HUD recently released a memo giving guidance regarding remote Management and Occupancy Reviews (MORs) conducted by Performance-Based Contract Administrators (PBCAs). This updated guidance is effective with MORs scheduled on or after January 1, 2024. HUD says that Management Occupancy Reviews are an important task that PBCAs perform for HUD to verify that property owners and management agents are in compliance with HUD regulations and guidelines and the Housing Assistance Payments (HAP) contracts.
The big take-aways
HUD requires MORs to be conducted on site by PBCAs Tenant Files, EIV reports, waiting lists cannot be reviewed remotely. Should there be health and safety issues that prevent an on-site MOR, PBCAs must contact their Headquarters Contract Administration Oversight Monitor who will determine if any part of the MOR can be conducted remotely (excluding tenant files, EIV reports, waiting lists).
Why is “on site” so important?
HUD says that on-site MORs allow for receiving feedback from residents and offer the opportunity to interview staff and owner representatives in person. HUD adds that on-site MORs make it possible to observe property conditions in common areas and units including the follow-up on REAC inspections findings as well as the evaluation of project records and tenant files, and help protect tenant Personal Identifiable Information (PII).
