COMPLIANCE NEVER SLEEPS

Last evening, I got a telephone call from a colleague and friend of many years standing. The conversation included some discussion of compliance, including one point that was so interesting I had to share it here.

During an audit, it was discovered that the property was using a now outdated HUD Form 9887 and 9887A. The current version of the form is readily available via HUDCLIPS.

When given the current version of the form, the response of staff at the property was, "We only use forms sent to us by our corporate office."

There's absolutely nothing wrong with centralizing compliance functions at a high level within a property management firm or PHA. And centralization is certainly the way to go for owner/agent created forms, in my opinion.

But when it comes to HUD forms, compliance never sleeps. Someone at the corporate level responsible for compliance has to ensure that the site staff is getting these forms quickly, along with any appropriate instructions for their their use. The availability of these forms on HUDCLIPS, often announced by RHIIP emails, means corporate is deprived of any "wiggle room" on these points. This leads to negative findings on an MOR.

Is there any finding more miserable on an MOR than the one that says you are not using the current version of a HUD form?

Of course, as I have said ad nauseum, if HUD would only put all this "new stuff" (some of which is no longer that new) in a HUD Handbook change, our industry would be much better off. I am still waiting for Change 4, and if I had held my breath I would have been declared brain dead and removed from life support more than two years ago.