Slide #1 Annie Stevenson Enterprise Income Verification © Copyright 2008 Nan McKay & Associates.

Slide #1

Annie Stevenson

Enterprise Income Verification

© Copyright 2008 Nan McKay & Associates

Slide #2

Welcome to Lunch N Learn!

Upcoming topics for the occupancy series:• 9/4/08: Public Housing Denials and

Terminations• 9/5/08: HCV Reasonable Accommodation


Slide #3

Welcome to Lunch N Learn!

Today’s topics:• EIV data availability• Tenant income data processing• Income discrepancy report• EIV reports


Slide #4

Enterprise Income Verification (EIV) System


Slide #5

HUD’S Rental Housing Integrity Improvement Project (RHIIP)

Priority Secretarial initiative designed to reduce income and rent errors and improper subsidy payments

Comprehensive strategy to correct program errors in HUD’s high-risk rental housing subsidy programs

HUD’s objective: ensure the correct amount of assistance is provided to the families who need it


Slide #6

Statistics from 2001 Quality Control for Rental Assistance Subsidies Study

HUD overpaid rental subsidy by $2.6 billion (QC Study – 2001)

Estimated 60% of all subsidy and rent calculations contained some type of error:• Calculation errors• Failure to verify income • Incorrect deductions


Slide #7

Statistics from 2001 Quality Control for Rental Assistance Subsidies Study

Approximately 70% of subsidy payment errors are attributable to tenant under-reporting and/or non-disclosure of income• Intentional or unintentional


Slide #8

2001 Quality Control Report

Families statistically most likely to conceal income• Families with 2 or more sources of earned

income• Families with TANF and at least 1 source of

earned income


Slide #9

2001 Quality Control Report

Most error-prone components of rent calculation (PHA and tenant error)• Earned income• Social Security benefits• Allowances and deductions


Slide #10

HUD’s Strategy to Reduce Tenant Under-Reporting & Non-Disclosure of

Income Development and implementation of the

Enterprise Income Verification (EIV) System Encourage PHAs to implement UIV tools PHA resolution of substantial income

discrepancies disclosed through HUD UIV systems


Slide #11

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


Slide #12


UIV is an extremely effective tool for error reduction

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


Slide #13


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

applicants and participants


Slide #14

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


Slide #15

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$2400 discrepancy


Slide #16

NEW! HUD Guidance on EIV

Webcast available at http://www.hud.gov/webcasts/archives/ph.cfm

Training materials from webcast• Powerpoints, case study & solution• http://www.hud.gov/offices/pih/programs/ph/rhii

p/training.cfm


Slide #17

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


Slide #18

HUD Guidance on EIV

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


Slide #19

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)


Slide #20

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


Slide #21

HUD Guidance on EIV

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


Slide #22

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


Slide #23

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


Slide #24

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


Slide #25

EIV System Interactions© Copyright 2008 Nan McKay & Associates

Slide #26

Data Displayed by EIV

Employment information (new hires) Quarterly wages Unemployment insurance Social Security benefits (SS)

• Dual entitlement


Slide #27


Medicare data Supplemental Security (SSI) benefits Black Lung entitlement Disability information


Slide #28


National Directory of New Hires (NDNH) data replaced state SWICA data in October, 2005• EIV now contains NATIONAL wage and

unemployment data


Slide #29

Authorization for Release of Information/ Privacy Act Statement

(Form HUD-9886) Form 9886 is HUD’s authorization to perform

income-matching activities Form 9886 must be signed by:

• All adult family members (18 years of age) • Head & spouse, regardless of age


Slide #30

EIV Modules

Tenant Income Data Income Discrepancy Report

• Formerly Exceeds Threshold Report Different data for different purposes


Slide #31

EIV: Tenant Income Data


Slide #32

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


Slide #33


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

admission Data is updated quarterly


Slide #34

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 (later)


Slide #35

Household Summary© Copyright 2008 Nan McKay & Associates

Slide #36

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


Slide #37

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


Slide #38

Identity Verification© Copyright 2008 Nan McKay & Associates

Slide #39


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


Slide #40

EIV Tenant Income Data© Copyright 2008 Nan McKay & Associates

Slide #41


Slide #42


Slide #43


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


Slide #44


Slide #45


Print the results• “Printer Friendly Version” button• Opens a pop-up window

The printout is retained in the family’s file (except in FL) as per the PHA’s record retention policy


Slide #46


Slide #47


Slide #48

Timing of Quarterly & Monthly Income & Employment Data

There are time frames associated with the reporting of quarterly income and employment data

Employers and state unemployment offices are required to report calendar quarter data within specific timeframes


Slide #49

Income & Employment Data Reporting Timeframes

New Hire Employment Information• Employers are required to transmit by 2

monthly transmissions Quarterly Wage (Non-Federal)

• States are required to transmit within 4 months after the end of the reporting period


Slide #50

Income & Employment Data Reporting Timeframes

Quarterly Wage (Federal)• Federal agencies are required to transmit

no later than 1 month after the end of the reporting period

Quarterly Unemployment Compensation• States are required to transmit within 1

month after the end of the reporting period


Slide #51

EIV and Portability

HUD recommends that initial PHA should print EIV info and send to receiving PHA with portability paperwork

Receiving PHA will not have access until receiving agency has control of record in PIC


Slide #52

Tenant Income Data:Annual Reexam Processing


Slide #53

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??”


Slide #54

Data Processing Steps 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


Slide #55

Data Processing Steps

Reexam packets returned to PHA Print & distribute EIV data Compare EIV and tenant-supplied documents

(paystubs)• Unreported employment?• Other discrepancies?


Slide #56

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


Slide #57

Evaluating EIV Data

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

verification


Slide #58

Evaluating EIV Data If the PHA determines that additional information

is necessary:• PHA must request third-party written

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

(reduced hours, reduced rate of pay)


Slide #59

Evaluating EIV Data

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


Slide #60

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


Slide #61

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.


Slide #62

EIV: Income Discrepancy Report


Slide #63

Income Discrepancy Report

Data is not current Used to identify families who may have failed

to report or under-reported income in the past Excludes families with discrepancies

< $2400 per year• No substantial difference


Slide #64


The report identifies families with a discrepancy between:• A 50058 in PIC, and• EIV income for a prior period


Slide #65


Our job is to analyze the discrepancy, and to determine whether the family met reporting responsibilities

If family did NOT meet reporting responsibilities, was subsidy overpaid?


Slide #66


Some families on the report may have concealed income

Others are listed because they lost a source of income, such as a job


Slide #67

Key Concepts

The 50058 under consideration may not be the most recent 50058 in the case file

No adverse action may be taken based solely on the ETR• Third-party confirmation required


Slide #68

Key Concepts

Report compares EIV data with 50058 data for only these income types:• Earned: F, HA, M, W• Social Security or SSI: S, SS• Unemployment benefits: U

Report shows PIC income as $0 when none of these codes are present


Slide #69

Key Concepts

It may be necessary to determine start date and/or end date of employment in order to determine whether reporting responsibilities were met, and whether subsidy was overpaid


Slide #70

Income Discrepancy Resolution

Once the PHA has verified and validated the income discrepancy, the PHA should calculate the tenant retroactive rent due and initiate a repayment agreement and/or other corrective action

PHAs are encouraged to refer egregious cases to the local HUD OIG


Slide #71

Limitations of the Report

Early results indicate that about 1/3 of the households shown may have concealed or under-reported income• Very preliminary and based on only a few

PHAs• Still good information for identifying program

abuse


Slide #72


A household is eliminated from the report:• after a new 50058 submission (annual or

interim reexamination) resulting in an annual income discrepancy less than $2400

• and after 3 months lapse to allow for EIV reporting


Slide #73


This means that the PHA will need to identify “false positive” results and track these households until eliminated from the report• Could be a year or more• Prevent duplication of effort


Slide #74

EIV Policy Issues

Some PHAs have established an “amnesty” period to encourage full reporting• Participants given limited period to come

forward if they have concealed incomeWill not be terminated from programMust repay overpaid subsidy


Slide #75

EIV Policy Issues

Review admin plan policies for families who commit program abuse• For example, family didn’t report full-time student

daughter was working (how much income would you have counted for her?)$480

Was a sworn statement in the file? Was it false?


Slide #76

EIV Policy Issues

What are the guidelines for deciding between:• Demand for immediate repayment• Repayment agreement• Termination of assistance• Legal action

What if you have many families in this situation? Are you going to terminate all?


Slide #77

More EIV Information

HUD’s EIV page:• http://www.hud.gov/offices/pih/programs/ph/rhiip/

uivsystem.cfmEIV User Manual (revised December 2007)Privacy and Security RequirementsSecurity Procedures GuideFraud prosecutions as a result of UIV/EIV


Slide #78

EIV Reports


Slide #79

EIV Reports Module

Existing tenant search Multiple subsidy report

• PIH and Multifamily Identity verification report Deceased tenant report


Slide #80

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


Slide #81

NMA Lunch ‘n’ Learn Seminar

NEXT TOPIC…


Slide #1 Annie Stevenson Enterprise Income Verification © Copyright 2008 Nan McKay & Associates.

Documents

Transcript of Slide #1 Annie Stevenson Enterprise Income Verification © Copyright 2008 Nan McKay & Associates.