Notes from the HUD TRACS Industry Meeting 10/29/2014

As you might know HUD usually holds two meetings each year in Washington, DC devoted to TRACS issues. The meetings are usually held right after the NAHMA meetings for convenience of many attendees that attend both conferences. The purpose is to bring together interested parties from Contract Administrators, Housing Authorities, owner agents, software vendors and other interested persons that are involved or impacted by TRACS. This session feature topic was the recent rollout of TRACS version 2.0.2D. TRACS Implementation Schedule is from August 1, 2014 to February 1, 2015.

The first day agenda outline:

• Opening – Carolyn Cockrell, Director, Office of Systems and Management and Lanier M. Hylton Housing Program Manager thanked everyone for attending.
• Presentation “Status of TRACS 202(d) Implementation/Specification Changes” presented by Mary Ross, CPO, FHC, MORS, President, CEO Ross Business Development, Inc. and Jed Graef Product Manager MRI Software LLC.
• Update TRACS 202(d) by Lanier M. Hylton, Housing Program Manager.
• JSON Discussion presented by Jesse Jaime, Tenmast Software and Frank Shofner, Shopcorp LLC.
• Electronic Signature presented by Rafi Khan, Pyramid Systems, Inc

MultiSite has been on the TRACS 202D Working Group for several years and we learned some new things at this meeting. Mary and Jed did a great job of organizing and presenting the material. We have summarized below the items that jumped out to us at the presentation (Note: This was an all day event and we are not attempting to recount each detail).

If you wish to download the document used in the discussion you may download it here http://www.multisitesystems.com/documents/Tracs Industry Meeting Agenda October 2014.pdf

Notable Items

• DUNS & TIN – You may have heard that 202D version would require DUNS and TIN (Taxpayer Identification Number – for Section 8, Rent Supplement, RAP and PRAC). This was originally in the 202D specification but TRACS is not currently enforcing this rule. These may be enforced in the future. This does NOT mean that you can just willy-nilly disregard the DUNS & TIN numbers. TRACS is very specific in the way you send them or do not send them. The discussion at the meeting was that it was all or nothing decision to transmit the indicators.

		Tip: If you do not have both then leave both blank.
		The specification also has two new fields “Parent Company DUNS” and “Parent Company TIN”. Ask you management company supervisor about this. If there is not a parent company NO NOT enter the same ID’s you entered for the TIN and DUNS. This will fatal if the ID’s match. Parent company and owner id’s may not match.

• Income Limits – The definition of Extremely-Low Income (ELI) has changed for the Section 8 program. HUD does not publish the 30% limits anymore. Be sure you enter the ELI into your software.

		Tip:You can find the Federal Poverty Level at the following website. http://aspe.hhs.gov/poverty/14poverty.cfm FYI: Poverty level is not defined for Puerto Rico ask your local authority for this information.
		Congress has changed the definition so ELI would never be less than the poverty level. So the above formula may not be necessary in the future.

• Income Targeting – Section 8 properties must ensure that no less than 40% of all new assistance (MI or IC) provided in a properties fiscal year is to residents who meet the definition of an ELI family. See handbook Revision 1, Change 4, Paragraph 4-25.

• Targeting compliance begins July1, 2015.

• TRACS Processing Order – Most people assume TRACS processes the files in date order. Your files are NOT processed in Date order. To make sure your files are processed in the order you desire you must know a few things about how TRACS processes their files.

• Mass file processing begins at night and processing of all received files continues as time allows. All file processing stops when TRACS runs out of time. During the first 10 days of the month all files are not guaranteed to be processed each night and ready the next day.

• Undesirable results may occur if you transmit more than one partial certification for a unit on the same day. For example: EIV discovery requires you to go back 3 years. You enter corrections to the past three years of certifications, as needed. When you are done you could have 2-3 Gross Rents; 1 or more transfers and one or more Terminations and several AR, IR, IC certifications. If you send them all on the same day TRACS may end up with the wrong current certification or even wrong unit. Here is the TRACS file processing order.

• 1. Processes Move-Outs first (MAT 40).
• 2. Followed by terminations (MAT 65)
• 3. Followed by full certifications (MAT10)
• 4. Followed by unit transfers/Gross rents (MAT 70)

		Files are not processed in Date order or in Unit order. Multiple certifications for a household bundled in the same TRACS transmission may not give you the result you want. For example: A UT and a subsequent AR transmitted at the same time may fatal because the Unit number does not match the previous certification. See the order, above, Full Certifications #3 are processed before UT #4.
		Tip:If you have multiple partial certifications or a mixture of partial and full certifications for a household, never send them on the same day. Spread them out over one or more days. TRACS considers the last partial certification processed to be the most current. Wait for a response before sending the next batch of certs.

• Residents without a Social Security Number (SSN) – If a resident, including children, foster children, adults, live-in aides and “None of the Above”, enter all 9’s.

• You must enter a “SSN Exception” code if the resident does not have a SSN.

Tip:You will be sent a Temporary “T-ID” number from your CA. If you cannot find it and need to know the T-ID you can call the Help Desk or query EIV for “Failed EIV Pre-Screening Report”.

• Vouchers

• End of Paper Submission – This is at the discretion of the CA. It is not required that you stop sending paper vouchers. You should continue to send paper until your CA agrees that paper submissions are no longer required.

• Voucher Reconciliation Report – is still required. CA’s will continue to send the Reconciliation Report under 202D.

• You may need to check your “Tracs Inbox” in your software more frequently. The MAT error files for MAT 10’s have not changed.

• The CA may send out one or more “Preliminary” Voucher Final Payment files. Or, at the discretion of the CA, may choose to only send a “Final” file.

• The CA will send out a Final Payment Voucher File when the CA is ready to submit the voucher for payment. This file will include an expected payment date.

• The error files for Voucher Mat 30’s are new and will display the raw information from the Regular Assistance and Adjustments with a new field “Paid Amount”.

• Miscellaneous Account Request codes have been revised and you will NOT be allowed to submit “Repayment agreements” using OARQ.

• Repayment Agreement

• Repayment agreement reporting to TRACS is complicated, in my opinion. The moderators explained one question I had been uncertain about. “How to change the Agreement Amount”. To help understand this you must know that the Agreement Amount has nothing to do with the Amount Requested. What is important is the Amount Requested. To enter or correct the Agreement Amount: Enter a new Agreement Amount with a zero (0) Change Amount. The Zero Change Amount tells TRACS this is a correction to the Agreement Amount.

• The report “Repayment Agreements for Schedule of Tenant Assistance Payments Due” or HUD 52670-A part 6 does not total from left to right. Many users, including myself, always try to total from left to right. You are not crazy it just doesn’t total this way.