'Tis the Season for Giving (and Receiving)...What to Do if you Receive a Gift

Very often at this time of year, questions arise around what gifts are and are not OK for staff to accept, and what to do if a gift is left in the office or a Resident refuses to take "no" for an answer.

Gifts from Residents / Vendors:

EHM policy states that:

"Employees and anyone with whom they have a personal and/or business relationship (such as family members and/or business partner) must not accept entertainment, gifts, or personal favors that could, in any way, influence, or appear to influence, business decisions in favor of any person or Company with whom or with which EHM has, or is likely to have, business dealings.  Similarly, employees and anyone with whom they have a personal and/or business relationship must not accept any other preferential treatment under these circumstances because their position with EHM might be inclined to, or be perceived to, place them under obligation."  (EHM Employee Handbook, Page 18, "Gifts, Entertainment, and Favors)

Generally speaking, a holiday or similar gift that is under $25 in value will not cause concern.  But please bear in mind that regardless of the dollar amount, any gift that appears to be part of a quid pro quo may be an issue.  Great care should always be taken to avoid any impression of bias for or against any resident or group or residents, especially those who are members of a protected class.

In some cases, Managers may be concerned about refusing a well-intentioned gift.  In some cases, there are other options.  Where possible, gifts that may cause a concern if accepted by the individual Manager, but that are not necessarily a concern with regard to amount, can simply be diverted to the building so that they may be enjoyed by all.'

For Example:
1.   Resident Mary Smith brings down a large tin of holiday butter cookies.  The Property Manager is hesitant to accept the gift for herself, but Mary is insistent.  The Manager may take the option of thanking Mary for her gift, and advising Mary that the cookies look so wonderful, they should be shared.  She will tell Mary that the tin of cookies will be left in the Community Room, where everyone can enjoy them.

2.  Joseph's daughter stops by and says that after her father's fall on the ice a few weeks ago, the staff was so kind that she would like to give them a gift of $200, to be split among the Super and the Administrator.  The Administrator tells her that staff is prohibited from accepting such a gift directly, but if she wishes to make a donation to the building, or to EHM / New Samaritan, they will ensure that it is put to good use.

3.  Murphy's Snow Removal and Landscaping sends a gift tower of snacks to the corporate office every year, addressed to the Maintenance Supervisor.  It is always left in the break room where everyone can enjoy it.


Gifts from Owners / Boards of Directors:

Just as with Residents, gifts provided by the property Owners can also causes concerns.  As an EHM employee, your compensation must come solely from EHM.  As stated in the Employee Handbook:

Regarding EHM's business activities, employees and anyone with whom they have a personal and/or business relationship may not receive payment or compensation of any kind, except as authorized by EHM.  In particular, EHM strictly prohibits the acceptance of kickbacks and secret commissions from suppliers others.  Any breach of this rule will result in immediate termination and prosecution to the fullest extent of the law. (EHM Employee Handbook, page 18 "Kickbacks and Secret Commissions")

Again, staff should be concerned with anything that gives the impression that the above is occurring.  Vendors should clearly be told that we are not permitted to accept commissions, referral fees, etc.

Boards / Owners occasionally will want to provide a "holiday bonus" or similar gift to the site staff.  This can only be done with the direct approval of EHM, and there are certain steps that must be taken to ensure that the rules are followed.

Any time anyone outside of EHM payroll is attempting to provide compensation, the Regional Coordinator should be contacted immediately for guidance.  The same is true with anyone who wishes to provide a gift to staff that may conflict with policy.  Just as with most things in our business, it is important to document everything.  While it is wonderful to be appreciated by the Residents, Boards, and Vendors we come into contact with, it is vital that we do our jobs in a manner that is above reproach.

References:
EHM Employee Handbook

Questions to:
Regional Manager
Pam Kazlauskas, Assistant Director of Property Management
Tammy Lautz, Director of Property Management
Jill Vangor, Director of Human Resources.

"My Son is Paying My Rent..." - Recurring Gifts

Recurring Gift income is one of the most difficult items to verify and track.  Often, we find out after the fact, by discovering something on a bank statement, seeing a different name on a rent check, etc.

HUD, DECD, CHFA, and USDA all look at recurring gift income.  The language in all cases is largely identical to HUD's:

Owners must count as income any regular contributions and gifts from persons not living in the unit. These sources may include rent and utility payments paid on behalf of the family, and other cash or noncash contributions provided on a regular basis.

Most of the time, you're dealing with a definite amount - the amount of a car payment, or health insurance, for example.  In the case of utility bills, you can get a general idea by averaging the last six payments.

But what do you do when someone will be paying the rent for a tenant?  That can get very tricky, and here's why:

Let's say we do all the calculations, and here is our new resident's financial profile:

Non-Asset income:  $12,000
Asset income :  $0
Expenses:  $1200
Allowable Medical Deduction:  $840 (3% of annual income is $360)
Elderly Household Allowance:  $400
Total Deductions:  $1240
Adjusted Income:  $10,760
Tenant Payment (30% of adjusted) = $269

So now we have to recalculate based on the son's gift.  He says he's going to pay that $269.  Watch what happens:

Now, non-asset income becomes $12,000 + $3228 = $15,228

Allowable Medical Expenses are now $743 (3% of $15,228 is $457).
Add in the Elderly Household Allowance, and the total deductions are $1,143.

This makes the adjusted income $14,085, and the Tenant Rent $352

So, that $269 monthly gift translated to $83 more rent monthly.  If he then says, OK, I'll pay the $352, we now have a situation where we've got a moving target.  Each time we increase the monthly contribution, the rent increases.  So if they are really set on paying "the rent" for the tenant, this it will be necessary to keep making calculations until we arrive at a point that the contribution and the rent are relatively equal.  In this case, that wouldn't happen until we arrive at a monthly contribution of $400, and a rent of $403.

How, then, do we address this situation?

The easiest way, by far, is to have the individual contribute a set amount to the household monthly.  This is easy to document, and makes the calculation simpler.  If it gets any more complicated than that, contact your Regional Manager, or the Assistant Director of Property Management (Pam) for assistance.

Things to Remember:
Don't forget, recurring gifts include any payments made on behalf of your tenant, or contributions to them, except for:

- Gifts of Food
   (actual food.  Money intended to be used for food IS COUNTED)

- Direct payments to a child care provider
  Again, if the money is given to the tenant with the intent that it go to pay
  for childcare, IT'S INCOME

- Payment of medical expenses on someone's behalf
  (but then it also isn't counted as an expense)

Payment of any other expenses on behalf of a tenant (credit card bills, car payments, renters' insurance, etc.) IS INCOME, and must be counted.  Be sure to explain that question adequately in the interview, so your Resident / Applicant understands what we're asking.



References: 
HUD 4350.3, REV-1, CHG-4, paragraph 5-6(G), page 5-12
USDA HB-2-3560, Attachment 6-A, page 6-57

OneSite Issue - Internet Explorer 11 Users

If you are having trouble running OneSite right now, it may be because your computer automatically updated to Internet Explorer 11 Preview.  Below is information on how to check to see what version you're running, as well as how to resolve the issue if you are indeed running Internet Explorer 11.  Click the pictures to see larger versions. 

NOTE:  If you don't see the options listed below, you may be running an even older version of Internet Explorer.  If this is the case, please let me know so that I can assist you in getting an updated version.  Be VERY careful, and don't download a browser unless you know what you're doing - it's very easy to get a malicious program into your system if you don't pay close attention to where you're downloading from.

To check to see which version of Internet Explorer you're running:

 
1.     Open an Internet Explorer window

2.     In the top right-hand corner, click the little gear-looking icon, then click on “About

        Internet Explorer.”

3.     A little window will open and tell you which version of Internet Explorer you are

        running.  While you are on that window, uncheck the box that says “Install updates

        Automatically.”  This will prevent future problems.

4.     If you are running Internet Explorer 10, but are still having problems,

        check these settings.  If that doesn't work, please let me know.

How to fix the Internet Explorer issue:

If you are running Internet Explorer 11, here’s how to solve your problem (easy-peasy, lemon squeezy)!

1.     Close out that little box that tells you your Internet Explorer version. 

2.     Go up to the top right-hand corner again, and click the little gear again.  This time,

        when the menu opens, click on "Compatibility View Settings."

3.     In the window that opens, you will see "*.realpage.com" listed as a website to add to

        the list of sites to run in "Compatibility View."  Click "Add," and then click "Close."

OneSite should now run for you. 

If it doesn't, or if you need help, please let me know.

Snowmen in the Kitchen...

Check out this stroke of decorating genius.  The artist is Linda, a Resident at Lymewood: