Streamlining Compliance Protocol for Consolidated Monitoring
The following protocol is intended to ensure all streamlining participants follow consistent steps while performing regulatory audits and inspections and defines the roles of lead inspector and auditor. This protocol will be updated as deemed appropriate. All documents required will be made available using a digital worksheet, created and hosted by Oregon Housing and Community Services (OHCS).
OHCS hosts an annual State Streamlining Compliance Conference every September. The conference consists of committee meetings (Inspection, Steering, and Joint) and an annual National Standards for the Physical Inspections of Real Estate (NSPIRE) refresher training. This annual conference is in-person or virtual at OHCS discretion.
Setting the date and appointing Lead(s)
Thirty (30) days prior to the Annual State Streamlining Conference each year, OHCS will prepare the upcoming year’s tracker. All parties will be granted access to a page in the tracker specific to their organization. Upon notification of the tracker’s publication, all parties will be responsible for reviewing the list of properties, adding any newly acquired properties not currently included, and removing any that are no longer subject to HOME program requirements. All updates, additions, or corrections to the tracker must be completed within 14 days (two weeks) of the notification date. For current participants, refer to the previously shared State Streamlining Portfolio Compliance Monitoring Tracker instructions for details on how to fill it out.
During the Inspection Committee meeting at the annual conference, the committee members will meet to develop a schedule for coordinated monitoring visits required for the following year. The meeting may be in person, virtual or both at OHCS discretion. Inspection schedules will be completed by December 1 each year for appropriate notice to be given to the owners and managers of the properties to be inspected. Part of setting the schedule is identifying how many units need to be inspected to satisfy the program requirements and to see if there are any specific issues that need to be discussed prior to the inspection.
While setting the inspection schedule, the Inspection Committee will determine the lead inspector for each monitoring visit. The lead inspector is the contact person for the property manager/sponsor to contact with any changes or questions about the monitoring visit.
The auditor will always be a representative of OHCS. The auditor and lead inspector could be the same person, or the tasks could be divided between two different agencies. Regardless, the lead inspector is the person who will coordinate the inspection and communicate with the property owner/manager regarding any changes or questions about the monitoring visit.
The group may decide on specific dates for monitoring visits or may leave it to the lead inspector for each monitoring visit to arrange a date within the month that has been targeted for the inspection.
Coordinated monitoring process
A. Setting the date and sending notice of coordinated monitoring visit
- 60 days prior to audit (calendar year)
- Lead inspector sends proposed date of audit as well as the pre-inspection questionnaire to the streamlining partner (SP) via email.
- SP completes questionnaire and uploads it to the tracker and sends the lead inspector a notice of the uploaded completed questionnaire. This must be done within the first 14 days once the request is received.
- Lead inspector and auditor connect to discuss monitoring visit date to ensure it meets all requirements and coordinated availability.
- 15 days prior (email notice and instructions)
- Lead inspector will send an email to the owner, property manager and SP notifying the property of the upcoming audit date. The following docs will be attached to the email and saved to the tracker:
- Notice of Intent to Audit (Confirmation Letter)
- Resident Services Plan Report
- Seven days prior, owner or property management uploads pre-review documents and other requested items into Procorem as per the Procorem instructions.
- Two days prior
- Lead inspector moves completed submitted docs to the tracker from Procorem.
- Lead inspector reviews all documents submitted as well as the pre-inspection questionnaire to determine which units to inspect.
B. Day of the scheduled audit and/or inspection
All inspectors and auditors (if applicable) should arrive at the same time. Inspections
must wait until all members of the inspection team are present to start. All inspectors should bring a camera (phone, tablet, or applicable device with upload ability) with them or at least have someone take photos of all inspected units, common areas, systems, exterior, and general condition where findings have been identified and noted. Please be aware that the owner’s representative must always provide a representative for each inspector while on-site. Each inspector requires an owner representative to accompany them through the property and units. For example, if there are three inspectors, then three owner representatives must be present. The representative must be prepared to test all smoke detectors, open all units and doors, and to turn on all ranges/stove tops for all units inspected.
- Lead inspector will email property managers, owners, and auditor a list of units and files to be audited with any instructions on how to prepare.
- Lead inspector completes a review of on-site documents via OHCS onsite checklist, which is to be completed with the managers and owners (if present) and collects any outstanding or required reports and documents before starting inspection.
- Lead inspector visually confirms notice of entry to ensure proper notification was given to all residents prior to beginning inspection. If proper notification is NOT given, the lead inspector must stop the inspection (automatic Does Not Meet).
- If more than one inspector or auditor is present, all inspectors/auditors should compare notes and agree on final scoring for each item/file that may affect scoring as they complete the inspections so that they reach consensus. The goal is for all the reviewers to agree to a common understanding of what scores mean.
- The inspectors agree on the health and safety issues, and the lead inspector ensures that owner/property management are given a list of the health and safety issues that are to be resolved within 24 hours.
- The lead inspector completes the
HUD Checklist for NSPIRE, used to identify any deficiencies noted in the exterior, interior, and units. If lead inspector is from OHCS, OHCS will use software approved by the agency for NSPIRE standards.
- The lead inspector should notify the owner/property management about any health and safety issues that are to be resolved within 24 hours. The lead inspector will provide a copy of the Health and Safety 24 hour Action List before end of day. A copy is uploaded to the tracker and the auditor is notified.
C. Following the audit and/or inspection
- 1-3 days after the inspection (or agreed upon timeline) the lead inspector uploads to the tracker all completed HUD Checklist inspection forms and any notes and photos taken. Once uploaded the lead inspector will either send an email to all team members or leave a note in the tracker that all findings and photos have been uploaded to the tracker. Care must be taken so that all photos correlate to the appropriate HUD Checklist.
- The auditor will upload into the tracker the file audit results and will notify all team members.
- Once all documents have been uploaded into the tracker, the auditor prepares the draft report of the findings, uploads it to the tracker and notifies all team members. Team members are required to provide feedback within 7 days of the draft being sent.
- The auditor finalizes the monitoring report and ensures that the final report is sent to the owner/property manager within 30 days of the inspection. The final report includes instructions and a time frame for responding to any findings. Owner/property management has 30 days to respond to the report.
D. Following receipt of response to the final report
- The auditor contacts each participating funder to ensure that the response to the final report is satisfactory to each. Once the response has been found to be acceptable to all participating funders, auditor emails the close out letter to the owner/property manager and uploads them to the tracker.
- The auditor will be responsible for making sure all documents in the tracker are archived to a drive that is backed up in case of tracker failure.
Qualified inspectors
Streamlined inspections must only be completed by
NSPIRE trained inspectors.
Inspectors are required to follow Streamlining Inspection Guidelines. Inspectors become qualified through one of two methods:
- Attend an annual Streamlining Inspectors Refresher Training hosted and coordinated by OHCS.
- “Shadow” a qualified inspector on at least two inspections (preferably with two different qualified inspectors) to learn the proper procedure and inspection reporting standards.
Monitoring feedback
If any funder is dissatisfied with the quality of the physical inspection report or the file audit, they should contact the inspector/auditor and request that they provide additional information. If there are ongoing problems with a particular inspector/auditor, these issues should be reported to the inspector/auditor’s direct supervisor or to the section manager at OHCS.