Transcript SEMAP - Nan McKay and Associates
Managing SEMAP
Gail Gillispie
December 2008 1
© Copyright 2008 Nan McKay & Associates Steps to Success 1.
Establish desired outcomes What will be quality controlled?
What outcomes are acceptable?
Goals must be: Attainable
Measurable Clearly defined December 2008 2
© Copyright 2008 Nan McKay & Associates Steps to Success 2.
Educate all staff on how their daily work impacts the PHA SEMAP score
Hold a series of workshops to discuss and train: SEMAP indictors SEMAP requirements Related policies Application of requirements December 2008 3
© Copyright 2008 Nan McKay & Associates Educate
Workshop discussion example:
Determination of adjusted income requires staff to follow verification requirements
Discuss
Regulatory requirement
PHA verification policies
How staff applies these policies daily
How staff documents verification attempts December 2008 4
© Copyright 2008 Nan McKay & Associates Educate
Hold the workshops ongoing – and don’t be afraid to repeat a topic
Provides emphasis, additional clarity, and clears misunderstandings December 2008 5
© Copyright 2008 Nan McKay & Associates Steps to Success 3.
Assign SEMAP QC role to one or more key staff
Large PHA: QC department conducts SEMAP and non-SEMAP QC activities Ongoing file reviews Ongoing financial reviews Ongoing HQS reviews December 2008 6
© Copyright 2008 Nan McKay & Associates Assigning SEMAP QC Role
Midsize PHA: QC supervisor – but fewer support staff
Rely more on supervisor review efforts Small PHA:
Assign to staff supervisors – but avoid assigning indicators for which the supervisor is responsible Work with neighboring PHAs to QC each other December 2008 7
© Copyright 2008 Nan McKay & Associates Steps to Success 4.
Establish a review schedule for each indicator: What are the program requirements?
What will be reviewed?
How will it be reviewed?
How often reviewed?
Who will review?
How will results be communicated to staff and management? December 2008 8
© Copyright 2008 Nan McKay & Associates Establish an Indicator Review Schedule
Example:
SEMAP indicator: Lease-up
What are program requirements?
The percent of units leased or the percent of allocated budget authority expended during the PHA fiscal year was 98% or more December 2008 9
© Copyright 2008 Nan McKay & Associates Establish an Indicator Review Schedule
Example:
SEMAP indicator: Lease-up
What will be reviewed?
Internal financial records will be reviewed to determine year-to-date lease up (units and budget authority)
VMS and software lease-up data will be compared December 2008 10
© Copyright 2008 Nan McKay & Associates Establish an Indicator Review Schedule
Example:
SEMAP indicator: Lease-up
How will it be reviewed?
What internal tracking document will be used to capture:
Unit months leased, year-to-date?
Expended budget authority, year-to date?
December 2008 11
© Copyright 2008 Nan McKay & Associates Establish an Indicator Review Schedule
Example:
SEMAP indicator: Lease-up
How often reviewed?
By the 15th of each month: year to date status is to be reviewed through previous month
Who will review?
Name specific staff December 2008 12
© Copyright 2008 Nan McKay & Associates Establish an Indicator Review Schedule
Example:
SEMAP indicator: Lease-up
How will results be communicated to staff and management?
Options:
Paper/electronic reports December 2008 13
© Copyright 2008 Nan McKay & Associates Establish an Indicator Review Schedule
Communicating results:
Make sure all Key Performance Indicators (KPIs) are addressed
Make sure all KPIs are reported on timely, as scheduled December 2008 14
© Copyright 2008 Nan McKay & Associates Steps to Success 5.
Establish a record keeping system Where will records be maintained? How will records be maintained? December 2008 15
© Copyright 2008 Nan McKay & Associates Establish Record Keeping System
One approach:
Make up 15 (plus bonus if applicable) file folders
1 general file folder
Random methodology
1 file folder for each indicator
Remember, you want PROOF December 2008 16
© Copyright 2008 Nan McKay & Associates Internal Audit Files
Description of indicator and performance standard Place data from audit for each indicator reviewed Any other “proof” of certification score Use auditor minimum file sample and increase sample if needed December 2008 17
© Copyright 2008 Nan McKay & Associates Steps to Success 6.
Conduct preliminary and ongoing audits PHA supervisory audits December 2008 18
© Copyright 2008 Nan McKay & Associates Supervisory QC Reviews
Periodic samples of files
Drawn in unbiased manner (leave clear audit trail)
Reviewed by supervisor or other qualified person other than the one who did the work Objective: determine compliance with indicator December 2008 19
© Copyright 2008 Nan McKay & Associates Supervisory Audit Indicators Selection from Waiting List Reasonable Rent Determination of Adjusted Income HQS Quality Control Inspections HQS Enforcement 15 20 20 5 10 December 2008 20
© Copyright 2008 Nan McKay & Associates Size of Universe
Determines file sample size Different for each indicator
e.g., # number of admissions vs. number of families assisted December 2008 21
© Copyright 2008 Nan McKay & Associates Audit Sample Selection
50 or less 51-600
601-2000
Over 2000
5
5 + 1 for each 50 (or part of 50) over 50
16 + 1 for each 100 (or part) over 600
30 + 1 for each 200 (or part) over 2000 December 2008 22
File Sampling © Copyright 2008 Nan McKay & Associates
Determine the universe Determine number of files to be selected for review Determine “nth” file this represents Include all staff in sample FY is period for analysis December 2008 23
© Copyright 2008 Nan McKay & Associates Minimum Files Example
Waiting List Selection:
Based on # of new admissions per FY Example: PHA has admitted 260 families
minimum # of files to audit?
10
# of files which must meet criteria to receive 15 points? Note: 98% 98.8 (10) files 51-600 = 5 + 1 for each 50 (or part of 50) over 50 December 2008 24
© Copyright 2008 Nan McKay & Associates Random Sampling Example
Universe requirement File sample Files to be pulled 260 files 10 files Every 26th file
If all staff are not represented, select closest file below 26th file December 2008 25
© Copyright 2008 Nan McKay & Associates HUD SEMAP Indicators December 2008 26
© Copyright 2008 Nan McKay & Associates 1. Selection from Waiting List (15/0 points)
Universe
Number of families admitted to program during audit period Two separate samples drawn from:
Applicant names that reached the top of the waiting list during the audit period
Families admitted to the program during the audit period December 2008 27
© Copyright 2008 Nan McKay & Associates 1. Selection from Waiting List (Supervisory Audit)
PHAs must have written selection policies in administrative plan At least 98% of families must be selected from the waiting list in accordance with the PHA’s policies
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December 2008 28
© Copyright 2008 Nan McKay & Associates 1. Selection from Waiting List
PHA follows policies in selecting families from waiting list Families met selection criteria that determined their place on waiting list and order of selection December 2008 29
© Copyright 2008 Nan McKay & Associates Most Likely Error Points
Get up to date on preferences in 982.207
Income targeting 982.201(b)(2) Special admissions 982.203
Special program (targeted) admissions 982.204(e) December 2008 30
© Copyright 2008 Nan McKay & Associates Policies for Audit File
Document policy charges during PHA FY
Example: October FY PHA
10/1/XX
3/1/XX
7/1/XX 10/1/XX-2/28/XX 3/1/XX-6/30/XX 7/1/XX-9/30/XX December 2008 31
© Copyright 2008 Nan McKay & Associates 2. Reasonable Rent (20/15/0 points)
Universe
Number of families assisted for PHA FY Sample drawn from
Number of families assisted for PHA FY December 2008 32
© Copyright 2008 Nan McKay & Associates 2. Reasonable Rent (Supervisory Audit)
The PHA must have a reasonable written method to determine
Rent to owner is reasonable based on current rents charged for comparable unassisted units
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December 2008 33
© Copyright 2008 Nan McKay & Associates 2. Reasonable Rent
The method may take into consideration
Location
Amenities
Size
Housing services
Type
Maintenance
Quality
Utilities
Age December 2008 34
© Copyright 2008 Nan McKay & Associates 2. Reasonable Rent
PHA must follow its written method Document determination that the rent to owner is reasonable at required times
Initial leasing of a unit
Any increase in rent to owner
5% decrease in the FMR in effect 60 days before HAPC anniversary date December 2008 35
© Copyright 2008 Nan McKay & Associates 3. Determination of Adjusted Income (20/15/0 points)
Universe
Number of families assisted for PHA FY Sample drawn from
Number of families assisted for PHA FY
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December 2008 36
© Copyright 2008 Nan McKay & Associates 3. Determination of Adjusted Income (Supervisory Audit)
At admission and reexamination, the PHA must properly:
Obtain third-party verification of income or document why impossible to obtain
Use the verified information
Properly attribute allowances for expenses
Use the appropriate utility allowances
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December 2008 37
© Copyright 2008 Nan McKay & Associates Most Likely Error Points
Market/cash value of assets Asset income Training program income EID for persons with disabilities Disability assistance & medical expenses Conflict between utilities in lease and worksheet December 2008 38
© Copyright 2008 Nan McKay & Associates Recommended Levels of Verification
Highest – Up-front income verification (UIV) High – Written 3rd party Medium – Third party oral Medium-low – Document review Low – Tenant declaration December 2008 39
© Copyright 2008 Nan McKay & Associates Use of UIV for Verification
UIV is third-party verification
Most preferred form
Meets regulatory requirements UIV is intended to streamline the verification process
Eliminates the need for written third-party verification in many cases December 2008 40
© Copyright 2008 Nan McKay & Associates NEW! HUD Guidance on EIV
HUD webcasts 1/16/08 and 8/26/08 contained revised guidance on use of EIV
Previous guidance is obsolete and has been removed from EIV website
Both webcasts available at http://www.hud.gov/webcasts/archives/iv.cfm
Training materials available at http://www.hud.gov/offices/pih/programs/ph/ rhiip/training.cfm
December 2008 41
© Copyright 2008 Nan McKay & Associates 4. Utility Allowance Schedule (5/0 points)
PHA has reviewed utility rate data within prior 12 months
PHA has adjusted schedule if 10%+ change in rate since last utility allowance schedule revision
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December 2008 42
© Copyright 2008 Nan McKay & Associates 5. HQS Quality Control Inspections (5/0 points)
Universe
Units under HAPC during last completed FY
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December 2008 43
© Copyright 2008 Nan McKay & Associates 5. HQS Quality Control Inspections (Supervisory Audit)
PHA performs QC inspection of units under contract Sampling drawn from:
Recently completed inspections
Cross section of neighborhoods
Work of cross section of inspectors
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December 2008 44
© Copyright 2008 Nan McKay & Associates 6. HQS Enforcement (10/0 points)
Universe
Number of failed HQS inspections in last FY Sample drawn from
Number of failed HQS inspections in last FY
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December 2008 45
© Copyright 2008 Nan McKay & Associates HQS Enforcement (Supervisory Audit)
All life threatening fails corrected within 24 hours, and 98% of other fails corrected within 30 days or PHA approved extension or PHA took action
Owner fails: abated HAP
Family fails: enforced family obligations December 2008 46
© Copyright 2008 Nan McKay & Associates 7. Expanding Housing Opportunities (5/0 points) A. Written policy to encourage owner participation outside areas of poverty or minority concentration B. Documentation shows PHA followed policy C. PHA has created a briefing packet (e.g. maps, job opportunities, schools and other services in the areas) to encourage voucher holders to seek these opportunities December 2008 47
© Copyright 2008 Nan McKay & Associates Expanding Housing Opportunities D. Information packet has
List of owners willing to lease
Other organizations (housing counseling, advocacy groups, service providers) which assist families in finding units E. Information packet explains portability and provides list of contacts at neighboring PHAs December 2008 48
© Copyright 2008 Nan McKay & Associates Expanding Housing Opportunities F. PHAs have analyzed:
Difficulties of voucher holders finding units in these areas
If so, has analyzed
Whether to seek approval of exception payment standards
Sought approval for exception payment standards if needed December 2008 49
© Copyright 2008 Nan McKay & Associates 8. Payment Standards (5/0 points)
The PHA must adopt payment standards
By unit size
For each FMR area in the PHA jurisdiction
Between 90-110% of the HUD-published FMR
If applicable, for each PHA-designated part of an FMR area
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December 2008 50
© Copyright 2008 Nan McKay & Associates 8. Payment Standards
If any PS schedule contains a PS that is out of range from the appropriate FMR
Field office will assign 0 points for the indicator December 2008 51
© Copyright 2008 Nan McKay & Associates 8. Payment Standards
Example:
FMR for 2 bedroom unit $756
$756 x 1.10 = $831.60 (round down)
$756 x .90 = $680.40 (round up)
To be within range PS can be between:
$681 - $831 December 2008 52
© Copyright 2008 Nan McKay & Associates
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December 2008 HUD Indicators Verified by PIC 53
PIC Reporting © Copyright 2008 Nan McKay & Associates
If a PHA has not reported at least 95% of its program participants to PIC
Any indicator for which HUD verifies performance using PIC data will be rated zero!!
December 2008 54
© Copyright 2008 Nan McKay & Associates PIC Factors
Factors affected by the 95% reporting rate:
Annual reexaminations
Correct tenant rent calculations
Pre-contract HQS inspections
Family self-sufficiency 10 pts 5 pts 5 pts 10 pts
Annual HQS inspections 10 pts Zero pts for each if 95% not achieved December 2008 55
© Copyright 2008 Nan McKay & Associates 9. Annual Reexaminations (10/5/0 points)
PHA must complete a reexamination for each participating family at least every 12 months Remember PIC reporting
End participation (#6) Other change of unit (#7) vs. annual reexam (#2) Annual reexam searching (#9) 56
© Copyright 2008 Nan McKay & Associates 10. Correct Tenant Rent Calculations (5/0 points)
The PHA must correctly calculate family’s share of rent to owner
Inaccurate or missing data from indictor 3 (adjusted income) will affect the accuracy of this indicator
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December 2008 57
© Copyright 2008 Nan McKay & Associates 11. Pre-Contract HQS Inspections (5/0 points)
Newly leased units must pass HQS inspection before HAP contract effective date
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December 2008 58
© Copyright 2008 Nan McKay & Associates 12.Annual HQS Inspections (10/5/0)
The PHA inspects each unit under contract at least annually At least annually means within 12 months from date inspector conducted full HQS inspection
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December 2008 59
© Copyright 2008 Nan McKay & Associates 12. Annual HQS Inspections
HUD-50058 form has an action code to allow reporting of the annual HQS inspection at the time it occurs PIC extract will list % of inspections more than 2 months overdue
The 2 month allowance is to accommodate a possible lag in electronic reporting December 2008 60
© Copyright 2008 Nan McKay & Associates Annual HQS Inspection Only
If a 50058 is submitted within 2 months from annual HQS effective date
Put HQS effective date on line 5i If more than 2 months, annual HQS must have its own 50058 December 2008 61
© Copyright 2008 Nan McKay & Associates 13. Lease-Up (20/15/0 points)
The PHA enters into HAP contracts for the number of units under ACC for at least one year
PHA has leased at least 98% or 95% of the units under ACC, or
PHA has used at least 98% or 95% of its allocated budget authority December 2008 62
14. FSS (10/8/5/3/0) © Copyright 2008 Nan McKay & Associates
Applies only to PHAs required to administer an FSS program PHA checks off on the certification form if the indicator does not apply to them
If checked, HUD field office will verify that the PHA is not required to administer an FSS program
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December 2008 63
© Copyright 2008 Nan McKay & Associates 14a. FSS Enrollment PHA Certifies: A. # of mandatory slots or # slots with HUD-approved exception B. # of FSS families currently enrolled December 2008 64
© Copyright 2008 Nan McKay & Associates 14a. FSS Enrollment PHA Certifies: C. Portability: If you are the initial PHA, enter # families currently enrolled but who have moved under portability and whose S8 assistance is administered by another PHA D. % of FSS slots filled (b + c divided by a) December 2008 65
© Copyright 2008 Nan McKay & Associates Rating FSS Enrollment
The HUD field office will verify the # of mandatory FSS slots (or with exception) reported on the PHA’s certification PIC supplies the number of FSS families currently enrolled December 2008 66
© Copyright 2008 Nan McKay & Associates 14b. % of FSS Participants with Escrow Balances
The PHA has made progress in supporting family self-sufficiency as measured by the % of currently enrolled FSS families with escrow account balances (need 30% for full points) Yes___ No___ $ December 2008 67
© Copyright 2008 Nan McKay & Associates 14 b. % of FSS Participants with Escrow Balances
Portability: If you are the initial PHA
Enter the number of families with FSS escrow accounts currently enrolled in your FSS program, but who have moved under portability and whose Section 8 assistance is administered by another PHA December 2008 68
© Copyright 2008 Nan McKay & Associates Rating FSS Escrow Account Balances
The percent of FSS families with escrow account balances comes directly from PIC # of FSS families with positive escrow balance or with a positive amount of escrow disbursed # of families in PIC w/progress reports = % with escrow accounts balance
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December 2008 69
© Copyright 2008 Nan McKay & Associates Deconcentration BONUS
Mandatory for PHA using PS amount(s) that exceed 100% of FMR set at 50th percentile Optional for all other PHAs Criterion 1
50% or more of all S8 families with children resided in low poverty census tracts last FY
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December 2008 70
© Copyright 2008 Nan McKay & Associates Deconcentration BONUS
Criterion 2 and 3 2. % of S8 families with children who have moved to low poverty census tracts last FY
At least 2% higher than % of All S8 families with children living in low poverty census tracts last FY 3. Same as (2), except over past two FY 5 points
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December 2008 71
© Copyright 2008 Nan McKay & Associates Deconcentration Bonus
Criterion 4
State and regional PHAs
Must complete data for each metro area or portion of a metro area where the PHA has assisted 20 or more S8 families with children last FY 5 Points December 2008 72
© Copyright 2008 Nan McKay & Associates Success Rate of Voucher Holders
Applies only to PHAs with HUD approval to establish success rate PS amounts Initially effective for 2nd full PHA FY following date of HUD approval of success rate PS amounts >>>>>>>>>
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December 2008 73
© Copyright 2008 Nan McKay & Associates Success Rate of Voucher Holders
Measures whether voucher holders were successful in leasing units HUD verification method: PIC 5 Points December 2008 74
© Copyright 2008 Nan McKay & Associates Additional Information
A PHA may include with its SEMAP certification any information bearing on the accuracy or completeness of the information used by the PHA in completing its certification (comments) A PHA may also send paper documentation to the HUD field office
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December 2008 75
© Copyright 2008 Nan McKay & Associates So what’s a PHA to do???
December 2008 76
© Copyright 2008 Nan McKay & Associates Review Steps to Success December 2008 77
© Copyright 2008 Nan McKay & Associates
UPCOMING LUNCH ‘N’ LEARNS January 16 – Earned Income Disallowance January 23 – Rent Reasonableness January 30 – Managing the Maintenance Function February 13 – EIV Security and Update March 6 - Income Exclusions (not including Earned Income Disallowance) December 2008 78