There’s No Room for Complacency in Compliance

As a career HUD consultant, one of the most common questions I get asked is, “How do you remember all this stuff?” The answer? We live, eat, and breathe it – all day, every day.

My mantra has always been, “It is so much harder to regain compliance than it is to maintain compliance.”  This means there is no room for complacency in compliance.  Taking shortcuts and eliminating critical checks and balances can be huge gambles in the world of HUD regulatory compliance and staff oversight. Oftentimes, these efforts to save time and money ironically backfire in a big way – costing the owner more resources to fix the problem resulting from that decision.

The climate in the affordable housing industry is fragile right now; rules, priorities and staff are constantly changing. On any given day, housing professionals are tasked with staying abreast of multiple developments regarding regulatory changes, HUD announcements, and of course compliance deadlines for a variety of contractual obligations. It is a full-time job for compliance departments to ensure policies are updated, procedures are compliant, software is functioning correctly, staff are trained, and the correct paperwork is being used to document completed tasks. This becomes an even harder task when a property has multiple funding layers and conflicting program guidance.

Do you ever ask yourself, “What don’t I know?”  or “What am I missing?”

With all these variables in the mix, how do owners avoid becoming complacent? Here is what some of our high-performing, superstar clients have said contributed to their success:

  • Be intentional. Set aside time on your calendar to look at the forest rather than jumping from tree to tree. What are your organization’s strengths and weaknesses?  If you completed an MOR or Compliance Review on your own property, what would you find, and how would you propose fixing the root cause of the problem? Do you know your average make ready period? When was the last time you evaluated how audit friendly your waiting list is? How much are you carrying in subsidy arrears because of TRACS errors not yet resolved? Do you take the time to prioritize self-assessments of your operation?
  • Plan out a year. Do you create a “Year at a Glance Schedule” that spreads out agency-wide tasks throughout the year, or do you unrealistically squeeze a year’s worth of QC tasks into two weeks because you get notification of a scheduled MOR? Do you strategically schedule group Security Awareness Training or monitor the unique schedule for 50+ staff unnecessarily? What months have the most Annual Recertifications due? Knowing when you and your staff will be busiest also tells you when you should have the bandwidth to tackle special quality control projects.
  • Aim high. No one has ever lucked out with a “Superior” MOR rating. They earned it every day of the year, throughout the year, completing tasks that may not be required, but they know, set them apart in a favorable way. Adopt policies that clearly outline responsibilities of staff and residents and then hold everyone accountable.

Some properties are in a position to successfully incorporate these initiatives internally.  Others may need some outsourced help. That’s where DeSilva Housing Group comes in.

When weighing the costs to outsource tasks, we encourage you to do the math. Compare the fixed cost of services offered by DeSilva Housing Group with the hourly rate internal team members will cost the property to complete these same tasks. For example, you could spend $400 for a robust preventative maintenance plan that can be used portfolio wide, or utilize countless hours of staff time coordinating between site staff, maintenance staff and company leadership to draft a plan from scratch. These cost comparisons consistently illustrate that outsourcing can be a cost-effective route to a reliable and immediately accessible solution all the while freeing up your staff’s time to complete daily tasks. We offer high yield and quick turnaround times.

  • Need help writing policies? We’re here to provide you customized versions that fit your needs –  whether that is for one property or fifty properties.
  • Want an outside entity to review your processes with the goal of saving time and money? We’re here for you.  Outside eyes and perspectives often identify what internal eyes have become desensitized to.
  • Want a file review assessment to identify patterns of non-compliance before an MOR, or does an MOR-prompted 100% file audit sound like more fun?
  • Need help navigating the setup of your TRACS compliance software for a new acquisition?

Whether you lack industry knowledge or resources or are just spread thin and need a few things off your plate, we can help. Let us manage EIV compliance, voucher submissions, preparation of AFHMPs, preparation of subsidy repayment agreements, submission of Special Claims, staff training, and HUD Secure System access for staff. We bring decades of experience in HUD and tax credit compliance. We are here, every day, to help you work smarter, not harder.

Jack Nicklaus said, “Complacency is a continuous struggle we all have to fight.” We’re here to help you elevate and excel!