Stranger Danger - When is a Secure Buildling Not Secure?

DANBURY --Just after midnight Saturday, neighbors heard screams coming from a seventh-floor apartment at the Wooster Manor senior housing complex. Worried neighbors knocked on the door, calling the name of the 85-year-old woman who lived there.

But when a male voice answered, "Everything's fine, there's nothing to worry about," they knew the opposite was true.

"His voice was so calm. That's when I knew for sure that something bad was going on," one of the neighbors said Monday.

Something bad was. 

The story above comes from the Danbury News-Times (the full story is here).  Thanks to neighbors who would not give up on their friend, and kept pounding on the door and demanding entry, the attacker fled. Worth noting here is that he had a gun, and they would probably have been better off to call the police and let them deal directly with him rather than attempting to confront him.  After a chase lasting approximately 14 hours, police were able to arrest the attacker, who had a prior history of assaults, etc.  The woman survived, and her condition is improving.  

How did the attacker get in?

You cannot stress enough to your Residents that no matter what security system you have, it is only as secure as the Residents and Staff make it.  I always make sure to compliment Residents when I show up at a site and am told that "I don't know you so I can't let you in."  I always tell them that's fine; I'll simply call the office and let them know I'm here, or have someone reach a Superintendent.  I also thank them for being diligent about security.  In fact, if they let me in, I'll often kindly tell them that they really shouldn't have if they don't know me.  What is their response?  Typically, it's "Well, you said you were from the management company, and you look nice..."

I certainly don't mean harm to the Residents, but people who make a living getting let into buildings so that they can do harm know how to get people to open doors for them.  Please, please stress to your Residents that they should always be careful, and should never open the doors for someone they don't know personally.  Even with a neighbor's child, etc., they should not be opening the door.  Guests should be contacting a particular Resident to be let in, or speaking with Management.

In the case of emergency personnel, almost all first responders (police, fire, etc.) have a Knox Box or other method of entering the building in an emergency.  If they need to, they'll break a door.  I always tell Residents that if it comes to that, I'm happy to replace a door if it means the police or fire department were able to do what they need to.  If your building does not have a means for emergency personnel to enter after hours (and I would be surprised if that was the case), speak with the local Fire Marshal about what you need to do in order to get them quick access.

Residents can always call the police department if they are concerned about the authenticity of an individual claiming to be a police worker.  A dispatcher can verify for them that indeed, a police officer is at the door.  Residents who have called the police should be at the door to meet them if it is safe to do so, and if they are able.

We don't want to frighten our Residents unnecessarily, but it is important to remind them that they need to be serious about security.  I sincerely hope that the victim in this case recovers fully and swiftly.  It is also my hope that her horrible ordeal serves as a lesson to others, and saves someone else from a similar experience.

The Handbook, it is a' Changin'...

Change 4 is out, and in effect.  The updated 4350.3 Handbook is available for download here.  Get it.  Be it.  Live it.  Well, not really.  Just get it - and know what's in it.

For those of you who remember, the old handbook had 30 changes before it was scrapped altogether, and Mark Alper of the National Center for Housing Management has stated he's already heard that Changes 5 and 6 may already been in the works.  

First, the bad news:
HUD has not changed their view on allowing housekeeping services as a deductible expense even when recommended / ordered by a physician.  Housekeeping is allowable as a disability expense, but remember, disability expenses must necessitate employment.

HUD has not clarified the addition of adult children to a 202 PRAC versus a 202/8 (Paragraph 3-), so please continue to speak with Pam if you get these requests.  


Now, the good news:
Most of the Change 4 revisions really just clarify items we already know about, but that weren't in the Handbook.  Nothing earth-shattering in Change 4.


And now, the details.
What follows is a very brief analysis of Change 4.  

CHAPTER 1 - INTRODUCTION
This chapter is an introduction to the subsidized housing programs funded by HUD.  No major revisions here; HUD added a few of the programs to the list of the ones not covered by the 4350.3, revised some wording, and updated links.

CHAPTER 2 - FAIR HOUSING
There have been no significant changes to this Chapter.

CHAPTER 3 - ELIGIBILITY
HUD has added EIV into this Chapter, and given it its own paragraph detailing requirements with regard to eligibility.

HUD has also:

• clarified the rule on Social Security Numbers
• removed Foster persons from the "excluded from income" list, as we now do include some items for Foster persons.
• revised some wording to make requirements clearer
• clarified verification of disability

CHAPTER 4 - WAIT LIST AND TENANT SELECTION
HUD has added EIV, VAWA, and Lifetime Sex Offender screening to the required topics to be covered in Selection Plans.

The HUD-92006 "Supplement to Application" is now noted as required to be included in the Application packet, which you should already be doing.

HUD has changed their wording regarding noting the file when an individual refuses to complete the Race and Ethnicity Form (Paragraph 4-14A4, page 4-34).  Now, instead of saying that you "should" do this, HUD says you "may."  Please note that EHM says that you "WILL" note the file.  You simply need to include the form with your note on it that states that the resident declined to fill out the form.  This should also be noted on subsequent Recertification Acknowledgement forms.

CHAPTER 5 - INCOME, ASSETS, EXPENSES, AND RENT CALCULATION
Here, HUD has largely just updated language to include EIV.

Language has been updated to clarify that in Section 8 units, delayed payments received in a lump sum from the Dept. of Veterans Affairs are excluded from income.  Please note that NORMAL VA PAYMENTS ARE INCLUDED.

HUD has clarified that IRA, Keough, and other retirement accounts are considered assets, unless payments are periodic.  They have not updated the language to clarify Required Minimum Distributions, so check with me if you have questions.

HUD has noted that legal custody of a child is not a requirement to have the child classified as a dependent (and get the $480 allowance).

Similarly for our purposes, in order to verify that a child is legally authorized to be there, you do not need proof of legal custody.  A signed statement from the legal parent is fine.

Importantly, HUD notes in Paragraph 5-18D, page 5-61 that originals of Tenant-provided documents must be returned to the Tenant.

HUD has updated their language on allowable Medical Expenses in Exhibit 5-3.  Notable items:

• Transportation to/from lodging is connection with medical treatment, as with any other medical expense, is not allowable if it is reimbursed from an outside source.

• The language about allowable personal expenses has been updated. (Exhibit 5-3, Page 1)

CHAPTER 6 - LEASING
Again, the changes here are really more about clarification.

HUD has updated language around VAWA and service animals.

CHAPTER 7 - RECERTIFICATIONS
Again, no real changes here; HUD has included information on EIV that has already been addressed in notices.  The language here now reflects that included in HUD's Notice 2013-06.

One significant change is that HUD now says that Tenants in 202 PRAC and 811 PRAC programs WILL be evicted, rather than MAY be evicted for noncompliance with recertification requirements.  Administrators in those properties should therefore keep their Regional Managers informed when Residents are not cooperating with their recertification.

The section on Interims because of a change in Household Composition now includes information on Lifetime Sex Offender checks and Social Security Number disclosure.

CHAPTER 8 - TERMINATIONS
Failure to sign or submit consent forms, and failure to disclose Social Security Numbers are now included in acceptable reasons to terminate tenancy.

HUD has clarified that you cannot evict a Tenant who was admitted prior to June 25, 2001, for presence on a Lifetime Sex Offender registry unless there is a lease violation or other criminal behavior.

Tenant repayment obligations are now limited to a five-year window; you cannot go back any further.  Owners must have 50059s for the period during which they are claiming that subsidy was improperly collected by a Resident in order to pursue repayment.

CHAPTER 9 - EIV (FORMERLY BILLING AND SPECIAL CLAIMS)
This, in truth, is the biggest "change" in Change 4.  The entire Chapter on Billing and Special Claims has been eliminated.  The chapter is now solely devoted to EIV, and mirrors the language in HUD's 2013-06 notice.

This is especially of concern for 236 properties, since Chapter 9 was the location of the only reference to Excess Income Reporting.  236 sites (Hello, Frost Homestead) should keep a copy of the old Chapter 9 handy to refer to.

For Special Claims, Administrators should download a copy of the Special Claims Processing Guide, available here.

************************************************************************************

So that's the skinny on Change 4.  I strongly recommend that you attend or view online training regarding the Changes, but I understand that many sites have very limited training budgets.  

NCHM's online, 2-hour webinar is one of the most cost-effective options for Change 4 Training.  

Discuss your site's budget and your training needs with your Regional Manager to determine what the best option is for you.

As always, feel free to contact Pam with questions

http://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/handbooks/hsgh/4350.3

Recertifications - The Need for Promptness

Recertifcations are a time-consuming and very important part of managing a subsidized housing facility.  No matter the regulatory body, recertifications are fairly similar:  Interview the Resident, verify the information, and complete the necessary paperwork by the applicable deadline.

Sounds simple, doesn't it?  However, delayed or incomplete verifications, Residents who are away, and other elements can complicate the process.  All too often, these complications result in a delayed recertification.  It's important to remember that a late recertification should be an extreme rarity.  Managers should make every effort to ensure that recertifications are completed and submitted on time.  

To review deadlines:

CT law requires that residents receive 30 days notice of a rent increase, as do most regulatory guidelines.  With decreases in rent, or when the rent stays the same, regulatory guidelines and landlord-tenant law will permit the recert to be signed at any point up to the date the certification goes into effect.

Example:

A recert to be effective 10/01, with an increase in Tenant Rent, must be signed by 9/01.

A recert to be effective 10/01 with a decrease in Tenant Rent, can be signed at any point up to 10/01.

EHM / CHM policy is to have ALL recertifications signed a month in advance and to be submitted through the appropriate electronic platform as applicable (One Site, TRACs, MINC).  This means that it is important to take all necessary steps to ensure that recertifications are completed on time. Be sure to send all necessary reminder notices, and keep a copy on file.  Remember, it is the Resident's responsibility to respond on time, and to ensure that you have the information you require to complete the recertification.  If they fail to comply, they risk losing their subsidy.  In a HUD 202PRAC or HUD 811PRAC, they risk eviction.

Even when a Resident is away, either due to a planned absence or a medical issue, Administrators and Occupancy personnel must make an effort to complete the certification in a timely manner, and must document all steps taken.  Steps which should be taken to avoid late certifications due to Resident absence include:

1.  When Residents will be away during the recert period, either be sure to sign paperwork 

    before they leave, or be sure to obtain a mailing address so that needed paperwork can 

    be forwarded for signature.  Be sure to also obtain a phone number, so that a phone interview 

    can be conducted, and the Resident can be contacted for any missing paperwork.

2.  Check the Resident's file for any documentation of an individual with Power of Attorney 

     who may be able to assist with completion of paperwork.

3.  Make contact with the individual noted on the Residents HUD-92006 or Personal 

     Contact form  (if said individual is noted as the contact for certifications).

4.  If the Resident is away due to a medical issue, enlist the help of the site's RSC, 

     if applicable, to make contact with the Resident or Resident's family in order to 

     ascertain whether the Resident is well enough to receive visitors, and conduct 

     the interview in the healthcare facility or wherever the Resident is recuperating

     if feasible.  In HUD sites, a certification that is complete and simply awaiting a 

     signature, can be noted on the 50059 as "Resident unable to sign," with the 

     signature obtained when possible.

Please note, if a Resident causes a recertification to be late, either by not reporting for an interview by the deadline, by failing to supply necessary paperwork, or by failing to sign the recert, they forfeit their right to a 30-day notice, and the recert should be implemented as normal.  

If the delay is caused by Management or a third party, any decrease in subsidy must be implemented as of the effective date.  The Resident must be given a 30-day notice of the increase.  In HUD sites, the resulting gap in funding must be absorbed by the site.  In USDA/RD sites, it is the Management company who must absorb that loss.  

Missing Verifications:

Recertifications should never be delayed solely due to a missing third party verification.  Acceptable methods of verification include:

1.  Third party verification, including:

     -  Third party written

     -  Third party verbal / phone

     -  Third party obtained through fax or email.

    

     NOTE:  Third party verification is always the preferred method.  Other methods 

     should be considered ONLY when third party verification is impossible, delayed 

     beyond two weeks, or when regulatory guidelines specifically indicate another 

     method for a particular item (ex., EIV for Social Security income in HUD sites).  

     You should always attempt to follow-up on third party verifications at least twice

     (three total attempts) before considering them impossible.  

     Example:

     Administrator Lynn Jones is completing the Annual Recertification for Joe Renter.  

     Joe receives a foreign pension, which he says will take weeks to get a response on.  

     He there provides Lynn with four copies of his most recent pension check stubs.  

     Lynn sends out the first verification.  Two weeks later, she sends a second, marked 

     "2nd attempt."  One week after that, she sends out another, and notes it as "3rd attempt."  

     She then uses the copies Joe provided in order to calculate the Recertification.  If the 

     third-party verification comes back, she will check to make sure the amount she used is 

     correct, and will correct the certification as necessary.  

2.  Documents submitted by the tenant, including

     -  Copies of cancelled checks / receipts

     -  Statements showing payments made

      

     NOTE:  Bank statements are NOT acceptable proof of Social Security or 

     Pension income, as they do not show Gross amount; they show Net amount.  

3.  Signed statement by the Resident

     Such statement should include the Resident's best recollection of the 

     amount paid to a particular provider, the amount earned from an 

     employer, or the appropriate bank balance, interest earned, etc., during

     the previous twelve months, as well as the Resident's signature and the 

     date signed.

      NOTE:  A signed statement is a last resort, and should only be used when 

      other methods are impossible to obtain before the deadline.  All verification 

      attempts, including third-party requests and requests for documents from the 

      Resident, should be documented in the file before accepting a signed statement
      from the Resident.

And remember, the only information a Resident is required to provide involves income and assets.  Recerts awaiting only medical verifications should be completed using the methods above, or completed without the missing items and corrected later.  

Any recertification which appears to be headed for late completion should be reviewed with your Regional Manager or your Property Manager in order to ascertain whether additional steps can be taken in order to ensure timely completion.

Please refer to additional guidelines here.

New Procedures / Software Update Required / Regional Meeting

New Procedures:

Wanted to advise you that new procedures are being posted on the blog this week:

• The Move-Out procedure has been revised
• A new procedure has been developed to address Abandonment of a Unit / Death of Sole Household Member

Both procedures will be noted with a revision date. 

Please note that the tables in the security deposit disposition letters are not retaining formatting when updated in Google Drive, so those are not on the blog; they are attached in the email you received regarding the new procedures.   I will let you know when they are live on the blog.  I have included both “doc” and “docx” versions of the documents; those of you with older versions of Word (pre-2007) will want to use the “doc” versions.

These procedures will be reviewed at the July 31^st Regional Meeting.  Location and agenda will be confirmed this week via email; be sure to check your inbox regularly.

********************************************************************************************************

Software Update Required:

Please note that as we move all our procedures and forms to Google Drive, you should think about upgrading your software.  Currently, most documents are in “doc” format to allow those of you with older versions of Word to read them.  However, some functions are only available in current versions of Word / Excel.  Therefore, if you are currently using an old version of Word (which makes “doc” documents), you will need to upgrade to a newer version (Word 2007 or newer).  


Newer versions of Microsoft Office save documents as “docx” for Word or “xlsx” for Excel documents.  If you are upgrading software, be sure to look for a newer version of Microsoft Office.  Those of you with older versions of Word can download a converter so that you can see those documents (go here), but you will need to upgrade your software as soon as your budget allows.

REAC is a Four-Letter Word...

REAC.  Few things send a shiver down a HUD property manager's spine like that little acronym.

REAC - Real Estate Assessment Center.  Or, as I like to think of it:

RUN, EMAIL AND CRY

RUN:  Send notices, convince your tenants to untie emergency cords, get supplies for needed touch-ups, etc.

EMAIL:  your Regional Manager, with a CC:  to Tammy, Deb, Pam, and Ernie (ealbert@ehmchm.org) so that we can help you prepare and schedule your pre-REAC inspection.

AND CRY:  In fairness, not a necessary part of the preparation process, but REAC does cause more than its fair share of anxiety.

The sad thing is that while regulatory inspections are pretty much always going to be stressful, the REAC inspection doesn't need to be - and shouldn't be - such an out-and-out panic.  REAC should be on your mind every day:  Every service call, every contractor visit, every apartment inspection and every unit prep should include some level of REAC work.

When repairs are made, "good enough" should be "good enough for REAC."  Remember, HUD can stop by at any time and ask to tour your site.  While not everyone has the eyes of a REAC inspector, you should always maintain your site to a level where you'd be comfortable with a HUD inspection that day.

Those of us in the Administrative role tend to think of REAC as largely a maintenance issue - myself included.  In truth, though, the Administrators and Regional Managers, as well as other administrative staff, have a significant role to play in ensuring that the REAC inspection goes smoothly.

Ch-Ch-Ch-Changes

OK, so now I feel fairly old, since many of you probably aren't old enough to know the David Bowie song referenced in the title of this post...

But I digress.

HUD has recently announced a significant development - they're changing the way they do business in a way that will greatly impact us.  In short, they are dramatically reducing the number of offices they have:

Specifically, the Office of Multifamily Housing will streamline its organizational structure by consolidating 6 Headquarters business offices into 4 offices and consolidating its field structure of 17 Hubs to 5 Hub offices and 5 satellite offices reporting to the Hubs. The other 7 Hubs and 34 program centers will be consolidated into the remaining 10 offices (5 Hubs and 5 satellite offices). The 2 existing property disposition centers will be consolidated into one. Affected offices that will be consolidated include: 

Hartford CT, Manchester NH, Providence RI, Newark NJ, Buffalo NY, Philadelphia PA, Washington DC (field office only), Baltimore MD, Pittsburgh PA, Richmond VA, Charleston WV, Birmingham AL, Miami FL, Louisville KY, Jackson MS, Greensboro NC, San Juan PR, Columbia SC, Knoxville TN, Nashville TN, Indianapolis IN, Minneapolis MN, Cleveland OH, Milwaukee WI, Little Rock AK, New Orleans LA, Albuquerque NM, Oklahoma City OK, Houston TX, San Antonio TX, Des Moines IA, St. Louis MO, Omaha NE, Phoenix AZ, Los Angeles CA, Honolulu HI, Las Vegas NV, Anchorage AK, and Portland OR.

The big impact, for us, is the scaledown of HUD's 50 Multifamily offices to a total of only 10 nationwide.  HUD cites the need to update an outdated field structure, streamline operations, and eliminate unneeded and underused positions.  While HUD will be maintaining at least one office per state, it does not appear as though Multifamily offices will remain in each state.  The process is slated to begin this fall, and be completed by the end of FY 2016.

So why the change?  Well, as HUD detailed in its 4/24/2013 media release:

“The current organizational model for HUD is not sustainable from a financial and a service delivery point of view,” said Maurice Jones, HUD’s Deputy Secretary.  “We are reviewing every aspect of our operation to determine if we have the right people in the right places and we're determining where we can be even more efficient, to get the most value out of our limited resources.  We’re in a different budget environment and we’re at a point where we must make some extremely tough choices. That being said, we certainly understand that this type of change can be challenging for the agency’s employees and we are committed to moving forward on the plan in a way that is sensitive to the needs and concerns of HUD’s staff."

Reducing the cost of operations and the associated burden on the taxpayer is something that I think we can all agree is desirable.  However, for those of us working in the field, the idea of losing our local offices, who know our properties and the people who manage them, is less so.   There is no doubt that things will change significantly from what we are used to.  Whether that change is for the better remains to be seen.  

Some of the things that you can do to prepare are:

Plan for Success:
When you prepare anything to be submitted to HUD, remember that the person reviewing it may not be familiar with your site.  Try and include information that may head off questions, but don't include so much that the reviewer needs to sort through it all to get to what's needed. 

Make your submissions easy to review.  Submit organized packets, with tabbed dividers, a table of contents, cover letter, etc., as appropriate.  Include any relevant invoices, documentation, etc.  Avoid subjective comments, and make sure your justifications are simple and clear.

In short, provide just enough to fully cover what's needed, and make sure your submission is easy to navigate.  

Read relevant instructions and guidebooks to ensure you are on target, and make sure to check HUDClips to ensure you are using the most recent forms.  Be sure to contact your Regional Manager and/or other relevant staff for assistance where needed.

Submit items EARLY.  
Make sure that budgets, Reserve Requests, Contract Renewals, etc. are done in plenty of time for internal review and submission to JeffCo / HUD.

Know what's coming.  
Read the notices and stay up-to-date on coming changes.  Sign up for the HUDBlast (Ross Business Development) and the HUD RHIIP Listserv mailing lists.  And check this blog; we'll post developments as we become aware of them.  

Keep Breathing.
Air goes in, air goes out.  All is well.  Yes, this is a significant change, and any change is stressful.  This is uncharted territory, and there will be bumps in the road, no doubt.  But it isn't the end of the world, and worrying about it isn't going to stop if from happening.  If we keep informed, and do what we can to prepare for the change, we stand the best chance of weathering it with the least amount of stress. 

Relevant HUD Notices:

Federal Register, Volume 78, Number 81, Issued 4/26/2013

Federal Register, Volume 78, Number 83, Issued 4/30/2013 

HUD Media Release No. 13-054

Of Cowards and Heroes...and Housing Managers

This week's events in Boston remind us that though there are people out there who want to do harm, there are also those who go above and beyond.  We saw the worst and the best in humanity in one moment, on one city street.  Our thoughts and prayers are with the victims of the Boston Marathon bombing and their families at this difficult time, as well as with the members of law enforcement who are still working to apprehend all of the individuals responsible

.
From the individuals whose cowardly actions killed victims as young as eight years old to the military heroes who ran the marathon in full uniform and pack, then ran in to help victims of the blast, we saw the full range of what people are capable of.  

It's been an interesting week, to say the least. 

For those of us in housing, we also see the impact these events have on our Residents.  Some may have family members who live in the Boston area, or were running in the Marathon.  And the bombing, which at this point looks to be a terrorist attack, is bound to bring up memories of that awful September morning when we all learned that terrorism wasn't just a faraway threat. 

Your Residents may want to talk about the events.  There are likely to be several emotions that are prompted - grief, anger, fear.  While venting can be healthy, and we want to encourage our Residents to feel they can approach us, be aware that we have some other concerns we need to be mindful of.

As it appears right now, the perpetrators of this act are of Chechen Muslim descent, and immigrated to this country.  This information leaves open an opportunity for "those people" type comments.  While everyone is entitled to their opinion, no matter how distasteful, comments referencing any protected class are a potential Fair Housing concern.  Be sensitive in how you address this issue, but remember, discriminatory behavior is never appropriate. 

If you notice your Residents having a difficult time coping with these events, you should share this information with your RSC if you have one.  This way, he or she can follow up with Residents who may need some extra support. 

Flags at government and public institutions have been ordered to fly at half-staff until Saturday at sunset; sites with flags are encouraged to do the same.  You can read the Presidential proclamation here. 

The Latest on EIV

I really am beginning to think there's a reason my spellcheck suggests "evil" as the correction every time I type an email containing "EIV."  It's another of HUD's moving targets - the guidance changes frequently, and there are numerous parts to remember.  If you thought the guidance was done with the last memo, think again.  HUD has issued a new memo regarding EIV, and there are some very important elements.

By way of overview, HUD Notice 2013-06 does the following:

*     Advises that Section 811 Project Rental Assistance Demonstration units under 
      a Rental Assistance Contract are now under EIV requirements (Section II)

*     Includes a description of the active link found in the Identity Verification Report 
      Statistics.  The resulting report identifies the number of households represented 
      as not-verified (verification in process) (Section VII).

*     The "No Income Report" is now the "No Income Reported by HHS or SSA" report
      (Section VII).

*     Adds a new report - "No Income Reported on 50059" and discusses how the 
      report should be used (Section VII).

*     Identifies the New Hires report as a Verification Report and its location in the 
      Income Reports section of the system (Section VII).

*     Allows a violation for an owner/agent not having access and/or not using the 
      EIV system in its entirety to be identified and the penalty to be assessed 
      outside the scope of the MOR (Section XI).

Be sure to read the whole notice.  Perhaps the most important elements are the new report and the advisory on penalties, so I'll go into those a little more here.

The "No Income Reported on 50059" Report (p. 30 of Notice):
This report is located in the Monthly Summary Report when querying by Project Number or Contract Number.  If the text is underlined, it is an active link.  Print the summary page. 

Although HUD does not require you to keep a copy of this report on file, EHM does.  The EIV policy and attending documents will be revised shortly to reference this report, and will require the following:

*  The report must be run monthly as with your other EIV reports

*  If there are no "No Income Reported" reports, just file the summary page

*  If there are "No Income Reported" reports, print them and file. 

* Be sure to verify income status with households reporting zero income every 90 days by     
  means of the Zero Income Questionnaire.

For a screenshot of what the page looks like, click here.

Penalties:
If you do not have the CAAF on site, signed by HUD and the Owner, it is a significant issue.  Your reviewer will actually stop the review to get up and notify HUD of this, and your EIV access will be immediately cut off.

Any EIV violation results in a significant negative impact on the outcome of your review.  Be sure you know what the rules are, and follow them.

Remember that you must have EIV training yearly.  It is your responsibility to arrange for such training, unless you are informed that we will be doing an EIV training in-house.

RHIIP Posting #296 - Social Security Direct Express Debit Card

RHIIP Listserv Posting #296                                                                                                                                                                                               February 27, 2013

Welcome to the MULTIFAMILY HOUSING RENTAL HOUSING INTEGRITY IMPROVEMENT PROJECT (RHIIP) LISTSERV that brings you up-to-date RHIIP related publications, news, information and occupancy tips in an effort to help reduce errors in rent determinations and subsidy calculations.

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Social Security Benefits Move Fully Electronic

Effective by March 1, 2013

Clarification on the Treatment of the Direct Express Debit Card

The U.S. Social Security Administration has a new policy which will eliminate the option for Social Security and SSI recipients to receive their benefits in the form of paper checks beginning on March 1, 2013.  Recipients will continue to have the option to use direct deposit for their benefits or they may choose to receive a “Direct Express Debit Card.” The debit card is automatically loaded with a recipient’s benefits on the appropriate payment day of each month. The card is not associated with the recipient’s bank account and funds cannot be added to the card by the card holder.

We have received several inquiries about the Direct Express Debit Card and how it will affect income and asset calculations for tenants of HUD subsidized properties.  In order to remain consistent with HUD regulations, benefits received through direct deposit OR the Direct Express Debit Card will continue to be treated as income.  The balance on the Direct Express Debit Card is also considered an asset and will be verified consistent with existing savings account verification requirements.  Specifically, tenants who receive their benefit on a Direct Express Debit Card will need to provide an account balance no more than 120 days old at the time of recertification.  This balance can be obtained from an ATM, though the online account service, or a paper statement.  The verification document must identify the account and the account holder.  If the total household assets do not exceed $5,000, no income will be derived from this asset.  If household assets exceed $5,000, assets should be imputed at the standard rate of 2%.

For more information, please visit the SSA website at: http://www.ssa.gov/pubs/10073.html

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You can view the RHIIP Tips Archives, under "Listserv-Multifamily RHIIP Tips" at http://www.hud.gov/offices/hsg/mfh/rhiip/mfhrhiip.cfm

Now Listen Here, Groundhog...

Although Punxatawney Phil predicted an early Spring, it looks as though the Chuckles, the Connecticut weather prognosticator, may have been more accurate.  With winter storm Nemo (or in CT, Blizzard Charlotte) just behind us, it looks like we may have another blast of wintry weather headed our way.  I'm of the opinion that both of these groundhogs should get on the same page - meaning, whatever page means it's somewhere around 70 degrees tomorrow. 

In the meantime, I thought it might be interesting to show you how Nemo/Charlotte expressed him/herself at EHM/CHM sites.

This is Grace Meadows:

That misshapen lump?  The Superintendent's car. 

The small black dot about halfway up is the side mirror

And not to be outdone, here's Bernhardt Meadow:

Fortunately, these folks have garages, so they could still find their cars.

We in the northwest corner were fortunately spared the worst of this one, with average snowfall somewhere around two feet or so.  Usually, we're travelling by snowmobile while the rest of the state gets a flurry or two.

Not this time. 

The winner of the snow fall raffle this storm was undoubtedly the New Haven / Hamden area - with 40 inches of snow reportedly dropping by the storm's end.

Here's a picture of Davenport Dunbar:

OK, just kidding.  It wasn't quite that bad.  But close.  These are pictures of the streets near Davenport-Dunbar:

And this is at Oak View / Woods Edge:

And this was what my husband came out to when he got off of his 12-hour ambulance shift (which spanned the worst of the storm):

That lump there is my SUV, with that black oval being my side mirror.  At this point, I was stuck in my house with four to five foot snow drifts blocking all of my doors.  He had to come dig me out!

Things were no better at the barn where I board my horses - it looked like this:

To give you an idea of scale, there are two horses all the way on the right side of the picture.

This was an absolutely historic storm. 

Have some pictures of your site / home / area you'd like to share? 

Email them for posting! 

Be sure that if you have any residents in the picture,

you have a signed release from them before emailing a picture for posting on the blog. 

Now, if anyone needs me, I'll be cursing that groundhog and hoping for warm weather.

Take a Look - at Bonney Brook

Bonney Brook, a 10-unit HUD 202PRAC project, is currently in construction in Cornwall.  Slated for completion in Summer 2013, Bonney Brook will be managed by Elderly Housing Management. 

Uh Oh - Here Comes the Snow

As you've no doubt heard, this Friday's snowfall is likely to be significant, and is predicted to go into Saturday.

Winter storm Nemo is nowhere as cute and cuddly as his little cartoon clownfish namesake. It has the potential to bring record snowfalls, and comes very close to the 35th anniversary of the 1978 Blizzard that turned my neighborhood into a snow fort paradise when I was a kid.  I'm a lot less excited about blizzards these days.

Bad news for the shoreline is that damaging winds and coastal flooding are possible in areas that are still recovering from Superstorm Sandy.  And for those of us in interior areas of the state, two to three feet of snow are possible with this storm, along with the afore-mentioned damaging winds.

Granted, I'm always a bit skeptical about gloom-and-doom forecasts, but those of us who work in senior housing have a particularly vulnerable population to be concerned about.  In the day you have to prepare, be sure to do the following:

1.  Review emergency procedures with your staff.  Many of you have live-in staff who will be available; make sure that everyone knows who to get in touch with in the event of a concern

2.  Make sure that your Answering Service has an updated contact list.Remind your Residents that power outages are possible, and they should make preparations for the storm. Encourage them to use the "Buddy system" when going outside in the blizzard to walk a dog, retrieve something from a car, etc. They can let that person know when headed out, and when back, so if too much time goes by, someone can check on them.

Other suggestions can be found here.

This winter safety handout, shared by Dorothy of Davenport-Dunbar, provides additional helpful tips.

EHM sees the safety of its employees as the highest priority.  Use your judgement when deciding if it is safe to travel to your place of work.  Refer to the Employee Handbook for guidance.