59AI
File Compliance & Reviews

The Most Common MOR Findings (and How Reviewers Catch Them)

← All articles

Management and Occupancy Review findings cluster. Reviewers see the same failures property after property, which means you can predict most of your findings letter before the review happens — and eliminate it.

1. Certification and income errors

The dominant category, amplified by HOTMA: wrong asset treatment, outdated exclusions, effective-date errors, and math unsupported by the verifications in the file.

2. EIV procedural gaps

Reports not run on schedule, discrepancies never worked, missing EIV Use Policy, or access lists showing departed employees. EIV findings are pure process — no judgment calls, just done or not done.

3. VAWA documentation

Missing emergency transfer plan, 5380/5382 notices not delivered at required touchpoints (especially with termination notices), or confidentiality lapses.

4. Tenant selection plan deviations

The TSP says one thing; the waiting list shows another. Undocumented skips, screening criteria applied inconsistently, or a TSP never updated for HOTMA.

5. Lease and notice defects

Wrong lease versions, missing addenda, termination notices that don't meet content requirements.

6. Physical/maintenance documentation

Work order systems that can't produce records, missing unit turn documentation, or preventive maintenance that exists only verbally.

The pre-audit that mirrors the review

Reviewers sample files and test them against a checklist. Do exactly that yourself: pull a random sample monthly, score it against these six categories, and treat any repeated error as systemic. A property that self-audits this way walks into its MOR already knowing the answer.

Pre-auditing and hit a question? 59AI answers MOR and file questions instantly, with citations — $19.99/month.

FAQ

How many files does a reviewer pull? Sample sizes scale with property size and risk — assume enough that any systemic error will surface.

Are findings public? MOR ratings affect your standing with the contract administrator and can influence future participation — treat every review as reputationally material.


59AI's accredited courses train site teams to pass MORs, not just survive them.


Related articles