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HUD Management and Occupancy Review

Do you need assistance in preparing for and responding to a HUD Management and Occupancy Review? Since HUD has out sourced the administration of Section 8 Contracts, Contract Administrators are conducting the Reviews for the projects they have been assigned.

The purpose of a HUD Management and Occupancy Review is to verify compliance of the property with the terms of the Housing Assistance Payments (HAP) Contract, Regulatory Agreement, Management Agreement and Management Plan which is conducted on an annual basis. Owner compliance will also be verified regarding civil rights regulations, including Title VI, Title VII, the Americans with Disabilities Act, and Section 504 of the Rehabilitation Act of 1973.

An on-site Management and Occupancy review is scheduled with the owner/agent at least two weeks in advance of the review. The owner/agent is responsible for providing proper notice to residents advising them that their unit may be chosen for inspection.

Before the actual inspection, compliance will be reviewed to determine property status by referring to the latest REAC inspection and note any exigent health and safety concerns sited. Review any MIO Plan or Plan of Correction, prior Comprehensive Management Review, complaints from residents, Congressional inquiries and media reports to verify all concerns were responded to in a timely manner. Any contractual violations and imposed sanctions will also be reviewed.

The on-site Management and Occupancy Review begins with an interview with the owner/agent to review the completed the Management Review Questionnaire (HUD-9834) and determine whether existing policy conditions and procedures are acceptable and if corrective action is needed. The following will be discussed and reviewed, if applicable:

Affirmative Fair Housing marketing Plan

Management Agreement

Property’s current budget

Any current policy and procedure in place

Resident selection criteria

Waiting List and policy

Applicant rejection letter

Schedule of tenant damage charges

Rent collection procedure and late charge schedule

Property Rules

Move In and Move Out sheets

Pet policy (if applicable)

Preventive Maintenance policy

Resident request service logs

A random audit of resident files will be conducted to verify HUD compliance regarding:

  • Eligibility and selection

  • Income and assets

  • Third party verification of resident income and assets

  • Household characteristics

  • Adherence to income limit guidelines

  • Lease and lease addendums

  • Drug Free Housing Policy

  • Resident deposit

  • Certification and recertification of family eligibility

  • Initial notice of next recertification

  • Citizenship documentation

  • 9887/9887A Consent Form

  • Lead Based Paint Addendum

  • Social security number verification/documentation

  • Disposal of assets

  • HUD form 50059

The physical inspection will include a general inspection of buildings and grounds including, but not limited to:

Random selection of occupied and vacant resident units to determine the level of maintenance and security

  • Work and storage areas

  • Mechanical rooms

  • Laundry facilities

  • Trash storage

Particular attention will be paid to:

  • Areas cited for exigent health and safety items noted in the latest REAC inspection to ensure problems have been remedied.

  • Areas or units where Replacement Reserves have been released in the past 12 months.

  • A close-out meeting will be conducted upon the completion of the review to discuss the results and any preliminary findings and concerns identified.

Within 30 days of the review a written report which provides a rating, outline findings, cited and corrective actions needed. If the property is rated below satisfactory, a copy is sent to the Multifamily HUB or Program Center and mortgagee. An owner response is needed within 30 days from the date of the report outlining corrective action taken. Once it is determined that the owner has responded and taken all corrective action, the Compliance officer will notify the owner with a close-out letter.

I can offer you assistance by helping you to conduct preparatory review of your operation, resolve Review Findings, provide drafts of forms and documents to edit for your operation and other matters related to the Review.

Contact me  by phone 301-277-3465, or by email at and I can discuss the status of your project.

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Date Updated: 09/27/2023 03:40:48 AM