Housing Policies and Proce… · Web vie

2017Wesley Housing Corporation of Memphis, Inc. d.b.a Wesley Living1615 Appling, Cordova TN 38016

Ron Budynas, VP/COO

[HOUSING POLICIES AND PROCEDURES]This document and its contents comprise the general Policies and Procedures for management operations on all communities Managed by Wesley Housing Corporation of Memphis Inc. It is the intellectual property of Wesley Housing Corporation of Memphis Inc. Use by other entities is strictly forbidden.

WESLEY LIVING HOUSING POLICIES AND PROCEDURES

Contents

1. Wesley Philosophy .......................................................................................51.1. Mission Statement.......................................................................................................5

1.2. Philosophy..................................................................................................................5

2. Acronyms and Definition Used in this Book .............................................53. Community’s Management Plan ..............................................................103.1. Management Plan......................................................................................................10

4. Accounting ..................................................................................................104.1. General.....................................................................................................................10

4.2. Chart of Accounts......................................................................................................10

4.3. Accounts Payable......................................................................................................10

4.4. Accounts Receivable.................................................................................................11

4.5. Receipt (Payments) Processing.................................................................................11

4.6. Payroll Processing.....................................................................................................12

4.7. Budgeting and Financial Review................................................................................12

4.8. Employee Management............................................................................................13

5. Orientation for New Staff .........................................................................135.1. New Employees........................................................................................................13

5.2. Managers/Assistant Managers/Office Coordinators..................................................13

5.3. Other Community Staff.............................................................................................14

5.4. Safety Meetings........................................................................................................14

6. Residential ..................................................................................................146.1. Tenant Selection.......................................................................................................14

6.2. Limited English Proficiency Policy..........................................................................15

6.3. Collection policy.......................................................................................................16

6.4. Debt Repayment.......................................................................................................16

6.5. Pet Deposits..............................................................................................................16

6.6. Move-outs.................................................................................................................17

6.7. Eviction Policy..........................................................................................................17

6.8. Smoking....................................................................................................................19

6.9. Policy for Resident Space Use..................................................................................20

6.10. Incident Reporting.............................................................................................21

6.11. Flu Policy...........................................................................................................22

09/05/2017 2


6.12. Homeless Preference and Policy.......................................................................23

7. Call for Aide ...............................................................................................247.1. Introduction...............................................................................................................24

7.2. Calls with Enunciator Panels....................................................................................24

7.3. Calls without Enunciator Panels...............................................................................25

7.4. Pendants....................................................................................................................25

7.5. Monitored systems....................................................................................................25

7.6. Investigations............................................................................................................25

8. Security for Garden Style Apartments ....................................................268.1. Introduction...............................................................................................................26

8.2. Electronics Equipment..............................................................................................26

8.3. Security Level One...................................................................................................27

8.4. Security Level Two...................................................................................................30

8.5. Security Level Three.................................................................................................31

8.6. Security Level Assignments......................................................................................32

9. Security for High and Midrise Apartments ............................................339.1. Introduction...............................................................................................................33

9.2. Electronics Equipment..............................................................................................33

9.3. Security Level One...................................................................................................34

9.4. Security Level Two...................................................................................................36

9.5. Security Level Three.................................................................................................38

9.6. Security Level Assignments......................................................................................39

10. Key and Lock Security and Accountability .............................................3911. Tenant Administration ..............................................................................4211.1. Tenant Files and Compliance –.........................................................................42

11.2. Apartment Inspections......................................................................................43

11.4. Policy for Reasonable Accommodations...........................................................44

12. Resident Firearms and Weapons .............................................................4613. Inclement Weather Policy .........................................................................4814. Vehicle Operation and Maintenance .......................................................4914.1. Introduction.......................................................................................................49

14.2. Qualification.....................................................................................................50

14.3. Operating the Vehicle.......................................................................................50

14.4. Maintenance and Preventative Maintenance.....................................................52

09/05/2017 3


14.5. Accidents..........................................................................................................53

14.6. Safety................................................................................................................54

15. Maintenance ...............................................................................................5415.1. General..............................................................................................................54

15.2. Work Orders Paper............................................................................................54

15.4. Unit Make Ready..............................................................................................56

15.5. Emergencies......................................................................................................56

15.6. Contractors and Vendors...................................................................................57

15.7. Vendors Hired by Residents..............................................................................58

15.8. Preventive Maintenance....................................................................................58

15.9. Energy Conservation.........................................................................................60

15.10. Visually Appealing Property.............................................................................60

15.11. Advertising and Outreach..................................................................................61

15.12. Word of Mouth and Incentives..........................................................................61

15.13. Marketing Package:...........................................................................................61

15.14. Application Package:........................................................................................62

15.15. Tenant Selection Plans (TSPs)..........................................................................62

15.16. Required Postings:............................................................................................65

15.17. Parking..............................................................................................................66

16. Desk Top Procedures .................................................................................6616.1. General..............................................................................................................66

16.2. Desk Top Procedures........................................................................................67

16.2.1. Variations from Written Policy.....................................................................67

16.2.2. Additions to Written Policy...........................................................................67

Appendix A ...........................................................................................................69Appendix B ...........................................................................................................72

09/05/2017 4


1. Wesley Philosophy

1.1. Mission Statement - “In response to the love of God, the Mission of Wesley Senior Ministries is dedicated to providing excellent housing and services which enhance the quality of living for elderly persons and their families.”

1.2. Philosophy – Wesley Living is a not-for-profit enterprise of faith based services. We strive daily to provide those supportive services including housing and associated activities to provide a home and high quality of life.

2. Acronyms and Definition Used in this Book

2.1. AASC – American Association of Service Coordinators – The National Association providing technical assistance, continuing education, advocacy and overall policy guidance for Service Coordinators.

2.2. ADA/504 –Americans with Disabilities Act of 1990/Fair Housing Act of 1968. These acts set basic standards of protection for people with disabilities in employment, accessible community spaces in business properties and full accessibility in apartments over 4 units. The only part of ADA that applies to HUD housing is the requirement for accessibility in common spaces. Section 504 stresses physical modifications for reasonable accommodation, which requires us to make affordable modifications needed by a disabled person in our apartments.

2.3. AFHMP – Affirmative Fair Housing Marketing Plan – a HUD required plan which gives the basis for outreach to selected areas of your community. Must be updated every five years.

2.4. A/P- Accounts payable. See section 4.3

2.5. A/R – Accounts receivable. See section 4.4

2.6. BBRI – Budget Based Rent Increase. The method by which HUD/ and/or CA approve increases in rents. See HBK 4350.1 chapter 7 and the Section 8 Renewal Guide.

2.7. CA – Contract Administrator. A state or local agency which has the contract with HUD to monitor properties with Section 8 contracts in its catchment area.

2.8. CEU – Continuing Education Units. These are units that may be granted in some training classes. Training credit can be given in hours or CEUs.

2.9. CFR – Code of Federal Regulations. These are the agency interpretation of statute and have the force of law. Only Washington can waive a regulation.

09/05/2017 5


2.10. COC – Continuum of Care Program- This is a group of organizations dedicated to fighting homelessness.

2.11. Field offices may waive Handbook requirements if the waiver does not conflict with a regulation/statute.

2.12. COO - Chief Operating Officer and Vice President. Oversees the Housing and Health Care Divisions.

2.13. COS/CPO – Certified Occupancy Specialist/Certified Professional of Occupancy: A three-day course for Managers, Assistant Managers and Office Coordinators, to learn the basics of the HUD Occupancy process and practice transmission of data provided by National Center for Housing Management. Managers should accomplish either this certification or the Certified Professional of Occupancy (CPO) from SAHMA.

2.14. DoL – Department of Labor: The Federal agency that monitors compliance with wage and hour and safety laws.

2.15. Fair Housing Act of 1968 (FAA): Delineates statutory regulations for providing housing that is free from discrimination of protected and special class individuals.

2.16. FH&EO – Fair Housing and Equal Opportunity – The arm of HUD that investigates complaints of discrimination. See HBK 4350.3, Section 2, 4, 5 and 6, and HBK 4350.1, Chapter 9, for HUD requirements and review processes. These are under constant HUD updating.

2.17. FMR – Fair Market Rents – local rent levels set annually by HUD at the county/city level.

2.18. HBK – Handbook. The standard acronym for the major HUD rulebooks we follow.

2.19. HAP – Housing Assistance Payments: These are the subsidy payments provided to a housing provider under the Section 8 program. The “HAP” is a contract for a certain number of dollars covering 20-40 years. Twenty year contracts are generally renewable for an additional 20 years, at owner requested intervals.

2.20. HUD – The Department of Housing and Urban Development.

2.21. HR – WC Human Resources Department.

2.22. Leading Age - A national non-profit technical assistance and lobbying organization for senior housing, nursing homes and assisted living facilities. This organization was formerly AAHSA.

09/05/2017 6


2.23. LIHTC – the Low Income Housing Tax Credit program is an Internal Revenue Service (IRS) program which allows tax credits to be sold to syndicators to raise money for acquisition and or rehabilitation of existing low income housing and the development and building of new low income housing.

2.24. MCO – Managed Care Organization – An insurance company hired by the state to manage the Medicaid program.

2.25. MOU – Memorandum of Understanding – a non-binding agreement between two parties.

2.26. NCHM – National Center for Housing Management - a major provider of training nationally for housing managers and others.

2.27. Paylocity – The web based software used for HR and payroll management.

2.28. PM – Preventive Maintenance - The care and servicing by personnel for the purpose of maintaining equipment and facilities in satisfactory operating condition by providing for systematic inspection, detection, and correction of incipient failures either before they occur or before they develop into major defects. Preventive maintenance is covered in paragraph 15.8.

2.29. PRAC – Project Rental Assistance Contract: The subsidy program that replaced Section 8 and the HAPs for Section 202 projects in 1990. Eligibility, income and rent guidelines are slightly different than those of Section 8.

2.30. Quadel – a national training and technical assistance organization, similar to NCHM, above.

2.31. QA – Quality Assurance Representative is a person employed outside the housing management company who monitors the quality of service coordination programs within our housing portfolio.

2.32. RAM – Regional Asset Manager – Supervisor of assigned community Managers and Office Coordinators.

2.33. R4R- Reserve for Replacements – A HUD required escrow account in which budgeted dollars are set aside in a special reserve each month. These funds may be released with HUD approval for capital replacements (e.g., appliances, carpets, windows, roofs, HVAC units.)

2.34. RCS – Rent Comparability Study – Compares market rate apartment complexes to assign a fair market rent to the subject study property.

09/05/2017 7


2.35. REAC - Real Estate Assessment Center – The Arm of the Office of Housing in HUD that inspects all HUD properties for physical defects on an annual or multi-year schedule.

2.36. RR- Residual Receipts – “Surplus cash” existing at the end of the budget year in a non-profit community that is put into a restricted fund. It is used “for the benefit of the tenants” with HUD approval. HUD has announced that the RR funds may be used to reduce HAP payments.

2.37. SAHMA – Southeastern Affordable Housing Management Association: A Regional non-profit technical assistance, training and lobbying organization for multifamily and senior properties, both for-profit and non-profit. Its national affiliation is NAHMA.

2.38. SA – Site Assistant: A contracted person who lives on site and is on-call for emergencies when the office is closed.

2.39. SC – Service Coordinator – An employee who is a mental health professional, nurse or social worker who connects residents with needed services to stay independent.

2.40. TA - Technical Assistance. The process of helping someone do or carry out a process/program/activity and the like so they can do it on their own.

2.41. THDA – Tennessee Housing Development Agency: The Tennessee Housing Development Agency has partially funded Wesley Pine Meadow through the HOME program and is the current Contract Administrator for HUD on all Section 8 properties in Tennessee. Additionally, THDA is responsible for administration of the LIHTC program in Tennessee for the IRS.

2.42. TRACS – Tenant Rental Assistance Certification System. The HUD computer program that holds all tenant data. See section 11.3.

2.43. TSP – Tenant Selection Plan. A document required by HUD, which standardizes the manner in which people apply for and are selected for admission into a HUD subsidized community. These differ slightly among types of communities (e.g., Section 8, 2302/8 202/PRAC) See section 15.15.5

2.44. Wesley Web Site: Basic information on Wesley properties and other material. The address is “www.wesleyliving.com”. An additional web site is www.wesleyhousing.com. There is a supervisory section in the lower right of the home page for which you need a password and ID. Most forms are already available on the site. Additionally, vital documents such as rent schedules and AFHMP are stored there for access at any time.

09/05/2017 8


2.45. WC: Wesley Housing Corporation of Memphis Inc. dba Wesley Living: the management company that manages all contracted properties by agreement with the owning entities with HUD approval.

2.46. WSM – Wesley Senior Ministries, Inc., the company that provides certain supportive services to communities mostly in Shelby County that are managed by WC.

2.47. Yardi – Yardi is the web based management software used by Wesley Housing Corporation. Yardi is for use by authorized personnel only and contains all the information about residents, property finances, and maintenance. Log in for Yardi can be found at Login Login.

09/05/2017 9

https://www.yardiasptx11.com/23460wesley/pages/LoginAdvanced.aspx


3. Community’s Management Plan

3.1. Management Plan - The Management Plan is an agreement between the community owner and the management agent (WC) for HUD subsidized properties and is HUD approved. In all cases it lays out the manner in which the management company agrees to operate the community for the owner. A copy of the current management plan for your community is on the web site.

4. Accounting

4.1. General - The accounting procedures and policies are designed to ensure that no material weaknesses are found in association with Generally Accepted Accounting Principles (GAAP), as well as maintain compliance with regulatory agencies such as HUD. Material weaknesses occur when someone is able to circumvent processes, which then violate laws, rules, and regulations, many times for personal gain. To achieve a secure financial process, there must be checks and balances in place so that no one person has control over an entire process. The procedures outlined here are intended to minimize and prevent breakdowns in internal controls. Additionally, the accounting of revenue and expenses is important in planning rent increases, budgeting, payments, etc. Accounting functions are completed through Yardi. See Yardi Login for Yardi information and login.

4.2. Chart of Accounts – Although the general ledger chart of accounts is universal for all, some properties may have additional codes unique to that facility. You should use the general ledger account numbers in the Property’s Yardi trial balance or budget comparison reports as budgeted. If something occurs that was not budgeted and does not seem to fit into the budgeted accounts, you should contact the Accounting Manager or Chief Financial Officer (CFO) for direction of the appropriate account to be used.

4.3. Accounts Payable – Invoices and check requests (payables) are to be entered into Yardi by the community staff. All invoices should be approved for payment (preferably with a stamp) which details the location, whether it is eligible for replacement reserve funds, the apartment number (if applicable), the general ledger account number(s), dollar amount to be paid, and approval signature.

Invoices should be entered immediately as they are received. If the invoice is being disputed and not resolved within ten (10) working days then the original invoice should be entered in Yardi. This allows for payment planning and overall cash management. If an invoice is being disputed, the manager should communicate to the Regional Asset Manager, Director, and accounting to place a “hold” on the payable. The payable will remain on “hold” until the manager

09/05/2017 10


communicates the resolution to the same individuals of the outcome for either deletion, adjustment (via a credit memo) or payment. If this occurs at fiscal year-end then contact accounting.

Once entered into Yardi, the invoice should be stamped or noted as entered with the initials of the person who actually keyed the invoice into Yardi along with the date. The invoices are to be scanned and attached to the payable in Yardi. When an invoice is not attached to the Yardi payable, it should be scanned as a batch and emailed to accounting. Upon completion of the Yardi payable batch, an “Unposted Batch” report should be printed and then signed, dated, and scanned to accounting indicating the completion of the batch. Managers, or those entering the payables other than accounting, are not permitted to “post” batches. Managers should retain and file the original invoice by vendor, in order from the most recent to oldest. Original invoices should be stored for three years and then destroyed by shredding, as accounting will be maintaining the processed invoices in accordance with the document retention and destruction policy.

Accounting will post all batches upon review, and invoice payment will be completed in accordance with current accounting division practices. Checks to the vendors will be sent on a schedule determined by the CFO and will follow the priority schedule established by the management company.

4.4. Accounts Receivable - Receivables represent revenue earned and generated through the Yardi workflow of monthly postings of lease charges (pet deposits, non-HUD rents, etc.), postings of rent and HAP with the HUD voucher development, move-in and move-out processes, and manual charge postings (resident gets a pet, damages, etc.). These processes in Yardi should be conducted in accordance with the current monthly processing check sheet. The check sheet is to be filed with the voucher and paper work from HAP check deposits and must be used each month.

4.5. Receipt (Payments) Processing – Only checks or money orders are to be accepted as payment for any service or receivable. All payments should be processed through the bank check scanner on the day they are received. Leaving unprocessed checks is an invitation to theft and could jeopardize the safety of employees, residents, and visitors in or near the community office. Locations without check scanners should make bank deposits each day when payments are received (copies of the checks should be made before taking the deposit to the bank). All deposited checks should be retained for 30 days after the deposit and then shredded.

All bank deposits are to be entered by the community staff into Yardi. All Yardi batches must match the date and amount of the actual deposit for bank reconciliation and for ease of researching information between the banks and Yardi. Similar to the accounts payable entry, managers and those other than accounting entering a receipt batch are not permitted to “post” non-HAP receipts.

09/05/2017 11


Upon completion of a receipts batch, an “Unposted Batch” report (printed and signed), as well as deposit reports from the bank scanner software (or copy of deposit slip for those without a check scanner), are to be scanned and emailed to the receipts email address.

Caution and care should be used when applying a payment to charges on a tenant ledger. Failure to do so may prevent the ability to apply various housing policies related to occupancy. Additionally, other non-tenant receipts (i.e. laundry revenue, vending machine revenue, etc.) should be entered using the applicable charge code or general ledger account number.

Accounting will notify the Manager when the HUD subsidy payment (HAP) has been deposited into the bank account. Upon notification, Managers will enter the HAP receipt in Yardi in accordance with the current monthly processing check sheet. Those locations with mortgage payments deducted from the HAP payment will be advised on payment schedules in the same email from accounting, and the payments are to be reflected on the Yardi receipt as well.

4.6. Payroll Processing – Proper payments to employees help maintain morale and retain staff. Managers are responsible for the accuracy and submission of employee timekeeping, whether it is via a time and attendance system or paper timesheets. The manager is to review and ensure all time, whether worked or under a paid time off program defined in the employee handbook, is properly identified for payment, including overtime. The manager is to complete this process no later than 9:00 a.m. of the first business day following the pay period end date. There may be times that this will need to be completed sooner for holiday purposes. If a manager is planning on being out of the office on the day of payroll processing, they should arrange in advance for their direct supervisor to complete the process. If there are extenuating circumstances, a manager should contact the Accounting Manager or CFO. Please refer to the employee handbook for more information regarding payroll policies.

4.7. Budgeting and Financial Review - Budgeting is an important process that forecasts revenues and expenses for the property based on the anticipated operations. The budget process typically begins during the quarter prior to the fiscal year start date. The tools, with the applicable instructions, are created by the accounting department for the respective budget period.

Spending controls must be in place to ensure the community stays out of financial distress. Interim financial reports will be distributed to each manager upon completion by accounting. Within 5-work-days of receiving the financial reports, the Manager must review the budget comparison report and explain any revenue or expense line that varies by $500 or 10% of the budgeted amount. The explanation should be submitted to the Director of Housing via the Regional Asset Manager.

09/05/2017 12


4.8. Employee Management – Consistent and fair management of employees encourages development and retention. Managers should refer to the employee handbook and the Human Resources department for assistance and direction. The following addresses some key components of employee management for managers:

Open Positions – All open positions needing to be filled will be coordinated with a manager’s supervisor and Human Resources. All employment advertising will be done by Human Resources, with the manager choosing the applicants to interview. All applicants offered employment must meet screening requirements to be conducted by Human Resources.

Change in Payroll Form – A change in payroll form is to be completed for any new hire, termination, or general change of an employee’s position or compensation. These forms must have the required signatures and are to be turned into Human Resources well in advance of any effective dates.

Performance Evaluations – Timely and effective communication of an employee’s performance, good or bad, helps an employee understand expectations and adjust accordingly. The employee handbook addresses the performance evaluation deadlines.

Disciplinary Actions – All disciplinary actions, including separation of employment, should be reviewed with your supervisor and Human Resources prior to taking actions.

5. Orientation for New Staff

5.1. New Employees - All new employees get an orientation from their supervisor. See general and specific forms on the Wesley Website.

5.1.1. Employees will be expected to sign for any company property (I.E. credit cards, keys, tools, etc.) issued to the employee using the Acknowledgement of Receipt/Return of Company Property form from the web site or Smartsheet.

5.2. Managers/Assistant Managers/Office Coordinators: Managers normally get an orientation from their RAM or Housing Director over approximately 30 days. All managers are required to read this manual in its entirety as soon as hired. The Manager will similarly orient new Assistant Managers, as appropriate. Other Managers may assist as needed, as assigned by the RAM or Director of Housing. Additionally, one day for orientation at the corporate offices will be scheduled soon after hiring.

5.2.1. Depth and extent of orientation will depend on prior housing management experience and degree of HUD knowledge and experience. Basic training could last 30 days or more. The orientation will include at least basic

09/05/2017 13


Wesley Employee Handbook policies as needed, including supervision, Housing office operations, payroll and accounting operations, Yardi, Paylocity, Principle, basic property management and managerial responsibilities in accordance with current publications, and HUD procedures and processes.

5.2.2. The Manager/Assistant Manager and their supervisor will check-off and date each item on the orientation form. The employee and supervisor will sign and date the form when completed, keep copies and send the original to the Director of Housing for HR’s personnel file within 30 days of reporting for work. They will be used during the first 90 days review by the supervisor; the employee will provide feedback on the efficiency of the orientation system.

5.3. Other Community Staff: Community Staff (maintenance, housekeeping, Universal Caregiver, and service coordinators) will receive a more abbreviated orientation from the Manager (or their direct supervisor) in their first two weeks of employment. The orientation will include job duties and basic policies and procedures. HR will provide orientation during the hiring process as well.

5.3.1. Service Coordinators: Service Coordinators will receive orientation by the community Manager, RAM, HR, and QA Representative. Additional training will be met at sister properties working with a senior Service Coordinator. Orientation to the corporate offices will occur soon after hiring.

5.3.2. Quality Assurance will check-off and date each item on the orientation form. The employee and supervisor will sign and date the form when completed, keep copies and send the original to the Director of Housing for HR filing. These will be used during the first 90 days review by the supervisor; the employee will provide feedback on the efficacy of the orientation system.

5.4. Safety Meetings

5.4.1. Managers should train all staff monthly on a topic of safety. These should be documented on the appropriate form from the web site or Smartsheet and sent to HR. The topic is up to the manger. Suggestions may be available from HR.

6. Residential

6.1. Tenant Selection - Each community has a tenant selection plan. This is a detailed and up to date criteria for taking, processing, evaluating and accepting or rejecting applications. All applicants must be entered into Yardi as a guest. If

09/05/2017 14


they are not processed for immediate tenancy then they must be rejected or placed on the waiting list. No manual or paper waiting lists are permitted. Applications for HUD properties will be processed in accordance with HUD directive and the tenant selection plan only. All other properties will process applicants in accordance with the individual standard operating procedures for that community.

6.1.1. Applicants who are selected for move-in must pay a security deposit in accordance with HUD regulations, or for properties that are not HUD, must pay the security deposit assigned to that property. All security deposits are due before move-in along with the first month’s prorated rent. These may be collected in advance when the applicant agrees to take the apartment or when they sign the lease on move-in day (The process known as pre-leasing). Either procedure is permissible but managers should minimize the vacancy of a unit. Realizing that most applicants will have to give notice to the landlord where they currently live and that most of those landlords require a 30-day notice, applicants should be identified as soon as notice by your current resident is given.

6.1.2. All payments will be processed in accordance with the receivables section of this manual and appropriate check sheets. A portion of the rent may be placed in a written payment plan which is part of this policy manual (See Appendix B. The portion allowed to be placed on the payment plan must be approved by the RAM or Director of Housing.

6.1.3. All applicants will be screened. Applicants at subsidized properties will be screened in accordance with the tenant selection plan for that property. All other properties will be screened in accordance with the standard operating procedures for that property. Subsidized properties will screen at a minimum the credit worthiness of an applicant and all family members over 18 years old, background, and landlord references or personal references. Every effort should be made to use at least two landlord references (current and previous landlord.)

6.1.4. Applicants may appeal a decision of rejected if done so within fourteen (14) days of the rejection in writing. Once an applicant appeals a rejection, the Appeal should be forward to the RAM. The RAM will conduct an interview and review of paperwork and render a decision.

6.2. Limited English Proficiency Policy 6.2.1. Although most applicants for housing speak English, Wesley Housing

Corporation managed properties encourage LEP applications. Wesley Housing provides informational materials and legal documents in Arabic, Armenian, Chinese, Farsi, French, Khmer (Cambodian), Korean, Portuguese, Russian, Spanish, Tagalog, and Vietnamese. Materials available to applicants include Fair Housing Materials, Certification Materials, and leases. These materials are available to all Wesley Managers for use at any

09/05/2017 15


time they have an applicant who struggles with English through the internet. Additionally, some translation service is available to applicants who speak languages most common to this area such as Spanish. Managers should request translation services when communication is difficult. Services for translation will be provided by phone. The translation service is also available for applicant assistance during the completion of the application. Wesley Housing will make every effort to accommodate applicants and residents of all cultures, heritages, and backgrounds and does not discriminate based on race, color, creed, national origin, religion, familial status, sex, income, handicap, or sexual orientation.

6.3. Collection policy - Rent is due and payable at the office on the first day of each month. We extend a grace period until the 5th of the month for the convenience of our tenants. If the 5th falls on a holiday or weekend then the period will be extended to the end of the first business day after the holiday or weekend. A late letter will be generated on the 6th day of the month (or after the first business day when the 5th falls on a weekend or holiday) in the event the rent is not paid (or a check is returned.) A 30-day notice to vacate the apartment will be sent to the tenant on the 11th. The late and 30-day notices are located on the Wesley Web Site. Legal action will be taken upon the end of the 30 day notice. Any unpaid charges older than 30 days will be reported to the collection agency. Rent paid after the 30-day notice has been issued will be marked “Accepted with Reservation” on the back of the check. If additional rent has been charged after the 30-day notice was issued and the resident makes payment, then the credit will go toward the newest charges leaving the oldest charges open. These payments will be marked “Accepted with Reservation” as well. Payments made after the resident has been turned over to an attorney will be made directly to the attorney. Take no checks from residents after they have been turned over to the attorney.

6.4. Debt Repayment - Information pertaining to repayment of debts by residents is contained in the most recent copy of the Collection, Payment or Repayment Plan for properties managed by WC which is Appendix B. This plan may also be found under the Housing-General tab of the Wesley Housing web site or on the appropriate Smartsheet.

6.5. Pet Deposits - A $300 pet security deposit is charged on all subsidized or LIHTC properties. The deposit may be paid in full or paid as a $50 initial payment and an additional 25 payments of $10. There is no payment plan necessary for this activity as this is per HUD regulation. At non-subsidized properties there is a $100 non-refundable pet deposit and $15 per month pet fee. Pet deposits on the HUD/LIHTC properties are returned when the pet is no longer with the resident. When the resident notifies the Manager that the pet is no longer in the building then the Manager should inspect the apartment for damage, odor, or infestation (using the annual inspection form) caused by the pet. If any of these conditions exist then they should be corrected and billed against the deposit. Send an email to accounting and copy the Director of Housing with a summary stating that the

09/05/2017 16


inspections were done and what portion of the deposit should be returned and what portion should be applied to charges. The Manager should enter the charges into the resident’s account before asking for the deposit return. This must be done within one week after the tenant has made notification so that the deposit can be processed.

6.6. Move-outs - Move-outs must be processed in a timely manner. State law mandates that security deposits be returned to former residents within 30-days. In order for this to occur, Managers must make inspection of the apartments immediately upon the resident vacating the unit. All damages should be annotated on the inspection with the resident present if possible. Both the resident and the Manager should sign the move-out inspection. If the resident does not agree with the inspection, then there is an area for them to write what they disagree with. Pictures should be taken of all damages as well as disputed items in case the dispute goes to court. Process the move-out and complete deposit accounting in Yardi in accordance with current check sheets within five days of the move-out.

6.7. Eviction Policy

6.7.1. The standardization of evictions is necessary to ensure that all of the residents as well as managers and service coordinators are aware of those actions which will be considered other good cause or material non-compliance with the lease. All instances of eviction will be in accordance with this policy unless specifically not covered here. Those types of situations will be handled by the Regional Asset Manager with consultation of the Director of Housing.

6.7.2. Evictions are discouraged and considered an act of last resort. Wesley Living’s philosophy has always been that “We are in the business of housing, not un-housing.” Even when an eviction notice is filed and delivered to the resident, an appropriate cure may be negotiated with the resident. Only when no cure or no cooperation with the resident is possible will evictions be prosecuted. Again, this will be closely coordinated with the Regional Asset Manager and Director of Housing. Eviction notices shall not be given to a resident unless the Director of Housing has approved both the action and paperwork.

6.7.3. Although the Tennessee Residential Tenant and Landlord Act only covers counties with populations above 68,000 according to any federal census after 1970 and excludes counties with populations between 80,000 and 83,000, 92,200 and 92,500, 118,400 and 118,700, and 140,000 and 145,000; all properties will abide by the law as it provides guidance and protections for both the residents and the landlord. Any county or state not covered by a Residential Tenant and Landlord Act has no protections for the resident and supplies no structure for handling real estate transactions. By adopting the

09/05/2017 17


spirit of the law in counties and states without a statute, those protections and structure are preserved. Currently this included Kentucky and Arkansas.

6.7.4. Leases are provided by the Department of Housing and Urban Development. All leases on all properties are in accordance with HUD regulations. Addendums used with any HUD leases are approved by the Department. The lease is made up of the lease, any approved addendums to the lease, and the three attachments which are the House Rules, Pet Rules, and the Move-in/Move-out inspection. Service Animal Rules may substitute for the Pet Rules. A violation of any document including the lease, lease addendums, or attachments is considered a lease violation. All leases are for an initial term of one year. The lease is extended month by month after the one year. Changes to the lease in the first year are not permitted as the lease is a contract and has a term and therefore cannot be changed by the tenant, HUD or the owner/manager. The lease obligates the tenant to occupy the apartment for one year, pay one year’s worth of rent in 12 monthly payments, and to pay the security deposit prior to occupying the apartment.

6.7.5. All security deposits are due and payable before occupancy. Only the Director of Housing may authorize an applicant to move into an apartment without paying security deposits. Residents moving from one apartment complex to another may not use the security deposit from another facility to cover the security deposit of a different facility.

6.7.6. The lease allows landlords to evict residents for material non-compliance with the lease. Examples of material non-compliance are listed in your lease and the following:

6.7.6.1. One or more substantial violations of the lease. A substantial violation of the lease can cause eviction on the first offense. These types of evictions will be decided on a case by case basis by the Director of Housing. The more severe the impact on the property or the other residents the more likely the eviction. Violations for violence or threats to health, safety, or welfare of persons or property will result in termination of the lease with three (3) days for the resident to vacate per T.C.A. §66-28-517. Violations of the firearms policy are guided by.

6.7.7. Repeated minor violations of the lease may cause an eviction notice to be issued. More than four (4) minor violations in an eight (8) month period shall be cause for an eviction. Minor violations of the lease are those violations that:

6.7.7.1. Disrupt the livability of the project;

6.7.7.2. Adversely affect the health or safety of any person or the right of any tenant to the quiet enjoyment to the leased premises and related project facilities,

09/05/2017 18


6.7.7.3. Interfere with the management of the project, or

6.7.7.4. Have an adverse financial effect on the project

6.7.7.5. Failure of the tenant to timely supply all required information on the income and composition, or eligibility factors, of the tenant household (including, but not limited to, failure to meet the disclosure and verification requirements for Social Security Numbers, or failure to sign and submit consent forms for the obtaining of wage and claim information from State Wage Information Collection Agencies), and

6.7.8. Non-payment of rent or any other financial obligation due under the lease beyond any grace period permitted under State law. More than four (4) payments of rent after the grace period in an eight (8) month period constitutes a breach of the lease.

6.7.9. The lease may be terminated for other good cause, which includes, but is not limited to, the tenant’s refusal to accept changes to the lease agreement. Terminations for “other good cause” may only be effective as of the end of any initial or successive term.

6.7.10. When damages are caused to the property of the apartment complex and it is not normal wear and tear then the resident will be responsible for the cost of repairs. The resident may elect to have the damages repaired by a licensed, certified contractor agreeable to management and pay them directly or management will have the damages repaired and bill the resident. Damages may be paid for in installments in accordance with Wesley’s Payment and Repayment Policy. Generally, the resident has 30-days to pay for damages and may be evicted if damages are not paid in that period of time.

6.8.Smoking

6.8.1. All Wesley Living communities are non-smoking facilities. Managers are expected to have vigorous enforcement of the policy. The minimum policy is that there will be no smoking within 25 feet of any occupied building. The policy may also be that the property is entirely smoke free. The enforcement should continue with the precedence established of either 25 feet or entire campus unless changed by the Director of Housing. Employees are reminded that the same regulations for smoking apply to them as well.

6.9. Policy for Resident Space Use

6.9.1. Wesley Living is a provider of housing for the elderly. Our requirement from the Department of Housing and Urban Development is to provide Safe, Decent and Sanitary housing. We have a contractual requirement to provide such. In order to provide these conditions within our housing the resident is required to meet certain conditions within their residence. While we are

09/05/2017 19


defining these conditions, we should also stay aware that the resident has a certain right to privacy within the apartment and in no way should this policy infringe on that right. The reason for this policy is to ensure that the quantity and placement of personal items does not infringe on our requirement to do pest control, that there is no danger of items falling on someone and causing injury, and that the storage of items does not violate common sense health concerns.

6.9.2. Within both HUD policy and the lease, the landlord has a requirement to ensure there are no pests within the units. Although it is impossible to completely eradicate pests within our apartments we must stay vigilant in containing the number of pests to avoid an infestation. In order to do that, we have agreements with professional pest control companies who apply different compounds to control pests within all apartments at a reasonable cycle. Pest control is required in all apartments. Residents do not have the option of participating or not participating. We may use different compounds and devices to accommodate personal sensitivities but all residents are required to participate in the management approved processes.

6.9.3. In order for pest control agencies to be able to provide pest control, resident personal belongings must not interfere with access by the pest control agents. Therefore, when belongings are stacked in an apartment the item must not stack higher than 4 feet high and must be at least 6 inches from the wall if the stack is less than 5 feet wide and 12 inches from the wall if it is longer than 5 feet wide. Stacked belongings should not block any door or window including closet doors. Closets may not have items stacked on the floor in a manner that prevents pest control from treating the insides of the closets. If items are stored in the closet they must be removable (i.e. placed on dollies or moveable platforms, or stored in drawers with casters, etc.) for pest control. Chests or dressers placed in a closet that have gaps or clearance at the bottom may be used if the pest control agent can use the openings for access.

6.9.4. In an effort to ensure safety, belongings should be stored in a manner in which they will not fall on persons in the apartment and cause injury. Belongings that are stacked in accordance with the previous paragraph must be stable. Any evidence that the stacked belongings may be unstable and fall on any person or child is not allowed.

6.9.5. Belongings should not constitute an unreasonable weight load on any flooring in multiple floor buildings. Unreasonable weight loads will be the judgment of management, however, a resident may present professional opinion from an engineering company to dispute management judgment. In this case management may accept the opinion or may get a second opinion. The opinion of the management engineer will be the guiding judgment.

09/05/2017 20


6.9.6. There should be no trash stored with resident items. Trash is considered any item that causes a health issue (such as unrefrigerated food, used plastic bags, used paper products, etc.) or is unusable in day to day activities engaged by the resident. Items such as hobby materials may be kept in a reasonable quantity and in a useable and systematic storage methods.

6.9.7. No placement of furniture, storage items, or any personal items of the resident may restrict movement around the apartment. There must be a minimum 36 inch clearance path through any room in the apartment. This path must be clear to any window, door, closet or adjoining room. This clearance is necessary for egress during an emergency such as fire and for emergency medical persons to have access. Any turns in the access path must have a 48 inch turn area so that emergency medical personnel may maneuver a gurney or stretcher.

6.9.8. Any violation of this policy is a minor violation of the lease although serious health and safety infractions such as spoiled food, feces, excess weight, etc. may be deemed a serious violation. Residents may be given a reasonable time to correct deficiencies to this policy. In the event the clutter and storage is classified as hoarding, the service coordinator should be introduced so that the resident can obtain assistance in understanding hoarding and how to deal with it. In no way does the classification of hoarding allow for the violation of this policy, however, additional time frames may be necessary for the resident to comply. Violations of health or safety must be mitigated immediately whether it is hoarding or not. No longer than 14 days should be allowed to mitigate dangerous or health related situations, however, imminent situations should be remedied within 48 hours. Imminent situations would be spoiled food or dishes with maggots, mold, dangerous stacking that is so severe the threat of it falling and causing injury is evident, blocked egress, etc.

6.10. Incident Reporting6.10.1. Incidents outside normal or routine operations should be reported to

supervisors through the Incident Report located on the Wesley Web Site or Smartsheet. Incidents include but are not limited to the death of aresident, fire, flood, damage to property, accidents, resident injury, etc.

6.11. Flu Policy

6.11.1. In order to provide continued service to our fragile populations as well as look out for their general wellbeing and the wellbeing of our employees, we will follow this policy guide to do everything we can to minimize the flu impact:

6.11.1.1. Update the contacts on the residents sponsor forms to ensure the information that is provided is accurate and the person indicated is appropriate to take action on behalf of the resident if required.

09/05/2017 21


6.11.1.2. All residents should be paired up with another or other residents so they check on each other to ensure they are OK. Contacts are best made by phone and not in person to more minimize the contact between individuals and minimize the opportunity for spreading the diseases. Door signs are encouraged.

6.11.1.3. Once a resident is identified as contracting the disease then our staff should be kept abreast of the resident’s condition for preventative measures as well as be prepared to contact family members if necessary. Release of this information should be approved by the resident in writing. This is not public information. Residents who do not wish this information to be given out should also indicate in writing that they do not wish family to know. Employees should be told that they should exercise disease prevention measures when entering the room but should not be given specific information about the illness.

6.11.1.4. Resident meetings should include education on this program as well as overall education on the flu viruses and both detection and prevention methods.

6.11.2. We should make every effort to encourage residents to buy and use hand sanitizer. Possibly even offering hand sanitizer for bingo prizes. Hand sanitizer should be conspicuous in common spaces and especially in office spaces, community rooms, and public rest rooms.

6.11.3. When possible, we should arrange for grocery delivery for ill residents. We should have a release available so that when the groceries are delivered, property staff can sign for the delivery. We will place the groceries at the door of the resident and they will be able to get them without moving through the populated areas of the building.

6.11.4. Explore avenues of alternate communication such as email, notes, etc. so that contact between individuals is kept at a minimum.

6.11.5. Service coordinators should ensure that shots are scheduled at the facilities at least once prior to the flu season.

6.11.6. The following guidelines should be followed for employees:

6.11.7. All employees are encouraged strongly to get the seasonal flu shot. This will be paid for by the company. Personnel shortfalls are our biggest challenge. We cannot afford to have many employees off for long periods of time all at the same time.

6.11.8. Ensure that all maintenance staff uses latex gloves when working in residents’ apartments. Ensure maintenance staff carries hand sanitizer in work pouches and they are encouraged to use it after working each job.

6.11.9. Ensure that hand sanitizers that are purchased for the communities consist of at least 70% alcohol.

09/05/2017 22


6.11.10. Ensure that we are sanitizing common spaces where hand contact is common (Such as elevator controls, phones, television controls, computer controls, etc.) with a good quality sanitizing cleaning agent. On surfaces that can resist bleach; you may use a solution of three ounces of bleach to one gallon of water from a spray bottle. The solution should be left on the surface for a minimum of 30 seconds before wiping off.

6.11.11. Employees suffering from flu symptoms (Running nose, cough, and/or fever) will not report to work on days they are suffering from these symptoms. Managers are forbidden to work when they are suffering from these symptoms and any employee showing up for work with these symptoms should be immediately sent home.

6.11.12.This policy should be given to every employee, posted at every employee posting board and reinforced at all staff meetings. At some point the vigilance that we attain in the beginning will wane and we will fall back into routine. These reinforcements should work toward keeping us vigilant in our endeavors for the season. Should anyone have additional thoughts on prevention and containment or other reactionary measures, please feel free to submit them to the Director of Housing and Home Services and we will incorporate them into the policy if appropriate.

6.12. Homeless Preference and Policy

6.12.1. All Wesley Living managed properties have a preference for homeless families. The definition of Homeless can be found in your properties Tenant Selection Plan. It is a requirement that if an applicant requests a homeless preference, we must verify that the person’s condition is truly homeless by the definition of the Tenant Selection Plan.

6.12.2. Any applicant who applies for housing through a Continuum of Care (COC) will be considered homeless as verified by the COC. A memo should be obtained from the COC stating that this person is homeless and is being referred to us through their referral system. This memo is considered adequate verification. Additionally, anyone referred to us from the money follows the person program should have a memo from the referring Managed Care Organization (MCO) that the person is living in substandard housing, is losing housing through their action, or has lost housing due to hospital or rehabilitation care. Homecare should be able to acquire the needed verifications.

6.12.3. Applicants who are in immediate danger of losing housing are eligible under our definition. A letter from the current landlord, bank or code enforcement officer should be obtained describing the reason they are losing their housing. Additionally, if an applicant is leasing or living with another individual and that individual is losing the housing then that person and the landlord/bank should provide a memo of reason. This memo should be accompanied by a landlord reference. If this information is taken over the

09/05/2017 23


phone then the manager should document the person they spoke to and time and date of verification call.

6.12.4. Applicants who are living with a relative must verify the date they moved in with the relative, and the reason for the move. If the applicant voluntarily moved in with family then they are not considered homeless. Even if they moved in to convalesce after a sickness or injury. If they have resided in the family home for more than three months then they are not considered homeless. They must provide a contact to verify why they moved in with family or they are not considered homeless.

6.12.5. Applicants living without structure or in substandard housing or in housing not designed for permanent human habitation and cannot verify their conditions with any landlord or family may make a personal statement as to the reason they are living in the current conditions, that their housing does not meet their needs and that they meet the definition of homeless from the tenant selection plan.

7. Call for Aide

7.1. Introduction

7.1.1. To ensure all resident emergencies are handled when the call for aid is activated, the following procedures should be in place. The call for aid is a critical system for resident safety. Although there are different types of call for aid as explained below, all calls should be investigated.

7.2. Calls with Enunciator Panels

7.2.1. Communities with main buildings (Not garden style) will usually have systems with enunciator panels. There may be more than one. Most times the panel is located in an apartment and that apartment is designated as a non-revenue producing apartment. The person occupying such apartment (normally a contractor) is responsible for investigating any calls indicated by the panel immediately.

7.2.2. Panels are generally located in the vicinity of the office as well. During regular work hours, the manager is also responsible for investigating all calls indicated by the panel.

7.2.3. Apartments will have indicator lights and audible alarms outside the unit which illuminate and/or sound in the event the call for aid is activated. Residents and employees should be trained to investigate any time the light and/or audible device sounds at an apartment.

09/05/2017 24


7.3. Calls without Enunciator Panels

7.3.1. Garden style apartments will have a visual indicator (Usually a light) outside each apartment door. They will also have an audible device (Bell or horn) which will sound in the event the call for aid is activated. All residents and employees should be trained to investigate when a light and/or an audible device is observed.

7.4. Pendants

7.4.1. Some communities have been equipped with wireless pendants that the resident wears. The resident pushes a button on the pendant and that sends a signal to a monitoring station.

7.5. Monitored systems

7.5.1. Some communities have systems which are monitored by a central monitoring station (May be wireless pendants or hardwired stations with panels). Third party contractors are used for these systems. These systems will report to the monitoring station when the system has been activated. The monitoring company will then respond by telephone. Calling sequences should be as follows:

7.5.2. Communities using pendants should have the monitoring company call the resident in an effort to confirm that help is needed.

7.5.3. If there is no answer at the resident’s home or the monitoring company doesn’t have the means to call the resident then the monitoring company should have a call down list as follows:

7.5.3.1. During working hours the manager should be called first, then the Service Coordinator and then the maintenance staff. If there is no answer then the site assistant should be called.

7.5.3.2. After work hours the site assistant should be called to confirm the emergency. If no answer at the manager’s office, employees or the site assistant’s unit then the monitoring company should activate the Emergency Medical System (EMS).

7.6. Investigations - Anyone investigating a call for aid should contact the resident. If after a reasonable time the resident cannot be contacted (Won’t answer a locked door, no sounds or yelling) then employees may use a master key to enter the unit. If a key isn’t available or does not work on the unit, then the maintenance staff should be notified so that access can be obtained. Simultaneously the Emergency Medical System should be activated. If maintenance has not gained entry to the unit by the time EMS has arrived then EMS personnel should determine the best response to include forced entry.

09/05/2017 25


8. Security for Garden Style Apartments

8.1. Introduction - Many of our communities are Garden Style Apartments which offer unique security challenges. Unlike single access buildings, garden style apartment are spread out with numerous entry points which are either lightly secured or not secured at all. This security policy standardizes security procedures for those type facilities. This policy does not apply to high, mid and low rise style apartments. This policy gives guidance as to the security systems that we will deploy at these types of facilities. This policy will employ security personnel as well as other measures designed to minimize threats to the residents and staff. Where the policy refers to security personnel, the reference is to employees specifically hired as security or companies hired to provide security within a building as a proprietary security agency. This security policy should be the basis for all security procedures within the portfolio.

8.1.1. For the purposes of this policy, security is a reference to creating an atmosphere where our residents feel safe, property is protected, threats of harm are mitigated or prevented, and data is secure from damage or theft. Security will include security levels, designation of authorized and secure areas, visitor procedures, staff procedures, and reporting. The idea is to provide just the level of activity needed to provide security. It is not the intent of this policy to be all encompassing. Additions and alterations to this policy are the same as for all policies in the policies and procedures manual.

8.1.2. For the purposes of this policy, security will be broken down into three security levels. Level one will pertain to properties in metropolitan areas subject to moderate to high crime.

8.1.3. Level two pertains to properties in low to moderate urban, suburban, and rural areas with low to moderate threats.

8.1.4. Level three pertains to properties in rural and suburban areas with low threats of crime and procedures will be considered a minimum.

8.2. Electronics Equipment

8.2.1. All electronic equipment for a property, whether for residents or for staff, must be secured in a room with a locking door. All equipment will have cable locks and they will be locked together as well as anchored to an anchoring point (Counter, I-bolt in wall, stud, etc.). As additional security, equipment may also be placed in a locking cabinet within the secured room.

8.2.2. For televisions, WII’s etc. that cannot be locked in a room will still be secured by locking cables. TVs will also be secured with a locking wall mount. Wii games, controllers, etc. will also have a locking cabinet where these materials will be stored. There will be no electronic equipment (Except

09/05/2017 26


remote controls and game controllers) that is not locked and secured in some manner.

8.3. Security Level One

8.3.1. Security level one is the highest level of security granted to communities. It will consist of combinations of some or all systems. Systems consist of security guards from independent guard companies, community employees, controlled access systems, closed circuit cameras, physical barriers on site police officers, and authorization of agency. This security level must be approved by the Director of Housing or Chief Operating Officer in the Director’s absence and have a plan for systems to be incorporated completed.

8.3.2. Security guard companies – This will be a company whose sole purpose is to supply qualified security staff and guards. The company must be registered with the state as a proprietary security agency and must carry the minimum liability insurance as well as bonding. Security guard companies must be approved before use by the Director of Housing.

8.3.3. Security guard duties will include at a minimum of standing a post, regular patrols, and reporting. Most of the time the post will be at the front gate or entrance to the property.

8.3.4. Security guards must ensure that anyone entering the property was admitted by a family member through the controlled access system.

8.3.5. Security guards are not allowed to admit anyone into the facility who has not been granted access through the controlled access terminal except:

8.3.6. A resident who is known by security personnel or can prove their identity and has lost or forgotten their access fob or card reader may be granted access. In other instances, identification must be confirmed upon resident entry. In any case the resident must sign into a log book for such resident incidents. Managers should follow up the next day to ensure the resident does not need help obtaining a new access fob or card reader.

8.3.7. Attending staff (Home health, in home services, etc.) may be granted access if the agency is registered with management in accordance with the outside vendor policy and the employee of the agency has a company issued picture ID. Approved company listings should be published by management and available to security personnel.

8.3.8. Wesley staff members should be admitted with a Wesley badge as well. Wesley staff should use the controlled access for the building. The universal staff PIN should be available at all properties with controlled access. Additionally, a list of Wesley staff members is published and their fob or card reader identities entered into the control access so that corporate fobs or

09/05/2017 27


card readers will work on all properties. Wesley staff is not required to sign into the visitors or any other log.

8.3.9. All security posts will have a published standard operating procedure. The procedure will include the contents of this policy as it pertains to the security guards, times of occupancy of the post, challenging procedures, pass down logs, frequency of patrols (if applicable), names, photos (if possible) and descriptions of banned individuals, and daily instructions. Reports of patrols will include a report of lights that are not working which should be completed each night. Incident reports should be generated for anything outside the normal.

8.3.10. Community employees – Employees of the community may be solely hired for security or may contribute to security procedures through direct or indirect activities. This may range from manning a post at a facility to checking that systems like controlled access or camera systems are operating to changing sign in logs. Community employees are an integral part of a successful security program. All employees are tasked with ensuring banned individuals do not access the property, visitors sign the logs (If logs are used), and no visitors are on the premises without being escorted by a resident.

8.3.11. Controlled Access – When a controlled access system is in place, residents are able to allow access to visitors. Controlled access should allow access at doors and gates only during specified times. This will allow access during periods when the staff is present and residents are active but deny access at other times when there is no resident activity and fewer employees. Other guidelines for controlled access are:

8.3.11.1. Access to the property will not be given to resident visitors unless special circumstances occur and authorization has been granted to employees or security guards by the manager, RAM and Director. House rules require visitors to be with the residents at all times while on the property. This exists specifically to prevent resident visitors from accessing the premises when the resident is not home. Therefore, only the resident may allow access to visitors.

8.3.11.2. Visitors, when access has been granted by the resident, must remain with the resident during their visit to the property within reason (i.e. if the resident’s visitor is doing laundry for the resident, they may go to and from the laundry room without the resident, etc.)

8.3.11.3. Occasionally, each facility should have a day when all visitors must show a picture ID before signing into the visitor’s log (If a visitor’s log is used). ID checks should occur a minimum of 6 times per year. Sign in sheets on ID check days should be a different color.

09/05/2017 28


8.3.11.4. Any replaced fobs or card readers should be logged into the system to the resident. The lost fob or card reader will be deactivated immediately. If the fob or card reader is found then it may be reactivated and the replacement fob or card reader recovered without charge to the resident (or a credit back to the resident if they have already paid for it). Otherwise, all replacement fobs or card readers should be charged to the resident in accordance with current company policy.

8.3.12. Closed Circuit Cameras – Closed circuit cameras are used to monitor the actual people who enter or leave the property or surveillance of sensitive areas. Cameras should be installed so that the faces of persons entering the facility or exiting the facility at the gate are plainly recorded. Also cameras are placed in areas to protect physical barriers (i.e. a camera may be positioned on a gate to ensure anyone damaging the gate is recorded. In this way the camera protects the gate which is the physical barrier). Camera systems may be used in lieu of manual monitoring systems such as security guards. Off hour reviews of camera systems should be accomplished often to monitor what occurs after hours on the property and evaluate whether additional security is needed.

8.3.13. Alarm Systems – Alarm systems will be employed in high risk communities. Alarms will be placed on the office and community buildings. Alarms will have audible horns and will be monitored by a central system. Appropriate staff will be listed in order with the Director of Housing and Chief Operating Officer as the last two calls on the list. Call priority lists will be approved by the RAMs. Passwords and codes should be submitted to the Housing Office Clerk and Director of IT upon installation or change.

8.3.14. Physical Barriers – Physical barriers may be placed on properties to control traffic and deny access. Physical barriers may include fences, driveway gates, pedestrian gates, etc. Use of these systems will be part of an overall security program and designed to limit or deny use of areas and will be incorporated with other security systems such as controlled access and cameras. Physical barriers should not be evident. Barriers should be aesthetic and blend with the architecture, design and decoration of the community. Physical barriers also pertain to locks. Areas of sensitive information or pilferable materials should be secured by locked doors and cabinets. Locks which come with cabinets may be defeated easily. In high threat areas cabinets should have additional locks added to ruggedize and secure cabinets and possibly doors. Keys should be limited to those individuals who have a need to gain entry and no others. See section 10 for further information.

8.3.15. Authorization of Agency – In some communities, police departments allow the registration of banned individuals from a facility. Managers should notify the police departments upon discovery of any threats. The law will require the notification of the individual (Usually by the police department)

09/05/2017 29


before citing or arresting an individual. Any resident who allows a banned individual in their apartment is in violation of their lease. Lists of banned individuals should be posted in a public place where all persons can see and a copy of the list placed in the desk top procedures.

8.4. Security Level Two

8.4.1. Security Level Two uses elements of Security Level One. Security Level Two could contain elements as follows:

8.4.2. Community employees – Community employees are an integral part of a successful security program. All employees are tasked with ensuring banned individuals do not access the facility, visitors sign the logs (if required), and no visitors are in any building without being escorted by a resident.

8.4.3. Controlled Access – When a controlled access system is in place, residents are able to allow access to visitors. Controlled access should allow access at remote gates only. Other guidelines for controlled access are:

8.4.4. Visitors, when access has been granted by the resident, must sign the visitor’s log (if applicable) and proceed directly to the resident’s apartment. They must remain with the resident during their visit to the facility within reason (i.e. if the resident’s visitor is doing laundry for the resident, they may go to and from the laundry room without the resident, etc.) They must also sign the visitor’s log upon leaving the facility (if applicable).

8.4.5. Any replaced fobs or card readers should be logged into the system to the resident. The lost fob or card reader will be deactivated immediately. If the fob or card reader is found then it may be reactivated and the replacement fob or card reader recovered without charge to the resident (or a credit back to the resident if they have already paid for it). Otherwise, all replacement fobs or card readers should be charged to the resident in accordance with current company policy.

8.4.6. Closed Circuit Cameras – Closed circuit cameras are used to monitor areas of the property. Cameras should be installed so that the faces of persons entering the facility or exiting the facility at the main gate are plainly recorded. Off hour reviews of camera systems should be accomplished often to monitor what occurs after hours on the property to determine if additional security measures are needed.

8.4.7. Physical Barriers – Physical barriers may be placed on properties to control traffic and deny access. Physical barriers may include fences, driveway gates, pedestrian gates, etc. Use of these systems will be part of an overall security program and designed to limit or deny use of areas and will be incorporated with other security systems such as controlled access and cameras. Physical barriers should not be evident. Barriers should be aesthetic and blend with the architecture, design and decoration of the community.

09/05/2017 30


Physical barriers also pertain to locks. Areas of sensitive information or pilferable materials should be secured by locked doors and cabinets. Locks which come with cabinets may be defeated easily. In high threat areas cabinets should have additional locks added to ruggedize and secure cabinets and possibly doors. Keys should be limited to those individuals who have a need to gain entry and no others. See policy 10 for further information.

8.4.8. Authorization of Agency – In some communities, police departments allow the registration of banned individuals from a facility. Managers should notify the police departments upon discovery of any threats. The law will require the notification of the individual (Usually by the police department) before citing or arresting an individual. Any resident who allows a banned individual in their apartment is in violation of their lease. Lists of banned individuals should be posted in a public place where all persons can see. A copy of the list should be placed in the desk top procedures.

8.5. Security Level Three

8.5.1. Security Level Three is the lowest level of security we use in our garden style communities. It is designed to monitor who comes and goes and give some level of security however restrictions on visitors and residents are low. Elements of Security Level Three are:

8.5.2. Community employees – Community employees are an integral part of a successful security program. All employees are tasked with ensuring banned individuals do not access the facility, and no visitors are in the building or on the property without being escorted by a resident.

8.5.3. Visitors must proceed directly to the resident’s apartment. They must remain with the resident during their visit to the facility within reason (i.e. if the resident’s visitor is doing laundry for the resident, they may go to and from the laundry room without the resident, etc.)

8.5.4. Authorization of Agency – In some communities, police departments allow the registration of banned individuals from a facility. Managers should notify the police departments upon discovery of any threats. The law will require the notification of the individual (Usually by the police department) before citing or arresting an individual. Any resident who allows a banned individual in their apartment is in violation of their lease. Lists of banned individuals should be posted in a public place where all persons can see.

8.5.5. Physical Barriers – Physical barriers may be placed on properties to control traffic and deny access. Physical barriers should not be evident. Barriers should be aesthetic and blend with the architecture, design and decoration of the community. Physical barriers also pertain to locks. Areas of sensitive information or pilferable materials should be secured by locked doors and cabinets. Locks which come with cabinets may be defeated easily.

09/05/2017 31


In high threat areas cabinets should have additional locks added to ruggedize and secure cabinets and possibly doors. Keys should be limited to those individuals who have a need to gain entry and no others. See policy for Keys 10 for further information.


8.6. Security Level Assignments

8.7. Security Levels may be changed should situations or activity merit a review by the Director of Housing and/or the Chief Operating Officer. Properties where this policy applies and the levels they are authorized are listed as follows:

Wesley Graceland Gardens – Level 2Wesley at Adamsville – Level 3Wesley Oakhaven Village – Level 3Wesley Pine Ridge – Level 3Wesley Highland Meadows – Level 2Wesley Park Meadows – Level 3Wesley at Martin – Level 3Wesley Hills-Dyersburg – Level 3Wesley Pine Meadow – Level 3St Joseph Village – Level 3St Mark Manor – Level 3Woodland Homes – Level 3Wesley Murray Meadow – Level 3

9. Security for High, Mid-rise, and Low-rise Apartments

9.1. Introduction

9.1.1. Numerous communities provide a single building, common hall entry for the residents. They range from single story and as many as 10. This security policy standardizes security procedures for those type facilities. This policy does not apply to garden style apartments offering independent unit entry without a common building entry. Additionally, where the policy refers to security personnel, the reference is to employees specifically hired as

09/05/2017 32


security or companies hired to provide security within a building as a proprietary security agency. This security policy should be the basis for all security procedures within the portfolio.

9.1.2. For the purposes of this policy, security is a reference to creating an atmosphere where our residents feel safe, property is protected, threats of harm are mitigated or prevented, and data is secure from damage or theft. Security will include security levels, designation of authorized and secure areas, visitor procedures, staff procedures, and reporting. The intent is to provide just the level of activity needed to provide security. It is not the intent of this policy to be all encompassing. Additions and alterations to this policy are the same for all policies in the policies and procedures manual.

9.1.3. For the purposes of this policy, security will be broken down into three security levels. Level one will pertain to properties in metropolitan areas subject to moderate to high crime.

9.1.4. Level two pertains to properties in low to moderate urban, suburban, and rural areas with low to moderate threats.

9.1.5. Level three pertains to properties in rural and suburban areas with low threats of crime and procedures will be considered a minimum.

9.2. Electronics Equipment

9.2.1. All electronic equipment for a property, whether for residents or for staff, must be secured in a room with a locking door. All equipment will have cable locks on the equipment and they will be locked together as well as anchored to an anchoring point (Counter, I-bolt in wall, stud, etc.) As additional security, equipment may also be placed in a locking cabinet within the secured room.

9.2.2. For televisions, WII’s etc. that cannot be locked in a room will still be secured by locking cables. TVs will also be secured with a locking wall mount. Wii games, controllers, etc. will also have a locking cabinet where these materials will be stored. There will be no electronic equipment (Except remote controls and game controllers) that is not locked and secured in some manner.

9.3. Security Level One

9.3.1. Security level one is the highest level of security granted to communities. It will consist of combinations of some or all systems. Systems consist of security guards from independent guard companies, community employees, controlled access systems, closed circuit cameras, physical barriers and authorization of agency. This security level must be approved by the Director of Housing or Chief Operating Officer in the Director’s absence and have a plan for systems to be incorporated completed.

09/05/2017 33


9.3.2. Security guard companies – This will be a company whose sole purpose is to supply qualified security staff and guards. The company must be registered with the state as a proprietary security agency and must carry the minimum liability insurance as well as bonding. Security guard companies must be approved before use by the Director of Housing.

9.3.3. Security guard duties will include at a minimum of standing a post, regular patrols, and reporting. Most of the time the post will be at the front main entrance.

9.3.4. Security guards must ensure that anyone entering the facility was admitted by a family member through the controlled access system.

9.3.5. Security guards are not allowed to admit anyone into the facility who has not been granted access through the controlled access terminal except:

9.3.5.1. A resident who is known by security personnel or can prove their identity and has lost or forgotten their access fob or card reader may be granted access. In other instances, identification must be confirmed upon resident entry. In any case the resident must sign into a log book for such resident incidents. Managers should follow up the next day to ensure the resident does not need help obtaining a new access fob or card reader.

9.3.5.2. Attending staff (Home health, in home services, etc.) may be granted access if their agency is registered with management in accordance with the outside vendor policy and the employee has a picture ID from the agency.

9.3.5.3. Wesley staff members should be admitted with a Wesley badge. Wesley staff should use the controlled access for the building. The universal staff PIN should be available at all properties with controlled access. Additionally, a list of Wesley staff members is published and their fob or card reader identities entered into the control access so that corporate fobs or card readers will work on all properties. Wesley staff is not required to sign into the visitors or any other log.

9.3.6. All security posts will have a published standard operating procedure. The procedure will include the contents of this policy as it pertains to the security guards, times of occupancy of the post, challenging procedures, pass down logs, frequency of patrols (if applicable), names, photos (if possible) and descriptions of banned individuals, and daily instructions. Reports of patrols will include a report of lights that are not working which should be completed each night. Incident reports should be generated for anything outside the normal.

9.3.7. Community employees – Employees of the community may be solely hired for security or may contribute to security procedures through direct or

09/05/2017 34


indirect activities. This may range from manning a post at a facility to checking that systems like controlled access or camera systems are operating to changing sign in logs. Community employees are an integral part of a successful security program. All employees are tasked with ensuring banned individuals do not access the facility, visitors sign the logs, and no visitors are in the building without being escorted by a resident.

9.3.8. Controlled Access – When a controlled access system is in place, residents are able to allow access to visitors. Controlled access should allow access at doors only during specified times. This will allow access during periods when the staff is present and residents are active but deny access later in the night when there is no resident activity and fewer employees. Other guidelines for controlled access are:

9.3.9. Access to the facility will not be given to resident visitors unless special circumstances occur and authorization has been granted to employees or security guards by the manager, RAM and Director. House rules require visitors to be with the residents at all times while on the property. This exists specifically to prevent resident visitors from accessing the building when the resident is not home. Therefore, only the resident may allow access to visitors.

9.3.10. Visitors, when access has been granted by the resident, must sign the visitor’s log and proceed directly to the resident’s apartment. They must remain with the resident during their visit to the facility within reason (i.e. if the resident’s visitor is doing laundry for the resident, they may go to and from the laundry room without the resident, etc.) They must also sign the visitor’s log upon leaving the facility.

9.3.11. Occasionally, each facility should have a day when all visitors must show a picture ID before signing into the visitor’s log. ID checks should occur a minimum of 6 times per year. Sign in sheets on ID check days should be a different color.


9.3.13. Closed Circuit Cameras – Closed circuit cameras are used to monitor the actual people who enter or leave the facility. Cameras should be installed so that the faces of persons entering the facility or exiting the facility are plainly recorded. Also cameras are placed in areas to protect physical barriers (i.e. a camera may be positioned on a gate to ensure anyone

09/05/2017 35


damaging the gate is recorded. In this way the camera protects the gate which is the physical barrier). Camera systems may be used in lieu of manual monitoring systems such as security guards. Off hour reviews of camera systems should be accomplished often to monitor what occurs after hours in the facility and if additional security is needed.

9.3.14. Physical Barriers – Physical barriers may be placed on properties to control traffic and deny access. Physical barriers may include fences, driveway gates, pedestrian gates, etc. Use of these systems will be part of an overall security program and designed to limit or deny use of areas and will be incorporated with other security systems such as controlled access and cameras. Physical barriers should not be evident. Barriers should be aesthetic and blend with the architecture, design and decoration of the community. Physical barriers also pertain to locks. Areas of sensitive information or pilferable materials should be secured by locked doors and cabinets. Locks which come with cabinets may be defeated easily. In high threat areas cabinets should have additional locks added to ruggedize and secure cabinets and possibly doors. Keys should be limited to those individuals who have a need to gain entry and no others. See the policy 10 for Keys for further information.


9.4. Security Level Two

9.4.1. Security Level Two uses elements of Security Level One. Security Level Two could contain elements as follows:

9.4.2. Community employees – Community employees are an integral part of a successful security program. All employees are tasked with ensuring banned individuals do not access the facility, visitors sign the logs, and no visitors are in the building without being escorted by a resident.

9.4.3. Controlled Access – When a controlled access system is in place, residents are able to allow access to visitors. Controlled access should allow access at remote doors only during specified times. This will allow access during periods when the staff is present and residents are active for instance but deny access later in the night when there is no resident activity and fewer employees. Other guidelines for controlled access are:

09/05/2017 36


9.4.3.1. Access to the facility will not be given to resident visitors by employees unless special circumstances occur and authorization has been granted to employees by the manager, RAM and Director. House rules require visitors to be with the residents at all times while on the property. This exists specifically to prevent resident visitors from accessing the building when the resident is not home. Therefore, only the resident may allow access to visitors.

9.4.3.2. Visitors, when access has been granted by the resident, must sign the visitor’s log and proceed directly to the resident’s apartment. They must remain with the resident during their visit to the facility within reason (i.e. if the resident’s visitor is doing laundry for the resident, they may go to and from the laundry room without the resident, etc.) They must also sign the visitor’s log upon leaving the facility.


9.4.5. Closed Circuit Cameras – Closed circuit cameras are used to monitor the actual people who enter or leave the facility. Cameras should be installed so that the faces of persons entering the facility or exiting the facility are plainly recorded. Off hour reviews of camera systems should be accomplished often to monitor what occurs after hours in the facility and if additional security is needed.

9.4.6. Physical Barriers – Physical barriers may be placed on properties to control traffic and deny access. Physical barriers may include fences, driveway gates, pedestrian gates, etc. Use of these systems will be part of an overall security program and designed to limit or deny use of areas and will be incorporated with other security systems such as controlled access and cameras. Physical barriers should not be evident. Barriers should be aesthetic and blend with the architecture, design and decoration of the community. Physical barriers also pertain to locks. Areas of sensitive information or pilferable materials should be secured by locked doors and cabinets. Locks which come with cabinets may be defeated easily. In high threat areas cabinets should have additional locks added to ruggedize and secure cabinets and possibly doors. Keys should be limited to those individuals who have a need to gain entry and no others. See the policy 10 for Keys for further information.

9.4.7. Authorization of Agency – In some communities, police departments allow the registration of banned individuals from a facility. Managers should

09/05/2017 37


notify the police departments upon discovery of any threats. The law will require the notification of the individual (Usually by the police department) before citing or arresting an individual. Any resident who allows a banned individual in their apartment is in violation of their lease. Lists of banned individuals should be posted in a public place where all persons can see. A copy of the list should be placed in the desk top procedures.

9.5. Security Level Three

9.5.1. Security Level Three is the lowest level of security we use in our high and low-rise apartment buildings. It is designed to monitor who comes and goes and give some level of security however restrictions on visitors and residents are low. Elements of Security Level Three are:

9.5.2. Community employees – Community employees are an integral part of a successful security program. All employees are tasked with ensuring banned individuals do not access the facility, visitors sign the logs, and no visitors are in the building without being escorted by a resident.

9.5.3. Visitors must sign the visitor’s log and proceed directly to the resident’s apartment. They must remain with the resident during their visit to the facility within reason (i.e. if the resident’s visitor is doing laundry for the resident, they may go to and from the laundry room without the resident, etc.) They must also sign the visitor’s log upon leaving the facility.


9.5.5. Physical Barriers – Physical barriers may be placed on properties to control traffic and deny access. Physical barriers should not be evident. Barriers should be aesthetic and blend with the architecture, design and decoration of the community. Physical barriers also pertain to locks. Areas of sensitive information or pilferable materials should be secured by locked doors and cabinets. Locks which come with cabinets may be defeated easily. In high threat areas cabinets should have additional locks added to ruggedize and secure cabinets and possibly doors. Keys should be limited to those individuals who have a need to gain entry and no others. See the policy 10 for Keys for further information.

09/05/2017 38


9.6. Security Level Assignments

9.6.1. Security Levels may be changed should situations or activity merit a review by the Director of Housing and/or the Chief Operating Officer. Properties where this policy applies and the levels they are authorized are listed as follows:

Wesley Millington Towers – Level 2Luther Terrace – Level 2Wesley Homes Lake County – Level 2Wesley Homes Dyersburg – Level 3Wesley Stage Park – Level 2Wesley on the Ridge – Level 2Wesley Jackson Highlands – Level 2Wesley at Murray – Level 2Latham Terrace – Level 2Magnolia Terrace – Level 2St Joseph Manor – Level 2St Matthew Manor – Level 2St Matthew Manor West – Level 2Good Samaritan Village – Level 2St Peter Manor – Level 1St Mary Manor – Level 2Union Avenue Baptist Towers – Level 2

10. Key and Lock Security and Accountability

10.1. This policy is designed to work in conjunction with the Security Policy. This policy establishes procedures for the security of keys within each facility. Keys are used to circumvent physical barriers. Physical barriers exist to restrict access to either an area or to equipment. Area security is promulgated in the Security Policy as well as adopted accesses annotated in the Desktop Procedures. Access to controlled areas will be specifically listed and designed for streamlined access during high use periods and limiting access as necessary during other periods. Keys for all locks (cable locks, cabinet locks, desk locks, door locks, deadbolt locks, apartment locks etc.) will be kept in a master key locker. The key locker will be kept in a secure location accessible only to persons authorized to have access. Generally, the master key locker will be kept in the manager’s office or the office where resident files are kept. The manager should be the only employee with keys to access this area. No other employee is authorized to have access unless granted by the manager. Access to the master key locker is also restricted to the manager only. No other employees should have access to the key locker except that corporate personnel will have access through a duplicate set of keys in the corporate office master key locker. Other locations for the key locker must be approved

09/05/2017 39


by the RAM. Other locations will only be acceptable if the access to the area is restricted to the manager only.

10.2. The purpose for this policy is to minimize damages and threats caused by lost keys. Should a master key become lost it may be necessary to rekey an entire property causing increased difficulties for residents who now have to have new keys and an expense the property may not be able to afford. This policy will ensure that keys are safeguarded against such incidents.

10.3. All offices should be set up so that employees may gain access with keys to their work spaces only. Employee’s keys should not allow access to any other areas. Employees should have access to cabinets and desk spaces within their work areas. Keys for secured items such as computers with cable locks should not be accessible to the employee as there is no reason to routinely unlock these areas. Keys for these items should be kept in the key locker only. Duplicate keys should be stored in the master key locker for all cabinets, desks, etc. for which the employee has a key.

10.4. No apartment keys or master keys should ever leave the property. All master keys will be secured in the master key locker or separate key lockers for specific employees when needed. Separate key lockers will be located in a secure area accessible by the employee who requires access. IE, the maintenance person has a need to have a master key for access to apartments during work hours and after hours during emergency calls. Since the maintenance person does not have access to the master key locker after hours, a key locker that the maintenance staff knows the code for or has a duplicate key for can be located in a secure area of the maintenance room. If there is more than one maintenance person then a separate locker for each employee should be installed. The master key will be kept in the locker when the maintenance person is not using them or is off the property. A key log must be kept for each instance the key is removed from the locker indicating the time it was removed and the time it was returned. This should only be used during emergency calls and not for regular work days where the maintenance person can get rings from the manager. Specifically designed rings may be checked out during regular work hours as defined below. Managers should inventory the master key locker as well as the satellite key lockers at least once per month. The inventory will be a sight inventory only. RAMs will spot check and note the sight inventory date and time. The sight inventory should be noted in the key log. It is specifically prohibited to make copies of keys. Only managers will be permitted to authorize copies of keys. Any unauthorized duplication of keys without proper authorization is insubordination and may be punishable by termination.

10.5. The master key locker should contain all keys for cabinets, common area doors, locks and locking devices, apartments, and mailboxes. At least one extra key should remain in the box at all times. Under no circumstances should the last key be removed and used for any purpose other than making another key. The key locker should be set

09/05/2017 40


up so that a sight inventory can be made. Each hook should be labeled and listed on a master key inventory. A sight inventory should be accomplished monthly and annotated in the inventory log. Missing keys should initiate a search and investigation. Missing master keys will be reported to the RAM. Any lock where a key has been lost will be rekeyed or replaced.

10.6. Any resident who installs a security door on their apartment after permission is granted is required to provide 5 copies of the key to the manager. The key shall be stored with the apartment key in the master key locker. A copy will also accompany the key ring for the maintenance person, manager and site assistant. One will also be put in the satellite key locker as required. Residents are not permitted to change the locks on their apartment doors. Any resident who changes the locks should have the locks changed back to our keys and masters at the resident’s expense.

10.7. For high, mid and low rise apartments, a Medico or Knox box should be installed at the front door. The Medico box at a minimum will include the key to the front door (If the master does not open the front door), a master key that fits all locks in the facility, and the elevator key (both the door opening key and the fire reset key). The fire department must send a representative to close and lock the box with the keys inside. As a courtesy, a map of the facility showing apartment numbers may be put in the box as well.

10.8. Key fobs that are turned in by vacating residents should be deactivated and returned to the fob pool. The fobs can be reactivated when a new resident receives the fob. No fobs in the fob pool should be active. They should all be removed from the computer once the resident vacates and reentered when reissued.

10.9. All access control doors should have the fobs for management personnel entered in the system. A current list of corporate fobs and numbers are attachment one of this policy. Guidance from the company installing the controlled access system may be needed in order to program corporate fobs into the system. Additionally, the corporate pin should be included in all controlled access systems. Corporate fobs should allow access into all access controlled areas 24 hours per day, 7 days per week. Additionally, a duplicate copy of all manager’s keys, including office keys, master key locker keys, and front door keys, as well as a copy of all master keys will be maintained in the master key locker at corporate. Managers are specifically responsible for making sure these keys are kept up to date. Any changes of these keys should be changed at corporate as well.

10.10. A master listing of all keys in the master key locker should be kept in the master key locker. All keys should have key tags. Apartment key tags should have the account number on the tag and not the address. This is so that if the key were inadvertently lost and someone found the key they would not know what address the key went to. All

09/05/2017 41


other keys should be labeled as to what the key fits. Keys should be neatly placed in the master locker and all keys should have a single hook. Multiple location keys should not be kept on a single hook other than rings developed for employee use.

10.11. Some employees have a need for multiple keys including apartment access keys for regular duties. Key rings which include resident apartment keys will be stored in the master key locker. These keys will be checked out each day and returned at the end of the day. Key rings should be inventoried at check out and check in. The minimum number of keys to accomplish routine jobs should be included on rings. Keys that are only used on seldom occasion should be kept in the master key locker and checked out when needed. IE the maintenance staff needs to access the fire extinguisher cases once per week. The case keys should be kept in the master key locker and checked out weekly to do the work. Key rings will have an inventory in the master key locker and kept with the master key locker inventory. Rings should have their own hook and should be returned each day.

11. Tenant Administration

11.1. Tenant Files and Compliance –

11.1.1. A file should be started when an application is submitted. The complete application and supporting documents should be stored in this file until the applicant is either rejected or approved. Supporting paperwork is all paperwork required by the tenant selection plan and HUD directives for the HUD properties. Supporting paperwork such as credit checks, landlord checks, etc. may or may not apply to non-subsidized communities. Those communities should proceed in accordance with the standard operating procedures for that property. If an applicant is rejected then the file should be kept for one year and then stored with the dead files for three years before being destroyed. EIV reports should be run in accordance with the current EIV Policy which is Appendix A.

11.1.2. Affordable applicants approved for move-in will have the file organized in accordance with the most current checklist available on the web site. All other sites will have files arranged according to the properties standard operating procedures. All initial paperwork from the move in, to include application, verifications, 50059, etc., will be kept on the left side of the file. Other documents will be kept in accordance with the current check sheet. File may contain the initial move-in 50059 on the left side, and the past and current year only on the right with all other years maintained in a separate file kept behind the working file. This is to alleviate the bulk and size that the working file can attain after several years’ worth of recertifications. A colored sheet of paper should be placed between years.

09/05/2017 42


11.1.3. All files are confidential and must be kept in a locked drawer or cabinet in a locked room.

11.1.4. Current files are kept in apartment number order.

11.1.5. Annual unit inspections will be filed in the tenant file on the right hand side with each recertification year.

11.1.6. When a resident moves out of the community, after the move-out process is complete and documented, move the file to a separate, locked drawer for dead files. Dead files are kept for three years and then destroyed.

11.1.7. All rejected applicants will be stored in the dead file for a minimum of three years as well and filed by date of rejection.

EIV data, stored in the tenant files, whether dead or active may have different destruction dates than the files themselves. See the most current EIV policies Appendix A.

11.1.8. Entry of data into Yardi for move-ins, move-outs and applicants will be in accordance with the most recent available check sheet available on the web site.

11.1.9. Resident Certifications for affordable properties are done in accordance with current HUD regulations. All notices for annual certifications will be generated and dates posted in Yardi in accordance with the monthly check sheet. All notices will be filed in the tenant file with the current certification paperwork. Notices will continue to be generated until the resident signs the 50059. Once the 50059 is signed then Yardi should be annotated with the completion date.

11.2. Apartment Inspections

11.2.1. All apartments will be inspected at move-in, move-out and a minimum of once per year by both the manager and maintenance.

11.2.2. Apartment cleanliness should be maintained in the same condition they were in when rented. Pictures of the unit should be taken and attached to the resident file in Yardi. Additional pictures should be added each year during the annual inspection. Units not kept in a clean condition should be rescheduled for follow up inspections until the unit is satisfactory. Minor lease infraction notices may have to be given in extreme circumstances.

11.2.3. Inspection forms should be kept in the tenant file with the current year paperwork.

09/05/2017 43


11.3. HAP/PRAC/Service Coordinator Vouchers - Processing Payment Vouchers (HUD subsidy and Service Coordinator only)

11.3.1. The processing of monthly activity for rent and HAP payments in Yardi is delineated in the current check sheet. When the voucher is filed for payment, a paper copy of the voucher should be printed immediately after transmission. Vouchers will be filed by month in a locked drawer or cabinet. Upon completion of the monthly check sheet, the original check sheet will be added to the file. If the voucher is transmitted to a contract administrator (CA) then a copy of the confirmation of payment will be filed in the file as well as transmitted to the accounts receivable person in accounting. A copy of this confirmation is necessary in accounting in order to document any changes from Yardi.

11.3.2. All reconciliation changes made by the CA should be analyzed to see if they are legitimate adjustments. Yardi will automatically put correcting entries into the ledgers. If the corrections are not legitimate, then the Manager should notify the RAM or Director of Housing immediately and contact the CA for explanation and correction. Follow the directions of the CA for all corrections.

11.3.3. Managers will log in to the HUD secure server near the end of the month to verify that the payment of subsidy has been received by HUD and there is a scheduled payment pending. If the payment is not pending then the Manager should notify their RAM or Director of Housing immediately.

11.4. Policy for Reasonable Accommodations

11.4.1. Wesley Living is a provider of housing for the elderly. As such, most of our residents and applicants will be disabled as well. Although we create policies and design apartments (i.e., adaptable cabinets, tub cuts, etc.) with the intent that accommodations are already provided in these areas, from time to time individuals will have a need to vary from standard policies or physically modify their apartments so that they may remain independent and have full enjoyment of their facilities. When accommodations are needed, we have processes in place to ensure that we cover all the areas in HUD compliance as well as provide the accommodations if at all possible. Accommodations should not be seen as special treatment for any one resident but should be treated as changes that all our residents may need at one time or another. We serve a fragile population and it is our mission and ministry to provide homes for elderly families that are affordable, safe, decent and sanitary and meet their needs.

11.4.2. Requesting accommodation by a resident does not necessarily mean that the request is specific or in writing. Employees may have a casual conversation with a resident where the resident mentions that they have a

09/05/2017 44


need. This should be treated the same as a request in writing. We may ask that the resident puts the request in writing on our form to ensure we understand the need however it is not necessary that the resident fill out our paperwork in order for it to be an official request for reasonable accommodation. Any request whether in writing or verbal should be acted upon. If a resident elects not to use our form then we should send a letter to the resident, explaining what we understand the request is in detail and instruction on how to verify the disability if necessary.

11.4.3. If the disability is evident then no verification is necessary. An example would be that if the resident is in a wheel chair and requests a ramp for entry into the apartment, the request may be approved without verification. In other instances the disability may not be evident and therefore may need to have verification completed. Such verifications should be completed on our verification requests to ensure that all the required information is obtained which can be found on the Wesley Website or appropriate Smartsheet. Some reasonable accommodations have an impact on the rent that a resident pays and deductions that are allowed by HUD and so thorough verifications are essential to substantiate with HUD that the deductions are legitimate. If there are questions about what the resident needs, then further information can be requested from the verifying official.

11.4.4. Reasonable accommodations do not necessarily have to be exactly what the resident has requested. The objective is to ensure that the resident has the modification needed and that the accommodation is necessary; that there is a nexus or identifiable relationship between the requested accommodation and the individual’s disability. A person with vision problems may not request handicap cabinets with roll under counter tops unless they can demonstrate that there is a relationship between the disability (Vision problems) and that they need a roll under cabinet. If there is no relationship between the disability and the requested accommodation then further dialog must occur to understand why the resident may think they need this accommodation. Should a nexus or identifiable relationship not be recognized then the accommodation may be disapproved. Requests are not automatic, however; we are in a service industry and our goal is to satisfy our customer. It may be as important to our marketing effort to provide an accommodation or service even though it is not required, as it is to provide an accommodation morally or legally because it is needed. We should strive to give the residents what they want unless it is completely unreasonable.

11.4.5. Unreasonable accommodation in this policy would be a modification that the resident wanted, that was expensive, and not needed for the disability. Cost alone should not be a determining factor for unreasonableness. Additionally, structural modifications of a building would also be a reason that an accommodation is unreasonable. Once all requests and verifications have been received the accommodation request should be entered into the Smartsheet for Reasonable Accommodation. All blocks of the Smartsheet

09/05/2017 45


should be completed and all paperwork attached. All requests are approved or denied by the Chief Operating Officer or 504 coordinator.

12. Resident Firearms and Weapons

12.1. Wesley is a provider of housing for the elderly. As such, certain rights are protected by both law and constitution. Residents owning, possessing, transporting or carrying firearms must be in strict compliance with local, state and federal laws as well as within the guidelines of this policy. Managers should ensure wide dissemination of the policy to all who possess firearms. Any resident who is known to possess firearms is required to come to the office and read the current policy. This document sets forth guidelines for residents and staff about the rights of residents regarding firearms. The violation of the policy and the house rules that speak to that policy is a material non-compliance with the lease and managers will give a notice to vacate to the resident. The notice may be a 14-day non-curable notice or in the event the act constituted a dangerous situation for the resident involved or other residents, the notice may be a 3-day notice.

12.2. Persons who are United States Citizens have a constitutional right to own firearms. The use of firearms may be recreational or for personal protection. There are however federal stipulations on gun ownership. These statutory requirements will be vigorously enforced by management. Persons who may not own firearms or possess them at any time are as follows:

12.2.1. Anyone who has been convicted of a felony offense;

12.2.2. Anyone who has been convicted of driving under the influence of an intoxicant two or more times within ten years and one of the convictions is within the last 5 years.

12.2.3. Anyone convicted of a misdemeanor crime of domestic violence;

12.2.4. Anyone convicted of the offense of stalking;

12.2.5. Anyone who is under indictment for a felony offense;

12.2.6. Anyone subject to an order of protection;

12.2.7. Anyone who is a fugitive from justice;

12.2.8. Anyone who is an unlawful user of or addicted to alcohol or any controlled substance and has a court-ordered out-patient program or in a rehabilitation program within the last ten years or has been in a voluntary rehabilitation program within the last three years;

12.2.9. Anyone who has been adjudicated as a mental defective, or has been judicially committed, or has a court-appointed conservator by reason of a mental defect. Known residents with memory or impaired cognitive

09/05/2017 46


functions by the manager may request verification from the resident’s physician of competency to own a firearm;

12.2.10. Anyone who is an alien or is illegally or unlawfully in the United States;

12.2.11. Anyone who has been discharged from the Armed Forces of the United States Military under dishonorable conditions;

12.2.12. Anyone who has renounced his or her citizenship of the United States:

12.2.13. Anyone receiving social security disability benefits by reason of alcohol dependence, drug dependence or mental disability.

12.3. Any resident found in possession of a firearm, loaded or unloaded, who meets any of the above listed conditions will be given a notice to vacate without cure.

12.4. Other residents who own or possess firearms may maintain the firearms in their apartments. Managers should consider anyone keeping a firearm for the purposes of self-defense and maintains the firearm loaded and committing any of the following as a material noncompliance with a 3 day notice and notifying authorities:

12.4.1. Making known that they have or maintain a firearm. This is considered a threat;

12.4.2. Threatening any person with the use of the firearm whether armed at the time or unarmed;

12.4.3. Brandishing any firearm whether loaded or unloaded (brandishing is the act of showing a firearm holstered or upholstered for the purpose of intimidation);

12.4.4. Discharging the firearm inside the apartment for any reason other than bonafide self-defense and even then, the resident is responsible for damage, injury or death from the discharged round. Any discharged round within the community that damages, injures or kills another person, other than a perpetrator against that resident, will receive a 3 day notice to vacate;

12.5. Storage of large quantities of ammunition is prohibited. No more than one box of ammunition for any single caliber weapon may be stored in the unit and it must be in the original box. No more than three different caliber rounds may be stored. If rounds are stored in the weapon then the rounds within the weapon count toward the total allowed. Rounds in a weapon may be in a magazine (if it is a semi-automatic weapon), chamber or revolver. Storage of large quantities of ammunition constitutes a fire danger.

09/05/2017 47


12.6. Fully automatic weapons are not allowed regardless of whether the resident has proper licensing or not.

12.7. The resident is liable for damages, injury and death caused by the discharge of any firearm. If a firearm is discharged, the resident may be open to monetary claims from injured parties including management. Managers should strongly encourage owners of firearms purchase an umbrella insurance policy to shield them from damage claims by other residents and management.

12.8. Possession of loaded firearms by persons (residents or visitors) without a Handgun or Concealed Carry Permit outside of the resident’s apartment will be grounds for a three day notice to vacate and notification to law enforcement.

12.9. Persons with a Handgun, Weapons or Concealed Carry Permit from a different state are not valid within communities even if there is a reciprocity agreement between states. Residents with permits issued outside the state are subject to the same rules as residents without permits until they are permitted in the state of residency.

12.10. Residents without a valid Handgun, Weapons or Concealed Carry Permit must transport firearms cased and unloaded in any common space within the community. Transporting firearms may only occur between the resident’s apartment unit and the resident’s vehicle. Residents without a valid permit may not transport a loaded weapon of any kind to another resident’s unit, a community or activity room, or any library or community use room. The only areas where unloaded and cased firearms may be transported is hallways and elevators in the direct path between the resident’s vehicle and the resident’s unit.

12.11. The House Rules mentions that firearm possession must meet the requirements under the current policy. Any resident who does not comply with that policy is in material violation of their lease and may receive a 3-day notice to vacate. Additionally, any resident not in compliance with the policy may also be in violation of state or federal law. These instances should be reported to law enforcement officials.

13. Inclement Weather Policy13.1. The Employee Handbook addresses inclement weather in the Attendance

and Punctuality section. However, as our facilities are spread over a large geographic area, and we experience the change of weather over that area, many of the decisions for attending work are left to the managers. It isn’t possible to gauge how severe the weather is in Jonesboro for instance from Memphis or Adamsville as the weather tends to transition so rapidly in this area. Therefore, it is imperative for the managers to be in touch with the staff to ensure we don’t try to travel into work when we shouldn’t. If you feel that the roads are unsafe to travel in the morning when it is time for you to come to work then you have the authority to change the start of operation for your facility a maximum of two hours. That means that if you have regular work hours that start at 8:00 then you

09/05/2017 48


may delay your staff until 10:00. However, you must communicate the change to both your staff and your supervisors (RAM, Director or Chief Operating Officer in the Directors absence). Some staff may still have the ability to come to work, despite the weather (they may live close to the facility and be able to walk or have four wheel drive vehicles) and want to come to work. That will be a manager’s decision during the two hour delay. Further modifications of office hours and staff attendance will be made in conference with the RAMs and Director or Chief Operating Officer.

13.2. Weather conditions also change rapidly on these days so if your modified hours need to be changed again communicate those changes to your staff and supervisors. Staff should remain on call all day in case conditions improve and roads are cleared. These are not meritorious days off. Your residents still need you on the properties so should road conditions improve staff is expected to be at work. The decision should be based on safety. As soon as roads are passable, all employees should report to work.

13.3. The Director monitors inclement weather during work days. If the manager feels that the roads or weather conditions are getting hazardous and you and your staff will need to leave early then contact your supervisor. In their absence contact your RAM, Director, or Chief Operating Officer to determine the best approach.

13.4. All Wesley Living managed buses and vans will be parked on days of inclement weather. Operation of these vehicles is not authorized when conditions are hazardous. Clearance to operate should be obtained from the RAMs.

13.5. Preparations should be made for emergency action in accordance with your Emergency Response Manual. This includes ice melt for sidewalks, plastic to cover broken windows, etc.

14. Vehicle Operation and Maintenance

14.1. Introduction

14.1.1. This policy replaces any previous versions and amplifies the Wesley Living Employee Handbook. The operation and safety of vehicles transporting residents and employees is paramount to the mission and ministry of our properties. Operation of vehicles is not simply jumping behind the driver's seat of a vehicle, starting it up and driving. This policy will set forth the requirements for driving and maintaining vehicles owned by Wesley Living as well as those vehicles owned by managed entities.

09/05/2017 49


14.2. Qualification

14.2.1. Candidates to operate vehicles must be employees of Wesley Living Non-employees may not operate any vehicle within the Wesley Living managed Fleet for any reason or for any purpose. This includes starting or unlocking vehicles. Keys for vehicles should not be in the possession of non-employees at any time for any reason.

14.2.2. Candidates must submit all the information required by Human Resources so that proper vetting can be accomplished and the employee can be added to the appropriate automobile insurance. This includes taking the safety test and submitting the completion certificate upon passing the course. The course is currently provided as a computer based, self-paced course. No employee is authorized to operate the vehicle until cleared by Human Resources.

14.2.3. Employees whose primary job is to drive the vehicles will have the appropriate license. For those operating vehicles of 15 passengers or less, employees will have the "F" endorsement on their license. For those operating vehicles which can accommodate more than 15 passengers, employees will be required to have a Commercial Driver's License.

14.2.4. Any employee who has a State Driver's License may operate vehicles of 15 or less passengers once they have completed the above requirements regardless of their primary job. Employees whose primary position is other than driver of the vehicle do not have to have the "F" endorsement on their license to occasionally operate the vehicle.

14.3. Operating the Vehicle

14.3.1. The operation of the vehicle in public areas serves to provide transportation of residents to areas of necessity and activity or transportation of supplies or personnel for maintenance or support functions. These programs are essential to the Ministry of Wesley Living and its managed entities. While operating vehicles, drivers must realize that they are not only transporting residents or employees, but they are also representatives of the company and the properties in very public areas. As such, all drivers should conduct themselves in a professional manner at all times. Drivers should dress appropriately and in accordance with Wesley Living's guidance for dress by professionals who are in contact with residents and the public. Operators of vehicles designed and in the act of moving residents must be particularly conscious of appearance and dress in appropriate clothing. For vans and busses this includes the following:

14.3.2. Clothing should be clean and free of stains, dirt, rips, and tears. Clothing should be completely serviceable without defect.

09/05/2017 50


14.3.3. Clothing should be professional and conservative. No blue jeans, T shirts, shorts, sleeveless shirts, low neck lines, short dresses, or excessive colors. Managers, RAMs and corporate executives have the sole decision about appropriate dress. Appropriate would be regular business casual.

14.3.4. Properties are authorized to provide coveralls for use during driver maintenance checks. Use coveralls to keep grease and dirt from contaminating clothing.

14.3.5. Dress should be appropriate to conduct the business of transportation. This means that some lifting and movement is necessary in support of the residents. Flat leather or plastic soled shoes are appropriate. Athletic shoes may be worn. Heels and platforms are not appropriate.

14.3.6. Employees operating support or maintenance vehicles should present a clean, neat and appropriate appearance. This includes clean clothing, no T shirts or sleeveless shirts, and no torn or unserviceable clothing.

14.3.7. There is no smoking allowed in any Wesley Living managed Vehicle at any time. This is regardless of whether residents are present or not. Smoking is not permitted in the vehicles. Violations of this policy will be dealt with in accordance with the Employee Handbook. Violations of this section are considered insubordination and will result in disciplinary action which could include termination.

14.3.8. There is no cell phone or portable electronic device use allowed during the operation of Wesley Living managed Vehicles. This includes hands free operation, voice operation, texting, or any use of cell phones or mobile devices. The only exception to this section is that before movement of the vehicle, GPS Navigation may be programmed and the navigation may continue during vehicle operation. Any changes to the navigation program however, must be accomplished after the vehicle has been stopped and the transmission put in park. Changes to the programming of GPS Navigation devices is not approved while the vehicle is in motion, in traffic, or on any street, or drive where vehicles are normally in motion. Violations of this policy will be dealt with in accordance with the Employee Handbook. Violations of this section are considered insubordination and will result in disciplinary action which could include termination.

14.4. Maintenance and Preventative Maintenance

14.4.1. Regular inspections of the vehicle are imperative to the long life of any vehicle. Preventative maintenance is accomplished through check sheets. Cleanliness serves to preserve the interior of the vehicle and present a professional look inside and out. No vehicle should be operated unless the

09/05/2017 51


preoperational checklist has been accomplished. Tools (such as tire gauges, etc.) should be equipped in every vehicle to ensure preoperational checks can be accomplished or remote checks can be completed.

14.4.2. Regular oil changes and mechanic checks should be performed in accordance with the Manufacturer's Owner's Manual. The only change is that oil changes will be accomplished every 5,000 miles or 4 months, whichever comes first. All oil changes will include a synthetic blend oil in the viscosity recommended by the mechanic for the time of year. A synthetic blend oil is usually one part synthetic oil to four parts regular oil. This allows the protection of synthetic oils without the cost of full synthetic use.

14.4.3. No vehicle should be operated if it is deemed unsafe.

14.4.4. The interior of the vehicle should be clean and free of unsecured objects. Storage of tools, parts, clothing, etc. is not authorized. These objects can get lodged under gas and brake pedals presenting a danger to the operation of the vehicle. Vehicles should be cleaned internally after operation each day. This includes removing refuse left behind, sweeping, vacuuming, etc. to maintain a good appearance in the vehicle. Additionally, cleaning solutions such as glass cleaner should be used regularly to ensure cleanliness of the interior of the vehicle. With the increase of bed bugs in resident units, all vehicles should be inspected for bed bugs after each use.

14.4.5. Beds of trucks should be cleaned out at the end of each operational day.

14.4.6. Exteriors of vehicles should be washed regularly to give a good presentation. This is a rolling bill board for our company and should look good at all times.

14.4.7. Be careful when using high pressure washers on the vehicles. This can remove the shrink wrap on the bus. Do not spray high pressure against these decals. Especially on the windows. Do not use automated car washes with either high pressure sprayers or brushes as this may remove the decals. Vehicles should be washed under low pressure where decals are present.

14.5. Accidents14.5.1. If an accident occurs, notify the authorities immediately and get medical

attention if necessary. Ensure the vehicle is in a place where it will not be hit again and ensure all passengers remain in the vehicle until authorities arrive.

14.5.2. Make no statements to anyone. The police will do an investigation into the accident using the available information at the scene of the accident. If there are any extenuating facts that the police need to know that aren't evident when they arrive then those facts may be supplied to the police. Otherwise they should do their investigation and drivers should say nothing. Drivers should make no statements of responsibility or blame.

09/05/2017 52


14.5.3. Once injured passengers are taken care of and authorities have been notified and it is safe to do so all drivers should notify the manager responsible for the vehicle. If the manager is not available then the chain of command should be followed until someone in management has been notified. Drivers should have assessed the accident and be ready to give basic information when they notify management. Basic information would include:

14.5.3.1. Injuries - How many and to what extent are there injuries? 14.5.3.2. Will anyone be transported to a hospital? 14.5.3.3. Should a person be transported to a hospital that is refusing? 14.5.3.4. Is the vehicle still operable? 14.5.3.5. Can the vehicle make it back to the property or a property nearby? 14.5.3.6. Can it still carry passengers safely? 14.5.3.7. Are any fluids leaking from the vehicle? 14.5.3.8. Are all the seats still secure? 14.5.3.9. Can all windows and doors be closed? 14.5.3.10. Do you need towing?

14.5.4. Once the manager has been notified, they should ensure corporate is notified of the entire situation and any support that is needed.

14.5.5. Operators should get the name, contact information, insurance company, insurance agent, and policy number from all persons with a vehicle involved in the accident. If a person refuses to give that information then the operator should request that information from the police officer conducting the investigation.

14.5.6. Vehicle operators should complete a full written description of what happened as soon as returning to a property. The description should include all details of what occurred. This should include diagrams of vehicle paths of travel, approaches, and impacts. It should also include injuries to both passengers of the Wesley Living operated vehicle as well as injuries of other vehicles involved and estimates of damage to all property both vehicles and/or other property (fences, poles, lights, mail boxes, etc.)

14.6. Safety14.6.1. All vehicles should be operated in a cautious manner. No aggressive

driving and maintaining proper vehicle intervals and speed. Respect all driving laws. Stop for all stop signs and do not cross intersections on the yellow lights. We are not in a hurry. Please exercise caution during vehicle operation.

14.6.2. Drivers and all passengers should wear their seatbelt at all times when the vehicle is in operation. No exceptions. Drivers of vans transporting passengers are responsible to ensure they have buckled up.

09/05/2017 53


14.6.3. Van and bus drivers should walk to the back of the bus at the end of operations for the day. This is to ensure that no passenger is still on the bus and no items are left behind.

14.6.4. Passengers are not allowed to stand on buses and vans. All passengers must be seated.

14.6.5. Ensure tie downs for wheel chairs are in place and properly applied and adjusted.

15. Maintenance

15.1. General - The maintenance of the property protects our investment asset but more importantly provides the resident with a safe, decent and sanitary place to live. Above all this is the mission of Wesley Living. Maintenance staff comes in contact with residents more than any other employee. For this reason, maintenance staff should be well trained in apartment repair, well equipped with necessary tools, well dressed with clean clothing free from holes, tears, and stains. Staff should be well groomed with head and or facial hair neatly trimmed or worn. Staff should not exude any offensive odor. Maintenance staff should conduct themselves with the utmost professionalism while dealing with residents. Friendly and concerned maintenance staff will take care of residents within the mission of Wesley Living. These relationships should not become overly friendly or confrontational. Disagreements with residents about service should always be directed to the Community Manager.

15.2. Work Orders Paper - Maintenance is driven by the work that must be accomplished in order to make repairs to assets. The driving force for the maintenance program is therefore work orders. Work orders will be completed by Managers by initiating them in Yardi in accordance with current procedures.

15.2.1. All residents should call requests for maintenance in to the office. Managers should initiate all these types of requests. Managers will enter them in Yardi and print two copies of the work order. Both copies will be given to the maintenance staff. Maintenance staff should be given the latitude to prioritize work orders in accordance with published policies or the property’s desk top procedures. This gives the maintenance staff the opportunity to work efficiently, independently and generate a real feeling of ownership. Micromanagement of the maintenance system is discouraged unless the skill of the maintenance staff does not allow this type of independence. In this case the maintenance staff should receive intense training from the Manager in order to achieve this level of independence. This should be a common topic between Managers and RAMs during RAM visits.

15.2.2. Maintenance should accomplish the work on the work order and make all annotations required including start time, finish time, parts used, and a narrative on what they did to fix the problem. Maintenance staff will leave a

09/05/2017 54


completed copy of the work order in the resident’s apartment and return the other completed copy of the work order to the Manager. The Manager will complete the work order in Yardi in accordance with the most current procedures.

15.2.3. Work orders will be filed in a maintenance file established for each unit in the apartment complex. Work orders will be maintained in this file for the life of the building. Under no circumstances will work orders be removed or destroyed.

15.2.4. Work orders should be created for all maintenance. This includes work completed by contractors, vendors or outside labor.

15.2.5. Maintenance staff should be encouraged to detect maintenance that needs to be accomplished but does not yet have a work order. Maintenance staff may add this work to an existing work order if it is detected while completing a work order or may be submitted to the Manager for a work order to be created. If using electronic systems, the maintenance staff may create their own work order. Residents should still call the office for maintenance they discover.

15.2.6. If the maintenance is urgent or emergency in nature then it may be completed without a work order but a work order must be created and documented as soon as the urgent matter has been mitigated. If using electronic systems, the work order should be created immediately. No maintenance will be completed without a work order.

15.3. Work Orders Electronic – Management software has features where work orders may be entered and edited electronically with no paper. When a community uses this type of system, maintenance should be given cards that may be left in the resident’s apartment after completion. Follow all procedures established through the software and print a copy of the completed work order for the records. Priority and completion of work orders remains the same as above.

09/05/2017 55


15.4. Unit Make Ready

15.4.1. Make ready work orders should be completed in accordance with current Yardi procedures.

15.4.2. Make ready work orders should take no longer than five work days.

15.5. Emergencies - Emergency after hours’ maintenance should be approved by the Manager or other staff if the Manager has delegated that authority. The authority for other staff to call maintenance after hours should be documented in the property’s desk top procedures.

15.5.1. All emergency maintenance should be verified on site and in person by either the Site Assistant or Manager. Basic low level maintenance, such as plunging commodes, resetting breakers, turning off water, etc. should be accomplished by either the Site Assistant or Manager. Maintenance should not be called in on these types of events and should be handled on site. Maintenance should be called in when the extent of repairs, damages and clean up require higher skilled maintenance staff.

15.5.2. Maintenance staff will be paid salary for emergencies in accordance with the current Employee Handbook published by HR.

15.5.3. Emergency maintenance that qualifies maintenance staff to be called in are situations where there is fire or flood that the Site Assistant cannot control, AC when the outside temperature is above 75 degrees and no temporary AC is available, heat is out, backed up commode when an apartment only has one commode, all sinks are backed up, etc. Standards outside of these published standards may be approved by a Manager and RAM and published in the property desk top procedures.

15.5.4. All facilities should maintain portable air-conditioners/heaters. Use of window air-conditioners is not allowed on any property unless approved by the Director of Housing. Portable air-conditioning units allow air-conditioning with only vents extending out the windows. Other forms of AC are not to be used unless approved by the Director of Housing.

09/05/2017 56


15.6. Contractors and Vendors - Contractor and Vendor maintenance is performed when the work required exceeds the maintenance staff abilities. Contractor and vendor maintenance is approved by the RAM and Director of Housing. Extended contracts for major repairs or ongoing services are approved by the RAM, Director of Housing and the Chief Operating Officer. In all cases the Manager will sign the contracts only after confirmation by the approving authority. Contractor and vendor maintenance should always have a work order and if the work pertains to a unit then a copy of the scope of work or work agreement should be filed in the unit maintenance file.

15.6.1. Contractor and vendor maintenance that exceeds the maintenance staff ability but has an approved schedule (i.e. carpet) may be approved by the RAM.

15.6.2. Contractor and vendor maintenance may be performed on tasks that are within the maintenance staff’s abilities only when the work load exceeds the maintenance staff’s ability to deliver the work in a needed time frame. This must be approved by the RAM when an agreed schedule of work exists (i.e. painting an apartment) but all other agreements must be signed off by the RAM and Director of Housing.

15.6.3. A complete scope of work should be developed to present to contractors for bids. The scope may be developed by the Manager and maintenance staff and may include the Skilled Technician, RAM, Director, and COO. The same scope of work including materials used should be given to all the contractors bidding on the job. Changes in scope should be provided to all contractors and rebid. In the end of the process, all contractors should have bid on the same work using the same materials. No proposals should be sent to the RAM until this standard has been met. It is preferable to have at least three bids for any job but any job above $10,000 must have three bids. Approval of bids will be made considering the vendor’s ability to do the work, vendor’s ability to deliver quality work, vendor’s ability to deliver the work on time and the cost of the bid.

15.6.4. All contractors must have insurance including liability and worker’s compensation in the amount most currently published by Wesley Living. Contractors whose employees consist solely of owners or executives may register with the state to waive worker’s compensation requirements. This paperwork may take the place of the worker’s compensation requirement.

15.6.5. New contractors must have a new vendor form from the Wesley Living Web Site including a W-9 (and Certificate of Insurance listing the property as the certificate holder if they are not a supplier only) completed before work is accomplished and submitted to RAM.

09/05/2017 57


15.7. Vendors Hired by Residents – Residents may from time to time employ vendors for hire for services in their homes. Residents are encouraged to get services from vendors in order to maintain independence. Vendors within the homes of residents must be approved by management. Approved vendors must certify that any staff that comes on to the property has had a background check and that the company has liability insurance and a dishonesty bond. Certifications of resident vendor forms may be found on the Wesley Living Web Site.

15.7.1. Vendors must provide an insurance certificate showing the insurance agent, limits of liability insurance, and that a dishonesty bond covers all their employees. They must also prove appropriate licensing for services rendered.

15.7.2. Vendors failing to provide such information will be banned from the premises.

15.7.3. Sole proprietors may have background checks done through the office and by HR at the vendor’s expense. Sole proprietors must still meet the insurance requirements.

15.8. Preventive Maintenance - Preventive and scheduled maintenance should be accomplished at predetermined intervals for all mechanical equipment and building systems. Schedules should be entered into Yardi in accordance with the current preventive maintenance policy and your property’s desk top procedures.

15.8.1. All preventive maintenance requires work orders. Work orders may be assigned to a common space or building but must be filed that way as well.

15.8.2. Each property is unique to the preventive maintenance program needed to fulfill the requirements under the intent of the definition listed at 2.28. All properties should develop check sheets for each type of equipment. Check sheets should be filed by the maintenance technician by apartment and by date.

15.8.3. Required preventive maintenance should be scheduled at a minimum for the following equipment:

15.8.3.1. Clean split system Air-conditioners in the fall after the end of the A/C season.

15.8.3.2. Clean PTACS in between seasons when weather allows.15.8.3.3. Clean split system furnaces in the spring after the heat season has

passed.15.8.3.4. Clean PTACs for a second time in between seasons when weather

allows.

09/05/2017 58


15.8.3.5. Water source heat pumps should have maintenance scheduled for the tower per manufacturer requirements.

15.8.3.6. Refrigerators should be serviced annually.15.8.3.7. Boilers should be serviced at least semi-annually and in

accordance with manufacturer’s requirements. For buildings with condensing boilers, all preventive maintenance should be per manufacturer’s requirements.

15.8.3.8. Unit water heaters should be inspected annually. This may be documented on the Manager’s annual inspection if completed during that inspection.

15.8.3.9. Rain gutters should be cleaned and inspected after all leaves have fallen from the trees but before March 15.

15.8.3.10. Roofs should be checked annually. Leaks in roofs should be detected during the annual inspection in the individual units. Flat roofs should be visually inspected annually.

15.8.3.11. Windows should be checked for tightness of seal and operation at least annually. This may be documented on the Manager’s annual inspection if completed during that inspection.

15.8.3.12. Stoves should be checked for cleanliness and operation at least annually. This may be documented on the Manager’s annual inspection if completed during that inspection.

15.8.3.13. Refrigerator coils and gaskets should be checked and cleaned annually. This may be documented on the Manager’s annual inspection if completed during that inspection.

15.8.3.14. Electric panels, breaker boxes, fuse panels and GFI outlets and breakers should be checked annually. This may be documented on the Manager’s annual inspection if completed during that inspection.

15.8.3.15. Smoke detectors should be checked each time a maintenance action occurs in an apartment and annually. This may be documented on the work order during maintenance or on the Manager’s annual inspection if completed during that inspection.

15.8.3.16. The call for aid should be tested annually.15.8.3.17. Fire systems for low, mid and high rise apartments should be

completed in accordance with the local fire code. Generally this inspection is done by a certified fire systems vendor.

15.8.3.18. Elevators will be completed in accordance with local code and manufacturers’ recommendations. This maintenance will be conducted by a certified elevator maintenance vendor.

15.8.3.19. Sewer systems for garden style apartments will be hydro-cleaned at least every two years. This will be done by a plumber with the necessary equipment.

15.8.3.20. Emergency lighting.15.8.3.21. Fire equipment.

09/05/2017 59


15.9. Energy Conservation

15.9.1. Communities belong to the Better Building Challenge. As such we have committed to HUD and the Department of Energy that we will reduce energy consumption 20% from our 2015 levels. In order to do that we must use both conservation as well as technologic efficiencies.

15.9.2. All communities have a Green Operation and Management plan. These plans will be followed.

15.9.3. Thermostats for common spaces and offices will not be set higher than 70 degrees in the winter nor 76 degrees in the summer. Corridors and hallways will not be set higher than 68 degrees in the winter nor 78 degrees in the summer. Stairwells isolated by a door will not be set higher than 65 degrees in the winter nor 80 degrees in the summer.

15.9.4. Resident units should be set no higher than 76 degrees in the summer nor 72 degrees in the winter unless adjusted through a reasonable accommodation.

15.9.5. All common space thermostats will be installed so that residents and unauthorized people cannot access the controls to reset them. All HVAC devices will be thermostat controlled.

15.9.6. Resident education on green technology and energy conservation will be conducted regularly (a minimum of semiannually).

15.9.7. Residents will not operate HVAC systems in their units with the windows open.

15.9.8. Lighting should be converted to automatic controls in rooms only occupied occasionally such as common rest rooms.

Curb Appeal/Marketing/Outreach

15.10. Visually Appealing Property

15.10.1. Know your competition!! Think about how your property appears. First impressions are the most lasting ones. Are the sidewalks and parking lots swept and clean? Grass mowed? Parking lots surfaced and clearly striped? No obvious physical problems showing in/on buildings? Are the signs bright and clean, and meeting HUD and FH/EO standards? Is additional signage needed? Is there seasonal color? These items must be worked on all the time – and constantly in your thoughts!! If you cannot get the people through the front entrance/door, you cannot lease an apartment. Competition in our industry is growing and will become much stiffer in the near future.

09/05/2017 60


15.11. Advertising and Outreach

15.11.1. The main focus of advertising is outreach to the local community per your AFHMP and extra effort as appropriate. Put out flyers in grocery stores, drug stores, restaurants, health care facilities, senior centers and anywhere else that seniors tend to congregate. Document when advertising material is distributed so that you can show compliance with the AFHMP during MORs.

15.11.2. Meet with all the local ministers and their men’s/women’s groups and “sell” your property; go to the senior center and give talks/slide shows. Consider local radio and TV station(s) as appropriate. Also, the Wesley Living Administrative Corporate Office will design flyers, brochures and advertisements for the local paper(s), as appropriate. Also visit the local disabled persons’ advocate organizations and let them know that you have accessible apartments with a disability preference.

15.11.3. Market your services. Service coordinator programs, transportation and especially activities are essential in differentiating you from your competition.

15.12. Word of Mouth and Incentives.

15.12.1. Happy residents and families are your best Public Relations. Those communities with a waiting list MUST offer them to near-by Wesley Living managed communities with vacancies. If people accept such vacancies, the gaining community should share the information with the original community so its list can be updated.

15.12.2. Word of mouth by residents and their families is usually the most effective advertising tool. However, incentives for residents in communities with a history of vacancy problems may also be considered in discussion with your supervisor. Some examples are: small cash awards for residents who refer someone who moves in, small physical awards (e.g., toasters, flowers) etc.

15.12.3. In some cases paying residents to find other residents may be effective. Tenant finder fees must be approved by the RAM.

15.13. Marketing Package:

09/05/2017 61


15.13.1.Each community must have a marketing package for prospective applicants. This package should be placed in suitable locations in the community where seniors may congregate (e.g., the senior center, grocery store, pharmacies, churches, restaurants, health facilities). It must contain at least:

15.13.2. A form letter welcoming prospective tenants to the property.

15.13.3. A brochure describing the community and giving apartment lay-out.

15.13.4. The HUD form describing the eligibility and rent calculation process for that type property.

15.13.5. You must market every person who walks through the door regardless of the size of the waiting list. Many waiting lists are: ”only” 1/3 “real,” at best….

15.14. Application Package:

15.14.1. The application package must be given to anyone who so requests. Add the marketing package, if you are meeting the person for the first time and an application is requested. The application package consists of the application, the supplement to the application, notice to applicant, and homeless notification to applicant.

15.14.2. All applications that are complete will be date and time stamped, initialed, entered into Yardi and the applicant will be sent a wait list letter which is on the Wesley Web Site. Rejected applicants will receive the rejection letter from Yardi (not the one in the Yardi Screening).

15.14.3. Applicants are processed in accordance with the Tenant Selection Plan.

15.15. Tenant Selection Plans (TSPs)

15.15.1. HUD requires detailed TSPs. Nonsubsidized communities have simplified TSPs, primarily to ensure non-discrimination practices are followed.

15.15.2.The TSP describes the admission process (acceptance or rejection of an applicant), consistent with appropriate Federal regulations. The TSP normally covers:

09/05/2017 62


15.15.2.1. Procedures for giving out applications, and explaining requirements to applicants/family members (e.g., citizenship, income, social security number, etc).

15.15.2.2. Procedures for screening and accepting applications, including income targeting.

15.15.2.3. Nondiscrimination and equal opportunity requirements

15.15.2.4. Circumstances for rejecting applicants and how to process.

15.15.2.5. Keeping and using the waiting list,

15.15.2.6. Occupancy requirements

15.15.2.7. Basic Fair Housing rules.

15.15.2.8. Handling of refusals to take an offered apartment,

15.15.2.9. Unit transfer policies for in-place residents versus accepted applicant.

15.15.3.The TSP is not approved by HUD, but will be reviewed by either HUD or the CA. The TSP must be consistent with the program type involved and HUD rules (Handbook 4350.3, see chapters 2, 3, 4, 6 and 7 and HBK 4350.1, chapter 9). The TSP is subject to review and modification by Corporate at irregular intervals. HUD must pre-approve any preferences not listed in the 4350.3.

15.15.4.When the TSP is substantively changed, it must be posted for 30 days so residents may review and comment, and also sent to the organizations listed in the AFHMP.

15.15.5.Wesley Living has three types of HUD TSPs.

15.15.5.1. Straight Section 8: All have conventional (non-insured by HUD) loans. All are “elderly only” and limited to families in which the head of household is 62 or older (disability may be an admissions criterion for some properties). That means the family may include an adult child who is disabled or minor children for which there is a documented history of being cared for. In Section 8, a minor or adult child can move in after the resident and go on the lease. At various times, these senior properties may have had or may request an age exception, e.g., to 55. Such exceptions must be approved by HUD.

09/05/2017 63


15.15.5.2. Minor or adult children may NOT move into these projects except at initial occupancy where there is a documentable history of the person(s) living with the resident. At various times, these senior properties may have had or may request an age exception, e.g., to 50-55. This must be approved by HUD.

15.15.5.3. Section 202/8: These limit admissions to individuals or families in which the head of household is 62 or older. The family, at move-in, may include an adult child who is disabled and has a history of living in that household, or may have minor children.

09/05/2017 64


15.16. Required Postings:

15.16.1.New rent proposals must be posted for 30 days (except for 202/8’s.) The residents must be given an opportunity to comment on the proposed rent increase before it is sent to HUD/THDA and 30 days’ notice of the new rent levels. The notices will normally be provided by Corporate.

15.16.2.The following is a list of postings, which must be up at all times by the Office to be read by staff, residents or visitors. Separate bulletin boards should be maintained for employees. Employee bulletin boards must be posted in a place where employees will see it such as in a break room, or at a time clock. The other bulletin board must be place in plain sight for anyone who enters the property. The boards must contain the following:

15.16.2.1. Rent Schedule. It states the currently approved rent levels for the community. Whenever a rent increase is granted by HUD/CA, a new Rent Schedule is issued. (Resident)

15.16.2.2. EEOC Fair Housing Picture “We do business in accordance with Federal Fair Housing Laws” (Resident)

15.16.2.3. State Insurance Rules for Employees (Can be posted in a section for employees only.) (Employee)

15.16.2.4. Workers’ Compensation Instructions (Employee)

15.16.2.5. Tenant Selection Plan (TSP) (Resident)

15.16.2.6. AFHMP (Resident)

15.16.2.7. CA and HUD Complaint policy (as appropriate)/Grievance Procedure for Residents (Resident)

15.16.2.8. Resident Rights and Responsibilities (Resident)

15.16.2.9. DOL rules (Employee)

15.16.2.10. Occupancy Certificate must be available in office.

15.16.2.11. Office Hours – posted where they can be seen even if office is closed. (Resident)

15.16.2.12. Service Coordinator Hours (also at his/her Office) – posted where they can be seen when office is closed. (Resident)

09/05/2017 65


15.16.2.13. EEO – Job Safety and Health Protection, personnel information. (Employee)

15.16.2.14. Resident Council By-Laws (if applicable). (Resident)

15.16.2.15. “Things you should know,” (Resident)

15.16.2.16. Grievance Procedures (Resident)

15.16.2.17. Lease, House Rules, Pet Rules (Resident)

15.16.2.18. Collection Policy (Resident)

15.17. Parking

15.17.1. People with Disabilities: All communities must have designated parking for people with license plates or hang tags evidencing a disability on their mirror. These parking spots must conform to 504 standards (clear lines, wider parking slots and blue/white disability signs painted on ground in each slot and a vertical sign in the front of the parking place). Questions should be directed to the Director of Housing or the Luther Terrace Skilled Technician.

15.17.2. All parking areas for people with disabilities should be as close as possible to the main (or side) doors of a property. Side doors are appropriate if that door is closer to resident “x’s” apartment. If requests for parking from people with disabilities are received, they must be in writing; preferably use the reasonable accommodation request posted on the web site. The verification of disability form must be sent to a third party provider.

15.17.3.All Others: All communities normally have first-come first-served parking, including the areas as designated parking for the disabled. Assigned parking is strongly discouraged unless there is a specific reason related to reasonable accommodation. Discuss such situation with your supervisor.

16. Desk Top Procedures

16.1. General - Invariably there will be standard procedures that do not cover different locations. With variations in buildings, personnel, etc. there may be procedures that do not work or with modifications would work better. Therefore, Desk Top Procedures will be developed for each property by each Manager so that variations from each property will be identifiable in the event someone must take control of the property if a manager becomes unavailable (On vacation,

09/05/2017 66


becoming ill, etc.). Desk Top Procedures will also include things that are particular or peculiar about that specific property.

16.2. Desk Top Procedures will be kept in a one inch three ring binder and kept in a conspicuous place so it is easily found in the Manager’s absence. It will be arranged in sections. The sections will be divided as follows:

16.2.1. Variations from Written Policy – This section will include any operational variations from the Policies and Procedures Manual or any other written policies (EIV, Security, Etc.) These variations must be signed off by both the RAM and Director of Housing.

16.2.2.Additions to Written Policy – This section will contain further refinements of the Policies and Procedures Manual, or other published policies.

16.2.3.Schedule of Files

16.2.3.1. The first part of this section will list the vendor files (Both invoices and contracts) and their locations.

16.2.3.2. The second part of this section will list the locations of all current tenant files, EIV files, and voucher files.

16.2.3.3. The third part of this section will list the locations of the maintenance files.

16.2.3.4. The fourth part of this section will list the locations of all Service Coordinator voucher files.

16.2.3.5. The fifth part of this section will list the location of the dead files including move-outs and rejections.

16.2.3.6. The sixth section will be for any other files that the Manager thinks may be of value to anyone taking the property in the event of absence.

16.2.3.6.1. Telephone numbers - of local contacts (i.e., Chamber of Commerce, local politicians, local TV, etc.) that you have a relationship with that may assist someone running the property in your absence. If this list is kept in your computer, then you may print out a list from the computer quarterly and place the listing here.

16.2.3.6.2. Shift Schedule/Employee Schedule - If you have a shift schedule then the shift schedule should be kept here. It should be changed whenever an employee changes. This should be approved by the RAM.

09/05/2017 67


16.2.3.6.3. Preventive Maintenance Schedule – This will include vendors’ schedules (Elevator, pest control, etc.)

16.2.3.6.4. Utility Cut off Map – Map of the facility illustrating water cut offs, electric boxes, etc., which would be necessary in case of an emergency.

16.2.3.6.5. Unit Inspection Schedule – The anticipated schedule of when each unit will have its unit inspection completed.

16.2.3.6.6. Reference Section – Discretion of the Manager. May contain lists of forms on the web site, locations of manuals, other locations, etc.

09/05/2017 68


Appendix A

Enterprise Income Verification Policy

Enterprise Income Verification is an electronic verification of resident income that is provided by the U. S. Department of Housing and Urban Development. This policy is promulgated in response to the need for security of use of the site and reports generated by the site. All Wesley Living managed entities should be familiar with this policy and strict adherence is required. Violations of this policy could result in personnel disciplinary action as well as legal action taken by HUD or other interested parties. For the protection of the resident’s privacy, the following policies are established:

All computers will be password protected and security will be adhered to in accordance with Wesley Living Employee Handbook, section 516. Any computer security issues should be addressed to the Wesley Living IT Department. Any investigations into security breaches or unauthorized access of a Wesley Living computer will be conducted by the IT department. EIV security breaches or unauthorized use or suspected unauthorized use will be reported to the EIV Coordinator who is the Director of Housing and Home Services. All incidents should be reported immediately via email and or phone and followed up in writing on an incident report.

All EIV users will be approved by the EIV Coordinator. Access will be granted to properties where the employee has an assignment and a need for this information. All employees requesting access are required to complete the Security Awareness training as prescribed in the EIV user manual, section 4.1.3. Upon completion of the training; the employee will request access and the coordinator will grant access. Access must be requested and re-approved each six months. Employees will be notified when an access request is needed. Refresher training will be conducted at quarterly manager meetings.

Upon application by any person for residency at a community, an existing tenant search will be conducted. If the applicant is a current resident of a subsidized unit then other applicants who are not in subsidized units will have priority in accordance with the tenant selection plan for that community. Results of the existing tenant search will be attached to the application. When the resident becomes eligible for tenancy, coordinate the move-in with the existing facility so that no overlap of subsidy can occur. If the tenant is not admitted, then retain the report with the application file for three years after removing from the waiting list. The file must then be destroyed.

An income report will be conducted 90-days after move in to verify the information that was given during move-in was correct. Additionally, the income report will be run at each recertification. These reports will be retained with supporting documentation and applicable 50059 for tenancy plus three years. The report and file must be destroyed at that time.

09/05/2017 69


The new hire report will be run on all residents monthly. This will allow managers to double check information and allow tenants rents to be corrected before any debt becomes unmanageable. This report will be kept in the monthly master file with the voucher and other designated reports. These reports will be destroyed after three years.The income discrepancy report will be run monthly and at tenant recertification. Any resident who has an EIV detected discrepancy for under or over reported income will be contacted. If the resident agrees with the EIV report for under reporting then a corrected 50059 or interim 50059 will be created back to the date of the event and the resident will be responsible for repayment in accordance with the Wesley Living Payment and Repayment Policy. If the income was over reported then the Interim Recertification will be dated for the first of the following month. This file will be kept in the tenant file along with the repayment agreement or resolution. It will be destroyed with the entire file three years after tenancy ends.

The failed EIV pre-screening report and the Failed Verification Report will be run each month. All failed pre-screening reports and Failed Verification Reports will be investigated and corrected. All corrections will be through TRACS. This report will be kept in the monthly master file with the voucher and other designated reports and will be destroyed after three (3) years.

The multiple subsidy report will be run monthly with all reported multiple subsidies investigated and corrected. This report will be filed with the monthly master file with the voucher and other designated reports. It will be destroyed after three (3) years.

The deceased tenant report will also be run monthly with all deceased residents on the list being investigated and corrected. All corrections will be through TRACS. Copies of each of these reports will be filed with the monthly master file with the voucher and other designated reports and will be destroyed after three (3) years.

The summary report will be used at recertification to validate a tenant’s certification and to review and resolve discrepant or invalid personal identifiers of tenant’s with a status of failed or deceased. The summary report and supporting documentation must be retained in the tenant’s file for three (3) years after tenancy ends and then must be destroyed.

EIV Income reports will also be conducted at annual re-certifications and when a resident reports a change in income or family composition. Be aware that if the tenant is being paid under the table or the employer does not report the income then it may not be in EIV; therefore third party verification and review of documents is permitted in accordance with HUD regulation. The income discrepancy report is printed at the same time the Income Report is printed. Ensure follow-up of reported income discrepancies.

The No Income Report will be run quarterly on all residents reporting zero income. The resident will also be interviewed quarterly to ensure that there is no undisclosed income.

09/05/2017 70


The monthly master file must be kept in the same locked cabinets with other EIV documentation. Each month the file that is three years old should be removed and all EIV reports should be destroyed. A note should be placed in the file after destruction indicating the reports that were destroyed, method of destruction, date of destruction and the person destroying the documents.

As an up to date form HUD-9887 and HUD-9887A is required for EIV reporting; it is imperative that a new HUD-9887 and HUD-9887A be completed at each and every annual recertification signed by all members of the family who are 18 years of age or older. Verification of a current HUD 9887 and HUD-9887A will be verified before access to EIV. Families will be screened during annual recertification for members of families who will become 18 years old after the current recertification and before the next annual recertification. When this situation occurs, the manager will make a memo in Yardi under the tenant screen and ensure that the memo shows on the desktop calendar that the member must come in after his/her birthday to sign the paperwork. This way all aging up family members can be monitored. When the HUD-9887 and HUD-9887A has been signed by the family member the memo will be updated in Yardi and removed from the calendar. Whenever a family is moving from a market tenant to an assisted tenant through an initial certification, then a new HUD-9887 and HUD-9887A should be completed.

EIV documents are not authorized for LIHTC purposes nor may EIV documents be viewed by unauthorized personnel, which include Service Coordinators. Only authorized persons will be allowed to review the documents. Service Coordinators and individuals assisting the resident during their recertification are authorized to view documents if the resident signs a release. EIV documents will be placed in an envelope inside the tenant file with the recertification that it supports. The envelope will clearly identify the documents as EIV and the date of the reports will be annotated on the envelope along with the destruction date.

Master file reports must be destroyed after three years. All EIV reports filed in tenant files must be destroyed three years after move out.

As additional safeguards for EIV information, a list of all persons with access to the office where information is stored should be kept in the key cabinet. Keys for access to locked file cabinets containing EIV records will be kept in a separate key locker with access by the manager, RAM, Director of Housing or Wesley Living officer only. The key for access will be kept on the manager’s person and a copy of the key to this locker will be kept at the corporate office locked in the key locker at that location. A key log will be kept to track anyone accessing the key and information at both sites.

Any and all security breaches will be reported to the EIV coordinator immediately in accordance with these instructions. Any conflict between this policy and HUD directive is superseded by HUD directive for affected portions and becomes null and void however unaffected portions of the policy stay in force.

09/05/2017 71


Appendix B Payment and Repayment Policy

Introduction:

The purpose of this plan is to provide guidance for the payment or repayment of expenses acquired by residents during tenancy. Wesley Living, the communities managed, its subsidiaries, contractual organizations and its assigns do not discriminate based on race, color, religion, sex, handicap, familial status or national origin. This facility complies with all federal, state and local Fair Housing and Civil Rights laws. “We are pledged to the letter and the spirit of U.S. Department of Housing and Urban Development policy for the achievement of equal housing opportunity throughout the nation.” This plan should be followed when residents have accrued expenses equal to or exceeding the amount of money they pay in rent for one month. Any expenses less than the amount equal to one month’s payment for rent (Resident’s Share) does not qualify under this plan and must be paid within 30 days of notice.

This document may be available in another form as a reasonable accommodation.

Charges that Do/Do Not Qualify for This Plan:

Although late fees are less than rent, a written agreement for two or more late fees is permissible. Late fees must be paid within 45 days of the agreement.

For Memphis Housing Authority properties, where the security deposit is not paid during initial occupancy, the resident must enter the plan for the security deposit balance before taking possession of the apartment in order to qualify for move in. The agreement will be completed and placed in the file with the move-in paperwork.

Delinquent rent is expressly omitted from this policy unless the delinquent rent is originated by a report generated by EIV and corrected certifications. Current rent not generated by EIV compliance is due and payable on the 5th of the month. A reminder is sent to the resident on the 6th of the month and a 30-day notice is given on the 10th of the month. No exceptions to this rule except reasonable accommodations.

Any current charges that do not equal or exceed the higher of one month’s rent (resident’s share), or $100 are not eligible for this payment plan. These charges must be paid within 30-days of the date the resident is notified. If not paid in 30 days, a 30-day notice to vacate will be issued to the resident. Rent generated by compliance with EIV is exempt from this paragraph.

Multiple charges (except delinquent rent) that are less than the limits above may be grouped together to exceed the limits above and qualify for the repayment plan.

09/05/2017 72


All charges not collected within the 30-day limit delineated in the lease (except delinquent rent) must be placed under this repayment plan or a 30-day notice to vacate must be issued. That is to say that any resident who will not agree to enter the repayment plan and has not paid legitimate charges within the 30 days after notification will be evicted.

Residents who disagree with the charges have the right to have them reviewed by the manager’s supervisor. Please submit a written letter addressed to:

Management Supervisor (Your Property Name)1615 Appling RoadMemphis, TN 38016

All written correspondence must be submitted and post marked within 30 days of the notice of charges. Any charges older than 30 days are not eligible for review and the resident must either pay the charges or enter this plan or they must vacate the apartment.

Any charges older than 30 days, which do not have a payment plan agreement, will be entered on the resident’s credit report through Transunion reporting. Charges satisfactorily paid after entry on the credit report will be reported immediately.

Plan Instructions:

The resident must be notified in writing of all charges and provided a statement of account from the management software. Additionally, the resident must be given a copy of the enclosure entitled “Resident Repayment Plan Agreement”.

If the tenant wants to enter the plan they should fill out the enclosure “Resident Repayment Plan Agreement” and a copy of the signed document should be filed in the tenant file and the tenant provided with a copy. Additionally, a memo should be placed in Yardi to the facts of the repayment. A lease charge for the amount of the agreement and duration should be made in Yardi so that the charge will post with the monthly posting action. If payments will exceed the date of the next recertification then the lease charges should only run to the recertification date and new lease charges entered after recertification.

Tenants should elect the conditions of repayment when the initial form is completed. The resident may select either the 10% option for rent generated by EIV compliance, 20% minimum for other current charges or the up to 90-day option. The resident should check the box and initial after the line that they select.

Tenants should understand that a breach of this agreement results in withdrawal from the plan will constitute a lease violation, which will result in a 30-day notice to vacate being

09/05/2017 73


issued. Re-entering the program will only be considered under highly extraordinary circumstances and management reserves the right to make that determination based on the facts. Re-entry requests should be addressed in writing to the manager and must arrive prior to the 5th of the month the payment will be missed.

Payments/repayments for current charges must exceed 20% of the tenant’s adjusted income as computed on the most current 50059 and 10% maximum of the tenant’s adjusted income for EIV compliance. Payment minimum for current charges will be $50 regardless of the adjusted income on the 50059. Payment amounts will be recalculated at re-certification if the resident’s income changes. This recalculation will continue to exceed 20% of the resident’s adjusted income at re-certification for current charges and 10% maximum for EIV generated certification driven charges. The exception to the 20% standard will be that if the payment can be made within 90 days then the payment may be split into either two or three equal payments or rent derived from EIV compliance. The tenant may elect to pay half one month and half the next or three payments of 33% of the bill in three months. This election is made by the resident during the agreement to repay.

A memo entry must be made in Yardi pertaining to the details of the agreement in accordance with current Wesley Living policy.

All repayment plans will be immediately terminated and a 30-day notice for termination issued when a resident under the plan leaves employment without good reason. It will be the resident’s burden to prove that the loss of employment is good reason such as medical problems, employer’s abuse, family need, etc. It is recommended that voluntary separation from employment be discussed and good reason be agreed to before termination of employment. The determination of whether employment termination is good reason or not lies solely with management. This is clause covers both voluntary and involuntary separation from employment. Leaving employment without good cause will be construed as an attempt to circumvent the legitimate repayment of confirmed charges. In the event that a resident is withdrawn from the repayment plan they will immediately and voluntarily surrender the possession of the apartment to management.

09/05/2017 74


Resident Payment/Repayment Plan Agreement

This plan is initiated by both the resident, and in agreement with management, in order to repay a debt legally incurred by the resident, resident’s family member or on behalf of a legal visitor of the resident during residency in an effort to allow occupancy to continue. Failure to agree to the terms of this policy and execution of this agreement will result in the immediate issuance of a 30-day notice to vacate for material violations of the lease. By signing this agreement, you are consenting that the charges are legitimate, and that you agree to the terms of the contract contained herein. You further agree that any breach of this agreement will constitute a violation on your part and you agree to vacate the apartment immediately after management has issued the demand for possession due to delinquency. By signing you understand that there are no grace periods assigned to this agreement. All payments will be made prior to the 5th of the month at the location where rent is paid.

Head of Household Name:__________________________ Apartment #:_______

Total of charges: $_________________

Current adjusted income (From most recent 50059): $____________________

50059 date: ________________ Next 50059 recertification date: ______________

Minimum payment amount (20% of Current adjusted income above): $____________

Even payments of $_____________ for ___________ months (Not to exceed 3)

Payment of 10% for unreported income derived from an EIV report.

Agreed upon payment amount: $_________________ ___________ __________Resident’s Initials Manager’s Initials

List of charges entered into plan:

_________________________________ $______________Description of Charge Amount of Charge



_________________________________ $______________

09/05/2017 75


Description of Charge Amount of Charge



I have reviewed the charges for this plan. I agree that I am responsible for the payment of these charges. I have received, read and understand the publication of the Wesley Living Policy “Collection, Repayment or Payment Plan for Wesley Housing Properties.” I agree that I will make payment on these charges in accordance with the payment schedule above, and that if there are any defaults by me in these payments that I will promptly and voluntarily vacate the unit. I understand that this agreement will be recalculated upon a re-certification or change in my income (Increase of decrease) of $200 per month or more. The amount paid now or after any recalculation will not be lower than 20% of my adjusted income (10% for repayment of incorrect income reporting) for current charges from the new re-certification. I understand that the amount paid may increase if my adjusted income increases and conversely it may decrease if my adjusted income decreases. Voluntary separation from employment to avoid repayment as described in the policy publication will be terms for breach of this contract. Additionally, I understand that regardless of the adjusted income from the 50059, no agreement will be entered with payments less than $50 for current charges. My signature below reflects the agreement between management and me, and is acceptable to both.

___________________________________________ ____________Signature of Resident Date

___________________________________________ ____________Signature of Manager or Owner’s Agent Date

09/05/2017 76

Housing Policies and Proce… · Web vie

Documents

Transcript of Housing Policies and Proce… · Web vie