Post on 31-Dec-2015
description
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Rental Housing Integrity Improvement Project (RHIIP) Initiative
Secretarial initiative designed to reduce income and rent errors and improper subsidy payments
A comprehensive strategy to address root causes of income and rent errors in public housing and Section 8 HCV programs
Takes action to ensure the “right benefits go to the right persons”
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Background
The 2001 Office of Policy Development and Research (PD&R) Quality Control for Rental Assistance Subsidies Determination (QC) study found that HUD overpaid $2.6 billion and underpaid $634 million in annual housing subsidies
The QC study estimated that 60% of all rent and subsidy calculations contained some type of error
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Presidential Management Initiative #10
Mandated HUD to reduce the processing (administrative errors) error and improper payment rate by 50%, from 60% to 30% by 2005
HUD set aggressive interim goals in its Annual Performance Plan:
A 15% reduction by FY 2003 A 30% reduction by FY 2004
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Improper Payments Information Act of 2002
Requires agencies to: Annually review all programs
susceptible to significant erroneous payments
Measure the number and dollar amounts of errors and track progress towards reducing those errors
Report to the President and Congress, if the amount of improper payments exceeds $10 million
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2003 PD&R Quality Control Rental Assistance Subsidies Study
Methodology HUD PD&R measurement of progress
in reducing errors during FY 2003 Data collected from over 2,400
households at 600 sites Information from tenant files & in-
person interviews
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2003 PD&R Quality Control Rental Assistance Subsidies Study Results
Rental Assistance Program
FY 2003 Estimates of Errors/Gross Erroneous Payments
FY 2000 Estimates of Errors/Gross Erroneous Payments
% Reduction in Gross Errors
Public Housing $356,040 $631,776 43.6%
Vouchers & Mod Rehab
$797,508 $1,132,560 29.6%
Total PHA Administered
$1,153,548 $1,764,336 34.6%
Project-based Assistance
$395,796 $539,160 26.6%
Total $1,549,344
(+/– $229,000)
$2,303,496
(+/– $275,000)
32.7%
* – All values are presented in the thousands.
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FY 2003 Performance and Accountability Report, Note 17
Reports that HUD has exceeded its interim 2003 goal of a 15% reduction in administrative errors, based on study results for the first half of FY 2003
Describes the methodology used for updating the 2000 baseline error measurement
Discusses the corrective actions HUD has taken to address the causes of erroneous subsidy payments
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RIM Review Case Studies
Examined 37 large PHAs who had RIM reviews and follow-up reviews
Concluded that significant errors still existed, particularly regarding:
Verification of income
Improper calculations, including problems with utility allowances, deductions, and expenses
Accomplishments
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Accomplishments for 2003—Error Reduction Efforts
Exceeded HUD’s interim FY 2003 goal of a 15% reduction in estimated program administrator errors
Worked and coordinated with the Inspector General (IG) on fraud cases
Issued a letter to Certified Public Accountants (CPAs) to assess, mitigate, & report PHA improper calculation of subsidy payments
Presented the strategic goals and RHIIP objectives at over 30 conferences/meetings to industry group leaders
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Accomplishments for 2003— Monitoring/Reporting
Conducted over 700 RIM reviews at PHAs managing over 80 percent of PIH's funding
Exceeded the goal of an 85 percent PIC reporting rating -- 89 percent for public housing and 98 percent for HCV
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Accomplishments for 2003— Income Matching
Developed and began to test pilot the Upfront Income Verification (UIV) System at 40 PHAs in 7 pilot states
Established agreements with 24 states to allow computer matching of tenant income and State wage data
Legislation was introduced in Congress to access and use the National Directory of New Hires Database to detect unreported income
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Accomplishments for 2003— Guidance/Staff Training
Released the first Public Housing Occupancy Guidebook in over 20 years
Issued the Notice PIH 2003-34, Rental Integrity Monitoring (RIM) Disallowed Costs and Sanctions under RHIIP
Launched the new PIH RHIIP website Provided occupancy training to Field
Office staff and scheduled two regional trainings in occupancy for PHA: 1/26 to 1/30 and 2/2 to 2/6
Policy/Guidance
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PIH Policy and Guidance Program Simplification Proposals
Pubic Housing Occupancy and HCV Program Guidebooks, June 2003
Fact Sheet on Income and Rent Determinations, November 2002
Notice PIH 2003-34, Rental Integrity Monitoring (RIM) Disallowed Costs and Sanctions under RHIIP, December 19, 2003
Verification Guidance for PHAs (early 2004)
Up-front Income Verification (UIV)
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Current Sources for UIV Data
Social Security (SS) and Supplemental Security Income (SSI) information accessed via the Tenant Assessment Subsystem (TASS)
State Wage Information Collection Agencies (SWICAs)
State Temporary Assistance for Needy Families (TANF) systems
Private sector databases (e.g., The Work Number)
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HUD’s Tenant Assessment Subsystem (TASS)
The system compares tenant-reported information to other HUD systems with income data stored in the SSA and the IRS databases
Displays gross and net benefits for any Social Security Number (SSN) that is subsidized by HUD
HUD strongly encourages PHAs to systematically use the system to reduce incidents of undisclosed SS and SSI income
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HUD’s Tenant Assessment Subsystem (cont.)
HUD TASS Point of Contact (POC): Myra Newbill 202-708-4932 ext. 3211
HUD TASS website location: http://www.hud.gov/offices/reac/products/prodtass.cfm
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UIV System Pilot
Commenced on August 18, 2003
Participants: 40 PHAs in 8 states, with over 400 users
Currently testing release 3.0.1
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UIV System Pilot (cont.)
Objectives:
Obtain feedback on how wage and benefit data is displayed
Identify and assess implications of accessing SWICA data
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UIV System
For tenant recertifications, not new admissions--wage and benefit data is pulled for existing Social Security Numbers (SSNs) in the PIC system
PHAs may not view the tenant data without a signed Form HUD-9886, Authorization for the Release of Information/Privacy Act Notice in the tenant’s file
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Coming Soon: HUD UIV System
Will make integrated income data available to PHAs from one source via the Internet
Allows PHAs to view quarterly wage, weekly/bi-weekly unemployment, and monthly SS benefit information for tenants in their jurisdiction
Provides wage and benefit information through a data matching process for households covered by HUD Form 50058
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UIV System Privacy Requirements
Data must only be used for verification of tenant income and eligibility
Data must not be disclosed in any way that would violate the privacy of the individuals represented in the system
Tenants must be provided with access to their records and an opportunity to correct or challenge their contents
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UIV System Security
PHA Responsibilities: Ensure that access rights, roles and
responsibilities within PHAs are appropriately and adequately assigned and monitored
Conduct quarterly reviews conducted for all User IDs to determine if user still needs access to UIV data
Maintain security-related records Conduct security awareness training
Fraud
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OFFICE OF INSPECTOR GENERAL U.S. Department of Housing and Urban Development WASHINGTON, D.C. 20410-4500
HOTLINE COMPLAINT INTAKE FORMCOMPLAINT INFORMATION
Date:_______
COMPLAINANT CONTACT INFORMATION
PHA Name:________________________
Point of Contact Name:______________________
Address:___________________________ (Street)
___________________ _____________ _______________ (City) (State) (Zip Code)
Telephone: (Work)___________ (Cell Phone)_________________
Email:___________________________
SUBJECT INFORMATION
Subject Name or Name of Business:_____________________________________
Subject Address (If known) __________________, _________, ______ _________ (Street) (City) (State) (Zip Code)
COMPLAINT SUMMARY (Attach additional pages if necessary):
Loss Amount:
Nature of Allegation:
Initial Certification:________Recertification:________ U.S. Department of Housing and Urban
Development WASHINGTON, D.C. 20410-4500
Reporting Fraud
Hotline: 800-347-3735
Fax: 202-708-4829
Note: Incidents of fraud may be followed-up by HUD Field Offices and the Inspector General
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United States Attorney Southern District of New York
FOR IMMEDIATE RELEASE CONTACT: U.S. ATTORNEY’S OFFICEJUNE 3, 2003 MARVIN SMILON, HERBERT HADAD,
MICHAEL KULSTADPUBLIC INFORMATION OFFICE(212) 637-2600
BARBARA GUSS(914) 993-1903
31 CHARGED WITH FEDERAL HOUSING FRAUD THAT COST THE GOVERNMENT MORE THAN $650,000
JAMES B. COMEY, the United States Attorney for the Southern District of New York; RUTH A. RITZEMA the Special Agent in Charge of the New York/New Jersey Office of the Inspector General of the U.S. Department of Housing and Urban Development (“HUD”); and CHARLES A. COLA, the Commissioner of the Yonkers Police Department, announced that 31 defendants were charged with obtaining private housing rental subsidies to which they were not entitled. Twenty-seven were arrested and 4 others were being sought. The defendants were charged in 14 separate criminal Complaints unsealed in White Plains federal court and were presented in Court today before United States Magistrate Judge George A. YANTHIS. The defendant’ fraud is alleged to have costthe federal government more than $650,000.
Reporting Fraud
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Yonkers housing fraud bust nets charges against 31
By WILL DAVID THE JOURNAL NEWS (Original publication: June 4, 2003)
YONKERS — A federal and local investigation aimed at stamping out fraud in the Yonkers Municipal Housing Authority's Section 8 rent subsidy program culminated yesterday with the arrests of 27 people, and four others are being sought in connection with the probe, authorities said.
The 31 people charged in the investigation — all but two from Yonkers — are accused of obtaining private housing rental subsidies they were not entitled to because their incomes were too high, said James B. Comey, the U.S. attorney for the Southern District of New York.
Rental Integrity Monitoring (RIM) Re-reviews
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Purpose of Re-reviews
Confirm whether the PHA has implemented corrective actions as outlined in its approved corrective action plan (CAP)
Verify that the implementation of corrective actions has led to a reduction of errors
Determine whether errors identified during the initial RIM review have been corrected
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Scheduling of Re-reviews
Field offices must perform re-reviews to PHAs that received initial reviews during periods:
Baseline I (completed prior to 1/31/03). Re-reviews to be completed by 4/30/04
Baseline II (completed after 4/21/03 guidance). Re-reviews for PHA programs requiring CAP or when systemic errors were found to be completed by 9/30/04
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Re-review Protocol
Field Offices must:
Review approved PHA CAP; verify implementation and establishment of internal controls
Review initial and newly selected tenant files to ensure errors are corrected and determine accuracy of income/rent calculations after CAP implementation
Take appropriate action when PHA fails to comply with initial RIM review requirements
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Re-review Reporting Requirements
All re-reviewed PHAs receive a report that:
Details whether all corrective actions have been implemented
Lists findings, required corrective actions, observations & recommendations from review of new file sample
Details results of re-review of initial RIM review tenant files
Explains any actions/sanctions to be taken against the PHA
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Re-review Reporting Requirements (cont.)
PHAs are provided with final written report within 45 days of completion of re-review
PHAs are required to respond to the review report within 30 days, but not later than 45 days
Response must address problems found or enter into CAP; any disagreements with findings or proposed corrective actions must be addressed with the FO at this time
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Re-review Reporting Requirements (cont.)
If systemic or material findings exist, a copy of the review report should be sent to the PHA’s Independent Public Accountant (IPA) auditor
If actions must be taken against a PHA for failure to address deficiencies from the first RIM review, Field Offices must advise the Financial Management Center (FMC) to take appropriate action
Sanctions
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Sanctions Notice PIH 2003-34
Highlights the importance of timely and accurate income and rent determinations by PHAs and establishes consequences for failure to identify and correct deficiencies
An concerted approach to ensuring improved government performance and proper subsidy determinations in HUD’s rental programs
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Sanctions Notice PIH 2003-34 (cont.)
Applies to Public Housing and Section 8 HCV Program
Issued December 19, 2003 and its application became mandatory for all RIM actions—including reviews, required PHA responses, and corrective actions—subsequent to December 31, 2003
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Sanctions Notice—Areas Addressed Incentives, disallowed costs, and collection
of excess subsidies paid Sanctions for failure to timely respond to
the RIM Review Report and to implement a CAP
Adjustment of Section 8 Management Assessment Program (SEMAP) scores when inconsistent with RIM review findings
Self-assessment reviews Appeals
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Disallowed Costs Relate to PHA errors uncovered during
RIM reviews resulting in HUD overpayment of subsidy
Subsidy overpayments must be returned to HUD
Note: Disallowed costs due to HUD shall be forgiven if amounts are less than or equal to $2,500 per PHA program review
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Disallowed Costs/Excess Subsidies—HCV Program
Tenant Fraud
Overpayments: PHAs who enter into a repayment agreement with the family, initiate litigation against the family to recover excess subsidies, or initiate termination from the program may keep 50% of HCV funds collected if certain conditions are met. PHAs that do not do any of the above actions must return to HUD all amounts that constitute a subsidy overpayment
Underpayments: Not applicable
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Disallowed Costs/Excess Subsidies—HCV Program (cont.)
PHA Errors
Overpayments: PHA reimburses HUD for 50% of disallowed costs in excess of $2,000 dating from latest reexamination. PHA must correct tenant records and ensure accurate rent payments
Underpayments: PHA may only be reimbursed for current fiscal year not yet settled in HUDCAPS. PHA reimburses tenant according to PHA policy
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Disallowed Costs/Excess Subsidies—Public Housing Program
Tenant Fraud Overpayments: If PHAs detect tenant fraud
and enter into a repayment agreement with the family, sue the family to recover excess subsidies, or initiate eviction (public housing), they may keep 100% of fraud collections. PHAs that do not do any of the above actions must return to HUD all amounts that constitute a subsidy overpayment
Underpayments: Not applicable
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Disallowed Costs/Excess Subsidies—Public Housing Program (cont.)
PHA Errors
Overpayments: If the errors affect the rent roll used for operating subsidy calculation, HUD will calculate disallowed costs based on subsidy overpayment
Underpayments: PHAs will not be reimbursed by HUD. PHA reimburses tenant according to PHA policy
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Sanctions If a PHA does not respond to a RIM Review
Report within 45 days or does not implement corrective actions within approved timeframes, the Field Office can withhold: 10% of its monthly scheduled HCV
administrative fee 5% of its monthly scheduled Public
Housing operating subsidy Withholding begins with the month the
sanction is imposed and lasts until the PHA complies with program requirements
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SEMAP Indicator 3 A RIM review may serve as a SEMAP
confirmatory review
If a RIM review doesn’t support a PHA’s self-certification of SEMAP Indicator 3 (Determination of Adjusted Income) the Field Office must adjust the SEMAP score, regardless of its impact on the PHA’s performance designation
If a RIM review finds other indicators are not supported by file or other documentation, the SEMAP score for those indicators shall be adjusted
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Self-Assessment Reviews During FY 2004 and FY 2005, HUD will
conduct targeted and random RIM reviews of PHAs managing over 250 combined units of public housing and vouchers
HUD strongly encourages PHAs to conduct self-assessment reviews to quality control and ensure that the PHA’s income and rent determination process is in compliance with program requirements
RIM reference materials are available at: http://www.hud.gov/offices/pih/programs/ph/rhiip/index.cfm
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Sanctions Notice—Appeals A PHA may appeal a sanction/disallowed
cost to its Field Office within 30 days of imposition of adverse action(s)
Written appeals must provide material evidence or justification of any arguments or additional facts and data concerning the action
The Field Office must respond within 30 days from the receipt of a request for an appeal or the appeal is automatically granted
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Sanctions Notice—Appeals (cont.) If the Field Office denies the appeal, the
PHA has 15 days to appeal to the PIH Assistant Secretary
If the appeal is denied by the Assistant Secretary, there are no further appeals permitted for that sanction/disallowed cost
Note: For adjustments of SEMAP scores as a result of a RIM review, please refer to the SEMAP appeals process
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PHAs and RHIIP
HUD is committed to its error reduction goals, but we need PHA cooperation and
support to succeed in all our RHIIP initiatives!
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PHA Action: The Key to a Successful 2004!
Know and refer to HUD guidance materials Follow-up on RIM review findings Implement TASS and UIV to the extent
possible Visit the new PIH RHIIP website often at:
http://www.hud.gov/offices/pih/programs/ph/rhiip/index.cfm
Run your program like a business!
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Resolution for 2004
To continue to work together to further reduce errors in 2004 and ensure that there’s more housing money for those who need it the most.
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Questions and Answers