'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:

'Tis the Season

This week's small dose of the white stuff should serve as a reminder that the season of snow is upon us.  Although there aren't any imminent storms, the time to be prepared is now.  Don't let yourself get caught by surprise when the snow flies.  Here are some of the steps you'll want to take to make sure you, your staff, and your Residents are ready: 

 SNOW STORM PREPAREDNESS 

Property Preparedness 
•     Make sure snow removal equipment is ready and accessible – that storage shed may be 
      snowed in during the storm – have equipment stored where it can be easily reached. 

•     Snowblowers should have a full tank of gas with a supply of extra gas readily on hand – 
      snowfall is expected for more than 24 hours so ongoing snow removal will be critical. 

•     Check supplies of snow melt and sand – get extra if necessary 

•     High winds are expected – secure the outside of the building – remove any objects that 
       may come loose in high winds a pose a danger – hanging decorations, light furniture, etc. 

•     Check trees for potential loose limbs and remove any hanging or dangerous limbs in 
      advance of high winds 

•     Check your generator fuel levels and ensure that fuel levels are at maximum capacity 

•     Test all equipment – snow blowers, generators, emergency lighting, etc. 

•     Turn up the heat – get the building warm in case of power outages if you will lose heat  
      during a power outage

•     If your site serves meals – have ready to eat provisions on hand – canned meals that can 
      open without an opener (and/or have a manual can opener on hand), granola bars, etc. 

•     If your site is staffed 24/7 discuss coverage with staff today and have an emergency plan
      in place 

•     POST EMERGENCY CONTACT NUMBERS 

•     Have your property insurance contact information readily available in the event that there 
      are damages that need to be reported. Staff Preparedness 

•     Advise maintenance staff and others who will be outdoors to dress in layers and ensure all 
      exposed skin is covered 

•     Stay hydrated – hydrate before beginning physical activity (such as snow removal), hydrate 
      during and after 

•     Have all cell phone, radios and communication devices fully charged and ready 

•     Have an emergency contact plan ready so staff can stay in touch 

•     Safe snow removal –
      o     Begin early and often – remove snow in an ongoing effort which will reduce the risk of 
             heavy lifting 
      o     Dress in layers and in water repellent clothing 
      o     Take breaks – snow removal is aerobic activity – drink water 
      o     Keep your vision clear to prevent injury Resident Preparedness

•     Distribute memos to all residents today (the earlier the better) reminding them to prepare 
       o     Ensure that adequate supplies of prescriptions in the event that roads are impassable 
              or power goes out for a prolonged period of time 
       o     OXYGEN – residents who depend on oxygen should have an adequate back up 
              supply in the event of power outage 
       o     Plan for relocation in the event of a prolonged power outage – talk to family members 
              and make a plan      
       o     Have flashlights at hand with adequate batteries 
       o     Charge cell phones continually throughout the storm so they are fully charged in the 
              event of power outage 
       o     Consider having a battery operated radio on hand to stay connected in the event of 
              power outage 
       o     Have food on hand that can be eaten without being cooked (ready-made canned 
              food, energy bars, etc.) 
       o     Have adequate water supplies for staying hydrated 

•     Remind residents to have adequate warm clothing for the outdoors in the event they need 
       to relocate – coats, gloves, hats 

•     Remind residents not to drive during an ongoing storm unless absolutely necessary 

•     Fill cars with gas today – remember in a prolonged power outage the gas stations shut      
      down 

•     Pet supplies – for residents with pets make sure they have a food supply Post Storm 

•    Check in with your trash removal vendors regarding status of weekly pick-up post storm. 
      You should advise the vendors of the status of the dumpster area (date it will be cleared 
      for pick up) and see if they have any changes in their scheduled pick up due to the snow. 

•     Consider advising residents to adopt the buddy system if they have to go out. Check in 
      with a neighbor before going out to walk a dog or retrieve an item from the car. Check
      back in when you return. If your “buddy” has not heard back from you by a set time they are 
      checking in and letting someone else know. 

•     Be sure that fire hydrants on your property are cleared and accessible to emergency 
      personnel and fill pipes for fuel tanks as applicable.

•     Please ensure that the main entryway to your building is cleared and accessible by 
      emergency personnel. Please emphasize with plow contractors that this is priority 
      one when clearing snow from the facility. 

•     Check your roofs and gutters –get out the roof rakes and clear affected areas. Make sure 
      that entrances are clearly marked and/or cordoned off during roof snow removal so 
      residents are safe. 

•     Check ground level or below grade apartments to ensure that windows are clear for       
      emergency egress.

•     Treat walks and parking areas with sand/salt as necessary to minimize slippery 
      conditions -- complete your snow removal logs throughout noting date, time, conditions and 
      any material applied (sand, salt, snow melt) 

•     Check all boiler rooms and building vents to ensure that vents are clear and proper air 
      circulation is maintained. 

•     Maintain staff communication and check in with your emergency call service for any reports.

•     If possible, have staff that are able to get into the site check on residents.


Links to Helpful Information:
Preparing for Winter Storms and Extreme Cold - ready.gov
Winter Storm Preparedness Checklist - redcross.org
7 Winter Safety Tips for Seniors - care.com
Preparing to Stay Healthy in Winter - 4elders.org

Know a good link for more info?  Share it in the comments!

Scenes of Autumn, Maples Style

Some of us in the Northwest corner of CT (like me) woke up to a bit of a wintry scene this morning.  The same is true of parts of Massachusetts - here's what the Maples looked like this morning:

Which reminds me...now is a good time to make sure you're prepared for winter - snowblower serviced, contracts firmed up, ice-melt / sand ordered, policy communicated to residents, generator fueled and serviced, etc.  

I'll be posting an article soon on the things you will want to do to make sure you're ready for winter.

Scenes of Autumn

Pretty Autumn foliage from SayeBrooke Village:

Do you have some pictures of foliage from your site that you'd like to share?  Send them my way, and I'd be happy to post them!

To Those Who Serve

To all of our colleagues, residents, friends, and family members 
who have served in the military,

 and to all others who have served, currently serve, and will serve...

Thank you.

Brasil visits Norwalk

Look who stopped by to visit Miss Laura M. Raymond Homes!  This is Brasil the therapy dog. Brasil and his owner, Don Smith, visit nursing homes and have worked extensively with disabled children struggling with Autism and other conditions.  Brasil is calm and quiet, approaching walkers, wheelchairs, etc. without concern.  Don and Brasil are part of the Healing Hounds of Stamford program, have won awards, been on tv, visited the library - Brasil, I discovered, is even a clothing model!  He has logged more than 3,000 hours visiting others. Therapy dogs are now even assisting children to read!

Programs like Healing Hounds and Tails of Joy are just a couple of the many therapy animal programs out there.  After the tragic shooting in Sandy Hook, therapy dogs were brought in to assist the children in dealing with those events.  Recently, CT law recognized the value of these types of programs.  

Approximately 20 Residents visited with the pair; Don and Brasil will be visitng Miss Laura Raymond Homes monthly.  

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.