Coming Soon – Opportunity to Review MOR Form Revisions

Regulation | August 19, 2019 | by Colleen Bloom

For several months now, a complete review of form HUD 9834 used for the Management and Occupancy Reviews (MORs) has been underway and drafts of a wholly restructured and revised document should be available shortly for public comment. And LeadingAge will be strongly encouraging members to take a look and provide feedback.

For the last several months, LeadingAge staff have been representing member interests in nearly weekly meetings as part of an internal HUD task force, as well as an external stakeholder working group, focused on updating and revising the current form HUD 9834 used to guide the process for HUD and/or PBCA staff to perform a close review of resident files for the purposes of ascertaining compliance with HUD required management and occupancy policies.

Substantial work has been completed on the onsite review to achieve the stated goal of ensuring that the MOR focus on eliminating fraud, waste and mismanagement. Secondary goals of reducing the size of the document and enhancing consistency have also been driving forces. As a result, a completely reworked onsite checklist and new Excel spreadsheet form for the file-review questionnaire are currently being polished up for imminent release to a broader audience for further review and comment very soon.

Because of the diverse background of participants in both groups, the perspectives of HUD as compliance reviewer, PBCA as contract administrator serving HUD, owners/agents seeking to remain in compliance, and consultants and trainers working to help ensure their advice is on track, many recommendations were made for additions, deletions and clarifications already.

Currently circulating drafts of the new forms reflect a comprehensive effort to ensure that any scorable question on the form be tied back to a specific HUD requirement, posing the question in such a way that “yes” is always the correct answer, removing elements that may no longer be relevant, adding categories of questions for issues that were not previously reflected (such as VAWA and EIV), and consolidating all questions that pertain exclusively to HUD or the mortgagee at the end.

Additionally, several questions will now reference “compliance with existing HUD guidance” so that, instead of incorporating a number of check-off items that could become irrelevant for what they do, or do not, include (requiring additional OMB review to make any changes), reviewers -- as well as owners/agents -- will know what to look for in future MOR situations by referencing a supplemental Audit Guide that is yet to be finalized, but can be updated as needed to reflect changes in HUD policies.

Still to come will be discussions about how to improve both fairness and consistency in scoring.

So, stay tuned. We’ll announce the opportunity to view the draft revisions and comment via the LeadingAge Housing Operations and Policy listserv as soon as they are available.