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HomeMy WebLinkAbout21. 18-592 DECEMBER 11, 2018 18-592 RESOLUTION (CARRIED 7-0 LOST LAID OVER WITHDRAWN ) PURPOSE: APPROVE RECOVERY AGREEMENT BETWEEN OSHKOSH HOUSING AUTHORITY, THE UNITED STATES DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT AND THE CITY OF OSHKOSH INITIATED BY: OSHKOSH HOUSING AUTHORITY BE IT RESOLVED by the Common Council of the City of Oshkosh that the attached Recovery Agreement between the Oshkosh Housing Authority, the United States Department of Housing and Urban Development and the City of Oshkosh is hereby approved and the proper City officials are hereby authorized to execute and deliver the agreement in substantially the same form as attached hereto, any changes in the execution copy being deemed approved by their respective signatures, and said City officials are authorized and directed to take those steps necessary to implement the terms and conditions of the Agreement. TO: Mayor and Members of the Common Council FROM: Lynn A. Lorenson, City Attorney DATE: December 6, 2018 RE: Approve Recovery Agreement between Oshkosh Housing Authority, the United States Department of Housing and Urban Development and the City of Oshkosh BACKGROUND The Oshkosh Housing Authority is audited and regulated through the United States Department of Housing and Urban Development (HUD). HUD uses a method of evaluating public housing performance called the Public Housing Assessment System (PHAS). Under this system HUD evaluates what they term AMPS (Asset Management Projects). Under the PHAS system, Housing Authorities are expected to reach a minimum score of at least 60. In 2016, due to a number of factors the Oshkosh Housing Authority scored 57 and under HUD rules must now enter into a Recovery Agreement to establish performance targets, set strategies for meeting these targets, provide incentives for effective implementation and sanctions for failure to meet implementation goals all leading to the recovery of performance by the Authority financially. Because Housing Authorities in Wisconsin are created by the City and the City appoints the governing body, the City is required to also be a party to this Agreement. Attached to this memorandum is a memorandum from Susan van Houwelingen, Executive Director of the Oshkosh Housing Authority which provides greater detail on the scoring and the commitment of the Housing Authority to address the concerns raised by HUD. ANALYSIS The City of Oshkosh is required to be a party to the Agreement as the appointing authority for the governing Housing Authority Board. The agreement in most places references only obligations of the Housing Authority, but the last paragraph references the City as follows: City Hall, 215 Church Avenue P.O. Box 1130 Oshkosh, WI 54903-1130 920.236.5000 http://www.ci.oshkosh.wi.us The City of Oshkosh, through its Appointing Authority, acknowledges the importance of effective governance as part of the recovery and sustainability of the Oshkosh Housing Authority. As a signatory of this Agreement, the City of Oshkosh commits to oversee and monitor its duly appointed agents, the appointees to the Oshkosh Housing Authority Governing Board, in the discharge of their duties. Upon the discovery of any failure of the Oshkosh Housing Authority Board to discharge its duties under this Agreement, the City of Oshkosh will take all necessary steps to correct the Board's actions or omissions and ensure compliance with the terms of this Agreement. In discussions with Diane Schultz, HUD's program specialist assigned to the Oshkosh Housing Authority, HUD's expectation would be that if a public housing authority board of commissioners would not be performing its responsibility over the public housing authority related to governance and fiduciary oversite, that the City would be requested to step in to discuss these issues with the public housing authority board of commissioners or in extreme circumstances to remove a commissioner or commissioners and appoint new commissioners. Ms. Schultz also emphasized that these are not common interventions and that she has no reason to believe that this will be required in this case. FISCAL IMPACT There is no anticipated fiscal impact to the City of Oshkosh from this Agreement. RECOMMENDATION Staff recommends adoption of the resolution and approval of the Agreement to allow the Oshkosh Housing Authority to proceed with the Recovery Plan. Respectfully Submitted, jyyA. Lorenson City Attorney Approved: Mark A. Rohloff City Manager City Hall, 215 Church Avenue P.O. Box 1130 Oshkosh, WI 54903-1130 920.236.5000 http://www.ci.oshkosh.wi.us Oshkosh' Winnebago County Housing Authority November 5, 2018 Oshkosh Housing Authority Winnebago County Housing Authority 600 Merritt Avenue -• Oshkosh, Wl 0 i' (920) 424-1474 www.ohawcha.org ' bago • '.. • ! To: Oshkosh City Council: ,ikMA, �HOMEBUYER PROGRAM - Subject: Explanation of Public Housing Assessment System and Recovery Agreement for 2016 Status Determination The Oshkosh Housing Authority is audited and regulated through the United States Department of Housing and Urban Development (HUD). HUD uses a method of evaluating public housing performance called the Public Housing Assessment System (PHAS). Under this system HUD evaluates what they term AMPS (Asset Management Projects). Under the PHAS system, Housing Authorities are expected to reach a minimum score of at least 60. The Oshkosh Housing Authority is comprised of: 70 scattered site units which are designated AMP 3, Tower Redevelopment LLC which is designated AMP 6, Tower Redevelopment Phase II, LLC which is designated AMP 7, and Raulf Place Redevelopment, LLC which is designated AMP 9. All of these AMP's are under the public housing HUD program and receive HUD funding to assist with operations and capital needs of the properties. The Oshkosh Housing Authority has completed renovations of Court Tower and Raulf Place using mixed financing which required these properties to be purchased by limited liability companies with the Housing Authority still having a percent ownership. Using this method of financing and ownership removed these properties from HUD's Public Housing Assessment System (PHAS) and they do not receive a PHAS score. Prior to these properties being removed from the PHAS scoring, Oshkosh Housing Authority Public Housing properties typically scored in the 80 percentile range. With the changes in ownership to the renovated properties only the Oshkosh Scattered Sites (AMP 3) were scored in 2016. The resulting PHAS score was 57. Had Court Tower and Raulf Place remained included, the score would be in the 80 percentile range. So out of 471 units owned and managed by the Oshkosh Housing Authority; 278 public housing units and 193 multi -family units; HUD Public Housing has deemed OHA troubled based on only those 70 AMP 3 units of public housing. Public Housing units are scored in four areas: 1) Physical Assessment Subsystem or PASS 2) Management Assessment Subsystem or MASS; 3) Financial Assessment Subsystem (FASS); and 4) Capital Fund Program or CFP. The biggest point reduction in the PHAS scoring was FASS. There were not enough current assets at the end of 2016 to receive any points in FASS scoring. The two main causes of less than adequate current assets are that HUD is not funding any of the public housing programs at full eligible funding; and that Oshkosh Housing Authority carried a higher than a HUD desirable tenant account receivable ratio. In this regard, it is important to note that this ratio was 2% of the total tenant revenue and represented our Agency's attempts to assist families struggling to make ends meet by allowing signed payment plans with residents. The AMP 3 - 70 units also lost points for 95% occupancy. To gain all points in the MASS scoring the project must average 97% or higher for the year. Because of the lower score for 2016, the Housing Authority is required to enter into a Recovery Agreement with HUD. Because in Wisconsin Housing Authorities are created by the City and the City appoints the governing body, the City is required to also be a party to this Agreement. The purpose of the Agreement is to establish performance targets, set our strategies for meeting these targets, provide incentives for effective implementation and sanctions for failure to meet implementation goals all leading to the recovery of performance by the Authority financially. While I do not wish to minimize the designation received or the importance of the Recovery Agreement, as you know, I am Executive Director for Oshkosh Housing Authority and Winnebago County Housing Authority (WCHA) for combined management of over 1100 families being housed. Out of 471 units owned and managed by the Oshkosh Housing Authority; 278 public housing units and 193 multi -family units; HUD Public Housing has deemed OHA troubled based on only 70 AMP 3 units of public housing. It is only these AMP 3 -70 units that the Troubled Agency Status is directed toward. The Agency has not yet received the completed HUD PHAS score for 2017, however our FASS score for 2017 was 20 points, so that alone will raise our score to 77 points. The Housing Authority staff and Oshkosh Housing Authority Board are committed to the effective, efficient and financially sound management of the Housing Authority and all its properties. Going forward the agency will use more Capital Fund Operational dollars and even some of the agency's nonfederal dollars to support the AMP 3 -70 units, if necessary. If you have any questions feel free to contact me at suv@ohawcha.org, 920-424-1470 x112 office, 920- 642-3480 cell phone. Thank you, Susan van Houwelingen Executive Director Cc: Oshkosh Housing Authority Board Nicholas Hahn — Chair Julie Spanbauer— Vice Chair Sara Muhlbauer Tom Pech Rob Paterson Oshkosh ° Winnebago County Housing Authority November 5, 2018 Oshkosh Housing Authority Winnebago County Housing Authority 600 Merritt Avenue RO. Box Oshkosh, 54903-0397 i A. (920) 424-1474 www.ohawcha.org - wwwwinnebagohomebuyer.ol To: Oshkosh City Council: 4■ ;I • HOMEBUYER PROGRAM+ Subject: Explanation of Public Housing Assessment System and Recovery Agreement for 2016 Status Determination The Oshkosh Housing Authority is audited and regulated through the United States Department of Housing and Urban Development (HUD). HUD uses a method of evaluating public housing performance called the Public Housing Assessment System (PHAS). Under this system HUD evaluates what they term AMPS (Asset Management Projects). Under the PHAS system, Housing Authorities are expected to reach a minimum score of at least 60. The Oshkosh Housing Authority is comprised of: 70 scattered site units which are designated AMP 3, Tower Redevelopment LLC which is designated AMP 6, Tower Redevelopment Phase It, LLC which is designated AMP 7, and Raulf Place Redevelopment, LLC which is designated AMP 9. All of these AMP's are under the public housing HUD program and receive HUD funding to assist with operations and capital needs of the properties. The Oshkosh Housing Authority has completed renovations of Court Tower and Raulf Place using mixed financing which required these properties to be purchased by limited liability companies with the Housing Authority still having a percent ownership. Using this method of financing and ownership removed these properties from HUD's Public Housing Assessment System (PHAS) and they do not receive a PHAS score. Prior to these properties being removed from the PHAS scoring, Oshkosh Housing Authority Public Housing properties typically scored in the 80 percentile range. With the changes in ownership to the renovated properties only the Oshkosh Scattered Sites (AMP 3) were scored in 2016. The resulting PHAS score was 57. Had Court Tower and Raulf Place remained included, the score would be in the 80 percentile range. So out of 471 units owned and managed by the Oshkosh Housing Authority; 278 public housing units and 193 multi -family units; HUD Public Housing has deemed OHA troubled based on only those 70 AMP 3 units of public housing. Public Housing units are scored in four areas: 1) Physical Assessment Subsystem or PASS 2) Management Assessment Subsystem or MASS; 3) Financial Assessment Subsystem (FASS); and 4) Capital Fund Program or CFP. The biggest point reduction in the PHAS scoring was FASS. There were not enough current assets at the end of 2016 to receive any points in FASS scoring. The two main causes of less than adequate current assets are that HUD is not funding any of the public housing programs at full eligible funding; and that Oshkosh Housing Authority carried a higher than a HUD desirable tenant account receivable ratio. In this regard, it is important to note that this ratio was 2% of the total tenant revenue and represented our Agency's attempts to assist families struggling to make ends meet by allowing signed payment plans with residents. The AMP 3 - 70 units also lost points for 95°l occupancy. To gain all points in the MASS scoring the project must average 97% or higher for the year. Because of the lower score for 2016, the Housing Authority is required to enter into a Recovery Agreement with HUD. Because in Wisconsin Housing Authorities are created by the City and the City appoints the governing body, the City is required to also be a party to this Agreement. The purpose of the Agreement is to establish performance targets, set our strategies for meeting these targets, provide incentives for effective implementation and sanctions for failure to meet implementation goals all leading to the recovery of performance by the Authority financially. While I do not wish to minimize the designation received or the importance of the Recovery Agreement, as you know, I am Executive Director for Oshkosh Housing Authority and Winnebago County Housing Authority (WCHA) for combined management of over 1100 families being housed. Out of 471 units owned and managed by the Oshkosh Housing Authority; 278 public housing units and 193 multi -family units; HUD Public Housing has deemed OHA troubled based on only 70 AMP 3 units of public housing. It is only these AMP 3 -70 units that the Troubled Agency Status is directed toward. The Agency has not yet received the completed HUD PHAS score for 2017, however our FASS score for 2017 was 20 points, so that alone will raise our score to 77 points. The Housing Authority staff and Oshkosh Housing Authority Board are committed to the effective, efficient and financially sound management of the Housing Authority and all its properties. Going forward the agency will use more Capital Fund Operational dollars and even some of the agency's nonfederal dollars to support the AMP 3 -70 units, if necessary. If you have any questions feel free to contact me at suv@ohawcha.org, 920-424-1470 x112 office, 920- 642-3480 cell phone. Thank you, Susan van Houwelingen Executive Director Cc: Oshkosh Housing Authority Board Nicholas Hahn —Chair Julie Spanbauer—Vice Chair Sara Muhlbauer Tom Pech Rob Paterson Recovery Agreement between Oshkosh Housing Authority And the United States Department of Housing and Urban Development And the City of Oshkosh This Recovery Agreement is entered into between the Oshkosh Housing Authority, the UNITED STATES DEPARMENT OF HOUSING AND URBAN DEVELOPMENT ("HUD") and the City of Oshkosh as of this day of RECITALS 2018. WHEREAS, under the United States Housing Act of 1937, as amended, ("Act"), 42 U.S.C. § 1437 et seq., the United States Department of Housing and Urban Development ("HUD") is responsible for administering low income housing programs, and pursuant to the Act, HUD has entered into an Annual Contributions Contract ("ACC") with the Oshkosh Hous- ing Authority to develop and operate public housing projects of the Oshkosh Housing Authority; and WHEREAS, pursuant to the Act, HUD must evaluate public housing performance and has instituted the Public Housing Assessment System ("PHAS"); and WHEREAS, on the basis of an annual PHAS score, the Oshkosh Housing Authority has been designated Troubled for financial, physical and/or management indicators, or other such deficiencies as HUD has identified; and WHEREAS, the Act requires HUD to enter into agreements that establish performance targets, set out strategies for meeting targets, provide for incentives and sanctions for effective implementation of the strategies leading to recovery of performance and attain an improved sta- tus of at least a Standard Performer; and WHEREAS, the recovery of performance is intended to lead to a sustainable sound fiscal management and good governance; and WHEREAS, the parties desire to correct all HUD -identified deficiencies through the im- plementation of this Recovery Agreement, ("Agreement"); NOW THEREFORE, in consideration of the mutual covenants and agreements herein contained, HUD, the Oshkosh Housing Authority and the City of Oshkosh agree as follows: I. The Oshkosh Housing Authority agrees to achieve the outcomes outlined in the Action Plan and incorporated into this Agreement as Exhibit A. II. The Oshkosh Housing Authority and the City of Oshkosh agree to work together to de- velop and implement a Sustainability Plan if necessary to achieve recovery. III. The Action Plan describes the results following HUD's review and assessments of PHA performance, the measures that need to be implemented to improve the performance and the desired outcomes to be achieved and establishes a timetable to achieve those out- comes. The Action Plan also identifies the available remedies to resolve HUD's determi- nation of non-performance. IV. Upon execution of the Agreement, the Oshkosh Housing Authority will commence with the required actions listed in the Plan within the timeframes set forth therein. V. The Oshkosh Housing Authority will cure identified deficiencies within the timeframes established in the Action Plan. VI. Subject to section XII, regardless of possible changes in the Oshkosh Housing Authori- ty's Board composition, or the decision-making individuals for HUD or the City of Osh- kosh, the term of this Agreement is effective as of the execution date of this document and will continue until completion of the Action Plan in accordance with 60) (2) and (3) of the Act, and any agreed upon extensions. This Agreement will remain in effect until the Oshkosh Housing Authority has completed all items listed in the Plan, even if HUD removes the Oshkosh Housing Authority's troubled/substandard designation. VII. HUD, in its discretion, may provide technical assistance, including training or contract support, to the Oshkosh Housing Authority to facilitate accomplishment of the items in the Action Plan. The Oshkosh Housing Authority's compliance with the Action Plan, however, shall not be contingent on HUD's provision of any technical assistance or other discretionary assistance. VIII. The Oshkosh Housing Authority shall provide HUD with written progress reports as identified in the Action Plan. The report shall detail the Oshkosh Housing Authority's progress towards the completion of the items required by the Action Plan. The reports shall identify those items that have been completed and provide any necessary documen- tation to support this determination. IX. HUD will review the Action Plan progress reports submitted by the Oshkosh Housing Authority and supporting documentation. HUD will confirm in writing to the Oshkosh Housing Authority the items that HUD determines to have been successfully completed, those that require additional documentation and those that are past due. X. If the Oshkosh Housing Authority disagrees with HUD's determination concerning the completion of any item, the Oshkosh Housing Authority may request a reconsideration of the determination and submit additional information to support its position. HUD will provide the Oshkosh Housing Authority with a written notice of its decision. XI. The failure of the Oshkosh Housing Authority, its employees, officers, agents, or contrac- tors to comply with this Agreement, including the failure to achieve the agreed upon out- comes or to take the actions or comply with the time frame set forth in the Action Plan, Recovery Agreement—November 2018 Page 2 may result in HUD seeking any available remedies, including any of the following ac- tions sequentially or simultaneously: a. Consolidation; b. Consortia/Joint Venture; c. Contraction of Operational Activities; d. Cooperative Endeavor Agreement; e. Debarment; f. Deliver possession and control of project(s) to HUD; g. Limited Denial of Participation; h. Receivership; and/or i. Suspension. XII. The parties by mutual written agreement may agree to extend the timeframes set forth in the Action Plan from time to time. In the event said timeframes are extended, HUD agrees that it will not take any of the actions against the Oshkosh Housing Authority as set forth in this section of the Agreement for noncompliance with original timeframes. XIII. Communication related to the Recovery Agreement and Action Plan shall be provided to the Public Housing Director and the HUD Recovery Team leader, if applicable. XIV. HUD, the Oshkosh Housing Authority and their employees, subcontractors, partners or assigns, and the City of Oshkosh shall comply with all applicable federal, state, and local laws and regulations relating to the performance of this Agreement to which their activi- ties are subject. XV. Notwithstanding any provisions of this Agreement to the contrary, the parties shall not be held liable for any failure or delay in the performance of this Agreement that arises from fires, floods, strikes, embargoes, acts of the public enemy, unusually severe weather, out- break of war, riots, civil commotion, force majeure, acts of God, or for any other cause of same character which is unavoidable through the exercise of due care and beyond the control of the parties, provided that said failure or delay in the performance of this Agreement attributed to any of the events described herein is acknowledged in writing by HUD. Upon the issuance of HUD's written acknowledgement, the failure to perform shall be deemed excused during the continuance of such circumstances as determined by HUD, but this Agreement shall otherwise remain in effect. XVI. In the event of any conflict between terms in this Agreement, including all exhibits, attachments and all other documents specifically incorporated by reference, and HUD's applicable Public Housing requirements including, but not limited to, the Act, HUD regu- lations there under (and; to the extent applicable, any HUD -approved waivers of regulato- ry requirements), the ACC, HUD notices, the HUD -approved Declaration of Trust or Recovery Agreement—November 2018 Page 3 Declaration of Restrictive Covenants in favor of HUD, and all applicable Federal statuto- ry, executive order and regulatory requirements, as those requirements may be amended from time to time, the applicable Public Housing requirements shall prevail. HUD re- serves the right to resolve any conflict. XVII. Any modification or amendment of any condition or provision in this Agreement by ei- ther party will not imply or constitute a further modification or amendment of the same or any other condition or provision, nor shall it relieve the parties from performing any sub- sequent obligations strictly in accordance with the term of this Agreement. No modifica- tion or amendment shall be effective unless in writing and signed by the party against whom enforcement is sought. Such modification or amendment shall be limited to provi- sions of this Agreement specifically referred to therein and shall not be deemed a modifi- cation or amendment of any other provision. No modification or amendment of this Agreement shall constitute a HUD -approved waiver of regulatory requirements. XVIII. Should any term or provision of this Agreement be held, to any extent invalid or unen- forceable, as against any person, entity or circumstance during the term hereof, by force of any statute, law, or ruling of any forum of competent jurisdiction, such invalidity shall not affect any other term or provision of this Agreement to the extent that the Agreement shall remain operable, enforceable and in full force and effect to the extent permitted by law. XIX. To the extent authorized by the Act and HUD regulations, HUD can unilaterally amend this Agreement. Otherwise, this agreement may be amended by mutual agreement of the parties. XX. This Agreement states the entire understanding and agreement between the parties and supersedes any and all written or oral representations, statements, negotiations, or agree- ments previously existing between the parties with respect to the subject matter of this Agreement. However, this Agreement does not supersede, modify or amend the ACC as further described in Paragraph XXII. The parties recognize that any representations, statements or negotiations made by the staff of either party does not suffice to legally bind either party in a contractual relationship unless they have been reduced to writing and signed by their authorized representative(s). This Agreement shall inure to the bene- fit of and shall be binding upon the parties, their respective assigns, and successors in in- terest. XXI. This Agreement may be executed and delivered in separate counterparts, which, when so executed and delivered, shall be deemed an original. XXII. This Agreement does not supersede, modify or amend the ACC between HUD and the Oshkosh Housing Authority, or in any way excuse the Oshkosh Housing Authority from complying fully with its obligations under the ACC. HUD does not waive its statutory, regulatory or contractual rights. Nothing contained in this Agreement shall serve to limit, modify or preclude HUD's right to take any remedial action allowed by the ACC or any provision of the Act or related regulations. Nothing contained in this Agreement shall Recovery Agreement—November 2018 Page 4 serve to limit, modify or preclude HUD or the Oshkosh Housing Authority's right to take any remedial action allowed by the Agreement. XXIII. The parties agree that any cost associated with the implementation of this Agreement, the Action Plan and the Sustainability Plan shall be their individual responsibility unless spe- cifically agreed in writing between the parties. XXIV. The City of Oshkosh, through its Appointing Authority, acknowledges the importance of effective governance as part of the recovery and sustainability of the Oshkosh Housing Authority. As a signatory of this Agreement, the City of Oshkosh commits to oversee and monitor its duly appointed agents, the appointees to the Oshkosh Housing Authority Governing Board, in the discharge of their duties. Upon the discovery of any failure of the Oshkosh Housing Authority Board to discharge its duties under this Agreement, the City of Oshkosh will take all necessary steps to correct the Board's actions or omissions and ensure compliance with the terms of this Agreement. IN WITNESS WHEREOF, the parties or their duly authorized representatives hereby ex- ecute this Agreement on the date first written above. UNITED STATES DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Shirley Wong Public Housing Director Milwaukee Field Office Oshkosh Housing Authority ATTEST: BY ITS BOARD OF COMMISSIONERS By: Nicholas Flffm- Board Chair Oshkosh Housing Authority By: L - Susan van Houwelingen Executive Director Oshkosh Housing Authority By: Mark Rohloff City Manager City of Oshkosh Recovery Agreement—November 2018 Page S Page 1 A B C D E F G IT J K 1 2 Recovery Agreement Action Plan Between Oshkosh Housing Authority and HUD 3 Item Results and Determinations Statutory Measurement Target Actual tB.,alineData and PHAS Score Number from AssessmentRequired Desired Outcome Accom Nshmenf PP Accom hshment Remedies 7Comments!Accom Ilshmenls P4 s of 613012016 PHAS Score Date Date 5 AREA: W ERNANCE G001 In progress -- OHA has not submitted a Troubled The Board becomes more aware of OHA'e Troubled Status Agency PHAThe last submitted Five Yeearar PHA Plan was and the acgons OHA is taking to recover from Troubled 11/512018 OHA must submit a Troubled Agency PHA Plan to HUD. January 1, 2015. Status. 6 G002 F Will submit revised ACOP & related policies with 0003, 6 1st response to HUD. Will submit self - G004 OHA must update Its Admissions and certifcations of annual updates to HUDI. Will Continued Occupancy Policy and associated policies to be in PHA policies are in compliance ith HUD regulations end submit to HUD self certficiations of Board and compliance with HUD regulations reququiremremenle. Submitted ACOP and related pegq revisions to HUD. Staff training. In 2018 have started Board training and requirement.. through LEAD THE WAY training resource from OHA Implements an annual schedule The Board and sten are involved In updating the ACOP and HUD. lo update the ACOP and associated related policies. 11312018 Submittal of annual update schedule. PHA self - policies. certification to follow schedule to HUD. OHA must train the Board and staff The Board and staff are aware of the updated ACOP and on the updated ACOP and related policies, Submittal of board and stars training PHA selfceNficaBon associated policies. to HUD. 7 G006 OHA has several weak internal In 2014 E.D. rec'd permission from HUD to use controls including allowing the one signatory as safer than Executive Director to be the sole OHA must revise its Financial Policy to include increased machine stamped signatory on checks with no counter internal controls and to reduce overall risk to the agency. 11312019 submittal of revised Financial Policy to HUD, signatures. Have removed from audit segregation signature and no general purchase of duties find in audit per SVA. Will revise the limit for elan purchases. financial policy to include new process. e G007 OHA did not write off its tenant account receivable prior to the end of OHA must revise its Financial Policy to oulline its write orf of This was done and have backup dOCDmentatl0n fiscal year 12131/16. bad debt procedures 11312019 Submittal of revised Financial Policy to HUD, showing completion in 2016. s 1 o AHE RNIANCE,m OHA must reduce the HUD allowed management fee earned by the Central Office Cost Center to assist in reducing Based on the most recent approved FDS expenses. data submission, the Housing Authoritys OHA must achieve a MENAR of 4 or greater based on FDS OHA did not implement all corrective current Financial Condition is shown Schedule for FYE 121312019. actions in the PHARS Troubled below. A Quick Ratio of less than one Status Response and Action Plan (1) indicates current liabilities could not OHA increases its Months Expendable Monthly financial reports must be submitted to HUD (dated 727117) ORA must keep in place the reduced bookkeeping fee in an be paid If they immediately became due. Net Asset. Raso (MENAR) to 4.0. evidencing reduced COCC management and bookkeeping effort to reduce operating costs for AMP 003. A MENAR of less than (1) indicates that fee.. Agency has reduced mgmt fees. Agency will Fool, F004, OHA must continuethe practices OHA must keep the reduction of the part-Bme maintenance there are no financial reserves available. 12/312019 On 711712018, OHA requested a budget line adjustment to dispute with HUD the reduction of a 112 time F005 ouginadinthe PHARSTroubled person in place in an effort to reduce operagngcosts for AMP 003 InorderloachieveaMENARo14.0, increase Budget Line Item to percent osition.Bud et line item will be added to the P g Status Response end Action Plan AMP 003. Housing Authority must Increase its net OHA must include this request in their 2019CFP budget as tin their CFP 2019 budget for Capital Fund operations. dated 727/17 to Increase its net ( ) Current Quick Rego: 0.84 available unrestricted assets or reduce its monthly operating expenses by a well after consideration of debt service, significant capital available unrestricted assets or OHA must for any shortfall for operating utilize Capital Fund Cunent MENAR: -0,36 needs, and emergency needs. reduce its monthly operating Program Budget Line Item 1406 to increase liquidity and Current Assets: $61,868 combined $140,000. expenses. financial reserves for AMP 003; however, all debt service, Current Liabilities: $73,409 significant capital needs, and emergency needs must be Monthly Operating Expenses: $32,194 balanced with the need to utilize BLI 1406, Debt Service: None 1121 1 Page 1 Page 2 A B C D E F I G H I K 3 Item Results and Determinations Statutory Measurement ry Target Actual Baseline Data and PHAS Score Required PHAS Score Number from Assessment Desired Outcome Accomplishment Accomplishment Remedies Comments /Accomplishments 4 as of 613 012 01 6 ate Dale OHA must achieve a Quick Ratio of at least 1.0 based on Based on the =at recent approved FDS the FDS Schedule for FYE 121312019. data submission, the Housing Authodtys OHA performed actions in violation ORA must restore $50,000 hack to AMP 003 to increase current Financial Condition as shown The PHA increases its Quick Ratio QR ( ) OHA must adopt a Board of Commissioners resolution of HUD financial management current assets. below. te Quick Ratio of less than one to 1.0. acknowledging that 5 p AMP 003 9 9 repaid standards transferring $50,000 indicates current liabilities could not he e twelve (2) monthly ll prior from COCC funds in Twelve (12) monthly included F002 O from NeCOCCinto AMP 003on paid ifNeyimmediately became due. Ins to 121152019. An attestation must ha included In the Board resolution will be prepared for Nov meeting 12r27117 and then transferring In order to achieve a OR of 1.0, the PHA 12/312019 resolution that the restored funding will remainwithAMP to lace the monies theCCCthe monies backintoa COCC on AMP 003 mustincreaseltsCurrentAasetsor 003 and no further funds will be transferred from AMP 003 year. p y reduce its Current Liabilities by a back to the COCC. Current Quick Ratio: 0.84 combined $11,541. Current Assels: $61,868 Documentation evidencing the transfers including G/L Current Liabilities: $73,409 detail, journal entries, or other information as required by HUD must be submitted to HUD on a monthly basis prior to the 20th of each month. 13 OHA tracks repayment agreements Increase knowledge of the Board of Commissioners and on an individual basis in tenant case OHA slag on status of repayment agreements in an effort to OHA must achieve a TARS of one point five (1.5) percent notes. OHA can not provide overall reduce tenant accounts receivables. or less of net tenant rental revenues. details of repayment agreements including the number of repayment Based on the most recent a roved FDS PP The PHA reduces Tenant Accounts OHA must anter repayment agreements into the repayment agreements, total amount owed on data submission, the Housing Authorilysagreement than Receivable (TARS) to less than one module of their software and the HUD PICIIMS TAR will be achieved by increasing the Allowance F003, all repeymenlagreemenls,lolel current financial condition is as below. point five (1.5%) of net tenant rental revenues. system to be able to track more readily and for Doubtful accounts per HUD financial training 0001, amount of remaining retroactive rent comprehensively the amount of tenant accounts receivable attended. OHA is working with staff to implement and F006 owed, the total of current payments, P y the total AMP 003 In order to achieve a tenants accounts 12/312919 due toOHA. l useof m module the full use of the repayment module in software. repaymentin oftwar and of overdue payments, receivable of less than 1.5% the Housing th TARS: Authority must increase net tenant rentalhas OHA the late fee d discussed late rent Oe staff wlae. ts:2.$ revenue or reduce tenant accounts with staff. wasinA fee was in place. It was discovered It wasures iscovereda anR ental Rev nue:$ Net Tenant Rental Revenue: E193,520 receivables. Nat OHA hes a lower late rent fee Influence residents to pay rent on a timely basis to increase Revise OHA late fee policy for public housing, Nan other surrounding public net tenant rental revenue. Increase stag knowledge on rent housing authorities. collection practices. Provide stag training on late fee. 141 1 OHA tracks installment security The PHA reduces Tenant Accounts deposits on a case-by-case basis in eased on the most recent approved FDS pp Receivable (TARS) to less than one Receipoint vablen one e (T RS) to the tenant case notes. OHA can not data submission, the Housing Authority's percenlaf not OHA must achieve a TARS of one point five (1.5) percent provide overall details of installment P OHA must enter installment security deposits into the ty P current financial condition is as below: rental revenues. or less of net tenant rental revenues. TAR will be achieved by Increasing the Allowance for Doubtful Fo04 security deposits including the repayment agreements module of their software to be able AMP 003 accounts per HUD financial training attended. OHA Is working with number of installment security track more readily and comprehensively the amount of In order to achieve a tenants accounts OHA must enter tenant installment security deposit stag to Implement the full use of the repayment module In software. deposits, total amount owed on tenant accounts receivable due to OHA. TARS: 2.2% receivable of less then one point five agreements into the repayment module of their software to OHA has raised the late fee and has discussed with stag. security deposits, the (1.5) percent, OHA must increase not be able to track more readily and comprehensively the totInstallment number of current payments, A/R - Tenants: $4,262 tenant rental revenue or reduce tenant amount of tenants accounts receivable due to OHA. annddthe total of overdue payments. Net Tenant Rental Revenue: accounts receivables. 151 1 16y 3 i t: ,� p.. 3 'il 7 ,+i' k ' �.- n,. .... .. <, a .. �: :te� !' '�; - �.:",• . ! 3 ..t Based on its occupancy rates of AMP 003, OHA should improve Improved communication with the hoard on actual number of OHA must increase its occupancy rate to 96 percent based communication with the Board of vacancies and length of vacancies, upon the FDS Schedule for FYE 121311% Occupancy rate to 95 is difficult ficult to do if HUD Commissioners on actual units vacant and number of days vacant. The PHA increase its occupancy anc rate p y le to 96 percent to obtain up to eight(8)more ORA must revise their occupancy report per HUD's requires reduction in maintenance staff for 70 Current occupancy score: 95.05% points on the MASS occupancy indicator. suggestion. It must be presented to the Board of scattered sites. OHA will change occupancy G005, OHA should increase ulilization of Commissioners upon completion and on a monthly basis report to reflect how HUD wants it presented to Pool PIH Notice 2011-07 due to a less than 96% of units being occupied. Increased usage of unit status change 'Vacant HUD- Vacancies> 90 days:3 units Based upon its current inventory (70 units, or 788 unit months) and its current 1/312019 thereafter. Board. OHA staff is making a charge of required Approved: Undergoing Modernization' to increase Operating Long-term vacancies> 180 days: 0 units occupancy (64 units), the PHA must OHA must submit the revised occupancy report to HUD on submissions to HUD. Turn around time decrease Subsidy and increase the occupancy percentage in the Management maintain at least 63 units per month in an a monthly basis. will be difficult to achieve based on staff Assessment Subsystem (MASS), occupied status. OHNs average unit hummer time is OHA should attempt to reduce its turnaround time to ten reduction request. on average twenty-five (25) days. Decreased turnaround time end reduced operating costs. (10) to twenty (20) days per HUD's recommendation. 17 Page 2 Page 3 A B C D E F G H I J K 3 Item Results and Determinations Statutory Measurement Target Actual Baseline Data and PHAS Score Required PHAS Score Number from Assessment Desired Outcome Accomplishment Accomplishment Remedies Comments /Accomplishments 4 as of 6f3012018 Date Date Based on the scattered sites nature of AMP 003 which includes Based on the most recent approved FDS increasing operating and data submission, OHA's current physical OHA must consider repositioning its Low Rent Public p 0 P002 maintenance costs, may have aging Improve the physical and financial condition of remaining condition is show as below, Housing Assets under PIH Notice 201232, Rev 4 or successor notices, PIH Notice 2018-04, or other OHA is working with Development Team to review units,longerenciesrraDMKIdlong term OHApublichousingunitsinAMP003, 3, PASS score: 33 0140 torthcomin HUD y 9 repositioning guidance, which ma repositioning of 70 scatterd sites. p g vacancies, HUD MKE recommends that MHA review EHBS: 6 deficiencies; none were life- include a combination of mixed finance, RAD and/or AMP 003. threateningdispositioning or demolishing assets. repositioning 18 . _ � .. �. � � .. '. .. AREA�SRSTA7 ABILITY ^. i; 3377 Develop and implement a Sustainability Plan in conjuncdon with the local Long-term standard pedormerorhigher for all PHAS governing entities and other community To be discussed with HUD and/or other HA indicators partners that supports the PHA's agency to get guidance on how other agencies mission, addresses outstanding have accomplished this task. compliance deficiencies, and ensures sustainable performance of the PHA. 20 21 22 Housing Authority shall submit monthly orociress reports to the Field Office using this Action Plan as the reporting template commencing 11/1/2018 and every month thereafter until the Recovery A reement Is terminated." Page 3