If you have been reading these columns for any length of time at all, you’ve noticed that the majority of them have dealt with matters of regulation (Title 24 of the Code of Federal Regulations), handbooks, forms and the like. This shouldn’t be surprising since these are component parts of the compliance picture, including compliance monitoring.
If you’ve attended NCHM training programs, you’re probably aware that we have two types of programs: Compliance programs (COS, COS-P, TCS) and Performance programs (CMH, CMM). Each of the compliance programs has some performance training, as each of the performance programs has some elements of compliance. I had this in mind when I developed our Fair Housing Essentials (FHE) and Fair Housing Roundtable (FHR) programs. Each of these courses is jam-packed with information; information that is critical in our industry.
During the past year or so, I have been giving some thought to how these fundamental, or foundation programs can be built upon using the technology we have at our fingertips. There are many things that are essential for top-notch compliance but require a skill set outside the scope of regulations. One example would be training on conducting an effective compliance interview. There’s little or nothing about that in 24 CFR or the various handbooks.
I have done thousands of file audits over the years, and I’ve lost count of the number of times where there has been no apparent interview of the resident. Instead, the resident brings in some documents (often months ahead of time, because I find these items loose in a file well before the first reminder notice goes out). That isn’t managing compliance, as both HUD Handbook 4350.3, Rev. 1 and the Public Housing Occupancy Guidebook specify. It’s being reactive….it’s letting the “ball play you” and there are probably countless other sports analogies I could mention for those of you who think ball games are tedious.
If you think that the universal implementation of Enterprise Income Verification (EIV) for HUD programs on September 30th solves this, think again. EIV won’t contain asset information, nor will it contain information on an applicant household that’s never received HUD assistance. And your compliance operations are only as strong as your process, and the ability to conduct an effective interview to elicit all the information you need is at the heart of that process.
I am not unsympathetic to site staff who will point out, in response to this column, that they are already overburdened with the myriad number of things that need to be handled on a daily basis. I completely understand that sentiment and empathize. But cutting corners in compliance functions seldom works out well for management, and “management error” can be costly.