| ID | Status | Date | Public/Private | Industry | AHACPA Contact |
|---|---|---|---|---|---|
| #7671 | Closed | public | Multifamily | Les Sparks |
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We work with a management company that manages 6 HUD projects (memory-assisted, specifically) The COO at the management company would like to implement a director of marketing and a director of nursing to oversee those functions for all 6 projects – I would generally agree both roles are necessary as the operations of these facilities require a high level of care (director of nursing) and their biggest hurdle in the past has been vacancies (director of marketing). In their roles, the two directors would only be working on the projects themselves, with no work being done for the management company. They would be on the management company’s payroll, but assuming proper documentation was maintained for allocating and invoicing these salaries to the projects, would these be allowable costs to the projects’ operations? Or are these costs that are really included in the management fees already being paid? I have looked at 4381.5 and 4370.2 and did not find any concrete answer one way or the other. Please let me know if you need more information. Anything you could let me know would be greatly appreciated. |
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From Les Sparks: In general the references used in your analysis are no longer applicable as HUD has issued new guidance specific to 232 entities. I have included below a portion of that guidance. It comes from Handbook 4232.1, Section II, Chapter 8 page 8. As far as I can tell this is the only guidance in the Handbook. Now there might be some question as to whether the nursing supervisor is front-line or not. However, it may be harder to convince anyone of the front-line nature of the marketing person. I wish there was more clarity on this matter, but there is not. It appears some judgment is in order. The only definitive answer I. Staffing Levels: The Lender must provide a listing of the staff whose salaries will be paid from the project’s operating account. The list must include: Note: Salaries of Management Agent supervisory staff not assigned to the project must be paid from the management fee. Only full-time, front-line supervisors may be paid from the project account. The Lender must review job-titles, duties, and salaries of all employees to be working for the project to determine if the number, salaries, and duties of the proposed staff are reasonable for the size and type of the proposed project. The Lender must identify whether the proposed staffing levels are reasonable based on patient acuity, economies of scale of operations, state regulatory requirements, etc. |