# Presentation: 824109

## HUD RHIIP Training – PH/HCV

- Chapter 5: Verifications

- Chapter 5: Verification

- May 2003

## Up-Front Income Verifications

- Under the RHIIP Initiative there is a new emphasis on the use of Up-Front Income Verification (UIV) techniques
- HUD estimates that $600 to $900 million in income and rent errors are attributable to unreported income

- Chapter 5: Verification

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## Up-Front Income Verifications

- UIV is a key strategy in reducing these errors and has been proven to increase the accuracy and efficiency in determining family eligibility and rent calculations

- Chapter 5: Verification

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## Up-Front Income Verifications

- Due to the importance of UIV, this concept will be discussed in depth later in this session

- Chapter 5: Verification

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## Verifications Overview

- Cuts across all occupancy areas
- All information in tenant family’s file must be verified and properly documented
- PHAs need to establish verification standards and procedures in the ACOP/Admin Plan
- Documentation and verification is a joint responsibility of the PHA and family
- Family must provide required paperwork and sign release forms
- Family must be responsive to requests

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## Overview

- Verifications are key to high quality administration
- Income verification plays an intricate role in determining family eligibility and the amount of rental subsidy

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## Release Forms

- To obtain verifications, a PHA must obtain a release of information from the family member whose info. is being requested
- HUD Form 9886 (required)
- Verification request forms for specific types of information
- PHAs should not use generic release forms

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## Authorization for Release of Information/ Privacy Act Statement (form HUD-9886)

- All adult family members & spouse must sign
- Can be used between regular reexams to verify unreported income
- Applicant’s certification that income & other information is accurate and complete

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## Authorization for Release of Information/ Privacy Act Statement (form HUD-9886)

- HUD-9886 may only be used for verification sources listed on the form
- Valid for 15 months from date of signature

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## What Must Be Verified

- In this section we will be discussing what must be verified in terms of income and rent issues

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## What Must Be Verified

- Income, assets and asset income
- Divested assets
- Income exclusions
- Allowances and deductions
- Family composition
- Social security numbers
- Citizenship or Eligible Immigration Status

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## Verifying Annual Income

- PHAs need a thorough understanding of what constitutes income
- PHAs should not make assumptions about whether someone may or may not have a particular type of income
- For example, family without children may be receiving back child support payments

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## Verifying Annual Income

- Requires PHA staff to conduct a thorough interview
- Initial interview sets the groundwork for future interim/annual reexam interviews
- Purpose is to obtain complete and accurate household income information

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## Verifying Annual Income

- Many PHAs have gone to mail-in recertifications; it is imperative that the PHA’s written materials ask the right questions

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## Zero Income Families

- A family budget or statement of financial responsibility may be required
- Use up-front verification, for example:
- SWICA
- Credit report
- PHAs must attempt to determine the source of income when the family’s regular expenditures conflict with their claim of zero income

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- May 2003

**Notes:**
Trainer note: SWICA CFRs begin at 5.234

## Verifying Income Exclusions

- A PHA needs to obtain verification for an income exclusion, if, without that verification, a PHA would not be able to determine whether or not the income is to be excluded

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## Verifying Income Exclusions

- Depending on the circumstances any or all of the following may need to be verified
- Source of excluded income
- Circumstances that qualify family member’s income to be excluded
- Amount of exclusion

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## Verifying Income Exclusions

- For example, payments received under Title V of the Older Americans Act of 1985
- The PHA would have to, at minimum, verify the source of that income
- The wages of a child under 18 would be the same situation
- Verify age - verification of amount is not necessary for wages

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## Verifying Income Exclusions

- There are also situations where it would be necessary to obtain 3rd party of both the source and the amount of the income in order to calculate appropriately, for example;
- Mandatory earned income disallowance
- Qualifying State or Local training program income

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**Notes:**
Do we want to leave the reference to 3rd party here? Because actual amounts are important to have

## Verifying Income Exclusions

- Even though the need or type of verification may differ, all exclusions and excluded amounts associated with family members must
- be declared by the family, and
- be reported by the PHA in field 7e of the 50058

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## Verifying Allowances and Deductions

- PHAs must also take into account all anticipated deductions from annual income to obtain accurate adjusted annual income

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## What Must Be Verified

- Deductions, such as;
- Family members under 18
- Age or disability of head or spouse
- Disability of other family members
- Full time student status
- Child care costs
- Disability assistance expense
- Unreimbursed medical expenses

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## Verification and Documentation

- UIV and/or third party written verification
- To the maximum extent feasible, PHAs should utilize up-front verification sources
- TASS (Tenant Assessment Sub-System)
- SWICAs (State Wage Info. Collection Agencies)
- The Work Number
- Must not be hand carried by the family
- Independent, directly from third party by mail, fax, or other reliable means

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**Notes:**
Trainer Note: TASS is going to folded into the integrated UIV system

## Verification and Documentation

- Third party oral verification
- Use where third party written is impossible to obtain or not timely (follow up with written)
- Phone or interview by PHA staff
- PHA records information
- Date/time of contact
- Name and source of information
- PHA staff name/signature
- Summary of information
- Rationale for using oral verification

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## Verification and Documentation

- 3. Document review
- Record of documents reviewed by PHA which support family’s statements
- Original copies of documents should be reviewed, photocopied (unless prohibited by law), and placed in family’s file
- PHA summarizes information and signs/dates
- PHA follows-up with written verification and documents why this verification method used

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## Verification and Documentation

- 3. Document review
- Examples of documents viewed include:
- Pay stubs
- Bank statements
- Award letters or benefit checks
- Child support payment cancelled checks and/or award letters
- IRS tax forms, including Form 1099, Form 1040, Form 4506 and Form 8821
- W-2 forms

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## Verification and Documentation

- Family Declaration or Certification
- Used only when other methods are impossible
- Can use notarized statement or signed affidavit from family attesting to information
- PHA must clearly document why other verification methods were not used

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## Verification and Documentation

- PHAs need to establish timeframes for receipt of third party verification before accepting documents provided by the family
- i.e; 2 weeks and follow up, 4 weeks, 21 days, 30 days, etc.
- Must document in the case file why third party was not available

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## Verification and Documentation

- The PHA is the final judge of what constitutes adequate and credible verification and documentation
- If there is doubt about reliability of information, staff should pursue additional information
- PHA should have reasonable confidence that documentation is accurate
- PHA staff are not required to accept information, simply because it is offered

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## Verification and Documentation

- PHA should establish reasonable time limits on “age” of documentation sources
- Generally, documentation that is more than 90-120 days old should be considered “not timely”  (obtain new documentation)
- Not applicable to date of birth, SSNs, citizenship
- PHA must verify that an applicant is eligible within 60 days before the PHA issues a voucher (982.201[e])

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## Discussion:Verification Issues

- How should the PHAs resolve discrepancies between third-party verifications and documents (i.e. pay stubs)?
- a) Always use third-party verification
- b) Always use information from pay stubs
- c) Use the method that benefits the family
- d) Contact the source of third-party verification

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## Discussion:Verification Issues

- How should the PHAs resolve discrepancies between third-party verifications and documents (i.e. pay stubs)?
- a) Always use third-party verification
- b) Always use information from pay stubs
- c) Use the method that benefits the family
- d) ***Contact the source of third-party verification*****

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## Up-Front Income Verifications

- HUD Presenter

- Chapter 5: Verification

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## Up-Front Income Verifications

- Definition: the verification of income through an independent source
- Before or during family reexamination
- Systematically and uniformly maintains income information in computerized form for a large number of individuals

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## Up-Front Income Verifications

- HUD strongly encourages that PHAs to use up-front income verification during all required reexaminations of family income

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## Up-Front Income Verifications

- Use of up-front income verifications will:
- Strengthen the income verification process
- Expedite the process
- Reduce income and rent errors
- Promote integrity in the reporting of income
- Reduce underreporting and unreported income
- Decrease housing fraud

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## Types of UIV Techniques

- Tenant Assessment Sub-System (TASS)
- Social Security and SSI benefit information
- Available to all PHAs through HUD
- PHAs may contact REAC to obtain a user ID and password
- _[http://hud.gov/offices/reac/online/online_registration.cfm](http://hud.gov/offices/reac/online/online_registration.cfm)_

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## Types of UIV Techniques

- State Wage Information Collection Agencies (SWICA)
- PHAs may enter into MOU or MOA with the SWICA to get wage and unemployment data
- PHAs pay a fee
- SWICAs may share data electronically or on paper

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## Private UIV Vendors

- Various Private UIV Vendors
- Provides controlled access to a national database of employment records
- Provides automated verification of employment and income
- Data is received from employer on a “per pay period” basis

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## Private UIV Vendors

- The Work Number
- 800-996-7566 or _[www.theworknumber.com](http://www.theworknumber.com/)_
- Basic service is free
- Advanced HR Solutions
- 800-211-6645 or _[www.advancedhr.com](http://www.advancedhr.com/)_
- Free for government agencies
- Experian
- 888-217-6064 X 1176 or _[www.experian.com](http://www.experian.com/)_
- Contact company for cost

- *List is not all-inclusive – other vendors are available

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## Types of UIV Techniques

- Federal, State and/or Local Government Agencies
- For example, Department of Social Services, VA, local Child Support Office
- PHAs may enter into a MOU or MOA

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## Types of Income Verified

- All income types may be verified using UIV
- Wages, social security benefits, disability benefits, pensions etc
- Income from assets may not be verifiable through UIV

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## UIV Process

- PHA obtains income verification using UIV prior to obtaining information from family
- UIV information is available to the PHA during the family reexamination
- PHA compares UIV information and family disclosed information
- PHA should inform family of use of UIV

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## Tenant Consent

- PHA is always required to obtain signature of all family members 18 yrs and older on a consent form authorizing release of information
- PHAs should review their consent forms to ensure that various methods to verify income are included

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- May 2003