 |
|
 |
 |
• Read Reducing Energy and Utility Costs in Multi-Family Housing |
By Mark S. Alper, RHM NCHM Director of Compliance Services
Back to the Basics, Part I
One of the things all of us do from time to time is to question our own base of knowledge. We live in a complicated world with all manner of pressures and so on which we confront on a daily basis. As a result we sometimes forget things that we've known for years, including those things that have become second nature.
Since I've had many such examples come my way through NCHM's eHotline technical assistance service, I felt it might be useful to go "back to the basics" for the next two columns. If much of this is familiar to you, consider this as a refresher of sorts and feel free to hang on to it in the event you have one of those "I knew that when I came in here this morning" moments we all have.
VERIFICATIONS
There seems to be a temptation to "cut corners" in the verification process. I've seen this most frequently in senior housing, where files that aren't due for recertification for another ten months already have the annual Social Security award letter (which is an acceptable form of verification: HUD Handbook 4350.3, Rev. 1, Appendix 3, page 11) -- although at this point you should be using the Enterprise Income Verification (EIV) system for primary verification purposes; only if this proves impossible or delayed for more than two weeks (and a manager forgetting to use EIV doesn't mean a "delay" in this context) can you use documents submitted by the applicant/resident. NOTE: Yes, I am very aware that many of you have problems with EIV. To me, it is reminiscent of the problems those of us in housing management had with TRACS when that was first introduced.
Those bank statements, however, will be obsolete by the time the recertification begins. Here again, I am aware of getting accurate third party verifications from banks which often will only give you the average two or three month balance instead of the six month balance required by HUD. But getting the resident to bring statements ten months before the AR isn't a good idea.
NON-CITIZEN RULE
HUD issued regulations implementing the restrictions on federal housing assistance to non-citizens back in 1995, although the law was enacted fifteen years earlier. In HUD Handbook 4350.3, Rev. 1, the guidelines for implementation are found in Paragraph 3-12. This paragraph indicates which HUD programs must implement the rule and those that are exempt.
Since some contract administrators have written on HUD Form 9834 that owners/agents must repay unentitled subsidy it is useful to remember the provisions of Paragraph 3-12D in HUD Handbook 4350.3, Rev. 1 that state HUD will not take any compliance action, disallowance or penalty against the owner/agent in connection with the non-citizen rule if the owner/agent followed the regulations and guidelines. This paragraph lists five steps the owner/agent should have taken, if applicable.
Two things to remember:
-
Change 2 stated you no longer have to reference "temporary deferral of termination of assistance" in your tenant selection plan. This provision technically would not be applicable for years after 1998;
-
Individuals who are 62 years of age or older, who declare they are eligible noncitizens, are not subject to Department of Homeland Security (DHS) verification and need only sign the declaration and show proof of their age (HUD Handbook 4350.3, Rev. 1, Paragraph 3-12I(1)(b), page 3-23).
More next time….
Reducing Energy and Utility Costs in Multi-Family Housing
This is the first installment in a planned series of articles on the important and timely issue of energy reduction. Since the creation of what is today known as the federally assisted housing management industry through the passage of the US Housing Act of 1937, billions of dollars have been spent on energy-related budget items.
Although the issue of global warming has share of both advocates and detractors in the political and scientific field, what is beyond dispute is the increasing costs of energy consumption. While HUD began looking at its long-term costs with respect to gross rents and federal housing assistance in the early to mid-1990's, the agency has been slow to address energy consumption as a cost item and is only now starting to take tentative steps toward the development of an energy-related strategy tied to the long term viability of federally assisted housing.
Everything we discuss here has been applied successfully to energy reduction, with results ranging from satisfactory to outstanding. I'll examine barriers to implementation as well, including the pitfalls, because things often do not work out as originally planned. . These are not general concepts, nor are they drawn from work done in modern office buildings, architectural masterpieces, etc. They were developed in, and applied to, residential properties.
While news commentaries often focus on the increasing costs of filling up your gas tank at the pumps, a fluctuation that impacts everyone who drives a car, what is sometimes overlooked is that the costs of heating oil has also increased. There has also been commensurate increases in costs connected with electric power, water and sewage treatment. Both individually and as a whole, these increases can put a strain on a property's budget.
There are many ways to address the rising costs of energy, even if a property lacks the capital funds to make equipment improvements. There’s a surprising amount you can do with little or no capital investment; “little capital investment” includes measures that can be paid for out of the operating budget because they will pay for themselves in less than one year.
While analysts such as myself find historical billing data essential to obtain a picture of the energy/ utility picture of a residential property, collecting your own data can pay dividends in the potential for reduced energy consumption. Hard data provides increased reliability and the prospect of decreasing maintenance costs as well. Since maintenance budgets are always under pressure, this will make everyone's lives easier, and can also justify a higher level of maintenance to your owner as well as the relevant regulatory agency.
NCHM is in the process of addressing these and many other issues that directly confront owners, managing agents, and regulatory agencies. Stay tuned.
