Common Questions about Form-HUD 9902

A revised HUD form 9902 became effective on October 1, 2006. Form 9902 is the Housing Counseling Program data collection instrument for all HUD-approved housing counseling agencies. The following questions and answers are designed to assist agencies in using the revised form and accurately reporting housing counseling activities.

1. What is the purpose of the revised form HUD-9902?

   The goal of the revised HUD-9902 form is to improve the quality of Housing Counseling Program data and to standardize the response methodology. The 9902 data is critical for demonstrating the impact of the program to Congress and the Office of Management and Budget and the White House. HUD uses data analysis to justify proposed appropriations, develop performance indicators, and report performance goal accomplishments.

   Form HUD-9902 data also plays a critical role in Notice of Funding Availability (NOFA) scoring. HUD evaluates 9902 data within the context of type of services provided, costs, spending decisions, and other factors. It is extremely important for agencies to accurately report education and counseling activities.

2. How does an agency access the new form HUD-9902?

   Each participating agency's template is available on HCS. HCS can be accessed on HUD's website.

3. When are form HUD-9902 submissions due?

   Starting in FY 07, Form HUD-9902 is due quarterly. The first and third quarter reports and the midterm report are due on the last calendar day of the month after the end of the reporting period. The final report is due December 31st. In the rare instance where HUD or an agency terminates approval, the agency will be asked to submit form 9902 within 30 days from the date of termination.

4. Does quarterly reporting require submissions be cumulative?

   Agency activities should be reported cumulatively. The quarterly 9902 should reflect cumulative year-to-date data.

5. How does an agency participating in the housing counseling program submit form 9902?

   Every agency is required to submit form HUD-9902 electronically through the HCS system or through a Client Management System (CMS) that interfaces with HUD's database.

6. What is the reporting period?

   HUD's reporting period follows the federal government's fiscal year cycle: October 1 through September 30.

7. What are the reporting requirements for State Housing Finance Agencies (SHFAs) that do not receive HUD funding?

   An SHFA electing to participate in the program, despite not having received a grant, must meet all program requirements, including Form 9902 reporting.

   Many HUD-approved housing counseling agencies do not apply and/or receive funding through the NOFA. Why should these agencies submit a form 9902 and perform accurate data collection?

   Submitting form 9902 is a requirement for continued HUD approval and program participation. Accurately reporting activities on 9902 is in your best interest. Accurate data assists HUD in demonstrating vital needs and demand for housing counseling nationwide. It is also a basis for HUD's justification of funding for training HUD-approved Housing Counseling Agencies.

8. Who and what gets counted on Form 9902?

   Only counseling and education activities are recorded. Marketing and outreach, such as community presentations, are not recorded.

9. Is a course that occurs in four 2-hour sessions considered four courses or one?

   The form is designed to capture participation in each complete course on a unique educational topic. Whether a course is completed in one 8-hour session, or four 2-hour classes, it counts as one course.

10. Does Section 6 exclusively capture workshop activity?

    Yes. Section 6 exclusively captures workshop activity. One-on-one counseling activity is not to be recorded in Section 6.

11. Are group education and/or activities and results recorded in Section 7? For example, an individual participates in a homebuyer education course. That provides sufficient information to successfully purchase a home. Does the agency record an individual's participation in Section 6, the group section, and record the result in Section 7?

    No. Group education/outreach session results aren't recorded in Section 7.

    HUD is aware that some agencies have developed follow-up systems and/or surveys to capture results of group education sessions. HUD encourages that practice and grant recipient agencies can include the results in the midterm and final narratives.

12. If an agency offers predatory lending and financial literacy in one seminar, how should this be reported?

    Report it in Section 6 under a workshop category or "h. other" category". This type of workshop is treated as one unique workshop covering different topics.

13. How can I quality control my submission to make sure that the data is accurate and complete?

    The new form has a built-in quality control mechanism. This means that the Section 3 total = Section 4 total, = Section 5 total, = the total of Sections 6 and 7 combined.

14. HCS auto-populates HUD grant activity in the right hand column of form 9902. Will these HCS-produced figures be used to evaluate performance relative to projections made on the logic model, form HUD-96010?

    No. The logic model will be used by grantees to make projections relative to the grant and report on the actual activities attributed to the grant. On the 9902, numbers HCS attributes to an agency will not necessarily be the same as the activity the agency reports on the logic model.

15. Do quarterly 9902 reports replace the logic model?

    No. Specific HUD Housing Counseling grant activities will be reported through the logic model.

16. How were the race and ethnicity categories established?

    The Office of Management and Budget requires us to collect this data and developed these categories. It is part of a government-wide effort to capture race and ethnicity data for all beneficiaries of government programs.

17. How does an agency properly complete Sections 3 and 4 of form 9902?

    An agency should select one option under Section 3 and one under Section 4 for each counseling or education activity recorded, resulting in equal totals reported in Sections 3 and 4.

    HUD requires racial and ethnic data for those participating in education and workshops as well as those receiving one-on-one counseling. Ideally, the number of households counted in the racial/ethnicity section would equal the total number counseled. The 9902 has a new category to facilitate this: "chose not to respond" for those clients who are unwilling or unable to self-identify.

18. There are no categories for people of Middle Eastern descent in Section 4. How would an agency report these clients?

    Report these clients as "white" according to OMB guideline definition of "white" as "a person having origins in any of the original peoples of Europe, the Middle East, or North Africa".

19. What if an individual comes in for multiple, distinct types of counseling in a reporting period? Would an agency consider the person a new client each time and record demographic data each time?

    Yes. Record racial and ethnic data each time an individual visits the agency for a different type of counseling service. For example, if an individual comes in for one type of counseling (pre-purchase), record demographic data, type of counseling, and outcome once the file is terminated. If the same person returns later in the reporting period for another type of counseling (default counseling), record the new activity in Section 7 and record demographic data a second time.

20. How does an agency report a client seeking counseling more than once for the same issue? For example, an individual receives housing counseling for mortgage default. The default is resolved through a special forbearance. Several months later, the person returns for default counseling again. Are these reported as two separate clients?

    The answer depends on whether the agency terminated counseling after the first visit. In this example, the first visit resulted in an initiated forbearance agreement or payment plan. The agency should have terminated the counseling and closed the file. The second visit for the same issue counted as a new event and the agency should report the demographic information and counseling results again for the individual.

    In the second scenario, the client never resolved the default at the first visit and the file was not terminated. The client's second session is considered a continuation of their default counseling. In this situation, the agency should only record demographic data once. The result of the counseling would be reported as: "currently receiving Foreclosure Prevention/Budget Counseling".

21. How often does HUD publish income data limits?

    HUD publishes new income data limits each year. The latest set is available at: www.huduser.org/datasets/il.html

22. How does an agency accurately calculate income levels?

    Agencies should record income levels in Section 5 for all activities and record individual counseling or group education activities in Sections 6 and 7. Income levels are based on the percentage of the median income for the area (AMI) for each client recorded. AMI's for each state or county can be found at HUD's website.

    To find "Income Levels" data:

    • Click on the HUD User data sets link.
    • On the Data Sets page, scroll down to the U.S. map.
    • Click on the applicable state to view Median Family Income by county and family size.