.  If the owner ended up in court for some reason and the judge asked if the TM Code was an accurate description of why the TM occurred, the owner would have to say that it was not and cases were often dismissed or decided against the owner for that reason.  While the 202D codes do include ones for natural disasters and the like, the OT code may be used for any legitimate TM reason not covered by the others.

Important Note: Do not use a termination to end subsidy after the death of a sole member. Use the move-out transaction instead. HUD Policy has said that a TM is never appropriate following the death of a sole member, even in cases where the deceased’s estate is delayed in removing the possessions from the unit.  It is fine to keep billing subsidy for the unit.  The MO, when submitted, will be effective on the actual MO date—the date when the owner/agent takes possession of the unit.  Site software will automatically return any subsidy billed past the 14-day maximum allowed after the death so long as MO Code 4 is used.

For a more in-depth look at all of the changes coming in 202D as well as links to preview the new TRACS forms, download the Industry Bulletin: Affordable Housing Preparedness for TRACS 202D Modification.

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