Slide Number #1 © 2007 Nan McKay & Associates Hosted By: Cara Gillette Project-Based Accounting,...

Slide Number #1

©2007 Nan McKay & Associates

Hosted By:

Cara Gillette

Project-Based Accounting, Project-Based Accounting, Budgeting, and Management – Budgeting, and Management – Strategic DecisionsStrategic Decisions


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The New ModelThe New Model

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OverviewOverview

The new formula:• Requires PHAs with 250 or more PH units to transition

to PBM• Is based on HUD’s multifamily industry• Will force the PH program to become more property-

based to ensure the viability of each property

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HUD’s TimetableHUD’s Timetable

2007 All PHAs with 250 or more PH units must be using project-based accounting

2009 HUD will consider revising the system to use actual costs

2011 All PHAs with 250 or more units must be asset-management compliant

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How the New Model WorksHow the New Model Works

Historically, operating subsidy was calculated on an aggregate level• Op sub was allocated to the central

office, which decided where the subsidy went

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The New ModelThe New Model

Subsidy now is calculated for and allocated to each project• All other activities are supported by fees paid by

the projects• In other words, all the money goes to the projects,

and projects pay for everything else

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Compliance with Asset Compliance with Asset ManagementManagement

Best definition of compliance so far is Stop-Loss Kit• Guidance on

successful conversion for stop-loss agencies

Stop-Loss ProvisionStop-Loss Provision

Year Two Kit• Attachment 1• This is a valuable

roadmap for all PHAs

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The Deal with Stop-LossThe Deal with Stop-Loss

PHAs who are losing operating subsidy in the new formula can stop the loss by early conversion to asset management

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The deadline is October 15, 2007 If PHA demonstrates conversion by that date,

the reduction of subsidy will be stopped at 5% of the difference for CY 2007 That means that 95% of the PUM difference will

be added to the lower op sub level under the final rule

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The added subsidy will continue to be received by the PHA each calendar year that the PHA remains in compliance with the asset management requirements• This means that the PHA must be in

compliance each year or go back to the original loss

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Seven Criteria for Compliance Seven Criteria for Compliance with Asset Managementwith Asset Management

1. Project-based accounting• Monthly operating statements for each project – revenues and

expenses vs. budget levels, including all fees from COCC and CFG

• Must reasonably reflect the financial performance of each project

Sum of operating statements = total PH

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1. Project-based accounting second year: Project-specific balance sheets not required

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2. Project-based management• Property management services are arranged

or provided in the best interest of the property considering needs, cost, and responsiveness, relative to local market standards

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3. Central office cost center (COCC)• All central office fees must be reasonable• COCC must operate on the allowable fees and other

permitted reimbursements from its PH and S8 programs

• In other words, the COCC must support itself

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3. Central office (COCC) second year:• PHA may not fund the COCC with:

Sale of assets acquired with PH funds Amounts from Capital Fund other than

permitted (e.g., can’t use “Management Improvement” funds to pay for general accounting staff)

Funds from state or local governments

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4. Centralized services• Centralized services that directly support

projects are funded using a fee-for-service approach or through other allowable charge-backs

• Each project is charged for actual services received

• Must be reasonable compared to local market

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5. Review of project performance• PHA systematically reviews financial,

physical, and management performance of each project, and identifies non-performing properties

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5. Review of project performance – a non-performing property has:

• PHAS physical score below 70• Significant crime and drug problems• Below 95% occupancy• TARS that exceed 7% of monthly rent roll

FAQ clarifies this means rent…

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5. Review of project performance – a non-performing property has:

• PHAS grade of “D” or below for vacant unit turnaround and work orders

• Utility consumption more than 120% of agency average

• Other major management problemsTurnaround = D more than 30 daysWOs = D more than 40 days

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5. Non-performing property second year:• Significant drug and crime as defined by

Uniform Crime Reporting = exceeds the surrounding community by 120%

• For any projects identified as non-performing, PHA has management plan with set of recommendations and measurable goals

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6. Capital planning• Physical needs assessment and a five-year

plan for each project Five-year plan needs to consider revenue

sources, market, tenancy, and project needs• PHA demonstrates commitment to long-range

energy consumption reduction

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7. Risk management responsibilities related to regulatory compliance

• PHA not carrying out responsibilities if: Designated troubled under PHAS Any outstanding FHEO findings or voluntary

compliance agreement not implemented…

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7. Regulatory noncompliance if:• No current energy audit…• Outstanding IG audit findings w/no progress• Not in compliance with ACOP• Unsatisfactory progress under RHIIP/RIM• PIC (50058) reporting rate under 95%• Any other major compliance deficiency

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7. Regulatory noncompliance:• Stop-Loss FAQs, published 9/1/06 clarifies:

Regulatory compliance is agency-wide for now

• But at some point it will be analyzed by project

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7. Regulatory noncompliance second year: Designated troubled under PHAS physical,

financial, management, or CFG Outstanding IG audit findings greater than 6

months old without progress Not in compliance with ACOP and other related

occupancy directives…

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7. Regulatory noncompliance second year: Not meeting statutory Capital Fund obligation

and expenditure deadlines

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Follow the MoneyFollow the Money

How the op sub is calculated and allocated is driving these fundamental changes

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How the Money WorksHow the Money Works

The old op sub was aggregate - AEL Under the new formula, subsidy is

calculated and allocated by project - PEL• The op sub will go directly to the projects,

and all other activities will be supported by fees paid by the projects

• We see these in PUM (per unit month) figures

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The New Operating SubsidyThe New Operating Subsidy

Operating subsidy formula:Project expense level (PEL)

+ Utility expense level- Formula income frozen at 2004 level

+ Applicable add-ons

= Operating subsidy

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Operating Fund FormulaOperating Fund Formula

PEL uses 10 cost drivers or variables:1. Geographic variable

2. Location variable

3. Clientele (occupancy) variable

4. Property size

5. Building type

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Operating Fund FormulaOperating Fund Formula

PEL uses 10 cost drivers or variables:6. Bedroom mix (unit size)

7. Percent assisted

8. Property age

9. Neighborhood poverty

10. Ownership type

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Add-ons – PHA determines as applicable:1. Self-sufficiency

2. Energy loan amortization

3. PILOT

4. Audit cost – actual most recent

5. Resident participation - $25 per unit per yr

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Add-ons – the PHA determines:6. Asset management fee

$4 PUM for PHAs with 250 or more $2 PUM for smaller PHAS who transition to

PBM who have a COCC

7. Information technology fee $2 PUM

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Add-ons – the PHA determines:8. Asset repositioning fee – demo and dispo

9. Costs attributable to changes in federal law, regulation, or economy

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Approved vacancies – still get op sub:• Units undergoing mod (if on schedule)• Units approved for resident services• Units in court litigation• Units undergoing casualty loss settlement• Units vacant due to disaster (federal or

state)…

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Approved vacancies – still get op sub:• Units vacant due to changing market

conditions• Limited vacancies, up to 3%

The PHA will enter types of vacancies into PIC

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CostsCosts

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CostsCosts

All budgeted costs and expenses will fall into one of three general categories: Direct or frontline cost (at the project) Central office cost center (COCC)

• Direct services (e.g., central maintenance)• Indirect services • Allocated allocated services

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AMPAMP Frontline, or direct, costs of the AMP:

• Personnel costs of staff assigned to project• Repair and maintenance costs including

supplies, contracted repairs, make-readies, preventive maintenance, etc.

• Utility costs• Costs related to the site office – phones, office

supplies, computers, postage, etc…

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AMP Frontline (Direct) CostsAMP Frontline (Direct) Costs

These are expenses of the project:• Advertising including procurement and

employment notices• Costs of employee recruiting and screening• PILOT• Insurance (allocated)• Legal fees

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AMP Frontline (Direct) CostsAMP Frontline (Direct) Costs

These are expenses of the project:• Fees paid to the central office• Audit costs (allocated)

PHA should allocate a reasonable share of the audit cost to each AMP, COCC, and program

• Vehicle expense for site-based vehicles

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Cost CentersCost Centers

Any service provided to the project that doesn’t reside at the project will need to come from a cost center

• The projects will pay for the direct services that don’t reside at the project

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Cost CentersCost Centers

A cost center is a cluster of activities that indirectly or directly support an AMP but aren’t under the direct control of a property manager• Every PHA will have at least one cost center,

the central office cost center (COCC)• Centralized maintenance may also be a cost

center

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Central Office Cost Center Central Office Cost Center (COCC)(COCC)

The COCC is the PHA’s collection of indirect costs of operation - all programs

COCC will have its own column on FDS We’ll talk about the fees the COCC

charges to the projects a bit later

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COCC ActivitiesCOCC Activities• Executive director• Human resources• Regional PH mgmt• Corporate legal• Finance • IT• Risk management

• Centralized (if not an optional service center) Procurement Maintenance Work orders Inspections

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Other Cost (Service) CentersOther Cost (Service) Centers

Maintenance is an example of services that may need to be provided directly to projects that are centrally located and charged based on time spent or actual work performed

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How to organize maintenance is an important PBM decision• A PHA can decide to organize maintenance:

Decentralized – front line• Supervised by the property manager

CentrallyA mix (i.e., highly skilled technicians are

central)

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If the PHA uses centralized maintenance, will be required to use fee-for-service method when charging the project• Project can only be charged for actual

services providedCould be a single blended hourly rate, separate

hourly rates for various activities, or flat fee – must be reasonable

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Centralized Maintenance Centralized Maintenance

For all centralized maintenance staff providing direct services, the PHA can charge up to the market rate• Even if it’s above what the

technician is actually paid

May charge for actual materials used as well as labor

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Centralized MaintenanceCentralized MaintenanceHow Much Can the PHA Charge?How Much Can the PHA Charge?

Sally is a maintenance worker $62.26 Wages

$17.50 Benefits (45%)

$79.76 Hourly rate

If the market rate is $100, the hourly charge could be $100, regardless of what Sally is paid

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Other FunctionsOther Functions

Charging back to the project• Where it’s cost-effective,

PHA can prorate across projects the cost of centralized staff who perform frontline functions

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Charging Back to the ProjectCharging Back to the Project

These are called front line allocated costs• For example, collecting rent centrally,

employee handing rent collection, as well as direct costs, could be charged back to applicable projects on any reasonable basis

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Two exceptions to charging projects for centralized staff performing frontline functions:• Can’t charge projects for cost of a centralized

supervisor• Can’t charge projects cost of centralized staff

handling procurement

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Update – Centralized Update – Centralized WarehouseWarehouse

FAQ December 1, 2006 If a warehouse at the COCC is for

“storerooms” of scattered sites, with HUD approval, this can be an eligible frontline cost

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HUD will allow charging back to project:• Central waiting lists, screening, leasing and

occupancy – PHAs can prorate costs direct costs of these functions to the AMPs, including supervisory personnel The proration can be based on the number of units

leased at a project, average turnover at a project, or other reasonable allocation method

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HUD will allow charging back to project:• Resident programs – PHA can prorate

centralized resident programs across projects on a reasonable basis, including supervisory staff

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HUD will allow charging back to project:• Protective services – PHAs can charge

centralized protective services, either in-house or through local law enforcement, including supervisory staff

• HUD eventually wants these tracked by project

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HUD will allow charging back to project:• Work order processing

Although it is the norm in multifamily housing to handle work order processing on site, a PHA may charge the cost of centralized work order processing only if the PHA can document/justify that the cost pro rated is reasonable and necessary

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Shared Resource CostsShared Resource Costs

- What if there is PHA personnel who provide services both to the projects and the central office cost center?

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HUD recognizes it may not make economic sense to have full-time staff dedicated to a specific project• In this case the PHA may establish a

reasonable method to spread these personnel costs to the AMPS that receive the service

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Shared Resource CostsShared Resource Costs Shared resource costs are distinguished

from front line prorated costs in that the services being shared are limited to a few projects as opposed to being pro rated across all projects• An example of a shared resource cost might

be a maintenance person assigned to and paid for by two projects

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- For PHA staff who provide services both to the projects and the central office cost center, the PHA must separate the amount of time spent on providing services to the projects and the central office cost center, based on a reasonable methodology

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- The time spent by the staff on projects must be at an hourly rate that does not exceed the reasonable hourly fee for the service

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Fees Allowed under PBMFees Allowed under PBM

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Fees the projects will pay to the COCC:• Property management fees• Bookkeeping fees• Asset management fees• Capital fund management fees

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Property management fee• Is “reasonable fee” paid by project to COCC

for project oversight• HUD has established some “reasonability”

guidelines Notice: Guidance on Implementation of Asset

Management, issued Sept 6, 2006

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Management fee – “reasonable”• Based on multifamily fee (annual letter from

field office); or • 80th percentile as established by HUD; or• Other compelling data of local market

Might include fees paid pay the PHA for private management of other properties

Updated April 10, 2007Updated April 10, 2007

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Management fee• Based on units leased (occupied units and

approved vacancies, but not the 3% limited vacancies) using average monthly lease-up rateStop-loss FAQs (question 12) says that the

PHA can use either the first day or last day of the month (but must be consistent)

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Property Management Fee Property Management Fee Calculation ExampleCalculation Example

X { + + }

PHA has:• 1200 Occupied Unit Months • 100 HUD-Approved Vacant Unit Months

80th percentile of FHA = $49.02 Calculation: 1200 + 100 x $49.02 = $63,726

PUM Prop Mgmt Fee

Occupied HUD-Approved Vacancy

Demo/DispUnit Mos

Not in book

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X { + + }

What if the AMP has 120 units? That would be a potential 1340 Occupied Unit Months + HUD-Approved Vacant Unit Months

80th percentile of FHA = $49.02 Calculation: 1440 x 49.02 = $70,589

PUM Prop Mgmt

Fee


Demo/DispUnit Mos

Not in book

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X { + + }

In this case, the AMP’s property management fees are $6,863 less than optimum

If AMPs aren’t fully leased up, there needs to be a plan

PUM Prop Mgmt Fee


Demo/DispUnit Mos

Not in book

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Bookkeeping fee• An extension of the management fee• For accounting for project funds, charged to

the project from the COCC• Based on occupied units and allowable

vacancies• HUD will consider $7.50 PUM reasonable

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Asset management fee• Fee paid by project to COCC for oversight of

portfolio • Based on total ACC• Must be reasonable, not to exceed $10 PUM• Only paid if the project has excess cash flow

(no limit first year)

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Asset Management Fee Asset Management Fee Calculation ExampleCalculation Example

X

AMP has 100 units:• 100 units x 12 months x $10

Calculation: 100 x 12 x $10 = $12,000

$10 PUMAsset Mgmt Fee

Total ACC Units

Not in book

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Asset Mgmt FeeAsset Mgmt Fee

• In the 1st year of PBM, there is no excess cash requirement for the payment of the fee

• In the 2nd year, each project must have excess cash to pay the asset management fee

• In the 3rd and subsequent years, excess cash must equal one month of operating expenses to pay the asset management fee

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Capital Fund Management Capital Fund Management FeeFee

Fee may be up to 10% of the CFG including replacement housing funds• The fee is paid by each AMP from CFG

proceeds

HUD is still defining the way the fee will be earned

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AttachmentsAttachments

Attachment 2 – table of fees Attachment 3 – PIH 2007-9

• Changes in financial reporting

Attachment 4 – Financial FAQs 7/27/07 Attachment 5 – Schedule of AMP provisions

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Costs of a ProjectCosts of a Project

Project

Front line costs:Direct admin costsDirect maintenanceDirect office costsUtilitiesFees paid by project Management fee Asset management fee Bookkeeping fee Other fees for services

Central OfficeCost Center

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How Cost Centers are FundedHow Cost Centers are Funded

Central OfficeCost Center

Central MaintenanceCost Center

Waiting ListEligibility

Cost recovery based on fees paid by projects and from other programs

Cost recovery will occur based billing projects for services performed

Some centrally provided service costs will be allowed to be allocated to projects

RevenuesRevenues

ProjectRevenues

- Dwelling rent

- Other tenant revenue

- Interest income

- Misc. income

- Operating subsidy

- Capital grant funds

-Management fees earned-Bookkeeping fees-Asset mgmt fees earned-Capital fund mgmt fees-S8 management fees-Other eligible reimbursements-No direct subsidy!!

COCCRevenues

Summary Summary Management

ActivityFrontline Activity

Method

Management Fees

AdministrativeRent CollectionSecurityScreening/WLOccupancyLeasingResident SvcsWork Orders

OtherAudit CostsWarehousing

MaintenanceTechnical Routine

Inspections

OtherPurchasingOther

Method

Proration Fees for Service None

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Strategic Decision PointsStrategic Decision Points

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General StrategiesGeneral Strategies

This is a fundamental shift for public housing• The projects are the economic engine of the

public housing program• How can I ensure the properties are performing

well or are turning around?• How can I ensure skilled staff at the sites?

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Big change for staff• “I’ve always worked at the central office – and now

I have to work at a project?”• “I’ve been a property manager for years – and now

you’re going to hold me responsible for all these vacancies?”

• “What decisions is the executive team making behind closed doors? Why is it secret?”

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Big change for staff• “Hey – I’m union!”• “I’ve been a maintenance tech for 30 years and

have always reported to Joe, and now I have to report to Cindy?”

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The Central OfficeThe Central Office

You should be running your numbers now• Project-based

accounting

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Every position (salaries and benefits), post-retirement obligation, every cost, every receivable, every asset goes into an AMP column or the COCC column (or, if there is another cost center, that column)

ColumnsColumns

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You should be running your numbers • After running your pro-formas (accounting for

every cost and source of income), how much money do you estimate coming into your COCC?

• How much does your COCC actually cost?

Sample Proforma – Attachment 6Sample Proforma – Attachment 6

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HUD Budget ToolHUD Budget Tool

At HUD’s asset management page: • http://www.hud.gov/offices/pih/programs/p

h/am/fm.cfm

http://www.hud.gov/offices/pih/programs/ph/am/fm.cfm

http://www.hud.gov/offices/pih/programs/ph/am/fm.cfm

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If all the PH fees, HCV admin fees, and fees from other programs total $3,298,030, and if your COCC actually costs 3,000,000

You’re good to go

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If all the PH fees, HCV admin fees, and fees from other programs total $3,298,030

BUT your COCC actually costs 3,500,000 You’ve got a $201,970 shortfall

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The Central Office - StrategiesThe Central Office - Strategies

You’ve got a shortfall – strategic decisions• Place more staff at the AMPs• Ensure property managers are skilled• Cut unnecessary costs• Update job descriptions and ensure staff is

working to their job descriptions• Right-size the central office

The Central Office - StrategiesThe Central Office - Strategies

You need to analyze whether PH or HCV is paying more than its share of COCC costs• Year 2 Stop-loss Kit calls out for much more

detail on HCV costs

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MaintenanceMaintenance

Since maintenance is one of the biggest expenses in public housing, maintenance delivery will be a key issue

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Key issues:• Maintenance staff longevity – highly paid

compared to same skill set in private sector• Benefits• Overtime• May be reporting to a new boss (property

manager)

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Strategic decisions:• Decentralize routine maintenance• For highly skilled technicians, their pay must

be reasonable compared to the market• Reduce overtime• Some PHAs are assigning maintenance to

be property managers – new learning

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UnionsUnions

We can see that some jobs may be affected• New assignments• New skills• More accountability

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Unions - StrategiesUnions - Strategies

Communicate now• And keep communicating• Educate the union how the money works

Educate everyone together – your board, the union, your executive staff, all staff

You’re all in this together – everyone needs to see they have shared interests in making this work

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Property ManagersProperty Managers

The property managers’ knowledge, skills, abilities, and accountability are key to making the projects work

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Some new/increased skill sets:• Marketing• Higher supervision skills

Some will be supervising maintenance for the first time

• Budgeting and working within budget

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Some new and increased skill sets:• More rigorous oversight of annual and

interim reexams• Nondiscrimination – reasonable

accommodation• Risk management - keeping liability down• Procurement and contract management

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What Will Make This WorkWhat Will Make This Work

If it’s going well, keep doing what you’re doing

If improvement is needed:• Leadership, a plan,

and some hard work

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Leadership• A leader is someone with a vision and has the

ability to articulate the vision• Communicate, communicate, communicate -

don’t think all PBM decisions must be made before you educate your staff!

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Leadership• The executive director and team should

understand how this worksNot just the finance officer

• The executive director should ensure that the board understands how this works

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Leadership• Leaders will need to decide how transparent

department budgets will be It will be important for property managers to

know how their properties are doing, if they are to be held accountable

And how their properties are affecting the COCC

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Leadership• Leaders will need to decide how much

discussion, agreement, and discord will be accepted when fees are charged to the projects, when excess cash is transferred to other AMPs, and when the fees are allocated to individual departments

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A plan• A strategic plan will need to be articulated,

specific, shared with everyone, and fairWith benchmarks and timelines

• Good electronic reporting from sites is a must• Supervision and quality control is essential• Drill PHAS down to the sites now

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A plan for each project:• Maintain project as is• Identify capital improvements needed• Dispose of property (demo, sale, etc)• Neighborhood revitalization• Increased community collaboration• Political ramifications

Not in bookStop-Loss FAQs 9/1/06

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A plan• Skilled staff at the sites

Articulated individual development plans, to help staff increase knowledge and skills

The property manager must be the business manager of that property – and must have the skills and tools

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How does performance of the property affect the evaluation of the property manager?

What about the property manager who specializes in “turning around” a nonperforming property? Is he or she paid more? How transparent is everyone’s salary?

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How far up, and down, into the agency will the responsibility for achieving goals of project-based management go?

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A plan• Attracting and retaining higher income

tenants• Coordinating and collaborating resources so

existing tenants can increase income

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A plan• Senior leadership plays a vital role

• With involvement early on and continued involvement – leaders are visible and accessible

• Employees see the leaders as the source of communication

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A plan• Over communication is impossible

• Honest and open communication of what’s happening is what employees most want from leadership

• And the communication must be two way, with management listening to employees

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A plan• If downsizing becomes necessary, planning

should include senior leadership, HR, and labor Incentives such as early retirement and

buyouts can help employees and preserve morale

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A plan• If downsizing becomes necessary

Career counseling, career transition planning, outplacement assistance, resume writing assistance, access to office equipment, paid time off, financial counseling, and access to job fairs and internet job placement sites are all tools that have been used successfully

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A plan• Information not normally required in the

PHA’s day-to-day operations becomes criticalManagement must have information for

planning and monitoring, and employees need information so they know how things are going and can make decisions

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A plan• Successful planning includes the

development of business plans from various departmentsThis helps ensure that the managers of PH,

HR, Finance, Procurement, Maintenance, etc. are involved, and builds support

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A plan• Identification of work processes that will not

be needed is vital to the success of the planThis will also protect those processes that are

key to the PHA

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A plan• It will be a combination of multiple strategies

that will make this workSome strategies won’t work well, and others

will exceed expectations

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A plan• Monitoring progress is a chief component of

successful transitionPHAs need to keep close track of performance

of the properties, periodically review their policies and procedures, learn from their mistakes as well as successes, and incorporate what was learned

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A plan• Success or failure of big transitions depends

on the workforce• A well-planned, thought-out, and managed

process, which all employees perceive as being fair and humanely administered, promotes trust and faith in management and the future of the agency

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SummarySummary

Q &A

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Thank you for attending!Thank you for attending!Upcoming Lunch ‘n’ Learns:Sept 7 – HCV Ownership

Hosted by Annie StevensonSept 6 – Public Housing Community Service and Pets

Hosted by Terry ProvanceSept 14 – HCV Legislative and Regulatory Update

Hosted by Nan McKaySept 28 – Public Housing Supervision

Hosted by Patti Zatarian-Menard

Slide Number #1 © 2007 Nan McKay & Associates Hosted By: Cara Gillette Project-Based Accounting,...

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