The guidance supersedes pandemic-era guidance that shifted portions of the reviews to virtual or remote.
In an October 2023 memo, the Department of Housing and Urban Development (HUD) Office of Multifamily Housing announced a reinstatement of in-person Management and Occupancy Reviews (MORs) beginning January 1, 2024.
Reviews verify property compliance with HUD regulations and contracts, and are conducted at properties by Contract Administrators every one to three years on a risk-based schedule.
Titled “Required and Alternative Management and Occupancy Review (MOR) Procedures for Performance Based Contract Administrators (PBCAs),” the guidance supersedes prior pandemic-era guidance regarding remote MORs.
During the height of the pandemic, HUD allowed MORs to be conducted with remote elements, like entering a vacant unit instead of an inhabited unit, or receiving files virtually ahead of the visit.
HUD’s October 20 memo states that HUD sees value in MORs being completed on site, including receiving feedback from residents, interviewing staff in person, observing property conditions, evaluating files and records, and protecting tenant Personal Identifiable Information.
Beginning January 1, 2024, PBCAs will be required to conduct MORs in the following manner:
PBCAs must complete the on-site MOR entrance conference, MOR questionnaire and exit interview.
PBCAs must physically enter resident units to conduct follow-up inspections of Exigent Health and Safety (EH&S) issues cited in inspections conducted by the Real Estate Assessment Center (REAC).
PBCAs must conduct an on-site visual assessment of each building and the property’s grounds to document the physical conditions, general appearance, and security of the property.
PBCAs must complete on-site reviews of tenant files, tenant selection plan, waiting lists, and Enterprise Income Verification (EIV) master files, as HUD does not authorize the off-site transfer, either electronically or physically, of tenant files, EIV reports, or waiting lists. Tenant files, waiting lists, and EIV master files may be left in a secured on-site location for the PBCA to conduct their reviews.
PBCAs will be required to conduct MORs in person unless an alternative method is approved by HUD in advance. Authorization for an alternative approach could be based on federal or state/local laws, health codes, or emerging health and safety issues.
The memo refers only to reviews conducted by PBCAs, not HUD-conducted MORs at Section 202 PRAC properties.