Tuesday Tip Transcript

hello and welcome to Tuesday tips I’m Pam kowas and today we’re going to
be talking about mastering the we’re going to have a series of these the
first thing we’re going to be talking about is eiv and we’re going to
focus on the tenant files today it’s really important that your eiv
records be complete on site so that you don’t lose points to M findings
the first thing we’re going to talk about is certifications so with
hotma this is going to change some remember with hotma for anything
April 1st or later that’s the effective date you’re going to use just
what’s in eiv eiv should be updated by then so for any certifications
that are effective April 1st or later you’re going to use just what’s in
the I if you are doing certifications say you know September November
you’re not going to have what their social security is going to be in
the next year so you may be pulling eiv in say September or October it
is a really good idea to idea to pull eiv again if that certification
isn’t signed until say March so that you can make sure you have the
accurate information or you’re going going to be manually adding that
Cola the cost of living increase if you are processing that early again
it’s going to take a little while for it to hit the eiv system and HUD
says with hotma you must now use the Cola in addition to whatever award
you’re seeing say in September through December so make sure that
anything that is going to be effective January 1st 2025 and later has
that Cola taken into account what you’re doing currently remember is a
little different so preh hotma you have several options you can just use
what’s an eiv with no further calculations at all um I tend to think
this is the easiest way to do things makes it very simple for you you
look at eiv that’s the number you use or you can use what’s an eiv and
then add the cost of living increase for anything that’s effective
January or later or you can ask the tenants for their award letter which
is usually available in December or so so whichever of those approaches
that you use you just want to make sure that you’re being consistent
with whatever your management policy is and again once hotma takes
effect you’re going to be adding that Cola every certification after
January 1st so let’s talk about what we do with applicants with
applicants you’re going to be asking them for an award letter or a
benefit statement you’re going to use the amount that’s noted in that
letter and depending on your policy if they bring you either a benefit
statement or their December letter how you handle this and how you
handle the cola is going to depend on which one of those you use if you
get their December award letter that’s already factoring in the cola so
you can just use that if you get a benefits statement you may need to
add the cola or if it’s in June and I’m dealing with half of the year
and half of the year with Cola you may need to add it but that’s based
on what your owner policy is right now after hotma again you’re required
to account for the cola so again just some reminders for you when you
are using award letters and benefit statements with your initial
certifications or with your Movin you need to make sure that they are
dated within 120 days of receipt by the owner so if I am doing a
certification effective August 1st I cannot use their award letter from
December 2023 I need to ask them to get something more recent preh hotma
so pre January you can set the policy in terms of whether you add that
Cola or not and the big thing to remember is you have to use a
consistent policy so if your policy is to add Cola you need to do that
with everybody one of the findings that we are seeing on Ms out there is
inadequate documentation of discrepancies either there’s no
documentation or there’s not detailed documentation so I wanted to talk
to you a little bit about how we document those discrepancies when there
is a hit on the reports the multiple subsidy report your new hires
report income discrepancies you should be documenting your resolution
efforts in the tenant file generally what people do is they put a report
and a copy of those resolution efforts in the master file what has to be
in the master file is the actual report the resolution effort so your
phone calls your verifications anything that you did to look at the
discrepancy that all gets kept in the tenant file now what a lot of
people do is they document the resolution efforts they take that
original and put it in the tenant file they take a copy and put it in
the master file and that’s fine the key to remember though is that those
resolution efforts must be in your tenant file there’s a little
confusion on how exactly these things should be documented so you’ll see
what an e report looks like on the screen here that’s completely mocked
up so nobody’s information is being put out on Tuesday tips um when you
look at these the important thing to remember is that HUD is looking at
a specific time frame in the past and comparing it to what you entered
on your most recent 5059 so you’ll see that the period of income here is
given but that’s you know 2022 to 2023 or the full year of 2023 but it’s
a long way before now so a lot of things could legitimately have
happened between then and now you could have somebody that had a job and
got injured and lost their job before they came into affordable housing
you could have somebody who retired you could have someone who is laid
off so there can be a lot of legitimate reasons why this income doesn’t
match up so when you see one of these the first thing that you’re going
to do is go to your tenant and say hey we were reviewing the eiv reports
and you are showing as a discrepancy you give them an opportunity to
take a look at it and give you an explanation if I say to you oh yeah
that was before I moved in here I was was working and then I got injured
and I had to leave my job you’re going to look for some documentation
you may have that already in your file when I moved in you may have
verified that I lost my job and that I’m not working and you may have
that already but you have to have something on that report that tells
everybody what you did so you’ll see a sample down here this is somebody
who had an income discrepancy come up and what the note says is that the
resident was employed the employment was noted on the movein we spoke
with the store manager where they worked we verified the termination of
employment date and we had done an interim at that time so there’s
nothing further needed with the manager’s name and the date that all
that all happened so here is a comprehensive note in the that says yes
there was a discrepancy we investigated it there’s nothing we need to do
about it and that’s the end of it and this would go in the tenant file
so you want to make sure at any point that you are seeing these reports
or with a recertification that your tenant has the opportunity to review
it and to dispute it if necessary particularly with the ARs you are now
going to make sure that you’ve documented that you always were supposed
to be letting your tenants look at the report but now Hut is very clear
that they want to see something that documents that the tenants had the
right and the opportunity to review these how that happens is a matter
of management policy I have seen some management companies that just
have the resident sign a copy of the I report the one that’s in the file
indicating that they looked at it some people do a separate
acknowledgement just for eiv and some people will put that in the the
acknowledgement of the forms that somebody gets at research that list in
there I had an opportunity to review my eiv report but you’re going to
want to be putting something in the file that shows everyone that you
gave that tenant an opportunity to review and to dispute it if they
wanted to if they dispute the information in eiv you’re going to look
for additional documentation another one of the findings that we see
very frequently is conflicting information we get in the habit in
housing of more documentation is always better and unfortunately in this
case it’s not because you can get yourself in a position where you have
two conflicting sources of information let let’s say I’m doing a
certification in October and I pull eiv and eiv is a number that is not
accurate for January because that’s when Cola is going to kick in so I
also take the award letter when my tenant gets it where we have a
problem is when I do eiv plus the cola versus the award letter they may
different numbers or you’ll see that eiv is rounded numbers and a
statement of benefits may have pennies and those are conflicting sources
so if you have eiv and it’s accurate you always want to use the and you
can get rid of any extra documentation that you have however your
company does that usually it’s shredding and you can note that duplicate
information had eiv award letter shredded on xate or you can return it
to your tenant but you want to have one source of information that’s
accurate if you have a dispute you may need to get additional sources of
information you’re also going to note tenant disputed eiv they said they
were getting $1,250.00 to somebody that would never have seen your file
before so the goal is I should be able to go into your file and know
exactly what’s going on so remember again when you’re getting your M you
want your reviewer to be able to get in get through those files quickly
and easily and then leave as early as possible because you want to get
back to your work you have a lot of things going on and the less time we
have to spend reviewing it means more time for you to get back to your
work so always use one source of information that’s accurate usually eiv
the exception to that is sometimes when you have multiple regulatory
bodies at your property you really do want to be keeping separate mostly
duplicate files for multiple regulatory bodies for instance USDA um tax
credit and some of the State bodies they technically cannot see what’s
an eiv they’re not authorized to see those printouts so you want to make
sure they’re not seeing the eiv things and those of us looking at HUD
compliance are not really supposed to be looking at other regulatory
body documents so it’s a really good idea to have some way that people
who are reviewing HUD compliance only see HUD documents people who are
looking at say lihtc compliance are only seeing the relevant documents
they have in some cases that means you’re going to make be making two
copies of things birth certificates social security cards but in some
cases there are documents that are signed for one regulatory body that
are not going to be signed for another regulatory body that is all I
have for you today again my contact information for me and for Vicky
Bell our other corporate trainer is on the slide up here and please
don’t hesitate to reach out to your local navigate reps or to us if you
have any questions thanks and see you next time