Contract Administration N J H M F A Anthony Marchetta Executive

Transcription

Contract Administration N J H M F A Anthony Marchetta Executive
05/10/2016
N J H M F A
New Jersey Housing Mortgage and
Finance Agency
Contract Administration
Anthony Marchetta
Executive Director
2016 JAHMA Spring Management Event
Michael Floyd
Chief of Program Services
Francis A. Thomas
Director of Contract Administration
“Spring Management Event 2016”
Contract Administration Staff
Contract Administrator Team
Adonica Watkins, Manager
Kim Cunningham
Rick Griffiths
Laura Hallam
Schelika Muniz
Diana Page
TRACS Team
Jonelle Stewart, Manager
Maryann Crawley
George Long
Andrea Schrum
Toni Stewart
The Changes in the HAP Contract Renewal Process for Mark up to Market Contract Coordinators
Richard Dyer
Nicholas Meremianin
Subsidy Accountants
Shoba Narayan,
y , Manager
g
Sruti Swami
Debra Kauffman
Nagy Srinivasulu
Presented by Contract Coordinator: Richard Dyer
Project Assistants
Alicia Nicholson
Dana Belgrave
3
Changes to the Mark up to Market HAP Contract Renewal Process
• When you request a Rent Comparability Study (RCS) from your appraiser, have them verify that the adjusted rents are within 140% of the Median Rents. If the new rents fall below the 140% of Median Rents then a HUD RCS will not be required. Instead the Owner’s RCS will get a Substantive Review by the Agency’s 3rd party appraiser. The Median Rent Table is located on the HUD website.
i
Th M di R
T bl i l
d
h HUD b i
• If the Adjusted Rents exceed 140% of the Median Rents, then processing will continue as it did prior to the change in the Renewal Guide. HUD will complete an RCS and it will be reviewed by the Agency’s 3rd Party appraiser. The new rents will be either the Owner’s RCS rents or 105% of HUD’s RCS, whichever is lower. Option #1A limitations
When submitting a request for Option #1A Mark up to Market be aware that the RCS adjusted rents will be capped at 150% of the Fair Market Rents (FMR). For a rental increase in excess of the 150% of FMR you will need to request Option #1B y
y
“Discretionary Authority”.
Option 1B requires the property to meet at least one of the following:
50% of residents are elderly, disabled or large families.
3% or less vacancy rate for the area.
Property is a high priority for the local community. 1
05/10/2016
Renewal Requests in excess of 5 Years
Any rental increase request in excess of five (5) years will need the approval of the project’ss HUD Account Executive. In the past project
HUD Account Executive In the past
approvals were granted by HUD management staff.
CONTRACT RENEWAL
FUNDING IS APPROPRIATED
BY CONGRESS. THE
AGENCY CAN NOT SPEED UP
THE FUNDING PROCESS.
CONTRACT RENEWAL
PAPERWORK MUST BE
RECEIVED AT THE
CONTRACT
ADMINISTRATION OFFICE AT
LEAST 120 DAYS PRIOR TO
CONTRACT EXPIRATION
Nicholas Meremianin
nmeremianin@njhmfa.gov
(609) 278-7414
Richard Dyer
rdyer@njhmfa.gov
(609) 278-8807
(609) 943-5707 fax
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3
05/10/2016
Time to Prepare For Your Management/Occupancy Review
Speaker: Adonica Watkins, Manager of Asset Management
HOUSINGAnywhere, NJ
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What Will We Do?
Discussion Topics
•
•
•
•
1. Contact Owner/Agent
2. Send a Confirmation Letter
3. Complete Research for MOR
for MOR
4. Receive Owner’s Questionnaire
CA MOR Review Process
HUD form 9834 – On Site Review
Management Review Report Management Review Report Follow‐up
5. Conduct On‐Site Review
6. Complete Summary Report
7. Close the On‐Site Review
8. Report to HUD
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How Will We Do It?
Preparation for the Visit –
Research by the CA  Form HUD-9834,
Management Review
 Conduct a Limited Management/Occupancy Review
• Perform Physical Inspection Follow‐Up
Review Policies &
• Review Policies & Procedures
• Test of Tenant File Documentation
• Fair Housing Monitoring
 Form HUD‐9834 Management Reviews of Multifamily Projects
– PART I – Desk Review
– PART I – Desk Review
– PART II – On Site
Review
– Addendum A – Tenant
File Review Worksheet
– Addendum B – On Site
Limited Monitoring and
Section 504 Reviews
– Addendum C – Collect
Documents
•
•
•
•
•
•
•
•
•
•
•
Property Type
Date of Initial HAP
Regulatory Agreement
P
Population Served
l i S
d
Income Limits
REAC Score
Current Rents
Contract Expiration Date
TRACS Compliance
EIV Reports
Resident Concerns
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A. General Appearance & Security
Discuss Operations Categories with Site Staff 1. Property Walk Thru
 Form HUD‐9834 –Management Reviews of Multifamily Projects
– PART II – On-Site Review Categories
•
•
•
•
•
•
• Grounds / Common Areas
– Are the project’s exterior and common areas clean, free of graffiti, debris and damage?
A. General Appearance and Security
B Follow‐up and Monitoring of Project Inspections
B. Follow‐up and Monitoring of Project Inspections
C. Maintenance and Standard Operating Procedures
E. Leasing and Occupancy
F. Tenant /Management Relations
G. General Management Practices
2 Security Evaluation
2.
Security Evaluation
– Has the project experienced break‐ins, assaults, vandalism within the past 12 months?
– What is the owner’s plan to remedy?
Reference: 24 CFR Part 5.703 – Physical condition
standards for HUD housing that is in decent, safe, sanitary
and in good repair
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B. Follow‐up and Monitoring of Project Inspections
C. Maintenance and Standard Operating Procedures
• Preventive Maintenance Schedule
• Procedures for Unit Inspection
• Daily Maintenance and Work Orders
1. Observe REAC Exigent Health and Safety Issues
– Confirm the deficiencies have been corrected
– Process for emergencies; workorder backlog
2. Random Sampling of REAC report deficiencies
• Vacancy Turnover
V
T
– Is there a schedule for correcting open deficiencies?
– Current Vacancy Rate
– Condition of Units Ready for Occupancy
3. Follow‐up and Monitoring of Lead Based Paint
– Properties housing children under 6, built prior to 1978
• Energy Consumption
– Any conservation measures in‐place
Reference: 24 CFR Part 5.703 (d,e,f) – Each dwelling unit
within a building must be structurally sound, habitable,
and in good repair.
Reference: 24 CFR Part 5.703 – Each building on the site must be
structurally sound, secure, habitable, and in good repair.
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32
A. General Appearance & Security
Discuss Operations Categories with Site Staff 1. Property Walk Thru
 Form HUD‐9834 –Management Reviews of Multifamily Projects
– PART II – On-Site Review Categories
•
•
•
•
•
•
• Grounds / Common Areas
– Are the project’s exterior and common areas clean, free of graffiti, debris and damage?
A. General Appearance and Security
B Follow‐up and Monitoring of Project Inspections
B. Follow‐up and Monitoring of Project Inspections
C. Maintenance and Standard Operating Procedures
E. Leasing and Occupancy
F. Tenant /Management Relations
G. General Management Practices
2 Security Evaluation
2.
Security Evaluation
– Has the project experienced break‐ins, assaults, vandalism within the past 12 months?
– What is the owner’s plan to remedy?
Reference: 24 CFR Part 5.703 – Physical condition
standards for HUD housing that is in decent, safe, sanitary
and in good repair
33
B. Follow‐up and Monitoring of Project Inspections
34
C. Maintenance and Standard Operating Procedures
• Preventive Maintenance Schedule
• Procedures for Unit Inspection
• Daily Maintenance and Work Orders
1. Observe REAC Exigent Health and Safety Issues
– Confirm the deficiencies have been corrected
– Process for emergencies; workorder backlog
2. Random Sampling of REAC report deficiencies
• Vacancy Turnover
V
T
– Is there a schedule for correcting open deficiencies?
– Current Vacancy Rate
– Condition of Units Ready for Occupancy
3. Follow‐up and Monitoring of Lead Based Paint
– Properties housing children under 6, built prior to 1978
• Energy Consumption
– Any conservation measures in‐place
Reference: 24 CFR Part 5.703 (d,e,f) – Each dwelling unit
within a building must be structurally sound, habitable,
and in good repair.
Reference: 24 CFR Part 5.703 – Each building on the site must be
structurally sound, secure, habitable, and in good repair.
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E. Leasing and Occupancy
E. Leasing and Occupancy
• Tenant Selection Plan – required topics
–
–
–
–
1)Project Eligibility Requirements
2)Income Limits
3) Application Procedures
4)Occupancy Standards
• Tenant File Review – Addendum A
 Review Rent Calculation and Documentation
 Enterprise Income Verification System
5)Unit Transfer policy
6)Section 504 and Civil Rights policies
7)Policy for opening & closing Waiting List
8)Eligibility of Students for S/8
– EIV users and Certifications
– Security of System Information
– EIV Policies and Procedures
– Use of Verification and Income Report
– Use of EIV & You Brochure
– Tenant Consent forms (HUD 9887/9887a)
• Waiting list –
– HUD Handbook required fields – and notes required for application processing
• Lease and Security Deposits
– HUD Model Lease/Approved Addendums
Reference: HUD Handbook 4350.3, Change 4 - Chapter 5 and
Chapter 9
Reference: HUD Handbook 4350.3, Chapter 4
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F. Tenant/Management Relations
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Discuss Operations Categories with Site Staff 1. Resident Conflict Resolution Process
 Form HUD‐9834 –Management Reviews of Multifamily Projects
– PART II – On-Site Review Categories
– Written, descriptive, clear policy for residents to follow
– Inclusive of Appeal Process
– Include chain of command and contact information
•
•
•
•
•
•
2. Provision of Tenant Services
– List the social services provided
– Is there a social service coordinator?
A. General Appearance and Security
B Follow‐up and Monitoring of Project Inspections
B. Follow‐up and Monitoring of Project Inspections
C. Maintenance and Standard Operating Procedures
E. Leasing and Occupancy
F. Tenant /Management Relations
G. General Management Practices
Reference: HUD Handbook 4381.5, Rev-2, Management Agent
Handbook
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40
B. Follow‐up and Monitoring of Project Inspections
A. General Appearance & Security
1. Property Walk Thru
1. Observe REAC Exigent Health and Safety Issues
• Grounds / Common Areas
– Confirm the deficiencies have been corrected
– Are the project’s exterior and common areas clean, free of graffiti, debris and damage?
2. Random Sampling of REAC report deficiencies
2 Security Evaluation
2.
Security Evaluation
– Is there a schedule for correcting open deficiencies?
– Has the project experienced break‐ins, assaults, vandalism within the past 12 months?
– What is the owner’s plan to remedy?
3. Follow‐up and Monitoring of Lead Based Paint
– Properties housing children under 6, built prior to 1978
Reference: 24 CFR Part 5.703 – Physical condition
standards for HUD housing that is in decent, safe, sanitary
and in good repair
Reference: 24 CFR Part 5.703 (d,e,f) – Each dwelling unit
within a building must be structurally sound, habitable,
and in good repair.
41
42
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C. Maintenance and Standard Operating Procedures
E. Leasing and Occupancy
• Preventive Maintenance Schedule
• Procedures for Unit Inspection
• Daily Maintenance and Work Orders
• Tenant Selection Plan – required topics
–
–
–
–
– Process for emergencies; workorder backlog
1)Project Eligibility Requirements
2)Income Limits
3) Application Procedures
4)Occupancy Standards
5)Unit Transfer policy
6)Section 504 and Civil Rights policies
7)Policy for opening & closing Waiting List
8)Eligibility of Students for S/8
• Waiting list –
• Vacancy Turnover
V
T
– HUD Handbook required fields – and notes required for application processing
– Current Vacancy Rate
– Condition of Units Ready for Occupancy
• Lease and Security Deposits
• Energy Consumption
– HUD Model Lease/Approved Addendums
– Any conservation measures in‐place
Reference: 24 CFR Part 5.703 – Each building on the site must be
Reference: HUD Handbook 4350.3, Chapter 4
structurally sound, secure, habitable, and in good repair.
43
E. Leasing and Occupancy
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F. Tenant/Management Relations
• Tenant File Review – Addendum A
1. Resident Conflict Resolution Process
 Review Rent Calculation and Documentation
 Enterprise Income Verification System
– Written, descriptive, clear policy for residents to follow
– Inclusive of Appeal Process
– Include chain of command and contact information
– EIV users and Certifications
– Security of System Information
– EIV Policies and Procedures
– Use of Verification and Income Report
– Use of EIV & You Brochure
– Tenant Consent forms (HUD 9887/9887a)
2. Provision of Tenant Services
– List the social services provided
– Is there a social service coordinator?
Reference: HUD Handbook 4350.3, Change 4 - Chapter 5 and
Chapter 9
Reference: HUD Handbook 4381.5, Rev-2, Management Agent
Handbook
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46
G. General Management Practices
G. General Management Practices
EIV PENALTY
Attachment 9 (HUD Notice 2013‐06): Assessing the Five Percent Decrease in Voucher Payment
1. Implementing New HUD Guidance
Description of Finding
– How do you implement changes in HUD policies and procedures
– Is there a copy of HUD Handbook Change 4 in office
Access to the EIV System
Owner does not have access to the EIV
system.
Use of the EIV System
Owner is not using EIV system at all
2. Staff Training
5% Decrease
Documents to be Provided
Assessed?
Owner Certification
Yes
Owner must obtain access and
provide documentation
N/A
Yes
Owner must follow procedures for
specific report
N/A
Multiple Subsidy Report, Indentity Verification Reports, Deceased Tenant Report, New Hires Report
– Does the owner have formal ongoing training for staff?
Owner has never printed the report.
Yes
Owner must print current report and Certify the report will be used as
show evidence he/she is actively
described in their policies and
working the report
procedures
Yes
Owner must obtain third party
verification of income from the
employer
Income Report
Tenant has provided pay stubs to
determine income but income has not
been verified through the EIV system or
employer
Certify the report will be used to verify
income or if EIV was not available the
file will be documented to reflect this.
Reference: HUD Handbook 4350.3, Change 4, Chapter 9 and HUD Notice 2013-06
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Discuss Operations Categories with Site Staff Addendum B‐Fair Housing Monitoring

Part A: Accessible Units/Program Accessibility, Sections I, II
and III
– 1. Forward Part A of Addendum B of the Checklist
to the Owner for completion prior to the on-site
management review.
– If Part A is not complete for the Contract
Administrator, the Owner must forward this
document to the HUD Multifamily Housing Office
y of the management
g
review.
within 10 days



 Form HUD‐9834 –Management Reviews of Multifamily Projects
– PART II – On-Site Review Categories
•
•
•
•
•
•
Part B: On Site Limited Monitoring Review
Part C: Section 504 Review (Completed by CA)
Part D: Documents Reviewer Should Obtain from Owner
– 2. During the Management Review the Contract
Administrator will complete Parts B & C and
collect the documents for Part D. At the initial use
of the form the CA will collect the documents to
forward to the HUD Multifamily Housing Office.
A. General Appearance and Security
B Follow‐up and Monitoring of Project Inspections
B. Follow‐up and Monitoring of Project Inspections
C. Maintenance and Standard Operating Procedures
E. Leasing and Occupancy
F. Tenant /Management Relations
G. General Management Practices
49
50
B. Follow‐up and Monitoring of Project Inspections
A. General Appearance & Security
1. Property Walk Thru
1. Observe REAC Exigent Health and Safety Issues
• Grounds / Common Areas
– Confirm the deficiencies have been corrected
– Are the project’s exterior and common areas clean, free of graffiti, debris and damage?
2. Random Sampling of REAC report deficiencies
2 Security Evaluation
2.
Security Evaluation
– Is there a schedule for correcting open deficiencies?
– Has the project experienced break‐ins, assaults, vandalism within the past 12 months?
– What is the owner’s plan to remedy?
3. Follow‐up and Monitoring of Lead Based Paint
– Properties housing children under 6, built prior to 1978
Reference: 24 CFR Part 5.703 – Physical condition
standards for HUD housing that is in decent, safe, sanitary
and in good repair
Reference: 24 CFR Part 5.703 (d,e,f) – Each dwelling unit
within a building must be structurally sound, habitable,
and in good repair.
51
52
C. Maintenance and Standard Operating Procedures
E. Leasing and Occupancy
• Preventive Maintenance Schedule
• Procedures for Unit Inspection
• Daily Maintenance and Work Orders
• Tenant Selection Plan – required topics
–
–
–
–
– Process for emergencies; workorder backlog
1)Project Eligibility Requirements
2)Income Limits
3) Application Procedures
4)Occupancy Standards
5)Unit Transfer policy
6)Section 504 and Civil Rights policies
7)Policy for opening & closing Waiting List
8)Eligibility of Students for S/8
• Waiting list –
• Vacancy Turnover
V
T
– HUD Handbook required fields – and notes required for application processing
– Current Vacancy Rate
– Condition of Units Ready for Occupancy
• Lease and Security Deposits
• Energy Consumption
– HUD Model Lease/Approved Addendums
– Any conservation measures in‐place
Reference: 24 CFR Part 5.703 – Each building on the site must be
Reference: HUD Handbook 4350.3, Chapter 4
structurally sound, secure, habitable, and in good repair.
53
54
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05/10/2016
E. Leasing and Occupancy
F. Tenant/Management Relations
• Tenant File Review – Addendum A
1. Resident Conflict Resolution Process
 Review Rent Calculation and Documentation
 Enterprise Income Verification System
– Written, descriptive, clear policy for residents to follow
– Inclusive of Appeal Process
– Include chain of command and contact information
– EIV users and Certifications
– Security of System Information
– EIV Policies and Procedures
– Use of Verification and Income Report
– Use of EIV & You Brochure
– Tenant Consent forms (HUD 9887/9887a)
2. Provision of Tenant Services
– List the social services provided
– Is there a social service coordinator?
Reference: HUD Handbook 4350.3, Change 4 - Chapter 5 and
Chapter 9
Reference: HUD Handbook 4381.5, Rev-2, Management Agent
Handbook
55
56
G. General Management Practices
G. General Management Practices
EIV PENALTY
Attachment 9 (HUD Notice 2013‐06): Assessing the Five Percent Decrease in Voucher Payment
1. Implementing New HUD Guidance
Description of Finding
– How do you implement changes in HUD policies and procedures
– Is there a copy of HUD Handbook Change 4 in office
Access to the EIV System
Owner does not have access to the EIV
system.
Use of the EIV System
Owner is not using EIV system at all
2. Staff Training
5% Decrease
Documents to be Provided
Assessed?
Owner Certification
Yes
Owner must obtain access and
provide documentation
N/A
Yes
Owner must follow procedures for
specific report
N/A
Multiple Subsidy Report, Indentity Verification Reports, Deceased Tenant Report, New Hires Report
– Does the owner have formal ongoing training for staff?
Owner has never printed the report.
Yes
Owner must print current report and Certify the report will be used as
show evidence he/she is actively
described in their policies and
working the report
procedures
Yes
Owner must obtain third party
verification of income from the
employer
Income Report
Tenant has provided pay stubs to
determine income but income has not
been verified through the EIV system or
employer
Certify the report will be used to verify
income or if EIV was not available the
file will be documented to reflect this.
Reference: HUD Handbook 4350.3, Change 4, Chapter 9 and HUD Notice 2013-06
57
58
Addendum C ‐ Checklist
Addendum B‐Fair Housing Monitoring

 In addition to Documents from Addendum B; your CA will require a List of documents to be copied and available to take back to the AGENCY.
Part A: Accessible Units/Program Accessibility, Sections I, II
and III
– 1. Forward Part A of Addendum B of the Checklist
to the Owner for completion prior to the on-site
management review.
– If Part A is not complete for the Contract
Administrator, the Owner must forward this
document to the HUD Multifamily Housing Office
y of the management
g
review.
within 10 days



– General Documents such as:
•
•
•
•
•
•
•
•
•
•
•
•
•
Part B: On Site Limited Monitoring Review
Part C: Section 504 Review (Completed by CA)
Part D: Documents Reviewer Should Obtain from Owner
– 2. During the Management Review the Contract
Administrator will complete Parts B & C and
collect the documents for Part D. At the initial use
of the form the CA will collect the documents to
forward to the HUD Multifamily Housing Office.
59
Copy of pages of the Waiting List
Application
Lease and addendums
3rd Party Verification forms
Pet Policy
Applicant Rejection Letter
Unit Inspection forms
Work Order form
Fact Sheet
Acknowledgement form “Resident Rights & Responsibilities”
Lead Based Paint Certification
Income Targeting Tracking Log
EIV Certifications and Policies
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Management Review Report
On Site Exit Interview
EXIT INTERVIEW -
 At the Conclusion of the Management Review…
NJHMFA Contract Administration
Property Name(s)
Type Review Conducted:
Management Review
• All inclusive report of Management Occupancy Review findings, observations and corrective actions. actions.
• When an EIV penalty is present, the report reflects the finding and the corrective actions.
• Prepared and mailed to the Owner and Agent within 30 days of the management review performance date.
Occupancy Review
Review Conducted Date:
 Acknowledge Attendees
 Discuss observations, Discuss observations
conclusions and urgent issues
 Advise on the written report to be mailed within 30 days and any corrective action follow‐up ATTENDEES:
Name
DATE:
Title
Signature:
Findings/Observations Discussed:
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Management Review Follow‐up
Management Review Rating and Appeal Process
• The Owner must provide a plan for correction to each noted finding within thirty (30) days of the report receipt. • The EIV Penalty will be cured by obtaining access to and/or using EIV. • The penalty can only be removed when the The penalty can only be removed when the
property can demonstrate access to and use of the EIV system with all the supporting documentation
• The O/A will make an adjustment to the next scheduled voucher to collect the funds previously returned to HUD.
• Guidance on performance indicators, rating descriptions and appeal procedures is provided in HUD H db k 4350 1 REV 1 Ch
Handbook 4350.1, REV‐1, Change 2, 2
Chapter 6, Para 6‐11.
• When a Below Average or Unsatisfactory rating is determined, the owner/agent has an opportunity to appeal. 63
Management Review Follow‐up
64
Closure of the Management Review
• The Contract Administrator must conduct follow‐up activity until all corrective actions as required in the Summary Report have been completed. • The Contract Administrator will send a letter requesting a response to open deficiencies and transmission of tenant data required for corrections
transmission of tenant data required for corrections regarding rent calculation errors.
• If the EIV Penalty is not cured during the 30 day period following the mailed report, both the owner and the management agent, if applicable, will be flagged in HUD’s Active Partners Performance System (APPS). Once the finding is cured, the flags(s) will be removed. • For lower ratings pertaining to tenant files, a follow‐up Occupancy review may be required to ensure corrections are applied to 100% of tenant files.
• The Satisfactory progress on corrections yp g
required for 100% of tenant files will not change the overall MOR rating. • A close‐out letter will be sent to the Owner/Agent upon completion of all Management Review Report corrective actions. 65
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NJHMFA ‐ Contract Administration –
Contract Administrator Contact Information
Name
Phone Number
Email Address
Fax Number
Adonica Watkins,
(609)278‐8817
awatkins@njhmfa.gov
(609)943‐5707
(609)943‐5707
Mgr. of Asset Mgmt.
Diana Page
(609)278‐8815
dpage@njhmfa.gov
Kim Cunningham
(609)278‐7638
kcunningham@njhmfa.gov
(609)943‐5707
Laura Hallam
(609)278‐8821
lhallam@njhmfa.gov
(609)943‐5707
Rick Griffiths
(609)278‐7543
rgriffiths@njhmfa.gov
(609)943‐5707
Schelika Muniz
(609)278‐8813
smuniz@njhmfa.gov
(609)943‐5707
The Contract
Administration
Division Thanks You for Your
Time and Attention.
67
Q&A
SESSION
12