Pandemic Adjustments for MORs

Q With rising COVID-19 cases in my area, must unit inspections during on-site Management and Occupancy Reviews (MORs) still occur?

A The Section 8 Project-Based Rental Assistance program is subject to an annual audit and inspection known as a MOR. It’s one of the tools HUD uses to monitor a site to ensure that the owner is complying with its HAP contract, management certification, and HUD rules and regulations.

In its recently updated COVID-19 FAQ, HUD stated that it’s extending previously granted flexibility for unit inspections during on-site MOR reviews. Previously, HUD had allowed for Performance Based Contract Administrators (PBCA), traditional contract administrators (TCA), and HUD staff to conduct on-site MORs without entering resident units until Dec. 31.

The updated FAQ extends this timeline until May 31, 2021. And HUD’s earlier total suspension on MORs is lifted only “in locations where there are no restrictions by state or local law or ordinance to prevent them from performing these reviews.”

For REAC follow-up, in determining whether Exigent Health & Safety (EH&S) and other deficiencies have been corrected, the PBCA/TCA/HUD staff must attempt follow-up on those affected units via contact directly with the resident by way of phone or email and document the results or attempt made on the MOR report.

In addition, HUD won’t waive the requirement for an owner to perform annual unit inspections at this time. During tenant file reviews, owners will be penalized on MORs for not having conducted annual unit inspections even due to COVID-19. According to HUD Handbook 4350.3, paragraph 6-29(A)(3), owners perform unit inspections on at least an annual basis to determine whether the appliances and equipment in the unit are functioning properly and to assess whether a component needs to be repaired or replaced.

If local or state health department COVID-19 guidance prevents owners from entering a unit, the owner should consult with the tenant to confirm whether there are any issues with appliances, equipment, or other components in the unit and document the tenant’s reporting. HUD says owners may also consider using electronic means to perform remote or virtual unit inspections and as a means of submitting work orders to minimize in-person interactions during the pandemic, when possible.