After 30 Years What's Behind the Calculations Still Matters
5/14/2018 11:57:06 AM

Editor’s Note: Mark Alper is a familiar name to many NCHM graduates, particularly those who are Certified Occupancy Specialists. For 25 years from 1990 to 2015, Mark was the lead developer and instructor for COS©. Thousands of COSers attended his programs over the years and many ask us how he is doing. Well, Mark is doing fine, but we didn't want to leave it at that. So, we asked Mark to reflect on his long career and share some of his insights.


It was a different world in 1988 than it is today and nowhere better exemplifies that then the corner of the world called affordable housing.


President Ronald Regan was in the last year of his second term in office. There was no commercially available Internet, although it had been developed by the Pentagon’s Advanced Research and Project’s Administration, where it was known as ARPAnet. A gallon of gas was 91 cents. Rain Man was the biggest box office movie and the Cosby Show was the number one program on TV.


In the world of affordable housing software for recertifications was just beginning to be widely adopted. In 1986, I was doing 700 recertifications by hand. By 1988, I was doing many more than 700 using software. There was no EIV (Earned Income Verification system, for the uninitiated) in 1988. We had access to the Social Security Administration’s Third Party Query (TPQY) system for residents and applicants. This involved filling out computer cards for each resident and then mailing these to the local Social Security office at recertification time. Social Security would provide a benefits printout and return the computer cards so the housing provider could keep them on file for future use.


The HUD Handbook 4350.3 was on Change 3 in 1988. In the fifteen years that would follow, HUD would issue another 27 changes before the Handbook was rewritten in 2003. In 1988 the 4350.3 specified that a recertification was to begin 75 to 90 days prior to the effective date and be completed 35 days before the effective date. Thus, all recertification steps were to be completed within 55 days, at most.


The Fair Housing Act was amended to include individuals with disabilities and familial status as protected classes. The Final Rule would be issued in early 1989. For many it’s hard to imagine a time when disabilities and family status were not part of Fair Housing.


In 1988 I was in my second year as a Certified Occupancy Specialist® (COS®) and 29 years old. Spring forward to the present day. I am semi-retired, having left the NCHM staff as Vice President of Compliance in January of 2015 due to increasing mobility problems. I am engaged in some part-time consulting and remain interested and involved in the affordable housing profession.


Many things have changed, while others have stayed the same. In the HUD affordable housing world today occupancy specialists have ninety days to complete a recertification. It has been years since anyone has had to manually complete a 50059 form. Some guidance has been improved while others have vanished, and a fair number of areas remain as confusing as ever.


For me, the advent of the computer age in affordable housing is one of the greatest advancements as well as a source of concern. One skill set I developed from doing recertification compliance in the years before software was the ability to analyze and assess verification data. It was a skill born of necessity. If I missed something or if I made calculation errors, it was going to cost my employer money, jeopardizing its ability to run an effective housing community and put my job in jeopardy. This is why during my time at NCHM and to this day, NCHM has insisted that COSers learn what is behind the calculations. Software is great but relying on it exclusively is a mistake; particularly when much of the occupancy function requires the ability to explain the complex federal requirements to applicants and residents.


The need to understand what is behind the numbers became even more acute with the advent of so-called “blended” properties. In 1988 the subsidy world was far less complicated. There were the HUD programs and there was the Low-Income Housing Tax Credit program and, for the most part, they operated separately. As budgets got stretched over the years, the blending or mixing of programs became commonplace. Today it is not unusually to see properties with two, three, four and even more programs intertwined. Software helps us to run the numbers, but it doesn't help us to explain them.


Of course, the very need to automate is driven by the complexity of rules that we must follow. Many of these rules are grounded in good reason and good intentions. However, they also combine to add to the confusion and consume valuable time. Hopefully the current focus on “de-regulation” will find its way to the various federal housing programs. Some regulation is absolutely necessary – we need to make sure that only qualified applicants are admitted and that everyone pays their fair share – the government and the residents. We also need to maintain our commitment to fair housing. At the same time I hope we can find a way to streamline the process and devote a greater share of our precious resources on the actual delivery of quality housing. That would be an awesome result to be able to report on 30 years hence – in 2048!

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