HUD releases plan to resume “light touch” MORs

Regulation | July 10, 2020 | by Juliana Bilowich, Juliana Bilowich

HUD’s alternative MOR guidance requires on-site reviews in reopened areas, but allows limited staff, resident contact.

Effective May 22nd, HUD has lifted the suspension on MORs in locations where there are no health restrictions by state or local law. LeadingAge has pushed back on the restarting of MORs, regardless of an area’s “reopening” status, because of the ongoing health risk at older adult communities.

HUD has now publicly shared an internal memo from June 23nd to restart Management and Occupancy Reviews (MORs) at HUD-assisted properties. The memo, titled “Status of Management and Occupancy Reviews performed by PBCAs,” outlines guidance for an alternative approach for MORs, or “light touch” reviews. Although HUD is requiring on-site reviews to be conducted in areas of that country that have “reopened,” the agency is allowing an alternative approach to reduce interactions with site staff and residents.

Among other flexibilities, the alternative guidance allows PBCAs to conduct on-site MORs without entering resident units until September 30th, 2020; the guidance also temporarily allows the file review to be completed without contact with management staff by reviewing files delivered by property staff to a secured location.

To determine whether any Exigent Health and Safety (EHS) or other REAC deficiencies have been corrected during REAC follow-up, the PBCA must documents attempts made to reach out directly to residents of affected units by phone or email. Where local or state law prevents in-person interviews, virtual or phone interviews will also be documented by the PBCA.

Owners will be contacted directly for scheduling, and HUD is urging housing providers to follow CDC and local guidelines throughout the process. LeadingAge will continue to push back on the restarting of MORs, and will ask the agency to prioritize health and safety of communities instead.