Updates

I've updated a couple of things that you need to be aware of.

First, I've updated the Emergency Management procedure to include information on what to do when someone asks for a "Wellness check" of a resident.

Per our DRS, Christine McPherson, a "Wellness Check" is not a term that is used in our industry, as it implies a level of health assessment that our staff doesn't do.  If someone is asking you to assess the health or safety status of a resident, this is something that should be directed toward Emergency Services.  If they just want to confirm that someone is home, that's a different matter.  Please be sure to thoroughly read the procedure, and contact your Regional Manager, the DRS, or me for any questions.

I've also updated the Verification of Assets form for all regulatory bodies.  Often, we send a verification form to a bank thinking we're getting information on checking and savings accounts, etc., only to have them put in an IRA.  When they do that, we're not getting the information on RMDs that we need.  

If you have a resident with a known IRA, use the "IRA verification form" for that.  However, in the event that they have an IRA that will end up verified as part of their assets at a bank, the form now includes a space for IRAs / Annuities.  

REMEMBER, you should first be asking for documents to be submitted by the tenant / applicant.  Only if those are insufficient will you be sending out a third-party verification.

EIV Update - Income Discrepancy Report

The December 10, 2018  HUDBLAST has an interesting update to EIV Requirements...

Up until now, we've been printing the Income Discrepancy Report (found on the left-hand side of the main EIV page) and putting it in the Master file monthly.  Then, we've been printing out the individual report (one of the four-tabs accessed by clicking on "Income Reports" to document any resolution.

Now, that master Income Discrepancy Report (the one that wouldn't print on one page unless you resized the columns in Excel) is gone. 

You no longer have to print Income Discrepancy Reports monthly.  You DO have to:

1. Review the Income Discrepancy Report as part of the report you print 90 days after submission of a MI to TRACS.
2. Review the Income Discrepancy Report when you print the report for any Annual or Interim recertification.
3. Document resolution of any discrepancy in the tenant file.

That's it.

Don't you love it when HUD actually makes life easier?

Happy Thanksgiving Day!

Wishing all of you and yours a very happy Thanksgiving holiday.

I am grateful every day to work with such a dedicated and talented group of people.

EIV Income Discrepancy Report - A Better Way

I think we can all agree that the EIV Income Discrepancy Report is not very user-friendly. It's done in Excel, which isn't in and of itself a bad thing. What makes it so hard to work with is that the formatting is awful. The columns are so wide that the report doesn't fit on one page, and there are no cell borders. Fitting it on one page required resizing the columns, setting the formatting so that it wraps within the cells...it's time-consuming. 

 Fortunately, there is a much easier way to print the same information, and here it is: 

1.     Go to the HUD Secure Systems Login page at:        
        https://hudapps.hud.gov/HUD_Systems/ 

2     Jump through the usual hoops to log into EIV 

3.     In EIV, locate the "Income Information" heading, and select either Contract 
        or Project Number, and enter the appropriate number for your site.  Select "All" 
        months, and click "Go."

4.     Scroll down the page until you can see the listing of reports available.  
        Click on "Income Discrepancy Report."

5.     Print the page that pops up.  You can also print the Detail Reports from 
        this page by clicking on that tab.  These are the reports that you need for 
        documenting resolution.  

That's it - a simple, painless way to print Income Discrepancy Reports.

Please let me know if you have questions.  



Did you find this tip helpful?  Let us know in the comments!

Let's Try This Again - New Poll!

I am still on my quest to find a good, free poll maker. Please let me know if you have trouble voting, or can't see results.

What are you doing for Halloween?

Going broke distributing candy

Taking the kids / grandkids / nieces and nephews trick-or-treating

Volunteering / working at a community event

Avoiding the whole mess

Other

Created with QuizMaker

Test Poll

Testing out a new poll widget - please respond so I can see if this works!

Just for Fun!

New month, new poll! 

What I want to know after last month's poll is which of you are the two who have superpowers, and what they are!
Create your own user feedback survey

Just for Fun...

Sadly, Blogger has gotten rid of its poll widget.  

The good news is, I can create them in posts - and here's the latest, just for fun.

Which Superpower Would You Like to Have?

Mindreading

Invisibility

Flying

Time Travel

Teleportation

I already have a superpower!

Created with QuizMaker

USDA Releases FY 2018 Income Limits

USDA's 2018 Income Limits are out.

To get to them, log into MINC.

On the left side of the screen, click on Income Limits, and then click on your state, etc.

To update income limits in OneSite:

1.      Log in
2.      Click on the three bars in the top left corner
3.      Click on Administration
4.      In the menu on the left hand side, click "Settings" under "Affordable"
5.      Click "Income Limits"
6.      In the window that opens, click "Edit" next to the RHS income limits
7.      In the next window, enter the effective date (6/13/2018) in the upper right corner,                 then click the box below to make the table fully editable.
8.      Enter all numbers that you need based on apartment size and applicable income                 limits.  
9.      Click "Save" in the bottom right corner to save the limits.

Please be sure to do these no later than Friday, June 29th.

Geer Needs Our Help - UPDATED!

UPDATE:

On 4/24/2018, the Town of Canaan approved Geer's appeal.  This means that Beckley House, Beckley Expansion, the Skilled Nursing Facility, and the Assisted Living Facility will all remain tax exempt.  

Thank you all for adding your names to the petition in support of Geer's appeal.

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

As you are no doubt aware, Connecticut is in a financial crisis.  Unfortunately, the state's budget woes have had significant impact on the towns and cities as well.  One of the consequences of the state's significant deficit and the resulting loss of funds to municipalities is the loss of tax abatement for many of the towns in which our facilities are located.  

Recently, Geer Village was informed that the town is no longer going to recognize its not-for-profit status: 

Without warning or reason, the North Canaan Assessor’s Office is refusing to recognize Geer’s lawful tax-exempt status, which the Town appropriately recognized for the past 80 years. As a result, Geer could be facing an increase of over $500,000 per year in taxes. This is in addition to the $33,000 in taxes per year that we already pay to the Town for some taxable property, unrelated to our tax-exempt status.

 As you can imagine, the huge increase in taxes will have a dramatic impact on the services Geer can provide.  In addition to their ownership of Beckley House and Beckley Expansion (HUD 202 PRAC facilities managed by EHM) Geer also operates a skilled nursing facility, a memory care facility, adult daycare, an assisted living facility, and a 55-and-over residential facility.  Geer provides funding for the Dial-a-Ride facility in the area.  Geer is also a significant employer for the local area.  All of these vital elements will be negatively impacted.  

It is imperative that vital services continue for our vulnerable senior population.  Geer has asked for help in ensuring that the Town continues to treat Geer appropriately based on its not-for-profit status.  

If you would like to help, or to learn more, please click this link, and sign the petition if you are so moved.

Thank you.

Reasonable Accommodation Review

This week, I had the pleasure of providing a Fair Housing update for the Resident Services Coordinators.  One of the topics we covered was Reasonable Accommodations, so I thought it was a good time to review certain elements of the process with the property management staff as well...

Completing Requests
When you are completing a request form, please be sure to clearly note what is being requested:

"...resident has difficulty using her stove..."    NO
"...resident requests an an oven with knobs in the front ..."  YES

Who can / should be handling requests?
Administrators, Assistant Administrators, and Resident Services Coordinators can handle requests.  Superintendents / Maintenance staff who become aware that a resident has a need for an accommodation or modification should advise the Administrator within 24 hours.  

Although RSCs should be aware of all RAs at a property, they should not be the only ones taking requests.  This can result in undue delays in processing.  If a Resident is speaking with the Administrator / Assistant Administrator and makes a request, or implies that a change is needed, that staff person should immediately discuss the RA process with the Resident, and complete the request.  A copy of the request and the verification to be sent can then be made and provided to the RSC afterwards for any needed follow-up, with the referral or New Move-in Notification Form.  

Known and Obvious:
When the disability and the need are "known and obvious," there is no third-party verification required.  Known and Obvious generally indicates a visible disability, but can also indicate a disability that you become aware of through contact with the resident.  When in doubt, discuss the situation with the ADPM to determine what needs to be verified.  Some examples of known / obvious disabilities:  blindness / visual impairment, deafness / hearing impairment, use of a wheelchair / walker.

Even if you feel that you have a situation where this applies, you must still fill out a request form, and the known/obvious form, and send to the ADPM for approval.  This ensures that we are consistent, and that all requests are documented.  It also allows for a review to ensure that third-party verification is not required.  

Reviewing Verifications
Before forwarding, be sure to review the verification to determine whether all necessary information has been received.  Some items to examine:

• Did the verifier answer the question of whether the individual has a disability?
• Did the verifier answer the question of whether the individual needs what they are asking for?
• If they've asked for a parking space, did the verifier note the distance requirement?
• If a live-in aide or assistive animal, did the verifier answer the question of whether this particular individual / animal can provide the needed service(s)?
• If asking for an apartment with "more light," did the verifier provide specific information on what is needed?

If these key elements are not provided, you should follow up with the verifier before forwarding to the ADPM (Pam)  for approval.  If you are having trouble getting a clear answer from the verifier, forward the request to the ADPM for assistance.  

If you're unsure as to whether a determination can be made, go ahead and forward it to the ADPM.  However, if you identify key elements that are missing, please follow-up before you forward the request.  Doing so can avoid unnecessary delays.

"Unreasonable," "Undue Burden" and "Fundamental Alteration"
Although HUD permits us to deny requests that are unreasonable, that term doesn't always mean what you think it does:

Unreasonable:  something that is impossible to do because it compromises the financial health of the building, would jeopardize necessary capital projects, represent a change to the program offered, place the property in violation of the law or regulatory requirements, or make demands on staff that would make it impossible for them to perform their job.  

Undue Financial and Administrative Burden:  something that is impossible to do because the site does not have the funds (Operating / Reserves / Residual Receipts), there is no grant funding available, and there are no staff to research funds.  Or, something that would make such a demand on staff that we would have to hire additional staff to accomplish it. Example:  Site generally needs a buffer of $100,000 in reserves.  It currently has $125,000 in reserves with $50,000 coming out in the next year for capital projects that cannot be delayed.  $25,000 will be added to Reserves in the next year.  Resident requests an item that costs $43,000, and there is no grant funding that exists for the item.

Fundamental Alteration to the Nature of the Program:  something that is impossible to do because it would alter necessary rules or programmatic guidelines.  Examples:  waiving a no-smoking policy, waiving an income limit, admitting someone who does not meet eligibility criteria.

The determination on whether something is a burden will come from the ADPM.  If you believe something is a burden, be sure to include that information with your request so that she can work with you to make a determination.  

No, but...
A flat denial of a request will generally only come if the verifier states that an individual is not disabled, or does not need what they're asking for.  In almost all other cases, the denial will take a form that more resembles "We can't do what you're asking, but we could do..."
This means that the ADPM will send a letter that advises that the requested item is impossible, and offers alternatives or the opportunity to meet to discuss what alternatives may exist.  

Follow the Process:
Under no circumstances should a resident be told that something cannot be done before going through the process.  Even if you believe that something may be unreasonable, the process must be followed in order to document that we followed guidelines.  If you have questions, check with your RM or the ADPM.

Make Sure Residents / Applicants Understand the Process:
It's important to be sure that your residents and applicants are aware of the process and have been given information on how to make a request.  

Make sure that the RA/RM Notice is posted on the bulletin board, and given out:

• With applications
• At Initial Interview
• At Move-In
• At Annual Recertification

It's important that you review what's in the notice, especially when dealing with an applicant or a new Move-in.  Many applicants / new Residents are not familiar with Reasonable Accommodation requirements, so may not understand it clearly by just reading the notice.  They receive a lot of paperwork when they interview / move in, so it is helpful to point out important elements of life in assisted housing.

And finally...

Don't Sweat the Small Stuff:
It's really easy to get frustrated when you encounter individuals that appear to be taking advantage of the system, or residents that are challenging to deal with.  But it's important to remember that this isn't personal.  The ADA and Section 504 of the Rehabilitation Act require that we make Reasonable Accommodations.  Yes, there are individuals who take advantage of the system.  In general, people who make requests make them because they are dealing with significant challenges, and the changes we make allow them an equal opportunity to enjoy the property.  Small changes can sometimes have a huge positive impact on the lives of people living with disabilities.  

MOR Odds and Ends

Happy Friday!  Just wanted to refresh your memory on a few things that can make a difference in your MOR score.

APPLICATIONS

For those of you in HUD sites, it is imperative that you include the HUD 92006 form (that lists a contact person) and the Preliminary Screening Questionnaire in your application packet.  Both of those forms must come back; if they don't, you will need to follow up with the applicant.  If those items are missing, it will lead to a finding at your MOR.

HUD Application Packets should include:

• Cover letter
• Application form
• Facility Description / brochure / fact sheet (as applicable)
• 92006
• Preliminary Screening Questionnaire
• HUD "Fraud: Is it Worth It" handout
• HUD How Your Rent is Determined handout
• Applicant Release to 3rd party (must only be returned if the applicant wishes)
• Family Summary Sheet
• Notice RE:  Mandatory Meals (if applicable)

EIV REPORTS

The following reports must be run monthly and placed in your EIV binder whether or not there are any items noted:

Multiple Subsidy Report

Identity Verification Report

Deceased Tenant Report

New Hires Report

Income Discrepancy Report

While we're on the subject of that pesky Income Discrepancy Report, let me express my solidarity with any of you who don't like the formatting, now that it's in Excel.  I have an alternative you may prefer.

1. Print the page that shows that you have discrepancies
2. Print each individual discrepancy report, instead of that summary report, and place in the file.
3. You will then also have to place a copy of that individual discrepancy report in the tenant file (on top of the most recent RMF), with your resolution efforts.

Please remember, you should contact me (Pam) any time you see any EIV discrepancy, so that I can assist.  You are required to follow up on discrepancies; failure to do so will result in a MOR finding.

EIV SCREENING:

You are required to utlitize two elements of EIV with a move-in:

1. You must run the EIV Existing Tenant Search for all applicants (I do it at the same time I'm doing the credit / criminal / eviction screening), and place a copy of that report in the file
2. You must run an income report (the same paperwork you run at recertification time) 90 days after a move-in, and place that document on top of the move-in RMF in the tenant file.

Failure to do either of these will result in a MOR finding.

9887 FORMS:

Please ensure that the three address windows are filled out on every single 9887 packet you complete.  

The addresses are as follows:

HUD office:One Corporate Center20 Church Street, 10th FloorHartford, CT 06103-3220

O/A address:This will be the site's address

PHA office:Eric Strong
Navigate Affordable Housing Partners
100 Pearl Street, 14th Floor
Hartford, CT  06103

APARTMENT INSPECTIONS:

Apartments must be inspected at move-in, move-out, and annually.  All inspections must be documented on an inspection form, which must be signed by the tenant and filed.  Move-in / Move-out inspections are to be filed in the tenant file; annual inspections may be filed in a separate file.  If a tenant is unable to sign due to death or MO, this should be noted on the form.  Inspections must also be signed by Management.

SIGNATURES:

Any time there is a space for a signature, there should be one.  This applies to both applicants and Management.  If there is a space for a signature and date, please make sure that both are present.  Failure to sign / date forms can result in a finding.

If you have any questions on HUD guidelines, MORs, or procedures, please do not hesitate to ask your Regional Manager, me, or Tammy.  Getting it right the first time is always easier than fixing something that is incorrect!