eiv survey results - november 2013 - carh.org survey results - november 2013. ... your delinquencies...

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Attachment A lists the 49 CARH members that participated in the Survey Option Percentage Number of Answers Option Percentage Number of Answers Are you a CARH Member? Are You a Member of a CARH State Affiliated Association? Yes 75.5% 37 Yes 55.1% 27 No 24.5% 12 No 44.9% 22 How many HUD units do you own, manage or develop? Has your experience with EIV been positive? 0-50 67.3% 33 Yes 75.5% 37 51-150 26.5% 13 No 24.5% 12 151-300 4.1% 2 See Attachment C for a description of challenges/successes. 300+ 2.1% 1 See Attachment B for a listing of HUD funding types. Did your company develop procedures to deal with EIV? Yes 95.8% 47 Yes 32.7% 16 No 2.1% 1 No 67.3% 33 No Answer 2.1% 1 See Attachment D for a listing of how long it took to develop procedures. How often do you need to update EIV procedures? Do you send your staff to EIV training? See Attachment E for a listing of how often procedures are updated. Yes 93.9% 46 No 6.1% 3 See Attachment F for the costs associated with training. EIV Survey Results - November 2013 Rural Development (RD) is reviewing current procedures for verifying wages and income of residents who live in Section 515 and Section 514 housing. This verification is important given the budget issues revolving around the Section 521 Rental Assistance (RA) program as well as the Improper Payment Enforcement and Recovery Act (IPERA) error rates. One such mechanism that RD has explored using is the ability of rural housing providers to access data obtained through the Department of Housing and Urban Development’s (HUD) EIV system. RD has sought statutory changes to permit it to use EIV. In concept, CARH has supported EIV and systems that help take the burden off of owners and managers to monitor tenant income. However, as RD explores this option, a concern has developed about HUD’s experience using EIV and whether EIV is suitable for the rural housing portfolio. CARH surveyed members who currently manage HUD properties to ascertain staff time and regulatory impact/burden that the EIV system presents. Did you have to hire outside help to put procedues in place?

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Attachment A lists the 49 CARH members that participated in the Survey

Option Percentage Number of Answers Option Percentage Number of AnswersAre you a CARH Member? Are You a Member of a CARH State Affiliated Association?Yes 75.5% 37 Yes 55.1% 27No 24.5% 12 No 44.9% 22

How many HUD units do you own, manage or develop? Has your experience with EIV been positive?0-50 67.3% 33 Yes 75.5% 3751-150 26.5% 13 No 24.5% 12151-300 4.1% 2 See Attachment C for a description of challenges/successes.300+ 2.1% 1See Attachment B for a listing of HUD funding types.

Did your company develop procedures to deal with EIV?

Yes 95.8% 47 Yes 32.7% 16No 2.1% 1 No 67.3% 33No Answer 2.1% 1See Attachment D for a listing of how long it took to develop procedures.

How often do you need to update EIV procedures? Do you send your staff to EIV training?See Attachment E for a listing of how often procedures are updated. Yes 93.9% 46

No 6.1% 3See Attachment F for the costs associated with training.

EIV Survey Results - November 2013

Rural Development (RD) is reviewing current procedures for verifying wages and income of residents who live in Section 515 and Section 514 housing. This verification is important given the budget issues revolving around the Section 521 Rental Assistance (RA) program as well as the Improper Payment Enforcement and Recovery Act (IPERA) error rates. One such mechanism that RD has explored using is the ability of rural housing providers to access data obtained through the Department of Housing and Urban Development’s (HUD) EIV system. RD has sought statutory changes to permit it to use EIV. In concept, CARH has supported EIV and systems that help take the burden off of owners and managers to monitor tenant income. However, as RD explores this option, a concern has developed about HUD’s experience using EIV and whether EIV is suitable for the rural housing portfolio. CARH surveyed members who currently manage HUD properties to ascertain staff time and regulatory impact/burden that the EIV system presents.

Did you have to hire outside help to put procedues in place?

Can you charge properties for these training expenses? How do these costs compare to RD?Yes 49.2% 29 Greater Than 32.7% 16No 14.3% 7 About the Same 40.8% 20No Answer 26.5% 13 Less Than 0.0% 0

No Answer 26.5% 13

See Attachment G for a listing of costs involved.

How do repayent rates compare to RD?

More 24.5% 12 Helped 79.6% 39Same 51.0% 25 Hurt 10.2% 5Less 10.2% 5 No Answer 1.2% 5No Answer 14.3% 7 See Attachment H for listing of how EIV has helped or hurt.

See Attachment I for recommendations.

How much does it cost to run EIV reports and resolve discrepencies identified by the EIV System?

What are some recommendations for procedures that could be used by mangement agents that would verify income and wages and not increase costs to the properties?

Has EIV helped or hurt negotiating payment schedules with tenants?

Name Company E-Mail Phone

NAMES WITHHELD -- 49 RESPONDENTS

Attachment A

Survey Participants

Name Company E-Mail Phone

Attachment A

Survey Participants

Section 8

HOME, Section 8

SECTION 8

Section 8

Sec 8/RD 515 senior property-one only

Section 8/515

202/811

SECTION 8

Section 8 - PRAC - PAC

Section 8/515

HOME, Section 236, & Project Base Section 8

HOME, and Project based HUD assisted properties

Colntract based and Section 236

RD, HUD

Section 8

HUD Section 8 Properties and Home

HUD and section 515

Section 8

HOME, 202 Section 8, 202 PRAC, 202 PAC, 811 PRACSection 8- I do compliance and EIV for 30 properties with varying contracts. I am also manager of a project based section 8 property with 35 units

Section 236 HOME 515/Section 8 LIHTC PHA/ACC

Section 8

HOME/NSP/CDBG/SECTION 8

HUD 231, HUD 202/8, PRAC 811

Hud 202 section 8

Section 236, Section 236 Set-aside, Section 8 New Construction, Section 202/8

Attachment B

Listing of HUD Funding Programs Used

Attachment B

Listing of HUD Funding Programs Used

All types

HOME, Section 8

RD 515/piggy back

Section 8

Section 8/ 515

RD 515

HUD Section 8, Home

Section 8 Voucher Section 8 New Construction Public Housing

Section 8

HOME, 202 Prac

Project based section eight, 515/8 and 202/8

Section 236

Section 8

Section 8/515/LIHTC

Project based Section 8 and 202

Section 8 and HOME

SECTION 8

Section 8

USDA 515- Section 8

Public Housing

Public housing, Section 8 New Construction

Section 8, 202, PAC, PRAC.

Section 8

EIV sometimes uses more staff time

KEEPING UP WITH THE MANAGEMENT, HUD, RD AND NOW EIV COMPLIANCE HAS BECOME DIFFICULT

EIv requires more staff time and employment information can be outdated. Discrepancy information and duplicate subsidy as well as social security payments are a positive.In general it is helpful but the system is down frequently, extensive training is needed and there are frequently discrepencies that have to be checked out any way

I like that we can get resident's income off the EIV site....Making all the rules and running reports can be time consuming

The EIV system itself is a positive as far as the data you get. This taps into the IRS rather than just your states revenue system. You kow exactly what their income is and from what source they receive it. --Down side is the time it takes to get your staff registered, maintain their status, as well as the documentation you must keep for usage on the EIV system.

I AM THE EIV COORDINATOR FOR OUR MANAGEMENT CO & FROM MY POINT OF VIEW, IT IS MUCH TOO COMPLICATED & I'VE NEVER BEEN MORE FRUSTRATED THAN WHEN TRYING TO SET UP & REMOVE EMPLOYEES FROM IT! I WON'T EVEN GET STARTED ON THE ACCESS PROBLEMS & PASSWORD CHANGES.

EIV is time consuming, repetitive, the same reports print every month, constant documentation is needed. Waste of paper, files very large, filing time greatly increased. Would require more employees. Helpful in determining fraud

I like that I'm able to get residents' income off the EIV site

We don't have to get social security information from tenants and for employment purposes we only need 4 to 6 pay stubs. The issue is the time it takes to post information about employment. We don't get child support or publis assistance information from EIV.

The ability to detect fraud from residents

EIV saves time and usually is more accurate on verification, but we spend more time overall due to the extra requirements

Data is not current (usually 6 months in arrears) absorbs a lot of management time. The workload for a full time manager was at 85-90 units prior to EIV, it is now at 55-65 depending on the type of property. Expense has increased considerably.

works well

Since you cannot obtain SS information the system provides you with the financial needs for any resident going through annual recertification. Also has provided information on residents misreporting with new jobs, unemployment etc. Help to reduce improper payments.

Attachment C

Provide a Brief Description of Challenges/Successes re EIV

Attachment C

Provide a Brief Description of Challenges/Successes re EIV

Actually we do not have problems with the system in general.

Benefit of EIV is that it allows us to view actual wage and other data of our tenants, and has gone a long way to identifying and reducing underreporting of income by tenants. It is a great tool in the management process

EIV can be a valuable tool, however it comes at a cost. Challenges; Staff training - time and cost of training More money dedicated to complance, less for actual managment. Delayed real time data - Seek added information from residents and/or additional investigation. The EIV information should be reported in a more timely manner - 3 to 6 month old data is not very helpful. Successes; EIV has assisted in reducing errors and imroving accuracy, however not convinced the costs above justify EIV existence.

The program itself has been extremely beneficial in catching cases of fraud. Which there are many, but the system(as with most HUD procedures) is a time sucking nightmare. With all the rules and regulations and dates and don't be late by one day, and this and that and the other thing, that I am not sure that they aren't spending more time administering the program than they are gaining back from fraud. If the system and reporting and administering requirenments were much less, that I definitely believe it would be profitable tool.

its a waste of our time and efforts because we still have to third party verify everything because of Section 42, Section 515 and various other programs.

EIV does reveal unreported income however the requirements set forth by HUD for EIV causes extra work for staff.

It does take some extra staff time, but it's worth it. The extra time is in monitoring the reports. When you can verify employers, know if there is unemployment and the SS information, we are better able to keep on top resident's income.

I would classify this as a mixed experience. EIV is better than nothing, but it is not completely up to the minute accurate. Our understanding of the system is it picks up information from the most recent quarter which may not be completely accurate. Also, the process of EIV, more specifically, the file retention is much more cumbersome.

Wish we could answer yes and no to this question. For verifying SS and SSI it saves a great deal of time. There is also good information provided in the New Hires where we have caught folks who are working and not reporting the income. The piece that we have the most difficulty with is when the system reports an income reporting issue and the wages were actually earned prior to when the person was a tenant.

Out dated information - at least 90 days or more old. Does not reflect current info. However, does tell us about new hires and tells us about wrong SS# and if receiving multiple benefits. Helps with the liars who never report.

Takes up so much training and staff time. The rules are shockingly scary and developing the procedures about shut our little management company down!

Attachment C

Provide a Brief Description of Challenges/Successes re EIV

The challenges is just getting started with the program. After that it is basically easy to work, I personally feel that the information that we receive is stale and sometimes the tenant is no longer at the job it lists on the report. Getting a social security number corrected takes up to 3 - 4 mo.'s Getting renewed each year is sometimes a really hard task.

Saves time in verifying elderly households for SS/SSI payments.

Have mixed feelings on this. Had a hard time getting signed up however that was 3 years ago. Also the reporting is not always accurate and reported almost 6 months late

Site not accessible (down), information not posted on EIV in timely manner, difficult to correct incorrect information reported, site not user friendly (hard to find necessary info)

We have caught alot of unclaimed income at our properties however when you go retro on a certification it adds significantly to your delinquencies which the owners have a problem understanding. EIV and the repayment agreements and all the documentation is very time consuming but it is also a detirent for the residents who find it easy not to disclose their true incomes to the property managers.

One person runs all monthly reports that is required per EIV/ HUD guidelines. It is time consuming.. But we have found a lot of tenants that have been misreporting on their annual recertification's or at move in.

It is a simple process to pull the reports, one of the draw backs I see is, we can't get income information on new move ins. It does not produce the income and information concerning the whole household until after certification has taken place and the household gets put in the HUD system. It will however tell you before hand if that person is receiving HUD assistance somewhere else when they apply.

Definately uses more staff time. Successful in finding unreported income. ACCESS TO SS VERIFICATIONS!

It does take extra time and work to comply with the security requirements and to run the monthly/quarterly reports. However, it does allow us to discover unreported income that otherwise would not be known.

Employment income is not always up to date. Better for elderly and disabled properties

I can say truthfully it has been some of both while obtaining verifications has been a benefit. discrepancy reports are often outdated and require additional work/burden on management to clarify

The information is normally accurate

Successes: Several families have been evicted due to not reporting income and finding out that other people are living in the household.

Data in EIV is from the previous quarter and may be old. EIV shows unreported income! EIV saves postge, paper and time because verifications aren't mailed back & forth.

Attachment C

Provide a Brief Description of Challenges/Successes re EIV

Once everyone is set up with access to EIV, I would say that it saves more time for a straight HUD property. However, if the property has additional funders, such as LIHTC, we are required to still obtain a copy of SS benefit letter and it then creates additional work. If the other funders would accept the EIV Report, then it would be a time saver.

Saves staff time, uncovers un-reported income, exposes identity theft

Unsure

3 months

LONGER THAN EXPECTED

On going but intially at least 80 hours

Quite a bit of time was involved and we ended up buying eiv materials from Mary Ross

We went to a training with RBC and they give you a CD. This CD has the best practice procedures, so you just adjust for your company. The process take a few hours, but not really bad.

2 WEEKS

At least a year and we are still changing to produce more effective procedures

My boss did this..it was very time consuming and we had to buy the disc from Mary Ross

Attended seminars to assist in policies.

6 months

A few days

Overall about three months

Approximately 30 days.

This is on-going. As of January 1, 2014 we have one full time person hired to manage all the EIV payments and oversight of the process. Additional cost to the management agent and project.

they were in place when EIV was implemented.

6 months

Days - there are trainers who provide guidelines for EIV at little or no charge.

Attachment D

How Long Did it Take Your Company to Develop EIV Procedures?

Attachment D

How Long Did it Take Your Company to Develop EIV Procedures?

I developed the EIV procedures for United Marting. It has been an ongoing process as EIV has evolved. The HUD guidance in the handbook make it a fairly simple process.Approx. a month initially, however policies are consistenly modified to improve our protocol and accomodate frequently changing EIV procedures.

Its on going because HUD keeps changing the regulations and then the CA changes it every time we send it in resulting in more wasted time.

too long-

Two - three months

3 - 6 months

We attended training and then purchased a CD from Ross Business Development. The procedure was written with information and guidance from the materials provided.

All company procedures were taken from different trainings

About one work day

Takes a while to set-up and use correctly. Lots of hurtles to jump over online with acronyms. Not used friendly to set up. Especially because we only have two properities.

We just had to discuss how to keep EIV separate form RD papers for auditors.

It is still a work in progress as they keep changing the guidelines, but almost a year.

About 3 mo

2 weeks

Unsure, done awhile ago.

We have our guidelines in place if this is what you mean. It basically is the HUD compliance

2 years

We sub contracted in order to get good procedures in place.

six months

Attachment D

How Long Did it Take Your Company to Develop EIV Procedures?

A month

Not long, due to I used the recommended procedures from HUD as a guide.

Not long

It took a couple of months to develop procedures and checklists for using EIV. Attending Mary Ross's EIV Training was invaluable.

Couple days

It is an ongoing process and has required many hours of policy development overview and upkeep.

a couple of days

We approved procedures put together by HUD

HUD guidelines and online training were very helpful. Procedure manual is restatement tof HUD Secion 8 guidelines.

The process took a coupld of months to get everything implemented. We then later made additional changes to our process.

3 days

Annually

UNSURE

monthly to semi-annually

not often, just when the system changes

Constantly:)

Only when required by HUD.

AS OFTEN AS REQUIRED

Continuously, whenever there is a HUD procedural change

Constantly until Indiana Quadel quit coming

As often as HUD changes policies so this depends.

as often as necessary, depending on HUD procedure updates

Not unless there are changes to EIV

annually

Only as needed if EIV rules change.

As of often as HUD creates a new rule or policy on this procedure.

when HUD requires

when changes to policy

Yearly unless there is a change in the regs as we just had with Change 4.

Whenever there are changes to the system or how it is to be utilized.

At least bi-monthly, on average.

As often as HUD or the CA change their minds about something, which is frequent.

too often

Attachment E

How Often Do You Need to Update EIV Procedures?

Attachment E

How Often Do You Need to Update EIV Procedures?

Anytime there are changes in HUD requirements.

as necessary

Each time EIV is updated, usually annually.

It seems that every quarter something different comes out about EIV that needs to be changed.

When HUD makes a change the EIV system or requirements

User has to do on-line lesting and recertifying annually. Change and update some feature at least every three months.

Haven't had to.

Often

Every time employees change and at least 1 time a year

Occasionally

Review them annually

Once a year we take a test to keep certified

Annually

Every time there is a change in HUD's directive.

reviewed once a year

When there are changes from HUD or within our company.

When changes take place in HUD/EIV.

only as often as the regs change.

Once the EIV Procedures went into effect, most of it has stayed the same. Each year after attending Mary Ross's EIV Training, we have made little adjustments as needed.

Annually

frequently

annually

Attachment E

How Often Do You Need to Update EIV Procedures?

When needed

seldom

After the initial rollout, we reassigned some of the roles and responsibilies and tweaked our policies based on feedback from HUD and CMS.

as regs change, usually at least annually

Approximately $800 per person.

Course cost range from 0-$250 Travel has been close by only mileage 8 hours of wages per person for travel and course.

UNSURE OF THE COSTS

travel, course, wages, overnight stays......expensive usually $900/per person per training.

the training is nearly $300 plus means and transportation. usually the travel is somewht local so hotels are not necessary for us. But we also have to et HUD training as well as RD training for them so the anual costs are rising a lot for training

Most of the training sessions are only for a day, so depending on where the training is the cost would vary.

800

A class for one day can cost $300 to $400 per person and that is just the cost of the class, not included is mileage and food costs

Conferences are expensive and usually require a trip to Indianapolis..The last one was online but still expensive.

They have them in the Metro Area but it is approximately $200 to $300.

approx. $750-$800 per training, includes course costs, travel, meals, rooms, etc

Cost of Course, hotel, travel and wages for the entire day (+ overtime) for Corporate staff

$850 per person for travel, hotel stay, training, and salaries

It depends on if the training is sponsored by a housing association

Depending on the state that we are in, the cost can vary.

500

Approximately $ 400.00

Attachment F

What are the Costs Associated with Sending Staff to EIV training?

Attachment F

What are the Costs Associated with Sending Staff to EIV training?

I am the president of Southwest Affordable Housing Group and we provide training. We use Zeffert and Associates and Mary Ross for EIV. Employees are within driving distance and hotel cost is 120.00 per night (only 1 night needed) Cost is less than $100.00 per person for training. Also, we have a training program with Zeffert and we hold webinars on a regular basis at no cost.

I do not handle the training arrrangements, so I don't know

Course $300 Travel, Lodging Meals, Mileage $250/day Course is generally 1 day with one overnight for distant staff

Approximately $1000 per person per year

$1000 for the course, hotel, travel and meals

$2000 - $2500 annually for cost of courses and travel

average 300.00 per person

EIV training is done in-house. We usually pair EIV training with other training (updating or new procedures) to make it 2 days training. EIV training is usually most of one day. We charge $125/day for training, travel expense is around $90, overnight stay of $95 and meals about $80.

the average would be around $600 per employee

We have used Mary Ross training on line

Most is on-line for upwards of four hours at a time. Once you start the training you can not pause. Some outside EIV training was used but on-line is sufficient.

about $500

Paid wages for the seminar, travel expense, hotel and meal. Usually EIV training serves a meal and provides all materials

Unsure

Depending on the number of days and location. So far we have gone twice since implementing

2000

Attachment F

What are the Costs Associated with Sending Staff to EIV training?

I would say for all of our HUD staff to go to a EIV training, it is usually about $2,000. That is approximately 16-20 staff members.

It can be done with annual training with HUD/RRHA. The cost is between 250.00 to 300.00 depending, but they are getting other training as well.

$500 per person

an average of $400/training 2-3 trainings per year

Most of the time we will travel to San Antonio but I would say it cost about $1,000 for everything. But you get your moneys worth. EIV is a very good tool for saving tax dollars.

training is online at no added expense.

Printing costs, materials, location, hotel, meals, wages, etc.

about $200 annually

Approximately 2 hours per discrepancies

We spend much more time fixing discrepancies and some of them have no solution this is the biggest downfall of EIV. Could RD get the information and the discrepancies but only require us to figure out the recurring discrepancies once and that is it. Instead of getting the same information over and over. Some of our third parties are getting sick of us calling about the same issue every 3 months.

UNSURE OF THE COST

4-5 extra hours per week

can't estimate that

The reports are on the EIV system itself and deisrepancies are usually pretty easy to identify and repair.

UNKNOWN AS I AM NOT A USER

A family site, 48 units, printing reports, investigating, documenting, filing, 24 to 32 hours a month, could be more if discrepancies are found

The reports themselves not long....the discrepancies never make sense...some occur even before they were residents

It depends how many recerts you have month and if it is time for quarterly reports.

unable to track, as this depends on many variables each month

Varies with property and issues--could be 1 hour or more

$50 per month per property

Depending on resident turnover and recertification, or what they find with the reports, about 5 hours per month.

Increased manager salary by 20% the first year due to reduction of the number of units a person can manage and have increased by 8-10% for the past 2 years. As stated previously, have now had to hire a full time person just to oversee this specific item.

same

Approximately 2 hours per month

It doesn't take long.

Attachment G

How Much Does It Cost (Staff Time and Administrative Time) to Run EIV Reports and Resolve Discrepencies Identified by the EIV System?

Attachment G

How Much Does It Cost (Staff Time and Administrative Time) to Run EIV Reports and Resolve Discrepencies Identified by the EIV System?

per property - approximately 30 minutes a month to run. Resolution time of discrepancies varies.

9 properties with EIV 1 staff person [not site staff] spends approx. 10 hours a week @ $25/hr.

5-10 hours per property per month depending on the property size.

unable to break down the actual cost

Approximately 7 hours average time per EIV discrepancy. This does not include running the quarterly EIV reports.

unknown

First of each month - 1 hour Throughout the month (income reports) - 1 hour Quarterly reports - may take up to 4 hours depending on the number to be researched and followed up on.

Unknown

Running the reports is about 30 minutes a month. Resolving the issues varies depending on the item. Some can take several hours.

We only have two properties takes on average of an hour or two per month to run report. Discrepancies can take several hours for both staff and admin.

about an hour per month.

Staff time for us is less than 1 hour per month for our 2 properties, but if we added our other properties, it would probably take about 2-3 hours a week

Takes less time then chasing down verifications in many cases.

Depends on the size of property and if family units there are more changes usually. Between 2-3 hours approx.

$10000/annually

very mimimal, response time is quick

3 to 4 hours a month.. This depends on how many HUD properties you have and how many discrepancies you may have in a given month.

Attachment G

How Much Does It Cost (Staff Time and Administrative Time) to Run EIV Reports and Resolve Discrepencies Identified by the EIV System?

It takes about 15 to 20 minutes to run the reports. Then the resoulution of problems depends on the problem. You have to notify the tenat involved give them a chance to bring in the infomation to support what they say is accurate, and then third party verify the infomation to see which is correct.

$100-$200 per month

About 1/2 an hour each month to run the reports and resolve discrepancies. If unreported income is found then it will take longer to get verification and correct the certifications.

Very little

requires 1-2 hours more per day than the average rd property site manager

Anytime you are dealing with families it's time consuming and costly and again it's worth the money. We can evict or having families sign an agreement to repay the money. A lot of time they prefer to pay because there is no where else to go.

EIV reports can be run in 5 minutes. Discrepancies are caught sooner resulting in less money owed.

In compliance we see more labor/errors in the obtaining of the SS benefit letter than we do discrepancies on EIV Reports.

3 hours per month

By having documentation of employment

When we notice someone got a job and didn't tell us it is great to be able to bring up their EIV report and ask them about a specific job. I have had tenants leave because they did not want to repay but that is the point the unit is used by those in need not the sneakiest.

Tenants have a harder time arguing that they weren't working but we have also seen them just leave when they didn't agree or want to pay

Haven't had that problem yet

Once you know a tenants true income there is no way for them to hide income. This is always easier.

UNKNOWN

It does help, there is proof of income that wasn't reported, however the repayment agreements can't be more than 40% of income, some payment plans run more than a 100 months for Resident to pay back

You can see it right there in black and white

Makes it easier to confront resident and set up payment schedules.

They can't argue about start dates

have not had any

When you contact them pertaining to information provided in EIV they are usually more willing to cooperate.

We have only had one where fraud was discovered and we are on a workout plan. Keep in mind most of our HUD properties are for seniors and very few work.

has helped a lot

After EIV reports are run, we can more effectively show residents thier income and rent is calculated.

Attachment H

How has EIV Helped or Hurt Negotiating Payment Schedules with Tenants?

Attachment H

How has EIV Helped or Hurt Negotiating Payment Schedules with Tenants?

It has caught thousands and thousands of dollars in Fraud,

We deal mostly with elderly housing so we don't have a tremendous number of problems with this.

If a tenant who has unreported income signs a repayment agreement and then they quit their job we must put everything on hold until they have income again at some future time. Then we must recalculate the repayment agreement when this occurs.

greatly helped with income and social security verfication

EIV has indicated that we can collect the difference of 30% of adjusted income and 40%. We then have no dispute on what we can charge for repayment.

Having the information from a direct federal source often gets us better compliance with the tenant agreeing to enter into a payment arrangement.

It is about the same as a wage tape but it includes benefits. Can't dispute it - in black and white. Due especially to the new hires, keeps the time frame shorter between not reporting and getting caught.

Neither - don't have that many decrepencies.

Never had to use it

Proof is there on paper

Usually tenants have to admit that they were working and did not report.Depen

Repayment schedules are inflexible w/o regard to extenuating circumstances

If it is reported and shows where they did not report income, it makes it easier to explain to the tenant the reason they need to repay. The EIV information has dates as when employment or benefits received started, so there are legitimate dates to show the non reported income.

I had to answer - but I don't feel it has helped or hurt.

Attachment H

How has EIV Helped or Hurt Negotiating Payment Schedules with Tenants?

They are provided a brochure EIV & You which informs them that unreported income will be discovered through the EIV process. The EIV report itself provides proof that they did not disclose the income.

Not sure either

It is harder for tenants to dispute discrepencies when they are coming from this source.

We have collected money that we would not have done if it were not for EIV.

Tenants owe less money and can repay it more easily.

N/A

identifies income history so tenant cannot dispute

Continue to contact Rural Development representatives when management feels like there is a problem with fraud.

Is EIV completely separate from HUD? If RD could use it would they have to have the exact same regulations? I understand not sharing your password and only allowing certain people access to the information but does RD have to have annual training and annual certification letters in the file as well as the original documents in the file. With discrepancies if there was some way to only deal with a discrepancy once instead of every time the same discrepancy shows up. If RD can set is own regulations dealing with EIV then there would be a start up cost, but if their wasn't required annual training certifications then it wouldn't be a recurring cost. Also it is quicker to get income verifications from EIV than from the social security administration so that part would decrease expense. So if RD could decrease the regulations surrounding the discrepancy reports than this would be an option.

THESE RECOMMENDATIONS WOULD HAVE TO COME FROM A HIGHER AUTHORITY AT HOME OFFICE.

faxing is a helpful resource and fairly inexpensive for us.

Frankly the eiv system is pretty good. However, no one can see the reports that are not authorized to see them without all of the other training and approvals given by HUD. ie, RD reviewers cannot see these reports if they come to the property so we keep the EIV info in a separate folder. HUD has reminded us of this numerous times.

USE EIV

NOT SURE

No other recommendations, EIV will increase cost

I don't know

This I cannot answer.

wages reported by SS #

None I am aware of at this time.

Don't have any

Unknown

Residents or applicants required to bring in tax returns and W2's.

???? hmmmm

Attachment I

What are some Recommendations for Procedures that Could be Used by Management Agents that Would Verify Income and Wages and Not increase Costs to the Properties?

Attachment I

What are some Recommendations for Procedures that Could be Used by Management Agents that Would Verify Income and Wages and Not increase Costs to the Properties?

Maintain a schedule and provide written policy to residents if necessary

EIV works as good as anything else.

we follow the HUD handbook as always. EIV is an additional, and very valuable tool, in the process.

Develop thorough protcols, procedures, train, follow and monitor. At some point there is a diminshing rate of return. While errors are unacdeptable, there must be a point where the increased cost to reduce errors must be weighed against the incremental reduction of errors.

Follow change 4 of the HUD and not require 3rd party verification, but the use of tenant provided documents.

I'm not sure.

Eliminate quarterly EIV reports. Only require EIV income reports at annual recertification.

unknown

HUD (Change 4) is allowing Up-front Income Verification (UIV) that allows pay stubs and other documents to be used as third party verification. That will save time and decrease costs of processing verifications.

If we could use the IRS system

I would use the system only for SS and SSI. Until they fix the false error reports, conducting third party verifications is more accurate.

At this time RD properties are having difficult time getting SS & SSI benefits printouts and child support print outs. We are also having to use check stubs more often as there are so many who use payroll companies and the WORK NUMBER which costs too much money to the complex.

No recommendations

EIV is one way.

unknown

None at this time

Make the Work Number free again

Attachment I

What are some Recommendations for Procedures that Could be Used by Management Agents that Would Verify Income and Wages and Not increase Costs to the Properties?

EIV is a good system.

third party

The EIV would be an excellant choice, snce it does not cost anything over what you would expect to pay for training in any other program. The other option that it seems most employers are reporting to is The Work Number, but it does cost if you use it. But some employers will not verify income they just tell you to go to The Work Number.

no answer

N/A

N/a

none

I would think that the only cost would be the one time training and then after that the Management co. could inform the managers of any changes.

For mid-year income changes- only verify the change, not the entire recertification (income, assets and medical deductions). Recertification remains on anniversary of move in.

N/A

na