hello and welcome to another episode of Tuesday tips I’m Pam kowas and
today as part of our mastering the series we’re going to be looking at
tenant files one of the most common questions that we get when it comes
to tenant files is what should my files look like what order should be
things be in the answer to that is that HUD does not have a particular
order so that means that it’s up to you to decide what order your files
are going to be in there are a couple of common options we generally
either see people using a divided file so one of the files with a
different number of dividers in it and then they section it off as per
owner agent policy or we see some people that put their tenant files
into a binder again divided by sections there is no right way to do this
some section by year some will section by typee of document so they’ll
have say all of the leases in one place um all of the moving things in
one place so it’s really up to the owner agent to set the particular
order of a file what we do look at though is what those tenant files
should have so not necessarily what order they should be in but what
needs to be in there so some of the things that need to be in there
include your application screening and movein information so everything
from the point that someone applied to the point that they moved in
including that after moveing eiv report you’re also going to have in
that the most recent three years worth of certifications so the current
year and then two full previous years based on the tenants certification
date then again everything related to that movein in the tenant file
should be anything related to any eiv discrepancies that you found and
resolved and then any of your eiv income and summary reports included as
part of movein annual and then interims if you are currently doing those
then there are some things that should really not be in your tenant file
so the things that you do not want in your tenant file are one duplicate
or conflicting information this is a common source of questions and
potentially findings at your and what I mean by duplicate or conflicting
information is for instance let’s say that the tenant gave you their
yearly e uh social security statement and you also pulled eiv if the
social security benefit letter says they’re getting $1,000 and10 and the
EI report says $1,000 that’s conflicting information so as long as the
information is accurate in eiv that’s what you should be seeing and then
if you have gotten anything in the process that conflicts with that just
by virtue of having pennies you can get rid of that another thing that
should not be in there is vawa information vawa information has specific
guidelines on protection so you want to make sure that that is either
sealed in an envelope so that people can’t see it or preferably in a
completely different file so that it’s not in the active tenant file
that people are reviewing you want to be very careful about irrelevant
information information that we’re not using you don’t want to have
copies of actual Social Security checks in the file and you don’t want
to have things like specific disability diagnosis so I may need to know
whether somebody qualifies as disabled or whether they have a need for
the features of an adapted unit but I don’t need to know what their
specific medical diagnosis is and then you want to be careful of
information that is related to a different regulatory body this is
particularly concerning with tax credit properties so generally speaking
you’re having two files you’re having your tax credit file and your HUD
file if you have both of those regulatory bodies you can certainly to
make your life easier copy the information and then just place a copy in
each of those files but lihtc reviewers really shouldn’t be seeing your
HUD information and your HUD reviewers really don’t need to see your tax
credit information so be careful of that when you’re doing files as well
one reminder here is that when we are looking to verify Social Security
numbers a common misconception is that you have to get a copy of the
social security card you do not HUD actually specifically says it’s not
mandatory that the card itself be copied what you need is something that
verifies the number and there are a few different ways that you can do
that if you take a look at appendix 3 and the 4350.3 that will give you
a number of different ways that you can verify so I do have a slide that
shows you that so here we go this is the appendix 3 it’s hard to read
because it’s very small but if you go into the 4350.3 whether you have
that electronically or by paper and you look for appendex 3 which is
going to be in the back of the handbook you can see that HUD gives you a
list of all the different things you can use to verify it’s not a bad
idea to keep a copy of this handy so that when you’re looking at
documents that your tenant has given you especially in those short time
to process certifications you can look at the different things that you
can use to verify one caveat on that though is that hotma may change
this so you do want to be aware of that as well this right here has
drilled down into what the appendix 3 says about social security numbers
so you’ll see there are a number of different things that we can get we
can look at the original social security card um an original document
issued by another agency that shows the social security number or um
some of the what used to be called tpq benefit printouts from Social
Security will have the number on it there are some drivers’s licenses
that print Social Security numbers on them depending on what state
you’re in so if the tenant for any reason does not want to give you
their social security number or card or if the applicant doesn’t want to
do that you can look for other methods of verifying you just need to
make sure that you have something that verifies that social security
number when it comes to verifying disability you have to be very careful
about what specific information is in the file you need to know that
somebody is disabled and needs what they’re asking for but you don’t
necessarily need to know their specific diagnosis or the specific nature
or extent remember of disability so we all know that the doctors and you
know other healthc care providers out there tend to provide us with the
notes if you get a note instead of the verification form that will
contain information we don’t need they’ll say things like Mary has been
diagnosed with multiple sclerosis and has X Y and Z limitation and takes
X Y and Z medication we don’t need to know all that we need to know yes
she has a disability and yes she qualifies for an adapted unit so should
you get a healthc care provider letter that has all sorts of information
that you don’t need you want to be careful to exclude that from the file
you can do that one of two ways you can redact it which means you would
just black out the name of the specific diagnosis or you know the
information that you don’t need and then note the file that you’ve
redacted that specific information or you can keep the specific note in
a separate file and make a note in the tenant file that states physician
provided note that confirms that the person has a disability and go from
there so again what you need to know is does the indiv idual meet the
definition do they either need what they’re asking for when it’s an
accommodation or modification or do they qualify for a specific unit
there are some projects where eligibility for the project or for
specific unit is tied to whether that person has a disability or in some
cases has a particular type of disability so the ideal way to get that
is to send out a set verification form that only gathers the information
you need but you do often get those notes and you just want to check
them you may need to ask is the disability permanent or not um there are
sometimes where a person has a disability but may get surgery to correct
it or you know for some other reason may not remain disabled for the
rest of their life so you may need to be asking if it’s not perent how
long is it expected to last and again as long as you’re not asking for
what is their disability you know those are the questions that you can
ask and the information you want the file so here’s an example of a
physician’s note I’ve treated Janes SMI for the last 10 years she
suffers from multiple sclerosis she can’t ambulate without assistance
uses a wheelchair Walker or cane and she requires an accessible unit in
parking space so there’s information I need there and information I
don’t need in there so I’m going to redact that I’ve treated jange mitt
for the last 10 years she suffers from and I’ve taken out the diagnosis
she uses I don’t need to know what specific uh equipment that she uses
therefore she requires an accessible unit in parking space right so I
know she’s disabled she needs a parking space and then you’ll see
there’s a note at the bottom here this is the note that I would put in
the file it basically just references specific information on disability
has been redacted physicians’s confirmed she’s disabled and she needs
what she’s asking for sign and date okay so that’s an example of a
redacted one if items are kept separately here’s the kind of note you
could put in the file uh tenant voluntarily provided a copy of a letter
but that indicates you know a lot of information that I don’t need and
after review we’ve decided that yes it confirms the existence of a
disability yes it confirms the need sign and date so in this case that
actual note is going to be kept wherever I keep you know personal
correspondence things like that and this note is going to be kept in the
file that way if somebody needs to see that original note you have it
but in the file that’s being reviewed you don’t have information that
doesn’t necessarily need to be there so when you’re organizing that file
there are some helpful hints to to keep in mind one file items promptly
don’t stick them in there loose and intend to file them later we all
know that housing is a very busy Arena and it’s very difficult sometimes
to get back to things later so file items promptly and file them
securely do not leave loose paperwork in your file it’s very easy for
things to missing and it makes your file more difficult to review make
sure that you have a consistent order for your files that’s generally
sent by the management agent who will say this is our file order this is
what sections we have but make sure that you’re following that order
consistently and secure your files appropriately depending on what your
policies are that could mean a locked drawer in a locked cabinet could
just mean a a locked cabinet a locked office and you want to make sure
that you are limiting access to appropriate personnel so you want to
make sure that only the people who should be in there have access to
those files further tips cover sheets are very helpful or a file guide
they’re not required but it does help when we are reviewing your files
to have a general idea of what order we should see things in some people
do a cover sheet for each section some just have a file system guide
that they will give us but it does really help to have that so we can
get through your files quickly and easily another thing to note is that
depending on what file system you were using you know the secured files
with the clips or a binder it may be more helpful to have single sided
copies rather than double-sided I know that we all want to save paper
but double-sided copies often make the file a little hard to review and
sometimes that can result in things not being seen so you always want to
think of making that file easy to navigate easy to find things that we
want to see one of the common questions we also get too is what do we do
with rsc’s who need to see eiv copies because sometimes rsc’s are
helping with benefits and need Social Security information rsc’s your
resident services coordinators may not see eiv printouts unless that
happens with tenant consent the best way to do that is to provide a copy
to your tenant and let the tenant provide it to the RSC generally you’re
not going to use that third-party eiv consent with your own staff so it
is always a safer bet to provide a tenant with a copy that they can
share to the with the RSC if they want to you want to make sure that you
are making notes and using consent forms if you are providing any copies
of anything in the file to a third party um HUD does not dictate
anything other than the eiv thirdparty form so anything other than that
you are going to be providing on whatever the owner Agent form for
release is and again we talked about multiple regulatory bodies for
files before USDA lhtc Personnel none of them at present can see actual
eiv printouts unless a tenant is discussing it with them and wants to
share that so you are going to potentially put a note in the file let’s
say I have a USDA property with a HUD subsidy as far as Social Security
verification goes I am either going to get an award letter and use that
from my USDA file or write a note in there that I have used the IV
system and I verified that the social security amount is X um some
regulatory bodies will accept that others may not be as willing to
accept that so you may need to get some other proof like an award letter
what do we do about prior errors that we can’t fix either things that
happened under another management company or things that happened with
our staff but happened 5 years ago and there’s no way to fix them the
best thing that you can do with these is when you come across something
like that note the file put a note in there that says what happened and
what you did to address it so for instance I noticed that the existing
tenant search wasn’t run for an applicant when I’m looking at that file
as the owner agent I’m going to go into that file and go oh we didn’t
run that check so I’m going to put a note in the file that says noted
during a quality assurance review or during you know processing an
annual research whatever it was we noted that the existing tenant search
was not run for this applicant you’re going to then advise of the
corrective action um if I’m the regional I might say reviewed eiv
policies with existing staff and in the future this is how we’re going
to ensure that that doesn’t happen again in some cases when you do that
you’ve noted that there was an error you identified it you fixed it it
may mitigate or lower the the points if you will lower the severity of a
finding because you have identified the problem and addressed it so you
always want to do that if you come across prior errors so I have a
couple of examples for you first one is you know owner agent review
noted that existing tenant search was not run for this applicant’s move
in we attended eiv training on a particular date eight we reviewed the
requirements with the staff and moving forward this is going to be run
for everybody sign and date there’s another one for a 90day eiv report
this report wasn’t run for this tenants mve in this movement occurred
under a prior management company sign in date and as I said in some
cases that’s going to either mitigate or kind of temper that finding
because you’ve already noted it addressed it corrected it so in summary
looking at these files again the owner agent sets the order you just
want to make sure that the file order is consistent for all your files
you want to have the most recent three years plus the movein and the
move out if it’s a move out file with the move outs make sure you have
your final account statement whatever your final paperwork is that you
hand out to 10 when they move out final account statement a letter with
security deposit information on it whatever it is that you do for a move
out make sure that’s in your moveout files ensure that you’re filing
your paperwork promptly and securing any loose paperwork make sure that
you’re noting any unusual situations or unfixable errors remove any
unused duplicate conflicting information from the file if there’s
conflicting information for a legitimate reason let’s say your tenant
has reviewed their eiv print out with you and says no that’s a not
accurate my benefit amount just changed so you asked them to bring in a
a benefit letter and both of those are in the file for a legitimate
reason make sure you’re noting that tenant reviewed the eiv printout
said it wasn’t accurate so I asked for follow-up documentation and this
is what I got you want to make sure your files are secured so only those
people who should see them see them and the best thing to keep in mind
when you’re deciding how to do these tenant files is your file should
tell a complete story anybody that is coming in to look at your file or
if you think of somebody covering your office should be able to pick up
that file and know the complete story why did you count what you counted
why didn’t you count X y or Z why are there two pieces of information in
here that say different things you’re having your file tell a story that
is this is why I did what I did this is why I have the amounts that I
have and that kind of prevents any questions on why something’s in there
why you use this number that’s going to help you to have your reviewer
get in your building through your files and out of building as quickly
and efficiently as possible which is all of our goals we don’t want to
keep you away from your work any longer than we have to to do this
review and we want to give you a chance to shine at your review and show
us how well you’re managing this very complicated business that we’re in
so that is going to do it for today as always you can contact us you can
contact Vicky Bell our other trainer or me with the information that’s
on the screen thank you for joining us for this Tuesday tip and we’ll
see you next [Music]