During the past year or so, I have been privileged to work with many fine housing management organizations—including public housing as well as privately-owned, project-based housing—doing file audits, civil rights reviews, or management improvement studies.

The overwhelming majority of these housing providers have properties that run the gamut from decent to outstanding, have diligent, dedicated staff, and on the surface seem to be doing things right in so many ways.  So I understand their shock and dismay when they get a bad rating in connection with the Public Housing Assessment System (PHAS) or Management and Occupancy Review (MOR).  If this gets repeated, you’re well on your way to having what is known, formally or otherwise, as a “Troubled Property.”

It may be logical to assume that since on the surface everything appears solid, then getting a knock on PHAS or an MOR can only mean one thing: The person doing the review made a mistake.  Yet, my own experience over the past twenty-one years I’ve been with NCHM seems to demonstrate that by overly focusing on forms (think HUD), we often miss substance — what I’ve come to call “systemic disconnections.” Identifying and correcting those disconnections can go a long way from turning a troubled property (or potentially troubled property) into a high-performing property.

Some examples would be:

* Calculating medical expenses without looking at the date on the receipt, and counting something you already used as part of last year’s recertification;

* recertifications being submitted to TRACS or IMS/PIC without supervisory review, including both the certification and the backing verifications;

* late recertifications caused by residents not reporting on time, without any evidence of a single reminder notice.

If you would like an analogy, think of someone you know who eats the icing off of a cupcake, but not the cake itself, which is the foundation of the dessert.  Or, closer to home, I can recall many a time I dressed sharply and thought I looked “winning” (will anyone ever use that word henceforth without thinking of Charlie Sheen?) and I still didn’t get a date to the senior prom.

Over the past few years, HUD has been issuing vital material by notice or email rather than formal Handbook changes to the Public Housing Occupancy Guidebook, the Housing Choice Voucher Guidebook, or HUD Handbook 4350.3, Rev. 1.  We all are aware, I think, that our work has become much more challenging of late.  In future columns, webinars and programs, one of my primary areas of focus will be in making suggestions to meet those challenges head on.

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