If you aren’t accessing the Tenant Rental Assistance Certification System (TRACS) or iMAX at least once every 90 days, you could lose access to these systems, under new rules that started in October.
Multifamily owners, agents and regional directors, performance-based contract administrators, and property managers and housing authority office bearers should check to ensure compliance with new U.S. Department of Housing and Urban Development (HUD) rules for TRACS access, as well as a brand-new recertification process for all users.
The 90-Day Rule Is King
Users and Coordinators must access the HUD Web Access Security Subsystem (WASS) or Secure Connection and must change their password at least once every 90 days. If you fail to do so, WASS will deactivate the user due to inactivity. This will affect your access to TRACS and iMAX, and applies to both Users and Coordinators. “Even when a TRACS User is certified by the TRACS Coordinators, TRACS Users must access either TRACS or iMAX at least once every 90 days in order to be able to continue to use TRACS or iMAX,” warned Colleen Bloom of Washington, DC-based Leading Age in a recent notification.
If you lose access due to inactivity, you must ask your TRACS Coordinator to restore your User access.
Seven Steps for User Recertification
Also, TRACS Coordinators must certify all TRACS Users no later than Dec. 31, 2017, Bloom stated. Beginning on Sept. 1 each year, HUD now requires TRACS Coordinators to certify all TRACS Users who continue to need access to TRACS data. Coordinators must certify all Users no later than Dec. 31 annually, otherwise non-certified Users will no longer have access to TRACS.
The TRACS recertification is a new process and requires that the Coordinator follow these steps:
- Ensure the User completes the Security Awareness Training/Cyber Awareness Challenge within the last 12 months.
- Establish the relationship by going to the TRACS link > TRACS Recertification link > Add/View/Delete Assigned Staff link.
- Confirm assignments by going to the TRACS link > TRACS Recertification link > View/Flag Actions/Roles link.
- Request certification by going to the TRACS link > TRACS Recertification link > Request Recertification link.
- Access the WASS User Maintenance function using your own Coordinator M-ID.
- Choose the option to “Maintain User – Roles.”
- Make sure there is a check in the box next to the TCC (TRACS Coordinator) and TCR (TRACS Recertification) role. If these options are not checked, the Coordinator must click the checkbox to turn the Recertification functionality on.
Each Coordinator Must Certify Their Users
But what if a User is assigned to more than one Coordinator? Does just one Coordinator need to certify/recertify that User, or do all the Coordinators need to follow the process? HUD tackled this problem in a recent update to the TRACS User Recertification Training Questions & Answers, noting: “There are cases when a TRACS User needs TRACS access for multiple portfolios. This means that multiple Coordinators will be certifying the same TRACS User (e.g. Contract Administrators, service bureaus, TRACS consultants, etc.).”
For example, let’s say ABC Service Bureau submits TRACS files for three management companies. Alpha Management Company has 20 properties, Bravo Management Company has 10 properties, and Charlie Management Company has 10 properties. ABC Service Bureau has three employees that submit TRACS files and view TRACS queries for all properties.
The Coordinator for Alpha Management Company, the Coordinator for Bravo Management Company, and the Coordinator for Charlie Management Company will each need to complete the TRACS recertification process for the three ABC Service Bureau employees.
Currently, the TRACS recertification process has a weekly limit on the number of Coordinators who can request certification of an individual User, but an October release will remove this limit. To allow the TRACS development team to enhance the process of certifying Users with multiple Coordinators, HUD recommends that you begin the process for certifying these types of Users on or after Nov. 1, 2017.
Take Advantage of These Important Resources
Here are some official training resources that HUD makes available to all users:
- Recently updated training resources, including the TRACS Recertification Internet User’s Guide (revised in July 2017)
- Training questions and answers
- Recorded archive of the TRACS 2017 Mandatory User Recertification training video
For more information about how to train employees, avoid compliance violations, become better managers, steer clear of legal trouble, save money and/or time, and create compliant forms and documentation, check out the Assisted Housing Alert for insights vital to your job performance.
Also, to learn more about TRACS compliance, including how to use the new version of TRACS 203A, changes to the 50059 form and voucher, and the addition of new fields, join affordable housing compliance expert Debbie Hixon for a webinar for AudioSolutionz, “The Latest on TRACS 203A.” Debbie will discuss how to comply with relevant implementation dates of the new TRACS version, as well as help you make sure that the figures are correct on your 50059 form and your voucher.
