1 SECTION 232 UPDATES Office of Residential Care Facilities.
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Transcript of 1 SECTION 232 UPDATES Office of Residential Care Facilities.
3
OHP/ORCF – Who We Are
•OHP (Office of Healthcare Programs) – Roger Miller – DAS
•ORCF (Office of Residential Care Facilities)
•Hospitals (242)
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OHP/ORCF – Who We Are
•ORCF – Director – Michael Vaughn (as of mid-June will be Kelly Haines
•Production: Director – Roger Lewis (Seattle)•Asset Mgmt: Director – Kelly Haines (St. Louis)•Policy: Director – John Hartung (St. Louis)
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OHP/ORCF – Who We Are
•Designated Lender Relations Liaison is Mary Walsh – Ft. Worth:• Work with Lenders
• Submissions for Development and Asset Mgmt
• Measures of lender submission quality and risk profile
• LQMD –
• Lender Qualification• Post Closing Monitoring Activities
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A Much Brighter Picture!!!!
•2010: Loads of Applications, Hoping for more resources in 2011.
•2011: More Applications, We were in worse shape (total queue topped out over 400 projects).
•Now: Next Few Slides……..
•We’ve hired staff and added contractors…..
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Activity F Y ‘12 (5/31/12)
FY 2011 FY 2010 FY 2009
Applications Received
359/479 708 768 271
Commitments 546/728 473 318 132
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Office of Residential Care FacilitiesQueue Volume
QUEUE VOLUME
as of
12/31/11 as of
1/31/12 as of
2/29/12as of
3/31/12as of
5/31/12
223f Regular Queue 135 77 54 13 8
223f Portfolio Queue 0 5 2 5 1
223a7 27 19 21 22 15
232 Other 41 40 42 36 21
TOTAL 203 141 119 76 45
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Office of Residential Care FacilitiesInflow & Outflow
Application Inflow & OutflowSept.2011
Oct. 2011
Nov. 2011
Dec.2011
Jan. 2012
Feb. 2012
March2012
New Applications Received
16 33 45 51 31 48 54
223f 10 11 20 24 14 20 17
223a7 6 19 25 23 16 26 33
Other 0 3 0 4 1 2 4
Firm Commitments Issued
43 61 57 69 64 74 76
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Section 232 Lean Phase II
LEAN PHASE II
• Goals: End of Queue, Commitments issued within 30 days of application, closings within 45 days
• Adherence to these performance standards will increase the program’s attractiveness for high quality borrowers and facilities.
• Focus on both Internal and External production elements.
• Identifying Internal Bottlenecks
• Tracking through Internal Delay categories in Visual Management Report
• Making necessary changes in resource allocation, process steps• Other Queue
• Working with OGC and ORM to remove obstacles to production flow
• Setting expectations for Underwriting processing times
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Section 232 Lean Phase II
LEAN PHASE II (cont’d)
• Setting expectations for completeness of Lender submissions• Lender Narrative should address all issues/conclusions• HUD (or contractor) UW should be able to proceed without delay
• Tracking through External Delay categories in Visual Management Report
• Working with Lenders to reduce delays (Mary Walsh)
• Working with OGC/Lenders Counsel to reduce closing delays
• Reduction of Queue should reduce stale underwriting/document/legal delays
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Section 232 Lean Phase 2External Delay Categories
External Delay Categories
1a. NOI: Market/vacancy/payer mix (2) 4c. AR
1b. Cap Rate (1) 4d. Master Lease
1c. Incorrect/ineligible costs (2) 5a. Typographical errors
2a. Quality of Care/surveys 5b. Calculations/Math Errors (1)
2b. 2530 or other Derog Issues (2) 5c. Missing Exhibits (13)
2c. Operations (2) 5d. Not using standard lean standard templates/forms or obsolete
2d. DEC findings (2) 5e. Error in identifying Green Lane or Non-Green Lane criteria (a7)
2e. Failure to identify portfolio (3) 5f. Incorrect Amortization values (a7)
3a. Environmental (2) 6a. Updates to Financials (10)
3b. Obsolescence 6b. 2530
3c. Property Condition/Reserves (2) 6c. A/R
4a. Corp, Structure, Title 6d. Master Lease
4b. Litigation status/Other (1) 6e. Legal (4)
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Section 232 UnderwritingNew Construction Risk Mitigation
Risk Mitigation for 232 New Construction
Market analysis must support strong demand
Financial strength of the developer/owner/operator
Relevant experience of the developer/owner/operator
Conservative lease up
Substantial operating deficit reserve
Requirement for significant cash investment by strong ownership
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What’s New?
•Proposed Rule/Document Revisions:
•Comment Period until 7/2/12•Webcast today @ 2:30 to 5 EST•Information on our HUD.GOV website
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What’s New?
•We Created a Separate Queue for 241a’s
•Preference in Other Queue for projects with TC’s/Other Grant Funds for Affordable Units
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What’s New?
•Elimination of Legal Completeness Review:
•HUD Legal Review at same time as Underwriting
•Complete/Full Firm Submittal imperative given short queue
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What’s New?
•Initial Screening of Other Queue Projects:
•Diane Rosinski – Buffalo•Patrick Berry – Detroit – WLM•Dated submissions: if no longer feasible, request refund of app fee (before HUD assigns appraiser/UW).
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What’s New? Initial Screening Continued.
•Projects Placed in one of 3 categories:
• No Revision necessary
• Minor Revisions necessary
• Major Revisions necessary:
• Removed from queue until corrected • If Corrected, project returns to same spot in queue
relative to other projects – FIFO• Currently 13 Projects
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What’s New? Initial Screening Continued.
•Some items being reviewed:
• Compliance with previous Email Blasts: Experience, net worth/liquidity, equity investment.
• IOD
• Major Environmental Issues
• Brief review of APPS/2530’s
• Brief review of Forms
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What’s New?
•Swap Fees: ML 2012-8
•Contact OHP/Contract Closer if Firm Commitment issued (not closed) and want to include.
•We’ll be clarifying what we want to see in future submissions in Email Blast – until checklists/narratives can be revised.
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What’s New?
•Projects with Common Ownership:
•Per November 2011 Email Blast, identify on initial request form fro FHA Number and Certification for Electronic Submittal.
•If recommending no Master Lease separate issue – present risk based reasons to UW.
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What’s New? Revenue Funding Cuts.•If enacted (Medicare recently), reflect in appraisal and in Underwritten NOI
•If proposed (Illinois):
•If possible to quantify, show in sensitivity analysis how project may be affected – can still cover at 1.45 and 1.0 DSCR?
•Discuss owner/operator’s plan to deal with them if enacted.
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Section 232 Delinquencies
> 60 Day Delinquencies (earlier in 2012)
18 of 26 are Assisted Living
11 of those 18 are New Construction
8 of 26 are Nursing Homes
6 of those 8 are Refinances, 2 seasoned NC
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Section 232 Claims FY 2010 - 2012
• Type UPB Cohort Property City State Cause • AL 1,514,988 2002 BARSTOW RET.PL. BARSTOW CA Market/Owner • AL 2,111,004 2009 MAPLEWOOD RIDGE PELHAM AL Owner • AL 1,125,079 2005 RIVER BIRCH RES. HOLFORD MN Market/Owner • AL 4,933,963 2002 SUNAPEE COVE GEORGES NH Owner • BC 1,231,477 1995 ESSEX MANOR SUPERIOR MI Market/Owner • BC 1,613,754 1998 LANDMARK MANOR HAMPTON PA Market/Owner • BC 512,990 1997 LANDMARK MANOR HAMPTON PA Market/Owner • NH 26,482,547 2003 SOMERSET HOUSE CHICAGO IL Owner/State • NH 3,917,200 2002 FOX RIVER PAV. AURORA IL Owner/State • NH 4,588,799 2001 JAMES S TAYLOR LOUISVILLE KY Owner• NH 6,229,592 2000 WEST ROCK HC E. N. HAVEN CT Owner/State • NH 3,963,459 2008 PECAN RIDGE LC WACO TX Owner /State• AL 7,864,276 2000 GARDEN PK VILLAS ESCONDIDO CA Owner • AL 5,299,558 2008 NORTHPORT HLDS NORTHPORT MI Market/Owner • AL 3,317,582 2009 RIVER BEND AL VALLEY AL Owner • AL 2,637,155 2003 HEARTLAND PLAZA MOORE OK Market/Owner • NH 3,729,042 2001 FAIRCHILD MANOR LEWISTON NY Owner • NH 2,514,427 2008 GOVALLE CARE CTR AUSTIN TX Owner • NH 1,644,127 2003 NORTHVIEW DV CTR EASTLAND TX State/Owner• AL 21,183,217 2006 Lenox on the Lake Lauderhill FL Market/Owner• NH 3,988,697 2003 SouthPark Brownwood TX State/Owner• NH 988,953 2002 San Augustine San Augustine TX State/Owner