The Reinstatement of MORs in 42 PBCA Contested States

Via a letter issued to Performance-Based Contract Administrators (PBCAs) last month, HUD leadership indicated they are considering a proposal to permit PBCA staff in 42 states to resume conducting Management and Occupancy Reviews (MORs), as part of their interim contracts. The Owners and Agents (OAs) in these 42 states could be looking at MORs being phased in as early as March 2016.

Here’s a brief recap of what OAs should know:

1. HUD indicated the initial MORs would be performed on projects identified as high-risk. How HUD defines a property as ‘high-risk’ was not discussed in the letter.
2. HUD’s intention is to reinstate MORs in the 42 states; however the approach is being finalized. HUD acknowledges the undesirable impact that nearly 5 years with no MORs has had on owners in these 42 states. HUD appears eager to negotiate a solution as soon as possible, and not wait for the PBCA rebid to be completed.
3. HUD is currently assessing the cost/benefits of current PBCAs resuming the MORs versus having Alpine Companies (current asset management subcontractor for HUD’s transformation initiative) perform the MORs.
4. If your property is administered by a PBCA in one of the 11 uncontested states, by a Traditional CA, or by HUD (i.e. PRACs), your MORs will continue as they have in the past.

The reinstatement of MORs is imminent. Being aware of HUD’s plan in 2016 provides an opportunity for OAs to be informed, schedule file reviews and/or onsite visits, do quality control checks, etc., to reduce or eliminate the number of findings cited in a MOR report.

Possible factors OAs should evaluate to determine their likelihood of being selected for a review in this first round of MORs might include one or more of the following indicators:

• A previous Below Average or Unsatisfactory MOR rating
• APPS flags
• Failing REAC scores
• Poor financial ratings in FASS
• Recent OIG investigations/referrals
• Evidence of terminated access or inappropriate use of HUD’s EIV System
• Items of concern reported in TRACS queries

PMCS recognizes the anxiety the reinstatement of MORs will create. By providing timely updates and tangible instruction and consultation to help you prepare, we remain a reliable, qualified resource and veteran partner for you. We have done so for over 26 years.

As housing professionals, you have two choices:  You can proactively prepare before the MOR is scheduled or you can take your chances and be reactive to a MOR report that may include findings and require corrective actions that are stressful and costly to complete. Which choice will you make?

In light of these developments, PMCS is scheduling both webinars and live training classes focused on MOR preparedness.

Our first live MOR class for the year  is presented in association with SWAHMA and is scheduled for

• Friday, March 4, 2016 in Austin TX.

MOR Webinars have been scheduled for

• March 17, April 21 and May 17, 2016.

Additional MOR  live class and webinar dates, locations and times will be announced on our website, on Facebook and via email soon.

If you know you are in need of immediate assistance (pre-MOR site visit, sample tenant file review, policy review or revisions, AFHMP revision, EIV master file audit, etc.) contact us today to explore the cost-effective and convenient ways PMCS can assist in your MOR preparation, both on-site and in a remote capacity.

A small proactive investment for training and consultation now could yield a significant amount of time and monetary savings for you in post-MOR remedies.