RBD FASTFACTS - MONITORING TRACS TO ENSURE SUCCESSFUL TRANSMISSION - JANUARY 2021

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RBD FASTFACTS - MONITORING TRACS TO ENSURE SUCCESSFUL TRANSMISSION - JANUARY 2021
JANUARY 2021

    RBD FASTFACTS –
MONITORING TRACS TO
 ENSURE SUCCESSFUL
      TRANSMISSION
                            MARY ROSS
        ROSS BUSINESS DEVELOPMENT, INC
                       WW.RBDNOW.COM
RBD FASTFACTS - MONITORING TRACS TO ENSURE SUCCESSFUL TRANSMISSION - JANUARY 2021
FASTFacts
                         Monitoring TRACS to Ensure Successful Transmission
                                         Copyright 2021 Ross Business Development, Inc.
                                            All rights reserved. Not for duplication.

       All other brands and product names are trademarks or registered trademarks of their respective owners.

                                                   Ross Business Development, Inc.
                                                         3134 Shumard Way
                                                         Marietta, GA 30064
                                                           770-424-1806
                                                          www.rbdnow.com
                                                         info@rbdnow.com

                                                             Disclaimer

  The material contained in this document is not comprehensive of the continually emerging issues surrounding
  policies in The Multifamily Housing industry. In addition, the handbook guidance is derived from The HUD
  Handbook 4350.3 Rev 1 Change 4 released in August 2013 and in December 2013 and subsequent notices and
                                               memos from HUD.

                                                 These materials were updated 1/2021.

 The reader should understand that these materials are not designed for, nor should be relied upon, as a source of
                legal guidance or as a final authority with respect to any particular circumstance.

Ross Business Development makes no warranty of merchantability or fitness for a particular purpose or any other
                           warranty of any type with regard to these materials.
Owners and management should seek competent legal advice in developing and carrying out housing policies and
                                              procedures.

We have been diligent in our efforts to provide comprehensive and accurate regulatory instruction; Ross Business
                        Development shall not be responsible for errors or inaccuracies.

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RBD FASTFACTS - MONITORING TRACS TO ENSURE SUCCESSFUL TRANSMISSION - JANUARY 2021
FASTFacts
                         Monitoring TRACS to Ensure Successful Transmission

MONITORING TRACS TO ENSURE TRANSACTIONS ARE RECORDED SUCCESSFULLY
After sending TRACS Tenant Files, owner/agents should review the TRACS Certification Query to make sure
transactions have been recorded correctly.

Review certification submissions from the TRACS
Certification Query.

Make sure your compliance percentage is at 100%.
Then check the detailed information.

You are really trying to answer the following questions.

     ❖    Does the household appear in TRACS?
     ❖    Is the household in the correct unit?
     ❖    Is the last MAT 10 recorded correctly? (right type and effective date)
     ❖    Is the last action recorded correctly?
     ❖    Is the resident receiving the correct assistance?
     ❖    Is the unit Gross Rent correct?
     ❖    Is the household active?
     ❖    Does the household have unexplained errors?

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RBD FASTFACTS - MONITORING TRACS TO ENSURE SUCCESSFUL TRANSMISSION - JANUARY 2021
FASTFacts
                         Monitoring TRACS to Ensure Successful Transmission

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RBD FASTFACTS - MONITORING TRACS TO ENSURE SUCCESSFUL TRANSMISSION - JANUARY 2021
FASTFacts
                         Monitoring TRACS to Ensure Successful Transmission
If this is not the case, you should know why. (Ex: A Move-in or Annual Recertification submission resulted in a
FATAL error and the certification was rejected).
Keep in mind that the HOH names are “hot” and allow you to drill down in to TRACS to conduct further
investigation.

You have two options; you can view Discrepancies associated with the certifications shown on the certification
query…

If you are an auditor, and you discover an error, you may want to conduct research to see when the problem
started.
You can view certification history from the Certification Query as well.

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RBD FASTFACTS - MONITORING TRACS TO ENSURE SUCCESSFUL TRANSMISSION - JANUARY 2021
FASTFacts
                                                 Monitoring TRACS to Ensure Successful Transmission

In this case, the TTP has been incorrect since the IC was submitted. Minimum Rent in the Section 8 program (Subsidy Type 1) is $25.00.

The IC, the AR and the GR will all have to be corrected and resubmitted to TRACS.

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RBD FASTFACTS - MONITORING TRACS TO ENSURE SUCCESSFUL TRANSMISSION - JANUARY 2021
FASTFacts
                         Monitoring TRACS to Ensure Successful Transmission

TRACS AND EIV
Information is transmitted from the site, to TRACS to HUD’s Enterprise Income Verification System (EIV).

The Certification Query is the report used to investigate some EIV issues as well.

If you get a message stating that No 50059 Record Was Found, either
    1. The most recent certification has not been accepted in TRACS or
    2. The Social Security Number is wrong

You use the TRACS Certification Query to find out why EIV cannot find the 50059 data.
OPTIMUM TENANT COMPLIANCE (90%)
In order to qualify for payment, a property’s Compliance Percentage must be at least 90%. The Compliance
             Percentage is displayed on both the Certification and Voucher Queries. This Compliance
              Percentage is calculated nightly.

            Many people are trying to figure out exactly what the Compliance Percentage really is. HUD takes
the number of Active Certifications in TRACS and divides that number by the number of Units Receiving Subsidy
on the last voucher.

For example:
    • Property has 120 units under contract:
    • 10 of the units are vacant
    • 10 of the units are occupied by market renters.
    • On the voucher:
           o Field 6b (Units Receiving Subsidy) and
           o Field 9a (Units in Regular Billing) of the last voucher should reflect 100 units receiving subsidy.
    • To reach 90% Optimum Tenant Compliance, there must be 90 Active Certifications in TRACS for this
       contract

This is the extent of the TRACS Compliance Percentage Calculation; there is no match against household names
or subsidy.
Under the current TRACS design, the objective is to determine if it is reasonable to pay the voucher, not
determine if the information is an exact match to the site.

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RBD FASTFACTS - MONITORING TRACS TO ENSURE SUCCESSFUL TRANSMISSION - JANUARY 2021
FASTFacts
                         Monitoring TRACS to Ensure Successful Transmission

ACTIVE CERTIFICATIONS
Now, you ask, “What is an Active Certification?” An Active Certification is a MAT 10 (Move-in Certification,
Initial Certification, Annual Recertification) that was effective within the last 15 months – to the day. The
household must be considered an existing resident receiving subsidy. Future certifications do not count (ARs and
ICs submitted in advance of the Effective Date).

A certification has a limited life in TRACS. Since owner/agents are required to review residents’ household
income at least annually, the owner/agent uses HUD rules to establish the deadline for the first Annual
Recertification.

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FASTFacts
                         Monitoring TRACS to Ensure Successful Transmission
When the owner/agent creates a Move-in transaction, the Next Recert Date is usually the first of the same month
one year later. For example, if a resident moves in March 5, 2020, the owner/agent would establish a Next Recert
Date of March 1, 2021.

Note: Lease dates do not follow the same rule. Using this example, the Lease Start Date is March 5, 2020 and
the Lease End Date is either:
    • March 4, 2021 or
    • March 31, 2021.

If assistance stops for some reason and then is restarted at a later date, an owner/agent creates an Initial
Certification transaction, the Next Recert Date is usually the first of the same month, one year later. For example:
     • Resident fails to participate in the Annual Recertification process by anticipated voucher date of May 1,
         2020
     • Owner/agents must terminate subsidy effective April 30, 2020 (this is the last day of subsidy)
     • Resident reports and provides required documents on May 10 and qualifies for subsidy
     • Subsidy may start no earlier than June 1, 2020
     • Owner/agents establishes a Next Recert Date of June 1, 2021.

For PBRA RAD owner/agents who are creating the Conversion IC to switch residents from their current contract
to the new PBRA RAD contract, the Next Recert Date on that Conversion IC is always the same as the Next Recert
Date on the most recent 50059/50058 submitted prior to conversion to PBRA RAD.
WHY WOULD YOU BE UNDER 100%?
Missing Move-in transactions may cause a drop in the Compliance Percentage. You can use the TRACS
Certification Query to check to see if a certification is missing.

However, the most common reason seems to be failed Annual Recertifications. Owner/agents can monitor late
ARs using the TRACS Late Recertification Query.

If an Annual Recertification has been submitted yet the household still appears on this report, the owner/agent
must figure out how to get the certification accepted by TRACS.

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FASTFacts
                         Monitoring TRACS to Ensure Successful Transmission
If the Annual Recertification (MAT 10) was submitted but not properly recorded in TRACS, the owner/agent
must correct any errors and resubmit the Annual Recertification (MAT 10). If there are no errors, the Annual
Recertification (MAT 10) must be submitted again.

WHY WOULD YOU BE OVER 100%?
We see many properties that are over 100%. In these cases, the most common problem is a failed or “masked”
Move-out. If a Move-out does not work in TRACS, and the household’s last MAT10 was effective within 15
months, the database still considers this an Active Household.

Failed Move-outs create issues other than high Compliance Percentage. If the resident moves to another HUD
assisted unit, EIV will indicate that the household is receiving assistance in multiple properties/units on the EIV
Multiple Subsidy Report. This is because the resident is still “active” on your property.

Failed Terminations can have the same effect.

HUD also gives you the option to check Compliance Percentages for multiple properties within a single portfolio.

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