© Copyright 2008 Nan McKay & Associates December 20081 Managing SEMAP Gail Gillispie © Copyright...

December 2008December 2008 11

© Copyright 2008 Nan McKay & Associates

Managing SEMAPManaging SEMAP

Gail Gail GillispieGillispie




Steps to Success

1. Establish desired outcomes What will be quality controlled? What outcomes are acceptable?

Goals must be: Attainable Measurable Clearly defined



Steps to Success

2. Educate all staff on how their daily work impacts the PHA SEMAP score

Hold a series of workshops to discuss and train:

SEMAP indictors SEMAP requirements Related policies Application of requirements



Educate

Workshop discussion example: Determination of adjusted income requires

staff to follow verification requirements Discuss

Regulatory requirement PHA verification policies How staff applies these policies daily How staff documents verification attempts



Educate

Hold the workshops ongoing – and don’t be afraid to repeat a topic Provides emphasis, additional clarity, and

clears misunderstandings



Steps to Success

3. Assign SEMAP QC role to one or more key staff

Large PHA: QC department conducts SEMAP and non-SEMAP QC activities

Ongoing file reviews Ongoing financial reviews Ongoing HQS reviews



Assigning SEMAP QC Role

Midsize PHA: QC supervisor – but fewer support staff Rely more on supervisor review efforts

Small PHA: Assign to staff supervisors – but avoid assigning

indicators for which the supervisor is responsible

Work with neighboring PHAs to QC each other



Steps to Success

4. Establish a review schedule for each indicator: What are the program requirements? What will be reviewed? How will it be reviewed? How often reviewed? Who will review? How will results be communicated to staff and

management?



Establish an Indicator Review Schedule

Example: SEMAP indicator: Lease-up

What are program requirements?The percent of units leased or the

percent of allocated budget authority expended during the PHA fiscal year was 98% or more




What will be reviewed? Internal financial records will be reviewed

to determine year-to-date lease up (units and budget authority)

VMS and software lease-up data will be compared





How will it be reviewed?What internal tracking document will be

used to capture:Unit months leased, year-to-date? Expended budget authority, year-to-

date?





How often reviewed?By the 15th of each month: year to date

status is to be reviewed through previous month

Who will review?Name specific staff





How will results be communicated to staff and management?

Options:Paper/electronic reports




Communicating results: Make sure all Key Performance Indicators

(KPIs) are addressedMake sure all KPIs are reported on timely,

as scheduled




Steps to Success

5. Establish a record keeping system Where will records be maintained? How will records be maintained?



Establish Record Keeping System

One approach: Make up 15 (plus bonus if applicable) file

folders 1 general file folder

Random methodology 1 file folder for each indicator

Remember, you want PROOF



Internal Audit Files

Description of indicator and performance standard

Place data from audit for each indicator reviewed

Any other “proof” of certification score Use auditor minimum file sample and

increase sample if needed



Steps to Success

6. Conduct preliminary and ongoing audits PHA supervisory audits



Supervisory QC Reviews

Periodic samples of files Drawn in unbiased manner (leave clear audit

trail) Reviewed by supervisor or other qualified

person other than the one who did the work Objective: determine compliance with

indicator



Supervisory Audit Indicators

Selection from Waiting List 15Reasonable Rent 20Determination of Adjusted Income 20HQS Quality Control Inspections 5HQS Enforcement 10



Size of Universe

Determines file sample size Different for each indicator

e.g., # number of admissions vs. number of families assisted



Audit Sample Selection

50 or less 51-600

601-2000

Over 2000

5 5 + 1 for each 50

(or part of 50) over 50 16 + 1 for each 100 (or part)

over 600 30 + 1 for each 200 (or part)

over 2000



File Sampling

Determine the universe Determine number of files to be selected

for review Determine “nth” file this represents Include all staff in sample FY is period for analysis



Minimum Files Example

Waiting List Selection: Based on # of new admissions per FY

Example: PHA has admitted 260 families minimum # of files to audit? # of files which must meet criteria to receive

15 points? Note: 98%

10

98.8 (10) files

51-600 = 5 + 1 for each 50 (or part of 50) over 50



Random Sampling Example

Universe requirement 260 files File sample 10 files Files to be pulled Every 26th

file

If all staff are not represented, select closest file below 26th file



HUD SEMAP Indicators


© Copyright 2008 Nan McKay & Associates 1. Selection from Waiting List

(15/0 points) Universe

Number of families admitted to program during audit period

Two separate samples drawn from: Applicant names that reached the top of the

waiting list during the audit period Families admitted to the program during the

audit period



1. Selection from Waiting List (Supervisory Audit)

PHAs must have written selection policies in administrative plan

At least 98% of families must be selected from the waiting list in accordance with the PHA’s policies

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1. Selection from Waiting List

PHA follows policies in selecting families from waiting list

Families met selection criteria that determined their place on waiting list and order of selection



Most Likely Error Points

Get up to date on preferences in 982.207 Income targeting 982.201(b)(2) Special admissions 982.203 Special program (targeted) admissions

982.204(e)



Policies for Audit File

Document policy charges during PHA FY Example: October FY PHA

10/1/XX 10/1/XX-2/28/XX 3/1/XX 3/1/XX-6/30/XX 7/1/XX 7/1/XX-9/30/XX



2. Reasonable Rent(20/15/0 points)

Universe Number of families assisted for PHA FY

Sample drawn from Number of families assisted for PHA FY



2. Reasonable Rent (Supervisory Audit)

The PHA must have a reasonable written method to determine Rent to owner is reasonable based on current

rents charged for comparable unassisted units

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2. Reasonable Rent

The method may take into consideration Location Size Type Quality Age

Amenities Housing services Maintenance Utilities



2. Reasonable Rent

PHA must follow its written method Document determination that the rent to

owner is reasonable at required times Initial leasing of a unit Any increase in rent to owner 5% decrease in the FMR in effect 60 days

before HAPC anniversary date


© Copyright 2008 Nan McKay & Associates 3. Determination of Adjusted Income (20/15/0

points) Universe

Number of families assisted for PHA FY Sample drawn from

Number of families assisted for PHA FY

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© Copyright 2008 Nan McKay & Associates 3. Determination of Adjusted Income

(Supervisory Audit) At admission and reexamination, the PHA

must properly: Obtain third-party verification of income or

document why impossible to obtain Use the verified information Properly attribute allowances for expenses Use the appropriate utility allowances

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Most Likely Error Points

Market/cash value of assets Asset income Training program income EID for persons with disabilities Disability assistance & medical expenses Conflict between utilities in lease and

worksheet



Recommended Levels of Verification

Highest – Up-front income verification (UIV)

High – Written 3rd party Medium – Third party oral Medium-low – Document review Low – Tenant declaration



Use of UIV for Verification

UIV is third-party verification Most preferred form Meets regulatory requirements

UIV is intended to streamline the verification process Eliminates the need for written third-party

verification in many cases



NEW! HUD Guidance on EIV HUD webcasts 1/16/08 and 8/26/08 contained

revised guidance on use of EIV Previous guidance is obsolete and has been

removed from EIV website Both webcasts available at

http://www.hud.gov/webcasts/archives/iv.cfm Training materials available at

http://www.hud.gov/offices/pih/programs/ph/

rhiip/training.cfm


© Copyright 2008 Nan McKay & Associates 4. Utility Allowance Schedule

(5/0 points) PHA has reviewed utility rate data within

prior 12 months

PHA has adjusted schedule if 10%+ change in rate since last utility allowance schedule revision

Page 2-54



5. HQS Quality Control Inspections (5/0 points)

Universe Units under HAPC during last completed FY

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5. HQS Quality Control Inspections (Supervisory

Audit) PHA performs QC inspection of units

under contract Sampling drawn from:

Recently completed inspections Cross section of neighborhoods Work of cross section of inspectors

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6. HQS Enforcement(10/0 points)

Universe Number of failed HQS inspections in last FY

Sample drawn from Number of failed HQS inspections in last FY

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HQS Enforcement (Supervisory Audit)

All life threatening fails corrected within 24 hours, and

98% of other fails corrected within 30 days or PHA approved extension or PHA took action Owner fails: abated HAP Family fails: enforced family obligations



7. Expanding Housing Opportunities (5/0 points)

A. Written policy to encourage owner participation outside areas of poverty or minority concentration

B. Documentation shows PHA followed policyC. PHA has created a briefing packet (e.g. maps,

job opportunities, schools and other services in the areas) to encourage voucher holders to seek these opportunities



Expanding Housing Opportunities

D. Information packet has List of owners willing to lease Other organizations (housing counseling,

advocacy groups, service providers) which assist families in finding units

E. Information packet explains portability and provides list of contacts at neighboring PHAs



Expanding Housing Opportunities

F. PHAs have analyzed: Difficulties of voucher holders finding units in

these areas If so, has analyzed

Whether to seek approval of exception payment standards

Sought approval for exception payment standards if needed



8. Payment Standards(5/0 points)

The PHA must adopt payment standards By unit size For each FMR area in the PHA jurisdiction Between 90-110% of the HUD-published FMR If applicable, for each PHA-designated part of

an FMR area

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8. Payment Standards

If any PS schedule contains a PS that is out of range from the appropriate FMR Field office will assign 0 points for the

indicator



8. Payment Standards

Example: FMR for 2 bedroom unit $756

$756 x 1.10 = $831.60 (round down) $756 x .90 = $680.40 (round up)

To be within range PS can be between: $681 - $831



HUD IndicatorsVerified by PIC

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PIC Reporting

If a PHA has not reported at least 95% of its program participants to PIC Any indicator for which HUD verifies

performance using PIC data will be rated zero!!



PIC Factors

Factors affected by the 95% reporting rate: Annual reexaminations 10 pts Correct tenant rent calculations 5 pts Pre-contract HQS inspections 5 pts Family self-sufficiency 10 pts Annual HQS inspections 10 pts

Zero pts for each if 95% not achieved



9. Annual Reexaminations(10/5/0 points)

PHA must complete a reexamination for each participating family at least every 12 months

Remember PIC reporting End participation (#6) Other change of unit (#7) vs.

annual reexam (#2) Annual reexam searching (#9)

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10. Correct Tenant Rent Calculations (5/0 points)

The PHA must correctly calculate family’s share of rent to owner Inaccurate or missing data from indictor 3

(adjusted income) will affect the accuracy of this indicator

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11. Pre-Contract HQS Inspections (5/0 points)

Newly leased units must pass HQS inspection before HAP contract effective date

Page 2-105



12.Annual HQS Inspections(10/5/0)

The PHA inspects each unit under contract at least annually

At least annually means within 12 months from date inspector conducted full HQS inspection

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12. Annual HQS Inspections

HUD-50058 form has an action code to allow reporting of the annual HQS inspection at the time it occurs

PIC extract will list % of inspections more than 2 months overdue The 2 month allowance is to accommodate a

possible lag in electronic reporting



Annual HQS Inspection Only

If a 50058 is submitted within 2 months from annual HQS effective date Put HQS effective date on line 5i

If more than 2 months, annual HQS must have its own 50058



13. Lease-Up(20/15/0 points)

The PHA enters into HAP contracts for the number of units under ACC for at least one year PHA has leased at least 98% or 95% of the

units under ACC, or PHA has used at least 98% or 95% of its

allocated budget authority



14. FSS(10/8/5/3/0)

Applies only to PHAs required to administer an FSS program

PHA checks off on the certification form if the indicator does not apply to them If checked, HUD field office will verify that the

PHA is not required to administer an FSS program

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14a. FSS EnrollmentPHA Certifies:

A. # of mandatory slots or # slots with HUD-approved exception

B. # of FSS families currently enrolled



14a. FSS EnrollmentPHA Certifies:

C. Portability: If you are the initial PHA, enter # families currently enrolled but who have moved under portability and whose S8 assistance is administered by another PHA

D. % of FSS slots filled (b + c divided by a)



Rating FSS Enrollment

The HUD field office will verify the # of mandatory FSS slots (or with exception) reported on the PHA’s certification

PIC supplies the number of FSS families currently enrolled



14b. % of FSS Participantswith Escrow Balances

The PHA has made progress in supporting family self-sufficiency as measured by the % of currently enrolled FSS families with escrow account balances (need 30% for full points)Yes___ No___

$



14 b. % of FSS Participantswith Escrow Balances

Portability: If you are the initial PHA Enter the number of families with FSS escrow

accounts currently enrolled in your FSS program, but who have moved under portability and whose Section 8 assistance is administered by another PHA



Rating FSS Escrow Account Balances

The percent of FSS families with escrow account balances comes directly from PIC# of FSS families with positive escrow balance or with a positive amount of escrow disbursed# of families in PIC w/progress reports

= % with escrow accounts balance

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Deconcentration BONUS

Mandatory for PHA using PS amount(s) that exceed 100% of FMR set at 50th percentile

Optional for all other PHAs Criterion 1

50% or more of all S8 families with children resided in low poverty census tracts last FY

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Deconcentration BONUS

Criterion 2 and 32. % of S8 families with children who have

moved to low poverty census tracts last FY At least 2% higher than % of All S8 families with

children living in low poverty census tracts last FY

3. Same as (2), except over past two FY 5 points

Page 2-136



Deconcentration Bonus

Criterion 4 State and regional PHAs

Must complete data for each metro area or portion of a metro area where the PHA has assisted 20 or more S8 families with children last FY

5 Points



Success Rate of Voucher Holders

Applies only to PHAs with HUD approval to establish success rate PS amounts

Initially effective for 2nd full PHA FY following date of HUD approval of success rate PS amounts

>>>>>>>>>

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Success Rate of Voucher Holders

Measures whether voucher holders were successful in leasing units

HUD verification method: PIC 5 Points



Additional Information

A PHA may include with its SEMAP certification any information bearing on the accuracy or completeness of the information used by the PHA in completing its certification (comments)

A PHA may also send paper documentation to the HUD field office

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So what’s a PHA to do???



Review Steps to Success

1. Establish desired outcomes2. Educate all staff on how their daily work

impacts the PHA SEMAP score3. Assign SEMAP QC role to one or more key

staff 4. Establish an indicator review schedule5. Establish record keeping system6. Conduct preliminary and ongoing audits



January 16 – Earned Income Disallowance January 23 – Rent Reasonableness January 30 – Managing the Maintenance Function February 13 – EIV Security and Update March 6 - Income Exclusions (not including Earned Income Disallowance)

UPCOMING LUNCH ‘N’ LEARNS

© Copyright 2008 Nan McKay & Associates December 20081 Managing SEMAP Gail Gillispie © Copyright...

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