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Management Review Ratings

Policy: Management Operations

Meets OHCS Standards

  • The Owner/Agent follow established and consistent practices which meet the objectives of OHCS housing programs. (i.e. provisions of well-maintained housing at the lowest possible rents made available to households who qualify under the appropriate income limits with minimal errors).
  • The Owner/Agent has clear knowledge of the regulatory agreements, loan agreements, restrictive use agreements or any other OHCS documents governing the use of the property and appears to be in compliance with minimal to zero errors.
  • The Owner/Agent has established an appropriate Affirmative Fair Housing Marketing Plan (AFHMP) for the property. The Owner/Agent demonstrates they are following the current AFHMP and the plan is updated as required.
  • Marketing of the property supports the AFHMP and uses more than one method of advertising/outreach to reach potential residents.
  • Current Owner/management company approved by OHCS without any unauthorized changes.
  • Approved Management Agreement on file if applicable.
  • Current and timely with all annual Certifications of Continuing Program Compliance (CCPCs) – responds timely.
  • All previous and current IRS Form 8823's have been resolved.
  • Documentation that demonstrates proper request for OHCS approval for modifications of resident services, rent and fee increases, waivers, change of building use, manager unit designations, and any other action that requires OHCS approval.
  • Obvious internal quality assurance practices are used that ensure compliance with all program requirements.
  • Documentation demonstrates that Owner/Agent has a Tenant Selection Plan and that the plan does not violate any funding program(s) requirements.
  • Documentation demonstrates that Owner/Agent has a waiting list for the property.

Does Not Meet OHCS Standards

  • The Owner/Agent’s actions or failure to act have placed OHCS’s interest in jeopardy and/or stalled the achievement of the department’s housing objectives.
  • Violation of policies and procedures resulting in noncompliance with the regulatory agreements, loan agreements, restrictive use agreements, or any other OHCS documents governing the use of the property.
  • Documentation demonstrates that the Owner/Agent does NOT have an appropriate AFHMP for the property and does NOT employ affirmative marketing strategies which address changing local demographics (Limited English, various levels of disabilities, and family size).
  • Marketing and outreach efforts do NOT exist or are insufficient and/or unsuccessful in reaching potential residents.
  • Change in management company or owner without OHCS approval.
  • Approved management agreement is not on file or is not approved (if applicable)
  • Failure to submit annual Certifications of Continuing Program Compliance (CCPCs) when due and/or failure to respond to requests from OHCS for additional information or correction.
  • Previously issued and/or current IRS Form 8823s are unresolved.
  • Failure to appropriately request OHCS for approval for resident services modification, rent and fee increases, waivers, manager unit designations, change of building use, etc.
  • No evidence of internal quality assurance policies and procedures that insure compliance with all program requirements.
  • No evidence of a Tenant Selection Plan or the Tenant Selection Plan is very outdated and/or the plan is in violation of funding program requirements.
  • The Tenant Selection Plan is violation of any funding program(s) requirements.
  • Owner/Agent does NOT have a waiting list for the property and practices show violation of funding program(s) requirements.

Property Maintenance: Leasing & Occupancy Operations

Meets OHCS Standards

  • The Owner/Agent has preventative maintenance practices in use and keeps documentation supporting the practices are followed.
  • Vacancy rate is <10% for the last 12 months.
  • Unit turnover practices are in place to ensure units are prepared for occupancy within 15-30 days.
  • Units are consistently made ready for occupancy within 30 days or less.
  • No units required unplanned substantial rehab at turnover.
  • No units were taken offline due to deferred maintenance.

Does Not Meet OHCS Standards

  • The Owner/Agent has NO preventative maintenances practices in use and does not keep documentation.
  • Vacancy rate is >10% for the last 12 months.
  • Unit turnover practices are NOT in place to ensure units are prepared for occupancy within 30 days or less.
  • Units consistently take longer than 30 days to make ready for occupancy.
  • Units required unplanned substantial rehab at turnover.
  • Units were taken offline due to deferred maintenance.

Review Preparation Materials: Management Operations

Meets OHCS Standards

  • All documentation requested by OHCS in preparation for review was submitted to and received by OHCS no later than the due date.
  • All documentation requested was provided and the documentation was complete and accurate.

Does Not Meet OHCS Standards

  • Documentation requested by OHCS in preparation for review was not submitted and received by OHCS by the required due date.
  • OHCS had to make requests and/or send reminders to obtain the required documentation.
  • Documentation submitted/received was incomplete and/or inaccurate.

Review Tenant Files: Leasing & Occupancy Operations

Meets OHCS Standards

  • Files were organized in a consistent manner which allowed for an easy file audit.
  • Incidents of errors found in files during review result in no major adverse findings; due diligence was shown to be established.
  • No repeat findings found during the review.
  • No eligibility issues found during the review.
  • Correct rent/income limits were used – use of wrong limits is not a pattern and did not result in any eligibility issues.
  • Correct utility allowances were used – allowances are updated annually with the correct and approved calculation methods used.
  • All OHCS required forms are being used.
  • All required verbiage from OHCS recommended forms used on any Owner/Agent created forms.

Does Not Meet OHCS Standards

  • Pattern of repeat findings.
  • Incidents of errors found in files during review result in major adverse findings; due diligence was not shown.
  • Open findings from previous years reviews.
  • Utility allowances not updated annually, failure to apply correctly and/or failure to calculate the utility allowances with approved method.
  • Failure to correctly certify residents at move-in and/or recertify residents.
  • Fraudulent certifications performed by the Owner/Agent.
  • Pattern of utilizing the incorrect rent and/or income limits or the use of incorrect rent/income limits resulted in eligibility issue.
  • OHCS required forms are not being used or implemented in a timely manner.
  • Required verbiage from OHCS recommended forms not used on any Owner/Agent created forms.

Review Response: Management Operations

Meets OHCS Standards

  • The review response was received by OHCS no later than the required due date.
  • An extension was requested at least 10 days prior to the required due date and was then received by OHCS by the extended due date as required.
  • All requested documentation was provided and the documentation was accurate and complete with the first submission.

Does Not Meet OHCS Standards

  • The review response was not received by the required due date.
  • An extension was requested less than 10 prior to the required due date or no extension was requested.
  • Documentation submitted was incomplete and/or inaccurate.
  • OHCS had to make requests/reminders to obtain the required documentation.
  • OHCS had to make requests/reminders to obtain complete and/or accurate documentation

Resident Resources: Leasing & Occupancy Operations

Meets OHCS Standards

  • Required resident services are provided or coordinated at the property and they are appropriate for the current population.
  • Resident services are comparable to the original Resident Service Plan (RSP) with documentation to demonstrate the resident services are provided and evaluated periodically to meet the needs of the current population.
  • Any changes to the RSP have been preapproved by OHCS.

Does Not Meet OHCS Standards

  • Required resident services are not provided at the property.
  • Resident services that are provided are not comparable to the original RSP.
  • The RSP has been changed without OHCS preapproval.

Complaints: Leasing & Occupancy Operations

Meets OHCS Standards

  • No fair housing violations.
  • Resident complaints are resolved in a timely manner.

Does Not Meet OHCS Standards

  • Pattern of fair housing complaints or violations.
  • Unresolved fair housing complaints or violations.
  • Unresolved resident complaints.
  • Complaints received from residents demonstrate a lack of management oversight.

Financial: Management Operation

Meets OHCS Standards

  • No major adverse findings in the following areas:
    • Financial management/procurement process
    • Mortgage
    • Election to assignment of mortgage
    • Diversion of project funds
    • Distribution of funds
    • Funding the reserves for replacement account
    • Submitting reports as required
    • Filing financial statements as required
  • All fees and payments are current with no late payments.
  • All fees and deposits charged to residents meet OHCS and funding program requirements.

Does Not Meet OHCS Standards

  • Major adverse findings exist in any of the following areas:
    • Financial management/procurement process
    • Mortgage
    • Election to assignment of mortgage
    • Diversion of project funds
    • Distribution of funds
    • Funding the reserves for replacement account
    • Submitting reports as required
    • Filing financial statements as required
  • Failure to pay any OHCS fees<
  • Fees and payments are late and/or not current
  • Fees and deposits charged to residents to not meet OHCS and funding program requirements

Communication: Management Operations

Meets OHCS Standards

  • The Owner/Agent responds to all requests for information/documentation from OHCS by the required due date.
  • All requested information/documentation is accurate, complete, and received by OHCS by the required due date.
  • Extension was requested prior to the required due date; information/documentation was then received by OHCS by the extended due date.

Does Not Meet OHCS Standards

  • The Owner/Agent does NOT respond or responds late to all requests for information/documentation from OHCS.
  • The requested information/documentation is inaccurate and/or incomplete and/or not received by OHCS by the required due date.>
  • Extension was NOT requested.

Fair Housing & Equal Opportunity: Management Operations

Meets OHCS Standards

  • Owner/Agent has demonstrated knowledge and practices that meet industry standards

Does Not Meet OHCS Standards

  • Owner/Agent does NOT have demonstrated knowledge and practices that meet industry standards.

Questions? Email arh.portfolio@hcs.oregon.gov.

OHCS wants to ensure that everyone has access to its information and programs. If you would like this information in a different language, please email Language.Access@hcs.oregon.gov.