You may have thought that in affordable housing when you received the keys that the tenant was considered to be moved out, but that is simply not the case. A property cannot wait on moving out a tenant because they didn’t receive their keys, especially when they know that the unit has been vacated. According to the HUD Handbook… Continue reading When is a Section 8 tenant considered “Moved out”?
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I understand why Owners of HUD subsidized properties and Management companies are sometimes afraid to spend money on training their staff. Some folks had some questions about whether or not the classes would be considered HUD approved training expenses and others had concerns they are afraid to spend too much on training for fear their staff will take the skills they just learned and take them to “greener pastures”. In some cases this a cyclical process. Sometimes you lose an employee whom you just trained and then you pick one up. In today’s economic environment I would hazard to guess you are more likely to keep your employees because the job market is very tight. While your staff are there to perform their duties they have to be trained so you are not throwing money out the window. Training is very necessary if you want your property to be run correctly and in compliance with the HUD regulations. We all know that if we don’t know the ground rules it is very difficult to play the game. TRACS, Enterprise Income Verification (EIV), Management Occupancy Review s (MOR’s) and REAC; how are any property managers supposed to be able to navigate these subjects without formal training? Training your staff in your policies and procedures will keep your property portfolio moving in a positive direction towards “Superior” ratings for your MOR and REAC inspections. To this point I think I have addressed how important training is, but now I want to clarify that the training of your staff is considered by HUD to be an approved training expense. HUD has stipulated that training is mandatory and it is part of your HUD Section 8 contract budget. This is what my research revealed about HUD Approved Training Expenses: A). Management Costs paid from the Management Fee: “The Management Agent Handbook, 4381.5 Rev-2, 6.39”, it states:
B. Salaries, fringe benefits, office expenses, fees, and contract costs for the following activities must be paid out of management fee funds. These costs include: (1) Designing procedures/systems to keep the project running smoothly and in conformity with HUD requirements. (2) Preparing budgets required by the owner or HUD, exclusive of rent increase requests and MIO Plans. (3) Recruiting, hiring, and supervising project personnel. (4) Training for project personnel that exceed the line item budget for training expenses. (5) Project funds may be used to obtain project related training for front-line management staff. (6) Loan/Asset Management staff may use the following guidelines to assess whether amounts proposed for training are reasonable. C) At a minimum, the budget amount should be sufficient to allow one staff person from each functional area to attend a minimum of one project related training session per year. (a)As a rule of thumb for most projects, a reasonable training budget would not exceed the greater of $5,000 or one half of one percent (0.005) of gross rents. (b)Loan/Asset Management staff have the authority to approve training budgets that exceed the guidelines in paragraph (a) above if the owner/agent can clearly document the conditions that necessitate more extensive training for project staff. Figure 6-2 Examples of Costs Paid from Management Fee and Project Account Costs Paid from Fee Costs Paid from Project Account
There is no doubt that staff retention plays a big part in a successful business and having to worry if a class is “HUD approved training expense” can be a big drag. I hope this article clarifies for you that the training for your staff is vital and is also part of your Section 8 contract budget. Based on the most recent TRACS industry meeting, we were told about the new schedule for the release of TRACS 202D. As always this schedule is subject to change but for now the scheduled stands: Vendor Testing is to commence on: December 1 – This means that the affordable housing software vendors, Contract Administrators and the like will be testing and sending TRACS files to help sort out the bugs. The plan then is to correct any problems with TRACS 202D and Go live with the Contract Administrators by March. The next step is to implement and go live with the Owner/Agents between March 1st – September 1st. As always there is a transitional period and the drop dead date. You will have basically 3 months where TRACS will accept both TRACS 202C and TRACS 202D versions. The total conversion should take place between September 1 for October voucher. This is where the only files accepted will be for TRACS 202D. Visit us to find out more, take our TRACS 202D class: http://www.ahtcsonline.com/class_schedule.html The most recent TRACS 202d Industry meeting held on March 13th & 14th was two days of great information. HDS Software was nice enough to sponsor the first unsanctioned HUD meeting where we covered the TRACS 202d Final Specifications. Mary and Jed did a great job of going over the changes of the TRACS 202D specifications. Some of the changes involved: Continue reading Just Some of the New TRACS 202D Changes On January 30, 2012 HUD Secretary Shaun Donovan announced new regulations to ensure equal access to housing for all Americans regardless of sexual orientation, gender identity or marital status. These new regulations were published in the Federal Register on February 3, 2012 with an effective date of March 3, 2012. These regulations apply to all of HUD’s programs. The Final Rule, published as Equal Access to Housing in HUD programs makes the following provisions: Continue reading New HUD Protected Class Rule I had a client email me to ask if he was required by the ADA compliance to install a pool lift; “One of our properties is in the process of building a pool which will open in May. It is a Tax Credit property. Do we have to install a lift chair due to the new ADA rule? It would be a private pool. I get a lot of folks saying we probably do, the pool company saying definitely, and our CA saying maybe. It will cost $15,000 roughly. Thanks” Continue reading The ADA Guidelines Requiring Pool Lifts in HUD Subsidized Property When a tenant requires services that you don’t offer, does the tenant then need to consider assisted living rather than independent living? Does your Tenant Selection Plan (TSP) address whether your community is an independent living facility versus an assisted living community? I hate cleaning…well, I hate some aspects of it. I don’t mind vacuuming or mopping the floors…but I know I dislike dusting which makes me sneeze. No Matter how much I dislike cleaning, it is imperative to have well maintained affordable housing units. Having a clean and well maintained property contributes to a healthy environment and can have a positive affect on your next Management Occupancy Review (MOR). This is why it is vital to inform tenants as to your expectations on keeping their units in tip top shape. Continue reading Unit Inspections for Section 8 Housing As you may or may not have noticed, nobody from HUD or your Contract Administrator is knocking on your door to perform your annual management occupancy review (MOR). This past year all of the performance-based contracts went out for re-bid. Some PBCA’s were happy with the results but most were not. The eleven PBCA awards that were not contested were because HUD only received one bid for the contract. Those states included: Iowa, Maine, Minnesota, Montana, New Hampshire, North Dakota, South Dakota, Vermont, Wyoming, Puerto Rico and the U.S. Virgin Islands. Continue reading MOR’s May Be Suspended, But Let’s Pretend They Weren’t! I recently received a call from a client asking how long should a resident be considered a tenant if they are only there 6 months a year. What is a reasonable amount of time before you determine that this tenant has been gone for a while? Is it 2 weeks, 4 weeks…what is the limit you are willing to set? Obviously if that tenant is serving in the armed forces…you need to be a lenient as reasonably possible. Whatever the situation we need to be consistent across the board when it comes to your affordable housing property. Continue reading How to Deal with Extended Absence or Abandonment in Section 8 The U.S. Department of Housing and Urban Development (HUD) has just released the 2012 Income Limits for both LIHTC and Section 8 however they are on separate web pages. The MTSP income limits are to only be used by projects financed with tax-exempt housing bonds – referred to by HUD as Multifamily Tax Subsidy Projects (MTSPs) – and are calculated and presented separately from the Section 8 income limits. These MTSP income limits must be used for all new move-in transactions. Follow this link to obtain the updated income limits for FY 2012: 2012 MTSP income limits . The Section 8 income limits were also just released. All HUD Multifamily property managers must use the new income limits posted on the HUDUser web site at HUD Multifamily 2012 Income Limits. Some affordable housing software vendors update the income limits for you and some rely on their users to update their own income limits. Consult your software vendor to find out. In any case, PLEASE make sure you print the income limits for your MSA and keep them on file or in your binder for your next MOR. A “Frequently Asked Questions” page has also been set up at http://www.huduser.org/portal/datasets/il/il12/FAQs_12.pdf. “Safety First”…is one of those phrases we hear quite often…especially if you have kids or loved ones. When it comes to where we live, no matter what type of affordable housing we live in there resides the possibility of the silent killer…Carbon Monoxide. HUD has created a division called Healthy Homes Program to combat this type of life threatening hazard. The Healthy Homes Initiative (HHI) departs from the more traditional approach of attempting to correct just one hazard at a time (e.g., asbestos, radon). In April 1999, HUD submitted to Congress a preliminary plan containing a full description of the Initiative. Continue reading Carbon Monoxide Detector Mandates AHTCS, LLC will perform a complete HUD Section 8 file audit of your resident files to determine errors, weaknesses, lapses in performance, missing or inadequate documentation, etc. Upon completion of the file audit, we will complete all required corrective actions that must be completed to correct the Errors/Findings. The file audit is based on the HUD Form 9834, Addendum A, and includes the following during review: Continue reading AHTCS, LLC provides HUD Section 8 file audit and file reviews Our TRACS industry meeting began on a sad note: Willie Spearman, Gail Williamson and Deb Lear have announced their retirement from HUD. These three individuals have made large contributions to the multifamily housing industry. They will be sorely missed! Also discussed at the TRACS industry 202D working group meeting last week was how to address tenants who either skipped on their repayment agreement or did not want to sign their repayment agreement. Lanier Hylton from HUD spoke about HUD’s and OIG’s ongoing concern about recovery of these funds. This concern spurred conversation about tracking tenants who have left their property owing money to HUD as well as perhaps flagging these tenants as ineligible for any government assistance on any kind. What do you all think? Continue reading October TRACS Industry Working Group Meeting I have attempted to assemble a list of best practices observed by O/A’s that work with multifamily affordable housing. The list is not all inclusive or in order of importance. The ideas presented are merely another tool to assist O/A’s in the challenging role of retaining tenants and trying to keep units fully occupied by tenants so the property can meet their financial responsibilities. However when all is said and done, there is no substitute for affordable housing training. Click on the link to sign up for classes: http://www.ahtcsonline.com/regform.php Continue reading Best practices for affordable housing Section 8 Owner/Agents that work! My kids can be pests but that is story for a different day. Pests on a property are certainly no joking matter. Maintaining your property is no easy feat and when you add the unpredictable and uninvited guests…well it can be an arduous task to get rid of them. Having the right strategy for pest management seems to be the only smart plan. Having the right exterminator who knows their stuff should make for a great and effective pest management solution. Continue reading Implementing an Integrated Pest Management Strategy for Affordable Housing Properties Housing Notice 2011-21, Enterprise Income Verification (EIV) System, was issued today, August 19, 2011. This Notice supersedes Notices H 2008-03, H 2009-20, and H 2010-10. The Notice is posted on our website at: http://www.ahtcsonline.com/Industry Links/HUD Notices/HUD_Notice-H11-21.pdf. The revised Notice:
I think it should be clear now to everyone that conservation or “Going Green” as they say, isn’t just for those “Hippie” types and not just a trend. Conservation is our overdue way of showing respect for our environment. Respecting our environment and capitalizing on this new way of life can also be achieved at the same time. Let me show you what I mean using an affordable housing community as our sample: Conservation may have started for some as a fad, but now it seems more and more important for tenants to save as much as they can. And it plays well as a marketing ploy to appeal to those who are looking to live in a community where “Going Green” is important. You may be surprised at the number of more environmentally conscious people out there looking for an affordable housing community with the same “green” philosophy. Continue reading Save Money, Save the Environment going “Green” at your Affordable Housing Property There is no doubt about it, I am a “News Hound”. I watch the news all of the time. One of the most gripping headlines always includes how a woman or a child was assaulted by a sexual predator. MSNBC has even created a long going documentary called “To Catch a Predator”. I have been inspired to write this article as stark reminder that the safety of your affordable housing tenants needs to come first over the need to fill vacancies. So let me begin by reiterating the current regulatory requirements and to strongly encourage the establishment of standards and processes with a zero tolerance approach to prevent convicted sex offenders from living in multifamily housing and receiving federal housing assistance. The recommendations for new processes are to: Continue reading There are no Vacancies for Sexual Predators in Affordable Housing I recently read the most appalling article where HUD brought charges to the owner of a five-unit apartment building in Lebanon, NH, for violating the Fair Housing Act because the landlord allegedly refused to rent one of the units to a family with children. HUD is pursuing these charges on behalf of a mother with two children, who alleged that the owner, Robert Gerow, dared her to “turn him in” when she protested that his refusal to rent to children was unlawful. Further charges were brought when HUD also uncovered that the owner’s receptionist violated the Fair Housing Act when she, following the owner’s instructions, told potential renters and the mother of two that the owner did not want to rent to families with children. Continue reading Landlord Refuses to Rent to a Woman with Children Looking out of my office window and anticipating the snow’s disappearance, I am anxiously awaiting the emergence of my flowering bulbs. I was reminded of how my three little boys and I planted the seeds and bulbs last year. Even more important was the memory of how much fun it was when we all worked together. The boys were very excited and couldn’t wait to see the results of their labor. And how does this relate to affordable housing? Planting the seed often has far-reaching and better results than we originally may have anticipated. Continue reading Planting the Seed in Affordable Housing In the past year or so I have had two clients who after several months of having their vouchers revised by their CA, were not given any reason for the revision and when they inquired as to why their voucher was revised they were simply told to “figure it out on their own”. I got involved with my clients to help resolve the issues and called the CA myself. Rarely did I get a return phone call and there was never any follow up from the CA. Meanwhile, the Property Manager was getting squeezed from the owner wondering where their subsidy payment was. This put the PM in a very difficult position and often put their job at risk. This situation could have easily been avoided by the CA by them sending a reconciliation report back to the property after each months’ review. This gives the PM an opportunity to do their own reconciliation to see each tenants subsidy amount paid. In my opinion, the CA is there to help facilitate the process and not impede it. The intention of the RHIIP was to reduce under payments and over payments. I don’t see how CA’s who behave in this manner, contribute to this initiative when they fail to fully service the contract. I know they are not alone. Continue reading CA’s obligation to reconcile the Voucher with the property You wouldn’t believe how many affordable housing property owners & property managers I have spoken to who were in a state of panic because they were getting ready for their REAC inspection. My advice to those is just be prepared the best you can. Easier said than done, huh? Not really. My first suggestion is to perform your own pre-inspection using your physical inspection check list (make sure to include your maintenance person). When you walk your property, don’t walk with your head down…look around at your surroundings, correcting the most visible problems BEFORE “dooms day.” Sometimes there are inconsistencies with the way that the physical inspections are performed and, unfortunately, principles are not always placed before personalities. Let’s face it, when we are in a bad mood our job performance can be affected. However that doesn’t really help our REAC score, does it? So, again, I can only reiterate that preparation is your best chance of achieving a great score. Speaking of your score, do you know what it is? Here is a link to check your Physical Inspection score. Continue reading Preparing for your next Physical REAC Inspection Let us discuss which EIV reports should be maintained in the file. There is no doubt that HUD’s RHIIP initiative (through EIV) has done a great job to reduce over-payments and underpayments to HUD. On the other hand, a great responsibility has been added to the O/A in regard to HUD reporting. I must say, though, that the “good” definitely out-weighs the “bad.” This initiative has revealed and reduced over-payments to an estimated 1.9 billion of US tax dollars. Continue reading What should be included in the EIV “Master File?” |
           
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