Slide #1 © Copyright 2008 Nan McKay & Associates Annie Stevenson Managing EIV © Copyright 2008 Nan McKay & Associates

Slide #1 © Copyright 2008 Nan McKay & Associates

Annie Stevenson

Managing EIV

© Copyright 2008 Nan McKay & Associates


Welcome to Lunch N Learn!

Today’s topics:• EIV update• Annual reexam processing• EIV reports• HUD compliance monitoring


Introduction


Upfront Income Verification (UIV)

What is it?• The verification of income, before or during

a reexamination, through an independent source that systematically and uniformly maintains income information in computerized form for a large number of individuals



UIV is an extremely effective tool for error reduction

Before UIV, PHAs obtained third-party verification from income sources reported by applicants and participants



UIV enables PHAs to check a variety of income sources for all family members• Regardless of income sources reported by

applicants and participants


Use of UIV for Verification

UIV is third-party verification• Most preferred form• Meets regulatory requirements

UIV is intended to streamline the verification process• Eliminates the need for written third-party

verification in many cases


UIV Resources

UIV resources include:• HUD’s EIV System• State Wage Information Collection Agencies • State TANF systems• Credit Bureau Association (CBA) credit reports• Internal Revenue Service (IRS) – Tax transcript

Request with IRS form 4506-T• Private sector databases


EIV Update


HUD Guidance on EIV

2 HUD training webcasts on EIV• 1/16/08• 8/26/08

Webcasts are archived at http://www.hud.gov/webcasts/archives/index.cfm


HUD Guidance on EIV

Training materials from webcasts• Powerpoints• Case studies & solutions• http://www.hud.gov/offices/pih/programs/ph/rhii

p/training.cfm


HUD Guidance on EIV

8/26/08 webcast• Comprehensive training on “Effective Use of

EIV”• Extensive discussion of EIV reports and their

usage• EIV sign-on now includes certification of EIV &

security training


8/26/08 Webcast

Clarification that EIV is sufficient verification of SS/SSI if family agrees

PH flat rent families now excluded from income discrepancy report

Discussion of identity theft Guidance on use of income discrepancy report


NEW! HUD Guidance on EIV HUD webcast 1/16/08 contained revised

guidance on use of EIV• Previous guidance is obsolete and has been

removed from EIV website• Webcast available at

http://www.hud.gov/webcasts/archives/ph.cfm4 hours


HUD Guidance on EIV

EIV is sufficient as third-party verification when:• The family does not dispute the data, and• Current tenant-provided documents (i.e.

paystubs) are available


HUD Guidance on EIV

The PHA MUST obtain additional third-party verification when the family disputes EIV employer data


HUD Guidance on EIV The PHA MAY obtain additional third-party

verification when the PHA determines that additional information is necessary, such as:• Effective dates of employment• Pay rate, hours worked for new jobs• Confirmation of a change in circumstances

(reduced hours, reduced rate of pay)


HUD Guidance on EIV

Use tenant-provided documents to project annual income, unless:• The family disputes EIV employer data,

OR• The PHA determines that additional

information is necessary


HUD Guidance on EIV

HUD recommends that tenant-provided documents should be dated within 60 days of interview date• Current and consecutive


HUD Guidance on EIV Quote from webcast:

• “The PHA will use tenant-provided documents or most current information to calculate anticipated annual income.”

EIV quarterly wages are NOT used to project annual income


HUD Guidance on EIV:File Documentation

If the family does not dispute EIV employer data, and the PHA determines that additional information is not necessary:• EIV income details report

ICN in FL• Tenant-provided documents


HUD Guidance on EIV:File Documentation

If the family disputes, or PHA requires additional information:• EIV printout (except in FL)• Tenant-provided documents• Third-party written verification


EIV: Annual Reexams


EIV Modules

Tenant Income Data Income Discrepancy Report Different data for different purposes


Disclosure of EIV Data

PHAs may not disclose EIV data to any third parties (UIV data is property of HUD and protected by Federal Privacy Act)

PHAs in FL may not maintain HUD-provided UIV data in tenant files

PHAs may provide EIV data to the individual (only) to whom the record pertains

EIV data of minors may be provided to the minor’s parent or guardian


EIV Tenant Income Data Displays the most current data available

• 1 to 2 quarters old Review for all families at annual reexam

• Can also be used for interim reexams Meets regulatory requirement for third-party

verification• Per HUD guidelines


EIV Tenant Income Data

Not available at admission• Because family is not yet in PIC• Data will be available within 90 days of

admission Data is updated quarterly


EIV Tenant Income Data Navigate to Household Summary Report screen

• Search by name, SSN or birth date Note 3 tabs at top of screen

• Summary Report• Income Report• Income Discrepancy Report


Household Summary


Identity Verification Status

Displayed for each household member• Verified: tenant SSN, last name, and date

of birth combination has been verified by SSA

• Not Verified: tenant record has not been sent to SSA for verification yet


Identity Verification Status

• Failed: tenant SSN, last name and date of birth combination verification failed by SSA

• Deceased: according to SSA records, the tenant with SSN, last name and date of birth combination is deceased


Identity Verification



Click “Income Report” tab at top of screen Income data is displayed for all family

members• Earned/Unemployment: Family members 18 &

over• SSA/SSI: All family members• No data displayed for live-in aide









• Verifies Medicare Part B buy-in amount for medical expenses deduction




Data Processing Steps

Use of EIV data may require changes in PHA procedures for processing annual reexams• Different for each PHA

We’ll look at some basic processing steps• “I have the printout – now what??”



Reexam packet mailed to families• Add EIV informing notice • Request paystubs per PHA policy

Last 60 days would be reasonableShould be consistent among staff

• Request HUD-9886 for family members turning 18



Reexam packets returned to PHA Print & distribute EIV data Identify unreported employment/earnings Compare EIV and tenant-supplied documents

(paystubs)


Evaluating EIV Data

Annualize pay stubs• Average weekly x 52 or• Average bi-weekly x 26 or• Average semi-monthly x 24, etc.

May also consider year-to-date Need consistent method


Evaluating EIV Data

If family disputes EIV employment data:• PHA must request third-party written

verification


Evaluating EIV Data

If the PHA determines that additional information is necessary:• PHA must request third-party written verification

Effective dates of employmentPay rate, hours worked for new jobsConfirmation of a change in circumstances

(reduced hours, reduced rate of pay)


Evaluating EIV Data

If family does not dispute EIV data and no additional information is necessary:• Calculate annual income using paystubs


Evaluating EIV Data

If additional verification (such as employer statement) is obtained:• The PHA will use current tenant-provided

documents or most current information to calculate anticipated annual income


Evaluating EIV Data

File documentation• EIV printout (except FL)• Tenant-provided documents (paystubs)• Written third-party if required• Remember to leave a clear audit trail

Calculator tape, calculation worksheet, etc.


EIV Reports


EIV Reports Module

Existing tenant search Multiple subsidy report

• PIH and Multifamily Identity verification report Deceased tenant report


EIV Reports

Reports available by reexam month• Failed verification report• No income report (no income in EIV)• New hires report

Family members hired in last 180 days Can select “all” months to see complete list


HUD Monitoring


Consolidated Reviews

Program areas under review:• RIM• UIV• SEMAP• PHAS Management Assessment (MASS)• Civil rights


Consolidated Reviews

HUD UIV Monitoring Report• Implementation review• Security assessment• Income discrepancy review

5 highest dollar discrepancies per program


UIV Monitoring Report

Implementation• Has the PHA accessed EIV within 30

days?• Which UIV tools are used by the

PHA?


UIV Monitoring Report: Security Assessment

Designated security officer Security policies/procedures document Enforcement Record-keeping Separate user ID/password for each user



Signed authorizations & user agreements Key log for secure areas Log of destroyed documents OR records

retention policy Valid 9886 forms



Procedure for documentation of improper disclosures

Procedure for reporting security breaches Physical security measures Method of document disposal


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NMA Lunch ‘n’ Learn Seminar


Upcoming Lunch ‘n’ Learn Sessions…..

Nov 21, 2008 • Community Service

Dec 2, 2008• Effective Interviewing & Fraud Prevention

Dec 10, 2008 • Repositioning Public Housing Assets

Documents

Slide #1 © Copyright 2008 Nan McKay & Associates Annie Stevenson Managing EIV © Copyright 2008 Nan McKay & Associates