During tenant file reviews, Owner/Agents occasionally discover that required move-in documentation is missing, incomplete, or was never properly executed. While many file deficiencies can be corrected, certain documents are tied to a specific point in time and cannot be recreated after admission.

Attempting to recreate historical documentation may create inaccurate records, raise concerns regarding backdating, and fail to accurately reflect the circumstances that existed when the household was admitted.

When these situations occur, the recommended practice is to document the deficiency with a detailed Note to File that explains what is missing, why it cannot be reproduced, and any corrective actions taken.

Not every missing document should be recreated.
The following documents are examples of move-in records that generally cannot be recreated after move-in:

• Original Application
• EIV Existing Tenant Search
• Tenant Selection Plan Screening Documentation
• Move-In Inspection
• Move-In HUD-50059 (when a replacement is unavailable)

Instead of recreating these records, maintain a detailed Note to File documenting:

• The missing documentation
• When the deficiency was identified
• Why the document cannot be reproduced
• Any corrective actions implemented

Remember these best practices:

• Never backdate documents or signatures
• Do not recreate historical records using current information
• Clearly explain why documentation is unavailable
• Record when the deficiency was discovered
• Document process improvements to prevent future occurrences
• Maintain the Note to File for future audits, Management and Occupancy Reviews, and compliance monitoring

Proper documentation demonstrates transparency, supports good-faith compliance efforts, and provides valuable context during file reviews.

Examples of documentation that cannot be recreated include:

• Original Applications missing dates, times, or signatures
• Missing EIV Existing Tenant Search reports
• Tenant Selection Plan screening documentation
• Move-in inspection forms
• Original move-in HUD-50059 certifications

Important Reminder
If the Existing Tenant Search is unavailable, continue monitoring your Multiple Subsidy Report to identify any potential duplicate assistance issues.

Criminal history, drug-related screening, and sex offender screening must still be obtained if missing, even when discovered after move-in.

Review your move-in file documentation practices to ensure historical records are properly maintained and deficiencies are documented appropriately. Have a question? Reach out to us for help.