TRACS Development Status

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TRACS Development Status

• 202C More
• Jed Graef, Bostonpost Technology
• Mary Ross, Ross Business Development

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Goals

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

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Clarification of Current Rules

• Review of HUD Requirements

4
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? 

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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.

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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

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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

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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 _at__at_ 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 -CACA001-CA

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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

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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

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Move out After Death

• Termination is no longer appropriate
• This is a training issue
• HUD Field Offices
• Software Vendors
• Contract Administrators
• Owner/agents

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Options/Suggestions

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

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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

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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

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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

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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

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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

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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

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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

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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

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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)

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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

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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?

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Cert Rounding Issues

• Cert roundingare 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 adjustment202B vs 202C

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Changes to the Voucher

• Complaints
• Voucher too long
• Hard to read
• Hard to reconcile

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Example of Voucher Formatting Issues

• All double spacedno structuremore 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.

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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

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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.

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Necessary Changes

• Required Changes or Enhancements for TRACS or the
  MAT Guide

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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 tenants income
  increases and no code was needed at MO or IC
• New TRACS error?

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Options

• Implementation to be coordinated with a TRACS
  update

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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

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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

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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?

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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

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Options/Suggestions

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

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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.

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Options

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

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Timing of Software Changes

• Need to coordinate with any changes required to
  implement the new SSN rule that is effective
  September 30

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Options/Suggestions

• October rollout?
• February/March rollout?
• Fall and Spring releases?

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Action Items

• Summarize Action Item List

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Thank you for your time!
Thank you for your time!
Thank you for your time!