Management and Occupancy Reviews (MORs) are an important task that Navigate performs for HUD in order to verify that property owners and management agents are in compliance with HUD and other federal regulations and their Housing Assistance Payments (HAP) Contract.
Our Relationship Managers conduct MORs annually for each property that is covered under a Project Based Section 8 contract. The MOR consists of:
- A scheduling letter which is sent at least 30 days in advance of the MOR that includes a request for relevant documents to be provided to Navigate for review in advance of the MOR
- An on-site review of a random sampling of resident files
- An FHEO compliance review
- Follow up of the property’s most recent REAC inspection
- A report that is sent to the owner/agent and HUD within 30 days of the on-site Review indicating the results and rating of the Review
- Assisting the owner/agent in responding to any MOR findings within 30 days of the date of the report.
At Navigate, we pride ourselves on customer service and are always committed to positive communication with our clients throughout the MOR process.
The Real Estate Assessment Center (REAC) conducts physical inspections for HUD administered properties with a HAP contract. Navigate must provide follow-up on the results of these inspections. The first step to providing this follow-up is the proper tracking and monitoring of physical inspections as they occur. When your REAC inspection is complete, Navigate is responsible for:
- Reviewing the Physical Inspection generated by the REAC Physical Inspection Scheduler
- Contacting the Owner/Agent, via phone, fax, or e-mail, to confirm mitigation of the items cited
- Securing a certification of mitigation and any documentation associated with mitigating the EH&S items
When conducting the MOR, your Navigate Relationship Manager is responsible for selecting units cited on the REAC inspection to confirm all of the Exigent Health and Safety (EH&S) items, and a sampling of the remaining deficiencies have been mitigated.
Owner/Agents are required to mitigate REAC Findings in a timely manner in order to maintain decent, safe, and sanitary housing. Unmitigated items noted during the MOR may result in a Finding.
The Relationship Manager (RM) position is responsible for conducting MORs and serves as a local and immediate point of contact for owners and management agents.
MORs are scheduled by the RM at least thirty (30) days in advance starting with a telephone call to determine a date and time convenient for both parties. In general:
Prior to the On-Site Review An Owner Will:
- Receive a scheduling letter package that confirms the Review date and time, along with a checklist of items that may be submitted in advance of the Review in order to expedite the time on property
- Be asked to notify residents (in writing), and on-site staff of the Review date and time should the reviewer wish to speak to them
- Collect documents that will be reviewed while on site (e.g. EIV Rules of Behavior, work order journals and logs, etc.)
During the On-Site Review An Owner Can Expect:
- To be asked for responses to questions on form HUD 9834
- An evaluation of policies, procedures, and practices on the property
- A review of active resident files to verify occupancy related factors such as eligibility and resident selection, income, and tenant rent
- A review of move-out files to verify consistent processing and documentation
- A review of rejected application files to ensure compliance with HUD guidance and the owner’s own policies and procedures
- A review of the number of vacant units and their occupancy status
- A review of deficiencies noted on the most recent REAC to determine the status of corrective actions taken
- A review of EH&S deficiencies noted on the most recent REAC to verify mitigation
At the Close of the On-Site Review, An Owner Can Expect:
- A MOR Exit Meeting to discuss the discrepancies identified during the on-site portion of the MOR
- To be given the opportunity to provide additional information or documentation to resolve a discrepancy during the MOR Exit meeting so that it does not appear in the MOR report as a Finding
- To receive a copy of the Exit Meeting form showing all of the discrepancies identified during the on-site portion of the MOR. The form will also denote which items were resolved by the owner/management agent during the Exit Meeting and those items that remain unresolved
Once the MOR is Complete, An Owner Will:
- Receive a MOR report within thirty (30) days of the on-site Review that includes the Review results and a MOR rating
- Be required to provide a complete response to any MOR Findings within thirty (30) days of the date on the report letter.
- Be extended the opportunity to appeal an overall MOR score of Below Average or Unsatisfactory within thirty (30) calendar days of the report letter
During a MOR, a Navigate team member will verify certain documents are part of a resident file. Some of these documents include:
- Application – Signed and dated by applicant; showing the date and time received by management (management does not have to sign)
- Lead-Based Paint Acknowledgement (if built before 1978)
- HUD-9887 & 9887-A – A form signed and dated by each adult in the household (18 years of age and older)
- EIV & You Brochure – Documentation of distribution at Move-In and each Annual Recertification
- Resident Screening – Documentation of consistent criminal and sex offender screening, and other items as outlined in Tenant Selection Plan for property
- House Rules
- Zero Income Certification – at Move-In and each Annual Recertification, notarized
- All applicable EIV reports
- Third Party Verification of the Following:
- Income not reported in EIV
- Assets
- Medical Expenses
- Childcare Expenses
- Disability Expenses
- Disablility Verification
Remember, this is not a complete list; but, it does give you an idea of the types of documents a Navigate team member will ask to see.
When Navigate identifies deficiencies that require corrective action by the Owner/Agent, a finding is issued in the Management and Occupancy Review report.
Findings contain the following elements:
Criteria – Cites the regulation that applies to the finding.
Condition – Describes the deficiency found; the unit number and certification (if applicable) or the unit number and area (if it is a physical deficiency)
Cause – Describes why the deficiency occurred
Effect – Describes what did, or may have occurred as a result of the deficiency
Corrective Action – Indicates the steps the Owner/Agent must take to correct the deficiency, the documentation Navigate requires to confirm mitigation, and the date by which the documentation must be submitted to Navigate.
MOR Finding Response Requirements
- Due 30 Days From The Date On The MOR
Rating Letter
- Must address all findings noted in the MOR
- Must include documentation of mitigation
- If the finding involves a correction to a HUD 50059, the correction must be made to the certification indicated in the finding.
- It is helpful to prepare a cover letter that addresses each finding, and lists the documents attached that confirm mitigation of the finding.
- You must perform all steps and provide all documentation requested in the Corrective Action for each finding.
- If your response to a finding contains documents or actions other than what Navigate requested, explain your response in the cover letter.
- If, while preparing your response, you need clarification or assistance in mitigating a finding, you may call Navigate for advice or help in completing the mitigation.
- If you need additional time to prepare a complete response, contact your Navigate Relationship Manager or the CAC for your state.
- If all findings are not addressed as requested the MOR will remain open until Navigate receives the required documentation to confirm all findings have been mitigated.
- If the Owner does not respond to the MOR or does not submit all documentation required to close the MOR a referral to flag will be submitted to the HUD Office.
EIV
How do I gain access to EIV?
Where can I find a copy of the EIV and YOU Brochure?
Where can I find a copy of the EIV User Manual?
Where can I find the EIV main page?
What do we need to include in our Policies and Procedures?
Attachment 6 of HUD Notice 11-21 indicates which reports must be included in the policy and procedures. In summary:
| Report |
Policies & Procedures |
Tenant Selection Plan |
| Summary |
Include |
Do Not Include |
| Income |
Include |
Do Not Include |
| Income Discrepancy |
Include |
Do Not Include |
| No Income |
Include |
Do Not Include |
| New Hires |
Include |
Do Not Include |
| Existing Tenant Search |
Do Not Include |
Include |
| Multiple Subsidy |
Include |
Do Not Include |
| Failed EIV Prescreening Report |
Include |
Do Not Include |
| Failed Verification Report |
Include |
Do Not Include |
| Deceased Tenants Report |
Include |
Do Not Include |
How do I contact the EIV Helpdesk?
What EIV Reports do I need to run?
All reports must be utilized in accordance with HUD Notice 11-21 and the O/A’s written EIV Policies and Procedures.
| Report |
Report Use |
| Summary |
Must be used at annual and interim recertification |
| Income |
Must be used at annual, interim, and as indicated by your policies and procedures |
| Income Discrepancy |
Must be used at annual, interim, and as indicated by your policies and procedures. |
| No Income |
As identified in your policies and procedures. |
| New Hires |
At least quarterly |
| Existing Tenant Search |
At the time of processing an application for admission |
| Multiple Subsidy |
At least quarterly |
| Failed EIV Prescreening Report |
Monthly |
| Failed Verification Report |
Monthly |
| Deceased Tenants Report |
At least quarterly |
What are the document retention requirements?
See HUD Notice 10-10 and Attachment 6 for additional information on the following:
| Report |
Retention Policy |
| Summary |
must be retained in the tenant’s file for the term of tenancy plus 3 years |
| Income |
must be retained in the tenant’s file for the term of tenancy plus 3 years |
| Income Discrepancy |
must be retained in the tenant’s file for the term of tenancy plus 3 years |
| No Income |
must be retained in the tenant’s file for the term of tenancy plus 3 years |
| New Hires |
must be retained in the tenant’s file for the term of tenancy plus 3 years,
must also be retained in master files
|
| Existing Tenant Search |
must be retained in a denied applicants file for 3 years, or if admitted in the tenant’s file for term of tenancy plus 3 years |
| Multiple Subsidy |
must be retained in master files for 3 years* |
| Failed EIV Prescreening Report |
must be retained in master files for 3 years* |
| Failed Verification Report |
must be retained in master files for 3 years* |
| Deceased Tenants Report |
must be retained in master files for 3 years* |
* The Multiple Subsidy Detail report and any documentation provided to verify discrepant information for the Failed EIV Prescreening, Failed Verification Reports, and Deceased Tenants Report, must also be retained in the applicable tenant file for term of tenancy plus 3 years
Who needs to sign the Rules of Behavior form?
Rules of Behavior (ROB)
All EIV users who have access to the EIV system must adhere to the EIV ROB signed at the time of requesting access to the EIV system. O/A staff, service bureau staff, HUD staff and CA staff who do not have access to the EIV system but who view or use EIV data/reports provided by authorized EIV Coordinators or EIV Users in order to perform their job functions, must adhere to the EIV ROB.
Management and Occupancy
What EIV documents must be present at the MOR?
These must be the original signed forms:
- Owner’s authorization for individuals to access EIV on their behalf
- Multifamily Housing Coordinator Access Authorization Forms (Signed original copy and current copy- must be renewed annually.)
- User Access Authorization Form (Signed original copy and current copy- must be renewed annually.)
- Signed Rules of Behavior Form(s) (for individuals without access to the EIV system.)
- Copy of written policies and procedures for using the EIV employment and income data and reports.
- ISS Security Awareness Training Certificate (Annual)
The following documentation will be required as needed:
- Documentation relating to the follow-up of failed Identification/Verification Reports.
- Documentation relating to the follow-up of Multiple Subsidy Report.
- Documentation relating to the follow-up of Deceased Tenant Report.
- Tenant files must be properly documented in accordance to HUD Notice 11-21.
- Record of training conducted for staff annually.
What are acceptable forms of verification?
Where can I find the HUD Summary of Questions on Handbook 4350.3 REV1 document?
What are my options to appeal a score on a Management and Occupancy Review?
Initial Appeal
An appeal letter with specific examples explaining the facts supporting a change in the rating must be forwarded to the HUD Multifamily Program Center Director and/or CA and postmarked within 30 calendar days of the Summary Report date.
The appeal decision letter will be transmitted to the owner/agent by the HUD Multifamily Program Center Director or the CA within 45 calendar days from receipt of the appeal. (Refer to HUD Handbook 4350.1 Chapter 6).
Final Appeal
If the owner/agent does not agree with the initial appeal decision, the owner/agent may submit a final appeal to the Multifamily Hub Director within 15 calendar days of the date of the initial appeal decision letter for a final decision from HUD within 45 calendar days from receipt of the final appeal. (Refer to HUD Handbook 4350.1 Chapter 6).
The owner/agent may request a meeting with the Multifamily Hub Director to present verbal arguments. The meeting must be requested and scheduled during the 30 calendar day period following the transmittal date of the initial appeal decision letter.
Final appeal decisions will not be subject to further appeal.
What are HUD’s document retention requirements?
REAC Inspections
I just received a very low REAC score. I disagree with the findings. What do I do?
