TRACS Development Status

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

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

3. 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?

5. 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.

6. 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

7. 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

8. 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

9. 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

10. 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

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

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

13. 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

14. 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

15. 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

16. 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

17. 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

18. 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

19. 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

20. 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

21. 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)

22. 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

23. 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?

24. 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

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

26. 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.

27. 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

28. 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.

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

30. 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?

31. Options • Implementation to be coordinated with a TRACS update

32. 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

33. 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

34. 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?

35. 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

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

37. 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.

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

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

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

41. Action Items • Summarize Action Item List

42. Thank you for your time! Thank you for your time! Thank you for your time!