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Kentucky Housing Corporation's (KHC) Management and Occupancy Review (MOR) policy, in response to COVID-19, has been updated and new a memorandum from the U.S. Department of Housing and Urban Development (HUD) was released regarding special claims.
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MORs
KHC reinstated MOR activity beginning in June. We incorporated safety protocols for staff and created a
tip sheet for our partners that was shared via eGram last month. KHC staff are following these safety protocols that allow us to conduct MORs while ensuring not only our staff's safety, but also the safety of our partners and residents. We want to continue to encourage all property owners/agents to join us so that we all are doing our part to protect the health and safety of everyone involved.
On May 27, 2020, HUD provided some additional flexibilities for Performance Based Contract Administrations (PBCAs) when conducting MORs and provided responses to many questions related to the MOR process that were received by industry groups and PBCAs. We anticipate that the
Multifamily Q&A document on
HUD's website should be updated soon with this information.
HUD also shared the alternative MOR, which includes the following:
- HUD will, until September 30, 2020 (or such later date as HUD may determine), allow PBCAs to conduct on-site MORs without entering resident units.
- For Real Estate Assessment Center (REAC) follow-ups, in determining whether EH&S and other deficiencies have been corrected, the PBCA must attempt follow-up on those affected units via contact directly with the resident by way of phone or email and document the results or attempts made on the MOR report.
- A physical, on-site visit to the property must still occur to document the physical conditions, general appearance, and security of the property and should include a visual assessment of each building and the overall grounds of the property.
- An on-site, entrance/exit interview should occur, except in instances where state or local law or ordinances prevent such meetings. In instances where these interviews are prohibited from occurring on-site, they should be conducted by telephone or email and documented as such in the MOR Report.
- All other portions of the MOR, desk review, and on-site review must be completed in its entirety. This includes an on-site review of tenant files.
On June 23, 2020, HUD released a memorandum regarding the reinstatement and status of MORs.
Specific guidance was again provided to state that until September 30, 2020 (or such later date as HUD may determine), we will conduct on-site MORs without entering resident units.
Although HUD still requires an on-site MOR be conducted, as well as the tenant files to be reviewed on-site, they are allowing for some review of documents that can be submitted electronically. One Q&A shared by HUD confirmed that property owners/agents can
provide the required 9834 Addendum C documents to the PBCA reviewer electronically prior to the on-site Review so that information can be reviewed ahead of time and limit the time the reviewer is on site.
The Addendum C form is mailed to the property owner/agents at the time of scheduling and attached to the formal notification letter. Please work with KHC staff to identify which documents can be submitted electronically prior to the review.
It is important to note that in this most recent memorandum HUD is asking for owner/agents to cooperate with the PBCA for the scheduling of the MOR, arranging and completing entrance/exit interviews, and allowing the PBCA to perform the file review on-site.
NOTE: HUD has approved the scheduling of MORs through the month of September 2020. If your property is on KHC's work plan for this next quarter, you will be contacted soon.
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Special Claims
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HUD memorandum was issued July 6, 2020, through HUD's RHIIP Listserv notification system regarding the processing of Special Claims for Vacancy during the COVID-19 pandemic. Submission of special claims is a way for the owner/agent to recoup the loss of rental income for a vacant unit that was occupied by an assisted resident. This memo provides instructions for processing of claims for properties affected by COVID-19 during the period of March 27, 2020, through September 30, 2020. It is important to remember that
all claims must be received by KHC within 180 days from the date the unit was vacated - please do not wait too late to submit your claims! Refer to
this HUD memorandum for further instructions as well as the special claims processing guide. All Special Claims can be submitted electronically to
[email protected].
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