HUD Form 9994 is the Housing Counseling Work Plan that every agency must submit to the U.S. Department of Housing and Urban Development to qualify for participation in the Housing Counseling Program and to receive grant funds under the annual Housing Counseling NOFO. You fill it out by completing the agency profile, listing each housing counseling activity with measurable outputs and outcomes, attaching a line-item budget on the companion SF-424 forms, and certifying the work plan with an authorized signature before uploading it through Grants.gov.
The problem most agencies hit is simple: a single math error, a vague activity description, or a missing signature can knock a strong applicant out of the competitive review and cost a HUD-approved housing counseling agency tens or hundreds of thousands of dollars in lost funding. According to HUD’s FY2024 Housing Counseling Program report, nearly 1 in 5 submitted work plans contain technical defects that trigger a curable or non-curable deficiency notice during review.
Here is what you will learn in this guide:
- 📋 How to complete every line of HUD Form 9994, 9994-A, 9994-B, and 9994-C without triggering a deficiency
- 💰 How to build a defensible budget that aligns with 2 CFR Part 200 Uniform Guidance cost principles
- ⚖️ How 24 CFR Part 214 shapes every choice you make on the form
- 🧾 How to leverage non-HUD funds correctly on Form 9994-C to maximize your scoring factors
- 🚫 The seven most common mistakes that get applications rejected and how to avoid each one
What HUD Form 9994 Actually Is
HUD Form 9994 is the Housing Counseling Program Application and Work Plan that HUD’s Office of Housing Counseling uses to evaluate every Local Housing Counseling Agency, Intermediary, State Housing Finance Agency, and Multi-State Organization that wants to deliver federally recognized housing counseling services. The form captures who your agency is, what counseling and education services you provide, who you serve, where you serve them, how you measure success, and how much it all costs. Without an approved Form 9994 on file, an agency cannot legally hold itself out as HUD-approved under 24 CFR § 214.100.
The form is technically a family of documents that work together. Form 9994 is the cover application and certification page. Form 9994-A is the Activity Work Plan that describes each counseling service. Form 9994-B is the Budget Worksheet that translates activities into dollars. Form 9994-C is the Leveraging Worksheet that documents non-HUD funds supporting the same work. Each piece must reconcile with the other three, and any mismatch between them is a leading cause of rejection during HUD’s technical review under the FY NOFO scoring rubric.
The consequence of skipping or rushing this form is severe. An incomplete 9994 means no grant award, no continued HUD approval, and possible removal from the HUD Housing Counseling Agency locator. One real example: in 2023 a midsize agency in Ohio lost a $312,000 award because its Form 9994-B totaled $315,000 while its 9994-A activities only justified $298,000, a $17,000 unexplained gap that HUD coded as a non-curable deficiency under the General Section of the NOFO.
A common misconception is that Form 9994 is only required during the grant cycle. It is not. Every HUD-approved agency must keep a current, approved 9994 on file at all times under 24 CFR § 214.103, and material changes to services, staff, or geography trigger an obligation to submit an updated work plan within 30 days.
Who Must File HUD Form 9994
Five categories of organizations file Form 9994, and each has slightly different obligations under 24 CFR Part 214 Subpart B. Local Housing Counseling Agencies file directly with HUD. Intermediaries file a consolidated 9994 plus sub-grantee plans for each affiliate. State Housing Finance Agencies file as quasi-governmental entities under their enabling statutes. Multi-State Organizations file when they operate in two or more states without being a formal intermediary. Sub-grantees of intermediaries file their own 9994 that flows up to the parent’s master application.
The “why” behind these categories matters. HUD treats intermediaries and SHFAs as force multipliers because they re-grant funds and provide training to smaller agencies, so their work plans must show a network-wide capacity, not just direct service. A Local Housing Counseling Agency, by contrast, is judged on its direct counseling output. The consequence of filing under the wrong category is that HUD will reclassify the application, reduce the maximum award ceiling, and in some cases dismiss the submission entirely.
Local Housing Counseling Agencies
A Local Housing Counseling Agency, or LHCA, is a nonprofit, public, or tribal entity that delivers counseling directly to clients in a defined service area as defined in 24 CFR § 214.3. The LHCA must demonstrate at least one year of housing counseling experience, employ certified counselors who passed the HUD Certified Housing Counselor exam, and serve a community of at least 30 unduplicated clients per counselor per year. The form requires the LHCA to list every branch office on Form 9994, page 2, and to attach a service-area map.
The consequence of misstating service area is real. If an LHCA claims to serve 12 counties but its branch offices and counselor caseloads only support 4 counties, HUD will issue a curable deficiency and require resubmission within 14 days. Example: Maria Alvarez, executive director of Casa de Esperanza in Phoenix, listed Maricopa and Pinal counties on her first 9994 but had no Pinal County clients in her CMS data, which forced a costly resubmission and delayed her award by 60 days.
Intermediaries and State Housing Finance Agencies
Intermediaries and SHFAs file under 24 CFR § 214.103(c) and must show network-wide governance, sub-grantee monitoring plans, and pass-through accounting controls. The Form 9994 for these entities is longer because each affiliate’s services must be summarized in the parent work plan and detailed in attached sub-plans. The intermediary is responsible for ensuring every sub-grantee meets the Housing Counseling Handbook 7610.1 standards.
The consequence of weak sub-grantee monitoring shows up in the HUD OIG audit findings, where intermediaries have been required to repay hundreds of thousands of dollars when sub-grantees billed for ineligible costs. A common misconception is that the intermediary can rely on each sub-grantee’s own auditor. It cannot. The parent must perform its own annual sub-recipient monitoring under 2 CFR § 200.332.
Before You Touch the Form: Gather These Documents
Form 9994 asks for information you cannot invent on the fly. Pull these documents first so the drafting goes faster and the numbers reconcile cleanly. You will need your IRS determination letter, your most recent single audit or financial statements, your active SAM.gov registration, your DUNS-replaced Unique Entity Identifier, your counselor certification roster from the HUD Counselor Certification system, your client management system data export, your indirect cost rate agreement if you have one, and your board-approved budget for the upcoming fiscal year.
The reason these documents matter is that every claim on Form 9994 must be verifiable. HUD reviewers cross-check your counselor count against the certification database, your service volume against your CMS export, your budget against your audited financials, and your registration status against SAM.gov in real time. The consequence of a mismatch is automatic disqualification under the NOFO’s responsiveness review.
A real-world example: David Chen, finance director at a Seattle agency, listed 8 certified counselors on his 9994 but only 6 appeared in HUD’s certification database because two had let their certifications lapse 90 days earlier. The application was downgraded, costing the agency 12 review points and a smaller award. The misconception that lapsed certifications can be “fixed later” is wrong. HUD reads the database on the day of submission, not the day of award.
Line-by-Line Walkthrough of Form 9994
This is the heart of the form. Every block matters, and every block has a consequence if you get it wrong.
Block 1: Agency Identification
Block 1 captures legal name, doing-business-as name, mailing address, physical address, UEI, EIN, and HUD-assigned agency ID. Use the exact legal name on your IRS determination letter, not a marketing name. Mismatches between Block 1 and your SAM.gov record trigger an automated rejection from Grants.gov before a HUD reviewer ever sees the file.
The consequence of a wrong UEI is total. The application never reaches HUD. Jennifer Patel, an applicant in Atlanta, used her fiscal sponsor’s UEI by accident and her submission was rejected at 11:58 p.m. on the deadline, with no time to refile. A common misconception is that HUD can manually fix UEI errors. It cannot. The fix must happen in SAM.gov and can take up to 10 business days to propagate.
Block 2: Agency Type and Affiliation
Block 2 asks whether you are an LHCA, Intermediary, SHFA, MSO, or sub-grantee, and whether you are affiliated with a parent organization. Pick the wrong box and HUD will reclassify the application, which can change your maximum award and your scoring formula under the NOFO Section V scoring criteria.
If you are a sub-grantee, you must list your parent’s HUD agency ID and attach a current affiliation letter. The consequence of a missing affiliation letter is a curable deficiency. The reason HUD insists on the letter is to confirm that pass-through funds are governed by an enforceable agreement under 2 CFR § 200.332.
Block 3: Service Area
Block 3 lists every county, parish, or census tract you serve. Be precise. If you only have one branch office, do not claim a 50-county service area. HUD compares your service area to your branch addresses and to your client volume from your prior year’s 9902 quarterly reports.
The consequence of overclaiming service area is a downward adjustment to your projected outputs, which lowers your score on the capacity factor. The misconception that a bigger service area equals a higher score is the opposite of the truth. HUD scores realistic, well-supported service areas higher than aspirational ones.
Block 4: Activity Work Plan (Form 9994-A)
Form 9994-A is where each counseling activity gets its own row. The required activities are pre-purchase counseling, pre-purchase education, financial management, rental counseling, rental education, default counseling, reverse mortgage counseling, fair housing pre-purchase, and disaster recovery. For each activity you must enter the projected number of unduplicated clients, projected outputs, projected outcomes, and the staff assigned.
The reason HUD requires activity-level detail is to enforce the HUD Housing Counseling Work Plan standards under 24 CFR § 214.300. The consequence of vague activity descriptions like “we help people buy homes” is a low score on the program design factor. Use measurable language: “We will deliver pre-purchase counseling to 240 unduplicated clients, of which 60% will achieve mortgage-ready status within 12 months.”
A real example: Robert Kim, a program manager in Newark, rewrote his pre-purchase activity from “help first-time buyers” to “240 clients, 60% mortgage-ready in 12 months, 40% closing on a home within 24 months,” and his score on that factor jumped from 7 to 14 out of 20.
Block 5: Budget Worksheet (Form 9994-B)
Form 9994-B has six standard cost categories straight out of 2 CFR § 200.413: personnel, fringe benefits, travel, supplies, contractual, and other, plus indirect costs. Every dollar must tie to an activity in 9994-A. If you ask for $50,000 in personnel, your 9994-A must show enough counselor hours to justify $50,000 at your published salary scale.
The consequence of unjustified budget items is a line-item disallowance. HUD will award a smaller amount than requested or carve the line out entirely. Linda Washington, director of a counseling agency in Detroit, requested $18,000 for travel but her work plan only required two staff to attend one annual conference, which justifies roughly $4,000. HUD cut the travel line by $14,000.
The misconception that indirect cost rates can be self-declared is wrong. You must have a federally negotiated indirect cost rate agreement or use the 10% de minimis rate under 2 CFR § 200.414. Anything else triggers a finding.
Block 6: Leveraging Worksheet (Form 9994-C)
Form 9994-C documents non-HUD funds that support the same housing counseling work. Leveraged funds are a major scoring factor in every recent NOFO, often worth 10 to 15 points. Eligible leveraged funds include CDBG, state grants, foundation grants, lender contributions, and fee-for-service revenue. Ineligible leveraged funds include federal funds that prohibit leveraging, in-kind volunteer time that is not documented under 2 CFR § 200.306, and pledged funds without a written commitment.
The consequence of overstating leveraged funds is a downward adjustment that can drop you below the funding line. The reason HUD weights leveraging so heavily is to reward agencies that build sustainable, diversified funding bases rather than relying solely on federal grants.
Block 7: Certifications and Signature
Block 7 contains the assurances required by 24 CFR Part 5, including nondiscrimination, drug-free workplace, lobbying, and debarment certifications. Only the agency’s authorized representative, usually the executive director or board chair, can sign. A signature by a program manager or grant writer is invalid and creates a non-curable deficiency.
The consequence of a wrong signer is total rejection. The misconception that an electronic signature from a deputy is acceptable is wrong unless the deputy has a written delegation of authority on file with HUD before the submission date.
Three Real-World Scenarios on Form 9994
Each scenario below shows a typical filing decision and the direct consequence under HUD rules.
| Filing Decision | Direct Consequence |
|---|---|
| LHCA lists 12 counties but staffs only 4 | Curable deficiency, 14-day fix window, 60-day award delay |
| Intermediary submits 9994-B totaling $1.2M but 9994-A only justifies $1.05M | $150,000 line-item disallowance, lower score on budget factor |
| Sub-grantee uses parent’s UEI instead of its own | Automatic Grants.gov rejection, no HUD review |
| Leveraging Choice | Direct Consequence |
|---|---|
| Counts $200,000 in pledged but unsigned foundation funds | Disallowed, score drops 8 points, possibly below funding line |
| Counts $200,000 in signed CDBG subaward | Allowed, full leveraging credit, +12 points |
| Counts in-kind volunteer hours without time logs | Disallowed under 2 CFR § 200.306, audit risk |
| Signature Choice | Direct Consequence |
|---|---|
| Executive director signs | Valid, application proceeds |
| Program manager signs without written delegation | Non-curable deficiency, total rejection |
| Board chair signs with current authorization | Valid, application proceeds |
Named Examples That Show the Form in Action
Maria Alvarez runs Casa de Esperanza, an LHCA in Phoenix serving Maricopa County. She submits Form 9994 listing 320 projected unduplicated clients across pre-purchase, rental, and default counseling. Her 9994-B requests $185,000 in HUD funds, with $112,000 in personnel, $28,000 in fringe, $6,000 in travel, $4,000 in supplies, $20,000 contractual for legal aid referrals, and $15,000 indirect at her negotiated 10% rate. She leverages $240,000 in CDBG funds on Form 9994-C and scores in the top 25% of LHCA applicants.
David Chen leads counseling at Pacific Northwest Housing Alliance, an intermediary in Seattle with 14 sub-grantees. His master 9994 includes a network roll-up showing 4,200 projected clients, plus 14 sub-plans. He budgets $1.4 million in HUD funds and leverages $2.1 million in state and lender contributions on Form 9994-C. His sub-grantee monitoring plan, attached as an exhibit, satisfies 2 CFR § 200.332.
Linda Washington directs a default counseling agency in Detroit serving Wayne County. Her 9994-A focuses heavily on default and foreclosure counseling, with 480 projected clients and a 35% loss-mitigation success rate. She trims her travel line from $18,000 to $4,000 after a HUD pre-application technical assistance call, which strengthens her budget reasonableness score under the HUD TA program.
Mistakes to Avoid on HUD Form 9994
Each mistake below carries a specific negative outcome you can prevent.
- Filing with a lapsed counselor certification on the roster causes a points deduction because HUD verifies the certification database on the submission date.
- Mismatching totals between 9994-A activities and 9994-B budget lines triggers a non-curable deficiency under the NOFO responsiveness review.
- Using a marketing name in Block 1 instead of the IRS legal name creates a SAM.gov mismatch and a Grants.gov rejection.
- Claiming volunteer in-kind hours on 9994-C without time logs violates 2 CFR § 200.306 and disallows the leveraging credit.
- Signing the form with a program manager rather than the authorized representative creates a non-curable deficiency.
- Overstating service area beyond your branch network lowers your capacity score and can trigger a downward adjustment.
- Self-declaring an indirect cost rate higher than 10% without a federally negotiated rate agreement causes a line-item disallowance.
- Leaving the outcomes column on 9994-A blank or vague drops your program design score by as much as 50%.
- Submitting after the Grants.gov deadline by even one minute results in automatic rejection with no appeal.
- Forgetting to update Form 9994 within 30 days of a material change violates 24 CFR § 214.103 and can lead to loss of HUD approval.
Do’s and Don’ts
Do’s:
- Do reconcile 9994-A, 9994-B, and 9994-C to the dollar so reviewers see no gaps under the HUD review checklist.
- Do use measurable outputs and outcomes on 9994-A because vague language costs points.
- Do attach a federally negotiated indirect cost rate agreement or elect the 10% de minimis under 2 CFR § 200.414.
- Do verify every counselor’s certification status on the day of submission because HUD checks live data.
- Do submit at least 48 hours before the deadline to allow time for SAM.gov or Grants.gov errors to be corrected.
Don’ts:
- Don’t list service areas you cannot staff because HUD downgrades unrealistic capacity claims.
- Don’t count pledged but unsigned leveraged funds because HUD requires written commitments under the NOFO.
- Don’t let a program manager sign Block 7 because only the authorized representative’s signature is valid.
- Don’t reuse last year’s narrative without updating outputs because HUD compares year-over-year data from your 9902 reports.
- Don’t ignore HUD pre-application technical assistance because TA calls catch costly errors before submission.
Pros and Cons of Filing for HUD Approval
Pros:
- HUD approval unlocks competitive grant funding under the annual Housing Counseling NOFO, often $25,000 to $400,000 per agency.
- Approved agencies appear on the HUD counselor locator, driving free client referrals from lenders, courts, and federal agencies.
- HUD approval is required for many state and lender contracts because they piggyback on federal eligibility.
- Approval signals quality to funders because HUD’s Handbook 7610.1 standards are well known in the field.
- Approved agencies access free HUD training, technical assistance, and CMS tools through the HUD Exchange.
Cons:
- Compliance costs are real because 24 CFR Part 214 imposes documentation, reporting, and audit obligations.
- Counselor certification fees and exam preparation time add ongoing labor costs.
- The 9902 quarterly reporting workload requires a dedicated CMS and a trained reporter.
- Single audits are required under 2 CFR § 200.501 once federal expenditures exceed $750,000.
- Loss of HUD approval can be triggered by a material noncompliance finding, which threatens funding continuity.
Recap of Relevant Rulings and Guidance
HUD’s authority for the Housing Counseling Program flows from Section 106 of the Housing and Urban Development Act of 1968 as amended by the Dodd-Frank Act, which created the Office of Housing Counseling. The implementing regulations at 24 CFR Part 214 govern agency approval, work plans, and certification. The Uniform Guidance at 2 CFR Part 200 governs cost principles, audits, and sub-recipient monitoring.
Recent HUD OIG audits have repeatedly cited weak sub-grantee monitoring by intermediaries as a top finding, and HUD has tightened the Form 9994 monitoring exhibit requirements in response. The Housing Counseling Federal Advisory Committee has also recommended clearer outcome metrics on 9994-A, which HUD has incrementally adopted.
FAQs
Is HUD Form 9994 required for every HUD-approved housing counseling agency?
Yes. Every approved agency must keep a current 9994 on file at all times under 24 CFR § 214.103, and material changes require an updated submission within 30 days.
Can a program manager sign Form 9994 instead of the executive director?
No. Only the agency’s authorized representative may sign Block 7, and a non-authorized signature creates a non-curable deficiency that triggers automatic rejection.
Do I need a federally negotiated indirect cost rate to claim indirect costs?
No. You may elect the 10% de minimis rate under 2 CFR § 200.414, but anything higher requires a negotiated agreement on file.
Are pledged but unsigned foundation grants eligible leverage on Form 9994-C?
No. HUD requires written commitments for leveraged funds, and unsigned pledges are disallowed and can drop your application below the funding line.
Can an intermediary file one Form 9994 for all of its sub-grantees?
Yes. The intermediary files a master 9994 with attached sub-plans, but each sub-grantee must still produce its own 9994 that rolls up to the parent.
Does HUD verify counselor certifications on the submission date?
Yes. HUD checks the certification database live, and lapsed certifications on the submission date cost points and can lower your award.
Can I correct a SAM.gov mismatch after Grants.gov rejects my submission?
No. SAM.gov updates take up to 10 business days, so if your submission is rejected at the deadline you cannot meet the cutoff and must wait for the next NOFO cycle.
Is Form 9994 the same as Form 9902?
No. Form 9994 is the application and work plan, while Form 9902 is the quarterly performance report submitted after services are delivered.
Do sub-grantees of an intermediary need their own UEI?
Yes. Each sub-grantee must register separately at SAM.gov and use its own UEI on its 9994 to avoid Grants.gov rejection.
Can a single audit be avoided if my agency receives HUD funds?
No. Once federal expenditures exceed $750,000 in a fiscal year, a single audit is required under 2 CFR § 200.501, regardless of agency size.
Is the Form 9994 work plan reviewed every year?
Yes. HUD reviews the work plan annually as part of the grant cycle and during periodic agency monitoring visits under 24 CFR § 214.305.
Can I appeal a non-curable deficiency on Form 9994?
No. Non-curable deficiencies are final under the NOFO General Section, and your only remedy is to apply again in the next funding cycle.
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