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Overview of SEMAP

Overview of SEMAP. Purpose of SEMAP. SEMAP was created to: Objectively measure key areas Identify mgmt capabilities/deficiencies. Performance Indicators 14 indictors plus Bonus. Waiting list 15 Reasonable rent 20 Adjusted income 20 UA schedule 5 HQS QC 5 HQS enforcement 10

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Overview of SEMAP

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  1. Overview of SEMAP

  2. Purpose of SEMAP • SEMAP was created to: • Objectively measure key areas • Identify mgmt capabilities/deficiencies

  3. Performance Indicators14 indictors plus Bonus • Waiting list 15 • Reasonable rent 20 • Adjusted income 20 • UA schedule 5 • HQS QC 5 • HQS enforcement 10 • Expanding hsng 5 • Payment standards 5 • Annual reexams 10 • Correct tenant rent 5 • Precontract HQs 5 • Annual HQS 10 • Leaseup 20 • FSS 10

  4. The PHA Profile • The ratings make up the PHA profile • The profile contains • Point score for each indicator • Total point score • Percentage score • An overall rating

  5. 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

  6. Preparing for SEMAP • Conduct supervisory quality control audit on required indicators • Conduct a preliminary evaluation of the balance of the indicators to determine an estimated score

  7. Preparing for SEMAP • One approach: • 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

  8. Preparing for SEMAP • Internal audit files should contain: • Description of indicator and performance standard • Data reviewed for each indicator • Any other “proof” of certification score • Use auditor minimum file sample and increase sample if needed

  9. Preparing for SEMAP • Supervisory QC reviews: • Periodic samples of files • Drawn in unbiased manner (leave clear audit trail) • Reviewed by supervisor or other qualified person other than the one who did the work • Objective: determine compliance with indicator

  10. Indicators that require Supervisory Audit • Selection from Waiting List 15 • Reasonable Rent 20 • Determination of Adjusted Income 20 • HQS Quality Control Inspections 5 • HQS Enforcement 10

  11. Audit Sample Selection • Size of “universe” determines file sample size • Different for each indicator • e.g., # number of admissions vs. number of families assisted

  12. 5 5 + 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 Audit Sample Selection Chart • 50 or less • 51-600 • 601-2000 • Over 2000

  13. Determining File Sample Size • Determine the universe • Determine number of files to be selected for review • Determine “nth” file this represents • Include all staff in sample • FY is period for analysis

  14. Minimum Files Example • Waiting List Selection: • Based on # of new admissions per FY • Example: PHA has admitted 260 families • minimum # of files to audit? • # of files which must meet criteria to receive 15 points? Note: 98% 10 98.8 (10) files 51-600 = 5 + 1 for each 50 (or part of 50) over 50

  15. Random Sampling Example • Universe requirement 260 files • File sample 10 files • Files to be pulled Every 26th file • If all staff are not represented, select closest file below 26th file

  16. HUD SEMAP Indicators

  17. Selection from Waiting List(15/0 points) • Universe • Number of families admitted to program during audit period • Two separate samples drawn from: • Applicant names that reached the top of the waiting list during the audit period • Families admitted to the program during the audit period

  18. Selection from Waiting List (Supervisory Audit) • 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

  19. 1. Selection from Waiting List • PHA follows policies in selecting families from waiting list • Families met selection criteria that determined their place on waiting list and order of selection

  20. Most Likely Error Points • Preferences in 982.207 • Income targeting 982.201(b)(2) • Special admissions 982.203 • Special program (targeted) admissions 982.204(e)

  21. 2. Reasonable Rent(20/15/0 points) • Universe • Number of families assisted for PHA FY • Sample drawn from • Number of families with RR determinations during PHA FY

  22. 2. Reasonable Rent (Supervisory Audit) • The PHA must have a reasonable written method to determine • Rent to owner is reasonable based on current rents charged for comparable unassisted units

  23. 2. Reasonable Rent • The method may take into consideration • Location • Size • Type • Quality • Age • Amenities • Housing services • Maintenance • Utilities

  24. 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 • 5% decrease in the FMR in effect 60 days before HAPC anniversary date

  25. 3. Determination of Adjusted Income (20/15/0 points) • Universe • Number of families assisted for PHA FY • Sample drawn from • Number of families assisted for PHA FY

  26. 3. Determination of Adjusted Income (Supervisory Audit) • 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

  27. Most Likely Error Points • Market/cash value of assets • Asset income • Training program income • EID for persons with disabilities • Disability assistance & medical expenses • Conflict between utilities in lease and worksheet

  28. Regulatory Verification Requirement • The PHA must obtain and document in the family file third party verification of the following factors, or must document in the file why third party verification was not available: CFR 982.516 • Reported family annual income • The value of assets • Expenses related to deductions from annual income • Other factors that affect the determination of adjusted income

  29. Notice PIH 2010-19 • Published May 17, 2010 • Replaces verification hierarchy in Notice PIH 2004-1 with a new, 6-level hierarchy • Tenant-provided documents generated by a third party are now considered “third-party written” verification

  30. Hierarchy of Verification Methods • HUD has established a hierarchy of six verification levels • Using this hierarchy, PHAs should develop and adopt verification policies as to what qualifies as adequate verification • Policies must be consistent with the regulatory requirements

  31. Recommended Levels of Verification • Up-front income verification (UIV) using EIV • UIV using other sources • Written third-party docs provided by family • Written third-party verification form • Third-party oral • Tenant declaration

  32. Upfront Income Verification • What is it? • The verification of income, before or during a reexamination, through an independent source that systematically and uniformly maintains income information in computerized form for a large number of individuals

  33. Use of UIV for Verification • UIV is third-party verification • Most preferred form • Meets regulatory requirements • UIV is intended to streamline the verification process • Eliminates the need for written third-party verification forms in many cases

  34. Upfront Verification Using EIV • Use of EIV is required for annual and interim reexams • EIV is not available for applicant families or new members added to currently assisted households

  35. HUD Guidance on EIV • EIV is sufficient as third-party verification of employment when • The family does not dispute the data, AND • Current tenant provided documents (i.e. paystubs) are available

  36. HUD Guidance on EIV • The PHA MUST obtain additional third-party verification when the family disputes EIV employer data

  37. HUD Guidance on EIV • The PHA MAY obtain additional third-party verification if it determines that additional information is necessary, such as • Effective dates of employment • Pay rate, hours worked for new jobs • Confirmation of a change in circumstances (reduced hours, reduced rate of pay)

  38. HUD Guidance on EIV • Use tenant-provided documents to project annual income, unless • The family disputes EIV employer data, OR • The PHA determines that additional information is necessary

  39. HUD Guidance on EIV • Do not use EIV quarterly wages to anticipate annual income • The data is usually 6 months old and more current information (such as pay stubs) is available

  40. HUD Guidance on EIV:File Documentation • If the family does not dispute EIV employer data, and the PHA determines that additional information is not necessary • EIV income details report • ICN in FL • Tenant-provided documents

  41. HUD Guidance on EIV:File Documentation • If the family disputes or PHA requires additional information • EIV printout (except in FL) • Tenant-provided documents • Third-party written verification

  42. UIV Using Other Sources • Second most preferable form of verification • PHAs are encouraged to use non-HUD UIV tools, such as • The Work Number • State government databases/SWICA (continued…)

  43. UIV Using Other Sources • PHAs are encouraged to use non-HUD UIV tools, such as • State TANF systems • Credit Bureau Association (CBA) credit reports • Internal Revenue Service (IRS) – tax transcript • Request with IRS form 4506-T

  44. Written Third-Party Verification • An original or authentic document generated by a third-party source • Includes documents provided by family • Dated within 60 days of reexam or PHA request

  45. Written Third-Party Verification • Examples of acceptable tenant-provided documents generated by a third party • Pay stubs/payroll summary • SSA award letters • Bank statements • Welfare/unemployment notices • Etc.

  46. Written Third-Party Verification • The PHA may reject tenant-provided third-party documents only if they are • Not original • Forged • Altered, mutilated, or not legible • Must explain to family and request additional documentation

  47. Written Third-Party Verification Form • The “traditional” third-party written verification • Standardized form filled out by third party • Tenant-provided documents generated by a third party now rank higher than third-party forms

  48. Oral Third-Party Verification • PHAs contact the independent sources by telephone or in person • Third-party oral verification may be used when requests for written verification have not been returned within a reasonable time – e.g. 10 business days

  49. Tenant Declaration • An applicant or participant submits an affidavit or notarized statement to certify income or expenses that s/he has reported • This method should be used as a last resort when no other verification method is possible

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