They're Heeeeeeeere......

OK, maybe not THAT scary.

HUD has issued the FY 2016 income limits, effective 3/28/2016.  USDA sites, this means that the income limits should soon be posted to MINC - be on the lookout.  

How do the numbers stack up against last year's limits?  Kind of a mixed bag there.  Due to the way calculations are done, some slots have gone up slightly; some have decreased slightly.  There have not been huge changes either way, but it may very well change things for those folks who are close to the limit.  Be aware that some people on your wait list may no longer qualify.  

The income limits are here: 
https://www.huduser.gov/portal/datasets/il/il16/index_il2016.html

For those of you using OneSite, you will need to update the income limits in your system.  

To do so:

1.            Go to:  https://www.huduser.gov/portal/datasets/il.html

2.            Navigate to your income limits; print them out and make sure they are posted on site.

3.            Open OneSite.

4.            At the top right corner of the screen, click “Setup.”

5.            At the left side of the screen, in the blue menu bar, click “Affordable” under the

               “General property” category.

6.            In the center area of the screen, click “Income Limits” (third item down).

7.            In the window that opens, click “Edit” next to your HUD income limits.

8.            Your income limits will come up.  Be sure to enter the correct start date – 3/28/2016.

9.            Check the following settings to make sure they are correct:

               *     At the top of the window, make sure that “Round income limits to the 
          nearest $50 is UNCHECKED.

                

               *     Below that, make sure that you have CHECKED the box that allows you to 

                      make the table fully editable.  This is important, as the automatic calculations 

                      often do not match what HUD has; you will need to enter the numbers manually.

10.          Enter the income limits that you need.  For most sites, you will be filling out the 

               30% income limits, 50% income limits, and the 80% income limits completely.  

               You should also add the 4-person 100% limit.  For all items you do not need, 

               you should enter zero (OneSite will not allow you to leave these blank

11.          Click “Save” in the bottom right corner of the window to save your changes, and 

               you’re all set.

EHM Staff in the Community - Debbie Pelletier

Deb hard at work on budgets

Debbie Pelletier is the Asset Manager at EHM.  In addition to steering us through the complicated world of budgets, replacement reserve requests, EIV, REAC, and other regulatory and financial matters, Deb also keeps busy in her off hours.  Besides her passion for sailing and all things nautical, Deb has been involved in the annual Parkinson's Unity Walk for the last five years.  

The Unity Walk raises funds for research into a cure for Parkinson's Disease.  Parkinson's is a devastating illness that affects nearly one million Americans.  A chronic and progressive movement disorder, Parkinson's currently has no cure. Research is critical to finding effective treatments, and hopefully a cure.

100% of donations raised through the Unity Walk go to support the following organizations:  

• the American Parkinson Disease Association
•  the National Parkinson Foundation; 
•  the Parkinson's Action Network; 
•  the Parkinson's Disease Foundation; 
• The Michael J. Fox Foundation for Parkinson's Research; 
• The Parkinson Alliance
• The Parkinson's Institute and Clinical Center

Deb and her team, Deen's Day Trippers, will set off through NYC's Central Park on April 23rd of this year.  We wish them all the best of luck, with warm and benevolent weather!

If you would like to learn more about the Unity Walk, join Deb's team, or start your own, you can visit Deb's page here.


Care to share what you're up to in the community?  Email Pam

Welcome Back Artie!

To many of us at EHM, our coworkers become a second "family."  This is very true at Juniper Hill Village, where a variety of staff - Administrative, Maintenance, Resident Services, ALSA, and Dietary - come together to keep this very unique property running smoothly and enriching the lives of its residents.

Recently, a member of the JHV family experienced a serious medical issue, and has been away for several weeks.  For those of you who do not know JHV's Chef Manager Artie, he is the type of person who is always ready with a bright smile and a cheerful attitude.  He and the JHV dietary staff work hard to create nutritious, tasty, and creative meals for the Juniper Hill Village residents.  When the supervisory staff come to visit, we are always happy to sample some of their work!  It is quite the challenge to create variety, appeal to different tastes, and keep everything on target with the budget, but Artie and his staff are up to the challenge.

In what was truly a wonderful gift this holiday season, four weeks to the day after medical needs forced his absence, Artie returned for a visit.  He is pictured here with Kimmie and Jessica.  JHV's Administrator, Marlene, told me that Artie is well-known for giving Kimmie "rabbit ears"  in photos, and so Kimmie is returning the favor here.

Artie, we are so very happy that you stopped by to say hello, and wish you a speedy and full recovery.  We also wish you nothing but health and happiness in the coming New Year.

Decking the Halls at EHM

Bonney Brook, 2nd floor

Bonney Brook, 3rd floor

Bonney Brook, 1st floor

 Hearth Homes

The Ripton 

Marian Heights Community Room

Marian Heights 1st floor

On this Veterans' Day, we are proud to count so many Heroes among our staff and residents.  We thank you from the bottom of our hearts for your selfless service to our country. 

This nation will remain the land of the free only so long as it is the home of the brave. -Elmer Davis

"Veteran rides in Memorial Day Parade May 2009, Gloversville, NY" - by las - initially, Flickr

These heroes are dead.  They died for liberty - they died for us.  They are at rest.  They sleep in the land they made free, under the flag they rendered stainless, under the solemn pines, the sad hemlocks, the tearful willows, and the embracing vines.  They sleep beneath the shadows of the clouds, careless alike of sunshine or of storm, each in the windowless Place of Rest.  Earth may run red with other wars - they are at peace.  In the midst of battle, in the roar of conflict, they found the serenity of death. I have one sentiment for soldiers living and dead:  cheers for the living; tears for the dead.

- Robert G. Ingersol

EHM is on Facebook!

That's right - we're on Facebook.

Look for us as Elderly Housing Management (you can also click the button above).

Please "like" our page.  And while you're there, why not check out some of our recent posts:

Fun events at Davenport-Dunbar: 
Caribbean Cruise
Cultural Expo

We've also posted some great pictures of our sites.

And coming tomorrow - a birthday wish for one of our residents.

Please stop by and say hello - and be sure to check in frequently for news and updates!

Look What's Cooking at Juniper Hill Village

Travelling to the different sites, I occasionally have the opportunity to sample some of the meals at our sites with meal services.  I am always amazed at what our kitchen crews are able to put together on what are often very tight budgets.  

And some days, they really outdo themselves.

Check this out - Pumpkin cheesecake with Caramel Sauce and a Ginger Snap crust.  Well done, Jessica!

Fire Sprinkler Disclosure - What You Need to Know

As of October 1^st, 2015 a new Connecticut law (Section 57 of bill 1502) requires disclosure of operative fire sprinkler systems with any residential lease. 

Commercial leases are exempt unless there is a dwelling unit.

Who is Covered?

Any residential rental unit with a "fire sprinkler system," defined as "a system of piping and appurtenances designed and installed with generally accepted standards so that heat from a fire will automatically cause water to be discharged over the fire area to extinguish or prevent its further spread."

What is Required?

The new law requires landlords to take action as follows:

When renting any dwelling unit, the landlord...shall include notice in the rental agreement as to the existence or nonexistence of an operative fire sprinkler system in such dwelling unit and shall be printed in not less than twelve-point boldface type of uniform font. 

If there is an operative fire sprinkler system in the dwelling unit, the rental agreement shall provide further notice as to the last date of maintenance and inspection and shall be printed in not less than twelve-point boldface type of uniform font.  

What Steps Should I Take?

1.           Notice should have been provided to all existing residents.  If you did not 

              provide and post the notice, please let me know.

2.            The new Lease Addendum should be utilized effective immediately with 

               new residents. 

3.            Existing tenants will need to sign the Addendum with their next 

               recertification and Lease renewal.

4.            Because the document must contain the most recent available 

               information, the Fire Sprinkler Addendum must be signed 

               every year at recertification.

The Move-in / Recertification Acknowledgements have also been updated.  Be sure that you are using the current version.  

AFHMPs - What You Need to Know

Hopefully, you noticed that you received a calendar reminder on August 3rd which said:

Annual AFHMP Marketing (open this event to see notes)

The notes read as follows:

If you have not already done so this fiscal year, be sure to send out your AFHMP letters, and do your advertising.

 As a reminder, you must:

-          Send letters to all Community Contacts listed in your                                            Marketing Plan

o   Letters must be individually addressed and dated – KEEP COPIES OF ALL SENT

-          Advertise in all sources listed in your Plan

-          Advise Pam if any sources are obsolete                                                                      (phone numbers, names,  returned letters)

-          Review your plan if it is due for updating,                                                                    and advise Pam of any requested changes

o   USDA Plans must be revised every three years
o   HUD Plans must be revised every five years

This calendar reminder will pop up yearly.  You do not need to do this marketing in August; I just wanted a yearly prompt to remind you of your requirements in the event that you had not already done your marketing.  

This also presents a great opportunity to review what your requirements are, especially in light of the fact that there are some new tools to assist you in this area.  The new AFHMP procedure and forms will be posted shortly.  

To review, you are required to take the following actions with regard to Affirmative Fair Housing Marketing:

Posting:
Your AFHMP must be posted.  

If possible, post the plan with all attachments. It should be posted in an easily accessible location (the same bulletin board where the RSP and other required notices are posted).

Annual Marketing (Using the new AFHMP Checklist 3-39a and Affirmative Marketing Tracking Sheet 3-39c):
Once a year, you must place ads and contact all Community Agencies specified in your Plan. 

You must document your efforts, so be sure to:

• Get tear sheets (copies) of all ads'
• Keep copies of all letters (and envelopes) sent to Community Agencies
• Note any obsolete contacts and advise the ADPM (me) that you need a replacement.  
• Clip this documentation together and label with the month and year marketing was completed.  It should generally be done at the same time each year.

**HINT* Make one month a year Update Month.  Look at your Resident Selection Plan and Handbook; do they need updates?  Next, review your Plan and complete letters and advertising..  Finally, do your Wait List Update. 

Annual Review of Plan (See Affirmative Marketing Tracking Sheet 3-39c):
As stated above, this should occur once yearly, and should be documented using the
Affirmative Fair Housing Marketing Tracking Sheet (3-39b).  This form will allow you to note any obsolete contacts that may need replacement.

3-year (USDA) or 5-year (HUD, CHFA, DOH, LIHTC) Review (Using AFHMP Update Worksheet 3-39b):
You will be contacted when your site's Plan is due for review.  If for any reason you are not contacted, and you believe your Plan is due for review, please email the ADPM (me) for instructions.  

HUD requires that plans be reviewed every 5 years, and updated only if that is required.  If the demographics have not changed, and your contacts are current, the plan may not require any changes.  I will simply review the plan and provide you with documentation that the plan requires no changes.

USDA requires that plans be updated every 3 years, which means that you require a new complete Plan.

The Update Process:
For the most part, updates will be completed by the ADPM (me).  It is imperative that all your information in OneSite is accurate and current.  Demographic information regarding race, ethnicity, and disability status is required for the Plan.  I pull the demographic reports from OneSite when completing the Plans.

DOH sites and others not using OneSite, you will be asked to provide demographic information on your applicants and residents. 

If the plan requires updating, you will also be asked to provide a digital color photograph of the site sign, as well as information on the dimensions of the logos on the site sign. 

Once a final draft is completed, it will be emailed to you for review.  Finally it will be sent to the regulatory body for approval.  You will have a copy on site; be sure to keep the approved plan on file.

Failure to Update as Required:
Please note that failure to perform the steps required can result in a finding on your Management Review / USDA Compliance Review.  

Additional Marketing:
Remember, the AFHMP targets your least likely to apply.  If you are finding that your wait list is dwindling, you may also want to undertake additional marketing to those most likely to apply.  You can do that whenever you like, and as many times as you like.  You must, at a minimum, complete your AFHMP advertising yearly.  Speak to your Regional Manager if you believe your site needs to do additional marketing to add to your Wait List.

Questions:
If you have any questions, please be sure to direct them to your Regional Manager / Assistant Director of Property Management / Director of Property Management.   

Reasonable Accommodations Revisited

Few aspects of our business seem to generate the confusion, frustration, and discussion that Reasonable Accommodations do.  And few can get us into as much hot water.  I find that every few months or so, it's a good idea to review some of the main points of this tricky aspect of property management.


A Request, in Any Other Form, Would Smell Like a Request:
A requester does not need to fill out the exact forms we use in order to be making a request.  Don't ignore something just because the resident didn't specifically say "I want a Reasonable Accommodation."  A letter from a doctor, a casual remark, a comment to the Super, etc. can all be deemed to be requests.  At the very least, casual remarks open the door for you to say, "You mentioned to the Super that you have a difficult time walking from the back of the parking lot to the building.  I wanted to review our Reasonable Accommodation policy with you so that you can decide whether you would like to make a request."  Alternatively, if your site has a Resident Services Coordinator, you can ask him/her to meet with the resident to discuss whether a Reasonable Accommodation might be needed.  


When is a Verification Not a Verification:
We have all had the experience of having a doctor write out an ambiguously worded letter - something like this:

"Mrs. Jones states that she suffers from allergies caused by mold in the carpet.  It would be helpful if the carpet was removed for her."

This is NOT sufficient to serve as verification of either disability or need.  Specifically:

• The doctor is telling you that he/she is relying on statements by the resident about their condition and the cause of the problem.  We are asking that the verifier rely on their professional experience.  While we can rely on credible self-certification, this type of note isn't going to qualify as credible self-certification.

• "It would be helpful if" is not the same as "Mrs. Jones requires..."  Other phrases to watch for are "...would benefit from," "may assist with..." and "please consider..."

Sufficient verification, whether on our form or in another format, must contain the following:

• Documentation that the individual is disabled (in some cases, this is worded as the individual having a medical condition)

• Documentation that because of that disability, the requested item is necessary (not a good idea, not beneficial, and not a really nice thing to do).  

The important thing to remember here is that reasonable accommodations and modifications are changes that are necessary (not just something the individual would like) in order to permit a disabled individual an equal opportunity to live on the property, apply for housing, enjoy the facility, etc.  We, therefore, have to accommodate a need, but not necessarily a preference.  

All Requests Go Through the Assistant Director of Property Management (ADPM)
That's right - all of them.  From large print notices to walk-in showers, they all come through Pam for approval.  There are a few of reasons for this:

• It keeps our approach consistent.  The same person is always looking at them, and I have the knowledge of how we've responded to similar requests at the same site, as well as across the portfolio.

• It keeps the response objective.  We all have residents, applicants, family members, etc. that can push our buttons.  An arms' reach approach to approval helps to protect site staff from allegations of favoritism or unfair denials.

• It allows documentation and monitoring of our efforts.  All Accommodations and Modifications are tracked, and reported on monthly.  The Assistant Director of Property Management (Pam) and Director of Resident Services (Lee) work together to ensure that all requests have been completed appropriately, and to offer support for those that are more challenging than others.  

Remember, before forwarding a request to Pam, ensure that you have the following:

• A clear request that states what specifically is being asked for; AND
• A verification form that is complete, i.e., has answers to both the question of disability and the question of need.  

          OR

          A note from a verifier that addresses both areas listed above; 

          OR

• A clear request that states what specifically is being asked for; AND
• A Confirmation of Known/Obvious Disability and Need for Accommodation of Modification

Never Say Never:
When a resident asks us for an accommodation, we will almost never say, "No."  Reasons for a simple denial include 1) A verifier stating that an individual does not qualify as disabled, or 2) A verifier stating that an individual does not need what they're asking for.  Even in those circumstances, the answer is going to be somewhat complicated - it is likely to look like this when it comes from Pam:

"...your verifier stated that you were not disabled, and that you did not require...if you wish to submit an alternate name for a verifier, please do so no later than..." and so on.  

If the issue is that we have found a particular request to be an undue burden, or to be unreasonable for another reason, the response is likely to be something like this:

"...we have determined that the item you requested constitutes an unreasonable administrative and financial burden.  The site does not have the funds to support what you have requested.  Further, we are unaware of any grant funding which would allow us to complete this.  Finally, we do not have sufficient staffing to dedicate solely to obtaining funding for this project.  Therefore, we will offer you the following alternative..."

Basically, you are almost always going to be saying "No, but..." rather than "No."  You must enter into an "interactive dialogue" with the resident in order to arrive at something that everyone can live with.  It's the difference between trying to avoid action, and actively trying to solve the issue.  


The Financial Burden that Isn't:
Always remember that your definition of a financial burden, and your regulatory body's definition of a burden, can be two vastly different things.  Basically, a financial burden means that the cost is so high that it would compromise the financial health of the facility.  

Example:
Green Field Apartments is a 100-unit site with $45,000 in its Reserve Account.  The most recent Comprehensive Needs Assessment (CNA) shows that the property's roof is due to be replaced, it has several areas of unsafe concrete that need to be addressed, and the parking lot needs some work.  They are applying for grants for some of the items, but anticipate more than $40,000 will come out of Reserves for necessary work in the next three years.  Deposits right now are only $5,000 a year.  The boilers are almost at the end of their useful life, and the property has had three water heaters go in the last year.  

A resident puts in a request for a walk-in shower.  The estimates put the cost at somewhere between $5,000 - $7,000.  

This property could make a good argument for a financial burden.  The capital projects that are being planned are not optional, and likely could not be put off.  In addition, there are several more projects that will need to be undertaken, and deposits to reserve are low compared to the need.  In addition to examining its budget, this property will likely need to carefully examine any Reasonable Accommodation requests.  One option here might be to install a tub cut, which would likely cost under $1,000 and may bring the needed access.  

Example:
Plush Park is a 300-unit complex with more than $500,000 in Reserves.  It just completed grant work to install a new roof, new boilers, and new windows.  The parking lot is in great shape, and they weathered the last winter with very little concrete damage.  They have been doing cycle painting and replacement of carpeting, budgeting for some each year.  This seems to be working well.  There are no major capital projects planned at present.  

A resident puts in a request that her carpeting be removed and replaced with something that will not aggravate her breathing issues.  She asks for Italian marble flooring.  The site confirms with the verifier that Italian marble is not necessary; the resident's physician states that anything other than carpet is OK.

Estimates for the carpet removal and replacement with vinyl come in at about $3,500.  This facility will not be able to justify this as an undue burden, but will be able to deny the Italian marble.  They will advise the resident that they can offer replacement of the carpet with vinyl sheeting, their standard option, instead.  

The analysis of financial and administrative burden is something that will be normally be done with your RM and the ADPM.  When submitting a request that you feel is an undue burden, be sure to include sufficient information in your email to explain why you believe that.  This will facilitate review of the request.  


Document, Document, Document:
Remember, if it's not in writing, you're going to have a hard time proving it.  Make sure you document relevant conversations, emails, notes, etc.  Be sure to note date, time, name of any individual you spoke with, etc.  

Also remember there are some things that should not be put in a written record.  You are entitled to your personal viewpoints and feelings, but they don't belong in factual documentation.  For instance, a resident's remark that she believes her neighbor doesn't have a disability because she sees her walk to the garbage room isn't documentation of the lack of a disability.  It may be the basis for a conversation with the commenter, though! 

If you're unsure about whether something should be part of the official file, ask.  


It's Not Personal:
Dealing with Reasonable Accommodations can be challenging, to be sure.  This is especially true when it's that resident - the one who is often difficult, rarely seems to be satisfied, and takes a lot of time to deal with.  The bottom line, though, is that it's not personal.  Reasonable Accommodations are required of us.  If you're in federally-funded housing, they are required to be done at the property's expense, and can only be refused under certain circumstances.  

Do people take advantage of that?  Yes.  But the vast majority of people who ask for accommodations and modifications need them due to disabilities or medical conditions that result in a need.  Your responsibility is to verify as required, and consult with your Regional Manager, the Assistant Director of Property Management and/or other staff as appropriate.


A Final Note:
Elderly Housing Management takes Fair Housing seriously.  We actively work to ensure compliance, and Reasonable Accommodations and Modifications are part of that.  It's important to not only understand your requirements, but also to ask for help when it is needed.  Don't hesitate to contact your Regional Manager, the Assistant Director of Property Management, or the Director of Property Management when you need assistance.  We're all working towards the same goal, and it's always better to prevent a problem than respond to one.  

Pot, Providers, Pests, and a Picnic!

Thought I'd provide a brief recap of Tuesday's Regional Meeting...

Medical Marijuana:

Although medical marijuana is now legal in Connecticut, it is important for providers of federally-funded housing to remember that it is still considered illegal by the federal government.  

Refer to this blog's June 2nd post regarding guidance on medical marijuana.  ALL concerns regarding applicant / resident use of medical marijuana MUST be brought to the attention of the RM, ADPM and/or DPM.

The powerpoint from Tuesday's training is available for download here.

Provider Services:

Charlie Barratt (Resident Services Coordinator for Orford Village) gave us an overview of services available for low-income residents.  He had good news regarding Social Services; while they've had their share of challenges lately, the situation has improved.  

As always, the goal of working with community providers is to keep residents happy, healthy, and safe in their homes for as long as possible.  To that end, it is important that Administrators and RSCs work as a team.

Pests:

Waltham Pest Services provided information on bedbug control.  It is important to remember that bedbugs are secretive insects; they will hide in numerous spaces such as seams in furniture, behind electrical outlets, in screw holes, and in the folds and seams of clothing, upholstery, or luggage.  

It is essential that residents are aware of, and comply with, treatment requirements such as bagging items  and leaving them sealed until all treatments have been completed.  Other steps may include disposing of items that cannot be treated, and laundering clothing appropriately.

It is essential that Residents and Management follow EHM's pest prevention policy.  It is always better to be proactive to the maximum extent possible when dealing with bedbugs.

One suggestion Waltham provided was to ensure that when having furniture delivered, always ask to be the first delivery of the day, in order to avoid having new furniture contaminated by other furniture picked up for disposal during stops.  

Picnic!

Lunch was a "pot luck" which featured hot dogs, hamburgers, and an absolutely stunning collection of various salads, side dishes, and desserts.  Yum!  Due to the rain, we were relegated to inside, but that d

idn't do much to dampen the picnic spirit.  Thanks to all who shared your culinary talents!

Thanks to the staff at Woods Edge / Oak View for hosting our Regional Meeting, and for all the work that goes with setup, cleanup, and cooking!  

Medical Marijuana

A short time ago, we encountered our first resident with a prescription for medical marijuana. It won't be the last time. Medical marijuana is here, and is legal in both CT and MA. There is a fairly complicated online registration process for both. Conditions that may result in a prescription for medical marijuana include: 

• Cancer 
• Glaucoma
• Positive status for Human Immunodeficiency Virus (HIV) 
• Acquired Immune Deficiency Syndrome (AIDS) 
• Hepatitis C 
• Amyotrophic Lateral Sclerosis (ALS) – also known as Lou Gehrig’s disease 
• Crohn’s Disease 
• Parkinson’s Disease 
• Multiple Sclerosis (MS) 

Medical marijuana may also be prescribed for other conditions as determined in writing by a qualifying patient’s physician. 

It is very important for Administrators to understand the distinction between state and federal law. While state law permits use of medical marijuana, federal law considers any use of marijuana to be a crime - whether or not it is prescribed. 

Applicants in federally funded housing (including LIHTC sites) who are discovered to use medical marijuana MUST BE REJECTED, without exception. 

When a resident in federally funded housing is found to be using medical marijuana, the facility has the discretion as to whether or not eviction is appropriate. Several factors will be considered in this instance, including the level of disturbance to neighbors, and whether or not the resident can use it in a non-smoked form. Medical marijuana is never permitted as a deductible medical expense in federally funded housing. 

For state funded facilities, legal use of medical marijuana is just that - legal. 

Smoking of any substance in a non-smoking facility is an issue. 

Further information on this topic will be provided at the upcoming Regional Meeting. 

If you receive information that indicates an applicant or resident in federally funded housing is using medical marijuana, please consult with your Regional Manager and/or the Assistant Director or Director of Property Management immediately. 

Helpful Links:
HUD Medical Marijuana Memo (2014)
CT Medical Marijuana Information
MA Medical Marijuana Information