If a PHA does the five year look-back allowed in rule to identify and capture current employees, does the five years the rule allows a person to be counted into the future pertain to those people that were hired and met the Section 3 definition five years ago? Thus allowing the PHA to count them for a total of 10 years.

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Response From HUD:

No. There is no reach back into the time before the new rule effective date. PHAs and other recipients will have to recertify employees as Section 3 workers under the new rule sometime between November 30 and July 1, 2021.

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