HUD Annuals and Interims During Social Distancing

There have been a lot of questions on how to complete a certification while practicing Social Distancing.

You may need to employ some creativity to get these done on time.  We're obligated to comply with the rules, but we also may need to think a little outside the box on how we accomplish this.  

Some ideas are:

• Complete interviews over the phone
• Mail verifications to applicants / deliver packets to resident apartments
• Use a highlighter to indicate signature lines.
• Use a cover letter to advise residents of what they need to do
• Call to follow up after they have received the packet so you can assist / answer questions
• If they do not have statements, and you cannot reach a third party, have the resident sign something indicating amount for income / asset / expense.  Make sure the statement addresses everything you need (i.e., balance / interest rate).  Make a note to the file as to why other documentation was not available

As with everything else we're doing lately, remember to be patient.  We're all a little on edge about COVID-19, and no one more than those most at risk, which includes most of our residents.  

If you need to do anything outside of the norm, please discuss it with me so that we can strategize.  I've created a form for use with residents who are unemployed due to COVID-19; be sure to use that for any residents in that situation.  Make sure that if you have to do anything other than the standard procedure, there is a note to the file as to what you did and why.  

Example:
Mary has a recertification, but do to her bank's closure, she is unable to get 6 months' worth of bank statements for her checking account.  We have tried, but cannot reach the bank.  She only has two statements at home.  Take those two, average the balance, and if Mary agrees that those reflect her understanding of her average balance, have her sign on those that she certifies that this reflects her average 6-month balance to the best of her knowledge.  

Key to this is tprocess is that once the bank has reopened, you should follow up to make sure the balance is not sufficiently different to change her rent.  You can use this sheet to document any recertifications that may need follow-up.  Please note that this is also a useful tool if you have multiple staff working on recertifications.  Keep the log in a central place so that everyone can access it.  

If a tenant is unable / unwilling to sign due to social distancing, you may check the "tenant unable to sign" box.  You may select one of the following codes:  
1. Medical (if the resident has been ordered to quarantine)
2. Late due to accommodation / other 
3. Code 10 (Other) 

Again, once the social distancing protocol is over,  you will need to get signature and submit a corrected cert as applicable. 

Interim Recertifications
If income has been drastically reduced, perform an Interim.  Follow the usual rules for what to verify, and the above notes for how to verify and signatures.  

If you have trouble obtaining verification, please email me so that we can determine the best course of action.  

TRACS Help Desk:
TRACS users will still be able to reach the Help Desk Monday - Friday, 7am - 8pm.  You can also leave a message on voice mail for a call back.

COVID-19 Information

There is a lot of misinformation and fear-mongering out there related to COVID-19 (Coronavirus).  Lately, it's been hard to differentiate fact from fiction, and people are understandably worried.  

Our staff have received numerous inquiries as to what EHM and our sites are doing to prepare for Coronavirus.  

At this point, there have been no specific guidelines issued to our senior living communities regarding necessary precautions.  EHM has provided sites with information on how to prevent the spread of COVID-19, and we've asked that the information be posted in prominent common areas.  

Residents should consult with their healthcare provider to determine what steps they should take to protect against exposure to the virus.

EHM's Director of HR, Sally Norton, will issue guidance as appropriate should our employees need to take any special measures.  

Our sites will of course follow any state mandates or directives issued by the CDC or local health departments.  

If you find out that one of your residents has been exposed to COVID-19, please inform your Regional Manager immediately, so that we can determine how best to respond.

Please ensure that your communication with your residents is measured, fact-based, and reassuring.  We do not want to worry them unnecessarily.  

For further information:
https://portal.ct.gov/Coronavirus
https://www.mass.gov/resource/information-on-the-outbreak-of-coronavirus-disease-2019-covid-19
https://www.hud.gov/coronavirus
https://www.cdc.gov/coronavirus/2019-ncov/community/home/index.html
https://www.who.int/emergencies/diseases/novel-coronavirus-2019

Tuesday Funny

Tuesday Funny

This one was passed along from Heidi at Beckley House / Bonney Brook / Meadowbrook.

;)

Never underestimate the unofficial Neighborhood Watch. 

Tuesday Funny

Too accurate. 

Just a Reminder...

Words to live by in our business 😉

Critical Documents are Just That - Critical!

You all should have a binder on site that holds copies of your Critical Documents - things like:

Subsidy Contract
Affirmative Fair Housing Marketing Plan
Contractor List
Board list
Resident Selection Plan
Staff contact information
Computer information - passwords, etc.
Instructions for any essential equipment - resetting fire panels, door codes, fob programming instructions, etc.

There are others, but you get the idea.  Far from being just a handy book to blow the dust off of and use once in a while, this binder contains information you need to be familiar with.

Some of our sites (Twin Haven, Butter Brook, Templeton Farm, and Lymewood among them) have partial subsidy for the property.  That means that subsidy gets assigned to different tenants when it is freed up.  Subsidy is sometimes just a total number, and you can move it around to any unit.  Sometimes it's restricted by unit size or type.  If you don't know exactly what your contract says, you can make a very costly mistake.  Here's how it can happen:

Let's say Greenville Estates has 40 units, with only 20 subsidies.  Those subsidies can move around to any apartment, BUT in the contract there is a restriction of 18 one-bedroom and 2 two-bedroom allotments.  Let's say I have one of my one-bedroom subsidies open up.  OneSite's settings simply tell me I have 20 total subsidies.  So I assign that one-bedroom subsidy to a two-bedroom unit.  I'm still using 20, so all good, right?  

Nope - my contract says it has to be 18 and 2.  Now it's 17 and 3.  OneSite will let me adjust those numbers - it does so in case contracts change.  BUT when I send my HAP in, my Contract Administrator will disallow that two-bedroom unit.  I can only use two of those.  Now I have to go back and tell that two-bedroom tenant that they can't have the subsidy after all. And since the HAP already went in, odds are the site is out some money.

It's an error that can be avoided by knowing your contract.  Information like this is in your HAP Contract, and typically in your Resident Selection Plan as well.  Read them, and know them - or keep them handy to refer to when situations like this come up.

Likewise, knowing your Affirmative Fair Housing Marketing Plan can avoid errors that can cost you at MOR time.  You must send out community agency letters and place advertising every year.  Your AFHMP tells you the sources for these outreach efforts. Failure to comply can cost you at MOR time.  Make sure that you know your AFHMP.

Remember, working in regulated housing means there's a rule for just about everything.  Know your rules, and avoid a lot of headaches.  Direct questions to your Regional Manager or the appropriate staff when needed.  We all want to do our job well, and we all want to do things the way the regulatory body wants us done.  Knowledge is key.

USDA/RD Income Limits are (Finally) Out

Issued through a procedural notice, these limits are not yet showing in MINC.

The effective date is 7/22/2019, and you can find/download/print them here. 

For those of you using OneSite, you will need to enter them into the software, as follows:

1.  After logging into your property, click the little wheel in the top right corner of your screen
2.  Under the “General property” heading on the left-hand sidebar, click “Affordable”
3. Click “Income Limits” (third item down) in the central “General-Property” menu
4. In the window that opens, click “Edit” next to the RHS income limits
5. In the top right of the window, enter the effective date (7/22/2019)
6. Just above the first blue bar, you will see a box with the instructions “Enter the 50% very low income limits amount for the area.  To enter all income limit amounts, click here to make the table fully editable.  Check the box.
7.  Enter the Very Low, Low, Moderate, and 100% Median income limits
8.  Save and exit.

Once these are entered, please review any applications that were rejected as over-income between 7/22/2019 and now.  If they qualify under the new income limits, please contact the applicants, and advise that the new income limits were just issued and they qualify.  If they wish to be on the wait list, please put them on the wait list as of their application date.  Any applications received prior to 7/22/2019 that were rejected for income do not need to be adjusted.  

Any questions, please let me know.

Theyyyyyyyyre Heeeeeerrrrrre...

Hot off the presses, the HUD income limits are out today.  USDA has not yet updated them in MINC.

HUD’s are here:

https://www.huduser.gov/portal/datasets/il/il2019/select_Geography.odn

To update the income limits in OneSite:

1.    Go to the top left of your screen and click on the three horizontal lines there.

2.    Click on Administration

3.    Click on “Settings” under “Affordable”

4.    Click on “Income Limits” to the right of that menu

5.    A window will pop up displaying the current listing of income limits for your property.  

6.    Click on “Edit”

7.    Enter the effective date (4/24/2019)

8.    Just above the top blue bar, you will see a box to check to make the table fully editable.         YOU MUST CHECK THIS BOX.

9.    Enter income limits all the way across for the categories you need (ex. 80%, 50%,      

       30%.  You can make the unneeded ones zero. 

10.  Click “Save” in the bottom right corner of the window. 

That’s it – you’re done.  These should be completed no later than close of business Friday so that you minimize the amount of corrections you’ll have to make.

NOTE:  You will need to correct any recertifications 5/01 or later, as they will have incorrect income limits on them. 

Any questions, please let me know!

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.  



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