# Presentation: 006469

## UPFRONT INCOME VERIFICATION:
The Key to Reducing Income and Rent Errors within HUD Rental Assistance Programs

Introduction of HUD’s New EIV System

October 13, 2005

- The Key to Reducing Income and Rent Errors within HUD Rental Assistance Programs
***Introduction of HUD’s New EIV System***
- October 13, 2005

- Rental Housing Integrity Improvement Project (RHIIP) Training

## Agenda

- Welcome
- Rental Housing Integrity Improvement Project (RHIIP) Overview
- What’s New in the Enterprise Income Verification (EIV) System
- Security Awareness
- Getting Connected & Using EIV
- How to Use UIV Data & Income Discrepancy Resolution
- Questions & Answers Session

## 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

## What is Upfront Income Verification (UIV)?

_***Upfront Income Verification:***_*  *
*   **the verification of income, before or during a family re-examination, through an independent source that systemically and uniformly maintains income information in computerized form for a large number of individuals.*

## Getting Access to EIV

- PHA Executive Director identifies User Administrator(s) and occupancy users
- Submit access authorization and use agreement forms to HUD Field Office
- HUD Field Office approves PHA User Administrator(s)
- User administrators requests access for all staff
- HUD Field Office approves PHA requests
- ** All EIV users must have a WASS ID with PIC & EIV access rights

## Getting Access to EIV - Continued

- To request & obtain a WASS ID, go to:
**https://entp.hud.gov/idapp/html/pha_reg.htm**** **
- To obtain copies of EIV Access Authorization and/or Rules of Behavior and User Agreement forms, go to:
**http://www.hud.gov/offices/pih/programs/ph/rhiip/uivsystem.cfm**

## Logging On To EIV

- Click continue at the Legal Warning & Warning Notice screen

## Logging On To EIV - Continued

- Click on the Enterprise Income Verification (EIV) link to access the system
- Note:  If user does not see EIV link make sure WASS ID has PIC and EIV access rights assigned to it

## Using The EIV System

## Using The EIV System

## Obtaining Income Information For a Household

- Users can search for income records by HOH SSN or Re-examination month
- Click on either link to begin search

- Click on either link to begin search

## Searching For Income Records By Head of Household SSN

## Searching For Income Records By Head of Household SSN - Continued

- EIV allows multiple search criteria
- Head of Household SSN; and/or
- Head of Household Last Name; and/or
- Exact match
- Begins with
- Head of Household Date of Birth
- Click on **Search** or press **Enter**
- _Note:_  it easiest to search by simply entering the 	HOH’s SSN

## Searching For Income Records By Program Type and Re-examination Month

## Searching For Income Records By Program Type and Re-examination Month

- User can search for income records by:
- Program Type
- All PIH Programs; or
- Public Housing; or
- Section 8
- Re-examination Month

## Identity Verification Status

- _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
- _Failed:_ tenant SSN, last name and date of birth combination verification failed by SSA. No income information is displayed
- _Deceased:_ according to SSA records, the tenant with SSN, last name and date of birth combination is deceased
- Note:  Income information  will only be displayed          	     for individuals whose identity verification 	        	     status is “verified”

## Identity Verification StatusSample Screen Shots

- Failed

- Not Verified

## Identity Verification StatusSample Screen Shots - Continued

- Not Verified

- When identity verification status is deceased or failed, detailed information regarding the error is available upon clicking the view household income button. An error message is displayed under the household member whose identity verification failed

- Deceased/
- Verified

## Viewing UIV Data For a Household

- Simply click on the view household income button from the household summary page to display household income
- Available employment and income information is displayed for each household member
- Detailed error messages as to why a household member’s identity verification failed
- Date household member died is displayed for any household member whose identity verification status is “deceased”

## Viewing UIV Data For a Household - Continued

## Viewing UIV Data For a Household - Continued

- Each income source and other information is contained in a separate section.
- Employment Information
- Wages
- Unemployment Benefits
- Social Security Benefits (SS)
- Dual Entitlement
- Medicare Data
- Supplemental Security Benefits (SSI)
- Black Lung
- Disability

## Printing Household Income Details Report

- Simply click on the Printer-friendly version button and a new window will open up to enable the user to print a report  for the displayed household member
- Simply click on the printer icon to print out the income details report
- Report will include information for all household members

## Disclosure of UIV Data

- PHAs may _**not**_ disclose (or re-disclose) UIV data to _**any**_ third parties (UIV data is property of HUD and protected by Federal Privacy Act)
- PHAs in FL may not maintain HUD-provided UIV data in tenant files
- PHAs may provide UIV data to the individual (only)  to whom the record pertains
- UIV data of minors may be provided to the minor’s parent or guardian

## Accessing the Exceeds Threshold Report

- Click on the Exceeds Threshold Report Link to access report

## Exceeds Threshold Report - Continued

- Select % by which UIV income is greater than PIC reported income

## Exceeds Threshold Report - Continued

- PHA statistics
- # of households evaluated
- # of households exceeding the specified threshold
- # of households exceeding the specified threshold X 2 (Outliers)
- % of Discrepant Households
- Listing of Discrepant households
- Includes HOH last name & SSN exceeding specified threshold
- Includes HOH last name & SSN exceeding the specified threshold X 2

## Exceeds Threshold Report – ContinuedDetailed Household Report

- Includes income reported on 50058 and reported by UIV sources
- Compares 50058 income to UIV income
- Provides monthly and annual discrepancy amount along with %

## Benefits of HUD’s EIV System

- Quick access to web based application to obtain income verifications
- Eliminates the need for requesting written third party verification when tenant does not dispute UIV data _***and***_ additional information is not needed
- Meets regulatory requirement for written third party verification and justifies use of current tenant-provided documents for income calculations
- Identifies tenant income discrepancies

## How to Use UIV Data

## Projecting Annual Income When UIV Data is Available

- HUD guidelines for using UIV data consistently and uniformly
- Substantial difference: one that is $200 or more per month. (Equates to $2,400+ a year)

## Projecting Annual Income When UIV Data is Available - Continued

- When UIV data is _**not**_ substantially different than tenant-reported income:
- If UIV data is _**less**_ than tenant-reported income, use tenant-provided documents to calculate anticipated annual income
- If UIV data is _**greater**_ than tenant-reported income, use UIV data to calculate anticipated annual income, _unless_ tenant can provide the PHA with acceptable documentation to verify a change in circumstances.

## Projecting Annual Income When UIV Data is Available - Continued

- When UIV data is substantially different than tenant-reported income:
- PHA must request written third party verification from the discrepant income source [24 CFR 5.236(3)(I)]

## Use of UIV Data

- UIV data is used to validate tenant-reported income
- UIV data should not be used to calculate anticipated annual income
- When the tenant disputes the UIV data, the PHA must request written third party verification

## Federal Privacy Act 5 U.S.C 552a

- “In order to protect any individual whose records are used in a matching program, no recipient agency, non-Federal agency, or source agency may suspend, terminate, reduce or make a final denial of any financial assistance or payment under a Federal benefit program to such individual, or take other adverse action against such individual, as a result of information produced by such matching program, until the agency has independently verified the information.”

## Income Discrepancy Resolution

- When UIV data indicates a substantial income discrepancy _**and**_ the tenant disputes the UIV information, the PHA must request written third party verification ***[24 CFR 5.236(3)(I)]***
- The PHA should verify effective dates of new and terminated income sources
- The PHA may _**not**_ take any adverse action based ***solely*** on UIV data

## Income Discrepancy Resolution - Continued

- 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

## Income Discrepancy Resolution - Continued

- Income discrepancies are either:
- Valid
- Invalid

## Valid Income Discrepancies 

_**Valid Income Discrepancies:**_ are those discrepancies where:
- the tenant failed to disclose an income source and/or under reported the amount of income that was effective as of the interview date of a mandatory re-examination of income; **and/or**
- the tenant failed to report a change or increase in an income source and/or income amount as required by some PHA’s interim re-examination policies.
_***Note:***_  These discrepancies result in tenant rent 			      underpayments and HUD subsidy overpayments.

## Examples of Valid Income Discrepancies

- Mr. Jones reports he has no income, but fails to report that he is employed at McDonald’s.
- Mr. Jones reports he works at McDonald’s, but fails to report that he is also employed at ABC Box Company.
- Mr. Jones reports he receives welfare benefits, but fails to report that he also receives social security benefits.
- Mr. Jones reports he receives social security benefits, but fails to report that he also receives Supplemental Security Income.
- Mr. Jones received a substantial increase in his earnings from McDonald’s, but failed to report this increase to the PHA (as required by the PHA’s interim increase policy).
- Mr. Jones requests that his employer falsify the content of a PHA-provided wage form, and the employer misstates the tenant’s income. (i.e. the employer reports less earnings, lower wage rate or omits bonuses and over time amounts.)
_***Note:***_  These discrepancies result in tenant rent 			      	    underpayments and HUD subsidy overpayments.

## Invalid Income Discrepancies 

_**Invalid Income Discrepancies:**_ are those discrepancies that are not a result of tenant error.  These discrepancies may occur as a result of:
- PHA error; and/or
- incorrect UIV data

## Examples of Invalid Income Discrepancies

_**PHA Errors:**_
- The PHA recorded the income on Section 7 of the 50058 form incorrectly.
- The PHA recorded the earned income disallowance incorrectly on Section 7 of the 50058 form.  The PHA fails to exclude the income by inserting the earned income on line 7d and then listing the same dollar amount on 7e, which reflects the excluded amount.
- The PHA calculated household income based on the best available third party written verification, third party oral verification, and/or tenant provided documentation at the time of the re-examination interview.  If the PHA had had access to UIV tools, the PHA would have calculated a higher household income.			 _***Note:***_  This type of discrepancy results in tenant rent 			 underpayments and HUD subsidy overpayments. **The ****	****	**** PHA should correct these errors ASAP**

## Examples of Invalid Income Discrepancies - Continued

_**UIV Data Errors:**_
- The reporting agency (income data source) made an error in its records.
- Ex. The income reported under a social security number is incorrectly listed under the tenant’s SSN.
- There has been an incident of identity theft and someone else is using the tenant’s SSN.

## Benefits of Resolving Income Discrepancies

- Reduce HUD subsidy overpayments
- Reduce PHA income and rent errors
- Increase PHA rent revenue (Public Housing)
- Increase available HAP funds (HCV – S8)
- Ensure limited and decreasing Federal funding serve as many eligible families as possible
- Improves income integrity in HUD rental assistance programs

## UIV Case Study

## Case Study: Valid Income Discrepancy (Fraud)

- Mr. Jones previously reported his only income was $50 a month in non-wage income from his sister. This income has been reported for the last 3 years.
- PHA uses the EIV system, which indicates earnings of:
- Q1 2005 - $2,000 ABC Box Co.
- Q4 2004 - $2,000 ABC Box Co.
- Q3 2004 - $2,00 ABC Box Co.
- Q2 2004 - $2,000 ABC Box Co.
- Q1 2004 - $1,500 ABC Box Co.
- Q4 2003 - $1,500 ABC Box Co.
- Note:  tenant does not dispute UIV data

## Case Study: Valid Income Discrepancy (Fraud) - Continued

- Why may this income discrepancy be invalid?
- Why may this income discrepancy be valid?
- What Should the PHA do?
- May the PHA take adverse action based on the UIV data from the EIV system?

## Case Study Answers

- Upon initial view of UIV data, this income discrepancy could be invalid because Mr. Jones’ identity could have been compromised or the the employer may have reported the earnings under an incorrect SSN
- Upon initial review of the UIV data, this income discrepancy could be valid because it appears that Mr. Jones failed to disclose complete and accurate income information at the time of mandatory reexaminations of income.

## Case Study Answers

- 3.	The PHA should contact the tenant to discuss the income discrepancy and provide him/her the opportunity to contest or admit to the income discrepancy.  The PHA should also request needed documentation to resolve the income discrepancy.
- 4.	The PHA may not take any adverse action based solely on the UIV data.  If the tenant disputes the UIV data, the PHA must request written third party verification of the disputed information and request documentation from the tenant.

## Visit HUD’s Web Page For More Information on UIV

**www.hud.gov/offices/pih/programs/ph/rhiip/uiv.cfm**

## For Help with the EIV System

**EIV_Help@ HUD.gov**
**Or Contact the UIV Coordinator at **
**your local HUD Field Office**

## Ask HUD Session

- Panel Members
- Nicole Faison – RHIIP Manager
- Myra Newbill – EIV System Security Administrator
- David Sandler – EIV System IT Project Manager
- Tomas Vagoun – EIV System Analyst