Common Management Review Findings

Inadequate Waiting List management or documentation

During the Management Review SHCC reviews the property’s current Waiting List to ensure it contains all of the required data fields, and to determine how many applicants are currently awaiting housing.  We also review Waiting List history for the last12 months to ensure we can confirm the specific actions taken with each applicant.  This includes determining whether an applicant was contacted, selected for move-in, rejected, and/or removed from the Waiting List.  The Waiting List must clearly document that applicants were appropriately and fairly selected for the next available unit. 

To avoid this Finding: We encourage you to periodically review your Waiting List.  Does it contain all of the required data columns?  Are these columns consistently completed, for all applicants?  Are all actions taken with an applicant recorded on the Waiting List?  For example, any contact made with an applicant, such as a phone call or letter, must be noted on the Waiting List.  When an applicant moves into a unit, the date and time of their selection must be recorded on the Waiting List.  If an applicant is removed from the Waiting List, or rejected due to lack of eligibility, these actions must be recorded with the date and time.  When in doubt, document the action taken.  It is impossible to over document your Waiting List.  Your goal in the notations is to create transparency, so that an independent party can confirm each applicant was contacted and selected in the correct order.

Tenant Rent and HAP verification and/or calculation errors

SHCC’s reviewer will audit a sampling of resident files during the on-site portion of the Management Review.  As part the audit, SHCC must confirm that the tenant rent and HAP subsidy were verified and calculated correctly.  This includes verifying that:

• Tenant reported income, assets, expenses, and deductions were properly verified via third-party verification
• Income, assets, expenses, and deductions were calculated properly upon receipt of appropriate verification
• Upon proper verification and calculation, income, assets, expenses, and deductions were accurately recorded on the corresponding form HUD-50059

To avoid this Finding/Error: We understand the challenges presented in verifying and calculating tenant rent and HAP subsidy. We recommend the following to help with this process:

• Perform a thorough applicant/resident interview.  Asking the right questions during the interview aids in reducing errors.
• Use HUD’s EIV system for tenant recertifications.  Use of the EIV system is mandatory as of September 30, 2009, and the system is designed to help streamline the recertification process.
• Don’t settle for a lesser form of verification because it is easy.  Third-party verification, or third-party verification attempts, must be present in the tenant file for all income, assets, expenses, and deductions reported on the form HUD-50059.
• Review property created verification forms to ensure they clearly ask for the frequency of tenant income and/or expenses.  Calculation errors often occur because periodic wages and/or expenses are not accurately converted to annual figures.
• Have a second person review your calculations, and the corresponding form HUD-50059 that is created.  A second set of eyes will often catch any transcription errors or items inadvertently missed.

Lack of implementation of HUD updates

During the Management Review SHCC must confirm that HUD updates have been implemented in a timely manner.  HUD updates include, for example:

• Annual Income Limit changes
• Revised HUD forms that are released, such as the release of the OMB HUD Model Lease
• Policy updates issued through HUD Notices, such as the Violence Against Women Act (HUD Notice 08-07)
• Policy updates issued through the Federal Register, such as the Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Programs Final Rule

To avoid this Finding: We recognize the challenges of keeping up with HUD updates that are released.  We recommend that you sign up for HUD’s RHIIP Listserv, as well as SHCC’s Listserv.  These Listservs provide email announcements with the latest HUD update, and often contain information about new and/or upcoming changes in HUD policies and procedures. We encourage you to register to receive these updates.