Management and Occupancy Reviews (MORs) are critical tools in managing HUD-subsidized properties. MORs help determine and maintain property compliance of HUD regulations. Quadel MOR specialists have conducted over 12,000 MORs as part of Quadel’s Performance-Based Contract Administration (PBCA) contracts in Indiana and North Carolina and are highly skilled in assisting owner/agents meet all MOR and program regulations.
Pamala Jeffries, the Program Compliance Manager for Quadel’s PBCA program in North Carolina, discusses MORs and how owner/agents can best prepare for the annual review.
Read the MOR Appointment Letter Carefully
Jeffries believes a successful MOR starts with owner/agents taking the time to read the official MOR Appointment Letter as it contains all the information needed to properly prepare.
“The appointment letter provides the itinerary, the tenant file list to be audited, the deadline day and time for loading file documents into the share drive, and even the phone number and email address of the Compliance Specialist who will conduct the MOR. Our MOR specialists welcome any preparatory questions owners may have,” Jeffries said. “In addition, the letter has the website address where owners can access the HUD-9834 form that contains all onsite review questions to prepare in advance.”
Review the HUD-9834 Form and Understand all MOR Components
Jeffries believes MORs are so important to the PBCA program because the MOR acts as a “front-line” effort to discover any compliance issues needing to be addressed. MORs cover everything from eligibility and occupancy standards, to the physical state of the unit, to rent verification.
“We examine tenant files, corporate/management Standard Operating Procedures, maintenance records, office postings, EIV Master Reports, and EIV authorizations, Jeffries said. “We conduct a follow-up of the last REAC physical inspection in addition to performing a general walk-around of the property to observe building exteriors, property grounds, and common areas such as community rooms, laundry facilities, and vacant units.”
Be Aware of Changes Due to COVID-19 and Common Mistakes
In June 2020, HUD released a memorandum that provided instruction on conducting MORs during the COVID-19 pandemic. Prior to the pandemic, MOR specialists would enter occupied units as part of a REAC follow-up, but this practice is still on hold for now.
All MORs still must include an on-site review, but owner/agents can request a partial remote MOR or a traditional MOR. Either request will be honored. Owner/agents must confirm their preference.
“Due to COVID-19 regulation changes, we make contact with the tenant directly to determine whether REAC findings in their unit have been corrected instead of entering units to confirm changes. Common MOR findings involve EIV. This includes not using EIV in its entirety, not running EIV reports timely, not providing EIV authorization and approval forms, and not obtaining proper third-party verification,” Jeffries said. “We also often see missing signatures and/or dates on leasing documents and omission of required documents that should have been signed by the tenant.”