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Volume 5 Issue 3
WOW! It’s June 2013 already
During the annual managers conference many of you asked for changes in how new information is provided to your sites. The number one request was that you receive new and revised forms directly via e‐mail when changes are made. The second request was to delay publication until later in the month. Here at LWH Compliance Department we aim to please
Inside this issue
Page #
2 MOR and LIHTC Compliance Check up
3 Certification Procedures, who is in charge?
4 Debit Card * Wait list documentation
5 Systematic Alien Verification
6 Rent Collection * Vendor Invoices * Unit Assets
7 HVAC Certified Technicians * New and Revised Policies
And Forms
9 Cap‐Ex * Purchase Order Reminder* REAC
10 Calendar checklist
Marilyn Moody at Oakridge Apartments and Dawn Garner at
Woodbend Apartments earned their Certified Occupancy Specialist
designations. Congratulations Marilyn and Dawn!
Congratulations Carlos, Lyn and team Dodson! Dodson Avenue scored
99a on their REAC inspection!
June2013Policies,InsightsandHighlights
We’re on the Web: www.lawlerwoodhousing.com
Susan Howell [email protected]
Dena VanLeuvan
Annie McDougal [email protected]
m
Robin Hicks [email protected]
LaFonda Rogers
Liz Boyle [email protected]
Brian Wegrzyn
Compliance Mailbox [email protected]
Reasonable Modifications and Accommodations
Liability Insurance [email protected]
Visa P Card
Yardi [email protected]
Human Resources [email protected]
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Management and Occupancy Reviews
PBCA NOFA STATUS UPDATE – June 3, 2013 HUD announces: Unless we are prohibited from doing so by the United
States Court of Appeals for the Federal Circuit, HUD intends to announce the selection of PBCAs pursuant to the NOFA
on August 1, 2013. Based on this announcement from HUD Management and occupancy reviews could be just
around the corner. Are you ready for a PBCA inspection? Don’t wait, get prepared now!
Tips for MOR preparation
Self‐audit and correct, correct, correct, correct tenant files!
Be organized and make sure paperwork is correct the first time
Follow up with maintenance team on status of outstanding work order from most recent unit
inspections
Check LWH website, make sure you have the most up to date forms
Check required postings
Audit your waiting list
Audit move out files
Make sure your EIV master binder is in order and well documented
Make sure the LEP plan is up to date and includes the most recent update (it was due 5/10/2013)
What about 504? Have you completed required transition plan update for 2013?
Does your property have a current AFHMP? AFHMP’s must be updated every five years
Tax Credit Program Audits occur every three years. Is it time for your audit? Below is a list of properties that
should expect a tax credit audit in 2013.
Arbor Place Bankhead Chippington I Chippington II Cloverdale
Colony Square Hickory Forest Lee Manor Lynnridge MacArthur Park
Miller Village Ramblewood Towers East
Self‐audit files, tic and tie don’t forget administrators can issue 8823 for poor physical conditions. Prepare for a tax
credit audit just like you would a REAC inspection. The first year audits are especially critical * for additional guidance
refer to LWH pre‐audit procedure
LWH Certification Procedures, who is in charge? Section 8 Program Terminations should be the exception not
the rule. HUD and LIHTC program require that the recertification process begin 120 days before the Re‐certification is
due. This allows O/A three full months (ninety days) to process the AR and give resident a thirty (30) day notice of rent
change/increase. Time and time again, management processes terminations not because of residents failure to respond
but O/A’s failure to “work” the process. Recertification notices should be delivered on or by the 1st of month with a
3 copy in resident file. Interviews should be scheduled for the second and third week of month. Verifications should be
sent out by the fourth week of the month.
It is the resident’s responsibility to respond to the proper notices and provide info but it is not their responsibility to do
the O/A’s job. If all procedures are followed and non‐responsive residents are contacted repeatedly there should be
very few, if any, late certifications that would require Administrative Write off.
Recertification notices are one of the most crucial components of the recertification process yet over and over again
O/As fails to run the notices correctly in Yardi during month end close. In order to determine if you ran reports correctly,
here’s a quick way to see how your property stacks up to recertification compliance.
Login in Yardi, CM dashboard > Reports> Affordable Reports > Scheduled Annual Recertifications
Can you tell what’s missing?
Remember: Your cash flow $$ can go out the window by not following these policies and procedures:
IF AR is late because resident did not respond, resident waives his or her right to a 30 day notice of increase.
IF resident does not respond until after the 1st of AR effective month, resident must pay Market rent
IF market rent and HUD approved Utility allowance (HUD program) exceeds Maximum allowable Tax credit
rent, O/A must reduce amount charged to resident. Resident can never pay more than the allowable TC Gross
rent listed under Part VI. RENT of TIC for Rent and Utilities unless he or she receives at least $1.00 subsidy
Tax Credit Maximum Rent HUD Program Gross Rent
IF resident responds to certification notice and comes to office and fills out certification update form, signs the
requires HUD form 9887, HUD Form 9887a and individual consent forms during certification interview, but
O/A fails to send out verifications in a timely manner causing the certification to be late, management must
give a thirty day notice of rent increase/change. To give that notice O/A must request Administrative Write Off
approval for the difference in the current TR and the TR increase during the required notice period.
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Debit Card Verification
Those pesky pre‐paid cards! Did you know that Public Assistance (TANF and GA), Child Support, Unemployment, Social
Security benefits and SSI benefits are all paid on Pre‐paid cards? If a resident or applicant receives one of the benefits
listed and they check they have NO assets on the application or certification update form, THINK Again. Pre‐paid debit
cards are an asset, just like a checking, savings or even cash on hand. The balance on card must be verified at time of
certification. Cash value must be listed on HUD form 50059 and Tenant Income Certification (TIC). Here’s three ways to
verify balance on pre‐paid cards
Wait list documentation when applicant “cancels application” (no longer interested)
If an applicant changes his/her mind and cancels, the applicant must reapply. Start with NEW Guest in Yardi; do not use
the reapply button since this will displace other applicants on the wait list and property will be out of compliance.
Before your next management and occupancy review, read property specific Resident Selection Plan AND review HUD
Occupancy handbook 4350.3 REV 1 chapter 4. Remember all contact with applicants (phone, email and written) must be
reflected on the wait list and documented in the application package.
RHIIP Listserv Posting # 300 5/7/13 EIV system update 9.5 was successfully released on Monday May 6, 2013. The Multifamily weekend summarization job was successful on May 5, 2013, and all reports are current as of this date. Below are the new functionalities that have been added to Multifamily EIV. Any questions related to Multifamily Housing in EIV should be directed to the Multifamily helpdesk at 1-800-767-7588 or by email at [email protected].
Function Description
EIV — Income Reports
New Hires Report
Display the Tenant’s New Hires Data information for the past 6 months for each tenant
Displays the Tenant’s New Hires Data only when a user clicks on tenant’s SSN
Break is provided after each Member New Hire Data
Call 1‐800 on back of
card; verify balance,
complete telephone
verification form
Ask applicant or
resident for a copy of a
recent store receipt.
Balance is shown at
bottom
Ask applicant or
resident for a current
cash machine balance
inquiry
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Function Description
Income Report
Displays Income Information for Verified Household Members when a Head of Household has failed the verification report due to personal identifier(s) not matching.
Displays Income Information for Verified Household Members when a Head of Household is an ineligible Non-Citizen that has Failed Pre-screening
EIV — Verification Reports Deceased Tenants Report
Eliminated duplicate records in the HQ Management Deceased Tenant Report
Income Discrepancy Report
For HQA, HQU, HFU, CAC, and CAU roles:
Recognizes the discrepancies at different field office levels Identifies tenants who have possibly underreported income through the use of incremental percentage options. Report downloadable an Excel spreadsheet
Systematic Alien Verification
You just received an application And applicant checked Box 2 on Citizenship declaration What should you do next? The first thing you should do is verify the application is complete. If complete, add to the waiting list. At this point you can go ahead and begin the SAVE verification process. Don’t wait until applicant household moves to top of the list to begin SAVE verification process. If you have access to SAVE on line, that’s fantastic If you do not have access to SAVE verification on line, please complete FORM G‐845 Document Verification Request
Send complete original form (keep copy with application) and photocopy of primary immigration document(s) Tennessee Properties send to (USCIS) US Citizenship & Immigration Services 10 Fountain Plaza, 3rd Floor Buffalo NY 14202 ATT: Immigration Status Verification Unit Addresses listed in HUD occupancy handbook are no longer valid. You can go to DHS web site, go to SAVE page and look up address for all states.
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THANK YOU Elva Saylor, CM Summit Towers and the Pines Apartments For the SHOUT OUT
Please remember you may not delay application processing or occupancy if household reaches top of list before status is verified. Process as with any other applicant household, under eligibility on 50059 select PV “pending verification”
Rent Collection Policy
All households sign LWH Rent Collection Policy at move in. LWH Rent Collection Policy outlines requirements for rent payment and policy regarding late fees and returned checks. Paragraph 2, Acceptable forms of rental payment include personal check, money order or cashier’s check. The following forms of rental payment are not accepted:
Second party checks and cash are not accepted Partial rental payments are not accepted
Although policy does not specifically state 3rd party checks will not be accepted, please remember you should not accept 3rd party checks. A resident cannot sign over the UA check for payment of FTR repayment agreement.
Vendor Invoices Get your vendors paid on time! Please make sure all vendors know to send invoices to
Apartment Complex Name 900 South Gay St., Suite 2000 Attention: Accounts Payable
Knoxville TN 37902
Or if vendor prefers they may send invoices electronically to [email protected]
Unit Assets and Asset Directory
Everyone knows HUD requires a complete list of unit/property assets (appliance, HVAC etc.) as part of the
property “Reserve for Replacement” standard. When funds from R&R are used to purchase new carpet, tile or
appliances HUD requires back up documentation i.e. inventory. In addition, HUD and Performance Based
Contract Administrators (PBCA) can conduct a physical inspection to verify the assets reported in unit 202 are
really in 202.
Not sure if your assets are up to date in Yardi? Run the Unit Asset Directory
From the Work Order Dashboard > Left Menu > Assets > Asset Directory
Reports shows Unit #, Item, Date purchased (or placed in service) Model #, Serial number and cost.
Need to know more about how to enter or update assets in Yardi? Refer to Yardi Compliance Manual
Chapter 1: Introduction, AP, Work Orders and Unit Assets 013013
Regional Supervisors and Compliance are required to verify asset inventory during Quality Assurance Audits.
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HVAC Certified Technicians
All properties using R22 refrigerant and R410a refrigerant should have two sets
of gauges. Maintenance should never use gauges that have been used for R22 refrigerant on an
AC containing R410a. This will contaminate the system. Gauges should be clearly marked for R
22 use only and R410a use only. Gauges can be purchased through HD supply for under $100
Property Management
Certification Forms Application Checklist 021913 Application Requirements Outline 031813 Application to Lease HUD/LIHTC 031813 Application to Lease Tax Credit Only 031813 Landlord Telephone Verification 041913 Certification Update Form 031813
EIV/TRACs EIV Master Binder Requirements 042913 EIV Resident File Quick reference 022113 EIV Master File Quick Reference 022113
Forms/Misc./HOME/HUD/LIHTC 2013 HOME Income Limits 031513 2013 HOME Rent Limits 060113 9824 Current Version as of 030513
Management Forms & Reports QA/APIC Form DM/RPM/RVP 010113 AR File Documents required for Compliances Review 040113 Kroll Guidelines for National Criminal Reporting 022713 Move in File Documents Required for Compliance Review 040113 Customer Service Phone Number Notice 032713 2013 Staff Incentive Program 2013 Site Staff Performance Tracking Sheet
Policies & Procedures Cap‐Ex P & P 012313 Cap‐Ex Expense Re‐Class P & P 010213 EIV P & P 042913 504/ RA/RM P & P 022513 Asset Verification Procedures for Federal Benefit Debit Cards & Accounts 022813 Emergency Communication Plan 040413
NewandRevisedPoliciesandFormsJan2013‐May2013
8 RA/504 HUD Notice 042513 Service Animals & Assistance Animals
State Specific Forms AR‐ File Checklist 011113 TN‐ Knox Attorney Fee Notice 0213 TN‐Landlord Tenant Act Updates 0213
Training Materials Grace Hill Training Schedule 2013 REAC/ Physical Integrity Training 051013 REAC Updates on Inspection Criteria 0513
Verifications, Etc… Odd Job Self Declaration 010813 Clarification of Asset Verification for Debit Cards 030113 Payroll Average Worksheet W Greater Than Comparison 0213 Child Support Worksheet 010213 Agency Child Support Verification 010113
YARDI Chapter 1: 013013 Chapter 2: 011113 Chapter 3: 011113 Yardi Compliance Component 052313 Assigning Wait Unit Procedure Update 050213
HR Employee Handbook 2013
Insurance COI Package‐ New Vendor COI Package‐ Renewal COI Package – New Vendor Cap Ex Project COI Procedures & Exhibits for Community Managers COI Training Presentation Vendor Agreement Special Request Emergency Form Special Waiver of Min Requirements WC Exemption Form Incident Report‐ Non Employee
Cap‐Ex Policies and Procedures Exception to PO Procedures
Per the Capital Policies and Procedures a PO (purchase order) is required in Yardi system to be linked to any and all
capital purchases and projects in order for them to hit the correct capital GL accounts. While this holds true in most
instances, we have found that when IT makes a purchase for a property (e.g. software for PC’s, PC’s for managers/Asst.
managers/PCs for surveillance equipment, etc.) a PO is not necessary because it cannot ever be linked to the original
invoice/purchase. This is due to how the invoices flow through the company and accounting department. These
9 purchases would be considered an in‐house purchase/transfer of assets because it is purchased by housing and then
transferred out to the property. Because of this, you DO NOT need to enter a PO for this type of equipment. However,
if it is a purchase that is not in your approved capital budget, it is still considered unbudgeted and you will need to
continue to request approval to proceed with the purchase through the Cap‐Ex Committee.
Purchase Order Reminders
When setting up a PO, please be sure to include a description in the description box & on the description line. Also
include the correct unit number in the description & the Unit box. This is a great tool for research purposes and
provides more detailed and accurate information on the PO.
Purchase Order Workflow
The purpose of the Purchase Order is to capture “committed dollars”. Each month with End of Month (EOM) you are
asked if you have any POs that need to me closed out manually.
Look at open Purchase Orders
If you selected the wrong vendor, the PO is invalid, close manually
If you entered the PO AFTER the invoice was already in system, the PO is invalid, close manually
If the PO is valid, you made a purchase and the invoice is outstanding, you may want to follow up with vendor
If PO expense was denied (not approved by appropriate levels) close manually
OH NO………. REAC Inspections within the next 120 days!
Carbondale Towers, Maple Oak, Memphis Towers, Miller Village
Morningside Gardens, Plaza Hills and Tivoli Place
Jennifer, Leslie, Towanda, June, Rhonda, Carrie and Faye
Are you ready?
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June 2013
Daily/Weekly/Monthly: Collect Rent; inspect property; follow up on work order and status of unit turns; process
applications; update waiting list and record unit offers and applicant contact; schedule recertification interviews; review
aged delinquency; Approve payables; process/assign purchase orders for CAPEX expenses and obtain approvals in Yardi;
enter payroll in ADP; back up computers weekly to external drive device
Monday 6/24 Safety Meeting
Tuesday 6/25 Bad Debt and Admin write off request to RVP/RPM/DM for approval
Wednesday 6/26 Occupied Unit Inspections if not complete earlier in the month
Thursday 6/27 End of Month: Don’t forget that Annual Recert notices are a THREE step process. Make sure
you REVIEW, PRINT and POST (save a pdf copy to your computer)
Friday 6/28 CM review/audit MI files and send to compliance specialist within 5 days of Move in:
Pull November recertification tenant files. Recertification notices due to residents on July 1st
July 2013
Monday 7/1 Collect Rent; Pull info for Quarterly Investor Reporting (if required) Due to them by
7/10‐ City of Memphis, Boston Capital, Deutsche, Regions; Due to them by 7/15‐ US Bank & Wells Fargo
Tuesday 7/2 Run EIV Master File Reports: Failed Prescreen and Verification Report; Collect Rent
Wednesday 7/3 Run EIV Tenant File reports for November Annuals, Interims and MI’s in the last 90
days; File in resident file, take action on any discrepancies or other miss‐information; Collect Rent; Scan and E‐
mail CM Monthly Certification, EIV checklist and TRACS checklist for June to Susan Howell and Supervisor (due
by 5th):
Thursday July 4th Happy Independence Day
Friday 7/5 Schedule interview with residents with a November Annual recertification
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Monday 7/8 Review delinquent rent report; print, copy, deliver late rent notices
Tuesday 7/9 Meet with residents with a November Annual recertification
Wednesday 7/10 Follow up with residents who did not respond to first reminder notices prior month;
Thursday 7/11 Certification Interviews: Work order follow up: Interims: Mail/Fax verifications; CM
review/audit MI files and send to compliance specialist within 5 days of Move in Mail/Fax verifications from AR
interviews and Process Applications;
Friday 7/12 Certification Interviews: follow up with residents who did not respond to last month’s first
reminder notices; Work order follow up: Interims: Mail/Fax verifications; Process Applications;
Monday 7/15 Certification Interviews: Unit Inspections; Work order follow up: Annuals, Interims: Mail/Fax
verifications; Process Applications
Tuesday 7/16 Grace Hill required group course “Bed Bug Awareness” scan and email training
acknowledgement sheet to [email protected]
Wednesday 7/17 Make every effort to complete September Recertifications on or by the 15th allowing
resident sufficient time to come in and sign to avoid unnecessary termination of subsidy:
Thursday 7/18 CM review/audit MI files and send to compliance specialist within 5 days of Move in:
Friday 7/19 Occupied Unit Inspections
Monday 7/22 Check status of CAPEX purchase orders in Yardi; Safety Inspections
Tuesday 7/23 Organize Pending Special Claims folder
Wednesday 7/24 File eligible special claims
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Thursday 7/25 CM review/audit MI files and send to compliance specialist within 5 days of Move in
Friday 7/26 Safety Meeting
Monday 7/29 Bad Debt and Admin write off request to RVP/RPM/DM for approval
Tuesday 7/30 Occupied Unit Inspections if not complete earlier in the month
Wednesday 7/31 End of Month due by today! Don’t forget that Annual Recert notices are a THREE step
process. Make sure you REVIEW, PRINT and POST (save a pdf copy to your computer) CM review/audit MI
files and send to compliance specialist within 5 days of Move in: Pull December recertification tenant files.
Recertification notices due to residents on August 1st
Reminders
This calendar is a tool with a few reminders and is not intended as an all‐inclusive list.
Use the most up to date forms, policies and procedures
File Resident file information in resident file – including unit inspection repots
Audit your own paperwork to reduce errors
Training materials are available through many sources. Don’t get left behind!
www.lawlerwood.com Property Management> Training Materials & Policies & Procedures
SAHMA* State Contract Administrators * NCHM * NAHMA * NAHB *.
Make sure Service Team Members follow all Asbestos, respirator, hazard communication, blood borne
pathogen, lead base paint, mold & mildew and Freon / Refrigeration procedures and have the proper PPE to
perform their duties
Safety Inspections, it’s not just closing out a work order in Yardi. The safety inspection form has four parts and is
completed by employees monthly to document the condition of property work areas and common areas. The
Safety meeting with staff each month is the perfect time to discuss safety issues on your property and assign
work orders to address any deficiencies. Original Safety Meeting minutes and Safety Inspections should be filed
in the appropriate section of the Work Place Safety Binder (Meeting chapter 4 section B, Inspection chapter 3
section B)
