Management & Occupancy Reviews
Management and Occupancy Reviews, which monitor project operations are required to ensure that HUD’s multifamily housing programs are administered as intended by identifying deficiencies to eliminate fraud, waste, and mismanagement. Documented monitoring activities also provide support for enforcement actions when owners/agents will not correct deficiencies. The Management and Occupancy Review is one of the integral mechanisms of project monitoring used to ensure that owners/agents comply with the requirements under the Regulatory Agreement, Mortgage, Management Certification, Housing Assistance Payments (HAP) Contract and/or other relevant business agreements. The MOR is completed by Compliance Managers and consists of:
- A scheduling letter which is sent at least 14 days in advance of the MOR that includes a request for relevant documents to be provided to NHC for review in advance of the MOR
- A desk review completed prior to and in preparation for the on-site review to analyze the Tenant Selection Plan, House Rules, Lease, Application, EIV Policies and Procedures
- An on-site review of a random sampling of resident files
- Follow up of the property’s most recent REAC inspection (Pending HUD directive)
- A report that is sent to the owner/agent and HUD within 30 days of the on-site Review indicating the results and rating of the Review
- Assisting the owner/agent in responding to any MOR findings within 30 days of the date of the report.
National Housing Compliance is always committed to positive communication with our clients throughout the MOR process.
In situations where local conditions prohibit on-site reviews due to COVID-19 and overall health concerns are prominent a remote MOR is an option. The remote MOR allows for minimal face-to-face contact, but does require an on-site “physical inspection” of the property.
NOTE: A Remote MOR is conducted when the Owner/Agent volunteers to participate – it is not required or mandatory.
What You Can Expect:
- When scheduling the MOR, a phone call from a Compliance Manager describing the remote MOR process – and an opportunity to ask questions;
- A Scheduling Letter with detailed instructions;
- An email request for electronic tenant files 5 business days in advance of the MOR;
- A day before the MOR, a follow-up call to ensure the property is safe to visit and a checkpoint on electronic documents and tenant files;
- On the day of the MOR, an on-site visit of the property to “inspect” common areas, grounds and vacant units;
- Both an entrance and exit conference, via phone or zoom conferencing if preferred.
Helpful links below:
- Sample Scheduling Letter
- Sample File Review Organization Checklist
- MOR COVID Protocol
- HUD Memorandum, June 23, 2020
- HUD COVID-19 Q&A, January 4, 2021; Q3 under Asset Management, as updated 10/14/20