Tuesday Tip
A missing signature. An expired verification. A calculation that doesn’t quite add up.
These may seem like small oversights, but they can lead to findings during a Management and Occupancy Review (MOR).
The good news? Many common MOR findings can be addressed before your next review. From tenant files to EIV documentation, here are several areas owners and agents should check now.
1. Check for Missing Signatures and Dates
Missing signatures and dates continue to be common findings in MORs. Therefore, it’s important to review forms carefully before filing them.
Pay particular attention to:
- Leases and acknowledgments: Confirm that all required signatures and dates are present.
- Applications: Record the date and time received. If information is added by hand, include the initials of the person making the notation.
- Self-declarations: Make sure these documents are signed and dated.
- Household forms: Confirm that all required adult household or family members have signed, depending on the form.
Also, verify that individuals who should not sign certain documents, such as live-in aides on leases, have not done so.
2. Watch for Expired Verifications
Verification documents have specific validity requirements that owners and agents should keep in mind.
Generally, verifications must be no more than 120 days old when received. In addition, they must be used within 120 days of receipt.
This applies to documents such as Social Security award letters, third-party verification letters, and certain financial statements. However, exceptions may apply, including when collecting six consecutive bank statements.
The takeaway: Check both the age of the document when received and the date it was used. Meeting one requirement doesn’t automatically satisfy the other.
3. Double-Check Calculations and Rounding
Calculation errors can also result in MOR findings, particularly when staff work with multiple housing programs that follow different rounding practices.
For HUD calculations, use the full dollar-and-cent amounts throughout the calculation process. Then, apply the appropriate rounding when entering the final amount on Form HUD-50059.
For example, if a Social Security award letter shows a monthly benefit of $1,012.70, use that full amount when calculating annual income.
A handwritten calculation worksheet can also help. Compare your calculations against the amounts entered into your property management software to catch potential errors.
4. Don’t Leave Required Fields Blank
Blank fields can raise questions during an MOR, even when the missing information doesn’t apply to the household or unit.
One common example is the HUD-9887 consent packet. Inspection forms can present similar issues.
Instead of leaving a required field empty, enter the appropriate information or mark it “N/A” when the field does not apply.
This simple documentation practice can help reviewers understand that the field was considered rather than overlooked.
5. Review Your EIV Reports and Documentation
Enterprise Income Verification (EIV) continues to be an important area of MOR preparation.
Several documentation issues deserve attention:
Missing reports: Even when an EIV report returns no results, retain a copy showing that the report was run. If reports are missing from a previous period, document the gap, when it was discovered, and the corrective action taken.
User and coordinator documentation: Confirm that the EIV master binder contains the required owner authorization letter and current and original user and coordinator documentation.
Discrepancy resolutions: Keep documentation showing how discrepancies were investigated and resolved. Relevant records should be maintained in the appropriate master and tenant files.
Tenant review opportunities: Document that tenants had an opportunity to review their EIV information. Also, record any disputes and the steps taken to resolve them.
Remember that EIV information is sensitive. Access and disclosure must follow applicable requirements, including written consent when necessary.
6. Review Your HOTMA Policies
As HOTMA implementation requirements continue to develop, owners and agents should review their policies against applicable HUD guidance.
In particular, check your:
- Tenant Selection Plan
- EIV policies and procedures
- Public access to required policies
- Required policy topics and documentation
Additionally, review relevant HUD HOTMA notices for required updates and implementation instructions.
Because implementation requirements may change, confirm that your policies reflect the guidance currently applicable to your property.
Prepare Before Your Next MOR
MOR preparation shouldn’t begin when the review is scheduled.
Instead, regular file reviews, accurate documentation, and consistent internal procedures can help owners and agents identify potential issues early.
And if you’re unsure about a requirement, ask questions before the review. Navigate works with owners and agents to support compliance and help address concerns before they become findings.
Frequently Asked Questions About Common Findings
What are common findings during a Management and Occupancy Review?
Common MOR findings include missing signatures and dates, expired verification documents, calculation errors, incomplete forms, and missing EIV reports or discrepancy documentation.
How long are verification documents valid for HUD purposes?
Generally, verifications must be no more than 120 days old when received and must be used within 120 days of receipt. Certain exceptions may apply.
Should EIV reports be retained if they show no results?
Yes. Retaining a copy of a report showing no results helps document that the report was run.
How can owners and agents prepare for an upcoming MOR?
Regularly review tenant files, verify signatures and dates, check calculations, maintain EIV documentation, and confirm that property policies reflect applicable HUD requirements.
