UNDERSTANDING EIVENTERPRISE INCOME VERIFICATION

http://portal.hud.gov/hudportal/HUD?src=/program_offices/housing/mfh/trx/trxsum

TRACS – Tenant Rental Assistance Certification System- The Vouchering system used to pay HAP requests.

EIV – Enterprise Income Verification- Income Verification system to verify incomes and residency status.

PASS – Physical Assessment Subsystems- to check REAC scores and reports.

iMAX- Integrated Multifamily Access Exchange. System used for O/A to communicate and submit TRACS files from site to HUD.

SAVE- Systematic Alien Verification for Entitlements- used to verify citizenship and status of noncitizens.

HUD SECURE SYSTEMS

HUD SECURE SYSTEMS

EIV HOME PAGE

• IPAs may use printed EIV documents when auditing an owner’s compliance (An IPA is an Independent Public Auditor hired to audit a property’s financial statements)

• Indicates the following reports must be run by selecting the “All” recertification month:

No Income Report New Hires Report Identity Verification Report Deceased Tenant Report

HIGHLIGHTS FROM HUD NOTICE 2011-21

• O/A must make sure that the income appearing on the EIV Income Report does not meet a regulatory income exclusion.

• Clarifies that a tenant’s monthly repayment agreement payment may exceed 40% of the family’s monthly adjusted income if the family agrees to the amount stated in the repayment agreement.

• Recommends that an O/A has the head of household and, if applicable, the family member who had the unreported income sign a repayment agreement.

• Indicates the comment field on the voucher must be completed when explaining payment and costs retained even if no costs were retained.

HUD NOTICE 2011-21

Identifies an updated penalty for not using the EIV system. The O/A will now incur a penalty of a five percent decrease in the voucher payment for the month following the date the violation was found and each subsequent voucher payment until the MOR finding is cured.

Indicates a new security training requirement. EIV users are now required to complete the online Cyber Awareness Challenge” training program. The most recent HUD EIV webcast will no longer satisfy the security training requirement.

Clarifies that when mailing EIV data, data must be sent to an office of the O/A and must not be mailed to Independent Auditor offices.

HUD NOTICE 2011-21

Traci Wallace sets up users and is our overall coordinator

The principal responsibility for running EIV Reports and using EIV rests with the Community Manager.

We can’t see what reports are being run, or not run. Each site and Regional Manager is responsible for monitoring use of the system.

Ongoing Security training and site security operations are in the hands of the Community Manager.

EIV RESPONSIBILITIES

The module for online security training for EIV and TRACS has changed.  To complete the online security training, please follow the revised steps below.

http://iase.disa.mil/eta/index.html#onlinetraining

Click on “CyberAwareness Challenge” icon on the IA Education, Training and Awareness screen

Click on “Launch CyberAwareness Challenge Federal Version” to proceed with the training

ONLINE SECURITY TRAINING

ONLINE SECURITY TRAINING

1. EIV User Access Authorization Form (UAAF)- copy of the initial UAAF, and current UAAF for all staff having access to EIV. The initial is either the hard copy that was completed by hand upon original access, or the original electronic UAAF (this depends on the date in which you first gained access to EIV); the current is a printed version of the electronic UAAF in EIV.

2. EIV User Security Awareness Training Questionnaire- copy of the initial and current Security Awareness Training Questionnaire for all staff having access to EIV. The initial is the hard copy that was completed by hand upon original access; the current is a printed version from the electronic Security Exam in EIV.

3. Copy of the Owner’s approval letter for Coordinator(s). 4. Copy of the Coordinator Access Authorization Form (CAAF) (original and current); for

all Coordinators. 5. Copy of the EIV Coordinator Security Awareness Training Questionnaire (original and

current); for all Coordinators. 6. Rules of Behavior Form for individuals without access to the EIV System. 7. A copy of the EIV & Fraud Policies. 8. Copy of the “Cyber Awareness Challenge” Training Completion certificate for all

Users and anyone who has a completed Rules of Behavior Form in the file.http://iase.disa.mil/eta/index.html#onlinetraining

EIV MASTER PROPERTY FILE

In addition to assisting with the verification process, EIV is to be used to Monitor Compliance of Existing Residents. Owners/Agents are required to periodically view certain reports. Each property must maintain the following Report Binders:

• Identity Verification Reports (monthly) Failed EIV Pre-Screening Reports Failed EIV SSA Identity Reports • Deceased Tenant Report (quarterly)

• New Hires Report (quarterly)• Multiple Occupancy (quarterly)

EIV MASTER FILES

Edgewood Report Binder Requirement

• You are also required to maintain a report binder for the “Income Discrepancy” Reports.

• The report, along with all back-up regarding researching the discrepancy, as well as documentation of how the discrepancy was resolved, should still remain in the resident file.

• Only a copy of the Discrepancy Report will be in the report binder. This will allow an auditor, RPM, or Compliance Specialist easy access to a list of residents who should have executed repayment agreements, so the appropriate follow up can be done to ensure the repayment agreement is executed and the proper documentation is in the file without having to review all resident files.

EIV MASTER FILES

Regular review of these reports helps reduce errors with assistance payments. Owners/Agents are required to ensure that:

• Data recorded in TRACS is correct. • Information provided by residents is correct. • Residents are complying with reporting

requirements.

EIV MASTER FILES

• Reports are to be run within the 1st 10 days of the month corresponding with the TRACS Transmissions

• The Master Files must be kept secure in the same manner that resident files are kept secure, and must be maintained for 3 years. You must document the file when EIV records are destroyed.

• The Master File is not intended to serve as a resource for documenting actions. Master Files are a tool to ensure that resident compliance is reviewed periodically.

• Owners/agents should make should make notes on the reports in the Master Files, but copies of notices, verification documents, certification corrections, etc. are maintained in the resident file.

EIV MASTER FILES

The Failed Pre-Screening & Failed Verification Reports must be reviewed each month. These reports will show identity discrepancies for residents living in your community.

Failed Pre-Screening Report- this report must be run every month and the report must remain in the property’s Master File for 3 years. The report displays residents whose SSA information provided on HUD Form 50059 failed some level of edit. Usually these errors are caused by data entry errors or situations that you already know about.

Failed Verification Report- the personal identifiers are matched against SSA’s records for each active resident in TRACS. For those that fail the identity match against SSA’s records; no employment or income information will be provided by SSA and they will provide information on why the verification failed.

IDENTITY VERIFICATION REPORTS

If the error has already been reviewed and a correction certification has been submitted to TRACS, check TRACS to make sure that the correction has been received. Make a note of it!

If the error is created because the household member is exempt from providing a SSN….make a note of it!

If the error is returned as a result of a “previously know” situation, such as a previously identified error with SSA….make a note of it!

If there is a discrepancy that cannot be readily explained by reviewing the resident file, the resident must be contacted. AND…..make a note of it!

IDENTITY VERIFICATION REPORTS MASTER FILE DOCUMENTATION

A copy of the Failed Verification or Failed Pre Screening Report reflecting the discrepancy (the resident file may only include information about members of that household)

If the error was caused by a data entry error, the signed corrected certification must be in the resident file

All correspondence with the resident If the data in EIV is incorrect, notify the resident that he/she should

contact SSA If the resident provided incorrect information:

Notice of Material Lease Violation Correction Certification New Verification (if appropriate) Repayment Agreement (if appropriate) Notice of Termination of Tenancy (if appropriate)

IDENTITY VERIFICATION REPORTSRESIDENT FILE DOCUMENTATION

IDENTITY VERIFICATION REPORTS

IDENTITY VERIFICATION REPORTS

IDENTITY VERIFICATION REPORTS

The report identifies residents who are currently reflected in TRACS as existing/active residents and who have been identified by SSA as deceased. (This report is updated every weekend)

This report must be reviewed Quarterly, and maintained in the Master EIV File for 3 years.

This report should not display information for a resident who has passed away when the move-out or interim certification has been successfully recorded in TRACS.

In most cases there is a timing issue. If the MO or IR has been sent to TRACS, check TRACS to make sure the transaction has been recorded correctly. If the transaction has been recorded in TRACS make a note in the Master File. If a family member failed to notify you about the death of your resident, you will need to verify the date of death and recalculate the assistance.

DECEASED RESIDENT REPORT

If the error has already been reviewed and a corrections certification has been submitted to TRACS, check TRACS to make sure that the correction has been received. Make a note of it!

If the error has already been reviewed and the MO or IR has been submitted to TRACS, make sure that the MO/IR has been received. Make a note of it!

If the error is returned as a result of a “false hit” or a “previously known” situation, such as a previously identified error with SSA……..make a note of it!

If there is a discrepancy that cannot be readily explained by reviewing the resident file…..make a note of it! The resident must be notified.

DECEASED TENANT REPORTMASTER FILE DOCUMENTATION

A copy of the Deceased Tenant Report reflecting the discrepancy (The resident file may only include information about members of that household)

If the error was caused by a data entry error, the signed corrected certification must be in the resident file

All correspondence with the resident If the data is EIV is incorrect, notify the resident that he/she should

contact SSA If SSA benefits have been suspended, may need to implement

hardship exemption to reduce rent. Corresponding verification and certification must be included in the file. Once resolved, create IR to reinstate appropriate assistance.

If the resident provided incorrect information:

Notice of Material Lease Violation Correction Certification New Verification (if appropriate) Repayment Agreement (if appropriate) Notice of Termination of Tenancy (if appropriate)

DECEASED TENANT REPORTRESIDENT FILE DOCUMENTATION

DECEASED TENANT REPORT

MULTIPLE SUBSIDY REPORT

If the error has already been reviewed and a correction certification has been submitted to TRACS, check TRACS to make sure that the correction has been received. Make a note of it!

If the error is caused by a situation where dual subsidy is acceptable (minor in a joint custody arrangement or a “split” household)...make a note of it!

If the error is returned as a result of a “false hit” or “previously known” situation, such as a problem with the previous owner/agent MO transaction…make a note of it!

If there is a discrepancy that cannot be readily explained by reviewing the resident file, you must contact the resident. AND…make a note of it!

MULTIPLE SUBSIDY REPORTMASTER FILE DOCUMENTATION

A copy of the Multiple Subsidy Report reflecting the discrepancy (the resident file may only include information about members of that household)

If the error was caused by a data entry error, the signed corrected certification must be in the resident file

All correspondence with the resident If the resident claims the data in EIV is incorrect; verify the

information with the Owner noted in EIV. If the former landlord will not respond- note why the 3rd party was not obtained, attempt review of documents, accept notarized self-certification. Notify the resident that he/she should contact the former landlord

If the resident provided incorrect information or is living in another HUD property:

Notice of Material Lease Violation Verification Correction Certification (if appropriate Termination/IC) Repayment Agreement (if appropriate) Notice of Termination of Tenancy (if appropriate)

MULTIPLE SUBSIDY REPORTRESIDENT FILE DOCUMENTATION

MULTIPLE SUBSIDY REPORT

MULTIPLE SUBSIDY REPORT

This report provides employment information for residents who may have started new jobs within the last 180 days.

The information in this report is updated monthly.

This report must be reviewed Quarterly and maintained in the EIV Master File.

Discrepancies must be investigated and resolved if possible.

NEW HIRES REPORT

If the error has already been reviewed and a correction certification has ben submitted to TRACS, check TRACS to make sure that the correction has been received. Make a note of it!

If the resident reported the new job and no new certification is required….make a note of it!

If the error is returned as a result of a “previously known” situation, such as a problem with the employer’s records that has already been investigated….make a note of it!

If there is a discrepancy that cannot be readily explained by reviewing the resident file, the resident must be contacted. Make a note of it!

NEW HIRES REPORTMASTER FILE DOCUMENTATION

A copy of the New Hires Report reflecting the undisclosed new job (the resident file may only include information about members of that household)

All correspondence with the resident If the resident claims the data in EIV is incorrect; verify the

information with the employer noted in EIV. If the employer will not respond- note why the 3rd party was not obtained, attempt review of documents, accept notarized self-certification. Notify the resident that he/she should contact the employer and obtain such correspondence if possible

If the resident provided incorrect information or failed to notify the Owner of a change:

Material Lease Violation If the resident agrees with the information, obtain documents (pay

stubs) If the resident does not agree, obtain 3rd party verification. Correction Certification (if appropriate) Repayment Agreement (if appropriate) Notice of Termination of Tenancy (if appropriate)

NEW HIRES REPORTRESIDENT FILE DOCUMENTATION

NEW HIRES REPORT

NEW HIRES REPORT

NEW HIRES REPORT

This report identifies applicants applying for housing that ,ay be receiving rental assistance at the time of application processing at another location.

Discuss with the applicant if the report identifies that the applicant or a member of the applicant’s household is residing at another location.

Follow up with the respective PHA or Owner/Agent to confirm the individual’s program participation status before admission.

The report gives the O/A the ability to coordinate move-out and move-in dates with the PHA or O/A of the property at the other location.

EXISTING TENANT SEARCH REPORT

EXISTING TENANT SEARCH REPORT

If there’s no current active 50059 in TRACS, there will be no EIV data for that household.

If the resident’s most recent certification isn’t in TRACS, the Income Discrepancy Report will be inaccurate.

If the Certification shows incorrect identifiers for a resident, EIV information will be missing.

EIV & TRACS

Review the information in TRACS regularly.

You MUST use the Tenant Certification Query to ensure each household has a current and active certification in TRACS.

Make sure it’s the most recent 50059.

Work with your CA to ensure all certifications are in TRACS. Some CA’s prefer to retransmit missing certifications themselves.

EIV & TRACS

EIV & TRACS

EIV & TRACS

EIV & TRACS

• The EIV Income Report must be used as a 3rd party source to verify a resident’s employment and income during mandatory recertifications (annual & interim).

• The EIV Income Discrepancy Report (along with the New Hires & No Income Reports) assists in identifying issues or discrepancies which may impact the household’s assistance.

• When selecting the Income Report for an individual resident, there are 3 options that must be used at the time of recertification (annual or interim):

• Summary Report, Income Report, Income Discrepancy Report

USING EIV INCOME REPORTS

The Summary Report provides a summary of information taken from the current active certification in the TRACS file at the time of the income match. This also provides the Identity Verification Status for each household member.

Verified- personal identifiers (last name DOB, SSN) match the SSA database.

Failed- personal identifiers do not match the SSA database. Not verified- personal identifiers have not yet been sent by HUD

to SSA for validation or the validation is in process. Deceased- SSA’s records indicate the person is deceased.

USING EIV INCOME REPORTSSUMMARY REPORT

Owners/Agents must resolve the status of any member with “failed” or “deceased”. In order to resolve the discrepancy, you will follow the same steps for resolving discrepancies with the Identity Verification Reports.

USING EIV INCOME REPORTSSUMMARY REPORT

The income report provides a variety of information about each member of a household. The components of the report are:

TRACS Certification Information and personal identifiers Employment information Wages Unemployment benefits Social Security benefits Dual Entitlements Supplemental Security Income benefits SSA Disability Status

INCOME REPORT

INCOME REPORT

The following documentation is required to be in the resident file to demonstrate the Owner’s compliance with mandated use of EIV as the 3rd party source to verify employment and income information.

No dispute of EIV Information- EIV Income Report, and current resident provided documentation.

Disputed EIV Information- EIV Income Report and 3rd party

verification from the source of the disputed information.

Resident reported income not verified through EIV- EIV income report, current acceptable resident-provided documents and/or 3rd party from source.

INCOME REPORT

The income report identifying the employment is to be used as 3rd party verification of employment and NOT to be used to calculate income.

If the resident agrees that the employment/unemployment information in EIV is correct, request the resident to provide 6 consecutive pay stubs (minimum of 4) to support the current income being received.

If the resident disputes the employment or unemployment information, or when a resident reports employment and there is no information in EIV, obtain 3rd party verification from the source.

INCOME REPORT

The Income Report identifying the Social Security benefit information in EIV must be used as 3rd party verification of the resident’s income and must be used to calculate the income.

A copy of the award letter is not required unless the resident disputes the SSA information in EIV.

INCOME REPORT

The Income Discrepancy Report identifies households where there is a difference of $2,400 or more annually in the wages, unemployment and/or Social Security benefits that are reported from the respective agencies vs. what is reported to TRACS on the HUD 50059.

The report identifies residents whose income may have been under or over reported.

Negative numbers on the report represent a potential resident under reporting income.

A positive number represents a potential decrease in a resident’s income.

You must investigate fully in either instance.

INCOME DISCREPANCY REPORT

INCOME DISCREPANCY REPORT

INCOME DISCREPANCY REPORTVALID DISCREPANCY

INCOME DISCREPANCY REPORTINVALID DISCREPANCY

Print the Income Discrepancy Report at the same time you print the Income Report. It is important these reports are printed at the same time because each week a completely new report is generated based on the current information in the system for a resident.

Review and resolve discrepancies within 30 days of the EIV Income Report date.

Retain the Report along with detailed information on the resolution of the reported discrepancy in the resident file. Regardless if the discrepancy was valid or invalid.

Make certain the information in TRACS agrees with information on the form HUD 50059 in the resident’s file. If the information in TRACS differs from what is on the resident’s current 50059, retransmit the current 50059.

INCOME DISCREPANCY REPORT

www.emcnet.biz/Compliance/EIV

ADDITIONAL RESOURCES

• Do you have the most recent HUD Notice in your Master EIV File?• What does it mean if you receive the error message “no contracts

are currently assigned to you”?’• Do you have a current Owner Approval Letter? • Who needs to use the Rules of Behavior Form? • How often do you have to complete the required Cyber Awareness

Challenge Training?

• Do you have the most recent Edgewood EIV & Fraud Policy in the Master EIV file?

FINAL REMINDERS

Traci WallaceEdgewood Management Corporation

Compliance DirectorCPO, BOS, HCCP, SHCM

(301) 562-1624twallace@emcmgmt.com

THANK YOU!