EIV Site Manager Reference Manual

Table of Contents

Introduction

Discrepancies and Discrepancy Log

Initial Implementation of EIV

Existing Tenant Report

Failed Verification Report

Meeting with the Resident

Deceased Tenant Report

New Hires Report

Reporting at Annual Certification, Interim Certification and Unit Transfer

Income Report

Social Security Benefits

Wage and Unemployment Data From NDNH

Existing Tenant Report & Multiple Subsidy Report

EIV Discrepancy Reporting

Income Discrepancy Report

Effective Date for Changes in Household Rent/Assistance for Interim Certifications Initiated as a Result of Income Discrepancy Investigation

Questions

EIV Discrepancy Log

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Introduction

Use of EIV Reports reduces the overall burden of verification of income claimed by residents. EIV Income Reports can be used as 3rd-party electronic verification as prescribed by HUD. These reports are to be used for applicable HUD programs only as described in the EIV Security Policy. The EIV data of an adult household member may not be shared (or a copy provided or displayed) with another adult household member, unless the individual has provided written consent to disclose such information. You are not prohibited from discussing with the HOH and showing the HOH how the household’s income and rent were determined based on the total income reported and verified.

Under no circumstances will EIV be used as a tool to verify or monitor compliance for other programs such as Tax Credits (Section 42) or Rural Development (515).

Use of EIV for Income and Discrepancy Reporting is part of HUD’s initiative to reduce errors in assistance calculations and payments. Introduction of this new tool requires Management to develop policies to ensure consistent action when discrepancies are reported. Following written policies and procedures will ensure that residents are treated in a fair and consistent manner.

New documents have been created to facilitate use of EIV consistent with HUD requirements. Reference resources include but are not limited to:

  • HUD Notice 08-03Enterprise Income Verification (EIV) System issued June 25, 2008
  • Resolving Income Discrepancies between Resident-Provided and Enterprise Income Verification (EIV) System Income Data, dated May 2008
  • Multi-household Enterprise Income Verification Training December 16 & 17, 2008
  • HUD Handbook 4350.3 Revision 1, Change 2

Reports will be produced, secured and maintained in accordance with the EIV Security Policy.

Discrepancies and Discrepancy Log

When information in EIV indicates potential errors in the eligibility determination or assistance calculation, documentation of the investigations of such errors will be maintained in:

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  • The resident/applicant file
  • The EIV Discrepancy Log

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The EIV Discrepancy Log is used to record EIV discrepancies throughout the year. Since all EIV errors are not the result of errors in TRACS, it is helpful to maintain a record of response to errors in one place. The EIV Discrepancy Logwill be maintained for each year and at the end of each year, will be placed in front of the locked file drawer designated for EIV folders. Information tracked in the EIV Discrepancy Log includes:

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  • HOH Name
  • Unit Number
  • Name of Member with Discrepancy
  • Brief Description of Discrepancy
  • Date Notice Sent
  • Date Meeting Scheduled
  • Resolution
  • Close Date
  • Miscellaneous Notes

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More detailed information is maintained in the applicant/resident file. The EIV Discrepancy Log is attached to this policy and also available on the HUD only website page.

Initial Implementation of EIV

EIV has been provided as a way to identify errors in income reporting and assistance calculations. Because information provided in EIV was previously unavailable, Management will review and, if necessary, investigate information for all households upon initial implementation of EIV. This review must be completed within 90 days of initial implementation of EIV on 1/31/2010. Identity and income discrepancies should be discussed with residents. If appropriate, new certifications will be generated and “assistance paid in error” will be returned to HUD in compliance with HUD Handbook 4350.3 Revision 1, Chapter 8 and subsequent HUD communications. If Management discovers that any resident has violated the lease or HUD regulations, appropriate action will be taken, up to and including termination of assistance and/or tenancy and pursuit of fraud after discussion with your Regional Manager.

ANY EIV REPORTS THAT ARE RUN, SHOULD BE PRINTED OUT AND PLACED IN THE LOCKED FILE DRAWER WHERE EIV FOLDERS ARE MAINTAINED. THESE REPORTS MAY BE REQUESTED DURING A MOR.

Existing Tenant Report

Currently, there is only one EIV report available that provides information about applicants. This is the Existing Tenant Report. Management uses this report during the final eligibility interview. All applicants MUST disclose if they are currently receiving HUD housing assistance. Management will not knowingly assist applicants who will maintain a residence in addition to the HUD-assisted unit. HUD provides Management with information about an applicant’s current status as a HUD housing assistance recipient. Management will use the Existing TenantReport, during the final eligibility review,to determine if the applicant or any member of the applicant household may be receiving HUD assistance.

Since the applicant is required toprovide current landlord information on the application, Management should be aware of the housing assistance. Nothing prohibits a HUD housing assistance recipient from applying to this property. However, the applicant must move out of the current property and/or forfeit any HUD voucher before HUD assistance on this property will begin. Special consideration applies to minor children where both parents share 50% custody. Please talk to your Regional Property Manager in these circumstances.

The report gives Management the ability to coordinate move-out and move-in dates with the resident and the PHA or owner/agent of the property at the other location. Managementwillfollow-up with the respective PHA or owner/agent to confirm the individual’s program participation status before admission.

If the applicant or any member of the applicant household fails to fully and accurately disclose rental history on the application, the applicant may be denied based on “misrepresentation” of information. If Management discovers a discrepancy, the applicant will be notified and will have 14 business days to respond to the inquiry. Failure to respond to owner/agents requests for additional information and/or providing false or incomplete information will result in denial and removal from the waiting list in accordance with the property’s current resident selection plan. Unintentional errors that do not cause preferential treatment will not be used as a basis to deny assistance.

Failed Verification Report

This report identifies household members who failed the SSA identity match due to invalid personal identifiers.

  • Incorrect Social Security Number and/or
  • Date of birth and/or
  • Incorrect last name

Management will review the resident file to determine if a simple data entry error caused this discrepancy. If Management discovers a data entry error, the corresponding 50059 must be corrected within 30 days and the new, corrected, signed 50059 must be transmitted to the Contract Administrator and/or HUD.

Meeting with the Resident

If the discrepancy cannot be addressed after a simple file review, Management will contact the affected residentand notify him/her that theSocial Security Number, date of birth and/or last name are producing discrepancies. The resident will have 10 business days to respond to the notice. Failure to respond will result in termination of assistance and/or tenancy as appropriate. During the meeting, Management will discuss the discrepancy with the resident. In some cases, Management may request additional verification of the information provided. Management has the right to determine the truthfulness of the verification documents provided after discussing the documents with your Regional Manager if you doubt their accuracy. If the information provided by the resident was inaccurate, Management will issue a notice of “material lease violation” and begin the process to terminate assistance and/or tenancy as appropriate. Unintentional errors that do not cause preferential treatment will not be used as a basis to terminate assistance and/or tenancy.

Since providing a valid Social Security Number is an eligibility requirement for HUD programs, there may be cases where Management is required to attempt to recover subsidy paid in error. In these cases after discussing with your Regional Property Manager, you will:

  • Create/correct appropriate certifications
  • Request all “assistance paid in error” is returned to HUD in one lump sum
  • Require that all “assistance paid in error” is returned to HUD as scheduled in an executed re-payment agreement

If the resident refuses to sign the verification documents or attempts to refuse to return assistance paid in error, Management will take appropriate action up to and including termination of assistance and/or tenancy and pursuit of fraud.

If the resident claims that the information provided by EIV is inaccurate, the resident must sign appropriate verification release forms and assist Management in efforts to obtain verification of the information provided. Managementwill encourage the resident to contact the Social Security Administration to correct any inaccurate data in their databases.

Inthese cases, the Failed Verification Report will be printed and Management will note in the EIV DiscrepancyLog when the discrepancy was reviewed. Management will also describe contact with the resident and document efforts to communicate that he/she should attempt to resolve the discrepancy with the Social Security Administration in the resident file.

Since Social Security identification discrepancies can impact program eligibility, Management will maintain detailed information about discrepancy investigation and resolution. This information will be maintained in the resident file with the “Move-in” information so that the explanation is not inadvertently archived when files are purged. This information will also be documented in the EIV Discrepancy Log.

Deceased Tenant Report

This report identifies residents who are currently reflected in TRACS as existing/active residents and who have been identified by SSA as deceased. Management will confirm with the head-of-household, next of kin or emergency contact person to find out if the resident has passed away. If so, Management will create an interim 50059 to update the household composition and re-calculate assistance. Management will refer to HUD instruction provided in HUD Handbook 4350.3 when working with the resident and creating the interim certification.

In the case where the deceased resident is the sole member of a household, Management will process a HUD-50059 to terminate tenancy in accordance with the HUD Handbook 4350.3 and with HUD’s MAT Guide. The MAT Guide will be used as the reference when determining the termination of assistance and the move out date.

“For the death of the sole household member, enter the date provided by paragraph 9.12 E in HUD Handbook 4350.3 which requires that subsidy end on earlier of a) 14 days after the resident’s death; or b) the day the unit was vacated. In situations where the actual move out date is greater than 14 days after the death of the sole household member, enter the actual date but the site may only bill for subsidy through the 14 days.”

IfManagementverifies that the resident is not deceased, Managementwill encourage the resident to contact the SSA to get the discrepancy resolved. In some cases, Management may have to waive minimum rent if financial assistance is temporarily terminated.

Management will maintain detailed information about discrepancy investigation and resolution. This information will be maintained in the resident file with the “Move-out” information so that the explanation is not inadvertently archived when files are purged. This information will also be documented in the EIV Discrepancy Log.

New Hires Report

This report provides employment information for residents who may have started new jobs. The information in this report is updated monthly. Since most employers report information on new hires to their state within 30 days of the hire date, an owner/agent may know within 60 days whether a resident has started a new job. To ensure timely rent adjustments, this report will be reviewed on a MONTHLY basis.

Management will not deny, suspend, or reduce any benefits of a resident until HUD or the owner has taken appropriate steps to independently verify information relating to:

  1. The amount of the wages, other earnings or income, or unemployment compensation involved;
  2. Whether such resident actually has (or had) access to such wages, other earnings or income, or benefits for his or her own use; and
  3. The period (or periods) when, or with respect to which, the resident actually received such wages, other earnings or income, or benefits.

The first thing Management will do when there is undisclosed new employment, is investigate the resident’s requirement to report. The following resident reporting requirements are in place:

  • An adult member of the household who was reported as unemployed on the most recent certification or recertification obtains employment; or
  • The household income cumulatively increases by $200 or more per month
  • There is a change in household composition

If the household member identified in EIV’s New Hires Report was previously employed, Management will not contact the resident. Residents must be given the benefit of the doubt. Residents have no requirement to report a new job if the household cumulative income increases by less than $200 per month ($2400 per year) or if the household income decreases. In these cases, the discrepancy will be listed on the EIV Discrepancy Log and a note placed in the resident file to be discussed with the resident during the next certification interview. The actual printout should be placed in the locked file drawer reserved for EIV folders.

If a resident fails to report as required, the household will be provided with a notice, in accordance with HUD Handbook 4350.3. The household will be required to meet with Management or face lease termination. During the meeting, the resident will be asked if the information in EIV is accurate. If the information is accurate, the resident should sign appropriate verification release forms so that the hire date and income information can be verified with the employer. Based on the information provided, an interim certification will be created. The resident will be required to return to HUD any assistance paid in error. In these cases, after discussing with your Regional Property Manager, you will:

  • Request all “assistance paid in error” is returned to HUD in one lump sum
  • Require that all “assistance paid in error” is returned to HUD as scheduled in an executed re-payment agreement

If the resident refuses to sign the verification documents or attempts to refuse to return assistance paid in error, Management will take appropriate action up to and including termination of assistance and/or tenancy and pursuit of fraud. In addition, the resident will be provided with notice of material lease violation. Action will be taken based on our policy and procedure regarding material lease violation.

If the resident claims that the information is invalid, the resident must sign appropriate verification release forms. Management will contact the employer listed in EIV to verify the information provided by the resident. There can be several valid causes for errors that would preclude any action:

  1. Human error
  2. System Error (SSA/SSI/EIV/HHS)
  3. Identity Theft - If there is suspicion of identity theft, the resident should contact the Department of Justice and begin the process of reporting suspected identify theft.

Since failure to report changes in employment can impact the assistance calculation, you must maintain detailed information about discrepancy investigation and resolution. In the case of “New Hires” discrepancies, this information should be noted in the EIV Discrepancy Log and the resident notified of the discrepancy. Third party verifications should be sent out and normal verification processed followed to resolve the discrepancy. A note should be placed in the resident file as to the resolution of the discrepancy.

Reporting at Annual Certification, Interim Certification and Unit Transfer

Aside from the reports previously mentioned, EIV information will be reviewed for each resident household during the annual certification process. Reports will be produced and reviewed based on the following schedule.

Annual Certification Month / Discrepancy and Income Report
Viewed for Annual Certification
January / November 1-10
February / December 1-10
March / January 1-10
April / February 1-10
May / March 1-10
June / April 1-10
July / May 1-10
August / June 1-10
September / July 1-10
October / August 1-10
November / September 1-10
December / October 1-10

In addition, income reports will be reviewed by Management at:

  • Interim Certification - Residents are required to complete the Recertification Questionnaire before the Interview
  • Unit Transfer Request - Residents are required to complete the Recertification Questionnaire before the Interview

Income Report

The income report will be used to verify certain income/employment information as specified in this document. This report will be used as the preferred electronic 3rd party verification resource for this purpose per HUD’s instruction.

Social Security Benefits

The SSA match process begins at the beginning of each month with all of the data being loaded into EIV by the second week of the month. EIV retains the last eight actions processed by SSA for a resident. Social Security information provided by EIV includes: