As we bid adieu to the year 2010, it is fitting that this last column of the year should cast a look back at the state of compliance in the housing management industry.
There’s no question as to what the compliance issue of 2010 was: Enterprise Income Verification (EIV). As with the advent of TRACS, the arrival of EIV was greeted with uncertainty, anxiety, and no small amount of frustration on the part of many industry professionals. This state of affairs was not helped, in my view, by the shifting dates for implementation of EIV on the part of the former HUD administration.
Now that implementation of the EIV system has been mandatory for almost a full year, there is still confusion and consternation, but it has lessened. It might be difficult to imagine, but as someone who has been in this business for decades, I can assure you that there will come a time that our industry will have as its members individuals who will find it difficult to imagine a day that EIV wasn’t around…just as we have members today who could not fathom doing a HUD-50059 or HUD-50058 manually.
But with all the attention on EIV, there has been some slackening in the “fundamentals” of occupancy management. Basic elements of compliance are being overlooked, or perhaps temporarily forgotten in the stress and strain that accompanied EIV implementation. I’ve been privileged to do some file audits in the past year, and I’ve gotten a complete picture: From the top-notch, professional files to complete disasters and embarrassments that, were the file a person, you wouldn’t want to introduce them to family and friends.
I’ve also noticed that Performance Based Contract Administrators (PBCA’s) have improved exponentially since they were introduced into the HUD system. The early period was not without its problems, and while there is still some occasional unevenness, depending on the PBCA and/or staff member, the “learning curve” seems less steep now. When NCHM has been contracted to do follow-ups to an MOR, more often than not I find myself in full agreement with the findings of the PBCA. I’ve always felt credit should be given honestly when it is due.
I wish everyone a very safe, healthy, prosperous and Happy New Year. I hope to see many of you at a NCHM training in 2011.