So many housing properties have been out of the loop on Management and Occupancy Reviews (MOR) for several years. While that was a nice break, your compliance efforts have likely grown rusty. Time to shine them up—and get to know the “musts” defined in the 4350.3 Rev 1 HUD Handbook.
Waiting list management: Did you know that, even though the U.S. Department of Housing and Urban Development (HUD) allows owners and agents to create and maintain a system for taking applications and putting applicants on a waiting list, your process will be scrutinized during an MOR?
That’s why it’s so important to have a consistent, compliant application procedure in place and thus avoid discrimination, points out industry expert Debbie Hixon in the AudioSolutionz audio conference, “What You Should Know About Waiting List Management.” That procedure must outline how to match applicants on your list to available units, how to close a list, and how to re-open a waiting list—all of which she explains in her presentation.
5 Tips to Fill Compliance Holes
The MOR hiatus may have felt like a break, “but in reality, it may have been a prolonged opportunity for non-compliance issues to pile up,” US-Housing Consultants warned. “Noncompliance issues are like cavities, many skipped going to the dentist. And just like going to the dentist after several years away, you could find out that your brushing prevented issues, or you could discover that there is a multitude of issues.”
Get ready: In preparation for the return of MORs, US-HC advised that you ask yourself the following:
- Have your tenant files gone through another set of eyes?
- Are you complying with EIV requirements?
- Are you maintaining well-organized waiting lists?
- Is your Affirmative Fair Housing Marketing Plan up to date?
- Are your EIV and Tenant Selection Plans up to date?
Expect PBCAs to Scrutinize Your Rental Assistance Calculations
What’s more: In early 2016, HUD hosted a Performance Based Contract Administration (PBCA) day to kick-off discussions on next steps in the procurement process. And in that meeting, the agency instructed PBCAs to use MORs to help:
- reduce improper payments,
- process contract renewals and control program costs, and
- maintain PBRA projects in acceptable condition and protect tenants.
HUD instructed PBCAs to “monitor projects closely and take remedial actions promptly,” and to “take enforcement actions in a timely manner when necessary to protect all tenants and their children.”
Beware: As a result, during MORs, you can expect PBCAs to scrutinize the following:
- Tenants are reporting income, assets and expenses, and family composition—timely and accurately.
- Owners are calculating rental assistance properly and using available resources to verify tenant information.
- All aspects of the monthly payment voucher (units, adjustments, administrative fees, etc.) are correct.
- Assisted properties are properly maintained and offer decent and safe living conditions at all times.
Bottom line: If you haven’t reviewed your compliance in these key MOR areas lately, now is the time to do so. After all, compliance details can easily fall through the cracks when you’re out of practice—and the details matter.
For instance, Hixon answers participants’ thorny compliance questions about waiting list management, including what to do when a disabled family member is at the top of the list but there are no units available for that disability—as well as how to handle the denial of noncitizens.
Thanks to Sarah Terry, editor of Assisted Housing Alert, for contributions to this post.
