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Copyright 2016 Ross Business Development, Inc. Not for Duplication www.rbdnow.com 0 [email protected]

EIV BASICS A Review of HUD’s Enterprise Income

Verification System April 2016

Presented by: Mary Ross, CPO, FHC, MORS [email protected]

http://www.rbdnow.com/

mailto:[email protected]

http://www.leadingageny.org/leading-u/conferences/housing-professionals-annual-conference/

EIV Basics – Leading Age NY - April 2016


Copyright 2016 Ross Business Development, Inc.

All rights reserved. Not for duplication.

All other brands and product names are trademarks or registered trademarks of their respective

owners.

Printed in the United States of America

Ross Business Development, Inc.

3134 Shumard Way

Marietta, GA 30064

770-424-1806

www.rbdnow.com

Disclaimer

“The material contained in this document is not comprehensive of the continually emerging issues surrounding

policies in The Multifamily Housing industry. In addition, the handbook guidance is derived from The HUD

Handbook 4350.3 Rev 1 Change 4 released in August & December 2013 and subsequent notices, the TRACS MAT

Guide and the EIV Guides and Notices.

The student should understand that these training materials are not designed for, nor should be relied upon, as a

source of legal guidance or as a final authority with respect to any particular circumstance.

Ross Business Development makes no warranty of merchantability or fitness for a particular purpose or any other

warranty of any type with regard to these materials.

Owners and management should seek competent legal advice in developing and carrying out TRACS or EIV

policies and procedures.

While we have been diligent in our efforts to provide comprehensive and accurate regulatory training, Ross

Business Development shall not be responsible for errors or inaccuracies.”




HUD’s Enterprise Income Verification System

INTRODUCTION

The purpose of this lesson is to provide guidance on using the data in EIV for verifying the employment and income of individuals participating in one of Multifamily Housing’s rental assistance programs. Using the data in EIV will assist in reducing errors in determining a resident’s income, thereby reducing the number of improper payments in Multifamily Housing’s rental assistance programs. New documents have been created to facilitate use of EIV consistent with HUD requirements.

EIV POLICIES & PROCEDURES

Decide how you want to use EIV and then you must document your policy. HUD requires owner/agents to develop policies to ensure consistent action when discrepancies are reported. Developing written policies and procedures will ensure that residents are treated in a fair and consistent manner.

Reviewers will ask for a copy of your EIV Use Policy at each Management & Occupancy

Review. The Policy must explain: How data is secured

How resident privacy is protected

When you review each report

How you use the data provided in the report

EIV SECURITY

The owner or agent must ensure the security of EIV Data.

Before obtaining access to EIV, property owners were required provide an authorization letter stating that the owner of the property was giving authorization to someone who will act as the EIV Coordinator. The owner is required to provide such written authorization for each coordinator. This is done once for each coordinator.

TECHNICAL SAFEGUARDS

All individuals who have access to the EIV system must have a valid WASS User ID and password and must use this ID and password for accessing the EIV system. Upon receipt of the assigned WASS User ID, an individual must then apply to be approved for access to the EIV system.

Any person who is given access to EIV must complete the EIV Coordinator Access Authorization Form (HUD Form 90011) or the EIV User Access Authorization Form (HUD Form 90012) (Authorization Forms include the EIV Rules of Behavior).



RBD OTW – EIV Basics – March 2016


EIV Coordinators are certified by HUD once a year. The Coordinator must request such certification. If the Coordinator fails to do so, the EIV certification/authorization will expire and the Coordinator will no longer be able to access EIV data. EIV usually generates the message “no contracts assigned to this user.” EIV Users are certified by the property EIV Coordinator every six months. The Users must request such certification. If the User fails to request certification or if the Coordinator fails to certify the User, the EIV certification/authorization will expire and the User will no longer be able to access EIV data. EIV usually generates the message “no contracts assigned to this user.” Staff involved in the certification process that do not have access to EIV, but who do have access to EIV reports must sign an EIV Rules of Behavior Form. Independent Public Auditors (IPAs) performing the HUD financial audit will also view EIV reports when reviewing tenant files. These IPAs must also sign the EIV Rules of Behavior. IPAs must also sign an acknowledgement that they understand the rules about EIV reports. Restrictions on disclosure requirements for IPAs: (1) Can only access EIV income information within hard copy files and

only within the offices of the owner or management agent;

(2) Cannot transmit or transport EIV income information in any form;

(3) Cannot enter EIV income information on any portable media;

(4) Must sign non-disclosure oaths (Rules of Behavior for Non-system Users) that the EIV income

information will be used only for the purpose of the audit; and

(5) Cannot duplicate EIV income information or re-disclose EIV income information to any user not

authorized by Section 435(j)(7) of the Social Security Act to have access to the EIV income data.

A Security Awareness Training Questionnaire, which supplements required annual security training, must be completed at the time of initial access to the system and annually thereafter. The EIV system is designed to block the entry of those individuals who have not successfully completed the questionnaire (i.e., answered 90 percent of the questions correctly). Please note: this EIV functionality is currently disabled.

SECURITY AWARENESS TRAINING

If you use EIV, if you view EIV information of if you send TRACS files you are required to take Security Awareness Training annually as mandated by the Federal Information Security Management Act (FISMA) and Office of Management and Budget (OMB) Circular A-130.





This is not the same as completing the EIV Security Awareness Questionnaire.

1. Go to tp://iase.disa.mil/eta/index.html#onlinetraining.

2. Click on Cyber Awareness Challenge

3. Either Launch or Continue the training

4. Print the certificate once the training is complete

The requirements are for:

Any EIV User who has access to or uses EIV and

completed the EIV User Access Authorization Form

Any EIV Coordinator who has access to or uses EIV

and completed the EIV Coordinator Access

Authorization Form

Any person who may ever be involved in the

certification process so that they might have access to

EIV reports (this includes people who are doing filing,

etc.). (Not the IPA)

Any TRACS User who has access to or uses TRACS

and completed the TRACS Rules of Behavior

Any TRACS Coordinator who has access to or uses

TRACS and completed the TRACS Rules of Behavior

Any iMAX User who has access to or uses TRACS and completed the TRACS Rules of Behavior

ADMINISTRATIVE SAFEGUARDS

Policies and procedures must be established to govern the use of the EIV system. These procedures should address: 1. Authorized use of the EIV system;

2. How to handle security breaches; and

3. Destruction of EIV data.

EIV manuals and HUD instructions should be reviewed when implementing administrative safeguards. Posting of bulletins and flyers can assist in communicating how sensitive EIV data is and how the is data should be handled.

PHYSICAL SAFEGUARDS

Physical safeguarding of EIV data refers to steps that must be taken to help ensure the data is safe when stored electronically or in hardcopy and when transmitting data electronically.

Storing and Transmitting of Electronic EIV Data

EIV data stored electronically must be in a restricted access directory or, if placed on portable media, labeled appropriately and encrypted using a NIST compliant vendor.





Similarly, all emails containing EIV data must be encrypted using a NIST compliant vendor. A list of compliant vendors can be found at: http://csrc.nist.gov/groups/STM/cmvp/document s/140-1/1401vend.htm.

When using EIV data, the full nine-digit SSN for a resident must not be included in emails or other electronic communications.

Hardcopy EIV Data

EIV data that is printed out must not be left unattended. The documents should be retrieved as soon as they are printed and, if possible, use a restricted printer, copier, or facsimile machine.

When faxing EIV data, ensure there is someone waiting and ready to retrieve the fax as soon as it is received (printed). When mailing EIV data, the data must be sent to an office of the O/A. EIV data must not be mailed to Independent Public Auditor offices.

If you provide a copy of EIV reports to the resident, the copies should be stamped as copies. The resident file should be noted. Our recommendation is to specify who provided copies of the reports to the resident and when the copies were provided.

Computer Security

The EIV system is set up to time out after 30 minutes of inactivity. This automatic safeguard should not be the only security measure taken. Individuals who use the EIV system should use a password protected screensaver and lock their computer when leaving their workspace. A user should not leave a computer unattended with EIV data displayed on the screen. It is also recommended that users exit the EIV system by using the “X” at the top right of the screen which will remove the user from the entire WASS system.

Destroying EIV data

EIV data must be destroyed as soon as it has served its purpose as prescribed by HUD’s policies and procedures and in accordance with HUD’s prescribed retention period. Shredding, burning or pulverizing are all examples of acceptable ways to destroy EIV data.

EIV Reports

Now that we have been using EIV for a few years, it is time to step back and review current policy and procedure. Owner/agents should determine if the reports are being used as required. In many cases, we have discovered that property managers are doing more than is necessary based on

information in various notices. The purpose of this lesson is to reiterate the requirements and answer common questions about report use.





We also want to make sure owner/agents know what causes problems or discrepancies in each report. This will help everyone understand the correct way to document the resident files and the Master File.

PROBLEMS (DISCREPANCIES)

The EIV Use Policy must also describe how owner/agents address problems identified on the reports. HH 4350.3 R1, Change 4 provides information about how to use EIV. The EIV Questions And Answers provide additional clarification. The biggest misconception that we are hearing about right now is that all discrepancies have to be “fixed”. This is not the case. Problems really should be categorized and owner/agents should take

appropriate action based on the cause of each discrepancy generated. In our opinion, there are four

types of problems (discrepancies):

1. Discrepancies created as a result of residents’ failure to disclose

2. Discrepancies created as a result of a situation that the owner/agent already knows about

3. Discrepancies created as a result of data entry errors

4. Discrepancies created because of a “false hit”. A “false hit” can be caused by multiple factors.

It is easy to establish consistent EIV Use Policies when you can address each type of discrepancy.

EIV REPORT USED TO SCREEN APPLICANTS

THE EXISTING TENANT SEARCH

The only EIV Report used prior to move in is the Existing Tenant Search. This report provides information about applicants who are currently receiving HUD assistance so that owner/agents can take necessary steps to avoid dual subsidy. This report must be reviewed before OAs approve any new move-in. The resident file must contain a copy of this report for all household members starting January 31, 2010. There are two exceptions: 1. EIV was not available from April 16, 2010 through June 20, 2010 and

2. New residents who are exempt from the SSN disclosure requirements.

When you reference HH 4350.3 R1, C4, Paragraph 4-7-D, note that Change 4 indicates that the Existing Tenant Search must be completed for ALL members of the applicant’s household. This includes children and live-in aides. In Paragraph 4-4, the Handbook goes on to say… “Screening Using the EIV Existing Tenant Search Owners must establish procedures in their Tenant Selection Plan for using the EIV Existing Tenant Search to determine if the applicant or any member of the applicant’s household are being assisted under a HUD rental assistance program at another location.”





USING THE EXISTING TENANT SEARCH IN EIV

To check to see if an applicant is already receiving HUD housing assistance, choose the Existing Tenant Search option. Enter the applicant’s social security number and you will get one of two results. If the applicant is not receiving assistance, EIV will indicate that there is no matching SSN in either the Public & Indian Housing (PIH) system – PIC, or in the Multifamily Housing system – TRACS.

If the applicant is receiving assistance, information about the applicant – similar to the information in the example - will display. Please keep in mind that this “hit” indicates that the applicant MAY be receiving assistance.





Nothing prevents a recipient of HUD assistance from applying to another property. However, owner/agents should make it clear to the applicant that he/she must move out of the current property before assistance will be provided in the new unit. See sample form.

When an applicant is receiving subsidy, owner/agents should develop some system to verify that the applicant is moving out of their current apartment before starting subsidy in the new apartment. See sample form. Also keep in mind that a minor child in a joint custody situation may appear on this report if both households receive HUD housing assistance. This is acceptable. A live-in aide may not continue to live in a subsidized unit in addition to living with the resident in need of care. This is a violation of the single residency clause in the HUD Model Lease. It is important to understand the difference between an overnight care-giver and a live-in aide.

In some cases, owner/agents may discover that EIV indicates that an applicant did not fully disclose rental history. Never deny an applicant based solely on the information in EIV. You should notify the applicant and investigate if the resident disputes the discovery. If a prior move-out was not recorded properly in TRACS or PIC, owner/agents could get a “false positive”.

If the applicant does not respond to the owner/agent inquiries, then the owner/agent may deny the household in accordance with the applicant rejection requirement.

EIV Reports Used at Certification

Certain reports must be reviewed as part of the MI, AR and IR certification process.

INCOME REPORTS

When reviewing income information, owner/agents will be viewing any of the following reports.

1. Income Summary Report

2. Income Report (Detail)

3. Income Discrepancy Report

These reports must be reviewed:

Within 90 days of transmission of the move-in (Income Detail is required)

As part of each annual certification (Income Summary is required until all household members are

verified, Income Detail and Income Discrepancy required at each annual

As part of each interim certification (Income Summary is required until all household members are

verified, Income Detail and Income Discrepancy required at each interim,





Your EIV Use Policy must explain when and why you review these reports as described above. Also, if you are going to review the reports at other times, then you must describe when and why you would run the income reports. For example, some owner/agents like to review the reports as part of the unit transfer process. Other OAs will review the reports if there is credible evidence that indicates a resident may have gotten a new job. To view reports by HOH… When you enter the HOH Social Security Number, all of the required Income Reports are available. Chose the Print All option to print all the reports for the tenant file.

If you get a message stating that no 50059 record was found, either

1. The most recent certification has not been accepted in TRACS or 2. The Social Security Number is wrong

You must find out why EIV cannot find the 50059 data.





USING EIV WITHIN 90 DAYS OF MOVE IN

Owner/agents must provide the EIV & You brochure when applicants are selected from the waiting list for eligibility interview. During the eligibility interview, owner/agents should

explain that the EIV system is used immediately after MI to review recent employment activity, unemployment benefits and Social Security income. For all new admissions,

the owner/agents must:

(1) Review the Income Report within 90 days after transmission of the move-in certification to TRACS to

confirm/validate the income reported by the household.

(2) Resolve any income discrepancies with the household within 30 days of the Income Report date.

(3) Print and retain the Income Report in the resident file along with any documentation received to resolve

income discrepancies, if applicable.

There is no requirement to run the reports EXACTLY 90 days after the move-in. Establish a schedule to run these reports. For example, if you have decided to review EIV reports at the beginning of each month, when TRACS submissions are sent, you might say:





“ For new move-ins (including addition of new adult household members), EIV reports will be reviewed along with other EIV reports based on the following schedule: January MI – Reports reviewed in March

February MI – Reports reviewed in April

March MI – Reports reviewed in May

April MI – Reports reviewed in June

Since you cannot use EIV until the MI transaction is recorded in TRACS, EIV was not available as a verification source. Now, you just need to make sure there is nothing in the EIV database that makes you suspect that the resident failed to fully and accurately disclose information. There are key things to look for: Is the Social Security Information verified?

Are there any “red flags” associated with income information?

o If an employer was indicated at MI, does the information match what’s in EIV?

o Are there any undisclosed employers indicated in EIV?

o If applicable, does most recent income activity in EIV raise concerns about the information the

resident disclosed at MI?

o Does unemployment information coincide with information provided in EIV?

o Does SSA benefit information coincide with information provided in EIV?

If resident is claiming zero income, does the “No Income Report” support that claim?

Owner/agents print the Income Discrepancy Report “90 days post-move-in” but information provided is prior to move-in and generally will not have impact on the MI 50059. Information provided is for a timeframe that starts 15 months before MI. The Income Discrepancy Report is reviewed at interim certification and annual certification. See Exhibit 9-5 of HH 4350.3 R1, Change 4.

USING EIV AT ANNUAL AND INTERIM CERTIFICATION

EIV Income Reports must be reviewed when completing annual and interim certification for HUD programs. Review at annual and interim is very different than the review conducted “post-move-in”. In order to be compliant with HUD requirements for HUD programs, the EIV income information is used to verify:

Employment

Social Security Income

Dual Entitlement Income

SSI

Medical Expense (Medicare Part B premium)





Use EIV to verify this information unless:

There is no information for a resident

o Survivors benefits

o You are adding a new household member

o Household member not verified

o Household member is exempt from SSN reporting requirements

o Employer pays cash

The EIV information is incomplete

o No Hire Date

o Unidentified deductions

Child Support garnish

Repayment Agreement

Unpaid Student Loans garnish

The resident disputes the information in EIV

o Disability payments are indicated but resident says the amount is wrong

o Employment is indicated but resident claims he/she is not employed

When an owner/agent cannot use EIV, the OA must attempt third-party verification directly from the third party source to meet HUD’s requirements when the owner/agent is verifying:

Employment income

Unemployment income

Social Security income

If the owner/agent cannot obtain third-party verification any other way owner/agent must:

Document the file explaining why

OA may accept notarized or witnessed family/self-certification

EMPLOYMENT INCOME IN EIV

The Income Report identifying the NDNH employment, wage and unemployment income information in EIV must be used as third party verification of the resident’s employment and is not to be used to calculate the resident’s income.

The owner/agent must print the Income Report and use the report as third party verification of the resident’s employment and/or unemployment. During the certification interview, the owner/agent must confirm with the resident that the employment and/or unemployment information in EIV is correct.





If the resident agrees that the employment and/or unemployment information in EIV is correct, the owner/agent must: 1. Request the resident to provide current documentation, (e.g., four

current, consecutive check stubs, employment offer letter, etc.) Other resident-

provided documents are also acceptable.

2. Use the resident provided documentation for determining the resident’s

income

3. Annualize the resident’s income using the current income projected

forward for the next 12 months.

In our example, Alicia has indicated, on her AR questionnaire, that she is

employed with ABC Corporation.

EIV confirms her employment so the owner/agent must request current documents to complete income projections. See HH 4350.3 R1, C4, Paragraphs 5-13 and 9-10. While this will not work for all residents, it does add another option that makes the process of employment verification easier.

You can verify that Alicia works for ABC Corporation.





SOCIAL SECURITY INCOME IN EIV

The verification of Social Security income is much the same as it has been since the introduction of TASS years ago. The main difference here is that Social Security income information in EIV is never more than 90 days old. As has always been the case, if the owner/agent is unable to use EIV, the owner/agent must:

Attempt to verify this income using verification documents described in Appendix 3

Use other reasonable methods to verify this income

If the owner/agent cannot obtain third-party verification and cannot verify employment income, unemployment income or SSA income any other way, the owner/agent must document the file explaining why. Then the owner/agent may accept notarized or witnessed family/self-certification.





Fictitious data, for illustration purposes only





INCOME DISCREPANCY REPORT

Individual Income Discrepancy Reports must be reviewed at each annual and interim certification. You must run the Income Detail Report at the same time you run the Income Discrepancy Report because the discrepancy numbers are re-calculated every week.

Owner/agents are required to review and, if necessary, resolve any discrepancies in income reported on the Income Discrepancy Report following the guidance in HUD Handbook 4350.3, Revision 1, Change 4, Chapter 7 and Chapter 9.

DO NOT use the Income Discrepancy Report option displayed on the EIV Menu. This is for use by HUD staff. Owner/agents will review the Income Discrepancy Report which is available under the Income Information Option on the EIV Menu.





Owner/agents will review the Income Discrepancy Report at Annual and Interim when reviewing other Income Reports. You can access all Income Discrepancies for a Property.

However, since the report is reviewed during AR and IR, we suggest you view the reports by Head-of-Household so all three required reports can be produced at the same time.





UNDERSTANDING THE INCOME DISCREPANCY REPORT

Let’s look at an example of an Income Discrepancy Report for Erin Evans.

Name = The HOH reflected on the most current 50059

Social Security Number = the SSN for the HOH

Contract and Project Number = Contract and/or Project Number for the property

Project = Name of Project as reflected in Secure Systems

Effective Date of Action = the effective date of the most current 50059 in TRACS.

Note: If this does not match the effective date of the most current 50059 in the tenant file, then you need

to figure out what is wrong in TRACS)

Next Re-certification Date = the Next AR Date on the most current 50059 in TRACS.

IDENTIFYING PROJECTED ANNUAL WAGES & BENEFITS

Projected income information is derived from the most recent HUD-50059 records stored in TRACS. When you review a resident file, you need to know what income is reviewed by EIV and what income is ignored by EIV. EIV is only checking employment income, unemployment income

and SSA income. Nothing else is relevant in respect to EIV Income Reports.





For example: You have a 50059 - Income includes

$300/month SSI = $3600 $1200/month Employment = $14400 $200/month VA Disability = $2400 $100/month income from assets = $1200

Total income on 50059 = $21600.00 EIV will only check

$3600/year SSI via the data share agreement with SSA $14400/year Employment via the data share agreement with HHS

Total income to EIV is $18000.00 EIV ignores VA income because HUD does not have a data share agreement with the Veterans Administration so there is no way to compare the income provided by the resident to the VA database. EIV ignores income from assets because HUD does not have a data share agreement with the Internal Revenue Service so there is no way to compare the income provided by the resident to the IRS database.

It is critical to understand that EIV is not analyzing the accuracy of all income reported by the resident. However, EIV can compare the employment, unemployment and Social Security income on the 50059 to the income information in the HHS Database and the income information in the SSA database. EIV opens the 50059 and only extracts income entered using the following codes.

Only includes employment income unemployment income and Social

Security Income.





Income Code

Type of Income

B Business

F Federal Wage

M Military Pay

W Nonfederal Wage

U Unemployment

SS Social Security

SI Supplemental Security Income

IDENTIFYING THE PERIOD OF INCOME FOR DISCREPANCY ANALYSIS

The Period of Income Discrepancy is defined as follows Period of Income Start Date – This date represents the starting point for the income period. The

Period of Income Start Date is 15 months prior to the effective date on the HUD-50059. Period of Income End Date – This date represents the end of the Period of Income and is 3

months prior to the effective date on the form HUD-50059. This is the approximate period for the resident interview. The Period of Income End Date is 12 months from the Period of Income Start Date.





EIV looks at income information from HHS and SSA for that timeframe. In this example, EIV is looking at employment income, unemployment income and SSA income displayed in the Income Detail Report for 9/1/2014 through 8/31/2015.

EIV indicates that Erin’s household earned Actual Income of $4682.44 between 9/1/2014 and

8/31/2015. EIV then compares that number to the employment, unemployment and SSA income reflected on the most current 50059. If the variance is more than $2400 ($200 per month), EIV will generate a discrepancy. EIV also indicates that if you take the income reflected for the last quarter of POI (June, July and August), add that income together and multiply by four, the resident would have zero income. EIV also compares that number to the employment, unemployment and SSA income reflected on the most current 50059. If the variance is more than $2400 ($200 per month), EIV will generate a discrepancy. The only way to determine how EIV came up with those number is to review the income detail information include on the Income Report for the same period. Remember, for HHS Employment Income information, quarterly income is based on the calendar month. So: Q1 = January, February & March Q2 = April, May, June Q3 = July, August & September Q4 = October, November & December





So, for Erin, we must review income starting in Q3 2014 (September only) through Q3 2015 (October & November only).

Period of Income Discrepancy is 9/1/2014 through 8/31/2015.

This is 1 month of Q3 2014

All of Q4 2014 All of Q1 2015

All of Q2 2015 and Two months of Q3 2015





The EIV Income Discrepancy Report shows $4682.44. Many of you spend a lot of time trying to make the numbers tie – down to the penny. However, it is pointless to do that. As long as you have a general understanding of how HUD came up with the discrepancy, you have what you need to address the discrepancy. Based on Last Quarter, the income is projected as follows.

So now you understand how EIV is generating numbers. The next thing to do is understand how to address the discrepancy. HUD cannot check all information provided by a resident family. HUD can compare employment income disclosed by the resident to information disclosed by employers hen payroll information is reported via a payroll tax return and when payroll information is reported to HHS. HUD can also compare Social Security income on the 50059 to the information in the SSA databases. To truly understand how to address the discrepancy, remember that HUD is really asking two questions:

1. Can you check the 50059’s to confirm that the resident fully and accurately disclosed employment

income, unemployment income and Social Security Income?

2. If not, will you please correct appropriate certifications and have the resident return any assistance paid in

error?

Month EIV Income Notes

9/2014 961.33 2884.00/3=961.33

10/2014 1052.33

3157.00/3=1052.33

11/2014 1052.33

12/2014 1052.33

1/2015 195.00

585.00/3=195.00

2/2015 195.00

3/2015 195.00

4/2015 0.00 No info in EIV





Total $4703.32

Month EIV Income Notes




Total for Last Quarter $0.00 $0.00 X4





Continuing with the same example: The Period of Income Discrepancy Analysis is 9/1/2014 through 8/31/2015. The first question is:

1. Did this resident live on my property during the period of Income for Discrepancy Analysis?

If the answer is “No”, then you may not have an issue.

If the answer is “Yes”, then you need to continue to investigate. Answer the second question.

2. Which certifications were used to determine the assistance payment during this time?

Let’s say this resident moved in December 2013.

The MI certification cycle is December 15, 2013 through November 30, 2014.

IR effective 6/1/2014. The certification cycle is June 1, 2014 through May 31, 2015.

December 2014 AR. The certification cycle is December 1, 2014 through November 30, 2015.

IR effective 2/1/2015. The certification cycle is February 1, 2015 through January 31, 2016.

December 2015 AR. The certification cycle is December 1, 2015 through November 30, 2016.

Don’t forget we are required to investigate information for the previous five years. Since Erin has not lived on the property for five years, we are going to review all of the certifications in the file. You only have to complete the analysis once unless new information is provided by EIV. 3. Based on the information in the file, did the resident report employment income, unemployment income or SS income during the period of discrepancy analysis? If the answer is yes, then you must compare the information provided in the 50059 to the information provided by EIV. We like to use an Excel Spreadsheet to help us with the calculation. This spreadsheet was provided to you with the class materials. Once you have completed your analysis, you can print the worksheet, attach it to the certification and maintain it in the resident file to explain your actions. If the answer is No, then you will need to investigate why the employment income, unemployment income or SS income was not disclosed by the resident. You must compare the income information on the 50059 with the income information in EIV. The

50059 period starts Q4 2013 (December) and continues through Q4 2014 (October/November).





Erin reported zero income (from employment, unemployment and Social Security) at move in.

Let’s see what is in EIV for that timeframe.



RBD Online Training Workshop – EIV Basics – March 2016


The EIV Master File - Reports Used to Monitor Resident Compliance

MASTER FILE REPORTS

The EIV system contains stand-alone reports that identify potential issues which may impact the family’s assistance. O/As must use these reports as discussed below and at other times as established

in their policies and procedures to reduce subsidy payment errors. O/As must retain a “Master” file that contains a copy of the report and documentation and/or notations as indicated in the latest HUD Notice. Certain EIV reports must be produced and reviewed on a regular basis. These reports allow the owner/agent to monitor residents’ compliance with reporting requirements. These reports are:

Identity Verification The Failed Pre-Screening Report – at least monthly The Failed Verification Report – at least monthly

The Multiple Subsidy Report – at least quarterly

The Deceased Tenant Report – at least quarterly

The New Hires Report – at least quarterly

Caution: Any detail reports retained in a tenant’s file must contain information for members of that tenant’s household only. Many of the reports do not have page breaks between households, therefore, O/As will need to separate the reports by household by cutting the reports apart until page breaks are inserted in the EIV system.

OTHER REPORTS THAT MAY BE STORED IN THE MASTER FILE

The owner/agent may also review the Pending Verification Report each month to see if any household members are still Pending Verification. Because this report contains information about multiple households, it is good to maintain printed copies of this report in the Master File. If EIV is not used for income verification or review because the resident is still “Pending Verification” then a note should be included in the tenant file and reviewers can cross-reference information in the Master File for three years.





The owner/agent can also use the Master File to store reports used to monitor residents who report zero income for an entire household:

No Income on 50059 Report

No Income from SSA or HHS Report

RECORDKEEPING – MASTER FILE

Many owner/agents maintain the Master File by month, but we prefer to store the information by report type. HUD does not define how Master Files are set up so it is up to the owner/agent. We like to separate the Master Files by year. So, many of our customers currently have an EIV Master File for 2013 2014 2015 They are currently “working” the 2016 reports. This makes it easy to purge old Master Files. The Master Files will be purged after three years in accordance with HUD’s current data purge/destruction policies. We like to set up Master File binders and we incorporate the following tabs in the binders:

Master File – Admin – We do not purge these forms

o EIV MOR Checklist

o Staff Forms – UAAF, CAAF, ROB, Cyber Awareness Training Certificates

EIV Policies – We do not purge these forms

o EIV Use Policy

o EIV Security Policy

o Data Destruction Log

Identity Verification Reports – Purged after three years

o Failed Pre-Screening

o Failed Verification

o Pending Verification (optional)

Multiple Subsidy– Purged after three years

Deceased Tenant– Purged after three years

New Hires– Purged after three years

Zero Income (optional) – Individual Tenant Files are reviewed and purged 3 years after tenancy

ends

Owner/agent must also maintain detailed information about discrepancy investigation and resolution in the resident file. This includes notices, notes, verification documents and corrected certifications.

NEW HIRES REPORT

This report provides employment information for residents who may have started new jobs within the last 180 days.





This report must be reviewed at least quarterly and maintained in the EIV Master File. However, for some properties, reviewing the information quarterly may not be enough. In these cases, owner/agents can revise the EIV Use Policy to indicate that this report will be reviewed every month. Owner/agents must evaluate their own residents and determine how frequently this report should be run. When you select the property, you can see a list of everyone who has gotten a new job within the last six months.

INVESTIGATING THE HOUSEHOLD SITUATION-NEW HIRES REPORT

In many cases, the resident will have complied with their lease and notified the owner/agent at the time of employment. At the time the resident disclosed the new job, owner/agents must verify income and take one of three actions: 1. Determine that no new 50059 is required because projected income did not increase by

$200/month ($2400 annually); or 2. Create an interim certification; or 3. Include the new employment income on an AR So ask yourself, “Do I know that each of these residents recently got a new job?” If the answer is yes, then you don’t have to do anything but document the Master File. However, if the answer is ever “No”, then you need to take appropriate action. Detailed information is maintained in individual resident files. Let’s take a look at what’s going on with Barry Allen.

UNKNOWN NEW EMPLOYMENT AND/OR RESIDENT DISPUTES EIV INFORMATION





If the owner/agent suspects undisclosed new employment, the household must be provided with a notice in accordance with HUD Handbook 4350.3 Revision 1, Paragraph 7-12. The household will be required to meet with the owner/agent or face termination. Do not deny,

suspend, or reduce any benefits of a resident until HUD you have taken appropriate steps to independently verify information. Owner/agents must discuss this with the resident first and then investigate and confirm employer and income amounts on the EIV Income Report; they must contact the third-party income sources listed on the report and request written verification of employer and wage amounts reflected in EIV (24 CFR 5.236). If the owner/agent has made attempts to verify the EIV data but is unsuccessful in attempts to verify the income information, the owner/agent should request the resident certify that the employer and employment information displayed in EIV is invalid and has been wrongly attributed to his or her personal identifiers. The owner/agent should then advise the resident to contact the third-party income source(s), and if unsuccessful, contact that employer or agency remove the invalid income information from his or her records. The owner/agent must note the resident file, attaching:

1. A copy of the letters sent to the third-party income source attempting to verify the EIV information (24

CFR 5.659);

2. A copy of the certification that the resident signed disputing the employer and income from wages

reflected in EIV for the resident; and

3. Documentation to show the OWNER/AGENT advised the resident to contact the third-party income

source, and if unsuccessful, the SWA in his or her State to request the information be removed from his or

her record

HUD cannot remove the information from EIV for the resident.

ZERO INCOME HOUSEHOLDS

All households claiming zero income (all members claim zero income) can be required to report to the owner/agent every 90 days in order to participate in an income review. If you opt to review income information for these households every quarter, you should develop a consistent policy including use of some sort of Zero Income Questionnaire.





One approach is to meet with all zero income households quarterly, based on a calendar year. So, the meetings are held in March, June, September and December. This way, you can collect information and review reports on a more regular schedule.

To identify residents who must participate in the review, print the No Income Reported on 50059. This report is used to easily identify those residents who have reported zero income on the most recent MAT 10 (50059).





No Income Reported by HHS or SSA

Also review the No Income from HHS or SSA Report.

Residents with zero income should appear on both reports. If a zero income household does not appear on this report, review the Income Reports to figure out why. This report also includes households that have no employment income, unemployment income or SSA

income information in EIV.

Because these reports include information for multiple households, the summary information can be

maintained in the Master File. Detailed information is always maintained in the resident file.

Keep in mind, while it is strongly suggested, there is no requirement to review income information

for zero income household more frequently than once per year. There is no requirement to run

either the No Income on 50059 or the No Income Reported by HHS or SSA. However, you must

document whether or not you use this report in your EIV Use Policy.





MASTER FILE SUMMARY

In review, the Master File must include:

Identity Verification Reports

o The Failed Pre-Screening Report – run monthly

o The Failed Verification Report – run monthly

o May also include Pending Verification

The Deceased Tenant Report – run quarterly unless your policy indicates more frequent use

The Multiple Subsidy Report – run quarterly unless your policy indicates more frequent use

The New Hires Report – run quarterly unless your policy indicates more frequent use

There are two reports that can be included based on your own policy. You can, but are not required to include:

The No Income on 50059

The No Income from HHS or SSA

Be sure that you are familiar with and are complying with your own corporate EIV Use Policy.

PREPARING FOR THE MANAGEMENT & OCCUPANCY REVIEW Reviewers and owner/agents have received extensive instruction regarding compliance with EIV requirements. HUD has identified paperwork that must be available for review. The following checklist helps summarize these requirements.





APPENDIX B – SAMPLE EIV MOR FILE CHECKLIST

This document has been designed to assist with the monitoring of the EIV security process. Below is a sample of the form which has been completed using fictitious data. This should be maintained in the EIV file with all of the supporting documents.

Yes No ----Use Policy Yes No ----EIV Security Assessment Questionnaire if requested by reviewer Yes No ----EIV Master File (Includes Failed Screening, Failed Verification, Deceased Tenant, New Hire, Multiple Subsidy)

Property Name Contract

Type

Contract Number Authorization Letter(s) Coord 1 Authorization

Letter(s)

Coord 2

Oak Grove S8 GA1111111111 Yes

No

John Doe Yes

No

Mary

Stevens

User Name

Users with Access

to EIV Only

User (U)

Coord (C)

Status Pend,

Cert , Expired or

Term (date)

Access Authorization Request (CAAF or UAAF)

Coordinator can print current form from EIV

ISS Security Awareness Training

Certificate (Annual)

Original Current

John Doe C Cert Yes No Yes No NA Yes No

Mary Stevens C Cert Yes No Yes No NA Yes No

Davey Jones U Cert Yes No Yes No NA Yes No

Indiana Jones U Term 6/2015 Yes No Yes No NA Yes No

Bill Clark U Cert Yes No Yes No NA Yes No

Name People who view EIV Reports – No Access

Role or Title (i.e. Financial Auditor, Property Manager, Compliance Monitor,

Regional Manager)

Signed Rules of Behavior on File

ISS Security Awareness Training Certificate (Annual)

Mike Majors Independent Auditor Yes No Yes No N/A

Estelle Evans Administrator Yes No Yes No N/A

Dan Davis Compliance Monitor Yes No Yes No N/A

Gloria Garner Regional Manager Yes No Yes No N/A Fictitious data, for illustration purposes only





EIV BASICS SUMMARY

This concludes our discussion of EIV Basic Topics. You have information you need to Create EIV Policies

Review income information at certification

Create and maintain the Master File

Monitor residents claiming zero income





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