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.

---

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

---

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.

Happy New Year!

The New Year is a time for looking ahead, setting goals, and making changes.  That's
true for properties as well as individuals.  Many sites are beginning a new financial year,
so it's an appropriate time to perform a few office tasks.

While you're looking forward to all that 2013 has to bring, why not:

-          Archive old documents (old financial statements, board reports, bills,
           budgets, HAPs, files)

           Remember, you must keep a paper copy of your HAP for at least five years.
           This does not mean it has to be in your active file - you can box old items up
           and store them.  You simply must be able to access them if needed.

           It is also suggested that you keep the previous year's financial statements and
           bills handy in case you need to refer to them.  Older items can be shredded.

           Inactive tenant / applicant files must be kept for the duration of tenancy / time
           on the wait list, plus three years.  Once you have passed the three year mark,
           wait for your next review (MOR or USDA Supervisory Visit) to be closed out.
           After that, speak to your Regional Manager for clearance to destroy the file.  You
           must keep records of all files destroyed (the form will be posted on the blog in the
           Forms / Procedures section).

-          Service equipment
           Don't wait until the grass is in need of mowing to find out your equipment needs
           servicing.  Scheduling yearly servicing during the off-season may avoid
           unnecessary wait times.

-          Take Continuing Education Courses:
           For some, the winter months are slower.  If you have a Real Estate License, you
           must take continuing education courses to keep it active.   A number of
           companies offer online Real Estate Continuing Education courses.  It's a great
           activity for slower office days, or snow days.

-          Review your 504 Plan / CNA
           Remember, these documents aren't just for taking up space.  Look for small
           items that can be done easily and at low cost now; larger items will be
           handled as your budget / reserves dictate.

-          Set the Tone for the Year
           Have a staff meeting and lay out the goals and priorities for the next year.  Would
           you like to improve turnover time?  Service Call response time?  Are there issues
           with guests overstaying their welcome?  Remember, the site staff is a team.
           Ensuring that everyone is on the same page, and clarifying everyone's roles is a
           great way to start the new year.

           In addition, it's a good idea to start looking at when your staff is planning time off.
           While everyone may not have specific dates in mind, beginning a preliminary
           discussion of plans for time off can help avoid hurt feelings and other issues later
           on.  If there is a conflict, it may be much easier for dates to be changed well in
           advance, rather than right before a planned vacation.

What other suggestions do you have for how to start the year at your property?

Click the "Comments" link below, and chime in!

EHM remembers the families in Newtown whose lives were forever changed one week ago today.  We join with our neighbors throughout our State and our Nation today in a moment of silence to remember those lost.

It's Beginning to Look A Lot Like...

We're getting in the holiday spirit here at EHM...

Linda, Tammy and Lee putting together some gift bags for the Home Office crew.

What events do you does your community have for the holidays?

Have some great decorations you'd like to share a picture of?

Have a Resident whose door is particularly festive?

What holidays do your Residents celebrate? 

Rules of the Road - Reasonable Accommodations

Reasonable Accommodations and Modifications are one of the numerous challenging areas of our daily business.  Recently, some items have caught my attention, so I wanted to clarify some of the aspects of dealing with these requests.  

Documenting

Be sure to track Reasonable Accommodations using the log form (Procedure 3-25 on the Forms and Procedures page of this blog)

I was recently told by USDA/RD that they want Reasonable Accommodations kept in a separate file, all on their own.  SO, from this point onward, rather than keeping the Reasonable Accommodations in the “Personal” file, keep all accommodations in one separate file. Keep the log in that file as well.  A binder is acceptable, and may be more workable for you.

Be sure to keep my approval email in the file.  You will want to sign a Reasonable Accommodation Agreement for anything that has limiting conditions - modifications to policies, etc.  Grab bars do not require an agreement.

Parking

Remember that assigned parking spaces are, for the most part, easily granted and do not pose a burden. The exception is when people are requesting that we make a new handicap space, or are asking that we assign them one of the already labeled handicap spaces. Some things to keep in mind:

The mandated handicapped spaces MUST be available on a first-come, first-served basis to anyone with a permit – at all times.  We cannot in any way, or at any time, restrict their use.  Even if someone is assigned a space, if they have a handicapped permit, they can park in a handicapped space (in some cases, the reserved space may be further away from the handicap space).  If there is a specific concern, please bring it to my attention.

Response Requirements

We should have an initial response back to the resident within 10 days of receiving all needed documentation.  Sometimes, that response may be “We are researching…and expect to get back to you by…” but they must get a response.  If verification has not been received in two weeks, you should follow up as you would for any missing verification - and should advise the Resident that we have not received verification yet.  Feel free to nag me if you need to.  I am now tracking response times – I am using Outlook to monitor my own responses, and suggest that you utilize this resource for yourself.

I should receive a copy of all Reasonable Accommodation requests – grab bars,  parking, transfers – everything.  Some of you may install grab bars upon any request, without going through the RA process, and that’s fine, as long as you follow the same rule for everyone.  But anything that constitutes a Reasonable Accommodation should be copied to me.

Verification

RSCs can serve as verifiers – they have received direction from Lee as to what items and under what circumstances they can and cannot “sign off” on a request.  I trust their judgment on whether they feel they can do so.  If you have concerns, bring them to my attention, and I will discuss those with Lee.

Remember, with “obvious or known” disabilities, and/or “obvious or known” relationships between the item requested and a known disability, there may be no need for third-party documentation.  When in doubt, check with me before sending out a third-party verification. 

Undue Burden

The decision on whether something is an undue burden, or must be put off pending additional funds, must be reached in consultation with me.  There may indeed be times we decline to do an accommodation or modification due to substantial cost and low resources, but there is a process to be followed in such cases. 

Additional Note:

Please understand that my involvement is not meant to imply that I don’t trust our staff.  I do.  You are competent professionals and do your jobs with great care.  My involvement is to ensure that we comply with the rules – and to ensure that you all have the resources that you need.  In short, (and to adapt the "Scrubbing Bubbles" slogan) I worry about this stuff so you don’t have to.  When in doubt, I am only a phone call or email away.

Here We Go Again...

Looks like we've got a Nor'easter headed at us for mid-week.  Reports vary from rain, to snow, to rain-sleet-snow.  Two things everyone agrees on - it's going to be wet, and it's going to be windy.

This soon after another major storm, lots of wet and lots of wind can make this one even more dangerous than the last.  Saturated ground and weakened trees and branches can result in even more trees down than in the hurricane.  Make sure your site is prepared, and encourage your Residents to make preparations too.

The Red Cross has some great resources for storm preparation; you may want to post these at your site, or distribute them to your Residents:

Preparing for Power Outages

Pet Safety in Disasters

Food and Water in an Emergency

Central Voice Answering Service Down

Central Voice, which provides the answering service for most EHM / CHM sites, is based out of New Jersey.  Like a large part of New Jersey, that means that they are not operational at this time.

This means that if your site uses Central Voice, you do not have an answering service until further notice.  Please notify residents that the service is down until they are notified otherwise, and make sure that they have contact information that includes:

• Appropriate Site Staff (Superintendent / Maintenance staff / Administrator)
• Regional Manager 
• Assistant Director of Property Management (Pam)
• Director of Property Management (Tammy)

Please also advise them that those numbers should be reached in case of a building issue - for medical emergencies, the first call should always be to 911.  A courtesy call can be made to appropriate site staff if that is possible - but only after the medical emergency has been taken care of.