As we proceed into 2024, the U.S. Department of Housing and Urban Development (HUD) is reinstating a cornerstone of property oversight within the affordable housing sector. The on-site Management and Occupancy Review (MOR) is coming back. This move, detailed in a recent memorandum, marks a significant shift from the remote MOR procedures that became commonplace during the COVID-19 pandemic. The memo is available at the end of this post.
The Value of On-Site MORs
The essence of on-site MORs lies in their ability to offer an unfiltered, comprehensive view of a property’s operations. It also gives insight into compliance with HUD’s regulations. During these visits, Performance-Based Contract Administrators (PBCAs) engage with residents. We conduct in-person interviews with staff and assess the condition of common areas and individual units. This hands-on approach ensures a level of detail and immediacy that remote assessments cannot match.
Protecting Tenants and Integrity
On-site reviews are not merely about ticking off a checklist. In reality, they are about safeguarding tenant Personal Identifiable Information (PII) and observing real-time, unaltered operations. It’s about catching discrepancies that might not be evident in pre-arranged or sanitized digital submissions. In this context, on-site reviews are a protective measure for both tenants and the integrity of the affordable housing system.
Standard and Alternative Procedures
HUD requires PBCAs to follow a strict protocol for MORs. This includes physical inspections, assessments of building conditions, and reviews of tenant files on-site. However, the memorandum also outlines circumstances under which alternative procedures may be permitted. It also emphasizes the need for adaptability in the face of health and safety concerns.
Implications for Stakeholders
For multifamily owners, management agents, and PBCAs, this update necessitates a reacquaintance with the rigor of in-person reviews. It is a call to ensure that practices are up to par as the latitude for post-inspection corrections diminishes. For residents, this change promises a more authentic representation of their living conditions to the overseeing bodies.
Embracing Change for Better Housing
As we transition back to traditional MORs, we must recognize the broader implication. HUD reinforces its commitment to quality housing and accountability. This approach aligns with Navigate’s vision — to ensure that quality, livable housing is not just a standard but a guarantee.
Looking Ahead
The memorandum is a reminder that while the pandemic necessitated temporary flexibility, the core objectives of HUD have remained steadfast. As we approach the January 1, 2024, effective date for this change, let us view it as an opportunity. It is an opportunity to re-engage with our communities and improve our practices. It allows us to reaffirm our commitment to the principles of affordable housing for all.
For any concerns or queries, the memorandum directs contact to Doris Keeve, Contract Administration Branch Chief. This clearly indicates HUD’s proactive stance in facilitating a smooth transition to these updated procedures.
Navigating the waters of affordable housing requires steadfast adherence to regulations and a responsive attitude to emerging challenges. As we undertake on-site MORs again, we’re reminded ofthe tangible difference direct engagement and oversight can make in the communities we serve.
