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NMA now managing HCV programs in Louisiana and Kentucky

Posted by NMA on Sep 7, 2018 11:06:06 AM

Families participating in the housing choice voucher (HCV) program of Jefferson Parish, Louisiana will soon have a new program administrator. Nan McKay and Associates (NMA) will begin administering the Housing Authority of Jefferson Parish (HAJP)'s HCV program as of October 1, 2018. Jefferson Parish is the second largest parish in Louisiana, with a population of about half a million people.

On Monday, August 6, NMA also opened the doors and began administration of the HCV program for Kentucky Housing Corporation (KHC), a state housing finance agency that provides rental assistance throughout the state of Kentucky for low-income residents.

NMA, long known as the gold standard for performance excellence in the public housing and affordable housing industry, brings to Louisiana and Kentucky its four decades of experience providing professional services to housing authorities across the nation.

"We're extremely excited to provide the highest quality services for the people of Louisiana and Kentucky," stated John McKay, NMA's CEO. "We believe in partnering with agencies and their partners to serve families in need with outstanding customer service. Our commitment to the local community is to offer efficient, effective administration of the HCV program and an exceptional customer experience."

Learn more about program outsourcing

Topics: outsourcing, program management, company news

Q&A: Underpaid subsidies due to PHA error

Posted by NMA on Feb 1, 2016 12:03:48 PM

underpaid subsidiesQUESTION    It’s recently come to my agency’s attention that some of our clients have been paying too much rent. This was due to a calculation glitch and applies to both public housing (PH) residents and participants in the housing choice voucher (HCV) program.

We’ve fixed the error, but what about subsidy underpayments for past months? The monthly underpayments are small amounts but the error existed for several years. Does the PHA have to repay these amounts to our clients? If the agency retains documents for three years, can we limit repayments to the three-year period?

ANSWER    While the HUD regulations do not address this issue, HUD has issued written guidance on the subject. The most recent guidance is in Notice PIH 2007-27, Disallowed Costs and Sanctions Resulting from On-Site Monitoring Reviews. Treatment of underpaid subsidies depends upon the program.

Here’s an excerpt from the section on underpaid subsidy due to PHA error in the HCV program:

PHAs will not be reimbursed for underpayment of subsidies. PHAs are required to reimburse families for overpayment of the total family share. Such reimbursements of the tenant portion of the rent can be made in current and future months through an increase in HAP to the landlord and a decrease in the family share until the family’s overpayment is fully compensated. A PHA may not use funds from its HAP account or HAP net restricted assets to directly reimburse families for overpayment of the total family share. If the family did not receive the full amount of utility reimbursement from the PHA, the PHA must reimburse the family.

Here’s the guidance for the PH program:

PHAs will not be reimbursed for underpayment of subsidies. PHAs are required to reimburse residents for overpayment of tenant rent in accordance with PHA policy.

Since the notice does not require a specific look-back period for reimbursement, it’s probably safe to limit repayment to the period for which the PHA has records. In the HCV program, records from interim and annual reexaminations must be retained for at least three years. In the PH program, record retention periods are determined by policy, and three years is a popular option.

We recommend reimbursing the family for the full period for which the PHA has records for that family, regardless of the agency’s record retention policy. For example, if the family was charged too much rent for seven years and the family’s file contains records for the last five years, reimbursement should be made for five years.

Is keeping up with reexams giving you a headache? NMA can help make the process painless. We'll handle your recertifications offsite, saving money for your agency while ensuring you’re still in compliance. It’s easy—the processing work simply happens in our offices instead of yours. Visit our website or email sales@nanmckay.com for more information.

Topics: outsourcing, PIH notices, program management, Q&A, recertification, rent calculation

What does the deregulation of HQS inspections mean for our industry?

Posted by BEMuser on Jun 30, 2014 10:16:22 AM

Until last week, when HUD published the implementation notice for the changes mandated by the 2014 appropriations act, housing authorities were required to inspect units at the time of initial lease-up and thereafter at least once every twelve months. The new notice relaxes that requirement, specifying that an HQS inspection must occur at least once every two years.

It also provides PHAs with the option of relying on comparable inspections done by other agencies, such as those performed for the HOME or low-income housing tax credit (LIHTC) programs, if the other inspection uses similar standards to HUD's housing quality standards (HQS). This will be true for both initial and ongoing inspections.

PHAs are still responsible for ensuring that subsidies are paid only for units meeting HQS. The hope is that PHAs will focus inspections on the most risky units, while improving compliance overall.

In addition to this widely discussed change from annual inspections to biennial inspections, there's also the issue of self-certification, with relatively undefined guidelines. HUD offered some guidance last year with the issuance of Notice PIH 2013-17, which provided instructions for the use of photos during the HQS inspection process and included the key point that PHAs may use them to verify that deficiencies have been corrected.

These HQS deregulations are intended to save costs, reduce administrative burdens, and streamline rental programs. While they are now available for implementation by PHAs on a limited basis, further guidance and rule making is expected from HUD. However, we now have enough information to discuss and plan for these changes. How will they affect the affordable housing industry and, more importantly, how will they affect the families we serve?

Over the last year, the housing choice voucher program felt some of the most immediate and severe consequences of sequestration. Industry groups estimate that, due to sequestration, the program served about 70,000 fewer families as compared to a year earlier. Reductions in administrative fees have caused financial stress throughout the industry. Ultimately, the entire program has taken a beating over the last few years, and PHAs are struggling to find ways to continue operations and the business of serving families.

Providing access to affordable housing in safe, secure, and sanitary condition remains the mission of our agencies and the foundation of the HCV program. PHAs need to balance available resources to ensure that families have HAP contracts, that lease-ups are done correctly and on time, and that all other requirements are in place. As an industry, we find ourselves considering several weighty questions: How do we balance deregulation of HQS inspections with what's right for the family? How do our decisions reflect the mission statement at each individual agency? At what point do we lose sight of our mission statement?

In other words, just because we can, does that mean we should?

It's a delicate balance. We're faced with a moral dilemma which is driven by economics, need, and desire to help as many families as possible. And we recognize that it's not a perfect environment in today's world and certain things have to give.

Tip #1: Consider your PHA's mission statement.

Most agencies have always viewed themselves as the protector of their clientele, meaning that they are the guiding force that ensures all families have safe, secure, and sanitary housing. That's the mission statement of HQS inspections; it's been the mission statement from the beginning. In moving forward with these new pieces of deregulation, it's important that PHAs consider their own mission statements as they're designing and crafting ways to take advantage of these available resources. Just because these new options are available, are they always the best choice for our agencies and for the families in our program?

The agencies I've been working with recently are grappling with this question, and the answer isn't always immediately clear. Agencies are trying to put their resources in the very best places, and while no one is particularly excited about not doing reinspections or not confirming that repairs have been done, the budgets just don't allow us to do everything we'd like to do. These are very difficult decisions for agencies to make.

The real question is: Where do we put the family in the

mission statement, and how does that apply to deregulation?

Is it always a good idea, and if it is, is it always an all-or-nothing?

Ultimately, we should strive to find a balance between the new options available to us and how we can apply them to the program while staying true to our mission statement.

Tip #2: Don't assume, "Biennial is good, because it's going to save us money."

Biennial inspections are something we've seen handled in two different ways. In some cases, the PHA just cuts inspections down the middle — every odd number gets inspected this year, and the next year the other batch gets inspected. That's a more extreme option.

On the other hand, I work with several MTW agencies that, given this flexibility, chose to focus their efforts on properties that have not been maintained in HQS (that is, they have failed the first inspection) and developed their guidelines accordingly. For example, one agency said, "If you fail the first inspection, we're going to come back out in six months." They want to stay right on top of it. If you pass the first inspection, then you're eligible for the biennial. This reduces the potential for fraud and abuse by landlords.

In the high level, we have two points of deregulation that

are available: self-certification components (without a clear

idea of what that should look like) and biennial inspections,

which have been available to Moving to Work (MTW)

agencies for years and will now be available to all PHAs.

My concern, in the bigger picture, is when you start merging biennial inspections and self-certification. If an agency decides to do biennial inspections but keep reinspections, at least there's a check and balance. Or if an agency says they'll do annual inspections but allow landlords to self-certify, again, there's a check and balance. It's when you start combining both those options that you begin to see how things can unravel.

In the worst-case scenario, you could have a property that fails for significant deficiencies. The landlord opts to participate in the self-certification program. He signs an affidavit that repairs have been made, no reinspection has been put into place, and you end up with a property that hasn't been looked at in two years and isn't safe, secure, or sanitary.

When we push deregulation options to the furthest extreme, it's vital that we consider the risk of paying HAP on a property that doesn't meet minimum HQS and is putting families in danger of living in such conditions for a period of two years before someone even goes out to check.

Tip #3: Think through what your agency would need to manage a well-run self-certification program.

With self-certification, the idea is that we're eliminating the reinspect process, which would save time, effort, and energy for agency staff. But before making a decision, consider what the self-certification option might look like at your agency. Remember, you still have to have an affidavit or an inspection within the 30 days. Even self-certification doesn't allow you to send out a notice and then not have a follow-up. So if you wait 21 days to find out if the certification comes in, and it doesn't, then you're out of time to give reasonable notice to the landlord and the tenant that the inspection is going to move forward.

The primary issue with self-certification, then, is the need it creates for a new tracking system. The most viable one I've seen is that you actually schedule the reinspection, provide the self-certification documentation with a drop-dead date (say, 21 days), and if they haven't provided the self-certification documents within that time period, then the reinspection automatically moves forward. Otherwise you run into a situation where you don't have adequate time to notice it and you're going to be falling outside of the 30-day reinspection notice required by HUD.

So does self-certification actually save time? You've got clerical staff touching these documents two, three, four times — picking up the file, scheduling the reinspection, managing and tracking the self-certification, possibly including images to document proof of repair and appending them to the file, and going in and canceling the reinspection. And they're doing all this manually, because no housing software has a solid tracking system for self-certification — it's something that's just hit the boards, and everyone's doing it a little differently. There's room for a lot of things to slip through the cracks and have a direct impact on SEMAP findings.

Another issue with self-certification is the question of who's going to sign the affidavit — owner, tenant? We're asking someone who's never been to HQS training to certify that a repair meets HQS standards. So the other approach I've seen is agencies asking for proof of repair, such as a photograph or a receipt. But now somebody has to gather the documentation, we still have the notice issue, we still have the reinspection issue, and now you have to have staff focus on tracking every single fail to determine whether or not a self-certification came in, and if it did come in, did the documentation meet minimum standards for your agency to mark it as a pass?

That's a lot of subjective review. It's time-consuming, and it puts an agency at substantial liability because now your agency is making a decision as to whether or not a landlord has provided adequate verification of repair.

Of course, we'll know more about the potential benefits and drawbacks of HQS deregulation after HUD integrates stakeholder input into a final rule. But for the time being, these questions should give us plenty to think about.

As project manager of NMA Inspections, Michael Petragallo leverages over 20 years of experience providing HQS inspection services and more than 1.5 million successfully completed HQS, UPCS, and rehabilitation inspections. Our team of NMAI inspectors have an average background of 12 years’ experience conducting inspections, are highly qualified and certified in HQS and/or UPCS, and have completed required sensitivity and sexual harassment training as well as extensive criminal background checks before beginning work. For more information about NMA Inspections, please visit our website or contact us directly at sales@nanmckay.com.

Topics: appropriations, HQS, inspections, LIHTC, MTW, outsourcing, PIH notices, SEMAP, UPCS

How to run a successful VASH program: Tip #4

Posted by BEMuser on Jan 28, 2014 3:25:06 PM

Tip #4: Train the VA caseworkers to conduct initial inspections.

Many PHAs contract out certain functions of their program for greater efficiency and cost savings. Why not train your VA case managers on housing quality standards (HQS) and allow them to conduct an initial inspection of the unit?

Empowering the VA caseworker to inspect the unit while onsite with the veteran saves your PHA time and money, and helps to ensure that the veteran gets leased quickly and the PHA receives administrative fees sooner. It's a win-win!

Of course, a key component of quality inspections is PHA oversight and monitoring. When outsourcing initial inspections to a third party, it's imperative that your PHA performs a certain level of quality control to guarantee that the outside entity is meeting unit standards.

Next: How to run a successful VASH program: Tip #5

With an exceptional knowledge of HUD regulations, NMA senior trainer and consultant Cydney Jones is expert in providing a wide range of technical assistance, management training, and on-site expertise for multifamily assisted programs and the HCV program. Ms. Jones recently headed operations for NMA’s contract with one of the largest public housing authorities in the country, including administration of VASH vouchers.

Nan McKay and Associates has assisted a number of agencies across the country with their VASH voucher programs and can leverage that experience to help your PHA be more successful. For information, contact sales@nanmckay.com.

Topics: HQS, inspections, outsourcing, UPCS, VASH, veterans

Introducing Nan McKay and Associates Inspections (NMAI)

Posted by NMA on Sep 3, 2013 11:15:19 AM

Dorian JenkinsYou may have already heard about NMA's newest division of services — Nan McKay and Associates Inspections. This project was a long time in the making. Over the past years, we've seen an increasing demand for high-quality HQS outsourcing in the affordable housing industry. It was a service that NMA was eager to provide for our clients, but we wanted to first ensure that we could offer a variety of inspection models at a price that budget-conscious housing authorities could afford.

We found a valuable partner in Michael Petragallo and Sterling Management, Inc., a respected national company with over 20 years of experience providing HQS inspection services and more than 1.5 million completed HQS, UPCS, and rehabilitation inspections. I'd like to take this opportunity to give them a hearty welcome to the NMA team! Our firms share the same values, vision, and emphasis on outstanding customer service, and we're all very excited to have them on board.

Here are a few facts about inspections that you may not be aware of:

  • By outsourcing HQS inspections, an agency can cut costs by up to 50 percent
  • According to our research, outsourcing HQS inspections typically increases customer satisfaction
  • On average, NMAI inspectors complete 15–20 inspections per day

Our team of NMAI inspectors have an average background of 12 years' experience conducting inspections, are highly qualified and certified in HQS and/or UPCS, and have completed required sensitivity and sexual harassment training as well as extensive criminal background checks before beginning work.

In today's budgetary climate, everyone is looking to improve efficiency while conserving valuable agency funds. NMAI is a great place to start doing just that.

As VP of Program Management for NMA, Dorian Jenkins currently leads NMA’s Chicago team, which administers 17,000 contracts on behalf of the Chicago Housing Authority (CHA). His team has successfully maximized unit and budget utilization for the CHA’s HCV, Mod Rehab, and PBV programs, while incorporating a customer-focused culture within the CHA. For more information about NMA Inspections, please visit our website or contact us directly at sales@nanmckay.com.

Topics: HQS, inspections, outsourcing, UPCS

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