Programme compliance, all 50 states
A perfect building with imperfect files
Inspections test the property. Programme compliance tests the paperwork behind it: who lives there, what they were certified at, what you claimed and whether you can prove it.
Most organisations only need two or three of these. Knowing which is the fastest way to stop reading guidance that does not apply to you.
Start here
Which compliance problem do you actually have?
Compliance failures announce themselves in fairly specific ways. Pick the symptom rather than the acronym and it usually points straight at the cause.
What this covers
The half of compliance that has nothing to do with the building
You can pass an inspection with a perfect score and still be non-compliant. Tenant files, income verifications, certifications, subsidy calculations and system submissions are a separate body of requirements, tested separately and enforced separately.
Getting them wrong is expensive in a specific way. Physical findings cost points. Programme findings cost money: repayment of subsidy claimed in error, withheld payments, penalties, and in serious cases the contract itself.
They also fail quietly. A property does not notice a documentation problem the way it notices a leak. It surfaces during a management review, a HUD audit, or a rejected submission, at which point it has usually been accumulating for a while.
The four programmes below cover the areas we are asked about most. Where physical condition is also in scope, and in an audit it almost always is, our inspection services and repair services handle that side, and consulting services covers the strategic questions around both.
Choose an area
All our compliance services
Four areas, and most organisations are subject to two or three of them. The selector above narrows it faster than reading all four.
HUD EIV Compliance
Enterprise Income Verification obligations: using the system correctly, resolving discrepancies properly, and documenting that you did. Most EIV findings are not about failing to check income. They are about being unable to prove the check happened.
HUD EIV complianceHUD HCV Compliance
Housing Choice Voucher administration: waiting lists, eligibility, briefings, subsidy determinations, and the inspection obligations that sit alongside them. The programme has more moving parts than any other and most findings come from process rather than intent.
HUD HCV complianceHUD TRACS Compliance
Certification and voucher submissions for project-based assistance, and the monthly cycle behind your subsidy payments. Rejected or late submissions delay payment, and repeated errors attract review on their own.
HUD TRACS compliancePBV Compliance
Project-Based Voucher requirements: HAP contracts, unit selection, subsidy limits, initial and periodic inspection obligations. PBV sits between the voucher and project-based worlds, which is exactly why it gets administered from the wrong rulebook.
PBV complianceHow we work
Four steps, whichever area applies
Establish which rules apply
Programme, contract type and role first. A surprising share of compliance findings come from following the right procedure for the wrong programme.
Review files as a reviewer would
A sample tested the way a management review or audit tests it, so you find the pattern before somebody external does and can act on it rather than defend it.
Fix the process, not just the file
Correcting twenty files is a day of work. Correcting the procedure that produced them stops the twenty-first. Written procedures, and evidence that they were followed.
Stay with it
Support through submissions, reviews and audits, including escort on the day and a written response where a finding is contestable.
Why one firm for both
Reviewers do not split records from condition
An audit examines your files and your building in the same visit, and reports on both. Splitting that work between a compliance consultant and a contractor means nobody is looking at the whole exposure.
We handle both halves, which also means the awkward overlaps get caught. An inspection obligation missed on a voucher unit is a compliance finding and a physical one at the same time, and it usually only shows up if the same team is looking at both.
- Records and physical condition reviewed together
- Programme requirements matched to your contract type
- Procedures documented, not just performed
- Escort and written responses during reviews and audits
- Remote file review where a site visit is not needed
Submissions being rejected, or a review coming up? A file sample tells you where you stand in days rather than months.
Not sure which of these apply to you? That is the first question we answer.
Questions
Compliance services FAQs
Which of these four applies to us?
It depends on your role. A housing authority administering vouchers deals with HCV and, where it has HAP contracts on specific units, PBV. An owner or agent of project-based assisted units deals with TRACS. EIV reaches both.
The selector near the top of this page narrows it from a symptom, which is usually faster than working it out from the acronyms.
Can we be non-compliant with a good inspection score?
Easily, and it is common. Programme compliance is a separate body of requirements, tested separately. A property in excellent physical condition with incomplete certifications is exposed, and the exposure is financial rather than a score.
What does a compliance finding actually cost?
Typically repayment of subsidy claimed in error, withheld payments while the issue is resolved, and administrative penalties. Serious or repeated findings reach contract standing.
That is the difference from a physical finding, which costs points and attracts closer attention. This side reaches the money directly.
Is this the same as a HUD audit?
No. Compliance work is the ongoing obligation. A HUD audit is an event that tests whether you met it, alongside physical condition.
Doing the first properly is what makes the second uneventful. If an audit notice has already arrived, start on the audit page.
Do you work remotely or on site?
Both. File and submission review is often better done remotely, on a sample, which is faster and cheaper than a site visit.
Where physical condition is in scope, or where a review or audit is happening in person, we attend.
Can you train our staff rather than doing it for us?
Yes, and for recurring findings it is usually the better purchase. Correcting files is temporary; changing how the person who creates them works is not.
On the physical side, inspector shadowing does the equivalent for maintenance staff.