ComplianceClose-up

Service Coordinators and EIV

Should Service Coordinators have access to EIV information contained in a tenant's file?  If they do, should they sign a "Rules of Behavior" form?

I take a very strict position on this question, based on the broader issue of whether a Service Coordinator should have access to a tenant's file as a matter of course.

My answer to the broader question is: A Service Coordinator should have no access to a tenant's file without a signed (and dated) authorization from the tenant, which the tenant has the right to rescind at any time.

Consequently, a tenant can authorize a Service Coordinator to have access to their file, and to specify which items in the file they wish to be made available as part of that authorization, including EIV.  A Service Coordinator should not have the carte blanche to review EIV records, which a Rules of Behavior might confer, in the absence of tenant authorization.

Keep in mind that if the Service Coordinator is assisting Mr. John Doe, and Mr. Doe gives authorization to disclose information about him that is in his tenant file, the Service Coordinator should not be given any information (including, but not limited to, EIV) about Mrs. Doe or other members of the Doe household. 

Just when I thought I had heard it all....

.....along comes something that genuinely surprises me.

Now, I know this is not all that uncommon.  But after 36 years in or around the business, and in my 21st year at NCHM, I've seen and heard a lot.  Some good, some bad, and some that seems to come from the former-planet-now-dwarf-Pluto.

Such was the case with the first eHotline message I got this morning.  A property manager informed me that he had been instructed that if a resident had not had a checking account for six months, he was to use the six month balance on the checking account that had been closed.

It is with all the humility and dignity I can muster that I respectfully share my response:

"WHAT????!!!!"

As far as I know, HUD hasn't issued any guidance to this effect, and I checked this morning.  Further, where in Title 24 of the Code of Federal Regulations (24 CFR) does it state that we use for calculations purposes assets that no longer exist? (the exception being disposed assets, of course).

The point of this post is not to point the fickle finger of blame.  It is, however, to state that it is this kind of thing to causes chaos, frustration, and in every other way can serve as an obstacle to running a housing assistance program in a sound manner that is in compliance with existing rules.

And it is to repeat my appeal to HUD: HUD Handbook 4350.3, Rev. 1 is in need of a change/update.  HUD's "Frequently Asked Questions," one of the most helpful things the Department created, is in need of review, revision and updating. 

I don't want to see a repeat of what happened to Public Housing.  The old HUD Handbook 7465.1 Rev. 2 was not updated for years; instead, a number of PIH notices were issued. In my opinion, this had some role -- whether it is was a significant factor can be argued -- in the problems that beset public housing. Handbooks are the lifeblood of compliance management, for good or ill, and to not update them regularly is to court disaster, in my opinion.

Another source of potential disaster is to make up rules that aren't there.  And if the rule is there, make sure it is widely disseminated.  Stealth is a good name for a military aircraft, but it is not the way to ensure compliance with HUD guidelines.