Understanding EIV Part II HUD’s Enterprise Income Verification System

Understanding EIV Part II Set-up & Reminders: All Users must have their own WASS ID. This will not only allow you access to EIV, but also SAVE within the EIV system, TRACS, REAC, and iMAX. Instructions for obtaining a new WASS ID are in our EIV Policy as well as in the Policy and Procedures Manual, Volume I, Section I, page 61. EIV applies to the following Programs: Project Based Section 8; Section 202/8; Section 101 Rent Supplement; Section 202 PAC; Section 202 PRAC; Section 811 PRAC; Section 236; Section 236 RAP; Section 221(d)(3) BMIR

Understanding EIV Part II Intranet Reminders & Policy Updates: www.emcnet.biz Compliance/EIV. Updated EIV Policy dated 12/1/10. Updated UAAF form; with signatures for both Coordinators. EIV & You Brochure- required to be distributed to applicants at move-in when selected from the waitlist for screening, and existing residents at annual recertification. Rules of Behavior- required for all non-system users viewing EIV data at the property. Coordinator & Compliance Department Certification forms.

Understanding EIV Part II Requirements for Using EIV Data: Tenant Selection Plan- O/A’s must use the Existing Tenant Search in EIV as part of their screening criteria for new residents, and must include written policies for using the search in their Tenant Selection Plan. Policies and Procedures- O/A’s must have written policies and procedures for staff to follow for using the EIV Income Report as third party verification of employment and income, and for using the other EIV Reports (Income Discrepancy Report & EIV Verification Reports).

Understanding EIV Part II MOR Requirements: 1. O/A must have access to EIV. 2. O/A must be using EIV for recertifications effective 6/1/10. 3. Missing/incomplete EIV documents (Email HUD Headquarters immediately to Terminate coordinator’s/user’s access at the following address: mf_alert@hud.gov. Name, property, MOR date and missing documentation. Advise O/A mitigate and contact CA to reinstate access). 4. Rules of Behavior for non-system users must be used where applicable. 5. EIV data being shared with other entities, e.g., state officials monitoring tax credit projects, rural Housing staff monitoring Section 515 projects, or Service Coordinators.

Understanding EIV Part II MOR Requirements cont.: 6. EIV data must be kept secure. 7. O/A must update Policies and Procedures to include EIV use. 8. O/A must update Tenant Selection Plan to include use of Existing Tenant Search. 9. EIV Income Reports must be in tenant files as third party verification. 10. Tenant files must have documentation to support EIV income discrepancy resolution. 11. O/A must use Existing Tenant Search. 12. O/A must review New Hires Report. 13. O/A must resolve Failed Verification (SSA Identity Test) and Pre-Screening discrepancies.

Understanding EIV Part II MOR Requirements cont.: 14. Deceased Tenants Report must be reviewed and errors corrected. 15. Multiple Subsidy Report must be reviewed and errors corrected. 16. O/A must follow HUD’s record retention requirements. 17. Missing/Incomplete form HUD-9887. 18. O/A must provide tenants with the EIV & You Brochure when selected from waiting list to move-in, and at annual recertification. 19. Individuals having access to the EIV system or data must have annual security training. 20. O/A must NOT share WASS ID’s and passwords.

Understanding EIV Part II Category of MOR Findings: Category A Findings- these findings could affect the overall MOR score, as they are items relating to EIV which are included under existing occupancy requirements currently listed on the HUD-9834. O/A has not updated Policies and Procedures to include EIV use. O/A has not updated the Tenant Selection Plan to include use of Existing Tenant Search Report. Unresolved Failed Verification and Pre-Screening discrepancies. O/A is not following HUD’s record retention requirements. Missing/incomplete form HUD-9887.

Understanding EIV Part II Category of MOR Findings: Category B Findings- These findings will not affect the overall MOR score, but they will be listed as a finding on the MOR Report, and will need to be corrected in order to close the MOR. O/A does not have access to EIV. O/A is not using EIV for recertifications as of 6/1/10. Missing/incomplete EIV documents. Rules of Behavior for non-system users missing where applicable. EIV data being shared with other entities. EIV Income Reports are not in the resident files as 3rd party verification. Resident files do not have documentation to support EIV discrepancy resolution.

Understanding EIV Part II Category of MOR Findings: Category B Findings cont.- These findings will not affect the overall MOR score, but they will be listed as a findings on the MOR Report, and will need to be corrected in order to close the MOR. O/A is not reviewing the New Hires Report. Deceased Tenant Report has not been reviewed and errors corrected. Multiple Subsidy Report has not been reviewed and errors corrected. O/A is not providing residents with the EIV & You Brochure at move-in and recertification.

Understanding EIV Part II Consent for the Release of Information: Applicants: The form HUD-9887 Notice & Consent for Release of Information signed by the applicant and each applicant household member 18 years of age or older does not need to be on file in order to use the Existing Tenant Search in EIV at the time of application processing and tenant screening. Residents- A current form HUD-9887 must be on file before accessing the employment or income data contained in EIV for a resident. The form must be signed and dated by each adult member of the household; regardless of whether he or she has income.

Understanding EIV Part II Consent for the Release of Information cont.: If a resident turns 18, and has not signed the 9887, you must not use the Income Reports until the form is signed. Anyone turning 18 must come to the management office to sign the 9887 immediately. If the HUD 9887 has not been signed within 30 days of the household member turning 18, the household is in noncompliance with their lease, and assistance and/or tenancy may be terminated.

Understanding EIV Part II Consent for the Release of Information cont.: In addition to the 9887, a signed and dated form 9887-A must also be on file for each adult member of the household. This form authorizes the O/A to request information about the resident from a third party source. The form HUD 9887 is not required for accessing the Verification Reports. Both forms HUD 9887 & 9887-A limit the O/A from requesting information about the resident to “within the last 5 years when the tenant received assistance.”

Understanding EIV Part II Employment & Income Data Available in EIV Social Security Administration- Social Security (SS) benefits Supplemental Security Income (SSI) benefits Dual Entitlement benefits Medicare premium information Disability status National Directory of New Hires (NDNH)- New Hires (W-4) Quarterly wages for federal and non-federal employees Quarterly unemployment compensation benefits

Understanding EIV Part II Using EIV Reports Effective January 31, 2010, it is mandatory that O/A use the EIV system in its entirety. O/A must use the: EIV Income Report as a third party source to verify a resident’s employment and income during mandatory recertifications (annual & interim) of household composition and income & Other EIV Income Reports (Income Discrepancy Report, New Hires Report and No Income Report) to identify issues or discrepancies which may impact a household’s assistance & EIV Verification Reports (Existing Tenant Search, Multiple Subsidy Report, Identity Verification Report, and Deceased Tenants Report) that further assist in reducing subsidy payment errors.

Understanding EIV Part II Summary Report: This is a summary of household information from the current/active certification in TRACS. This report must be used at recertification. Resident file must contain the Summary Report as verification of the SSN for all household members whose status is “verified”. You must also document what was done to resolve a “failed” or “deceased” status. Retention time is term of tenancy plus 3 years.

Understanding EIV Part II Income Report: This report provides employment and income reported by HHS & SSA for each household member that passes the SSA identity test. This report must be used at recertification, and retained in the resident file. Run this report 90 days after move-in information is transmitted to TRACS. Resolve discrepancies within 30 days of the EIV Income Report date. Retention time is term of tenancy, plus 3 years.

Understanding EIV Part II Income Discrepancy Report: Identifies households where there is a difference of $2,400 or more in the wage, unemployment and SSA benefit information reported in EIV and TRACS. This report must be used at recertification. This report must be printed at the same time the income report is printed. Resolve discrepancies within 30 days of the EIV Income Report date. Retention time is term of tenancy, plus 3 years in the resident file.

Understanding EIV Part II No Income Report: This report identifies who passed the SSA identity test, but no income was reported. Recommend “zero” income residents be required to disclose and O/A re-verify income at least quarterly. Retention- any documentation or third party verifications for other income reported by the resident for the term of tenancy, plus 3 years in the resident file.

Understanding EIV Part II New Hires Report: This report identifies who has new employment within the last 6 months. This report should be run at least Quarterly. Retention- Tenant File- retain New Hires Detail Report, along with any correspondence and third party verifications, in the resident file for the term of tenancy plus 3 years. Master File- retain New Hires Summary Report in a Master “New Hires Report” file for 3 years.

Understanding EIV Part II Existing Tenant Search: This report identifies applicants who may be receiving assistance at another Multifamily or PIH location. This report should be run at the time of processing an applicant for admission. Retention- Applicant file- if not admitted, retain search results and any supporting documentation with the application for 3 years. Note: you are not required to run the Existing Tenant Search on an applicant already deemed ineligible by another applicant screening factor. Resident File- if admitted, retain search results and any supporting documentation with the application for term of tenancy, plus 3 years.

Understanding EIV Part II Multiple Subsidy Report: This report identifies residents who may be receiving rental assistance at more than one location. This report must be run at least Quarterly. You must search both queries: search within MF, and search within PIH. You must document the file to support any action taken if household member is receiving multiple subsidies. Retention- Tenant File- retain a copy of the report and documentation of action taken for term of tenancy, plus 3 years. Master File- retain report and supporting documentation in a master “Multiple Subsidy Report” file for 3 years.

Understanding EIV Part II Failed EIV Pre-Screening Report: This report identifies who has missing or invalid personal identifiers (last name, DOB, SSN) in TRACS. This report must be run at least Monthly. You must follow up with residents identified on the report where discrepant personal identifiers were not corrected at the time of recertification. You must correct TRACS data within 30 days of the date of the report. Retention- Tenant File- documentation to verify discrepant personal identifiers for term of tenancy plus 3 years. Master File- retain a copy of the report in a master “Failed Pre-screening Report” file for 3 years.

Understanding EIV Part II Failed Verification Report: This report identifies residents whose personal identifiers (last name, DOB, SSN) do not match the SSA database. This report must be run at least Monthly. You must correct TRACS data within 30 days of the date of the report. Retention- Tenant File- documentation to verify discrepant personal identifiers for term of tenancy plus 3 years. Master File- retain a copy of the report in a master “Failed EIV SSA Identity Report” file for 3 years.

Understanding EIV Part II Deceased Tenants Report: This report identifies residents reported by SSA as being deceased. This report must be run at least Quarterly. If deceased, within 30 days from date of report- update household composition, and income and allowances if applicable. Retention- Tenant File- Report along with HUD form 50059, plus any other documentation received must be retained for term of tenancy, plus 3 years. Master File- Retain a copy of the report in a master “Failed Pre-screening Report” file for 3 years.

Understanding EIV Part II Master File of EIV Verification Reports: To summarize- you are required to maintain a Master File of EIV Verification Reports. The reports should be maintained in a 3 ring binder, separated by report. Identity Verification Report- Monthly Failed EIV Pre-Screening Reports- Monthly Failed EIV SSA Identity Reports- Monthly Deceased Tenant Report- Quarterly New Hires Report- Quarterly Multiple Subsidy Report- Quarterly

Understanding EIV Part II Investigating and Resolving Income Discrepancies: Under the EIV rules we are required to investigate fully and resolve any discrepancies between the income the resident declared on their 50059, and the income that is displayed on the EIV Reports. Any income discrepancy greater than $2,400 in a year must be fully investigated, the correct income determined, and any overpaid subsidy recovered. Overpaid subsidy cases will result either in a repayment plan, termination of subsidy, or referral to the HUD Office of Inspector General for prosecution.

Understanding EIV Part II Investigating and Resolving Income Discrepancies: When you have a discrepancy, you must: Notify the resident of the discrepancy. Meet with the resident and request current documents (i.e.- pay stubs, original SSA benefit letter, etc. dated within 120 days) in accordance with HUD 4350.3. Request written third party verification of any income source that the resident disputes. Confirm effective dates of unreported income. Write a summary of the findings of the investigation, send the summary to the resident, and provide the resident the right to contest the findings. Determine any retroactive rent due in cases where management confirms the resident failed to report income. It is important to note that the overpaid subsidy must be repaid even if the resident’s income has gone back down, or has lost a job.

Understanding EIV Part II Investigating and Resolving Income Discrepancies: When you have a discrepancy, you must: Execute a repayment agreement with the resident, when the resident is unable to pay the amount due in full; in accordance with HUD 4350.3 Chapter 8. Adjust the rent, as necessary, in accordance with HUD 4350.3 Chapter 7. It is our Policy not to suspend, terminate, reduce make a final Denial of rental assistance or take any other adverse action against an individual based solely on the data from EIV. We are required to look carefully into any discrepancy and confirm the information we get from EIV.

Understanding EIV Part II Steps to follow after a discrepancy has been confirmed: Adjust the Tenant Rent to the proper rent for the first of the month following the final meeting with Tenant. If the Rent Underpayment is less than $300 issue the one time payment letter to the resident. (sample letter in Policy) For Rent Underpayment balances between $300 and $11,000, a repayment agreement will be set with the resident. For Rent Underpayment balances $11,000 or more you should consult your RPM/AVP/VP. Balances over $11,000 will be referred to the HUD Office of Inspector General for action and prosecution. We have the right to terminate subsidy if in our judgment and program rules the resident should lose their subsidy. All subsidy terminations have to be approved by the RPM/AVP/VP.

Understanding EIV Part II Penalties for Failure to use EIV as Required: If an O/A is not using EIV at the time of MOR, the O/A will: Receive a finding on the MOR Report. Incur a penalty of a 5% decrease in the voucher payment for the month following the date the violation was found. Be required to make an adjustment on the next scheduled voucher to adjust for the 5% decrease. Be monitored by the CA to ensure the adjustment was made.

Understanding EIV Part II Penalties for Failure to use EIV as Required: The O/A will have 30 days to cure the finding. If the finding is not cured during the 30 day period, both the Owner and Management Agent will be flagged in HUD’s Active Partner’s Performance System (APPS). Once the finding is cured, the flag will be removed.

Understanding EIV Part II Master EIV Folder : Each property is required to maintain a Master EIV Folder containing the following documents: UAAF (User Access Authorization Form)- an original and current form must be in the folder for each User at the property, as well as for all of the Compliance Specialists. Compliance Department UAAF’s are on the intranet. Your original UAAF is the handwritten form, and the current UAAF can be printed directly from EIV. Once you have logged into EIV select the link for “Authorization Form” from the left column menu to print your form.

Understanding EIV Part II Master EIV Folder cont. CAAF- (Coordinator Access Authorization Form)- an original and current form must be in the folder for both Edgewood Coordinators; Fred Mifflin & Traci Wallace. The original and current CAAF forms are on the intranet for both Coordinators. User Security Awareness Exam- an original and current Security Awareness Exam must be in the folder for all Users at the property. The original is the handwritten form, and the current can be printed directly from EIV. Once you have logged into EIV select the link for “Security Exam Report” from the left column menu to print your exam. You must also have the Security Awareness Exams for the Compliance Specialists. These forms are on the intranet.

Understanding EIV Part II Master EIV Folder cont. Coordinator Security Awareness Exam- an original and current exam must be in the folder for both Edgewood Coordinators; Fred Mifflin & Traci Wallace. The original and current Security Awareness Exams are on the intranet for both Coordinators. Owner Approval Letter- Each property must have an Owner Approval Letter for both Fred Mifflin & Traci Wallace. These are currently being updated, and all Owner Approval Letters will be placed on the intranet. Rules of Behavior- this form must be in your EIV Folder for those accessing EIV who are non-system Users. EIV Policy- a copy of Edgewood’s full EIV Policy must be in your EIV Folder for review.

Understanding EIV Part II Wrap-up & Reminders: Review the Updated Edgewood EIV Policy on the intranet. Make certain you have implemented and are using all required policies, forms and reports. Review HUD EIV Instruction Update Notice 10-10 for detailed information regarding how to use, and interpret all EIV Reports and requirements. Contact Traci Wallace twallace@emcmgmt.com with any questions regarding EIV. Be on the lookout for Understanding EIV Part III!!