CARH’S BROADCAST E-MAIL – Regulatory Alert

December 11, 2015

Rural Development (RD)’s Centralized Servicing Center (CSC) is again conducting audits of Rental Assistance (RA) payments as required by the Improper Payments Elimination & Recovery Improvement Act (IPERIA). The audit letters were sent to selected borrowers in November, and properties are required to submit the requested documents to CSC for review no later than December 22, 2015. (Click here to view a sample audit letter.)

CARH urges management companies to inform your staff that, if they receive a letter from CSC indicating that an audit is being done on an RA payment, that all requested information should be completed in a thorough manner and within the time frames allotted by the CSC request. In addition, before returning requested information to CSC, it is highly recommended that someone in senior management review the response for accuracy and completeness prior to submission to CSC to ensure compliance.

These audits are used as the agency moves forward on budget requests for Rental Assistance and as we know, the results will be used by the Agency in determining whether or not to increase management fees. Therefore, it is vitally important to ensure that all documentation is submitted timely and accurately.

If your property receives a letter from CSC, you are required to submit the following required documentation by December 22, 2015:

• Fax Cover Sheet with corresponding Record Number included in the audit letter
• Tenant Certification, Form RD 3560-8 (submit the tenant certification based upon the requested effective date).
• Verification of Income
• Verification of Assets
• Medical Expense
• Verification of Disability
• Verification of Citizenship (Farm Labor Only)

Also submit any supporting documentation. Supporting documents include all calculation tapes, internal worksheets and third-party verification used to complete the Tenant Certification. Examples of supporting documents include:

• Verification of Employment
• Zero Income Persons
• Unemployment and Unemployment Benefits
• Regular, Unearned Income (e.g., Social Security, pensions, workers compensation)
• Public Assistance
• Alimony or Child Support Payments
• Support for Foster Children or Adults
• Income Tax Return
• Verification of Assets and Income from Assets
• Disability/Handicapped Documentation
• Medical Expense
• Citizenship (Farm Labor Only)

Before submitting your response to CSC, review carefully your documentation regarding the following top five causes of improper payments:

• Income Documentation/Calculation
• Medical Deductions
• Tenant Certification Dated and Signed
• Tenant Certification Current
• Award Letter Included

To assist on-site and property managers, in 2008 CARH created a Training Manual in response to past IPERIA (formerly IPIA) audits whose high error rates pose a threat to RD’s RA budget. The Training Manual includes a checklist of common errors and proposes solutions. It also references regulations made in Handbook 3560. The manual is a live document, so any questions or comments to improve the Training Manual are welcome.

Please contact the CARH national office at carh@carh.org or 703-837-9001 should you have further questions.