TRACS Development Status - PowerPoint Presentation

TRACS Development Status 202C & More Jed Graef, Bostonpost Technology Mary Ross, Ross Business Development

Goals Develop workable action plan Identify & Address Areas of Concern Maintenance Release Potential Enhancements

Clarification of Current Rules Review of HUD Requirements

Certification Submission Requirements – Sites to HUD Does site software make it easy or hard to submit certs as they are completed? Can the function be made automatic? Enter “transmit and receive mode” Prompt to send when site is closed?  

Certification Submission Requirements – CA to HUD Must allow multiple transmissions from OAs throughout the month. Must forward information to HUD as processed . Failure to do so results in false double subsidy situations. Some CAs are batching based on the voucher and holding certs until they appear on the voucher. Do not batch.

CA Edits and Error Messages There are four and only four categories of messages outside of MAT errors Fatal Error Discrepancy 1, 2, 3, 4 Informational Status Code (voucher) Use these and only these as message types followed by a colon and the message code

CA Error Compliance If reporting a discrepancy, the next line must contain an Action Processed code that reflects the severity that the CA attaches to the error-1 through 4. If the CA software is fataling a cert with a level 1 discrepancy it should be reported as: Fatal Error : CE111 This allows the site to understand what is expected

Receipt Acknowledgement If you want to acknowledge the receipt of a file, do not say that you have received the file followed by the usual @*@ and header. The header must come first followed by the acknowledgement The message must have a type and code Informational : CA001 (or whatever) Thanks for file xxxxxxxxx.yyy And end with “-CA”—CA001-CA

Options CAs need to follow the spec and not invent new error categories and methods of communicating information When reporting a calculation error, report both the site submitted value and the CA calculated value Ditto for income limit and rent errors and similar discrepancies

Fatal Errors and Compliant Files CAs may not fatal or hold certifications that are legal per the spec and acceptable to TRACS. Split GRs that are currently legal MAT10 GRs that the CA software does not handle properly Household splits and swaps that do not count as double subsidy situations per the 202C spec Children in joint custody If it is unclear whether TRACS would accept, try submitting

Move out After Death Termination is no longer appropriate This is a training issue HUD Field Offices Software Vendors Contract Administrators Owner/agents

Options/Suggestions Increase Awareness Monitor Compliance Software Vendors Update/Enhance Site Products Contract Administrators Users

Contract Combinations/Terminations Last HAP Issue Run next HAP after the contract is expired Take the total and add as an OARQ to the current HAP Design/site software issue Some software cannot run a subsequent HAP until the first one is closed

Options/Suggestions Modify site software to allow the workaround in a final voucher situation Define an exception to the cert selection rules for a final voucher

Certification Selection Rules Clarification Document Mid month MI to AR beginning of next month Some feel that rule does not make sense 12/31 TM on Feb voucher MAT 10 UT following partial rule not full cert rule Need to consider when data is entered on site

Cert Selection Rules CAs must not change a voucher date unless the date is Is illegal (voucher date is too early per the rules) or Is wildly off (voucher date is more than 3-4 months in the future relative to the cert) Or because cert processing and voucher inclusion is delayed If the CA software fixes illegal dates - good practice to return a message to the site listing the reported and new dates

Gross Rent Changes Signature Requirements – currently required only if TTP, TR, UA change due to: UA Change Noncitizen rule Cannot auto-sign MAT 10 with GRC Notices vs when the GR is executed

GRCs--Continued Recommendations vs. Rules Cert selection is a rule When to execute the GR is a recommendation MOR vs. Voucher processing at CA When signature is required, current handbook forbids transmission of the GR certs until they are signed A modification to this policy has been requested for Change 3

Option 1 Make it explicit that you can run a “GR-like” notice process whenever you want to produce the 30-day notice. Consider scenarios CAs must respect the anticipated voucher date Clean up is required on the notice if new certs are entered later on

Option 2 Another is that the GRC could be entered in advance Site software creates Notice Cert for signature Similar cleanup issues MI effective earlier than the GR

Option 3 Change the anticipated voucher date rule for GRCs Allow them to appear on an earlier voucher Only for GRCs effective on the first of the month (7/1 GR on July voucher)

Resolution Primarily a software issue Should we say it is OK to run GRCs in advance? If so, need to pick up what happens to certs entered after the GRC MI IC AR IR UT

Adjustment Issues Adjustment and rounding (daily rate and line totals) Are there calculation issues with Adjustment line items? Incorrect adj periods? Incorrect cert selection? Numbers printed seem to be accurate – are property managers/site software or CA software completing the calculations correctly?

Cert Rounding Issues Cert rounding—are there issues? CA adjustments for rounding cannot be automatic unless you can prove you are right – Appendix H is the deciding document CAs must be able to accept site certs if the CA software calculates incorrectly Is this an issue with “old” certs that have been corrected? Corrected move in calculates using 202C rules If only changing non-financial aspects may have $1.00 adjustment—202B vs 202C

Changes to the Voucher Complaints Voucher too long Hard to read Hard to reconcile

Example of Voucher Formatting Issues All double spaced—no structure—more pages GRC adjustment through May 31. Some adjustments ended on 2/2. Makes no sense unless there was a MO, TM or UT. The reason the adjustment stops needs to be illustrated or it does not make sense to the voucher auditor.

Options/Suggestions Clarify the rules Single space adjustments with a blank line between units/tenants Clarify starting and ending dates For clarity, ending date needs to pull in TMs and MOs previously billed Add an adjustment total in the blank line

Options/Suggestion Add more examples to the spec – Jenny spreadsheet New Cert type codes AR-U (already flagged) IR-U (already flagged) AR-G (no flag) IR-G (no flag) MI-G (no flag) Etc.

Necessary Changes Required Changes or Enhancements for TRACS or the MAT Guide

S8 Income Exception Code MAT Guide is being updated Original Exception Code is included on all subsequent MAT 10 records A code is not added if a tenant’s income increases and no code was needed at MO or IC New TRACS error?

Options Implementation to be coordinated with a TRACS update

First HAP Issues First HAP issues (regulatory) KC HUB – 202C Specific Cert selection rules for initial PRAC HAP Resolution is necessary is to agree how first vouchers get created

Options/Suggestions Treat an initial PRAC HAP the same as a RAP/Rent Supp HAP for month 1 only Include all certs effective less than or equal to the voucher date on the HAP

TM for PRAC (Not a 202C Issue) Rules require the tenant to pay operating rent if they fail to certify and they are paying less than operating rent at that time What transaction is required TM? AR or IR with the rent forced to operating rent but otherwise not calculating correctly?

Regulatory Requirements Double subsidy? SSN Rule?– Should a TM be allowed if the tenant is paying less than operating rent? Zero assistance MAT 10 certs are allowed in PRAC situations What happens to the annual recert requirement? – PRACS recertify no matter what

Options/Suggestions Allow terminations despite the Handbook statement that TMs do not apply to PRACS Require MAT10s forcing the rent to operating rent

Multi-year retroactive certifications due to fraud and other reasons – Not 202C Specific Warning – as CAs take over new properties or as CAs change, new CAs will often start with nothing but a current baseline. What are the requirements on history? Also occurs with site SW vendor change.

Options Best practices for proof of missing history Signed Certification? Original Voucher? Eliminate retroactive activity as does RHS (only future certs)

Timing of Software Changes Need to coordinate with any changes required to implement the new SSN rule that is effective September 30

Options/Suggestions October rollout? February/March rollout? Fall and Spring releases?

Action Items Summarize Action Item List

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