Successful Compliance Of Multiple Program Requirements
While managing any low income housing tax credit or subsidized community can be a challenge, consider what happens when you have more than one program type involved; a blending of requirements that can exponentially complicate matters.
That's why FOURMIDABLE has taken the initiative to create a Compliance Department. One of our primary responsibilities is to monitor and ensure compliance with multiple program regulations for the entire FOURMIDABLE portfolio.
The result has been identifying best practices and lessons learned.
If you're dealing with a community with layered programs, pay attention to the mix of the program and the requirements surrounding it. Following the more restrictive requirement is typically the way to go, and the more likely the programs will be successful.
As a first step, it is extremely important to keep current with the standards established by the Department of Housing and Urban Development (HUD), state agencies and housing authorities.
As you can imagine, details are paramount when it comes to a well-managed compliance program and that starts with fully understanding the myriad of requirements that will ultimately drive what needs to occur and when. This starts with eligibility requirements that determine who will be able to live at a particular property; for example, age or income requirements.
That flows over to a properly crafted tenant selection plan, one that's based on the occupancy standards associated with the community. From there, a compliance strategy will also pay attention to how a waiting list is created and managed. Ultimately, the end result is to have a fully occupied community with qualified residents and prospects waiting to move in.
Appeals and hearings are also a critical part of any housing program where federal dollars are involved. From a compliance standpoint, make sure you're doing what is expected, especially if HUD has already been explicit in what it anticipates going forward.
Again, attention to detail will go a long way towards making sure the programs are a success, not only from a financial standpoint (because a program in compliance is critical), but also simply because a well-managed program is one that government entities will want to support.
It's also important to have a clear understanding of how the rents for a community are developed; the ultimate goal being that the overall budget will balance and align closely with what the funding agency saw as critical to determining success.
Compliance success is also driven by having those involved in the management of a property know and understand the inspection protocol that an agency is applying to your community. This applies not only to the paperwork, which is important, but to the various physical inspection standards that you must comply with in order for a project to remain in a favorable light.
High scores are imperative when you're dealing with any community that requires physical inspections, so make sure you know and understand what's required and how to deliver on those expectations.
Underscoring the point, physical inspections aren't something that you prepare for in a week. It's not atypical for significant capital improvements to be required and those take time to deliver.
Remember, the reputation a community earns is something that will be contagious, positively or negatively. If a community earns a negative reputation, it is difficult to turn the image around.
And that brings us to the importance of having the right management agent and employees on site. The right people in the job will help in achieving high scores from a compliance standpoint. Professional, experienced staff who know and understand what's required and who have the inherent ability to deliver on those expectations is mandatory.