File Clean-Up: Compliance UGH
OK. Everyday is not sunshine when working with affordable housing. Here’s a question that came in recently and we thought we should get the word out.
Question: We’ve added an existing Section 42/Section8 property to our management portfolio. The files are a mess. Who’s responsible to do file clean-up? Or can we just make sure files that we do are squeaky clean and forget about the old files? We didn’t cause the problem…the old management company did and we are not exactly excited about taking on what should have been their responsibility. UGH.
You’ve touched on one of the toughest jobs in affordable housing compliance (at least that’s OUR opinion). There are those who jump for joy if a project like yours comes up, but most of us would rather have a root canal. Are you with me?
Answer: The existing files must be brought back into compliance. There are consequences both with HUD and Section 42 if we don’t take action to cure the problems. If you’re on the management/compliance team, it’s probably a job that’s coming your way.
OK. Let’s make this as enjoyable as possible:
1) Give thanks. You’ve got a job and your expertise is needed. (You can groan if you want to).
2) One thing at a time. Check a file; determine what needs to be done and do it.
3) If the household still lives in the property, it’s easier. It’s a knock on the door or a phone call.
4) If the household no longer lives on the property but can be located, ask them to cooperate.
5) If the household no longer lives on the property and can’t be located, show your efforts to find them. Look at old paperwork for emergency contacts and call those numbers.
6) If you need to go back in time to solve a problem, (such as an employment verification form that wasn’t completed, etc., get that verification form completed and ready to send or make that phone call.
7) Move on.
8) Keep track of all activity. Show everything you’ve done to cure the problem so that if you come to an impasse, your records show the action you took.
9) Understand what happens if you don’t act: Your HAP contract could be cancelled; the property’s tax credits could be lost.
10) Every time you get a file fixed, do something awesome for yourself. Also, let others (including. your supervisor) know!
Hope this is helpful. Remember what a difference you make to life and affordable housing!
The Compliance Team at TheoPRO