HOME Program Monitoring Guide for State Recipients and Subrecipients
Part III
HTFC Monitoring of State Recipients & Subrecipients Procedures & Checklists
Overview
In compliance with HOME regulations, HTFC will monitor LPAs annually to determine compliance with the regulations in implementing the HOME Program. In most cases, this will be an on-site review as described below, but HTFC reserves the right to conduct a phone and desk review. The reviews will be scheduled in advance by the
DHCR Regional Office.
Prior to coming on site, monitoring staff will review HTFC files, prior monitoring findings and IDIS information. The LPA may also receive in advance a set of questions to review and prepare to answer.
The on-site review will consist of:
- an interview;
- review of program files;
- review of a random sample of individual project/owner files; and
- a visit to several sites for visual confirmation of work.
LPA preparation for this annual visit should include the following activities:
- Review of program files for completeness using file checklists & these interview instruments;
- Review of owner/project files for completeness using file checklists & interview guides; and
- Preparation for interview using these guides and questions (if any) sent in advance by HTFC.
LPA staff should also review the HOME Program Monitoring Guide for additional checklists and information regarding HOME compliance.
DHCR/HTFC Staff Instructions & Procedures
The instructions below lay out a general protocol to follow when scheduling and conducting a monitoring site visit
to an LPA.
While the regulation requires annual review of recipients (and rental inspections and file reviews every 1 - 3 years), it is important to take into account risk factors in the frequency of monitoring. Some LPAs may benefit from more frequent visits based on certain risk factors or prior performance problems. Refer to the risk factors on p. 10 of HUD's Monitoring HOME Program Performance guide. Where possible, consider more frequent visits to those LPAs that reflect high risk factors.
Also, keep in mind that these protocols and instruments focus on compliance, and that productivity and performance are also important concerns that should be emphasized during the visit, and any other interactions with LPA staff.
- Schedule the Visit
Schedule the visit well enough in advance to give the recipient time to prepare and ensure appropriate people will be available on site. Review this Guide and the HUD Monitoring HOME Program Performance guide.
Be sure to make enough copies of the appropriate file checklists in Part II of this Guide, as needed, in order to conduct file reviews for at least 5 project files or 10 percent of the total, whichever is greater.
- Pre-visit Desk Audit
HTFC staff should complete the desk audit, Section I, as part of visit preparation to summarize the grantee's program basic information, program status, and any known difficulties and concerns. Then, mail Section II, sponsor's program design and operation questionnaire, with a letter confirming the date of the monitoring visit. Request that this form and any related exhibits be returned to DHCR/HTFC prior to the visit.
- Opening Conference
Review the topics to be covered during the visit and the status of known problems or issues. Determine if the grantee completed Section II, and review it or conduct the interview.
Draw a file sample early in the day; ask the contact person to set up project visits for the afternoon.
- Administrator Interview(s)
Begin with Section III, which deals with selected specific HOME rules and regulations for three subrecipient project types, as appropriate: rehabilitation of owner-occupied housing, rental rehab and first-time homebuyer assistance. Tenant-based assistance will be added in the future).
Complete Section IV, on "other" requirements and policies. These very general questions are intended to uncover additional compliance problems that warrant further review or technical assistance.
Space on the forms are limited. Attach field notes as appropriate to document the interview.
- Project Files Review
Refer to the project list on IDIS reports, and select files for review. It is recommended that 10 percent of the files (a minimum of 5 files) be selected for review. To the extent feasible, include a range of projects at various stages of completion (application stage, in progress/under construction, completed, occupied).
Use the file checklists in the previous section of this document to review the completeness of the file. Verify the adequacy and accuracy (not just the existence) of the appropriate file documentation and whether file information corresponds with IDIS reports. The key issues of the file review include the following:
- Are the required documents in the file?
- Is property eligibility documented?
- Is occupancy/income eligibility documented?
- Does the project meet property standards?
- Is there evidence of required compliance documents and ongoing compliance monitoring?
- Project Inspections
Using the brief Section V along with HQS inspection formats as appropriate, visit three to five projects, also at various stages of completion. Look generally for evidence that work has been completed as reported, and that the project meets HQS guidelines (or reasonably would have met HQS guidelines at time of completion for owner-occupied units). If the property is pre-1978, look for evidence that lead hazards have been addressed using safe work practices.
If time permits, interview project owners and tenants to verify file information and determine their satisfaction with the program.
- Exit Conference
If time permits, conduct an exit conference with key staff to give preliminary reactions and identify
issues that are likely to be raised in the monitoring letter. Provide guidance on how to resolve any issues
or concerns.
- Monitoring Letter and Follow-up
After the site visit, review and summarize the monitoring visit and any further actions needed.
Among the key topics to reconsider (beyond the basic regulatory compliance issues):
* Is the program design (including type and level of subsidy) appropriate for the locality?
* Has the sponsor done what was proposed? Do the activities and procedures correspond to the proposal, agreement and administrative plan? If not, do changes pose any regulatory compliance problems?
* Have there been any significant changes to activities, procedures, and units/beneficiaries that would constitute contract compliance issues beyond regulatory compliance? Specifically, are the actual results of any of the following (which were directly related to scoring factors) significantly different from what was originally proposed:
* Average income of households served;
* Timetable for commitment, disbursement, project completion and closeout;
* Target area served;
* Average per unit amount of HOME assistance; and
* Leverage of other funds.
* Were activities implemented according to schedule and in a reasonable period of time?
* Were program objectives achieved in a productive, cost- efficient manner?
* Are files maintained to demonstrate compliance with requirements, including project and cost eligibility?
* Were procurement and conflict of interest records kept to demonstrate reasonable and cost-effective award of contracts?
* What actions or technical assistance would improve the program?
The monitoring letter is the summary of all findings and concerns. It should not be limited to regulatory compliance issues, but also cover contract compliance issues, productivity and program effectiveness. Separate findings and matters of regulatory compliance from those matters of advice that reflect suggestions or recommendations for the recipient to consider.
The letter should be sent within two weeks of the monitoring visit. Establish a clear time frame for the recipient to respond to any findings or required responses. Usually, 30 days is reasonable.
Follow-up with the recipients during the response period to address any questions regarding the findings. Also, contact the recipient after the response period has elapsed without response, or if the response is inadequate.
Keep in mind the availability of TA to all HOME recipients through DHCR and through other TA providers under contract to HUD.
New York State HOME Program Monitoring Guide
PART I: PRE-VISIT FILE REVIEW
| 1. Grantee: | _______________________________ | | |
| Address: | _______________________________ | | |
| Contact person: | _______________________________ | | |
| SHARS number: | _______________________________ | Telephone number: | __________ |
| 2. Monitoring visit for Federal Fiscal Year ____________ | Visit date: | __________ |
| HTFC reviewer: ___________________________ |
| 3. Desk review checklist: |
| _____ Original application | _____ Current administrative plan |
| _____ Current HUD IDIS report | _____ Notice of visit |
| 4. Type of recipient |
| _____ State Recipient | _____ State Recipient with subrecipient |
| _____ Subrecipient | _____ Community Housing Development Organization
|
5. HOME Funding History
| Fiscal Year | Awarded | % Committed | % Expended |
| | | | |
| | | | |
| | | | |
| | | | |
6. Implementation (List key milestones from administrative plan and contract):
| Milestone | Target Date | Completed Date |
| | | |
| | | |
| | | |
| | | |
7. Activities funded (from IDIS and other DHCR reports):
| Activity | Units Planned | Committed | Completed |
| | | | |
| Owner-occupied Rehabilitation - one family | | | |
| Owner-occupied Rehabilitation - 2-4 family | | | |
| Rental Rehabilitation | | | |
| Home Purchase assistance - new construction | | | |
| Home Purchase assistance - rehabilitation | | | |
| Home Purchase assistance - no rehab | | | |
| Tenant-based rental assistance | | | |
8. Problems Identified (Note any previous monitoring Findings on this or other programs, and any problems that were identified during application review or subsequent contacts):
| Problem | Exists in this grant? | Comments |
| | | |
| Delay between commitment and initial draw | | |
| Projects committed then canceled | | |
Inadequate or inappropriate subsidy mechanisms
or program design | | |
| Construction monitoring process not clear/not followed | | |
| Final drawdown/closeout delay | | |
| Other | | |
9. Scoring Factors (Review the proposal/scoring sheets for the following items, and examine actual results for changes that might have affected the scoring factors):
| Scoring Factor Item | Basis for Score from Application |
| Average HH income proposed | |
| Timetable proposed | |
| Target Area proposed | |
| Ave. Per Unit HOME Subsidy proposed | |
| Leverage of Other Funds proposed | |
10. Resales/Foreclosures/Program Income/Recaptures.
Have there been any resales/foreclosures or other events related to projects funded in this or previous grants that were reported this period and may have produced recaptured or program income funds?
11. Other questions or concerns suggested by file review:
_________________________________________________________________________________________
_________________________________________________________________________________________
_________________________________________________________________________________________
PART II: GRANTEE QUESTIONAIRE
| 1. Grantee: | 2. SHARS ID: |
| 3. Contact Person: |
| 4. Staff assigned to program: |
| Name/function |
| Name/function |
| Name/function |
| Name/function |
5. Describe any changes in your HOME program activities from those indicated in the application and administrative plan:
|
6. Describe any changes in criteria for selecting recipients indicated in your HOME application and administrative plan:
|
7. Describe any changes in HOME administrative plan procedures as indicated below:
a. Procedures for determining the amount of funds for each assisted unit:
b. Methods of determining project feasibility:
c. Means for ensuring that minimum funds needed to maintain affordability were invested in each unit:
|
8. Have any of the following procedures for soliciting and processing applications changed from those described in your administrative plan? If so, describe below:
Program outreach/marketing:
Application intake:
Maintaining wait lists:
Determining income eligibility:
Determining property eligibility:
Initial inspection:
Work write-ups:
Review of plans and specifications:
Contractor selection:
Drawdown:
Are there written materials for these procedures?
|
9. Outline your general procedures for contractor procurement.
|
10. Describe your mechanisms/procedures for ensuring project completion.
|
11. Summary of applications for the year being monitored:
|
| Number received: | |
| Number withdrawn: | |
| Number rejected: | |
| What were the primary reasons for applicants dropping out? | |
| What were the primary reasons for rejecting applications? | |
12. Outline your general procedures for contractor procurement.
Are these procedures in writing?
|
13. Have funds other than HOME been used in HOME projects?
|
14. If your program involves rehabilitation:
a. Do you have a written rehabilitation standard? (review copy)
b. Have any units exceeded HOME after-rehabilitation property value limitations? Explain circumstances.
c. Indicate any other problems encountered in qualifying properties for eligibility.
|
PART III: HOME REQUIREMENTS FOR SPECIFIC PROJECT TYPES
A. REHABILITATION OF OWNER-OCCUPIED HOUSING
1. Income Eligibility/Targeting
- Were there any problems related to income eligibility or targeting?
- Is there file documentation of all owners meeting income limitations?
2. Affordability Provisions
What local requirements were imposed to preserve the affordability of units or provide for recapture of funds?
3. Per-Unit Costs
- Have you exceeded the DHCR $30,000 subsidy limitation?
- Were local cost limitations exceeded?
4. Property Valuation
What method was used for property valuation?
5. Financing
| a. Form(s) of assistance provided with HOME funds: |
| Loans | Deferred-payment loans | Grants |
(If loans, summarize the terms)
|
b. Is an owner match or contribution required?
|
| c. Where have owners typically received financing? |
| Private lending institutions | Other: |
|
d. Have private lenders been formally involved, as through a leveraging agreement?
|
| Yes | No
|
Describe:
|
| ___________________________________________________________________________________ |
| ___________________________________________________________________________________ |
| ___________________________________________________________________________________ |
6. Program Income
- Was the program designed to generate program income?
- Has there been any generated?
- What are your procedures for tracking/reporting/disbursing program income?
7. Resales/Foreclosures
- Have you had any resales or foreclosures in the past year?
- How were they handled?
- Did you have any recaptured funds?
PART III: HOME REQUIREMENTS FOR SPECIFIC PROJECT TYPES
B. MODERATE REHABILITATION OF RENTAL PROPERTY
- Income Eligibility/Targeting
Has the program met the requirement that 90 percent of units initially occupied after rehabilitation were occupied by households with incomes at or below 60 percent of median area income?
- Affordability Provisions
- What requirements were imposed to preserve the affordability of units?
- What legal documents were used?
- Rent Limitations/Leases
- Rent schedule used (date):
- Utility allowance schedule used (date):
- Are approved, standardized leases used?
- Per-Unit Costs
- Have you exceeded the DHCR $30,000 subsidy limitation?
- Were local cost limitations exceeded?
- Financing
a. Form(s) of assistance provided with HOME funds:
- Equity invested
- Amortizing Loans
- Deferred loans
- Grants
b. Is an owner match required?
c. Where have owners typically received financing? Have private lenders been formally involved, as through a leveraging agreement?
- Program Income
- Was the program designed to generate program income?
- Has there been any generated?
- What are your procedures for tracking/reporting/disbursing program income?
- Ongoing Compliance Monitoring
How do you monitor the project or ensure ongoing compliance with occupancy, rent and property standards?
PART III: HOME REQUIREMENTS FOR SPECIFIC PROJECT TYPES
C. HOME PURCHASE ASSISTANCE
- Income Eligibility/Targeting
a. Are specific types of households targeted (and included in selection criteria)?
b. Were the HOME income requirements a problem?
- Homebuyer Counseling
Is counseling provided for homebuyers participating in the program?
- Per-Unit Costs
a. Have you exceeded the DHCR $30,000 subsidy limitation?
b. Were local cost limitations exceeded?
- Property Valuation
What method was used for property valuation?
- Financing
a. Where have buyers typically received financing?
b. Have private lenders been formally involved, as through a leveraging agreement?
c. How do you qualify buyers and determine the amount of HOME subsidy and terms?
- Affordability Provisions
a. What resale/recapture method was selected to preserve affordability?
b. What legal documents were used/recorded?
c. Have any resales occurred? Any problems?
- Program Income
Was the program designed to generate program income?
Has there been any generated?
What are your procedures for tracking/reporting/disbursing program income?
- Resales/Foreclosures
Have you had any resales or foreclosures in the past year?
How were they handled?
Did you have any recaptured funds?
PART IV: OTHER REQUIREMENTS AND POLICIES
- Equal Opportunity/Fair Housing
- Do the policies for meeting equal opportunity and fair housing requirements correspond to those described in the HOME administrative plan?
- Have there been problems or complaints relating to equal opportunity or fair housing?
- Affirmative Marketing/MWBE Outreach
Have policies and procedures for affirmative marketing and minority- and women-owned business enterprise participation corresponded to those in the HOME administrative plan?
- Displacement/Relocation/Acquisition
- Have HOME activities resulted in tenant relocation?
- Did policies and procedures for assisting displaced persons correspond to those in the HOME administrative plan?
- Were any lower-income tenants displaced without benefits outlined in the written tenant assistance policy?
- Labor Standards
Did Davis-Bacon requirements apply?
Do records support compliance?
- Lead-Based Paint
Has the LPA adopted LBP procedures in compliance with the new rule?
- Have LPA staff received adequate training in:
LBP rules?
Safe Work Practices?
- Does the LPA have access to an adequate number of:
- Risk assessors (or visual assessors)?
- Interim control contractors?
- Abatement contractors?
- Clearance professionals?
- If rental properties, has the LPA ensured that owners are implementing ongoing maintenance procedures? Is the LPA conducting visual assessment as part of its rental property standards compliance monitoring?
- Are there any impediments to full implementation of the LBP rule for this program? What additional TA/training is needed?
- Environmental Review
- Is there an approved environmental review record for all HOME program sites?
- Have program sites triggered any of the following regulatory areas?
- Environmental quality
- Historic preservation
- ____________ Flood plain/wetlands
- Coastal zone management/waterfront
- ____________
- Other environmental issues _____________________________
- Scoring Factors
Compare the actual results of the program as implemented to date to what the applicant proposed originally. These are factors that affected the scoring and selection of this application. Compare the actual results to those proposed in the application. If the applicant had proposed what the program actually achieved, would the project still have been selected?
| Scoring Factor Item | Actual Results of the Program |
| Average HH income proposed | |
| Timetable proposed | |
| Target Area proposed | |
| Ave. Per Unit HOME Subsidy proposed | |
| Leverage of Other Funds proposed | |
PART V: PROJECT VISITS
- Project Address:
Identification number: __________________________
Number of units: ____________
HOME funding: $__________ Total cost: $__________
- Project type:
_____ Rehabilitation of owner-occupied housing
_____ Moderate rehabilitation of rental property
_____ First-time homebuyer assistance
_____ Tenant-based rental assistance
- Description of property and status of project:
- Are site observations consistent with data in the IDIS (with respect to level of completion)?
- Are site observations consistent with file materials? Does the construction or rehabilitation work reflect the scope as contained in the files and contract?
- (For projects underway or completed) Comment on the quality of the rehabilitation work.
- If pre-1978 property, is there evidence that LBP hazards were/are being addressed with proper methods?
- Is it reasonable to conclude that the unit meets HQS standards (or did so at the time improvements were done and the file inspection was completed, allowing for occupant changes since that time)? If a rental unit, does it currently meet HQS standards?
- (If time permits) Notes from interview with project owner or tenants to assess program satisfaction and verify income and rents information:
_________________________________________________________________________________
_________________________________________________________________________________
_________________________________________________________________________________
Last updated on 10/29/03
