SEMAP: Standing Up to an...

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SEMAP: Standing Up to an Audit

Teri Robertson

Learning Outcomes

Understand how to conduct required reviews leaving a

defensible audit trail

Purpose of SEMAP

Section Eight Management Assessment Program (SEMAP) was created to: Objectively measure key areas

Identify management capabilities/deficiencies

Improve HUD risk assessment for each problem identification

Provide self-assessment tool for PHAs

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Measuring PHA Performance Under SEMAP

PHA performance under SEMAP must be assessed annually

PHAs with less than 250 assisted units assessed and scored every other PHA fiscal year Unless PHA:

Elects to be assessed annually; or

Is designated as troubled

Percentage Score

Total points earned

Divide by total points that apply to your PHA

High performer 90%+

Standard performer 61-89%

Troubled performer 60% or less

Your goal

Ratings Based on CertificationRating for indicators 1-7 will initially be based

directly on what the PHA reports on its SEMAP certification

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Rating Profile

Waiting list 15Reasonable Rent 20Adjusted Income 20UA Schedule 5HQS QC 5HQS Enforcement 10Expanding Housing 5

Subject tomodification, based on audit

Comes from PHA certification

Rating Profile

Payment Standards 5 FOAnnual Rexaminations 10 PICCorrect Tenant Rent 5 PICPrecontract HQS 5 PICAnnual HQS 10 PIC Lease up 20 VMS FSS 10 FO/PIC

Prepare,Prepare,Prepare

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Audit Files

Make up 15 (plus bonus if applicable) “file folders” 1 general file folder

Random methodology

1 file folder for each indicator

Remember, you want PROOF

Internal Audit Files

Description of indicator and performance standard

Place data from audit for each indicator reviewed

Any other “proof” of certification score

Use auditor minimum file sample and increase sample if needed


Use a uniform data systemCaptures dataCalculates the score Leaves an audit trail Displays the data reviewedShows results

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Contact me via email, and I will send you NMA’s SEMAP toolJust tell me what your FYE is (4

versions)[email protected]

PHA Supervisory

Audits

Supervisory QC Reviews

Annual samples of files Drawn in unbiased manner (leave clear audit trail)

Supervisor or other qualified person other than the one who did the work

Objective is to determine compliance with indicator

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1st 7 SEMAP Indicators

Selection from Waiting List* 15

Reasonable Rent* 20

Determination of Adjusted Income* 20

Utility Allowance Schedule 5

HQS Quality Control Inspections* 5

HQS Enforcement* 10

Expanding Housing Opportunities 5

*indicates PHA audit needed

Size of Universe

Size of UniverseSelection from the Waiting List

Where the universe is: The number of admissions in the last year for each of

the two quality control samples under the SEMAP indicator at 985.3(a) Selection from the Waiting List;

Data source: software report showing new admissions

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Size of UniverseRent Reasonable and Adjusted Income

Where the universe is: The number of families assisted for the

SEMAP indicators at 985.3(b) Reasonable Rent, and 985.3(c) Determination of Adjusted Income; Number of families assisted as of FYE, plus

number of families that EOP’d during the year, plus number of families that ported out and were absorbed during FY

Size of UniverseHQS Quality Control

Where the universe is: The number of units under HAP contract during the

last completed PHA fiscal year for the SEMAP indicator at 985.3(e) HQS Quality Control Inspections;

Number of families assisted as of FYE plus number of families that EOP’d during FY, plus number of families that ported out and were absorbed, plus moves

Size of UniverseHQS Enforcement

Where the universe is: And the number of failed HQS inspections in the last

year for the SEMAP indicator at 985.3(f) HQS Enforcement

Documentation showing number of failed HQS during FY for units under contract

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Audit Sample Selection

50 or less

51-600

601-2000

Over 2000

55 + 1 for each 50 (or part of 50) over 50

16 + 1 for each 100 (or part)over 600

30 + 1 for each 200 (or part)over 2000

Random File Selection

File Sampling

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File Sampling

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Print before you click ‘Get Sets’ to retain for

your audit trail

File Sampling

Print before you click ‘Get Sets’ to retain for

your audit trail

Random Sampling Audit Trail

State in your overview folder: PHA uses Random.org to randomly select records for

review

Retain a copy of the Random.org request and the Random.org results

Print your record list, number each record

Circle each record selected by Random.org

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Random Sampling Audit Trail

In the folder dedicated to the indicator under review, retain: Two Random.org printouts

Printed list with selected families notated

Random Sampling Example

If you must select a replacement family: Notate next to the selected record why Randomly select replacement from random.org,

printing the random.org pages File

Notate replacement family name next to original family Notate original family name next to replacement

family

Random Sampling ExampleHQS Abatement 1. Tom Smith2. George Watson3. Mary Long No qualifying event

during FY; Alexis Trevor selected to replace

4. Melissa Roberts5. Keira Ashley6. Ali Quinn7. Alexis Trevor replacement for Mary

Long8. Amy Cameron9. Sam Daniels10. Joe Michaels

Record 3 was originally selected for review No qualifying

event

Record 7 was selected as the replacement

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Conducting Reviews Conducting

Reviews

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Random Sampling Example NMA tool calculates ytd score as data is entered

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Random Sampling Example 6/30 FYE PHA

Each month, enter in

reporting rates from IMS/PIC SEMAP module

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Random Sampling Example For indicators scored by IMS/PIC, PHA enters

that data on indicator page

Tool calculates score, moves to Summary page


Sheets for: Annual reexams Correct Tenant Rent PreContract HQS Continuing HQS FSS

Lease-up data is entered by PHA on its indicator page, based on VMS entries


PHA then conducts reviews for required indicators

Using spreadsheets ensures complete records are kept

Retains the data on a network drive Maintain the source documents in a book, or scan into

system

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NMA tools were developed to ensure consistency in approach, as well as to provide a solid audit trail

We are using our sheets as examples on how to create defensible records You may create your own or use ours

Not our intent to cover each indicator in depth Feel free to approach me after session

1. Selection from theWaiting List

PHAs must have written selection policies in administrative plan

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

1. Selection from Waiting List Selection

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1. Selection from Waiting List Admissions

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1. Selection from Waiting List Combined

1. Selection from Waiting ListMust score 98% in each of the two

samplings

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1. Selection from the Waiting List

Records in book Copy of selection policies from admin plan

If policy changed during FY, retain all Be sure eff dates of changes are clear

Copy of report showing all admissions Random.org selection record

Records from each WL selection Application/updates for each file reviewed

2. Reasonable Rent

PHA must follow its written method

Document determination that the rent to owner is reasonable at required times Initial leasing of a unit Any increase in rent to owner 10% decrease in the FMR in effect 60 days before

HAPC anniversary date

Points

20 points

15 points

0 points

Documentation for 98% of files selected

Documentation for 80-97% of files

Neither statement is true

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2. Reasonable Rent

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2. Reasonable RentRecords in book Copy of rent reasonableness policies from Admin Plan

If policy changed during FY, retain all Be sure eff dates of changes are clear

Copy of report showing all assisted families Random.org selection record

Records from each RR determination

3. Determination of Adjusted Income

At admission and reexamination, the PHA must properly: Obtain third party verification of income or

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

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Points

20 points

15 points

0 points

Documentation for 90% of files selected

Documentation for 80-89% of files

Neither statement is true


NMA uses a different spreadsheet to conduct reviews

Results are captured on SEMAP sheet PHA conducted 25 reviews; 1 file failed


Records in book Copy of calculation/verification policies Copy of report showing all assisted families

Random.org selection record

50058s, family declaration, verifications Utility allowance schedules

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4. Utility Allowance Schedule PHA has reviewed utility rate data within prior 12

months

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

Points

5 points Yes

0 points No

4. Utility Allowance Schedule Each time UA is updated, complete the SEMAP

sheet for that indicator

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4. Utility Allowance ScheduleRecords in book Copy of utility allowance schedule

This year Last year

Proof of required study

5. HQS Quality Control Inspections

PHA performs QC inspection of units under contract (according to HUD audit guide)

Sampling drawn from: Recently completed inspections Cross section of neighborhoods Work of cross section of inspectors

Points

5 points Yes, to both statements

0 points No

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5. HQS QC Inspections

5. HQS QC InspectionsRecords in book Signed HQS QC inspection form Documentation showing discrepancies were

discussed Can just notate QC inspection form

6. HQS Enforcement

Universe Number of HQS fails in previous PHA FY

Sample drawn from Units under contract that fail HQS

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6. HQS Enforcement

PHA must ensure that when a unit fails an HQS inspection : Any life-threatening deficiencies are corrected

within 24 hours, and All other HQS deficiencies are corrected within no

more than 30 calendar days

Or PHA-approved time extension

6. HQS Enforcement

If HQS deficiencies are not corrected within the required time frame, PHA must: Owner responsibility

Stop (abate) housing assistance payments no later than the first of the month following the specified correction period, or terminates the HAP contract

Family responsibility Take prompt and vigorous action to enforce family

obligations

HQS Enforcement Supervisory Audit

All life threatening fails corrected within 24 hrs, and

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

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HQS EnforcementScoring

1. Determine universe

2. Run/obtain report of all HQS fails

3. Capture whether 24 hour or non-24 hour One HQS failure can have both

4. Capture whether owner-caused or family-caused One HQS failure can be both


5. For each HQS unit audited, determine: Corrected as of reinspection? Y/N Verified corrected prior to effective date of

negative action? Y/N* Abated/enforced family obligations timely? Y/N If Yes to one of the above, passes indicator


Verified corrected prior to effective date of negative action? Y/N* BUT you did mail out intent to terminate/abated You have actually rescinded the action because the

unit passed before effective date of negative action

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Points

10 points Yes, met criteria

0 points No, didn’t meet criteria

6. HQS Enforcement

6. HQS EnforcementRecords in book Copy of policies from admin plan Copy of report showing failed inspections

Random.org selection record

Document showing Unit passed reinspection Abatement/family obligations enforced

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7. Expanding Housing Opportunities (MSAs only)

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

Documentation shows PHA followed policy

Expanding Housing Opportunities

PHA has created a briefing packet (e.g. maps, job opportunities, schools and other services in the areas) to encourage voucher holders to seek these opportunities


Information packet has: List of owners willing to lease Other organizations (housing counseling, advocacy

groups, service providers) which assist families in finding units

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Information packet explains portability and provides list of contacts at neighboring PHAs Name Address Phone


PHA has analyzed: Difficulties of voucher holders finding units in these

areas If so, has analyzed

Whether to seek approval of exception payment standards Sought approval for exception payment standards if

needed

Points

5 points Yes to all statements

0 points Audit report does not support statements

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Complete a checklist; retain source docs in book

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8. Payment Standards

The PHA must adopt payment standards By unit size For each FMR/SAFMR area in the PHA jurisdiction Between 90-110% of the HUD-published

FMR/SAFMR If applicable, for each PHA-designated part of an

FMR area

Points

5 points

0 points

98% of newly leased units are within the basic range

Statement is not true

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8. Payment Standards Update the spreadsheet each time PS is

changedCalculates the percentage of FMRRetain hard copy schedules and a print of

FMR webpage in book

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Closing

PHAs should ensure their SEMAP documentation “tells the story”

Any auditor should be able to review records and understand how score was calculated without having to ask questions

Closing

Be sure your records will withstand an audit Clear Complete Comprehensive

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Questions?

Thank you!

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SEMAP: Standing Up to an...

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