Transcript SEMAP - Nan McKay and Associates

©©Copyright
Copyright2009
2009Nan
2008
NanMcKay
McKay&&Associates
Associates
HousingHelp
Help
Sessions
Housing
Sessions
Name of
session
– date of session
SEMAP
– May
16, 2008
NMAHost:
Host:
NMA
TrainerGail
Enter
your name here
Trainer
Gillespie
Earned Income
Disallowance
© Copyright 2009 Nan McKay & Associates
PHA Supervisory Audits
Housing Help Sessions
SEMAP – May 16, 2008
Slide 2
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 3
1st 7 SEMAP Indicators
*Indicates PHA audit needed
© Copyright 2009 Nan McKay & Associates
Selection from Waiting List*
Reasonable Rent*
Determination of Adjusted Income*
Utility Allowance Schedule
HQS Quality Control Inspections*
HQS Enforcement*
Expanding HousingHousing
Opportunities
Help Sessions
SEMAP – May 16, 2008
Slide 4
15
20
20
5
5
10
5
© Copyright 2009 Nan McKay & Associates
Size of Universe
 Determines file sample size
 Not the same for each indicator
 e.g., # number of admissions vs.
number of families assisted
Housing Help Sessions
SEMAP – May 16, 2008
Slide 5
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 6
© Copyright 2009 Nan McKay & Associates
File Sampling
 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 7
© Copyright 2009 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 to receive 15
 # of files which must meet criteria
points? Note: 98%
98.8 (10) files
51-600 = 5 + 1 for each 50 (or part of 50) over 50
Housing Help Sessions
SEMAP – May 16, 2008
Slide 8
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 9
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 10
1. Selection from Waiting List (Supervisory
Audit)
© Copyright 2009 Nan McKay & Associates
 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
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-1
Slide 11
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 12
© Copyright 2009 Nan McKay & Associates
Most Likely Error Points
 Get up to date on preferences in 982.207
 Residency preference
 Working preference
 Singles preference
 Preference for persons with disabilities
Housing Help Sessions
SEMAP – May 16, 2008
Slide 13
© Copyright 2009 Nan McKay & Associates
Policies for Audit File
 Example: October FY PHA
 Policy changes in last year:
 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 14
© Copyright 2009 Nan McKay & Associates
Other Issues
 Income targeting
 75% of new admissions in PHA’s FY must be
Extremely Low Income Families
 ELI = 30% of Area Median
 How do you track this?
Housing Help Sessions
SEMAP – May 16, 2008
Slide 15
© Copyright 2009 Nan McKay & Associates
Other Issues
 Does PHA staff understand
 Special Admissions 982.203
 Targeted funding
 Funding for specified category of waiting list families,
such as:
Family Unification
Mainstream for Persons with Disabilities
Housing Help Sessions
SEMAP – May 16, 2008
Slide 16
© Copyright 2009 Nan McKay & Associates
Getting Proof
 Put copy of the top of the WL you pulled from
in file
 Note why you skipped someone if you did
 Note if you did any special admissions
 Attach copy of each letter sent
Housing Help Sessions
SEMAP – May 16, 2008
Slide 17
© Copyright 2009 Nan McKay & Associates
Waiting List Notations
 Jones
 Sarazac
 Verona
 Palstrom
 Belle
skipped (reason)
skipped (reason)
income targeting
skipped (reason)
income targeting
Housing Help Sessions
SEMAP – May 16, 2008
Slide 18
 Universe
2. Reasonable Rent
(20/15/0 points)
© Copyright 2009 Nan McKay & Associates
 Number of families assisted for PHA FY
 Sample drawn from
 Number of families assisted for PHA FY
Housing Help Sessions
SEMAP – May 16, 2008
Slide 19
2. Reasonable Rent
(Supervisory Audit)
© Copyright 2009 Nan McKay & Associates
 The PHA must have a reasonable written
method to determine
 Rent to owner is reasonable based on current
rents charged for comparable unassisted units
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-16
Slide 20
© Copyright 2009 Nan McKay & Associates
2. Reasonable Rent
 The method may take into consideration
 Location
 Size
 Type
 Quality
 Age
 Amenities
 Housing services
 Maintenance
 Utilities
Housing Help Sessions
SEMAP – May 16, 2008
Slide 21
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 22
© Copyright 2009 Nan McKay & Associates
Rent Reasonableness
 Involves two comparisons between the rent
charged for an HCV unit and the rent charged:
 For similar units in the private unassisted market
 For similar unassisted units on the premises
Housing Help Sessions
SEMAP – May 16, 2008
Slide 23
© Copyright 2009 Nan McKay & Associates
Documentation
 PHAs required to supply documentation about
each rent reasonableness determination
 Include data on unassisted units compared
 Identify who made the rent reasonableness
determination and when
Housing Help Sessions
SEMAP – May 16, 2008
Slide 24
Rent Reasonableness
Notice PIH 2003-12
© Copyright 2009 Nan McKay & Associates
 Use of Rent Reasonableness Factors
 Notice clarifies that PHAs are NOT required to
apply all nine rent reasonableness factors
individually to fully comply with the regulation at
24 CFR 982.507(b)
Housing Help Sessions
SEMAP – May 16, 2008
Slide 25
Rent Reasonableness
© Copyright 2009 Nan McKay & Associates
Notice PIH 2003-12
 Request for Tenancy Approval form:
 Item 12a: Owners of projects with >4 units must provide
rents on 3 comparable unassisted units on premises
 PHAs may use these comparables to determine and
document rent reasonableness in same multifamily
apartment complex
 If complex not substantially assisted, no additional
comparables required
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-17
Slide 26
Rent Reasonableness
Notice PIH 2003-12
© Copyright 2009 Nan McKay & Associates
 Commonsense approach calls for rent
reasonableness determinations that are:
 Accurate
 Based on comparables
 Documented
 Reasonable
 Consistent
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-17
Slide 27
3. Determination of Adjusted Income
(20/15/0 points)
© Copyright 2009 Nan McKay & Associates
 Universe
 Number of families assisted for PHA FY
 Sample drawn from
 Number of families assisted for PHA FY
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-44
Slide 28
3. Determination of Adjusted Income
(Supervisory Audit)
© Copyright 2009 Nan McKay & Associates
 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
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-44
Slide 29
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 30
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 31
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 32
© Copyright 2009 Nan McKay & Associates
NEW! HUD Guidance on EIV
 HUD webcast 1/16/08 contained revised
guidance on use of EIV
 Previous guidance is obsolete and has been
removed from EIV website
 Webcast available at
http://www.hud.gov/webcasts/archives/ph.cfm
 4 hours
Housing Help Sessions
SEMAP – May 16, 2008
Slide 33
4. Utility Allowance Schedule
(5 points)
© Copyright 2009 Nan McKay & Associates
 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
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-54
Slide 34
© Copyright 2009 Nan McKay & Associates
NOTE!
 PHA needs a record of the date each utility
rate on each utility allowance is revised
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-54
Slide 35
© Copyright 2009 Nan McKay & Associates
Exception
 Utility Allowance
 CFR 982.517: PHAs must revise utility
allowances whenever there is a utility rate
change of 10% or more
 PIH 2005-9: PHA experiencing financial difficulties
may request a HUD waiver, for good cause
Housing Help Sessions
SEMAP – May 16, 2008
Slide 36
5. HQS Quality Control Inspections (5/0
points)
© Copyright 2009 Nan McKay & Associates
 Universe
 Units under HAPC during last completed FY
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-61
Slide 37
5. HQS Quality Control Inspections
(Supervisory Audit)
 PHA performs QC inspection of units under
contract
 Sampling drawn from:
© Copyright 2009 Nan McKay & Associates
 Recently completed inspections
 Cross section of neighborhoods
 Work of cross section of inspectors
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-61
Slide 38
 Universe
6. HQS Enforcement
(10/0 points)
© Copyright 2009 Nan McKay & Associates
 Number of failed HQS inspections in last FY
 Sample drawn from
 Number of failed HQS inspections in last FY
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-68
Slide 39
© Copyright 2009 Nan McKay & Associates
6. HQS Enforcement (Supervisory Audit)
 The PHA must ensure that when a unit fails
an HQS inspection
 Any life-threatening deficiencies are corrected
within 24 hours, and
 All other HQS deficiencies are corrected within
no more than 30 calendar days or PHA approved
extension
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-68
Slide 40
© Copyright 2009 Nan McKay & Associates
6. HQS Enforcement
 If HQS deficiencies are not corrected within
the required time frame PHA must:
 Stop housing assistance payments, or
 Take prompt action to enforce the family
obligations
Housing Help Sessions
SEMAP – May 16, 2008
Slide 41
© Copyright 2009 Nan McKay & Associates
6. HQS Enforcement
 All life threatening fails corrected within
24 hrs
 98% of other fails corrected within 30 days or
PHA approved extension
 If not, PHA took action
 Owner fails: abated HAP
 Family fails: enforced family obligations
Housing Help Sessions
SEMAP – May 16, 2008
Slide 42
7. Expanding Housing Opportunities (5/0
points)
© Copyright 2009 Nan McKay & Associates
A. Written policy to encourage owner
participation outside areas of poverty or
minority concentration
B. Documentation shows PHA followed policy
Housing Help Sessions
SEMAP – May 16, 2008
Slide 43
© Copyright 2009 Nan McKay & Associates
Expanding Housing Opportunities
C. PHA has created a briefing packet to
encourage voucher holders to seek these
opportunities
(e.g. maps, job opportunities, schools and other
services in the areas)
Housing Help Sessions
SEMAP – May 16, 2008
Slide 44
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 45
© Copyright 2009 Nan McKay & Associates
Expanding Housing Opportunities
E. Information packet explains portability and
provides list of contacts at neighboring PHAs
 Name
 Address
 Phone
Housing Help Sessions
SEMAP – May 16, 2008
Slide 46
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 47
8. Payment Standards
(5/0 points)
© Copyright 2009 Nan McKay & Associates
 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
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-85
Slide 48
© Copyright 2009 Nan McKay & Associates
8. Payment Standards
 If any Payment Standard schedule contains a
payment standard that is out of range from the
appropriate FMR
 Field office will assign 0 points for the indicator
Housing Help Sessions
SEMAP – May 16, 2008
Slide 49
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 50
© Copyright 2009 Nan McKay & Associates
HUD Indicators
Verified by PIC
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-90
Slide 51
9. Annual Reexaminations
(10/5/0 points)
© Copyright 2009 Nan McKay & Associates
 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)
Housing Help Sessions
SEMAP – May 16, 2008
Slide 52
10. Correct Tenant Rent Calculations (5/0
points)
© Copyright 2009 Nan McKay & Associates
 The PHA must correctly calculate family’s
share of rent to owner
 PIC Report shows the percent of all families
with family’s share of rent to owner
discrepancies
 PIC Tenant Rent Discrepancy Report gives list
of families with rent discrepancies
Housing Help Sessions
SEMAP – May 16, 2008
Slide 53
11. PreContract HQS Inspections (5/0
points)
© Copyright 2009 Nan McKay & Associates
 Newly leased units must pass HQS inspection
before HAP Contract effective date
Housing Help Sessions
SEMAP – May 16, 2008
Slide 54
12. Annual HQS Inspections
(10/5/0 points)
© Copyright 2009 Nan McKay & Associates
 The PHA inspects each unit under contract at
least annually
 At least annually means within 12 months
from date inspector conducted full HQS
inspection
Housing Help Sessions
SEMAP – May 16, 2008
Slide 55
© Copyright 2009 Nan McKay & Associates
12. Annual HQS Inspections
 HUD-50058 form has an action code (#13) to
allow reporting of the annual HQS inspection
at the time it occurs
 PIC will list % of inspections more than 2
months overdue
 The 2 month allowance is to accommodate a
possible lag in electronic reporting
Housing Help Sessions
SEMAP – May 16, 2008
Slide 56
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 57
13. Lease-Up
(20/15/0 points)
© Copyright 2009 Nan McKay & Associates
 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
Housing Help Sessions
SEMAP – May 16, 2008
Slide 58
© Copyright 2009 Nan McKay & Associates
14. FSS
 Applies only to PHAs required to administer
an FSS program
 PHA checks off on the certification form if the
indicator does not apply them
 If checked, HUD field office will verify that the
PHA is not required to administer an FSS
program
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-123
Slide 59
14a. FSS Enrollment
PHA Certifies:
A. # of mandatory slots or # slots with
HUD-approved exception
© Copyright 2009 Nan McKay & Associates
B. # of FSS families currently enrolled
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-123
Slide 60
14a. FSS Enrollment
PHA Certifies:
© Copyright 2009 Nan McKay & Associates
C. Portability: If you are the initial PHA
Enter # families currently enrolled but who have
moved under portability and whose Section 8
assistance is administered by another PHA
D. % of FSS slots filled (b + c divided by a)
Housing Help Sessions
SEMAP – May 16, 2008
Slide 61
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-123
Slide 62
14b. % of FSS Participants
with Escrow Balances
© Copyright 2009 Nan McKay & Associates
 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___
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-124
Slide 63
14 b. % of FSS Participants
with Escrow Balances
© Copyright 2009 Nan McKay & Associates
 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
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-124
Slide 64
© Copyright 2009 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
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-124
Slide 65
© Copyright 2009 Nan McKay & Associates
FSS Points
 10 points
80% or more slots filled & 30% or
more have escrow accts
 8 points
60-79% slots filled & 30% or move
have escrow accts
 5 points
80% or more slots filled & less than
30% have escrow accts
Housing Help Sessions
SEMAP – May 16, 2008
Slide 66
© Copyright 2009 Nan McKay & Associates
FSS Points
 5 points
 3 points
30% or more have escrow accts &
less than 60% slots filled
60-79% slots filled & less than 30%
have escrow accts
 0 points
Less than 60% slots filled & less
than 30% have escrow accts
Housing Help Sessions
SEMAP – May 16, 2008
Slide 67
© Copyright 2009 Nan McKay & Associates
Scoring Your Agency Under SEMAP
 Conduct a preliminary evaluation of all
indicators
 Do a “trial run” if you don’t have an upcoming
FYE
 Analyze results of data collected
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-141
Slide 68
© Copyright 2009 Nan McKay & Associates
Scoring Your Agency Under SEMAP
 Determine an estimated score
 What is rating you will accept for your agency?
 What are the consequences for a standard score
in your city?
 What are the consequences for a troubled
status?
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-141
Slide 69
© Copyright 2009 Nan McKay & Associates
Scoring Your Agency Under SEMAP
 Determine the basis for prioritizing the
indicators you will work on first
 Points
 Easiest to complete
 Staff availability
 Control over indicator area
 Political consequences
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-141
Slide 70
© Copyright 2009 Nan McKay & Associates
Scoring Your Agency Under SEMAP
 Complete analysis and documentation
 Do percentages for PS vs. FMR
 Run PIC reports
 Problem solve/fix what you can
 Prepare audit files
Housing Help Sessions
SEMAP – May 16, 2008
Page 2-141
Slide 71
© Copyright 2009 Nan McKay & Associates
Upcoming Lunch ‘n’ Learns
 June 12 – PH Rent Calculation
 June 13 – HCV Rent Calculation
 June 20 - Ethics in Your Housing Authority
Housing Help Sessions
SEMAP – May 16, 2008
Slide 72