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2/19/2019
1
SEMAP: Standing Up to an Audit
Teri Robertson
Learning Outcomes
Understand how to conduct required reviews leaving a
defensible audit trail
Purpose of SEMAP
Section Eight Management Assessment Program (SEMAP) was created to: Objectively measure key areas
Identify management capabilities/deficiencies
Improve HUD risk assessment for each problem identification
Provide self-assessment tool for PHAs
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Measuring PHA Performance Under SEMAP
PHA performance under SEMAP must be assessed annually
PHAs with less than 250 assisted units assessed and scored every other PHA fiscal year Unless PHA:
Elects to be assessed annually; or
Is designated as troubled
Percentage Score
Total points earned
Divide by total points that apply to your PHA
High performer 90%+
Standard performer 61-89%
Troubled performer 60% or less
Your goal
Ratings Based on CertificationRating for indicators 1-7 will initially be based
directly on what the PHA reports on its SEMAP certification
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Rating Profile
Waiting list 15Reasonable Rent 20Adjusted Income 20UA Schedule 5HQS QC 5HQS Enforcement 10Expanding Housing 5
Subject tomodification, based on audit
Comes from PHA certification
Rating Profile
Payment Standards 5 FOAnnual Rexaminations 10 PICCorrect Tenant Rent 5 PICPrecontract HQS 5 PICAnnual HQS 10 PIC Lease up 20 VMS FSS 10 FO/PIC
Prepare,Prepare,Prepare
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Audit Files
Make up 15 (plus bonus if applicable) “file folders” 1 general file folder
Random methodology
1 file folder for each indicator
Remember, you want PROOF
Internal Audit Files
Description of indicator and performance standard
Place data from audit for each indicator reviewed
Any other “proof” of certification score
Use auditor minimum file sample and increase sample if needed
Internal Audit Files
Use a uniform data systemCaptures dataCalculates the score Leaves an audit trail Displays the data reviewedShows results
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Internal Audit Files
Contact me via email, and I will send you NMA’s SEMAP toolJust tell me what your FYE is (4
versions)Teri@nanmckay.com
PHA Supervisory
Audits
Supervisory QC Reviews
Annual samples of files Drawn in unbiased manner (leave clear audit trail)
Supervisor or other qualified person other than the one who did the work
Objective is to determine compliance with indicator
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1st 7 SEMAP Indicators
Selection from Waiting List* 15
Reasonable Rent* 20
Determination of Adjusted Income* 20
Utility Allowance Schedule 5
HQS Quality Control Inspections* 5
HQS Enforcement* 10
Expanding Housing Opportunities 5
*indicates PHA audit needed
Size of Universe
Size of UniverseSelection from the Waiting List
Where the universe is: The number of admissions in the last year for each of
the two quality control samples under the SEMAP indicator at 985.3(a) Selection from the Waiting List;
Data source: software report showing new admissions
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Size of UniverseRent Reasonable and Adjusted Income
Where the universe is: The number of families assisted for the
SEMAP indicators at 985.3(b) Reasonable Rent, and 985.3(c) Determination of Adjusted Income; Number of families assisted as of FYE, plus
number of families that EOP’d during the year, plus number of families that ported out and were absorbed during FY
Size of UniverseHQS Quality Control
Where the universe is: The number of units under HAP contract during the
last completed PHA fiscal year for the SEMAP indicator at 985.3(e) HQS Quality Control Inspections;
Number of families assisted as of FYE plus number of families that EOP’d during FY, plus number of families that ported out and were absorbed, plus moves
Size of UniverseHQS Enforcement
Where the universe is: And the number of failed HQS inspections in the last
year for the SEMAP indicator at 985.3(f) HQS Enforcement
Documentation showing number of failed HQS during FY for units under contract
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Audit Sample Selection
50 or less
51-600
601-2000
Over 2000
55 + 1 for each 50 (or part of 50) over 50
16 + 1 for each 100 (or part)over 600
30 + 1 for each 200 (or part)over 2000
Random File Selection
File Sampling
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File Sampling
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Print before you click ‘Get Sets’ to retain for
your audit trail
File Sampling
Print before you click ‘Get Sets’ to retain for
your audit trail
Random Sampling Audit Trail
State in your overview folder: PHA uses Random.org to randomly select records for
review
Retain a copy of the Random.org request and the Random.org results
Print your record list, number each record
Circle each record selected by Random.org
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Random Sampling Audit Trail
In the folder dedicated to the indicator under review, retain: Two Random.org printouts
Printed list with selected families notated
Random Sampling Example
If you must select a replacement family: Notate next to the selected record why Randomly select replacement from random.org,
printing the random.org pages File
Notate replacement family name next to original family Notate original family name next to replacement
family
Random Sampling ExampleHQS Abatement 1. Tom Smith2. George Watson3. Mary Long No qualifying event
during FY; Alexis Trevor selected to replace
4. Melissa Roberts5. Keira Ashley6. Ali Quinn7. Alexis Trevor replacement for Mary
Long8. Amy Cameron9. Sam Daniels10. Joe Michaels
Record 3 was originally selected for review No qualifying
event
Record 7 was selected as the replacement
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Conducting Reviews Conducting
Reviews
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Random Sampling Example NMA tool calculates ytd score as data is entered
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Random Sampling Example 6/30 FYE PHA
Each month, enter in
reporting rates from IMS/PIC SEMAP module
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Random Sampling Example For indicators scored by IMS/PIC, PHA enters
that data on indicator page
Tool calculates score, moves to Summary page
Random Sampling Example
Sheets for: Annual reexams Correct Tenant Rent PreContract HQS Continuing HQS FSS
Lease-up data is entered by PHA on its indicator page, based on VMS entries
Random Sampling Example
PHA then conducts reviews for required indicators
Using spreadsheets ensures complete records are kept
Retains the data on a network drive Maintain the source documents in a book, or scan into
system
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Random Sampling Example
NMA tools were developed to ensure consistency in approach, as well as to provide a solid audit trail
We are using our sheets as examples on how to create defensible records You may create your own or use ours
Not our intent to cover each indicator in depth Feel free to approach me after session
1. Selection from theWaiting List
PHAs must have written selection policies in administrative plan
At least 98% of families must be selected from the waiting list in accordance with the PHA’s policies
1. Selection from Waiting List Selection
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1. Selection from Waiting List Admissions
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1. Selection from Waiting List Combined
1. Selection from Waiting ListMust score 98% in each of the two
samplings
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1. Selection from the Waiting List
Records in book Copy of selection policies from admin plan
If policy changed during FY, retain all Be sure eff dates of changes are clear
Copy of report showing all admissions Random.org selection record
Records from each WL selection Application/updates for each file reviewed
2. Reasonable Rent
PHA must follow its written method
Document determination that the rent to owner is reasonable at required times Initial leasing of a unit Any increase in rent to owner 10% decrease in the FMR in effect 60 days before
HAPC anniversary date
Points
20 points
15 points
0 points
Documentation for 98% of files selected
Documentation for 80-97% of files
Neither statement is true
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2. Reasonable Rent
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2. Reasonable RentRecords in book Copy of rent reasonableness policies from Admin Plan
If policy changed during FY, retain all Be sure eff dates of changes are clear
Copy of report showing all assisted families Random.org selection record
Records from each RR determination
3. Determination of Adjusted Income
At admission and reexamination, the PHA must properly: Obtain third party verification of income or
document why impossible to obtain Use the verified information Properly attribute allowances for expenses Use the appropriate utility allowances
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Points
20 points
15 points
0 points
Documentation for 90% of files selected
Documentation for 80-89% of files
Neither statement is true
3. Determination of Adjusted Income
NMA uses a different spreadsheet to conduct reviews
Results are captured on SEMAP sheet PHA conducted 25 reviews; 1 file failed
3. Determination of Adjusted Income
Records in book Copy of calculation/verification policies Copy of report showing all assisted families
Random.org selection record
50058s, family declaration, verifications Utility allowance schedules
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4. Utility Allowance Schedule PHA has reviewed utility rate data within prior 12
months
PHA has adjusted schedule if 10%+ change in rate since last utility allowance schedule revision
Points
5 points Yes
0 points No
4. Utility Allowance Schedule Each time UA is updated, complete the SEMAP
sheet for that indicator
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4. Utility Allowance ScheduleRecords in book Copy of utility allowance schedule
This year Last year
Proof of required study
5. HQS Quality Control Inspections
PHA performs QC inspection of units under contract (according to HUD audit guide)
Sampling drawn from: Recently completed inspections Cross section of neighborhoods Work of cross section of inspectors
Points
5 points Yes, to both statements
0 points No
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5. HQS QC Inspections
5. HQS QC InspectionsRecords in book Signed HQS QC inspection form Documentation showing discrepancies were
discussed Can just notate QC inspection form
6. HQS Enforcement
Universe Number of HQS fails in previous PHA FY
Sample drawn from Units under contract that fail HQS
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6. HQS Enforcement
PHA must ensure that when a unit fails an HQS inspection : Any life-threatening deficiencies are corrected
within 24 hours, and All other HQS deficiencies are corrected within no
more than 30 calendar days
Or PHA-approved time extension
6. HQS Enforcement
If HQS deficiencies are not corrected within the required time frame, PHA must: Owner responsibility
Stop (abate) housing assistance payments no later than the first of the month following the specified correction period, or terminates the HAP contract
Family responsibility Take prompt and vigorous action to enforce family
obligations
HQS Enforcement Supervisory Audit
All life threatening fails corrected within 24 hrs, and
98% of other fails corrected within 30 days or PHA-approved extension or PHA took action Owner fails: abated HAP Family fails: enforced family obligations
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HQS EnforcementScoring
1. Determine universe
2. Run/obtain report of all HQS fails
3. Capture whether 24 hour or non-24 hour One HQS failure can have both
4. Capture whether owner-caused or family-caused One HQS failure can be both
HQS EnforcementScoring
5. For each HQS unit audited, determine: Corrected as of reinspection? Y/N Verified corrected prior to effective date of
negative action? Y/N* Abated/enforced family obligations timely? Y/N If Yes to one of the above, passes indicator
HQS EnforcementScoring
Verified corrected prior to effective date of negative action? Y/N* BUT you did mail out intent to terminate/abated You have actually rescinded the action because the
unit passed before effective date of negative action
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Points
10 points Yes, met criteria
0 points No, didn’t meet criteria
6. HQS Enforcement
6. HQS EnforcementRecords in book Copy of policies from admin plan Copy of report showing failed inspections
Random.org selection record
Document showing Unit passed reinspection Abatement/family obligations enforced
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7. Expanding Housing Opportunities (MSAs only)
A. Written policy to encourage owner participation outside areas of poverty or minority concentration
Documentation shows PHA followed policy
Expanding Housing Opportunities
PHA has created a briefing packet (e.g. maps, job opportunities, schools and other services in the areas) to encourage voucher holders to seek these opportunities
Expanding Housing Opportunities
Information packet has: List of owners willing to lease Other organizations (housing counseling, advocacy
groups, service providers) which assist families in finding units
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Expanding Housing Opportunities
Information packet explains portability and provides list of contacts at neighboring PHAs Name Address Phone
Expanding Housing Opportunities
PHA has analyzed: Difficulties of voucher holders finding units in these
areas If so, has analyzed
Whether to seek approval of exception payment standards Sought approval for exception payment standards if
needed
Points
5 points Yes to all statements
0 points Audit report does not support statements
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Expanding Housing Opportunities
Complete a checklist; retain source docs in book
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8. Payment Standards
The PHA must adopt payment standards By unit size For each FMR/SAFMR area in the PHA jurisdiction Between 90-110% of the HUD-published
FMR/SAFMR If applicable, for each PHA-designated part of an
FMR area
Points
5 points
0 points
98% of newly leased units are within the basic range
Statement is not true
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8. Payment Standards Update the spreadsheet each time PS is
changedCalculates the percentage of FMRRetain hard copy schedules and a print of
FMR webpage in book
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Closing
PHAs should ensure their SEMAP documentation “tells the story”
Any auditor should be able to review records and understand how score was calculated without having to ask questions
Closing
Be sure your records will withstand an audit Clear Complete Comprehensive
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