Hello and welcome to today's Tuesday Tip. I'm Pam. Today we're going to be taking a look at some common findings that we've had over the first quarter and some voucher errors that you can avoid by taking certain actions. There's a saying that an ounce of prevention is worth a pound of cure. That is Benjamin Franklin. what that simply means is that preventing errors is a lot easier, generally speaking, than correcting them.

So let's take a look first at the common MOR findings here to date. There have been some findings regarding VAWA that we're seeing frequently regarding the notices, either not using the correct notices or them not being distributed when they're supposed to be, VAWA transfer plans and appropriate postings. If you need a reminder on those, go ahead and rewatch our recent VAWA Tuesday tip that will let you know what you're supposed to be posting, what you're supposed to be distributing and when.

With reasonable accommodations, we're also seeing some findings regarding not having adequate documentation in the file. Remember, you want a request. And if that request comes verbally, just document that you got the request on such and such a date, who got it, what was said, what did they ask for. It's especially important if you're going to be denying a request.

that you document the reasons for that denial.

Some more common MOR findings with marketing plans. We're finding that sometimes people are forgetting to review those every five years or they've reviewed them but they didn't document the results of that review. Make sure you are updating them when you're required to do so, which is anytime there's a consolidated plan change for your area or if the demographics change significantly, make sure you are posting those marketing plans.


and make sure you're using those plans. There's a lot of confusion about when you have to market. Sometimes we will see people that say, we have a really long wait list. We really don't need to market. Remember that your affirmative fair housing marketing plan is designed to make sure that people who ordinarily wouldn't hear about your property based on their demographics hear about your property. So your

Affirmative Fair Housing Marketing Plan must be done every year advertising unless your waitlist is closed. If you have multiple waitlists and one is closed but two are open, you still need to advertise for the waitlists that are open every year. So you're going to advertise every year and keep documentation of that and you're going to review it every five

And if you do not need to make changes, just document your review. If you do need to make changes, those need to go to HUD for approval and keep documentation of when you sent it to HUD. We're also seeing errors with recertification notices. Make sure that every re-cert notice you need has been sent and that they're sent by the deadline.

Make sure that they are signed by management. A lot of people think that if the name is printed on the letter, they don't need to sign. You do. Anywhere there's a space for a signature, it needs to be signed. Document the tenant's response date. Most of that is done in property management software. You only need to continue to send notices if you're awaiting information from the tenant. So if the research is not complete,

or if the tenant has not come to do their interview. And follow up with items missing notices if third parties have not responded or if your tenant was supposed to bring you something and they haven't so that you can document that the research is not complete. EIV discrepancies is another common finding and the issues that we see here are either that monthly or quarterly reports are not

filed in the master file, make sure you're doing those as frequently as your policy or HUD's guidelines say that you have to. The four tab income report, when you do a research or anytime you're running that summary report plus all the other individual reports, that needs to be in the tenant file. If you have a discrepancy, resolution efforts need to be in the tenant file.

It's not wrong to keep a copy of the report in the master file, but the resolution efforts, exactly what you did to address any discrepancies, must be kept in the tenant file.

So some things that you can do to be prepared for your MOR. One of the things that you can do that is most helpful to your reviewer is to send all of those addendum C documents in advance as much as you can. Obviously you're not gonna be sending EIV, UAAFs and things like that, but your tenant selection plan, all of those other types of documents, if you can send those in advance,

It makes the review go a lot more smoothly and it gets us off your property more quickly. That is a suggestion. You are not required to do that. You're required to have it the day of review. But if you can send those things in advance, it's really helpful. And you can submit those through the Navigate portal. We also have people who are reluctant to provide salary information. Their concern is that it's confidential. But

You need to know that HUD requires us to get that information when we come on your property. So make sure you have gathered that for everyone that is charged to your property so that we have that when we come the day of review. You must provide all documents before the reviewer leaves your site with very few exceptions. Sometimes if it's a large document that we are looking at on site,

that it's going to be hard for us to scan, we will review that document and ask you to send it, but that is very rare. In general, you must provide all documents before we leave the site. And the reason for that is that HUD requires that MOR to be a snapshot of the property at the time of review. So we need to be looking at everything we're supposed to look at.

the day that we are there or the days that we are there if it's a multi-day route.

The other thing to look at is to make sure all of your expired users in EIV have been removed as users and all documents are on site. Now if they have expired and they actually don't work at your property anymore, that's fine. But if they're listed as expired and they're still users, that's going to be a problem. Also if somebody is no longer there and they're still listed as active, that's a problem. So make sure that you

go in and remove anybody who needs to be removed. And we have a recent Tuesday tip on that as well.

Voucher errors that we are seeing, the biggest one that we're seeing lately deals with joint custody dependence. And that is addressed in the 4350.3 at paragraph 5-63C, so that you can look that up. What it says is that when you have more than one family or more than one individual in two different households sharing custody of a child, and both families are in assisted housing,

only one at a time claims that dependent deduction. The family that counts the dependent deduction also counts the unearned income for that dependent. The other family doesn't claim anything. So when you have someone who has a child that's split evenly between two families and listed as dependent for both families, make sure that you are asking them to provide proof of who is going to claim that individual.

on the 50059 and that can be as simple as a signed statement.

It's only an issue when both parents are in subsidized housing, remember. You can get documents like a custody agreement if it's listed in the custody agreement, a letter from an attorney, or a self-certification. Anytime you're getting a self-certification, it's really good to make sure that that thing has something that tells them that providing false information to the government comes with some penalties.

just to remind them that they want to be extra careful to make sure that they're accurate on that form.

Some resources for some of the things we've talked about today. You have HUD 4350.3 Chapter 5, which details income, assets, expenses, and rent calculations. Chapter 9 is gonna be talking about vouchers. And you have some VAWA information on HUD's VAWA page. If you have suggestions for what we can do a Tuesday tip on and what might be helpful to you, please send them along. You can email them to us. My email address is on the screen.


You can also use Navigate's contact portal on their site to send those in. And we look forward to seeing you on the next Tuesday Tip.