Category: Affordable Housing

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Compliance Memorandum: 20 Most Common Physical Findings During An Audit

COMPLIANCE MEMORANDUM

 

TO: ALL MANAGERS

FROM: THE AFFORDABLE HOUSING COMPLIANCE DEPARTMENT

SUBJECT: 20 MOST COMMON PHYSICAL FINDINGS DURING AN AUDIT

DATE: 4/15/2013

CC: AFFORDABLE HOUSING COMPLIANCE DEPARTMENT; PORTFOLIO SUPERVISORS

 20 MOST COMMON PHYSICAL FINDINGS DURING AN AUDIT

Below you will find a list of the most common physical findings when your property is participating in an audit:

  • Drain stopper and pulls
  • Smoke Detectors
  • Egress Issues
  • Blocked Access to Electrical Panels
  • Carpet Fraying and/or Torn
  • Closet Doors Off and/or Off Track
  • Refrigerator and/or Freezer Door Bars Missing
  • Aerators
  • Towel Bar Missing or Broken
  • Caulking Around Bathtub
  • Overgrown Vegetation
  • Tripping Hazards
  • Siding or Soffits Missing or Damaged
  • Peeling Paint
  • Exterior Door Weather Stripping Damage
  • Sidewalk Spalling (i.e. crumbling, breaking, disrepair)
  • Patio Globes Missing
  • Ponding (i.e. pool of water in the middle of grass area)
  • Missing Interior Room Light Covers
  • Infestation—Bees, Insects, etc.

By utilizing this information in advance of an audit, necessary repairs can be made to prevent these common findings.

It may be beneficial to carry this list with you as you “walk your property” and look for the specific items listed.  Additionally, if you have maintenance staff, please share this list with them as well.

Thank you for helping Cambridge to maintain necessary property standards!

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Obtaining Social Security Verifications

compliance memorandum

TO: All managers

FROM: The compliance department

SUBJECT: Obtaining Social Security verifications

DATE: 4/9/2013

CC: Affordable housing compliance department; portfolio supervisors

obtaining social security verifications

In order to meet compliance standards, all verifications must be obtained within 120 days of the certification effective date; this includes Social Security benefits being received.

Oftentimes, the only benefit letter an applicant/resident will provide is the statement received at the end of each year informing them of their expected benefit amounts for the next year.  This letter may not fall within the 120 days and requires an updated letter be obtained.

In order to assist your applicants/residents with the process of obtaining a current Social Security benefit letter for verification purposes, please utilize the following information:

  • Online verification can be obtained through the following website: www.socialsecurity.gov/myaccount.  The applicant/tenant will need to set up an account if they don’t already have one.  If they are comfortable doing so and your time allows, this is an easy process and it may be beneficial to assist them in your office with this.  (This is the preferred method of the Social Security Administration as well as the quickest.)
  • Phone verification can be obtained by contacting the local SSA office.  To obtain the phone number for your local office follow these steps:
    • Go to www.socialsecurity.gov;
    • Click on Contact Us in the top right of the page;
    • Select Find an Office;
    • You will then be prompted to enter your ZIP Code half way down the page and need to click Locate.
    • This will provide you with the local telephone number as well as the address of the local SSA office.
    • If the applicant/resident is comfortable and your time allows, it may be beneficial to assist them in your office with this.
  • Phone verification can also be obtained by calling the main number at: 1.800.772.1213.  To speak to an SSA representative, you must call Monday through Friday, between 7 a.m. and 7 p.m.
  • Lastly, (and least preferred method by the SSA) is for the applicant/resident to go directly to the SSA office and request a print out.  Follow the steps outlined above for obtaining the local phone number, as this will also provide the address of the local SSA office.
  • Please remember, with the new changes in delivery of Social Security benefit payments, it is necessary to determine how the applicant/resident receives their payments.  Please refer to the Compliance Memo emailed on March 11, 2013 addressing this.  
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Dates on File Paperwork

As a friendly reminder, when reviewing and preparing files it is important to ensure the following:

  • For Tax Credit and HUD properties, the move-in and effective dates should match on page 1 of the TIC for move-ins. For RD properties, effective date of the TIC must be the 1st of the month (and the 1st of the next month if a household moves in after the 1st).
  • For Tax Credit and HUD properties, the move-in date on the Rental Agreement matches the move-in and effective date of the move-in TIC. For RD properties, effective date of the TIC must be the 1st of the month.
  • For Tax Credit and HUD properties, the effective date of the TIC should be the month and date of the move in but with the current year (ex. if a household moves in on 6/15/12 then the first recert effective date would be 6/15/13; the next recert effective date would be 6/15/14, etc.).
  •  If any form is signed after the effective date of the certification, write “True and accurate as of _______________ (the effective date)” on the bottom of each form necessary and have all residents over the age of 18 initial the statement(s).
  •  All household members over the age of 18 have the same signature dates on all forms.
  • Manager signature dates should be the same as the applicant’s / resident’s on all forms (certification paperwork and lease paperwork)

Should you have any questions, please feel free to contact Kristin Strong at kstrong@cambridgeres.com.

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Recertification and Preventative Maintenance Reminders

reminderYou should now be close to completing all recertifications due on April 1, 2013 in order to allow for a 30-day notice to be sent to those who have not responded to your 120, 90 and 60-day recertification reminders.

For those who still have outstanding recerts due for March 1st or sooner, please submit them as soon as possible to allow sufficient time for review, corrections (if necessary) and processing. If you are having difficulty getting residents to respond or they are being uncooperative in submitting critical information for their recertification, please contact your Supervisor immediately to determine the best course of action.

Also, please include a Preventative Maintenance Inspection Notification Form (Form C402 on eforms) with your 60-day reminders to your residents. This is a quick and easy way to help ensure that your property is in compliance and stays in good condition.

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Dates on Move-In Compliance Files

When reviewing and preparing move-in files, it is important to ensure the following:

For Tax Credit and HUD Properties

  •  Move-in and effective dates should always match on page 1 of the TIC for move-ins (see first Example below). example 1 square
  • The move-in date on the Rental Agreement should also match the move-in and effective date of the move-in TIC.

For RD Properties (Including those RD Properties with Tax Credits)

  •  For RD properties, the effective date of the TIC for a move in file must always be the 1st of the month, regardless if the move in occurred on the 1st of the month or not (see second example below).example 2
  • For RD properties, the move in date on the Rental Agreement should match the move in date on the 3560-8 while the effective date of the TIC must always be the 1st of the month.

For All Properties (Tax Credit, RD, HOME and HUD)

  • If any form is signed after the effective date of the certification, write “True and accurate as of _______________ (the effective date)” on the bottom of each form necessary and have all residents over the age of 18 initial the statement(s).
  • All household members over the age of 18 have the same signature dates on all forms.
  • Manager signature dates should be the same as the applicant’s / resident’s on all forms (certification paperwork and lease paperwork)
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Statement of Household Income

Effective immediately, please discontinue use of any version of the below forms from eforms. These forms are sent directly from a third-party annually for those properties with certain funding and therefore should not be used or completed from eforms.

We have requested these forms to be removed from eforms and should be within the next 24 – 48 hours.

If you have any questions, please contact Kristin Strong.

C474 lower-income households statement of family household income lower-income households statement of family household income

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HSA Accounts: Should We Count as an Asset?

Calculator & PencilThe definition of an asset is any item of economic value owned by an individual which could be converted to cash. Common examples are cash on hand; bank accounts including checking, savings; CDs and money market accounts; and real estate.

As you may know, many companies – including Cambridge — are now offering Health Savings Accounts (HSAs) for employer-provided health care benefits. HSAs come with a debit card that employees have direct access to that are (supposed) to be used for medical-related expenses. Employees can use the debit card for non-medical expenses however those who do risk an IRS audit and can have penalties for using the HSA card for non-medical related expenses.

We recently approached the state agencies to understand if we should be verifying and counting HSA accounts as assets. At this time, the state agencies do not believe that HSA accounts should be considered as an asset.

Should you have any questions, please feel free to contact:

Kristin Strong

Email: kstrong@cambridgeres.com

Direct: 503.450.0231

 

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Compliance File Reminders

reminderHere are just a few quick reminders for affordable housing managers:

  • When calculating income from employment, you are required to do all three (3) calculations on the Income Worksheet (Note: Idaho properties are permitted to do just the EV and YTD calculations). In almost all cases, you will reflect the highest of these calculations on the TIC.
  • Use the 6-month AVERAGE balance for checking accounts.
  • Use the CURRENT balance for all other accounts such as savings, money markets, CDs, etc.
  • Any and all cash on hand listed on the questionnaire must be reflected on the TIC as an asset.
  • Always use the GROSS amount for Social Security (before any deductions).

Should you have any questions, please feel free to contact the compliance team at the Site Employee Resource Center: 503.450.0230

 

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Social Security Income Reminders

Here are just a few friendly reminders on Social Security Income:

  • The state agencies are now requiring that the award letter(s) for Social Security Income and / or SSI cannot be dated more than 120 days before the effective date of the certification.
  • Updated and current award letters can be obtained by the resident / applicant calling Social Security from your office (1-800-772-1213) to request a current letter. The Social Security Administration will then fax a current award letter to the management office with the resident or applicant’s permission. Please note this information is also on the Verification of Social Security in eforms.
  • You must always use the GROSS amount of Social Security income received (ex. use $785.40 instead of $785.00) to calculate income. Never use the rounded down amount or the amount after any Medicare deductions.
  • For elderly RD and HUD properties, you can use the monthly Medicare premium(s) as a medical expense.

As always, please feel free to contact the Compliance Department with any questions.

Compliance Resources

Kristin Strong
p: 503.450.0231
e:kstrong@cambridgeres.com

Breana Thomas
p: 503.445.2791
e: bthomas@cambridgeres.com