The CA Quarterly Review (Summer 2022)

THE NEWS QUARTERLY FOR OWNERS AND AGENTS OF THE PERFORMANCE BASED CONTRACT ADMINISTRATION FOR Ohio & washington DC

 

From the Desk of DeAnne Foy, General Manager of Contract Administration


DeAnne

Welcome to the Summer 2022 Edition of CA Quarterly Review. 

During the summer months, our calendars tend to fill up rather quickly with parties, reunions, and outdoor activities. I encourage you to squeeze in some time to do an activity that recharges your internal battery. Maybe it is going for a hike, visiting a salt float spa (or creating your own), camping, or taking a meditation yoga class. Do whatever it is that relaxes you. Life can be hard at times, and it is important to refresh, renew and refocus our energy. Sometimes just resting is the most productive thing we can do.

We on the CMHA-AHSC team are so proud of our CEO, Charles D. Hillman, who was listed among Columbus Business First’s Power 100 most influential leaders. At a time in which we are enduring skyrocketing rents across the spectrum of affordable housing, coupled with a shortage of suitable units, we know we can count on Charles’ leadership.  His determination to providing safe and affordable housing, using innovative solutions, is to be admired. AHSC’s partnerships with Owners /Agents, CGI, and HUD through the PBCA contract is one of our greatest tools and we are very grateful for this collaboration.

Please include this information packed issue on your summer reading list. It includes important details about the Affordable Connectivity Program, data security, and lead based paint compliance, among several other topics. 
Have a wonderful, relaxing summer. By the way, for my summer activity I will be trying paddleboard yoga, we’ll see how that goes!

 

DeAnne Foy
General Manager of Contract Administration, Ohio and Washington, D.C.

Affordable Connectivity Program 


There is a new federal subsidy program that can help your residents pay for internet service.  The Affordable Connectivity Program, offered through many internet service providers, gives households $30 a month to cover the cost of internet service and a one-time subsidy of $100 for computer devices for eligible households.  

Public housing and Section 8 residents are eligible for ACP funding based on their receiving housing assistance, and the ACP subsidy is not considered income. To date, public housing residents are under-enrolled in the ACP program. Owners and Agents are encouraged make residents aware of this subsidy as it would increase their internet connectivity without added expense.


To assist with this, HUD has developed a Mini-Guide to the ACP to help staff conduct outreach and enrollment events. This guide covers:

• An overview of the program
• Tips and best practices from two PHAs that are actively enrolling residents in ACP
• Links to additional materials, including informational flyers in a variety of languages.

We hope you will make use of this resource to help your residents connect to this invaluable benefit. For more information, view the ACP Fact Sheet and read the Press Release.

If you need assistance, please contact connecthome@hud.gov.

 
Data Security 

 

Data Security refers to the protective measures of securing data from unapproved access and data corruption.  It is essential to safeguard all of your data both physically and on-line.  HUD requires that Owner/Agents protect the privacy of individual’s information and has provided some suggested guidance to better assist in enhancing the data security measures at your property.  The steps that will be discussed to help ensure guidance include:

  • Create (and adhere to) a written policy and procedures manual.
  • Review HUD policy for safeguarding Personal Identifying Information (PII)
  • Attend Security trainings
  • Never send a document to the PBCA with PII data security

 

Protecting Privacy Information

The Department of Housing and Urban Development (HUD) is committed to protecting the privacy of individuals’ information, stored electronically or in paper form, in accordance with the Privacy Act of 1974, as amended, and other federal privacy-related laws, guidance, and best practices. HUD expects its third party business partners who collect, use, maintain, or disseminate HUD information to protect the privacy of that information.  Definitions that will be used through this article include:

  • Personally Identifiable Information (PII). Defined in OMB M-07-16 as “...information which can be used to distinguish or trace an individual’s identity, such as their name, social security number, biometric records, etc., alone, or when combined with other personal or identifying information which is linked or linkable to a specific individual, such as date and place of birth, mother’s maiden name, etc.”
  • Sensitive Personally Identifiable Information (SPII). PII that when lost, compromised or disclosed could substantially harm an individual. Examples of sensitive PII include social security or driver’s license numbers, medical records, and financial account numbers (credit or debit card numbers).

Create a Written Data Security Policy

Chapter Nine, Section Four of the HUD Occupancy Handbook (4350.3) provides the guidance and security requirements that properties need to implement to safeguard EIV data.  However, EIV policies and procedures should be a subset of an overall strategy and policy handbook to safeguard all potential tenant/applicant PII that HUD requires to be collected and maintained.


As the opening paragraph reminds, data security is much more than protecting PII, a comprehensive policy should discuss Phishing attempts, using Social Media, and protecting all forms of sensitive information that is maintained in your place of business.  We strongly recommend a comprehensive written policy that takes into consideration multiple HUD sources that we will discuss in this article.

Review HUD Policy

HUD has created and published numerous handbooks and materials that discuss the various requirements for data security.  When creating a comprehensive plan, be sure, at minimum to review these resources:

  • HUD Handbook 4350.3 Rev-1 Change 4: Chapter 9 section four contains the required information to safeguard HUD’s EIV information.  
  • HUD Handbook 4350.3 Rev-1 Change 4: Chapter 5 paragraphs 5-19, 5-20, 5-23 discuss the framework to ensure privacy of applicant and tenant information 
  • HUD Handbook 4350.3 Rev-1 Change 4: Chapter 8 paragraph 8-14 emphasizes the importance of privacy requirements when obtaining criminal background reports and , 8-20 discusses EIV income reports 
  • Chapter Four of the EIV Multifamily Program User Manual provides specific Security information and guidance that must be adhered to when developing Policies and Procedures.
  • The Security Administration Manual for EIV Systems provides an overview and details the process for how access to the EIV system is granted.  The guidance found within this document should be reviewed when determining who to grant access to EIV, how to grant the applicable access, and how to terminate that access.
  • HUD Handbook 2400.25 TECHNOLOGY SECURITY POLICY is the comprehensive overview of all of HUD’s policies and safeguards.  This handbook should be reviewed by the person developing the project’s policy and procedures documents as well as the person/company responsible for maintaining the property’s computer system.

The most succinct publication for protecting privacy information can be found in HUD’s 2015 Protecting PII Capacity Building Guidance document distributed by HUD.  For your convenience, we have summarized this document’s guidance here:

Manage Access to Sensitive PII

  1. Only share or discuss sensitive PII with those who have a need to know for work purposes.
  2. Do not distribute or release sensitive PII to others until the release is authorized.
  3. Before discussing sensitive PII on the telephone, confirm that you are speaking to the right person and inform him/her that the discussion will include sensitive PII. Do not leave messages containing sensitive PII on voicemail.
  4. Avoid discussing sensitive PII if there are unauthorized persons in the adjacent cubicles, rooms, or hallways who may overhear your conversations.
  5. Hold meetings in secure spaces (no unauthorized access or eavesdropping possible) if sensitive PII will be discussed.
  6. Treat notes and minutes from such meetings as confidential unless you can verify that they do not contain sensitive PII. Record date, time, place, subject, chairperson, and attendees at any meeting involving sensitive PII.

 

Protect Hard Copy and Electronic Files Containing Sensitive PII

  1. Clearly label all files containing sensitive PII. Examples of appropriate labels might include – For Official Use Only, or For [Name of Individual/Office] Use only.
  2. Lock up all hard copy files containing sensitive PII in secured file cabinets. Do not leave sensitive PII in an open area unattended.
  3. Protect all media (e.g., thumb drives, CDs, etc.) that contain sensitive PII and do not leave unattended. This information should be maintained either in secured file cabinets or in computers that have been secured.
  4. Keep accurate records of where PII is stored, used and maintained.
  5. Periodically audit all sensitive PII holdings to make sure that all such information can be readily located.
  6. Secure digital copies of files containing sensitive PII. Protections include encryption, implementing enhanced authentication mechanisms such as two-factor authentication and limiting the number of people allowed access to the files.
  7. Store sensitive PII only on workstations that can be secured, such as workstations located in areas that have restricted physical access.

 

Protecting Electronic Transmissions of Sensitive PII via fax, email, etc.

  1. When faxing sensitive PII, use the date stamp function, confirm the fax number, verify that the intended recipient is available, and confirm that he/she has received the fax. Ensure that none of the transmission is stored in memory on the fax machine, and that all paper waste is disposed of properly (shredded). If possible, use a fax machine that uses a secure transmission line.
  2. When sending sensitive PII via email or via an unsecured information system, make sure the information and any attachments are encrypted.
  3. If a secure line is not available, contact the recipient office prior to faxing to inform them that information is coming. Then, contact the recipient office following transmission to ensure they received it. For each event, the best course of action is to limit access of PII only to those individuals authorized to handle it, create a paper trail, and to verify information reached its destination.
  4. Do not place PII on shared drives, multi-access calendars, the Intranet, or the Internet.
  5. Do not let PII documents sit on a printer where unauthorized employees or contractors can have access to the information.

 

Protecting Hard Copy Files Containing Sensitive PII

  1. Do not remove records with sensitive PII from facilities where HUD information is authorized to be stored, or access remotely (i.e., from locations other than such physical facilities), unless approval is first obtained from a supervisor.
  2. Do not use interoffice or translucent envelopes to mail sensitive PII. Use sealable opaque solid envelopes. Mark the envelope to the person’s attention
  3. When using the U.S. postal service to deliver information with sensitive PII, double wrap the document (use two envelopes – one inside the other)and mark only the inside envelope as confidential with the statement – To Be Opened by Addressee Only.
  4. If PII needs to be sent by courier, mark “signature required” when sending documents, in order to create a paper trail in the event items are misplaced or lost.

 

Records Management, Retention and Disposition

  1. Follow all applicable records management laws, regulations, and policies.
  2. Do not maintain records longer than required.
  3. Destroy records after retention requirements are met.
  4. Dispose of sensitive PII appropriately – permanently erase electronic records. Shred hard copy records.

 

Attend Additional Security Trainings

HUD requires all TRACS users and EIV users (or those that view EIV reports) to sign a Rules of Behavior form and complete an annual security awareness training.  Users must complete the FY2022 Cyber Awareness Challenge.  Users are reminded of the requirement to print and maintain the certificate as this will be requested during the onsite portion of the MOR.

In addition to the required training session, there are a few additional trainings located at the IASE web page.  It is highly suggested to have staff members also complete the following training modules.


Phishing Awareness Version 4.

This training was created to enable users to recognize phishing, spear phishing, and whaling attempts, determine the steps to take when targeted in a phishing attempt, and to take appropriate actions to avoid the potential losses that these social engineering scams can cause. The user is provided with examples of different types of phishing, as well as techniques used to conduct phishing, including deceptive e-mails, websites, and browser “tab nabbing”. Finally, the course reviews ways to combat phishing attempts, even from people within their own organization. (Length - 30 Min) 

​Identifying and Safeguarding Personally Identifiable Information (PII) Version 3

This course explains the responsibilities for safeguarding PII and PHI on both the organizational and individual levels, examines the authorized and unauthorized use and disclosure of PII and PHI, and the organizational and individual penalties for not complying with the policies governing PII and PHI maintenance and protection. This training is intended for DoD civilians, military members, and contractors using DoD information systems. This course may also be used by other Federal Agencies. (Length - 1 hr) 

Never send a document to your PBCA that contains PII that has not been redacted

Despite the information contained within our letters and reports, there are still occasions when Owners will send documents to the PBCA that contain PII.  Please update your procedures to address the following concerns.

MOR responses

Never send a paper certification to respond to a finding on an MOR.  All corrected certifications can be reviewed and verified within our vouchering software.  The finding will be closed out once the corrected certification is transmitted and approved via the typical vouchering protocol.

Never send any form of EIV report with your response.  Although the Handbook and HUD specifically focus on income reports when discussing PII, the PBCA requests that no EIV reports are ever electronically submitted to the PBCA.  The PBCA, if needed, can either verify via the EIV system or via the tenant file documentation during a subsequent visit to the property.

Special Claims Submissions

In our experience, the single largest breach of HUD’s security policy occurs when Owner/Agents submit materials to support a special claim.  Prior to sending information to the PBCA, REDACT all information from Section C, Section D, and Section E from the MI 50059.  This information is not required for the review and approval of the special claim.

In addition to this specific item, ensure that all potential Personal Information is redacted from all documents sent to support a special claim.  If in doubt, redact from the document prior to submission and error on safeguarding tenant PII.  If needed, the PBCA can follow-up with a phone call to discuss a specific omission.

Take a moment to review the policies and procedures that are currently in place at your property, review the resources that have been mentioned in this article, update your documents accordingly, and disseminate/educate all of your employees of the expectations to maintain the integrity of the data security at your place of business.  

Remember, in today’s world it is easy to be tricked, and it only takes once.  When in doubt, always ask questions.  Request the caller’s contact information, they will either hang up, or give it to you.  Reach out to HUD, provide the information to the Account Executive, and enable the AE to respond.

Unique Entity Identifier Replacing DUNS for LOCCS Users

 

As a reminder for HUD Line of Credit Control (LOCCS) users, as of April 4, 2022, the federal government is no longer using the Dun & Bradstreet data universal numbering system (DUNS) for identification for federal awards.  Instead they will utilize the new Unique Entity Identifier (UEI) for identification for federal awards.  Entities must be registered in SAM.gov to qualify for federal awards that are reported to the public through USASpending.gov. 

If you have not already registered or if your registration has expired, please register immediately. The General Services Administration (GSA) has provided tools that will assist you in registering your entity and obtaining a DUNS/UEI. Visit the GSA SAM web site that contains a number of resources related to the UEI implementation.

Watch a webinar from November 3, 2021, concerning the changes.

You can also go to fsd.gov and select the green "Help on UEI Transition" button to learn more.

FY 2022 Income Limits

 

HUD has published 2022 income limits Effective 4/18/2022. Owner/Agents must ensure that they utilize these income limits for files with certifications dated 4/18/2022 and after. Click here to see new limits.

Please keep in mind the RHIIP Listserv #293 - Timing of Income Eligibility Determinations - Clarification to Existing Policy Published on 12/19/2012. 

The RHIIP guidance specifically states: if a unit becomes available and an applicant is selected from the waiting list, is processed for eligibility, and meets all eligibility requirements at the time of processing, the applicant is eligible to move-in to the project even if new income limits have been published.

Withdrawal of "Clarification of Valuation on Non-Shelter Services" Memo 

 

Please see HUD’s Memorandum that withdraws HUD's "Clarification on Valuation of Non Shelter Services" memo dated November 15, 2021.

HUD expects to more fully address the issues that led to the release of this memo, as well as questions and concerns arising from the memo, in upcoming draft revisions to Chapter 9 of the Section 8 Renewal Policy Guidebook. These revisions will be available for public review and comment prior to taking effect.

Lead-Based Paint Compliance  

 

If your property was built prior to January 1, 1978, residents may be at risk of exposure to lead-based paint. Children under the age of six are especially at risk of harm due to lead based paint, as they are more likely to ingest the toxin from hand to mouth contact, toy to mouth contact from chipping paint, chewable surfaces or barren soil. 

Chances are you have already addressed the potential of lead-based paint at your property and are either certified lead free or have an on-going lead abatement or hazard control plan.  During your Management and Occupancy Review (MOR), the reviewer will examine your compliance with the Lead Safe Housing Rule.

This article will review the evaluation and disclosure requirements of the Lead Safe Housing Rule and documentation you are required to have available during your MOR to demonstrate your compliance with the Lead Safe Housing Rule.   

Applicability

Properties built before January 1, 1978 must comply with the Lead Safe House Rule. 

The lead based paint rules do not apply to any housing built on or after January 1, 1978, zero bedroom units or efficiencies, any housing where the leases are less than 100 days, housing for the elderly or disabled (unless a child under 6 resides there), or housing that is certified “lead free”. 

Evaluation Requirements

First and foremost, your property must be, where applicable, free of lead hazards or has an ongoing plan to mitigate and control the lead with the ultimate goal of abatement. Most property owners who have properties with lead-based paint have already taken steps to begin abatement, if not already certified lead-free altogether, but for those who have not, the first step is to have a certified inspector come and conduct a formal risk assessment and evaluation. Remember, only a certified professional is qualified to consult you on the risk assessment. 

Your certified risk assessor, planner or designer will then develop a site-specific hazard control plan. The plan should be based on the hazards identified, feasibility of the control measures, occupancy of young children and financing. Measures to mitigate or control lead-based paint must be taken throughout the life of the property.  Those measures vary depending upon the amount of housing assistance the project receives and include: 

  • Visual assessments to identify deteriorated paint or (for assistance over $5,000 per unit annually) risk assessments to identify lead-based paint hazards; 
  • Paint stabilization or (for assistance over $5,000 per unit annually) interim controls with clearance testing when appropriate; 
  • Ongoing lead-based paint maintenance to identify hazards (Lead Hazard Control Plan);
  • Re-evaluation conducted every two years by a certified professional to identify hazards; 
  • Notification of tenants about the actions above; and 
  • Special actions when a child under six years old is reported to have high blood lead levels. 

 

If your property has on ongoing Lead Hazard Control Plan, you must maintain documentation of your compliance with the plan (documentation of the interim controls, visual inspections, maintenance, tenant notifications etc.). 

Disclosure Requirements LBP Pamphlet

If the lead based paint requirements apply to your property, you will need to disclose any known information concerning lead paint and lead hazards to your residents, which includes, but is not limited to, disclosing the location of known lead-based paint, and the condition of painted surfaces. You will also need to keep your residents informed of any reports or records concerning lead based paint in the units and common areas when the information is available as a result of a building wide evaluation. 

Residents must be given an informational pamphlet titled, “Protect Your Family from Lead in Your Home.” You must also include an attachment to the lease that includes a lead warning statement and confirms that the owner is in compliance with the lead-based paint notification requirements. 

 

Demonstrating Lead-based Paint Compliance during the MOR

During your MOR, you will be required to provide documentation to demonstrate your compliance with the Lead Safe Housing Rule.  Below are examples of documents that you should maintain onsite and have available for review:

Properties Claiming Lead Free Status:

The reviewer will ask you to produce the certified lead-based paint inspector’s documentation of the status of lead hazards. In order to be considered “lead free”, you must obtain an official certification from a certified lead-based paint inspector (as certified by the state or EPA). An owner’s self-certification that the property is lead free is not sufficient proof that the property is free of lead hazards. 

HUD provided clarification that not all certified LBP consultants provide a Lead-Based Paint Free “Certificate.” HUD does not require a certificate as demonstration of a property being LBP free and exemption from the rules. HUD guide-lines suggest the use of the following language in the report, which would be satisfactory to determine that the property is lead based paint free: 

  • “The results of this inspection indicate that no lead in amounts greater than or equal to 1.0 mg/ cm2 in paint was found on any building components, using the inspection protocol in chapter 7 of the HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing.” 

 

“Elderly” or “Disabled” Properties:

If your property is “elderly” or “disabled”, the reviewer will ask if you have any children under the age of six in residence. If you have a child under the age of six residing at your “elderly” or “disabled” property, please keep in mind that the regulations apply to the dwelling unit in which the child resides, any common areas servicing such dwelling unit, and exterior painted surfaces associated with such dwelling unit or common areas. HUD expects that, if numerous exceptions are made to allow young children to reside in a property designated for occupancy by the elderly or persons with disabilities, the exemption from the regulation would no longer be available and the regulation would apply to the entire property. 

Properties built before January 1, 1978 that were identified as containing lead or lead hazards:

If your property receives an average of more than $5,000 per unit annually in project-based assistance, the reviewer will ask that you produce:

  • The initial risk assessment completed by a certified risk assessor and documentation that the required hazard reduction activities and subsequent clearance examination were completed, if applicable. 
  • The property’s Lead Hazard Control Plan and documentation that ongoing lead-based paint maintenance activities are being performed in accordance with the plan (interim controls, visual inspections, maintenance, tenant notifications etc.).  
  • Copies of the lead re-evaluation reports completed by a certified inspector or risk assessor every two years since the initial risk assessment was conducted.
  • Notifications provided to tenants regarding the above actions, if applicable.
  • Documentation relating to special actions taken when a child under six is reported to have high blood levels, if applicable.

 

If your property receives an average of $5,000 or less per unit annually in project-based assistance, the reviewer will ask that you produce:

  • The initial visual assessment, the results of the assessment, and paint stabilization activities completed to eliminate lead hazards, if applicable.   
  • The property’s Lead Hazard Control Plan and documentation that ongoing lead-based paint maintenance activities are being performed in accordance with the plan (interim controls, visual inspections, maintenance, tenant notifications etc.).  
  • Copies of the lead re-evaluation reports completed by a certified inspector or risk assessor every two years since the initial risk assessment was conducted.
  • Notifications provided to tenants regarding the above actions, if applicable.
  • Documentation relating to special actions taken when a child under six is reported to have high blood levels, if applicable.

 

Disclosure Requirements disclosure form

If the lead based paint requirements apply to your property, the reviewer will confirm that the tenant file contains:

  • An acknowledgement form or copy of the pamphlet signed and dated by the tenant certifying that the “Protect Your Family from Lead in Your Home” pamphlet was given to the household at move-in.
  • An attachment to the lease that includes a lead warning statement and confirms that the owner is in compliance with the lead-based paint notification requirements. 

 

Tips to Avoid Lead-based Paint findings

  • Maintain a file or binder on-site that contains all required lead-based paint documents.  Locate any documents that you do not have currently.  
  • Ensure visual inspections are conducted and documentation is maintained and available for review.  All activities to eliminate hazards identified by the visual inspections are completed and documentation is maintained and available for review, if applicable.
  • Ensure required lead reevaluations are conducted every two years by a certified inspector or risk assessor.  If it has been longer than two years since a lead reevaluation has been performed - schedule one now!  Be sure that all activities to eliminate hazards identified by the reevaluation is carried out and a subsequent clearance examination is performed, if applicable.  Documentation of all activities must be maintained and available for review.  
  • Know the requirements for when a reevaluation is no longer required.  To be exempt from additional reevaluation, at least two consecutive reevaluations conducted at such two-year intervals must be conducted without finding lead-based paint hazards or a failure of an encapsulation or enclosure. If, however, a reevaluation finds lead-based paint hazards or a failure, at least two more consecutive reevaluations conducted at such two year intervals must be conducted without finding lead-based paint hazards or a failure.
  • If you are a new owner/agent of a property built prior to 1978, be sure to locate all required lead-based paint documents.  Being a new owner/agent will not prevent lead-based paint findings. 
  • Provide staff training on lead-based paint requirements!

 

Procedures in the Event of Resident Displacement and/or Property Damage 

 

HUD has acquired a great amount of knowledge and best practices over the past several years on how to efficiently respond to a Presidentially Declared Disaster (PDD).  As a result HUD has developed guidance that covers the many different aspects of servicing multifamily properties that were damaged or vacated as a result of a PDD.  This guidance also applies to all HUD insured/HUD assisted properties in situations where the Hub Director determines that an emergency exists.  

To remind you of the procedures and tools available for owners and residents impacted by natural disasters, HUD has developed the Multifamily Housing Guidance for Disaster Recovery website.  The information found here will make post-recovery efforts go more smoothly if an event occurs that impacts your residents and/or your property.

For your convenience, Chapter 38: Multifamily Emergency/Disaster Guidance, from HUD Handbook 4350.1 includes procedures to provide HUD staff, Owners, Management Agents, and communities with the tools that they need to react to emergency situations.  HUD encourages you to review this material before an event occurs. 

Following an event that impacts residents and/or properties, HUD has reporting obligations based on information staff obtains from Owners and Management Agents of HUD insured and/or assisted properties.  Owners and Management Agents are obligated to always immediately report physical damage to a property interior or exterior that has resulted from a fire, flood, wind, severe cold, or other natural disaster or weather event.  It is most convenient for all parties if Owners and Agents proactively report to HUD.  Owners are encouraged to complete and forward damage assessments to HUD.  Please use the forms as follows:  

  • For a FEMA Declared Emergency or Disaster:   Preliminary Disaster Assessment (Appendix A-3 of Chapter 38 of Handbook 4350.1.)   
  • For an Event not declared by FEMA:  Basic Damage Assessment

 

Please forward the appropriate Assessment Form within 24 hours of the damage.  Either form should be legibly handwritten and emailed to:

To find your assigned Account Executive, please go to the following website:

OHIO:

 

WASHINGTON, D.C.:


Updated reports should be submitted as additional information is available concerning resident displacement or regarding the level/amount of damage sustained.  While the Department is not a payee on an insurance loss draft for a property with an insured mortgage, HUD must still be notified of the event and any damage sustained to the property.  

OWNER RESPONSIBILITIES

Owners/agents are responsible for:

  • Developing an emergency relocation plan to relocate residents prior to the storm especially at 202/811 Elderly or Disabled Properties and nursing homes;  
  • Developing a pre-disaster checklist that is shared with tenants in case of a disaster;
  • Ensuring that the property and records are secured and that residents’ possessions and valuables are secured and protected to the greatest extent possible.  
  • Contacting FEMA for on-going guidance and instruct residents to register with FEMA through 1-800-621-FEMA (3362), or www.fema.gov.  
  • Applying for assistance with FEMA, Small Business Administration, Housing Finance Agency and others;
  • Contacting the local HUD office following a disaster;
  • Providing a status report for the residents and property condition;
  • Ensuring that residents provide EMERGENCY contact numbers;  
  • Determining the extent of damage, security needs, resident property protection needs, etc.
  • Contacting the property’s insurance provider to apply for property and business interruption claims;
  • Maintaining inventory of all residents, property, phone numbers, mailing address, and emails;  
  • Determining which residents have been displaced due to unit damage or a failure of a major building system such as the electrical system, etc.; and
  • Tracking each displaced resident’s temporary location and maintain contact information for each displaced resident, particularly if the property will likely have units off-line for more than 30 days. 

 

REMINDER TO OWNERS IN AFFECTED AREAS:

Owners should not evict tenants from their unit in order to make hurricane related repairs.   The Department encourages you to revisit the instructions provided in Chapter 38 of Handbook 4350.1 for related Emergency/Disaster Guidance.

Other Important Contact Information :

  • Federal Emergency Management Agency (FEMA) 1-800-621-3362 – https://www.fema.gov/
  • American Red Cross - http://www.redcross.org 1 800 RED CROSS (1-800-733-2767)
  • HUD's housing discrimination hotline: 800-669-9777 (Voice), 800-927-9275 (TTY).


OHIO

 

WASHINGTON, D.C.

 

Compliance with EIV

 

MOR Compliance – EIV Reportscompliance

The Management and Occupancy Review includes a thorough evaluation of how owner/agents are running and using EIV reports, whether or not they are documenting the actions they’ve undertaken to investigate discrepancies, and how they are storing the reports. To stay compliant with HUD Handbook 4350.3, Chapter 9, owner/agents must use EIV in its entirety, this means running the reports in accordance with Chapter 9 and your own policies and procedures. 

Owners and Agents must develop EIV policies and procedures. In that document, owner/agents must include written policies for running and maintaining all required EIV reports. 

HUD has outlined basic guidelines for the frequency in which the reports must be run; however, owner/agents can develop policies that increase the frequency of the reports. For instance, if the trend among the tenant population is to change jobs frequently, the owner/agent might find it beneficial to run the New Hires Report on a monthly basis as opposed to the basic requirement that it be run at least quarterly. 

A reminder for all new admissions, including the initial certification (IC), the owner/agent must review the Income report within 90 days after transmission of the move-in certification to TRACS to confirm/validate the income reported by the household. If there any income discrepancies as a result of the report, resolve any income discrepancies with the household within 30 days of the Income Report date. Print and retain the Income Report in the tenant file along with any documentation received to resolve the discrepancies, if applicable. 

The Master Binder/Files must be made available at the time of the management and occupancy review. The master files must be retained for three years. Once the retention period has expired, owners must dispose of the data in a manner that will prevent any unauthorized access to personal information. 

Owner/agents are encouraged to become familiar with all EIV requirements outlined in Chapter 9 of the HUD Handbook 4350.3.  The handbook includes Exhibit 9-5 which is a valuable resource on EIV report usage, file documentation, and retention requirements.

 

New Civil Rights Guidance on Marketing and Application Requirements for Subsidized Multifamily Housing Properties

 

In case you missed it, HUD issued Civil Rights guidance April 21, 2022 on marketing and application requirements for MF properties that applies to the more than 1.5 million HUD-subsidized multifamily units nationwide, including Project-Based Rental Assistance, Section 202, and Section 811 subsidized units. 
 
The guidance clarifies how certain marketing, rental application processing, and waitlist management practices can perpetuate segregation or otherwise discriminate in violation of Title VI of the Civil Rights Act, and can result in segregation or disparate outcomes based on race and national origin. The guidance informs housing providers about exclusionary practices to avoid and educates about inclusionary practices to employ to ensure meaningful opportunities for persons of all racial and national origin groups to learn about and participate in HUD-subsidized housing programs. 

“Today’s publication provides practical guidance to help property owners and managers to reach all members of their community,” said Ethan Handelman, HUD Deputy Assistant Secretary for Multifamily Housing Programs. “This is the latest step in the Department’s work to support our program participants in their efforts to make affordable housing available without barriers.”

For additional information, read the Title VI Marketing Guidance, the Implementation Sheet, and the Press Release. 
 

Member Spotlight

Anna Stewart

Anna Marie Stewart has worked in the PBCA contact center for 7 years, helping Resident’s and Management maintain safe and sanitary housing. Utilizing the HUD handbooks as reference to answer their questions and concerns.  She was recently promoted to a Call Center Supervisor.

Anna Marie worked as a Customer Service Manager and in the Food Distribution Industry for 30 years before coming to CGI to put her skills to use in the Housing Industry. She is an organizer and is willing to share her knowledge and organizing abilities with whoever asks or needs her assistance. 

Anna Marie enjoys spending time with her Grandchildren, going to their sporting events and spends much of her time with family. She and her sister have already started working on their bucket list of all of the places they want to visit again. It is a really long list and should take them into their 80’s.

Working for and with the PBCA is an educational experience, there is always something new every day. You know the saying, “Just when you thought you heard it all” is an everyday occurrence in the contact center. Resolving those type of concerns and hearing the relief or smile on the other end of the line is very satisfying.

Anna Marie believes just listening with empathy is a great asset and makes whoever she is talking to feel important. Everyone wants to feel their concern and what they have to say is important from the very young to the very old.

From Andrea, Anna’s Supervisor: Anna Marie Stewart’s tenure in customer service demonstrates her commitment and ability in resolving resident concerns while providing information that can be used in the future. Anna’s dedication to providing resolutions and building relationships is confirmed by the continuous positive comments of gratitude when closing calls. Anna is always willing to assist Management and her peers without request and her efforts are very much appreciated.
 

AHSC Contact Center Poster 

 

Assisted Housing Services Corporation (AHSC) has created a Customer Contact Center poster that our Owners and Agents of Section 8 Multifamily Housing can post in their rental office.  This poster will provide your residents with useful information, such as our business hours, contact information, and general issues that AHSC can assist with, including but not limited to:  

  • Answering questions about the calculation of a tenant’s rent
  • Assisting with clarifying HUD Occupancy Handbook 4350.3 requirements
  • Serving as a neutral third party to residents, property owners and management agents, and the general public

 

A downloadable version of the AHSC Contact Center Poster can be found on the AHSC Website following the links be-low.  Or you can find a copy from the Owner/Agent Knowledge Center on the AHSC Website, under the Management and Occupancy tab. 

 

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