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Office of Multifamily Housing Assistance Restructuring (OMHAR). Mark-to-Market Program PAE Invoice Training - 2004. Objective .
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Office of Multifamily Housing Assistance Restructuring(OMHAR) Mark-to-Market Program PAE Invoice Training - 2004
Objective • To provide PAE staff with technical assistance on the Mark-to-Market invoicing process that will enable the PAE to become: 1) familiar with the invoicing process and its requirements; and 2) proficient in completing the invoicing forms.
Invoice Memoranda Form 2.12 Form SF 3881 Form 2.13 Form 2.14A Form 2.14B Form 2.15 Form 2.16 Form 2.17 Invoice timeline Gov’t Travel Info Per diem rates POV mileage rates Critical Dates Tracking Incentive fees Sample cases Invoice Training Materials
Invoice Memoranda (Tab C) • Guidance memos issued to clarify or update invoicing process: • Voucher Payment Process – February 22, 2000 • Third Party Payments – April 19, 2000 • Compensation regarding new owner and purchaser initiatives – October 4, 2000
Form 2.12 – Transmittal Letter (Tab D) • Transmittal Letter from OMHAR HQ to the PAE with Invoicing Instructions • Distributed following execution of PRA • Provided necessary invoicing forms • Provided summary guidance on completing each form
Form SF 3881 – ACH Payment (Tab E) • ACH Vendor/Miscellaneous Payment Enrollment Form • Standard government form • Used to obtain banking information in order to wire transfer payments to vendors • ANY change in banking information (account #, routing #, or TIN), required to complete new form • Ensure form is signed by Financial Institution • Forward to OMHAR HQ Senior Voucher Specialist
Form 2.13 (Tab F) • Asset Payment Authorization Form • Sets forth the maximum expenses that will be paid by OMHAR per PRA • Need waiver (Form 2.15) for ALL amounts exceeding 2.13 and PRA • Must be executed by the PAE for each asset identified on Exhibit 1 of the PRA limits
Form 2.13 (Tab F, cont’d) • Forward to the appropriate OMHAR Production Office for signature • Revised form must be attached to Form 2.16 whenever there is a change in asset status (e.g. lite to full; rent comp. to a lite; tier 1 to tier 2)
Form 2.14A (Tab G) • Asset Specific Fees • Third Party and Other Reimbursements • Base Fees • Incentive Fees • To request payment for restructuring expenses on individual assets • Submit one invoice per month per asset at any time during the month • Do not submit invoices for nominal amounts
Form 2.14A (Tab G, cont’d) • MUST attach supporting documentation for ALL items invoiced • Include completed Government Travel Voucher when travel is involved • Copies attached to invoice should be legible • Must include original signatures when submitting to PO • PAE must maintain copies of all invoices and supporting documents • Written explanation of disallowances is provided to PAE from Production Office
Form 2.14B (Tab H) • Non-asset specific invoice form • Used to request reimbursement for restructuring activities that pertain to the PAE as a whole (e.g. training) • PAE should receive written approval from the appropriate OMHAR Production Office before incurring non-asset specific expenses • Include a completed government travel voucher and supporting documentation when travel is involved
Form 2.14B (Tab H, cont’d) • Submit only one invoice per month as needed • PAE must maintain copies of all invoices and supporting documents
Form 2.15 (Tab I) • OMHAR Waiver Form • Used by PAE to request authorization from the OMHAR PO to exceed Form 2.13 limitations • Authorization must be granted by appropriate OMHAR PO prior to the PAE incurring the cost • Amounts exceeding limit by $15,000 must also have HQ approval • Line item - “Total Amount Requested” = additional cost + authorized cost
Form 2.15 (Tab I, cont’d) • Also used to request time waiver when PRA timeframes cannot be met. • If waiver is intended to allow PAE to earn an incentive fee, the form must specifically state this in the comments box • PRA ¶5.7.1 • Executed by PAE and appropriate OMHAR PD • Attach copy to Form 2.14A, when applicable
Form 2.16 (Tab J) • Used by PAE to Request Change of Asset Status • lite to full, rent comp. review to a lite or full, full to a lite, re-entry • Required whenever there is a change in asset status • Reminder - revised Form 2.13 is required except for reentry deals • May require a new contract renewal election (aka 99-36) from the owner – (anything to a full) • Attach to 2.14A, when applicable
Form 2.16 (Tab J, cont’d) • Complete when AOTC deal re-entering M2M Program • Third party reports < 18 months • Memo – “PAE Compensation on Properties Reentering the M2M Program” (5/2/03) • Provides guidance and fee schedule • Items to include in comments box • Fees previously paid • Additional base fees being requested • Additional 3rd party reports and travel costs • Timeframes for completing key milestones • Attach executed copy to invoice for relevant fees
Form 2.17 (Tab K) • PAE’s request to place a project on hold due to circumstances that have occurred outside the PAE’s control which prevents the PAE from doing work on the project for an extended period of time • Stops the clock • When clock resumes, may still be able to earn incentive fees per Exhibit 5 of PRA • Deduct hold time period from time to accomplish milestone to determine “true” timeframe • Attach to invoice when invoicing for incentive fees, when applicable
PAE Invoice Training Questions
Timeline OverviewInvoice Processing – PAE (Tab L) TARGET - 30 days from receipt of third party bill/receipt or earned fee Timeline • Prepare Form 2.14A or 2.14B • Assign invoice number • Verify claims are made on appropriate line items • Verify eligibility and accuracy of $ amounts • Check adequacy of supporting documentation • Ensure bills/receipts match claimed amounts • Include 2.15, 2.16, & 2.17, if applicable • Attach evidence that M2M MIS system has been updated, when applicable • Review third party work product for compliance with PRA • Third party bill/receipt must indicate work performed and reference project • Prepare bill on PAE letterhead for earned fees • Indicate work performed & reference project • Review travel voucher for compliance with Federal travel guidelines • Update M2M MIS system, if appropriate Submit one original invoice with copies of bills/receipts and other supporting documentation to the appropriate OMHAR Production Office Third Party bill/receipt received or fee earned PAE authorized official reviews for completeness and accuracy and signs Forms 2.14A, 2.14B, and government travel voucher
Timeline OverviewInvoice Processing – PO (Tab L) TARGET – 10 Days from receipt of complete invoice Timeline • Production Office Approval • Indicate allowed amounts and explain any disallowances • RM Verification/ Signature • PD Verification/ Signature • Update Integrated Invoice Tracking System • Production Office Logs-in/Updates Integrated Invoice Tracking System • PAE No. • Project No. • Invoice No. • Indicate if final invoice • Asset Designation • Date of Invoice • Date PO Received • Production Office Review for Accuracy • Checks for consistency w/ PRA and OPG • Verify claims are made on appropriate line items • Verify eligibility and accuracy of $ amounts • Check adequacy of supp. documentation • Ensure bills/receipts match claimed amounts • Ensure 2.15, 2.16, & 2.17 are included, if applicable • Verify M2M MIS system has been updated, if applicable Invoice received in mail Fed Ex orig., supporting documentation and copy of pgs. 1 & 2 of 2.14A or page 1 of 2.14B, whichever is applicable, to OMHAR HQ, Attn: Voucher Specialist PAE Corrects Deficiencies (Submitted to PAE for correction within 7 days of receipt. 30-day clock “restarts” when invoice is resubmitted to OMHAR PO.)
Timeline OverviewInvoice Processing – HQ (Tab L) TARGET - 10 days of HQ’s receipt of completed invoice TARGET - 10 days from completion of HQ’s review OVERALL TARGET- 30 days from receipt of completed invoice • HQ Reviews Invoices • Check for consistency with PRA and OPG • Verify eligibility and accuracy of $ amounts • Check adequacy of supp. documentation • Ensure bills/receipts match claimed amounts • Ensure 2.15, 2.16, & 2.17 are included, if applicable • Verify M2M MIS system has been updated Timeline Invoice received in mail from PO • OMHAR HQ • Enters invoice info into Integrated Invoice Tracking System • Enters into HUD payment system OMHAR HQ sends approved invoices grouped by PAE to Cash Management • OMHAR HQ • Confirms payment with Cash Mgmt. staff • Updates Integrated Invoice Tracking System • Notifies PAE and OMHAR PO by email of payment • HQ Logs-in/ Updates Integrated Invoice Tracking System • PAE No. • Project No. • Invoice No. • Indicate if final invoice • Asset Designation • Date of Invoice • Date Received Cash Mgmt. requests Treasury Wire Transfer Cash Mgmt. updates payment info in payment system PAE should receive payment within 5 business days of notification Notify OMHAR PO of deficiencies within 7 days of receipt. PO and/or PAE corrects deficiencies and/or provides missing documentation. 10-day clock for payment by OMHAR HQs “restarts” when revised invoice or missing documentation is submitted to OMHAR HQs.
PAE Invoice Training Questions
Government Travel • Government Contract Expense Reimbursement Travel Voucher (Tab M) • Traveler must summarize daily expenses, except for M&IEs, on this form • Guidance memo – May 2000 • Per diem rate (Tab O) • POV mileage rates (Tab P)
Critical Dates Tracking (Tab Q) • General Rule: Always attach to Form 2.14A • Exception – when amounts on invoice only include fees for other subcontractor fees and/or travel • Update M2M MIS system
Invoices - Things to remember • Submit only one invoice per asset each month • Record claims on the appropriate line items • Verify $ for eligibility and accuracy • Check adequacy of supporting documentation - Does it match claimed amount? • Update M2M MIS system, if applicable (i.e. PCA date) • Attach Critical Dates Tracking • OMHAR’s goal - pay invoices within 30 days of receipt of an acceptable invoice • Changes to banking information, complete new ACH Form (Form SF 3881)
PAE Invoice Training Questions
2.14A (Tab G)Third Party and Other Reimbursements F = Full; R = Rent Restructuring (Lite); C = Comparability Review
Form 2.14A (Tab G)Third Party and Other Reimbursements • Required supporting documentation • Attach receipts for ALL work performed by third party vendors (i.e. appraisals, PCA, legal counsel) • Travel voucher and supporting documents • Include waivers – Form 2.15 (actual > PRA $$) • Update M2M MIS system • Attach Critical Dates Tracking, when applicable • Not necessary when only invoicing for other subcontractors fees and/or travel
PAE Invoice Training Questions - Break 10 minutes -
Travel (Tab M) • Summarize daily expenses and per diem (Meals and Incidental Expenses, a.k.a M&IE) on Government Contract Expense Reimbursement Travel Voucher • Must sign travel form – travel and PAE certifier • Use most economical mode of travel • PAE receives letter from OMHAR HQ authorizing them to obtain Federal government rates (hotels, car rental) – (Tab N) • One travel voucher per traveler
Travel (Tab M, cont’d) • Include bills/receipts for all travel costs except M&IEs • Visiting multiple properties on one trip • Complete only one government travel voucher • Attach a summary breakdown of costs for each project to the travel voucher • Submit 2.14As for all projects visited on the one trip at the same time
Travel (Tab M, cont’d) • Multiple persons are traveling together • Each traveler must submit a separate travel voucher • Request reimbursement for the travel costs on the same 2.14A • Personal travel is combined with business travel • Include a written explanation which clearly identifies dates and costs associated with business travel • Only costs associated with business portion of the trip are reimbursable • SSN - not applicable • Address - required only when POV is used and reimbursement for mileage is from traveler’s residence
Travel (Tab M, cont’d) • Voucher number • Enter appropriate voucher number per the 2.14A • Per diem allowance (Tab O) • Daily payment for lodging, M&IEs • Established for most localities • Standard rate for U.S. localities that do not have a specific rate • Maximum per diem rates and lodging rates are published in the Federal Register and may be accessed through GSA web page • http://policyworks.gov/org/main/mt/homepage/mtt/perdiem/travel.htm
Travel (Tab M, cont’d) • Meals and Incidental Expenses (M&IE) • Limited to Federal government per diem rate (updated each fiscal year) • Must be in travel status for more than 12 hours and travel more than 50 miles from duty station • 3/4 (75%) of per diem rate allowed for first and last day of travel • Receipts for M&IE’s not required
Travel (Tab M, cont’d) • Lodging • Limited to lesser of actual cost or Federal government per diem rate • Actual cost > per diem rate • Only be allowed if it is evidenced that per diem rate was not available • Contact 3 other hotels in order to validate that rate was not available, attach this documentation to voucher • Per diem rate is not expected to cover room tax • Traveler should request the Federal government rate using letter issued by OMHAR (Tab N)
Travel (Tab M, cont’d) • Lodging Taxes • Claim under “other” • Only claim amount applicable to per diem rate • Airfare • Limited to cost of coach fares • Copy of ticket receipt required • Booking fee not reimbursable
Travel (Tab M, cont’d) • Car Rental • Written justification is required • Traveler should request the Federal government rate using letter issued by OMHAR (Tab N) • Compact cars must be used to the extent reasonable • Excess cost for renting luxury/full sized car will be borne by traveler • Supporting documentation must identify type of vehicle rented • Reimbursed for gas • Mileage NOT reimbursable
Travel (Tab M, cont’d) • Privately-Owned Vehicle (POV) • Flat mileage rate is allowed (updated each calendar year) • Must indicate number of miles traveled • Website for mileage rates – (Tab P): http://www.dtic.mil/perdiem/faqpovpast.html
Travel (Tab M, cont’d) • Other • Receipts for costs =< $75 are not required to be submitted to OMHAR (except trains) • PAE must retain copies of all bills/receipts (except M&IE’s) • Only business calls related to M2M Program are eligible for reimbursement • explanation of purpose must be provided
Reimbursable Expenses Coach airfare Rental car and gas POV mileage Per diem on travel greater than 12 hours Hotel costs within per diem limits Non-Reimbursable Expense Booking fee Rental car mileage Gas for POV Per diem on travel less than 12 hours Hotel costs exceeding per diem – unless noted Travel (Tab M, cont’d)
PAE Invoice Training Questions
Travel – Sample Case (Tab R) • Demonstrates • When multiple properties are visited during one trip • Documentation required for a car rental • Lodging rate > per diem rate • POV mileage – home to airport • Taxi fare – airport to home
PAE Invoice Training Questions - Lunch -
Base Fees • Items • Full Debt Restructuring • Rent Restructuring after Attempted Debt Restructuring (full to lite) • Tier 1 Rent Restructuring • Tier 2 Rent Restructuring • Rent Comparability Review • Other - Reactivated Project and Bonds and TPAs • Requires bill on PAE letterhead • Update M2M MIS system
Base Fees – Full • Refer to PRA and PAE Acceptance Date for appropriate amount • Adjusted each calendar year (eff. January 1) • Lite becomes a full restructuring • Any base fee paid for the Lite is applied against the full restructuring base fee (excludes incentives paid) • Verify amount is entered on appropriate line item • Update M2M MIS system • Attach Critical Dates Tracking
Base Fees – Full • Paid in increments – 30%-40%-30% • Initial 30% after completion of due diligence • Next 40% after PD’s approval of the Restructuring Plan • Final 30% within 30 days of closing and document distribution • Attach signed Form 8.1 from OMHAR Closing Dept. • Closing documents must have been distributed • Update M2M MIS system • Attach Critical Dates Tracking
Base Fees – Full to Lite • Fee paid upon the PD’s acceptance of the PAE’s required work products • Refer to PRA and PAE Acceptance Date for appropriate amount • Adjusted each calendar year • Update M2M MIS system • Attach Critical Dates Tracking
Base Fees – Lite (Tier 1 & 2) • Submit one invoice for the base fee • Fee paid upon the PD’s acceptance of the PAE’s required work products • Refer to PRA and PAE Acceptance Date for appropriate fee • Adjusted each calendar year • Reimbursable costs for third party reports can be invoiced separately from base fee • Update M2M MIS system • Attach Critical Dates Tracking
Base Fees – Rent Comp Review • Submit one invoice • Refer to PRA and PAE Acceptance Date for appropriate fee • Adjusted each calendar year • Include cost of 3rd party rent comp. study • Update M2M MIS system • Attach Critical Dates Tracking
Base Fees – Reactivated Projects • Attach a copy of the Form 2.16 • Executed by the PAE, RM, PD, and • Initialed by HQ PAE Management • Memo - “PAE Compensation on Properties Reentering M2M Program” (Tab J) • Guidance memo (05/02/2003)