# Presentation: 752678

## HUD’S RENTAL HOUSING INTEGRITY IMPROVEMENT PROJECT (RHIIP)

## Table of Contents

**Introduction**
**Section I.****	****The Income and Rent Integrity Problem**
**Section II. ****	****Rental Housing Integrity Improvement Project**
**Section III.****	****Up-front Income Verification**
**Section IV.****	****Rental Integrity Monitoring**
**Conclusion/Questions and Answers**

**Rental Housing Integrity Improvement Project**

## Introduction 

- The ***income and rent integrity problem*** in public housing and voucher programs
- The RHIIP initiative, especially
- Up-front income verification
- The rental integrity monitoring (RIM) initiative
- Program simplification

**Rental Housing Integrity Improvement Project**

**Introduction **

## Presidential Management Initiative # 10 Mandate

-  HUD mandated to reduce errors by **50%** by 2005
-  HUD’s Annual Performance Plan set interim goals:
- A **15%** reduction in the dollar amount of error by **FY**** ****2003**
- A **30%** reduction by FY 2004

**Rental Housing Integrity Improvement Project**

## Improper Payments Information Act of 2002

- If amount of improper payments exceeds $10 million, agency must report on resulting actions, including:
- Causes of improper payments, corrective action taken, and results
- Whether the agency has the systems and infrastructure to reduce improper payments
- Steps taken to ensure agency managers are being held accountable

**Rental Housing Integrity Improvement Project**

## 2003 PD&R Quality Control Rental Assistance Subsidies Study 

- HUD Office of Policy Development and Research (PD&R) measurement of progress in reducing number/dollar amounts of rent calculation errors for 2003
- Data collected from 2,700 households at 600 sites (Section 8, Section 811, Section 202, and public housing)
- Information from tenant files and in-person interviews
- Data collection completed before Summer 2003
- Results reported in 2003 Performance and Account Report and Financial Statement Audit

**Rental Housing Integrity Improvement Project**

## Section ITHE INCOME AND RENT INTEGRITY PROBLEM 

## What is the Overall Problem?

- GAO designated HUD’s rental housing assistance as one of 22 “high risk” federal government areas
- HUD overpaid $2.3 billion in annual housing subsidies
- $1.7 billion in administrative/component errors
- $600 to $900 million in unreported tenant income
- HUD underpaid $634 million in annual housing subsidies

**Rental Housing Integrity Improvement Project**

## Major Error Findings

- PD&R’s 2001 *Quality Control for Rental Assistance Subsidies Determinations* study found:
- 34% of households paying at least $5 per month less than they should
- 22% of households paying at least $5 per month more than they should
**60% of rent calculations contain some type of rent, administrative, or component error **

**Rental Housing Integrity Improvement Project**

## Rent Errors

- Household paid too much rent (overpayment) or too little rent (underpayment). Rent errors include:
-   Dollar rent errors
-   Gross rent errors
-   Net rent errors
-   Error rate
**Source: ***Quality Control for Rental Assistance Subsidies Determinations*, 2001, pp. 16-17.

**Rental Housing Integrity Improvement Project**

## Dollar Impact of Rent Errors

- Subsidy overpayments:
-  $95 (average monthly error per tenant)
-  $1.699 billion (total annual program errors)
- Subsidy underpayments:
-  $56 (average monthly error per tenant)
-  $634 million (total annual program errors)
**Source: ***Quality Control for Rental Assistance Subsidies Determinations*, 2001, p. 20.

**Rental Housing Integrity Improvement Project**

## Component Errors

- Incorrect calculation of income and expense components. Component errors include:
-   **Income Components:**
-   Earned income
-   Social Security and pensions
-   Public assistance (TANF)
-   Income from assets
**  ****Expense/Allowance Components:**
-   Elderly/disabled allowance
-   Dependent allowance
-   Medical, childcare, and disability expenses
**Source: ***Quality Control for Rental Assistance Subsidies Determinations*, 2001, p. 16.

**Rental Housing Integrity Improvement Project**

## Dollar Impact of Component Errors

| Administrative Type | Average Total Dollar Impact of Component Errors
(Per household, per year) |
| --- | --- |
| Public Housing | $4,837 |
| PHA-Administered Section 8 | $5,070 |
| Owner-Administered Section 8 | $3,351 |

**Rental Housing Integrity Improvement Project**

**Source: ***Quality Control for Rental Assistance Subsidies Determinations*, 2001, p. 29.

## Administrative Errors

- Errors that result from mistakes in procedure. Administrative errors include:
- Consistency errors
- Calculation errors
- Transcription errors
- Failure to conduct timely recertifications
- Failure to verify information (e.g., income, family composition)
**Source: ***Quality Control for Rental Assistance Subsidies Determinations*, 2001, pp. 16-17.

**Rental Housing Integrity Improvement Project**

## Dollar Impact of Administrative Errors

| Error Type | Percentage of Households in Error | Average Gross Dollars in Error
(Per household, per month) |
| --- | --- | --- |
| Transcription Errors | 50% | $12 |
| Calculation Errors—Allowances | 8% | $26 |
| Calculation Errors—Income | 3% | $10 |
| Calculation Errors—Other | 23% | $18 |
| Overdue Recertifications | 6% | $9 |
| Any Administrative Errors | 64% | $12 |

**Rental Housing Integrity Improvement Project**

**Source: ***Quality Control for Rental Assistance Subsidies Determinations*, 2001, p. 38.

## Error Measurement Estimates from 2001 QC Study and Income Matching

- This chart includes a breakdown of the various subsidy determination errors by program groupings in $ millions. The first two columns of data come from income matching, the third and fourth from the QC study.

**Rental Housing Integrity Improvement Project**

|  | Excess Subsidy-Unreported Earnings | Excess Subsidy-Unreported Unearned | Excess Subsidy-POA Error | Subsidy Shortfall-POA Error | Net Total QC/Income Match Error |
| --- | --- | --- | --- | --- | --- |
| Public Housing | $280 | $14 | $431 | $201 | $524 |
| HCV/     Mod Rehab | $369 | $49 | $876 | $256 | $1,038 |
| Section  8- Project Based | $199 | $67 | $362 | $177 | $451 |
| Total | $848 | $130 | $1,669 | $634 | $2,013 |

## QC Study and IG Recommendations

- Provide POAs with forms/training/other tools needed to determine rent correctly
- Hold POAs accountable for implementing regulations and correct rent calculations
- Simplify federal laws/regulations/HUD requirements
- Support occupancy functions and conduct POA outreach regarding availability of occupancy-related resources

**Rental Housing Integrity Improvement Project**

## Section IIRENTAL HOUSING INTEGRITY IMPROVEMENT PROJECT 

## How HUD Is Addressing the Problem

- Reassessing operations
- Studying other agencies’ error reduction efforts (e.g., Food Stamp Program’s quality control program)
- Emphasizing options with the most error reduction payoff
**Rental Housing Integrity Improvement Project**
- Reduce errors
- Ensure the “right benefits go to the right persons”
- Stretch HUD’s limited program funds to serve as many people as possible

**Rental Housing Integrity Improvement Project**

## RHIIP Components

- Error measurement (PD&R)
- Training and technical assistance
- Program guidance
- Incentives and sanctions
**Program simplification**
**Up-front income verification (UIV)**
**Rental integrity monitoring (RIM)**

**Rental Housing Integrity Improvement Project**

## Impact of Improving Accuracy of Income and Rent

- Corrects subsidy estimates and payments
- Prevents costly and time consuming corrections
- Ensures fundamental fairness among families
- Serves more eligible households
- Ensures the integrity of HUD’s financial statement
- Reduces errors

**Rental Housing Integrity Improvement Project**

## Section IIIUP-FRONT INCOME VERIFICATION 

## Up-Front Income Verification (UIV) 

***Definition:*** Verification of income, before or during a family reexamination, through an independent source that systematically and uniformly maintains income information in computerized form for a large number of individuals.
- Key strategy for reducing the error rate
- Notice PIH 2001-15 strongly encourages UIV in addition to third party verification

**Rental Housing Integrity Improvement Project**

## Current Resources for UIV

- Social Security (SS) and Supplemental Security Income (SSI) information accessed via a secure Internet facility (TASS)
- State Wage Information Collection Agencies (SWICAs)
- State TANF systems
- Credit Bureau Association (CBA) Credit Reports
- Internal Revenue Service (IRS) Letter 1722
- Private sector databases (e.g., The Work Number)

**Rental Housing Integrity Improvement Project**

## Model Programs

_***Delaware***_***: Delaware State Housing Authority***
- Mainframe computer linked with Department of Labor (DOL) and Department of Health and Human Services (HHS). Other state PHAs also have link
- Receives DOL wage/unemployment/disability benefits data
- Receives HHS welfare benefits/child support information
- Link prevents fraud since tenants know income and benefit checks are being performed

**Rental Housing Integrity Improvement Project**

## Other Model Programs

***Virginia:*** Fairfax County Department of Housing and Community Development, Compliance and Community Relations Program
***Arizona:*** City of Phoenix Housing Department
***South Carolina:*** Housing Authority of the City of Columbia
***Oklahoma:*** Oklahoma City Housing Authority and Oklahoma Housing Finance Agency

**Rental Housing Integrity Improvement Project**

## Future Resources for UIV

- HUD UIV system
- Health and Human Service’s (HHS) National Directory of New Hires Database
- HR-1030 (legislation pending) would allow HUD to compare public and assisted housing-related employment and income data with HHS New Hires Database

**Rental Housing Integrity Improvement Project**

## HUD UIV System

***Objective:*** Make integrated income data available to PHAs from one source, via the Internet, to improve income verification and reduce errors
- HUD agreements with SWICAs will let PHAs access information through HUD’s database
- Goal: Agreements with 20 states by end of 2003
- HUD UIV pilot (PHAs in Florida, Ohio, and Texas)
- Implementation

**Rental Housing Integrity Improvement Project**

## HUD UIV System (cont.)

***Protocol:***
- HUD matches Social Security Numbers (SSNs) and PIC data with SWICA data for all tenants over 18 years of age.
- If the SSN is not in PIC, data will not be made available
- Initially, 100% four times per year, may go to upcoming recertifications
- Link in UIV system to OIG Hotline

**Rental Housing Integrity Improvement Project**

## HUD UIV System (cont.)

***Security (HUD):***
- Data held in secure sub-systems/modules in PIC system
- Internet data access limited to requesting agency
- Records maintained on PHA requests and responses from SWICAs, private vendors, and SSA
- Records maintained and reports sent to SWICAs, private vendors, and SSA on data archived or destroyed

**Rental Housing Integrity Improvement Project**

## HUD UIV System (cont.)

***Security (PHAs):***
- Form 9886 or equivalent information must be on file
- Tenant files must be securely maintained

**Rental Housing Integrity Improvement Project**

## 			
	 OFFICE OF INSPECTOR GENERAL	  U.S. Department of Housing and Urban Development	  WASHINGTON, D.C. 20410-4500			

                                                HOTLINE COMPLAINT INTAKE FORM

COMPLAINT 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:________

**	****	****	**
**	**** ****OFFICE OF INSPECTOR GENERAL**	  U.S. Department of Housing and Urban Development	  WASHINGTON, D.C. 20410-4500
-                                                 **HOTLINE COMPLAINT INTAKE FORM**
**COMPLAINT 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:________
**	****	****	****	**

**Rental Housing Integrity Improvement Project**** **

**Hotline: 800-347-3735**
**Fax: 202-708-4829**
**E-mail: **_[hotline@](mailto:hotline@hudoig.gov)__[hudoig](mailto:hotline@hudoig.gov)__[.](mailto:hotline@hudoig.gov)__[gov](mailto:hotline@hudoig.gov)_

## 			    United States Attorney  		                Southern District of New York FOR IMMEDIATE RELEASE	   CONTACT: U.S. ATTORNEY’S OFFICEJUNE 3, 2003      		MARVIN SMILON, HERBERT HADAD, 			MICHAEL KULSTAD			PUBLIC 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 costthe federal government more than $650,000.

*	**	**	**    ****United States Attorney******  ******	******	******                Southern District of New York**** ***FOR IMMEDIATE RELEASE****	****   CONTACT: **_**U.S. ATTORNEY’S OFFICE**_**JUNE 3, 2003      ****	****	****MARVIN SMILON, HERBERT HADAD, ****	****	****	****MICHAEL KULSTAD****	****	****	****PUBLIC INFORMATION OFFICE****	****	****	****(212) 637-2600**** ****	****	****	****BARBARA GUSS****	****	****	****(914) 993-1903****	****	****      **_**31 CHARGED WITH FEDERAL HOUSING FRAUD**_**     **_**THAT COST THE GOVERNMENT MORE THAN $650,000**_**     ****J****AMES 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 cost****the federal government more than $650,000.**

**Rental Housing Integrity Improvement Project**

**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 Housing Integrity Improvement Project**

## Section IVRENTAL INTEGRITY MONITORING 

## Rental Integrity Monitoring (RIM)

- In June of 2002, HUD Headquarters directed HUD Field Offices to conduct onsite monitoring of PHAs—RIM Reviews—to:
- Detect and reduce errors in income and rent calculations at targeted PHAs
- Reduce rent underpayments and overpayments by residents
- Maximize HUD’s limited housing resources

**Rental Housing Integrity Improvement Project**

## Establishing a Baseline for Measuring Error Reduction

- RIM Reviews of PHAs, conducted from 7/02 through 1/03, examined:
- Income and rent
- PHA management of the occupancy function
- Verification and documentation
- Consistency between HUD-50058 data and PHA onsite records
- RIM Review Error Tracking Reports, submitted 2/14/03, form baseline of rent/administrative/component errors affecting rental subsidy payments

**Rental Housing Integrity Improvement Project**

## What is a RIM Review?

- Onsite monitoring of PHA policies and procedures related to income and rent determinations, performed by Field Office reviewers, including:
- Review of sample tenant files
- Gathering of PHA income and rent information
- Assessment of PHA policies and procedures
- Identification of income and rent errors
- Analysis of income and rent errors to establish root causes/recommended corrective actions
- Recording of income and rent findings and errors

**Rental Housing Integrity Improvement Project**

## Selection of PHAs—Original 

- HUD Field Offices used the existing PIH risk model, especially SEMAP- and PHAS-troubled PHAs, to determine PHAs most likely to have serious rent and income errors. Model supplemented by:
- SEMAP Indicators #3, #9, and #10
- Information from the PD&R Quality Control Study on income errors
- REAC large-scale match data
- As a result of these criteria, over 360 PHAs already received RIM reviews

**Rental Housing Integrity Improvement Project**

## Selection of PHAs—New Guidance

***Top priority:***** **RIM Reviews completed for an additional 347 PHAs by September 30, 2003.** **
***Second priority:***** **Follow-up RIM reviews

**Rental Housing Integrity Improvement Project**

## RIM Review Onsite Monitoring Activities

-  Occupancy functions
- Skill level and competency
- Staff training program
- Occupancy policies
- PHA “job-aids” (forms, worksheets, guides, etc.)
- Process for accepting and processing applications
- Computer software and programs

**Rental Housing Integrity Improvement Project**

## RIM Review Onsite Monitoring Activities (cont.)

- Verification and documentation procedures
- Reliability and acceptability
- Extent of usage of UIV and third-party verification
- Tenant records
- Consistency
- Completion
- Security

**Rental Housing Integrity Improvement Project**

## PHA RIM Review Summary Report

- Describes findings and basis for findings
- Outlines strategies for correcting the findings
- Includes targeted dates for completing corrective actions
- Findings will be communicated to the PHA
- Preliminary findings to date mirror those from the PD&R Quality Control Study on income errors

**Rental Housing Integrity Improvement Project**

## Sample RIM Report Findings

- Lack of verification of income/deductions
- Earned income/pension/public assistance miscalculations
- Incomplete/outdated PHA policies
- Data not being transferred to MTCS/PIC
- Documentation in file did not match data used to determine income and rent
- Failure to offer choice of rent (flat rent or income-based)
- Hardship exemptions not being offered
- Improper calculation of utility allowances

**Rental Housing Integrity Improvement Project**

## Sample Recommended Corrective Actions

- Establishing or improving internal quality control systems
- Establishing or improving procedures for gathering data for rent calculations
- Providing additional staff training
- Developing a checklist and log of required documents
- Using up-front as well as third-party verification of data whenever possible
- Successfully submitting 85% of participant data into MTCS/PIC

**Rental Housing Integrity Improvement Project**

## Follow-up and Resolution

- HUD Field Offices will:
- Monitor on an on-going basis PHAs’ progress in resolving income and rent error findings/discrepancies
- Track PHAs’ responses to report issues
- Report findings to Headquarters via quarterly updates of the Error Tracking Reports
- Analyze any PHA difficulties in addressing issues/ taking appropriate actions and provide technical assistance, as needed
- Corrective Action Plan, if required

**Rental Housing Integrity Improvement Project**

## Next steps for PHAs

- Review occupancy procedures for compliance with regulations
- Update or develop worksheets or forms as needed
- Review the consent or release form
- Review competency of occupancy specialists and train as needed on income and rent determination, changes in the law, and revised forms
- Explore up-front and third party verification resources, including technological solutions
- Institute internal quality control checks

**Rental Housing Integrity Improvement Project**

## Conclusion

- HUD and PHAs need to work ***together*** to reduce income determination and rent calculation errors and meet the mandated goals:
- A** 15% **reduction in the dollar amount of error by FY 2003
- A **30%** reduction by FY 2004
- A **50%** reduction by FY 2005
- Reducing errors means more housing money for the people who need it the most.

**Rental Housing Integrity Improvement Project**

## Questions and Answers

**Rental Housing Integrity Improvement Project**