To Count or Not to Count: Unemployment, Child Tax Credit, and Emergency Rental Assistance Updates

June 2021

There are many pandemic relief programs available. With each state having its own set of rules it can be difficult to know who is receiving what. Not to mention what can be counted as income. Read on as we review the currently available programs along with quick reference points to see what benefit to count or not to count.

Unemployment Compensation

The CARES Act introduced the following three types of unemployment compensation: 

• Section 2102: PUA (Pandemic Unemployment Assistance) – this the federal unemployment created for self-employed individuals, contractors, and gig job workers.  The extended benefits for PUA is up to 79 week through 9/6/21.  This income is included.
• Section 2107: PEUC (Pandemic Emergency Unemployment Compensation) – this is an extension of tradition Unemployment Insurance benefits.  The extended benefits for PEUC is up to 53 weeks through 9/4/21.  This income is included.
• Section 2104: FPUC (Federal Pandemic Unemployment Compensation ) – this is the additional $600 reduced later to $300) for those receiving unemployment.  This is available through 9/4/21, but be aware that many states are ending this program early (for example, in Ohio this is ending 6/26/21 while CA will continue the benefits with the caveat that the recipient must show attempts to become employed to get the benefit).  This income is excluded.

Advance Payment of Child Tax Credit may be received July 2021 – December 2021.  This payment will vary based on the number of children and ages of the children, but it will likely show up as a deposit on bank statements.  This income is excluded.

Emergency Rental Assistance (ERA)

HUD has not provided guidance for the Multifamily Housing Programs,  They have provided guidance for the Public and Indian Housing Programs, though. PIH guidance indicates that ERA income is excluded.  HUD stated, “Under section 501(j) of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116- 260 (Dec. 27, 2020), assistance provided to a household shall not be regarded as income and shall not be regarded as a resource for purposes of determining the eligibility of the household or any member of the household for benefits or assistance, or the amount or extent of benefits or assistance under any Federal program or under any State or local program financed in whole or in part with Federal funds.”