CONTRACT MANAGEMENT SERVICES

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Harold Reeves
8 years ago
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1 CONTRACT MANAGEMENT SERVICES Barrier Free Equal Housing Opportunity

2 CMS Contact Information Carlita Alegria, CMS Director Cindy Ross, CMS Associate Director Kristy Yeadon, Contracts & Compliance Manager ** Important Note ** We will cover how to prepare for an MOR and what to expect during the MOR process. This is not considered a certified occupancy training course. The MOR process and information covered in this session is based on PBCAs previous MOR processes prior to Components of this session may be subject to change (processing steps, content, and timing). CMS reports changes and impacts to Owners & Management Agents to all PBCA processes - MORs included - on the CMS web-site: Helpful Websites: RHIIP Listserv: HUD s Discussion Groups: HUD Clips: Page 2

com 360-616-7210 ** Important Note ** We will cover how to prepare for an MOR and what to expect during the MOR process. This is not considered a certified occupancy training course.

3 Before the MOR The Management & Occupancy Review process starts with scheduling of the MOR. CMS will contact the Owner/Agent (O/A) to set up a date and time to perform the MOR. After confirming an appointment time, CMS will send out a schedule confirmation letter that will also notify the O/A of all required documents needed prior to the MOR, as well as those documents required to be made available for review. The CMS Schedule Letter Attachments will include: Addendum B, Part A, Sections I, II, and III of the HUD-9834 Form Addendum C of the HUD-9834 Form CMS Questionnaire Owner s or Management Agent s Next Steps Collect the following applicable items and return to CMS prior to the site-visit: List of damages chargeable to tenants/maintenance charges List of fee charges, in addition to rent including HUD approval letter (i.e., parking fees, cable fees) Rent Collection Policy Rent Schedule (HUD-92458) Current Rent Roll Grievance Policy Tenant Handbook Community Room Rules Lead-Free Certification Move-in Inspection Form Evidence of Compliance with Income Targeting Affirmative Fair Housing Marketing Plan Copies of advertising efforts for past year in accordance with AFHMP Tenant Selection Plan Application/Pre-Application/Supplement to Application/Rejection Letter Page 3

required to be made available for review.

4 Waiting List (current sample pages) Lease and HUD approval letter (if modified lease in use) Lease Attachments, including House Rules Pet Policy Third-party Verification Forms EIV Policies and Procedures EIV Documents (can be made available at time of review) Complete the following HUD and CMS items and return to CMS prior to the site-visit: HUD-9834, Addendum B, Part A, Sections I, II and III (must be completed in its entirety with no blank spaces & signed by the Owner) CMS MOR Questionnaire Pay close attention to items listed on the HUD-9834, Addendum C as these are items that must be available on-site during the MOR. Tenant Notice - O/As need to post a notice to all tenants stating that the O/A or CMS may select their unit to enter during the site-visit. Other pre-site-visit best practices to consider: Perform a property walk-through of common areas Confirm that items from the prior REAC inspection were corrected Retrieve helpful CMS Checklist(s) from our CMS web-site and perform an internal compliance review of property-related policies and documents (i.e.: lease, house rules, tenant selection plan, etc.) Perform an internal tenant file review (current resident files, move-out files, and applicant files) Important Note: Maintaining good tenant files is an important step in having a successful MOR and reducing or eliminating the number of tenant file findings on the MOR report. Consider best practices below for maintaining tenant files. Utilize a tenant file checklist as an internal auditing tool to ensure you are meeting the Tenant File Document Requirements Page 4

III (must be completed in its entirety with no blank spaces & signed by the Owner) CMS MOR Questionnaire Pay close attention to items listed on the HUD-9834, Addendum C as these are items that must

5 Separate documents with the use of a 6-tab folder to ensure neat and organized tenant files Understand common tenant file findings at MORs and also how to avoid making them. CMS Desk Review CMS will complete the Desk Review portion of the HUD Reviewing and assessing information in CMS property files, HUD Secured Systems, and information received from the O/A is critical to this step in the process. Areas of concern (if any) identified during the Desk Review will be noted by the CMS reviewer to later discuss or follow-up on during the site-visit. CMS staff will choose a sample of tenant files to review. The sample files typically include new move-ins, re-certifications (interim, annual, and initial), rejected applicants, and recent moveouts. The number of files reviewed is based on the number of subsidized units at the property. Page 5

Reviewing and assessing information in CMS property files, HUD Secured Systems, and information received from the O/A is critical to this step in the process.

6 During the MOR Site-Visit CMS staff will report to the property for the MOR site-visit. CMS will: (*may not be conducted in this exact order) Complete an entrance meeting Perform a property walk-through * Follow-up on REAC items * Complete the MOR questionnaire * Check on vacant ready-to-rent units * Review tenant files * Conduct an exit meeting HUD-9834 MOR Questionnaire The HUD-9834 MOR Questionnaire consists of questions related to the categories below. A. General Appearance and Security, which addresses any: Security events that occurred at the property and any security measures in place to prevent further events B. Follow-up and Monitoring of Project inspections, addresses: The lead-based paint inspection and certification (if applicable) C. Maintenance and Standard Operating Procedures, addresses: Maintenance procedures and policies Vacancies and turnover Energy conservation practices implemented at the property E. Leasing and Occupancy includes questions related to: Application processing and tenant selection procedures Leases and Deposits Eviction and termination of assistance procedures EIV access and security compliance Compliance with using EIV data and reports TRACS monitoring and compliance TRACS security requirements Page 6

ready-to-rent units * Review tenant files * Conduct an exit meeting HUD-9834 MOR Questionnaire The HUD-9834 MOR Questionnaire consists of questions related to the categories below. A.

7 Tenant File Security F. Tenant/Management Relations address: Resolving resident concerns Tenant services available at the project or in the community G. General Management Practices includes questions about: General management operations at the property Staffing and personnel policies Property Walk-Through, REAC Items, and Vacant Units The property walk-through involves the following: CMS staff will walk the property and visually inspect the grounds, the common areas and any maintenance areas; CMS staff will ensure the following items are posted and/or made available for the residents: Rent Collection Policy (posted) Grievance Policy (posted) Office Sign, Office Hours and Emergency Phone Numbers (posted) Fair Housing Poster (posted) Current HUD approved AFHMP (available) Current REAC Inspection (available) Current Rent Schedule; (available) CMS staff will follow-up on items listed as deficient on the last REAC inspection (O/As need to post notice to all tenants that we may enter) CMS staff will visually inspect any vacant units to determine rent readiness Tenant File Review CMS will review files randomly selected during the CMS desk review process. The HUD-9834 Addendum A Checklist will be used for each tenant file review. The HUD-9834 Addendum A Checklist addresses compliance with HUD regulations related to: Household Information Verification Page 7

walk-through involves the following: CMS staff will walk the property and visually inspect the grounds, the common areas and any maintenance areas; CMS staff will ensure the following items are

8 Lease Certification/Recertification Activities Billing Move-out File Review (if applicable) Applicant Rejection Review (if applicable) Exit Meeting During the exit meeting CMS and the O/A will discuss any items noted by the CMS reviewer before or during the site-visit. Page 8

Exit Meeting During the exit meeting CMS and the O/A will discuss

9 After the MOR Site-Visit After the Site Visit is complete, the following items occur: 1. First, CMS staff will prepare the MOR Report and mail it out to the O/A approximately 30 days after the date of the on-site visit. The MOR Report identifies any areas of non-compliance as well as the required action necessary to address or correct any conditions noted as deficient. 2. After the O/A receives the MOR Report, the O/A has 30 days to address the corrective actions, prepare a MOR response letter and submit the response and supporting documentation to CMS. CMS staff will review the O/A response and supporting documentation to ensure the proper corrective action has been taken for each condition noted on the MOR Report. If there are any conditions noted on the MOR report that were not addressed by the O/A, CMS will send out a follow-up MOR response letter indicating what items are still open. This process will continue until all conditions are corrected; however, please note that CMS staff are available to address any questions and/or provide guidance on how to address an open condition. 3. After all conditions have been addressed, CMS will send out a MOR closure letter to the O/A. At this point the MOR is closed and no further action is required other than maintaining the tenant files in preparation for the next year s MOR. Page 9

The MOR Report identifies any areas of non-compliance as well as the required action necessary to address or correct any conditions noted as deficient. 2.

Management & Occupancy Review Timeline/Checklist

Management & Occupancy Review Timeline/Checklist Management & Occupancy Timeline/Checklist Before Before Before Before Before A. Print the 9834 from the HUD/Forms web site http://www.hud.gov/offices/adm/hudclips/forms/files/9834.doc Begin full file audit