Management occupancy reviews (MORs) are a panic-inducing part of the job for property managers and owners, housing authority staff, and developers. Required on an annual basis for every property that’s covered by a project-based Section 8 contract, the MOR verifies that property owners and management agents are in compliance with HUD and other federal regulations and their housing assistance payments (HAP) contract.
You don’t want an MOR rating of “below average” or “unsatisfactory,” according to property management consultant Paul Flogstad, who speaks for AudioSolutionz on public housing issues. Such a low rating can often result in an HUD “flag” that indicates you may be out of compliance.
HUD Keeps Changing Forms
And not to add to the confusion, but have you recently replaced your Form 9834: Management Review for Multifamily Housing Projects? Well, you need to replace it again. The U.S. Department of Housing and Urban Development (HUD) posted a new Form 9834—again—after just recently publishing an update. The newly updated form for MORs still bears the April 30, 2018 expiration date.
“This form will be used by reviewers when conducting MORs and should be used by owners when preparing for MORs,” stated A.J. Johnson Consulting Services, Inc. The significant changes to the form involve the questions regarding the Enterprise Income Verification (EIV) System.
Can You Answer These Utility Allowance Questions?
In Section I: The Desk Review, HUD modified Question 38, according to Mary Ross, CPO, FHC, MORS, president of Ross Business Development in Atlanta.
Before: In the last version, the question read:
- If there is a utility allowance, what was the effective date of last utility allowance adjustment?
What was the date of approval?
If a utility allowance was approved was it implemented in accordance with HUD guidelines?
Update: This newest version of the form now reads:
- If there is a utility allowance, when was the last adjustment approved?
Effective date of last utility allowance adjustment:
If a utility allowance was approved was it implemented within 75 days as required by HUD?
More: Also, in Section II: The On-Site Review, HUD added to Question 17d:
If yes, is a record kept of employees who attended the training?
This addition shows that reviewers will look for records of employees who attended EIV security awareness training.
Pay Attention to Removed Duplicative Questions
HUD removed Question 16b from Section II: The On-Site Review because this question is already covered in Addendum D, Ross says.
Question 16b asks whether the owner/agent has evicted or terminated assistance for all individuals subject to a lifetime sex offender registration requirement who were erroneously admitted after June 25, 2001.
In Section II, HUD also removed the question about the EIV Summary Report because this question is already part of the tenant file review.
Beware of New Questions about EIV Security Requirements
Also in Section II, HUD has added several new subparts to Question 20: “TRACS/EIV Security Requirements (applies to subsidized properties only).” These new subparts include the following:
- Is the owner/agent using TRACS queries to review and monitor their transmission? …
- Have staff with access to the EIV system completed the hard copy authorization form HUD-52676 when access was initially granted and completed the EIV online authorization form annually (coordinators) or semi-annually (users) as required?
- Have staff who use EIV reports, but do not access the EIV system in Secure Systems, completed the security awareness training annually and is there a signed Rules of Behavior?
- For new staff, or staff that was given access to EIV or TRACS within the last year, was the security awareness training completed before access, or within 30 days of being given access and signing the TRACS and EIV Rules of Behavior?
Relevant to item “c” above, know that HUD Form 52676 is the Office of Public and Indian Housing (PIH) EIV System User Access Authorization Form and Rules of Behavior and User Agreement.
And the two Multifamily Housing Access Forms now referenced in Section II are:
- HUD-90011 — EIV System Multifamily Housing Coordinator Access Authorization Form (http://portal.hud.gov/hudportal/documents/huddoc?id=90011.pdf)
- HUD-90012 — EIV System User Access Authorization Form (http://portal.hud.gov/hudportal/documents/huddoc?id=90012.pdf)