The Future of TRACS
BPR (Business Process Reengineering): For the past several years HUD/TRACS has been planning to do a full BPR whereby it examines all of its business rules and how it implements them with an eye to improvement. The effort has been combined with a similar one at HUD's office of Public and Indian Housing and has been put out to bid. The award of the contract is expected to occur soon.
One result of the BPR effort is expected to be a revamping of the TRACS system along with possible changes in the way TRACS processes and pays vouchers. A possible outcome is that paper and electronic vouchers would be eliminated in favor of TRACS generating payments based on certifications in its database. Should such a change come to pass, it would probably happen no earlier than several years from now.
In preparation for the BPR, TRACS awarded a contract to document all of the business rules embodied in the 4350.3; to indicate what TRACS currently does to enforce the rules; and to make suggestions for improvement. Jed Graef, IPM's Director of Compliance, was chosen to work on that effort along with some of the senior staff at TRACS. One outgrowth of that work was the publication of the specifications for the next set of TRACS updates that are summarized below.
A November TRACS update is planned to implement some changes that should not require a site software update.
- TRACS will no longer accept certifications for Section 8, RAP, Rent Supplement, and 202 PAC with a subsidy amount of $0 or a TTP that is greater than the gross rent. The expectation is that these tenants should be terminated.
- TRACS will implement the new handbook guidance on rents for police/security tenants. The old guidance was that the rent could not be less than 50% of contract rent. The new guidance is that the household should pay the subsidized rent except where the annual income is greater than the applicable Section 8 income limit. In that case the owner can set a rent that is not less than contract rent.
- When issuing an HQ termination (done when a tenant has not been recertified for 15 months), TRACS will terminate the household the day prior to the recertification date. Any subsidy collected past that date will need to be given back through a voucher adjustment.
TRACS Release 202B is currently scheduled for February 2005. Past practice has provided for a three-month window after the release where both the old and new format files are accepted. The primary focus of this release will be to implement handbook changes related to vouchers.
- This release of TRACS will finally implement the new HAP voucher forms published in November 2003 along with some formatting modifications still being discussed. As part of this change, owners will have to start reporting the number of abated units on each voucher but no longer will report the number of low-income units.
- The one tenant change in this release will be to implement upcoming guidance on tenants subject to the noncitizen rule who are currently subject to a temporary deferral of termination. HUD has determined that temporary deferral of termination no longer applies and that tenants should be paying the appropriate rent under the noncitizen rule. In many cases this will mean a prorated assistance and rent. In some cases a household will need to be terminated if nobody is eligible.
- For those with Section 202 or 811 group homes, HUD has committed to updating the contracts database such that contracts will be based on the number of residential spaces (subsidy slots) rather than the number of units. After this is done, you will no longer receive a discrepancy if you report more subsidized tenants than there are units in your contract for a group home.
- The voucher compliance percentage will be returned as part of the voucher message giving you the voucher id.
TRACS 202C will make many changes to data fields and TRACS edits for tenant certifications. The goal is to make TRACS compliant with the new 4350.3 HUD is talking about an August/September 2005 release date for this version.
- With this release owners will finally be able to report, at the household member level, the new race and ethnicity information they have been collecting for the past year.
- TRACS will start storing the number of anticipated children due to adoption or pregnancy along with the count of expected foster children. In addition a new household member special status code will be added allowing a child to be reported who, because of a shared custody agreement, is eligible for child care expenses but not for a dependent allowance.
- A future field in the TRACS file will be activated allowing sites to indicate when a new move-in or initial certification is subject to an eligibility waiver granted by HUD. In a similar vein, a do-not-check-eligibility flag will be added to deal with situations such as a contract combination where a tenant is not subject to the usual eligibility determination when they move to the new contract.
- A new Extenuating Circumstances field is being added to the certification. Using this field, owners will be able to report that a certification is late due to extenuating circumstances and have the certification accepted by TRACS and Contract Administrators--even if the tenant has been terminated for failure to recertify.
- Under 202C, divested assets will be reported with the date divested so that TRACS can determine whether the two-year period for reporting the asset has expired.
- TRACS is considering requiring the submission of limited data for market rate tenants so that it can better track inventory usage and spot cases where a household has more than one residence. It is not clear, at this time, whether or not this requirement will remain in the final specification, but it is being actively debated.
- TRACS is expected to require the submission of Social Security Numbers for all residents six years of age and older and less than 80. The only exceptions would be for ineligible noncitizens and live-in attendants and other non-family members. Certifications will be rejected that do not meet this requirement.
- More move-out and termination reasons will be available to choose from. HUD is interested in tracking the reasons in more detail than previously.
- HUD is considering requiring the new property to bill a tenant for assistance received at move-in if the former property submits a move-out effective on or after the move-in date. This proposal has generated some lively discussion and is not yet final.