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Form HUD-9834

HUD Form-9834 Reference Guide

CATEGORY A. GENERAL APPEARANCE AND SECURITY

1. General Appearance

Based on observation, are the project’s exterior and common areas (i.e., grounds, landscaping, parking lots, playgrounds, hallways, laundry room, elevator, garbage area, stairwells, management office) clean, free of graffiti, debris and damage?

2. Security

a. Indicate whether any of the events below have been documented in the last twelve months, and the frequency of the event(s).
b. Indicate which types of security measures, if any, are utilized on site.
c. Based on the answers provided in questions a and b above, what corrective actions, if any, have been taken by the owner/agent?
d. Has the owner/agent requested a rent increase based on cost increases in security costs?

CATEGORY B. FOLLOW-UP AND MONITORING OF PROJECT INSPECTIONS

3. Follow-Up & Monitoring of Project Inspections and Observations

a. Based on a sampling, if EH&S items were identified have the deficiencies been corrected and documented according to the owner/agent’s certification for the most recent REac inspection?
Does the analysis show any repetitive or systemic problems?
b. Based on a sampling of units and common areas, for all other deficiencies noted in the REAC inspection, as applicable, verify that corrective actions have been taken. Have the deficiencies been corrected?
If no, is there a schedule for correcting the deficiencies within a reasonable timeframe to comply with decent, safe, sanitary and good repair standards?

4. Follow-Up & Monitoring of Lead-Based Paint Inspection

a. Is there a certification on file documenting that the project has been certified to be free of lead-based paint or lead hazards?
b. Is the owner in compliance with the HUD approved lead hazard control plan as noted on the desk review?

CATEGORY C. MAINTENANCE & STANDARD OPERATING PROCEDURES

5. Maintenance

a. Indicate below to confirm that there is a schedule for preventive maintenance/servicing for the items listed that are applicable.

b. Is there a satisfactory inventory system to account for tools, equipment, supplies, and keys (serial numbers, bar codes, etc.)?
c. as the owner/agent secured inventory items, such as appliances and tools, to prevent theft?
d. Does the owner/agent have a written procedure that explains the process for inspecting units?
e. How often are units inspected?
f. How are unit inspections documented?
g. If deficiencies are noted during a unit inspection, what is the procedure for correction?               
h. What is the average number of days from move-out until the unit is ready for occupancy?
i. Is there a written procedure for completing work orders?          
j. Is there a procedure in place to handle emergency work orders?           
k. Is there a backlog of work orders?
l. Who is provided copies of completed work orders?
m. Is there documentation by unit that indicates the date of purchase, manufacturer, model, and serial number for appliance purchases (i.e., ranges, refrigerators, furnaces, air conditioners, hot water heaters, etc.)?

6. Vacancy and Turnover

a. How many units were vacant on the date of the on-site visit?

b. Walk through at least two vacant units that are ready for occupancy. Assess and document unit readiness.
c. Based on the interview with on-site staff, are any of the factors listed below contributing to vacancy problems
d. Based on the responses in questions a, b and c, what actions are being taken by the owner/agent to resolve the issue(s)?

7. Energy Conservation

Has management attempted to reduce energy consumption?

CATEGORY E.  LEASING AND OCCUPANCY 

14. Application Processing and Tenant Selection

a. Does the application form contain sufficient information to determine applicant eligibility?

b. Does the application ask whether the applicant or any member of the applicant’s household is subject to a lifetime state sex offender registration program in any state?
c. Does the application ask for a listing of states where the applicant and members of the applicant’s household have resided?
d. Is form HUD-92006 “Supplement to Application for Federally Assisted Housing”, an attachment to the application or part of the application package?
e. Is there an arm’s length procedure between the person who denies an application and the application appeal reviewer?            
f. Has the owner/agent leased a Section 8 unit to a police officer or security personnel who is over the income limit?
g. Does the owner/agent have a written tenant selection plan?  
If yes, does the plan include all required criteria stated in Chapter 4, Handbook 4350.3 REV-1 and all applicable notices?         
h. Does the project maintain a waiting list of prospective tenants? 
If yes, does the list include all required elements stated in Handbook 4350.3 REV-1?
i. Enter the number of applicants on the waiting list for each type of unit: 
j. Were the applicants selected from the waiting list in the proper order, recognizing applicable preferences?    
k. When preferences were applied, were they properly documented?
l. Is documentation available to show that the owner/agent has leased not less than 40% of the Section 8 units that became available for occupancy in the previous fiscal year to extremely low-income families?
m. What marketing steps has the owner/agent taken to attract extremely low-income families?
n. Does the advertising comply with the existing affirmative fair housing marketing plan?
o. Is the fair housing sign posted in the rental office?      
p. Is the fair housing logo included in published advertising materials?

15. Leases and Deposits

a. Have modifications been made to the HUD model lease?

If yes, has the lease and/or lease addenda in use been approved by HUD?
b. Aside from rents and security deposits, what other charges are assessed (replacement keys, lockouts, etc.)?
c. If other charges aside from rents and security deposits are assessed, have they been approved by HUD?
d. Are rents collected in accordance with the provisions of the lease?
e. Is the policy for late fee assessment in compliance with the Handbook 4350.3 REV-1 or with state/local requirements?
f. Are damages caused by tenants properly identified and charged to tenants?    

16. Eviction/Termination of Assistance Procedures

a. Are tenants notified of termination of tenancy or assistance in accordance with HUD requirements?

b. Are eviction procedures initiated timely, when warranted?     
c. Is the termination of assistance initiated timely when warranted?

17. Enterprise Income Verification (EIV) System Access and Security Compliance

a. Does the owner/agent have access to EIV?     

b. Does the EIV Coordinator(s) have an owner approval letter(s) authorizing access to EIV?
c. Does the owner/agent and/or EIV Coordinator have:
An initial and currently approved EIV Coordinator Access Authorization Form (CAAF) on file for each person designated by the owner as an EIV Coordinator?
An initial and currently approved EIV User Access Authorization Form (UAAF) on file for each person designated by the EIV Coordinator as an EIV User?
Signed copies of the EIV Rules of Behavior for Individuals without access to the EIV system, who use EIV reports and/or data to perform their job functions?         
d. Is there evidence that staff with access to the EIV system or to EIV reports take annual security awareness training? 
If yes, is a record kept of employees who attended the training?
e. Does the owner/agent have security measures in place to limit access to EIV information and reports to only those persons who have proper authorization?
f. Does the owner/agent have a procedure to review all EIV User IDs to periodically determine if the users still have a valid need to access EIV data?
g. Does the owner/agent terminate access promptly (within 30 days) of all users who no longer have a valid need to access EIV data?
h. Does the owner/agent have a procedure to document and report the occurrence of all improper disclosures of EIV data?
i. Does the owner/agent have a procedure to report any occurrence of unauthorized EIV access or security breach to the HUD National Help Desk?
j. Is there evidence that the owner/agent or any of their employees are sharing IDs and passwords?         
k. Is EIV data being improperly shared with other entities (e.g., state officials monitoring LIHTC projects, RHS staff, or Service Coordinators not participating in the re-certification process)?
l. Does the owner/agent keep in the tenant file the Tenant Consent for Disclosure of EIV Information, signed by the tenant and a third party when a third party assists in the re-certification process?  

18.  Compliance with Using EIV Data and Reports

a. Does the owner/agent have policies and procedures describing the use of EIV employment and income information and the EIV reports?

If yes, do they comply with HUD’s usage requirements?
b. Is the owner/agent using the following EIV reports, and taking appropriate action to correct discrepant data in TRACS, and/or to reduce improper subsidy payments and where applicable, retaining documentation to support the action(s)?
New Hires Report
No Income Report
Failed EIV Pre-screening Report
Failed Verification Report (Failed the SSA Identity Test)
Existing Tenant Search
Multiple Subsidy Report
Deceased Tenant Report

19. TRACS Monitoring and Compliance

a. Is the owner/agent using TRACS queries to review and monitor their transmission?      

b. Is the owner/agent following up and correcting deficiencies identified in TRACS data?

20. TRACS/EIV Security Requirements

a. Does staff log on using their own user name and password when accessing Secure Systems?

b. Have staff with access to EIV and/or TRACS in Secure Systems completed the required security awareness training each year and is there a signed Rules of Behavior?
c. Have staff with access to the EIV system completed the hard copy authorization form HUD-52676 when access was initially granted and completed the EIV online authorization form annually (coordinators) or semi-annually (users) as required?       
d. Have staff who use EIV reports, but do not access the EIV system in Secure Systems, completed the security awareness training annually and is there a signed the Rules of Behavior?              
e. For new staff, or staff that was given access to EIV or TRACS within the last year, was the security awareness training completed before access, or within 30 days of being given access and signing the TRACS and EIV Rules of Behavior?            

21. Tenant File Security

a. Are the tenant files, as well as other files that contain EIV reports, if applicable, locked and secured in a confidential manner?

b. Is documentation relating to an individual’s domestic violence, dating violence, or stalking, kept in a separate file in a secure location from other tenant files?
c. Is access to tenant file information limited to only authorized staff?
d. Who is authorized to have access to the tenant files? 
e. Is the owner/agent maintaining tenant files according to HUD’s document retention requirements?
f. Is the owner/agent properly disposing of tenant records (shred, burn, pulverize etc.)?                 

22. Summary of Tenant File Review

a. Tenant Files and Records

i. Are the tenant files organized and properly maintained
ii. Do the files contain all documentation as required in Handbook 4350.3 REV-1, applicable HUD Notices, and any changes to the CFR?
b. Application/Tenant Selection
i. Are the applications in the files signed and dated by applicant?
ii. Is screening conducted in accordance with the Tenant Selection Plan?
iii. Are the unit sizes appropriate for household composition at the time of this tenant file review?
iv. If a household was ineligible at move in, were exceptions granted?
c. Lease
i.  Are the correct model leases used?
ii. Are the leases signed and dated by all required parties?
iii. Are HUD issued lease addenda properly signed and in the file?             
iv. Are the applicable addenda attached to the lease?
v. Are security deposits collected in the correct amount for the program?
vi. Are pet deposits within acceptable range and payment installments allowed?
HUD-9887 Fact Sheet    
Lead Based Paint Disclosure
Resident Rights and Responsibilities Brochure
EIV & You Brochure        
Fact Sheet How Your Rent is Determined
Race/Ethnicity Form      
d. Certification/Re-Certification Activities
i. Are re-certification notices issued in accordance with HUD requirements?
ii. Are certifications completed on time?
iii. Are all necessary verifications completed and properly documented?
iv. Are EIV Income Reports used for third party verification of employment and income?
v. If the tenant disputed the EIV employment and/or income reported in EIV, was a third-party verification obtained from the source?
vi. Are appropriate actions being taken for income discrepancies reported on the EIV Income Discrepancy Report, and is the action documented?
vii. Are income and deductions calculated correctly prior to data entry?
viii. Does income information on the tenant certifications agree with verified file information?
ix. If tenants were granted a hardship exemption as part of the minimum rent, was the exemption applied correctly?
x.  Are Repayment Agreements in accordance with HUD requirements?
xi. Are notices provided to tenants in accordance with HUD tenant notification requirements when their portion of rent has increased?
xii. Are the correct contract rents used when determining the subsidy to be paid on behalf of tenants?
xiii. If tenants are paying their own utilities, are the current certifications reflecting the correct utility allowances?
xiv. Are utility reimbursement checks distributed within 5 business days of receipt of the housing assistance payments?
e. Voucher Billing
i. Are there any deficiencies noted in the tenant file review that results in over payment or under payment of the subsidy?
ii. For the move-in/move-out tenant file review, does the owner/agent make appropriate voucher adjustments?
f. Move-In Files
i. Are proper income limits used for determining eligibility at move-in?
ii. Do the files contain move-in inspections?
iii. If the files contain move-in inspections, have the owner/agent and the tenant signed and dated the inspection?
iv. Do the move-in files created after January 31, 2010 indicate that the owner/agent utilizes the EIV Existing Tenant Search for all household members and applicants?           
g. Move-Out Files
i. Do tenants provide written notice of intent to vacate in accordance with the HUD model lease?
ii. Are move-out inspections conducted?
iii. Are security deposits refunded in 30 days or less if required by state law?
iv. Are tenants provided an itemized list of charges against the security deposits?
v. If charges exceed the security deposit, are the tenants billed for the balance due?                                        
f. Application Rejection Files
i. Are applicants denied admittance in accordance with the Tenant Selection Plan?
ii. Do rejection letters provide applicants the right to appeal?
iii. If applicant appealed an application rejection, was the appeal reviewed by someone other than person who made the original decision to reject?
iv. Were appeals processed and applicants notified of the appeal decision within 5 days of the meeting?

CATEGORY F. TENANT/MANAGEMENT RELATIONS

23. Vacancy and Turnover

a. Is there a written procedure for resolving tenant complaints or concerns?

b. Does the procedure adequately cover appeals?
c. Is there an active tenant organization at this project?
d. Is tenant involvement in project operations encouraged?

24. Provision of Tenant Services

a. What social services are provided by the project, or the neighborhood, which meet the tenants’ needs? Below, indicate services that are available, and identify the entity providing the service (i.e., city/county/state, church/school, community groups, etc.) and enter the cost to the project, if any.
b. Is there a Service Coordinator for the project?
c. Is the Service Coordinator’s office clearly identifiable and private?
d. Are the Service Coordinator’s files kept secure and confidential?
e. Does the Service Coordinator maintain a directory of service agencies and contacts, and make the information available to all parties?
f. If there is a Neighborhood Networks Center as indicated on the Desk Review, what is the status of operations?
g. What programs are offered at the Neighborhood Networks Center?
h. The Department allows owners and their agents to provide services related to renter’s insurance products. Does the owner/agent offer such services? 
i. HUD policy prohibits an owner/agent from evicting tenants for delinquent renter’s insurance payments. How does the owner/agent deal with unpaid renter’s insurance?
j. Review the renter’s insurance information provided to tenants. Does the information provided to tenants clearly indicate that purchasing insurance is optional, and not required as a condition of occupancy?        

CATEGORY G. GENERAL MANAGEMENT PRACTICES

25. General Management Operations

a. Have the complaints, as noted on the Desk Review, been satisfactorily resolved?
b. Is the project staff able to adequately perform management and maintenance functions?
c. How does the owner/agent implement HUD changes in policies and procedures?
d. Does owner/agent have a formal ongoing training program for its staff?            
e. Are there signs enabling persons to locate the office?
f. Are there signs enabling persons to locate the office?
g. Are after hours and emergency telephone numbers posted?

27. Staffing and Personnel Practices

a. Has management made an effort to employ tenants in accordance with Section 3 of the Housing and Community Development Act of 1968?
b. List all on-site staff charged to the project. (Use additional sheets if necessary).