chapter 3. data collection, analysis, and documenting the rent calculation process

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Chapter 3. Data Collection, Analysis, and Documenting the Rent Calculation

Process

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Chapter 3. Section 1.Introduction

Learning ObjectiveGather, analyze and document information through

improved skill development in interviewing and analysis

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Introduction

• HUD programs rely greatly on voluntary disclosure by family

• PHA actions to reduce vulnerability– Critically analyze PHA intake and

reexamination processes– Work on improving the interviewing skills of

their staff– Train their staffs to analyze information

critically

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Introduction

• PHA actions to reduce vulnerability – Develop comprehensive data collection and

verification tools– Adopt policies that require relevant

documents to be provided by families– Make maximum use of UIV tools to prevent

and detect false statements and underreporting of income

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Introduction

• Steps in the rent calculation process:– Gathering data– Interviewing– Verification– Review and follow-up– Data entry and calculation– Maintaining files

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Introduction

• The steps are determined by the answers to three important questions:

– What information is needed for correct rent calculations?

– How will the information be verified?

– How will the information be processed and recorded?

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Chapter 3. Section 2.Step 1: Gathering Data

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Gathering Data: Forms

• For most PHAs, the admission or reexamination process begins when a “forms packet” is provided to the family

• The forms used for initial and annual certifications are most critical (application and recertification forms)

• RIM reviewers have found that many application and verification forms used by PHAs do not ask ALL necessary questions or questions are too vague to make accurate determinations of income and rent

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Gathering Data: Forms

• If the PHA’s forms do not ask ALL of the right questions clearly, staff may be unable to make correct income and rent determinations

• Forms should be reviewed for the 4 C’s: completeness, clarity, and compliance with current requirements

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Common Issues

• RIM reviewers have identified areas in which PHA forms may fall short:– Non-cash contributions: form only asks

about regular payment of a bill

– Disability assistance expenses: forms ask only elderly/disabled families about disabilities expenses or neglect to ask about the expenses entirely

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Common Issues

• RIM reviewers have identified areas in which PHA forms may fall short:– Medical expenses:

• PHA forms do not ask for anticipated medical expenses

• Forms are unclear about what is to be considered a medical expense

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Common Issues

• The questions may be flawed in these ways:

– Incomplete questions• “Does any employed family member pay

child care expenses for work?”

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Common Issues

• Missing questions:– No questions about divested assets– No question regarding qualifying factors

for EID purposes• Vague/confusing questions

– “Do you anticipate medical expenses in excess of 3% of your annual income for the 12 months following admission or reexamination?”

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Common Issues

• Forms may be out of date– Forms not revised to reflect changes in

regulations governing:• The Earned Income Disallowance• Training program income• Imputed welfare income

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PHA Application Form

• It should be comprehensive.

• It serves several important functions:– Critical to effective interviewing

– Ensures same questions are asked of all families

– Provides paper trail for false statements

– Is “proof” that questions were asked

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PHA Application Form

• Primary and secondary questions– Application form should ask two types

of questions:• Primary questions: These open up a topic

(i.e., a factor that affects income or rent)• Secondary questions: For additional

information about a topic

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PHA Application Form

• Sample application questions– Example 1 (page 3-6)

• Review questions• Each primary question is yes-or-no• Secondary questions are answered only if

response to the primary question is yes• Strength of this method is that applicant or tenant

must declare an answer to the primary question

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PHA Application Form

• Sample application questions– Example 2 (page 3-7)

• Review questions• Uses a statement rather than a question to open a

table• Uses a table to collect secondary information• PHA interviewers must ensure that no items are

left blank

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Sample Application Questions

• Review Sample Application Questions (pages 3-8 through 3-11)– Part 1: Income Information– Part 2: Assets– Part 3: Expenses– Review all questions and mark the ones that

are not included on the application form in your PHA. If you are not sure, compare when you go home.

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Sample Primary Questions by Topic

• Part I: Income Information• (Reexams only): Has anyone in your

household started a new job or had an increase in earnings? If yes, answer the following:• Has this person been unemployed 1+ years?• Is this person participating in any type of

economic self-sufficiency program?• Has this person received TANF in the past six

months, including one-time cash payments?

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Sample Primary Questions by Topic

• Part I: Income Information• Does any household member receive cash,

tips, bonuses, commissions, or any type of compensation for providing any type of services?

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Sample Application Questions

• TIP:– Many PHAs include questions pertaining to a

family’s current expenditures• Rent, electric, gas, water, telephone, car payment,

insurance, credit cards, medical bills, etc.• Allows comparison between expenditures and

current income• Creates opportunities for follow-up questions when

discrepancies and when families report zero income

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Gathering Data

• Learning Activity 3-1: Fix the Question (page 3-13)– Analyze Question #1 by responding to the

questions beneath it.– Be prepared to report results to group.– Questions #2 - #5: Take home

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Chapter 3. Section 3.Step 2: Interviewing

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Interviewing

• Interviewing is the most important skill in the housing process

• Interviews may either encourage or discourage compliance, cooperation and honest disclosure

• Initial eligibility interview is most crucial interview of all

• Interview training essential

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Interviewing

• To ensure consistency, interviewers should use a checklist

• Interviewers should have a “planned approach” to ensure consistency in the process– Pre-interview– Data collection – Analysis of the data collected– Closing the interview . . .

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Pre-Interview

• Interviewer sets the tone, builds trust

• Uses a checklist to establish ground rules for the interview (see Pre-Interview Checklist on page 3-20)

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Data Collection

• Focuses solely on gathering information from the family

• The interviewer asks all the questions pertaining to eligibility

• Documents the answer to each question

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Data Analysis

• The interviewer:– Evaluates the information and documents

provided by family to determine what needs to be verified

– Determines whether or not family must provide any additional documents or information

– Resolves any discrepancies between family’s statements and any UIV or other verification

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Closing the Interview

• The interviewer:– Reviews all forms with family– Obtains consent forms as needed– Provides family with written instructions about

any further information or documents that family must provide

– Answers any questions family may have– Provides any information family may need to

understand program rules and requirements

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Interviewing

• Some PHAs conduct reexaminations by mail– No regulatory requirement for face-to-face

interview

• If PHA does not interview family in person, completeness of application and reexamination forms is critical to income and rent determinations

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Interviewing

• Application or reexam form is generally used as a “template” for interview– Ask every question on form– Make sure all questions are answered (Do not

use n/a) – Make sure form is signed and dated by PHA

representative and family representative

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Asking the Right Questions

• Use global (open-ended) questions to get explanations. Who…? What…? Where..? How do you…? Why……?

• Use closed questions to get specifics. Do you? Is it? How much? How many?

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Probing Questions

• Use probing questions to get additional information about an issue – Clarifying – Resolving discrepancies

What do you mean by…..?

Could you explain how……?

Help me to understand this, how do you….?

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Probing Questions

• Probing questions may be very relevant when UIV conflicts with statements or documentation provided by family

• Example: SWICA report shows family employed last two quarters and family reports no employment– Where was the last place you worked?– How long were you there?– When did you leave?– (If not resolved, then ask “Can you explain . . . ?”)

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Avoid Multiple Questions

• Such as, “Do you have a checking or savings account or any type of investments such as an IRA or certificate of deposit”?

• They confuse some people

• They give others the opportunity to select the part of the question they want to answer or avoid

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Multiple Questions

• Good example of how to break down the questions:– Where do you bank?– What types of accounts do you have there?– What is the account number?– What is the account balance?– Do you have any other type of accounts at

this bank?– Are there any other banks you do business

with?

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Avoid Leading Questions

• You don’t have any income, do you?

• Everything’s the same as last year…right?

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Use “Mirror” Questions

• Reflect or restate a response

• Reflect or restate a scenario

• The purpose of “mirroring” or “reflecting” what an individual has said is to obtain confirmation, correction, clarification or amplification.

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Other Tips

• Allow adequate time for response• Don’t reword a question unless necessary

for accuracy or clarity• Avoid technical language or jargon• Educate while interviewing• Learn to ask the tough questions in a non-

threatening way– You don’t have to act tough to ask tough

questions

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Discussion Questions

• Do interviewers have a planned approach to the interview? (Pre-Interview Checklist)

• Do interviewers ask open-ended, inclusive questions vs. specific questions when exploring a topic?

• Do interviewers apply questions to all family members, even those not present at interviews?

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Discussion Questions

• Do interviewers review all types of income with families? For all family members?

• Do interviewers ask about excluded income? For all family members?

• Do interviewers review all types of assets with families? For all family members?

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Discussion Questions

• Do interviewers make families aware of all possible allowable expenses? For all family members?

• Do interviewers ask secondary questions regarding reimbursement of expenses claimed?

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Discussion Questions

• When increased earnings are reported, does staff determine:– Whether the individual meets any of the

criteria to qualify for earned income disallowance?

– Whether the individual is enrolled in a qualified training program?

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Interviewing

• Learning Activity 3-2: Situational Analysis(page 3-26)

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Chapter 3. Section 4.Step 3. Verification

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Verification

• Interviewer must be able to decide:– What additional documents are needed– What additional information must the applicant

provide– What must be verified to comply with HUD

requirements– What type of verification is needed

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Verification Forms

• Should be comprehensive, but not complicated

• Should ask secondary questions (are expenses reimbursed, etc)

• Should include a “false statement” statement

• Must include a signed authorization for release of information

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Verification Forms

• Should capture name, position, telephone number of information provider

• Should capture current and anticipated earnings and fluctuating pay rates and hours

• May want to consider including self-addressed stamped envelope with each verification form mailed out

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Verification

• We will discuss verification requirements in depth in the next session

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Chapter 3. Section 5.Step 4. Review and Follow-up

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Review and Follow-Up

• Verifications received from up-front sources and third parties must be compared to information provided by the family at the interview or in the application form

• In case of conflicting information, PHAs must:– Resolve any discrepancies by following up, as

necessary, with the third party, the family, or both– Document the resolution and leave a clear audit trail

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Discussion Question

• What procedure does your PHA follow when documents provided by the family conflict with up-front or other third-party verifications after the interview is over?– Example: Third-party employer form shows 20

hours per week employment, pay stubs show average of 25 weekly hours

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Discussion Question

• Possible answers from PHAs: – Always use the third-party verification– Always use pay stubs– Use the higher figure to avoid an overpayment– Use the lower figure to benefit the applicant or tenant

• But what is the “right” answer???• The answer you get as a result of resolving a

discrepancy based on the facts you get.

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Review and Follow-Up

• When there is a conflict between family-supplied information, up-front verification, or written third-party verification, the PHA must:– Obtain additional information from family

and/or third party– Resolve the discrepancy– Document thoroughly to leave a clear audit

trail

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Chapter 3. Section 6.Step 5. Data Entry and

Calculation

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Data Entry and Calculation

• Documentation is the key– Anyone reviewing the file should be able to

understand how the rent was calculated– Calculation documentation could include:

• Printout from software system showing calculations

• Calculator tape• Narrative entry explaining calculations• Signed, dated notation attached to third-party or

UIV document if computer printout doesn’t show calculations

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Data Entry and Calculation

• PHAs should develop methods for comparing information in file to staff’s rent calculations

– Show relationship between figures on verification forms and figures on 50058, rent calculation worksheet or printout

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Data Entry and Calculation

• HUD recommends having a printed 50058 form in the file.

• Due to PHA policy or software issues, staff may not be able to print one. Instead, it is:– Advisable to print a worksheet or summary– Essential to understand what is shown on the

printout and where those numbers come from (which data entry fields)

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Data Entry and Calculation

• Staff should verify each completed calculation by comparing it to file data and checking for: – Data entry errors– Transposed numbers– Incomplete information (adult not coded as a

full-time student)– Missing information (second source of

income)– Carryover of previous errors (birth date, SSN)

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Data Entry and Calculation

• A worksheet may be completed by hand for comparison to a software calculation for some or all staff– Manual calculations sometimes catch errors

that otherwise might be overlooked• Also provide hands-on experience with process of

rent determination

• PHAs should review and correct mistakes identified in PIC error reports

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Chapter 3. Section 7.Step 6. Maintaining Files

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Maintaining Files

• Rent calculation procedures should include a standardized system for creating and maintaining all case files– Ensures consistency– Easier for staff to fill in for one another during

vacations or other absences– Saves time for supervisory reviews, audits

and/or monitoring visits

More…

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Maintaining Files

• Every case file should follow a standard format so that a reviewer can find the same items in the same place in each file.

• Checking to ensure that staff members are following the standard file format should be part of a supervisory quality control review.

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Maintaining Files

• Considerations for file layout:– How will you divide sections?

• Could divide sections for left & right sides of folder• Could use tabs or colored pages to divide sections

– Will you place frequently-used items at the front of the file or elsewhere?

– How will you delineate between reexams so it is clear which documentation goes with which reexam?

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Chapter 3. Section 8.Conclusion

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Conclusion

• PHAs need to do a step-by-step review and analysis of the rent calculation process as an error-reduction strategy– Identify policies, procedures and all other

tools involved in the rent calculation process– Determine whether those policies, procedures

and tools support correct income and rent determinations . . .

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Conclusion

• PHAs need to do a step-by-step review and analysis of the rent calculation process as an error-reduction strategy– Revise existing policies, procedures and tools

as needed– Create new policies, procedures and tools

when necessary– Ensure that staff is implementing policies &

procedures consistently and utilizing tools as needed

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Learning Objective

• Gather, analyze and document information through improved skill development in interviewing and analysis