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If you ever need a rent comparability study (RCS)—for a Section 8 contract renewal, for example, or to help substantiate an annual rent increase request—you don't want to simply take what the appraiser gives you and hand it off to your contract administrator or local HUD office.

You should first review it carefully, even though it will be reviewed again at the regional and national levels. You'll want to examine it because your sign-off indicates that you did, and because appraisers sometimes make mistakes.

With a majority of the original 20-year Section 8 contracts maturing, many site owners are facing the future with a different rental income situation than they've been accustomed to. For years, Section 8 owners received automatic annual rent increases. These increases, in many cases, put rents at levels that were not on par with market rents.

The ripple effects from an unsteady economy and uneven housing market continue to be felt in the assisted housing industry. Depending upon your geographic location and the type of housing your site includes, you're probably encountering vexing issues, such as ever-growing waiting lists for Section 8 units, market rents that have the potential to wreak havoc on your budget, and operating expenses that continue to climb. And still you must contend with HUD's expectations that you remain fiscally sound and adhere to regulations and requirements for occupancy and determining rents.

When it comes to marketing your site, HUD has one key expectation: that you will do what you said you were going to do when you completed your Affirmative Fair Housing Marketing Plan (AFHMP), Form HUD-935.2A. HUD calls the AFHMP “the owner's blueprint for marketing activity.”

It's a straightforward requirement from HUD: Conduct an inspection whenever a new resident moves in and complete an inspection report.

You can hope you never need the services of a collection agency, but it's likely that you will. Suppose a resident skips out without paying the share of his rent above his subsidy. You are entitled to pursue the resident within legal means to collect past-due debts. That's when a good collection agency can be invaluable.

HUD could reimburse your loss from past-due debt, via a special damage claim, but first you must demonstrate that you have taken “all efforts to collect the debt.” Working with a collection agency can show you are making that effort.

When new residents move in to your site, you should take steps to assure that they understand their responsibilities as outlined in their lease and house rules. While HUD does not require you to do this, HUD strongly encourages you to—and it is a good site management practice.

HUD addresses this issue in the HUD Occupancy Handbook 4350.3, REV-1, Chapter 6. Paragraph 6-27 specifically encourages site managers to hold a new resident “briefing” prior to occupancy.

Under the federal Fair Housing Act and HUD guidelines, you must make every effort to provide “reasonable accommodations” at your site for residents with disabilities. For example, if a resident with limited mobility requests a ground-floor unit, HUD expects that you would try to accommodate the request. If a prospective resident needs a larger unit than your occupancy standards dictate in order to provide space for a live-in aide, HUD wants you to attempt to provide the extra space.

From time to time, you may be asked by a resident to approve the addition of a “live-in aide” to his household. Reasons for the aide vary. The resident may have a disability and need help with day-to-day living. An elderly resident may need an aide for assistance and companionship to continue living independently. Federal law says that you are required to consider the request and, upon verification of the reason for the request, okay it as a “reasonable accommodation.”

You are required by HUD to have at least one smoke detector in every unit at your site. It's more than good common sense to take this safety step; smoke detectors can save lives.

Having the required smoke detectors in place also could save you down the road in a legal battle—but only if you have proof that you equipped your units with working smoke detectors. You can accomplish this by having a smoke detector policy that includes a section for your residents to sign to acknowledge that the detector is in place.