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MTW Oversight

INTRODUCTION

MTW agencies are housing authorities that have been selected to participate in a demonstration that allows public housing and Housing Choice Voucher funds to be combined and used according to terms the agencies have proposed and HUD approved.  In all other respects, these agencies still function like other housing authorities.  They enter into Annual Contributions Contracts for their funding, and are subject to its requirements and the 1937 Housing Act and its implementing regulations unless they have requested exceptions in their Annual MTW Plans.  Per the MTW statute, MTW agencies are not exempt from the provisions of Sections 12 and 18 of the 1937 Housing Act.  MTW agencies are also still subject to all other Federal statutes and regulations.

In addition to providing the standard information required from all PHAs (submission into PIC, FDS and VMS, as well as annual IPA audits), MTW agencies are required to provide an Annual MTW Plan that is more detailed and provides extensive information about the agency and its MTW program.  MTW agencies also submit an Annual MTW Report to HUD.  While the Annual MTW Plan substitutes for the PHA Agency Plan, the Annual MTW Report is only provided by Moving to Work agencies.

A memorandum of understanding has been entered into between the program office for MTW and the field operations office.  A detailed field office desk guide has been assembled for PIH field office staff that describes the reporting and monitoring requirements as they relate to MTW agencies, as well as their role in providing oversight.  Below is a summary of some of those activities: 

FINANCIAL REPORTING REQUIREMENTS AND AUDITS

FDS Reporting/IPA Audits

1.         Section 230 of the 2010 Appropriations Act states that in addition to other reporting requirements, all MTW agencies shall report financial data to HUD as specified by the Secretary, so that the effect of MTW policy changes can be measured.  Accordingly MTW agencies must submit year-end financial information into the Financial Data Schedule (FDS).  FDS reporting requirements for MTW agencies are currently posted on the REAC website at http://www.hud.gov/offices/reac/products/fass/fass_pdf/mtw-reporting.pdf.

2.         An MTW Agency must submit unaudited financial statements into FDS within 60 days of the end of its fiscal year, and audited financials with nine months of the end of its fiscal year.  Although not scored in PHAS, a financial score shall be developed by REAC and provided to both the MTW office and PIH Field Office.  The PIH Field Office reviews the unaudited financial submission for basic financial soundness (e.g. cash balances, accounts receivable and accounts payable, quick ratio, current ratio, etc.).  Any potential risk identified as a result of this analysis should be brought to the attention of the MTW Coordinator and the MTW office.

3.         If subject to the Single Audit Act (SAA), the MTW Agency must procure an Independent Public Accountant (IPA) to perform an OMB Circular A-133 compliant audit.  An A-133 compliance supplement has been developed for the MTW program, and auditors began using this supplement effective March 2010.  Completed audits must be provided to both OPHI and the PIH Field Office.  Extensions of A-133 audit submissions are provided in the same manner as non-MTW agencies.

4.         PIH Field Offices review the IPA audits of MTW agencies to determine appropriate action relative to any findings, prepare recommendations for audit finding resolution, and follow up with MTW agencies to assure finding closure.  If there are audit findings related to the MTW program itself, the PIH Field Office informs the MTW Coordinator and monitors the resolution of all audit findings.

ASSESSMENT AND PROGRAM INTEGRITY

Public Housing Assessment System (PHAS)

1.         MTW agencies are exempt from receiving a score in PHAS unless they voluntarily choose to be scored.  However they are subject to HUD inspections (both physical and management) and must submit financial information as stated above.

2.         Per the MTW statute, when providing public housing, the MTW Agency must ensure that it is safe, decent, sanitary, and in good repair, according to an inspection protocol established or approved by the Secretary.  If an MTW Agency does not maintain public housing adequately, as evidenced by the physical inspection performed by HUD and is determined to be troubled in this area, REAC will refer the MTW Agency to the MTW Office and the PIH Field Office for remedial action.  The MTW Office and PIH Field Office will determine appropriate remedial actions, including referral to the PIH Field Office for oversight and monitoring.  The actions to be taken by HUD and the PHA will include actions statutorily required, and such other actions as may be determined appropriate by HUD.  These actions may include developing and executing a Memorandum of Agreement (MOA) with the MTW Agency, suspension or termination of the MTW Agreement in accordance with the provisions therein, or such other actions legally available to the Department.

Section 8 Management Assessment System (SEMAP)

1.         MTW agencies are exempt from receiving a score in SEMAP.  MTW agencies remain subject to on-site monitoring reviews by the PIH Field Office relating to VMS reporting and income integrity and the Quality Assurance Division relating to VMS reporting and rent reasonableness. 

PIC and VMS Reporting

1.         MTW agencies are required to report family information in PIC, and should use the MTW 50058 module (must use if the Agency uses an alternate rent structure/recertification).  MTW agencies must report all families receiving some form of tenant-based or project-based housing assistance, either directly or indirectly, as well as all public housing families, to at least a 95% level.  MTW agencies must also report in the Inventory Management System (IMS) in PIC and certify units.  PIH Field Offices monitor their MTW Agencies’ reporting to ensure compliance.

2.         MTW agencies are required to report voucher utilization in the Voucher Management System (VMS).  Because MTW agencies can combine HCV and public housing funds, they are not required to maintain Net Restricted Asset (NRA) or Unrestricted Net Asset (UNA) accounts.  The PIH Field Offices monitor MTW Agencies’ reporting to ensure compliance.

MONITORING

Enterprise Income Verification System (EIV) Reviews

1.         MTW agencies are required to comply with the final rule regarding EIV issued December 29, 2009 rule, and utilize EIV for all income verifications.  EIV has been modified for MTW agencies so that family information submitted in PIC will not expire for 40 months, in order to accommodate agencies choosing to extend recertification periods for up to three years.  MTW agencies will be subject to Rental Integrity Monitoring (RIM) reviews performed by the PIH Field Office to ensure compliance with EIV requirements.

Annual MTW Site Visit

1.         The MTW Office and the PIH Field Office jointly conduct Annual MTW Site Visits to discuss the MTW Agency’s MTW program and provide needed technical assistance regarding its program.  The MTW Office (specifically the MTW Coordinator assigned to the Agency) takes the lead role in conducting the visit.

2.         PIH Field Offices plan for MTW site visits when developing their annual management plans and must attend the annual monitoring visits to their MTW site.  Site visits are scheduled by an MTW Office staff member for the MTW Agency, in consultation with the PIH Field Office.  If possible, the visit will be coordinated with other monitoring reviews planned by the PIH Field Office.

3.         Specific assignments (e.g., resolution of specific issues, provision of TA) may be identified during the site visit that the PIH Field Office can best accomplish and shall take the lead for those items.

Appendix 1

Field Office Actions Related to Program Administration for MTW Agencies

PROCESSING TASK/MONITORING ACTIVITY

EFFECT ON PROGRAM

<--------Non-MTW Agency------->

 

Task/Activity

LIPH

Operating Fund

Capital Fund

Section 8

Development and Mixed Finance

Moving to Work Agency Action

Review and Approve Annual Plan

FO

 

FO

FO

 

Annual MTW Plan in lieu of Annual Plan.

MTW in consultation with FO

Approval of  annual subsidy request

 

FO (processed jointly with HQ and FO)

FO (processed jointly with HQ and FO)

No Action

 

Same as non-MTW, in accordance with Attachment A of MTW Agreement

PIC Reporting

FO (50058)

 

No Action

FO (50058)

 

FO (MTW 50058)

FO approve unit status changes

Some (certain categories must be approved/ entered by FO)

Some (certain categories must be approved/ entered by FO)

No Action

No Action

 

Same as non-MTW

FO approve PHA budget

No Action - Only for certain PHAs (Troubled only)

 

FO

No Action (separate from funding amount)

 

Same as non-MTW

FO load budgets

No Action

 

FO

No Action

 

Same as non-MTW

FO approve draw-downs

No Action - Only for certain PHAs (e.g. zero threshold)

 

No Action - Only for certain PHAs (e.g. zero threshold)

No Action

 

Same as non-MTW

FO approve budget revisions

No Action - Only for certain PHAs (e.g. zero threshold)

 

FO

No Action

 

Same as non-MTW

FO approve expenditures

No Action - Only for certain PHAs (e.g. zero threshold)

 

No Action – Only for certain PHAs (e.g. zero threshold)

No Action

 

Same as non-MTW

FO approve PHA contracts

No Action - Only for certain PHAs (e.g. zero threshold)

 

No Action – (Only for certain PHAs (e.g. zero threshold)

No Action

 

Same as non-MTW

FO receive/review routine financial reports (less than annual)

No Action

 

FO (semi-annual quarterly obligation/expenditure reports?)

No Action

 

Same as non-MTW

FO receive/review routine program monitoring reports (less than annual)

No Action

 

No Action

No Action

 

Same as non-MTW

FO approve tenant selection/admin plan

No Action

 

N/A

No Action

 

Same as non-MTW

Verification of FDS reporting

FO

 

FO

FO

 

MTW and FO

PHAS/SEMAP

FO

 

FO

FO

 

MTW Agencies exempt unless elect to be scored

Other

Obtain certificate of insurance (annual)

 

No Action

Special tasks re: relocation/conversions

 

N/A

Field Office Program Administration Responsibilities for MTW Agencies

ONGOING PROCESSING TASK/MONITORING ACTIVITY

EFFECT ON PROGRAM

<--------------------Non-MTW Agency--------------->

 

Task/Activity

LIPH

Operating Fund

Capital Fund

Section 8

Development and Mixed Finance

Moving to Work Agency

Budget Processing (annual)

FO

 

FO

No Action

 

Same as non-MTW

Budget Revisions

Troubled Only

 

No Action

No Action

 

Same as non-MTW

FO IPA audits quarterly

FO

 

FO

FO

 

FO and MTW

FO review IPA audits to determine appropriate follow-up

FO

 

FO

FO

 

Same as non-MTW

FO prepare recommendations for audit finding resolution

FO

 

FO

FO

 

Same as non-MTW

FO follows-up with PHAs to assure finding closure

FO

 

FO

FO

 

Same as non-MTW

FO reviews OIG Audits of PHAs

FO

 

FO

FO

 

FO in consultation with MTW

FO prepares management approval documents

FO

 

FO

FO

 

Same as non-MTW

FO writes letter to PHA with recommendations

FO

 

FO

FO

 

Same as non-MTW

FO follows-up with PHAs to assure finding closure`

FO

 

FO

FO

 

Same as non-MTW

FO prepares appropriate paperwork for OIG finding closure

FO

 

FO

FO

 

Same as non-MTW, unless Action Official for finding and management recommendation are transferred to OPHI.

Troubled Agency Oversight

FO

 

FO

FO

 

Same as non-MTW

MOA quarterly oversight

FO

 

FO

FO

 

Same as non-MTW

Corrective Action Plan Follow-up oversight

FO

 

FO

FO

 

Same as non-MTW

SEMAP Scoring quarterly

No Action

 

No Action

FO

 

MTW Agency is exempt from scoring in SEMAP

HOPE VI oversight

No Action

 

FO

No Action

FO

Same as non-MTW

Quarterly HOPE VI Reporting review

No Action

 

FO

No Action

FO

Same as non-MTW

Annual HOPE VI On-site Review

No Action

 

FO

No Action

FO

Same as non-MTW

Documents Review (Evidentiaries)

No Action

 

No Action

No Action

FO

Same as non-MTW

Capital Fund Processing

No Action

No Action

FO

No Action

FO

Same as non-MTW

CF ACC Amendments

No Action

No Action

FO

No Action

FO

Same as non-MTW

RHF Processing

No Action

No Action

FO

No Action

No Action

Same as non-MTW

CF Bonus Processing

No Action

No Action

FO

No Action

FO

Same as non-MTW

EHS Certification Reviews

No Action

No Action

FO

No Action

 

Same as non-MTW

Technical Assistance to PHAs

FO

 

FO

FO

FO

Same as non-MTW

Development of Training for PHAs

FO

 

FO

FO

FO

FO and MTW office

PHA and Board Training

FO

 

FO

FO

FO

Same as non-MTW

Environmental Review Oversight

FO

 

FO

FO

FO

Same as non-MTW

Energy Audit Reviews

FO

 

FO

No Action

FO

Same as non-MTW

Energy Performance Contracting

FO

 

FO

No Action

FO

FO and MTW office, especially if Agency has an alternate operating subsidy calculation

Annual Unliquidated Obligations Review

FO

 

FO

FO

FO

Same as non-MTW

 

Field Office Monitoring Functions for MTW Agencies

ONGOING PROCESSING TASK/MONITORING ACTIVITY

EFFECT ON PROGRAM

<---------------Non-MTW Agency----------->

 

Task/Activity

LIPH

Operating Fund

Capital Fund

Section 8

Development and Mixed Finance

Moving to Work Agency

RIM Reviews

FO

 

No Action

FO

FO

Same as non-MTW

MOA Monitoring

FO

 

FO

FO

FO

Same as non-MTW

MOA Assessment Reviews required within 60 days of Troubled Notification

FO

 

FO

FO

FO

Same as non-MTW

SEMAP QC

No Action

 

No Action

FO

No Action

FO if Agency elects to be scored, since MTW Agency is exempt from scoring in SEMAP, otherwise No Action

SEMAP Confirmatory required prior to removal of Troubled status

No Action

 

No Action

FO

No Action

FO if Agency elects to be scored, since MTW Agency is exempt from scoring in SEMAP, otherwise No Action

SEMAP Assessments Review required upon notification of Troubled status

No Action

 

No Action

FO

No Action

FO if Agency elects to be scored, since MTW Agency is exempt from scoring in SEMAP, otherwise No Action

EHS Review required during any on-site visit

No Action

 

FO

No Action

FO

Same as non-MTW

PHAS Confirmatory Review

FO

 

FO

No Action

No Action

MTW Agencies exempt unless elect to be scored

Management Reviews

FO

 

FO

FO

FO

Same as non-MTW

Limited Management Review (e.g. Procurement, Financial, CF)

FO

 

FO

No Action

FO

Same as non-MTW

Environmental Reviews

FO

 

FO

No Action

FO

Same as non-MTW

Compliance with applicable nondiscrimination and equal opportunity requirements including Section 504

FO

 

FO

FO

FO

FO

 

Field Office Systems Functions for MTW Agency

SYSTEM

Task/Activity

PIC Risk Assessment Module

FO reviews Annual MTW Plan and Report, inputs data annually or quarterly

PIC System PHA Administrator

FO assigns PHA authority and rights to system on an ongoing basis

EIV

FO assigns PHA authority and rights to system on an ongoing basis

PIC Development Module

FO review and/or approve building and unit data

PIC 50058 and/or 50058 MTW

FO review reporting rates
FO pulls RIM samples and data

PIC SEMAP

MTW agencies exempt from scoring

CRTT

FO staff inputs all monitoring activity

LOCCS

FO monitors; loads budget line items for CF; reviews CF obligation/expenditure reports

Fedreptg.gov/RAMPS report/ARRA

FO provides TA and oversight of PHA reporting