During a Management and Occupancy Review (MOR), one common finding involves incomplete or incorrect citizenship documentation. Frequently, parents unintentionally fill out the citizenship form on behalf of their children incorrectly, often missing required signatures or selecting the wrong status type.

Each family member, regardless of age, must have appropriate documentation verifying citizenship or eligible immigration status. For minors, parents or guardians may sign on their behalf, but all entries must accurately reflect each child’s individual status as required by HUD Handbook 4350.3.

To avoid MOR deficiencies, property staff should:

• Review each household’s citizenship documentation before submission.
• Ensure that parents understand how to complete the forms for their children correctly.
• Maintain copies of verification documents in tenant files.
• Provide refresher training to staff on processing citizenship and immigration documentation.

Taking these small steps helps properties maintain compliance, protect subsidy eligibility, and prevent unnecessary findings during MORs.

Remember to review your current tenant files and verify that all citizenship documentation is complete and correctly signed before your next MOR. For questions or staff training resources, contact the CMS Compliance Team.