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Technical Assistance Program EIV Micro-Workshop

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Technical Assistance Program

EIV Micro-Workshop

Session Objective

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A. Updating Project DocumentsB. Retention of EIV ReportsC. EIV Master File ReportsD. Verification of IncomeE. Resolving Income DiscrepanciesF. Other Household Specific EIV Reports

TA Program: EIV Micro-Workshop

A. Updating Project Documents

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A. Updating Project Documentsi. Tenant Selection Planii. Policies and Procedures

TA Program: EIV Micro-Workshop

A. Updating Project Documents

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i. Tenant Selection Plan

“O/As must use the Existing Tenant Search in the EIV system as part of their screening criteria for new tenants and must include written policies for using the search in their Tenant Selection Plan.”

(HUD Notice H2011-21 ¶ VI.A.1.)TA Program: EIV Micro-Workshop

A. Updating Project Documents

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ii. Policies and ProceduresAdministrative Safeguards: Physical Safeguards:

a) Authorized use of the EIV system

b) How to handle security breaches

c) Destruction of EIV data

a) Storing and Transmitting of Electronic EIV Data

b) Hardcopy EIV Datac) Computer Securityd) Destroying EIV

Data

(HUD Notice H2011-21 ¶ XII.G.)TA Program: EIV Micro-Workshop

A. Updating Project Documents

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ii. Policies and Procedures

“O/As 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, e.g., Income Discrepancy Report and the EIV Verification Reports.”

(HUD Notice H2011-21 ¶ VI.A.2.)TA Program: EIV Micro-Workshop

A. Updating Project Documents

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ii. Policies and ProceduresExample 1: The New Hires Report will be run at least quarterly.

TA Program: EIV Micro-Workshop

A. Updating Project Documents

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ii. Policies and ProceduresExample 2: The New Hires Report will be run on a quarterly basis in January, April, July, and

October. The report will be run for “All” recertification months. The report will be printed by the 10th of each applicable month and stored in the designated section of the Master File. Any

household specific Detail Report generated during this process will be placed in the corresponding tenant file and the discrepancy resolved by the last day of the given month.

TA Program: EIV Micro-Workshop

A. Updating Project Documents

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ii. Policies and Procedures

“O/As must address in their Policies and Procedures notification requirements and timeframes for tenants who turn 18 between annual recertifications to sign the consent forms .”

(HUD Notice H2011-21 ¶ VI.B.2.f.)TA Program: EIV Micro-Workshop

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B. Retention of EIV Reports

B. Retention of EIV Reportsi. Master File Reportsii. Tenant File Reports

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B. Retention of EIV Reports

i. Master File Reports

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B. Retention of EIV Reports

ii. Tenant File Reports

* If the Existing Tenant Search Report was run for an applicant who did not move into the project (due to rejection or some other reason), this report must be retained in the applicant file for at least 3 years.

** If your Policies and Procedures (P&P) require the No Income Report to be printed, it must be stored in the respective tenant file. However, this is not required to be printed.

*** If a discrepancy is generated for a specific household on the project-wide New Hires or Multiple Subsidy Report, these Detail Reports must be retained in the corresponding tenant file along with any supporting documentation for the

resolution of the discrepancy. (If “New Hires Report” or "Multiple Subsidy Report" are underlined, this shows that there is an active link; the detail report can be accessed by clicking on that link.)

TA Program: EIV Micro-Workshop

C. EIV Master File Reports

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C. EIV Master File Reportsi. New Hires Reportii. Multiple Subsidy Reportiii. Identity Verification Reports

a) Failed EIV Pre-Screening Reportb) Failed Verification (Failed SSA Identity

Test) Reportiv. Deceased Tenant Report

TA Program: EIV Micro-Workshop

14TA Program: Verification of Income Using EIV

i. New Hires ReportREPORT O/A REPORT USE FILE DOCUMENTATION RETENTION

New Hires Report Identifies tenants who have new employment within the last 6 months.

Updated monthly.

At least quarterly Contact tenant regarding new employment.

If confirmed, gather tenant-provided documents and/or TPV.

Process IR, if applicable.

New Hires Report with notation of action(s) taken. Agree: tenant-provided documents and/or TPV.

Dispute-TPV.

Correspondence between tenant and/or employer.

50059(s) if applicable.

Master fileRetain New Hires Summary Report. Tenant fileRetain New Hires Detail Report along with any correspondence, tenant-provided documentation, TPV, and 50059(s), if applicable.

C. EIV Master File Reports

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i. New Hires Report

C. EIV Master File Reports

TA Program: EIV Micro-Workshop

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i. New Hires Report

C. EIV Master File Reports

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i. New Hires Report

Sto

re in M

aster File

C. EIV Master File Reports

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i. New Hires Report

C. EIV Master File Reports

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i. New Hires Report

Sto

re in T

enan

t File

C. EIV Master File Reports

TA Program: EIV Micro-Workshop

20TA Program: Verification of Income Using EIV

ii. Multiple Subsidy ReportREPORT O/A REPORT USE FILE DOCUMENTATION RETENTION

Multiple Subsidy Report

Identifies tenants who may be receiving rental assistance at more than one location.

At least quarterly

Must search both queries: •Search within MF •Search within PIH

Discuss with tenant then other O/A.

Terminate assistance or tenancy if necessary.

Search results:

Documentation supporting any contacts that were made, information that was obtained, and/or actions that were taken.

Master file Retain Multiple Subsidy Summary Report and supporting documentation.

Tenant file Retain the Multiple Subsidy Detail Report along with documentation of action taken.

C. EIV Master File Reports

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ii. Multiple Subsidy Report

Store in Master File

C. EIV Master File Reports

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ii. Multiple Subsidy Report

C. EIV Master File Reports

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ii. Multiple Subsidy ReportS

tore

in

Ten

ant

Fil

e

C. EIV Master File Reports

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iii. Identity Verification Reportsa) Failed EIV Pre-Screening Report

b) Failed Verification Report (Failed SSA Identity Test)

Store in Master File

C. EIV Master File Reports

TA Program: EIV Micro-Workshop

25TA Program: Verification of Income Using EIV

iii. Identity Verification Reportsa) Failed EIV Pre-Screening Report

REPORT O/A REPORT USE FILE DOCUMENTATION RETENTION Failed EIV Pre-screening Report Identifies tenants who have missing or invalid personal identifiers (ex-SSN, DOB, name) in TRACS.

Identifies those who have to replace their TRACS id with an SSN.

Monthly Check data entry. Contact tenant.Correct TRACS data.

Follow up with tenants identified on the report where discrepant personal identifiers were not corrected at the time of recertification.

Failed EIV Pre-screening Report documented with action taken to resolve invalid or discrepant personal identifiers.

Those exempt from disclosing their SSN will appear—notate report.

Master fileRetain copy of Failed EIV Pre-screening Report.

Tenant fileDocumentation to verify discrepant personal identifiers.

C. EIV Master File Reports

26TA Program: Verification of Income Using EIV

iii. Identity Verification Reportsa) Failed EIV Pre-Screening Report

b) Failed Verification Report (Failed SSA Identity Test)REPORT O/A REPORT USE FILE DOCUMENTATION RETENTION

Failed Verification Report (Failed SSA Identity Test) Identifies tenants whose personal identifiers do not match the SSA database.

Monthly Check data entry. Contact tenant.Correct TRACS data.

Follow up with tenants identified on the report where discrepant personal identifiers were not corrected at the time of recertification.

Failed Verification Report (Failed SSA Identity Test) report documented with action taken to resolve invalid or discrepant personal identifiers.

Master fileRetain copy of report in a mater Failed EIV SSA Identity Test. Tenant fileDocumentation to verify discrepant personal identifiers.

C. EIV Master File Reports

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iii. Identity Verification Reports

C. EIV Master File Reports

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iii. Identity Verification Reports

HUD cannot correct data in the EIV system; only the originator of the data can correct the information.

C. EIV Master File Reports

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iii. Identity Verification Reportsa) Failed EIV Pre-Screening Report

b) Failed Verification Report (Failed SSA Identity Test)

There will not be any employment or income information in the EIV system for tenants who fail either the EIV pre-screening or SSA identity test so it is essential that any discrepancies are corrected within 30 days from the date of the reports. O/As must conduct third party verifications to obtain employment and income data for these tenants.

D. EIV Master File Reports

TA Program: EIV Micro-Workshop

30TA Program: Verification of Income Using EIV

iv. Deceased Tenant ReportREPORT O/A REPORT USE FILE DOCUMENTATION RETENTION

Deceased Tenants Report Identifies tenants reported by SSA as being deceased.

At least quarterly Confirm, in writing, with head of household or next of kin to determine whether or not the person is deceased.

Update 50059 if tenant is dead.

Encourage tenant to contact the SSA if the data is incorrect.

Deceased Tenants Report Documentation obtained to resolve discrepancy.

Updated 50059.

50059A if a move-out must be processed.

Master fileRetain copy of Deceased Tenants Report. Tenant fileForm HUD-50059 and/or form HUD-50059-A.

C. EIV Master File Reports

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iv. Deceased Tenant Report

Sto

re in M

aster File

C. EIV Master File Reports

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iv. Deceased Tenant Report

C. EIV Master File Reports

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D. Verification of Income

E. Verification of Incomei. Running the EIV Income Reportii. Evaluating the EIV Income Report

a) Summaryb) Income (Detail)c) Income Discrepancy

iii. Income Not Included in EIV

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i. Running the EIV Income Report

The EIV Income Report must be run within 90 days of the MI-50059 being transmitted to TRACS for all new admissions.

D. Verification of Income

(HUD Notice H2011-21 ¶ VII.A.2.e)TA Program: EIV Micro-Workshop

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D. Verification of Income

ii. Evaluating the Income Report

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ii. Evaluating the Income ReportREPORT O/A REPORT USE FILE DOCUMENTATION RETENTION

Summary Report Provides a summary of information taken from the current, active certifications contained in TRACS.

Matches personal identifiers on in TRACS with the SSA database.

Recertification (annual and interim) Used to verify a tenant’s SSN, or to review and resolve discrepant or invalid personal identifiers for those with a “failed” or “deceased” status.

Summary Report(s) as verification of the SSN for those “verified”. Correspondence or documentation received to resolve a tenant’s “failed” or “deceased” status.

Documentation for those exempt from the SSN disclosure rule.

Tenant fileSummary Report and supporting documentation.

Note: O/As may remove /destroy copies of the SSN once the Identity Verification Status shows “verified”.

D. Verification of Income

a) Summary

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D. Verification of Income

ii. Evaluating the Income Reporta) Summary

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* HUD cannot correct data in the EIV system; only the originator of the data can correct the information. *

D. Verification of Income

ii. Evaluating the Income Report

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i

TA Program: Verification of Income Using EIV

REPORT O/A REPORT USE FILE DOCUMENTATION RETENTION Income Report Provides employment and income reported by HHS and SSA for all who pass the SSA identity test.

Identifies tenants who may not have reported complete or accurate information.

Recertification (annual and interim) 90 Days after MI information is transmitted to TRACS.

TPV of income.

All discrepancies must be resolved within 30 days of the date on the report.

No Dispute: Income Report, tenant-provided documentation, TPV (if necessary).

Dispute: Income Report, TPV.Reported Income Not In EIV: Income Report, and tenant-provided documents and/or TPV.

Correspondence50059(s)

Tenant FileRetain copy of Income Report and supporting documentation with applicable 50059(s). Note: The O/A must make copies of any tenant provided documents and return the originals to tenant.

D. Verification of Income

ii. Evaluating the Income Reporta) Summary

b) Income (Detail)

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ii. Evaluating the Income Report

D. Verification of Income

a) Summaryb) Income (Detail)

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D. Verification of Income

ii. Evaluating the Income Reporta) Summary

b) Income (Detail)Components of the Report:

6. Employment info, Wages, and Unemployment Benefits

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Management must obtain independent third party verification from the source which is used to complement EIV data when:

• The tenant disputes the EIV income information;• The tenant is unable to provide acceptable and current employment and/or income documentation to support the wage and unemployment income in the EIV system;• There is an EIV income discrepancy reported at the time of the recertification which the tenant disputes; • There is incomplete EIV income data for a tenant; or• Income data is not available in EIV.

D. Verification of Income

ii. Evaluating the Income Report

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• HUD cannot correct data in the EIV system; only the originator of the data can correct the information. *

D. Verification of Income

ii. Evaluating the Income Report

Unemploy-ment

benefit Info

From the local SWA

TA Program: EIV Micro-Workshop

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REPORT O/A REPORT USE FILE DOCUMENTATION RETENTION Income Discrepancy Report Identifies households where there is an annual difference of at least $2400.

Used only as a tool, not to calculate income.

Always print with Income Report (AR, IR, and 90 days after the MI information is submitted to TRACS). Discrepancies must be resolved within 30 days of the report date.

All correspondence to/from the tenant regarding the income discrepancy. Documentation received to resolve the discrepancy.

If applicable, corrected 50059(s) and repayment agreements.

File must be documented whether discrepancy is valid or invalid.

Tenant fileRetain copy of Income Discrepancy Report and any documentation related to the resolution of the discrepancy.

D. Verification of Income

ii. Evaluating the Income Reporta) Summary

b) Income (Detail)c) Income Discrepancy

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D. Verification of Income

If you run the EIV Reports and there are no sources of income, does that mean this is a zero income

household?

TA Program: EIV Micro-Workshop

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E. Income not Included in EIVi. Pensionsii. Child Supportiii. Welfare Benefitsiv. Alimony

D. Verification of Income

iii. Income Not Included in EIV

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E. Resolving Income Discrepancies

Negative numbers = under-reporting of income

Positive numbers = over-reporting of income

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E. Resolving Income Discrepancies

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E. Resolving Income Discrepancies

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E. Resolving Income Discrepancies

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E. Resolving Income Discrepancies

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F. Other Household Specific EIV Reports

G. Other Household Specific EIV Reportsi. Existing Tenant Search Reportii. No Income Report

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F. Other Household Specific EIV Reports

TA Program: Verification of Income Using EIV

i. Existing Tenant Search ReportREPORT O/A REPORT USE FILE DOCUMENTATION RETENTION

Existing Tenant Search Identifies applicants who may be receiving assistance at another Multifamily or PIH location.

Run at the time of processing an applicant for admission.

Discuss with tenant to determine circumstances.

Contact other o/a.

Coordinate move-in/out dates.

Search results for all household members Any and all contacts with applicant and other owner/agent must be recorded and kept with/on the search results for affected member.

Application fileIf not admitted – retain search results and any supporting documentation with the application. Tenant fileIf admitted – retain search results and any supporting documentation with the application.

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F. Other Household Specific EIV Reports

i. Existing Tenant Search Report

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F. Other Household Specific EIV Reports

i. Existing Tenant Search Report

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F. Other Household Specific EIV Reports

TA Program: Verification of Income Using EIV

ii. No Income ReportREPORT O/A REPORT USE FILE DOCUMENTATION RETENTION

No Income Report Identifies tenants who passed the SSA Identity Test but no income was reported by HHS or SSA.

“Zero” income tenants should be re-verified at least quarterly.

As identified in O/A’s policies and procedures.

O/A should ask thorough and correct questions in order to provide tenant the opportunity to disclose all income.

Third party verification of other income sources, if applicable. Correspondence/documents for re-verification of zero income tenants.

Tenant fileAny documentation or third party verifications for other income reported by the tenant.

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F. Other Household Specific EIV Reports

ii. No Income ReportReverify zero income status at least quarterly.

• How do you pay monthly rent?• How do you pay for monthly utilities?

• How do you pay your monthly phone bill?• How do you purchase grocery items?

• How do you pay for vehicle maintenance?• Do you receive child support for your dependents?

• How do you pay for clothing expenses?• How do you pay for entertainment expenses?

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Questions?

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Round Table Discussion

TA Program: EIV Micro-Workshop