How to Prepare for a Management and Occupancy Review Inspection
If you receive any type of government funding, at some point your property may be subject to a Management and Occupancy Review (MOR) conducted by the US Department of Housing and Urban Development (HUD). This is the agency tasked with regulatory oversite of government-subsidized and affordable housing. The goal of MORs is to maintain adequate housing for vulnerable populations, to protect FHS insurance funds, to provide proper management and compliance with HUD standards, and to ensure the physical and financial wellbeing of properties.
When getting ready for a MOR, it’s most important to be well-organized and prepared. HUD reviewers will ask for a slew of documents which may require you to dig deep into your files. The more organized you are, the better prepared you will be to meet their demands and produce the required documentation.
Christian Church Home (CCH) has a full-time Compliance Department which works closely with its property managers to ensure we are doing the right thing and to minimize and correct any possible deficiencies in advance of a MOR.
The MOR process involves three steps:
- The Desk Review – completed by the owner in advance of an on-line inspection to pull relevant project information and prepare the HUD reviewer for the on-site inspection.
- The On-site Review – conducted by HUD to examine property-relevant materials such as maintenance-related documentation, REAC or physical property inspections, recent audits, preventative maintenance plans, capital improvement plans, the resident application and other resident-related documentation and occupancy materials.
- The Close-out / Summary Report – provided by the HUD reviewer which rates each of seven categories as either A (acceptable) or C (corrective action required). The reviewer will describe any conditions that require corrective action and provide a timeline for when corrections must be met to ensure errors or omissions do not reoccur.
Preparing for MORs can take a great deal of time and energy, but can be readily accomplished with some forethought and commitment. Deliverables don’t have to be overwhelming. Commit to prioritizing deliverables and setting deadlines to stay on track, even in the midst of a busy, everyday workload. Set aside time on a daily basis to pull together materials and keep a check list of what needs to be done and your progress. Take items in doable, small-size bites to get the task done. If you get off track, don’t panic–regroup, re-prioritize and carry forward.
Other suggested tips to prepare for a MOR include:
- Know what to expect by reviewing your processes and procedures
- Note any corrections and follow-up to ensure deficiencies are corrected
- Upon learning of the MOR appointment date, start collecting documents a little at a time and place items in two binders (one for the HUD representative and another for your organization) with all relevant materials in subject matter tabs
- Prioritize each deliverable and count backward the amount of time needed to complete it
- Maintain a calendar that identifies milestones for preparing parts of your report
- When inevitable interruptions occur, commit to returning to your calendar, reprioritizing your deliverables and getting back on track.
By staying organized and gauging your work in bite-size pieces along the way, it is possible to reduce anxiety, raise your confidence level and be prepared when inspection day arises.
For more helpful hints, be sure to review the HUD Management Review Worksheet (Form #9834). In addition to reviewing the questions listed on HUD 9834, also use internal audits to make continuous improvements in your operations and you’ll be well on your way to a successful MOR.