# Presentation: 752679

## Office of Public Housing

**and Voucher Programs**
**NAHRO Detroit Conference**
**Detroit, Michigan**** **

**July 16, 2004**

## Table of Contents

**Welcome and Introduction**
- Section I. 	Rental Housing Integrity Improvement Project (RHIIP)
- Section II.	Income and Rent Problem
- Section III.  	Overview of Upfront Income Verification (UIV)
- Section IV. 	UIV System Roll Out & Implementation
- Section V. 	Using the UIV System
- Section VI. 	Office of Inspector General (OIG) Role
- Section VII.	PHA Perspective on UIV
- Section VIII. 	Other RHIIP Initiatives
- Section IX. 	RHIIP and You

## Section I

- Rental Housing Integrity Improvement Project
*Our Strategy for Improving Income Integrity*

## Rental Housing Integrity Improvement Project (RHIIP)

- Initiated in 2001
- Addresses root causes of errors and improper payments
- Department-wide effort to ensure that the right benefits go to the people who need it most

**Notes:**
**Initiated in 2001, after the release of the 2001 (QC) study. Comprehensive  strategy designed to reduced income and rent errors in public housing and HCV programs. Program Office Participants include: Office of Multifamily Housing Programs, Office of Policy Development and Research (PD&R), and the Office of Chief Financial Officer (CFO). **

## Section II

- Income and Rent Problem

## 2001 Quality Control for Rental Assistance Subsidies Determination Study

- The 2001 (QC) study found that:
- HUD overpaid $2.6 billion
- Underpaid $634 million in annual housing subsidies
- Estimated that 60% of all rent and subsidy calculations contained some type of error

**Source: 2001 Office of Policy Development and Research (PD&R) Quality Control for Rental Assistance Subsidies Determination study**

## Most Common Sources of Errors

- Administrative
- Calculation errors
- Failure to verify income/expenses
- Failure to use UIV techniques
- Component
- Incorrect income and deduction amounts (i.e., earned income, pension income, and medical allowances)

## Improper Payments Information Actof 2002

- Requires agencies to:
- Annually review all programs susceptible to significant erroneous payments
- Measure the number and dollar amounts of errors
- Track progress towards reducing errors
- Report to the President and Congress, if the amount of improper payments exceeds $10 million

## Presidential Management Agenda

- Mandated HUD to reduce:
- The processing (administrative errors) error and improper payment rate by 50%, from 60% to 30% by FY 2005
- HUD set aggressive interim goals in its Annual Performance Plan:
- A 15% reduction by FY 2003
- A 30% reduction by FY 2004

## Section III

- Overview of Upfront Income Verification (UIV)
*The Biggest Bang for the Buck!*

## UIV

- Highest form of income verification
- Verification Guidance, Notice PIH 2004-01 *(see attachment)*
- Verification of income, before or during, a family re-certification through an independent source

**Notes:**
**HUD strongly recommends PHAs make use of the Tenant Assessment Subsystem (TASS), now, to verify tenant-reported income. PHAs may also obtain UIV through the following methods: (1) computer matching agreements with a Federal, State, or local government agency, or a private agency; and (2) submit direct requests for income verifications to a Federal, State, or local government agencies or a private agency. **

## Why Is UIV Important?

**To:**
- Ensure that more eligible families have an opportunity to benefit from HUD’s rental assistance programs
- Increase the accuracy of rent and income determinations
- Reduce incidents of underreported and unreported household income

## UIV – Overall Impact

- Integral to meeting the 50% error reduction goal by FY 2005
- Will reduce incidents of underreported and unreported household income
- Will replace the more time-consuming and less accurate third-party verification process

## UIV – Dollar Impact

- Of the $2.6 billion in overpayment errors, per the 2001 QC study, $1.8 billion (69%) was attributed to unreported and earned income-related errors.

**$860 Other**

**$809 Million Macro Earned Income Related Errors**

**$130 Million Excess Subsidy – Unreported Unearned Income**

**$848 Million Excess Subsidy – Unreported Earnings**

- 5%

- 32.6%

- 31.1%

- 33.1%

## 2001 Study Results

|  | Col. 1 | Col. 2 | Col. 3 | Col. 4 | Col. 5 | Col. 6 | Col. 7 |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
|  | Excess Subsidy – Unreported Earnings | Excess Subsidy – Unreported Unearned | Excess Subsidy – POA Error |  |  |  Total Subsidy Overpayments | Total Subsidy Underpayments | Net Subsidy Error |
|  | IRS/SSA Match (REAC) | IRS Match (REAC) | Macro – SSA/SSI/ Asset/Other Income and Deduction, Exclusion, & Calculation Errors | Macro Earned Income Related Errors | Total Macro, Inc. | Columns 1, 2 and 5 | Macro, Inc. | Columns   6 and 7 |
| Public Housing | $280 | $14 | $195 | $236 | $431 | $725 | ($201) | $524 |
| HCV/Mod Rehab | $369 | $49 | $493 | $383 | $876 | $1,294 | ($256) | $1,038 |
| S8 Project Based | $199 | $67 | $172 | $190 | $362 | $628 | ($177) | $451 |
| TOTAL | $848 | $130 | $860 | $809 | $1,669 | $2,647 | ($634) | $2,013 |

**Dollars in Millions**

## Section IV

- UIV System Roll Out & Implementation
*Making it Happen!*

## UIV System

- Integrated data available through HUD’s secure-system via the Internet
- Provides wage, unemployment compensation,  Supplemental Security Income (SSI) and Social Security (SS) benefit information
-  Provides income discrepancy reports

**Notes:**
**Allows PHAs to view quarterly wage, employer, weekly/bi-weekly unemployment benefit payments, monthly Social Security (SS) and Supplemental Security Income (SSI) benefits, and Medicare deductions and/or buy-ins for tenants in the PHA’s Jurisdictions.  Provides income discrepancy reports to identify families who may have substantially underreported household income. Users must have a valid Form HUD-9886, Authorization for the Release of Information/Privacy Act, signed by all household members who are at least 18 years of age to view income data in the system; alternative consent forms are not acceptable for PHA use.  **

## Benefit of the UIV System

- Replaces the more time consuming income verification process
- Available on-line at staff level
- Provides for integrity in HUD programs
- Under the FVP, can lead to higher income to PHAs

## UIV System

- PHAs must not view the tenant data without a signed Form HUD-9886, Authorization for the Release of Information/Privacy Act Notice in the tenant’s file

**UIV System**

## UIV System Privacy Requirements

- Data must only be used for verification of tenant income and eligibility
- Data must not be disclosed in any way that would violate the privacy of the individuals represented in the system
- Tenants must be provided with access to their records and an opportunity to correct or challenge their contents

## UIV System – Roll out

- System goes live in August 2004, with phased implementation, NY first
- Satellite training was held on 6/28/04, available at: _[http://www.hud.gov./webcasts/archives/ph.cfm](http://www.hud.gov./webcasts/archives/ph.cfm)_

## Executed Computer Matching Agreements with SWICAs

|   District of Columbia
  Florida
  Iowa
  Illinois
  Indiana
  Kansas
  Kentucky
  Louisiana
  Massachusetts 
  Michigan
  Minnesota
  Missouri
 North Carolina |   North Dakota
  Nebraska
  New Mexico
  New York
  Ohio
  Pennsylvania
  Rhode Island
  South Carolina
  South Dakota
  Texas
  Vermont
  West Virginia |
| --- | --- |
|  |  |

## States In Production

**Florida**
**Iowa**
**Illinois**
**Indiana**
**Kansas**
**Louisiana**
**Michigan**
**Minnesota**
**Missouri**
**North Carolina**

**North Dakota**
**Nebraska**
**New Mexico**
**New York**
**Ohio**
**Pennsylvania**
**Rhode Island**
**South Carolina**
**Texas**
**Vermont**

## UIV System – Getting Ready

- PHAs should be:
- Determining who will need access to the system
- Reviewing and revising policies as a result of implementing UIV into PHA’s operations
- Concluding how the PHA will include UIV as a part of the reexamination process
- Reviewing policies impacted by the prospect of underreported and unreported income
**Note: **
**Questions regarding UIV should be directed to: **_[UIV_help@hud.](mailto:UIV_help@hud.gov)__[gov](mailto:UIV_help@hud.gov)_

## UIV Security – Management

- Review internal security procedures
- Ensure PHA’s ability to safeguard UIV data
- Conduct periodic reviews of all User IDs to determine if the user still needs access
- File and maintain UIV data in a secure area
- Conduct security awareness training for authorized UIV system users

## Section V

- Using the UIV System
*The KEY to reducing income and rent errors*

## UIV System Web Site:http://www.hud.gov./offices/pih/programs/ph/rhiip/uivsystem.cfm

## Accessing the UIV System

- From your PC, open a web browser, for example, Internet Explorer 4.0+ or Netscape 4.0

-   Type the Uniform Resource Locator (URL)
- 		or web address of the UIV Logon screen

## UIV System – Preview

## Welcome 

**Page**

## You’re In! 

- Along the left-hand side of the Welcome Page, see navigation commands:
- _Log Off_
**Search Income Records**
_**By Head of Household Information**_
- Exceeds Threshold Reports
- User Manual

## Search for Head of Household Information

## Household Summary and Income Records Status

## Household

**Household**
**Income **
**Details**

## Discrepancy Reports

- Includes:
- Total wages, unemployment compensation, and SS benefits reported to HUD by the tenant
- Total wages, unemployment compensation, and SS benefits reported to HUD by the SSA/SWICA

## UIV Case Study #1 – Valid Wage Discrepancy

- PHA staff interviewed Mr. and Ms. Jones on 6/12/03
- The projected anticipated annual income was taken from HUD Form-50058 (effective date 9/01/03)
- The actual annual income from UIV is for the period of 1/01/03 through 12/31/03
- HA receives a UIV Wage Discrepancy Report on 5/7/04

## Potential Income Discrepancy 

| Household Member Name | Date of Birth | Relationship | Reported Income Source | Projected Anticipated Annual Income | Actual Annual Income Confirmed Using UIV (or Third Party Verification) | Potential Income Discrepancy |
| --- | --- | --- | --- | --- | --- | --- |
| Jones, Mary | 05/14/1951 | Head | Income In-kind | $1,200 | $1,200 | $0.00 |
| Jones, Harold | 12/08/1971 | Adult | None | $0.00 | $48,800 | ($48,800) |
| Totals |  |  |  | $1,200 | $50,000 | ($48,800) |

## Potential Income Discrepancy cont.

- Potential income discrepancy for the Jones family:
- $48,800
- Tenant Reported Income = $0
- UIV Reported Income = $48,800

## What Should You Do? 

**Action 1:**** **
- Obtain UIV Household Income Details Report from the UIV system or interim manual UIV Wage Report.
**Action 2:**
- Compare UIV data to tenant-reported income to determine if the tenant failed to report income at the time of the re-exam interview.

## Things to Consider...

- Does the UIV data indicate earnings during Quarter 4 of 2002, or Quarter 1 or 2 of 2003?
- Did the discrepant household member sign a declaration of no income?
- Did the household member fail to provide documentation of earnings?
- Is the household entitled to an EID and is it correctly reflected on the 50058?

## What’s Next?

**Action 3:**** **
- Contact the tenant to discuss the discrepancy.
- Request current income documents from the tenant.
- If the tenant disputes the UIV data, request written third-party verification of UIV data.

## What’s Next? cont.

**Action 4: **
- Upon validation or confirmation of discrepancy, calculate the correct total tenant payment (TTP) and retroactive rent payment due to the agency.
- Inform the tenant of retroactive rent due and execute a repayment agreement with the tenant.
**Action 5: **
- Determine the type of adverse action that will be taken as a result of lease violation.

## Adverse Action(s) as Appropriate

- Execute repayment agreement
- Lease termination
- Referral to the OIG
- Other

## UIV Case Study #2 – Invalid Wage Discrepancy

- HA receives a UIV Wage Discrepancy Report for its PH program on 5/14/04
- Projected anticipated annual income was taken from Form HUD Form-50058 (effective date 11/01/03
- The actual annual income from UIV is for the period of 1/01/03 through 12/31/03

## Potential Income Discrepancy

| Household Member Name | Date of Birth | Relationship | Reported Income Source | Projected Anticipated Annual Income | Actual Annual Income Confirmed Using UIV (or Third Party Verification) | Potential Income Discrepancy |
| --- | --- | --- | --- | --- | --- | --- |
| Smith, Ray | 12/01/1972 | Head | Wages | $26,000 | $40,000 | $14,000 |
| Smith, Amy | 01/25/1998 | Youth |  |  |  |  |
| Smith, Rob | 04/11/2000 | Youth |  |  |  |  |
| Smith, Dee | 08/12/2002 | Youth |  |  |  |  |
| Totals |  |  |  | $26,000 | $40,000 | ($14,000) |

## Things to Consider...

- PHA completed Mr. Smith’s annual re-exam on 07/05/03
- PHA does not require tenants to report increases in income between annual re-rexams
- Based on tenant-reported pay stubs and independent third-party verification, the PHA projected the Smith’s annual household income at $26,000
- At the time of the re-exam interview, the following UIV data was available

## Available UIV Wage Data

- Quarter 1 - 2003: $6,200
- Quarter 4 - 2002: $6,800
- Quarter 3 - 2002: $6,500
- Quarter 2 - 2002: $6,500

## Additional UIV Wage Data Attached to UIV Wage Discrepancy Report

- Quarter 2 - 2003: $6,600
- Quarter 3 - 2003: $9,100
- Quarter 4 - 2003: $18,100

## What Should You Do? 

**Action 1: **
- Obtain UIV Household Income Data Report from the UIV system or interim manual UIV Wage Report.
**Action 2:**
- Compare UIV data to tenant-reported income, based on documents submitted to complete the re-exam.

## What Should You Do? cont.

**Action 3:**** **
- Determine if the tenant failed to report income at the time of the re-exam interview.
**Action 4: **
- In cases where the PHA is uncertain of whether or not the increase in income occurred prior to the re-exam interview date, the PHA may obtain independent third-party verification of the UIV reported wages by an employment verification request form to the employer listed in the UIV system.

## Results – No Adverse Action(s) Necessary

- Based on the review of independent third-party verification documentation, it appears that Mr. Smith experienced an increase in wages _**after**_ the annual re-exam interview date.
- No adverse action(s) required.

## Exceeds Threshold Report

- Critical tool for pursuing undisclosed income
- Compares income sources reported in UIV with the Form HUD-50058
- Produces an “Exceeds Threshold Report” for PHA inquiry
- PHAs will determine their own “Exceeds Threshold Report” percentage

## Exceeds Threshold Report

**Exceeds Threshold Report**

- Set Threshold of discrepancy % between Household 50058 income vs. UIV Income from wage & SSA match

## PHA Exceeds Threshold Report

## Exceeds Threshold Report

**Detailed Household **
**Report**

## Projecting Annual Income When UIV Data is Available

- HUD has established the criteria for consistently and uniformly resolving both _substantial_ and _non-substantial_ income differences between tenant-provided and UIV data
_***Substantial difference***_***:****** ***one that is $200 or more per month
_***Non-substantial difference***_: one that is less than $200 per month

## Projecting Annual Income When UIV Data is Available cont.

- When UIV data is _not substantially_ different than tenant-reported income:
- If UIV data _<_ tenant-reported income, use tenant-provided documents to calculate anticipated annual income
- If UIV data _>_ 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 cont.

- 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)]
- PHA should review all historical and current income data. The PHA may consider historical patterns of income in the calculation of annual income along with the most current verified income.

## For Help with UIV

- _[UIV_Help@HUD.gov](mailto:UIV_Help@HUD.gov)_
- Or Contact the RHIIP Coordinator at your
- HUD Local Field Office

## Section VI

- Office of Inspector General (OIG) Role
*Maintaining integrity in HUD programs*

## OIG Role

- Detect, prevent, and investigate allegations of PHA and tenant fraud in HUD programs
- Seek administrative sanctions, civil recoveries, and/or prosecution of those responsible for fraud
- Keep the Secretary, Congress, and the American people fully informed

**Note:**
**See PIH’s RHIIP website for information on reporting fraud, waste, and abuse in HUD programs:**
- _[http://www.hud.gov./offices/pih/programs/ph/rhiip/uivreporting.cfm](http://www.hud.gov./offices/pih/programs/ph/rhiip/uivreporting.cfm)_

## Reporting Fraud

**	****	****	**
**	**** ****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:________
**	****  **
**	****U.S. Department of Housing and Urban Development****	****WASHINGTON, D.C. 20410-4500****	****	****	**
**                               **
**                                                **

**Reporting Fraud**
**Hotline: 800-347-3735**
**Fax: 202-708-4829**
***Note:****** *****Incidents of fraud may be followed-up by HUD Field Offices and the Inspector General**

## Reporting Fraud

**Reporting Fraud**

## Yonkers housing fraud bust nets charges against 31 

**Yonkers housing fraud bust nets charges against 31**
**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.

## “PHA Hits Possible 

**PHA hits possible fraud cases**
- _[By ](mailto:araceli.arreola@theparisnews.com)__[Araceli Arreola](mailto:araceli.arreola@theparisnews.com)_The Paris News
- Published February 16, 2004
- Paris Housing Authority is the first in the state to use a new trial system designed to catch and prosecute public housing residents who lie about their income. Four residents, Teresa Parkington, Crystle Mooneyham, Ethel Davis and Hobbie Davis, were indicted Thursday before a grand jury on securing execution of documents by deception, County Attorney Mark Burtner said. Together, these four residents allegedly owe $35,000 in rent due to misrepresentation, he said.Texas is one of nine states to use Up Front Income Verification System (UIV), developed by the Department of Housing and Urban Development. Other housing authorities plan to implement it by March 2004.UIV, a secure Internet-based system, provides housing authorities with information from the state’s wage income agency and Social Security Administration. That information is then matched with income certifications, provided by public housing residents. The certifications, filled out yearly, are used to determine a resident’s rent. Residents must report all income and employment. After yearly certifications, residents have 10 days to report any changes to earnings or new employment. “Any unreported income ... we are now privy to that information,” Denny Head, executive director of Paris Housing Authority, said. “We’ve needed this for a long, long time.”

**“****PHA Hits Possible **
**Fraud Cases”**

**Notes:**
***The Paris News***** article website address:**
- _[http://web.theparisnews.com/story.lasso?wcd=11487](http://web.theparisnews.com/story.lasso?wcd=11487)_

## Section VII

- A PHA Perspective
*Tampa Housing Authority (THA) & Fort Worth Housing Authority (FWHA)*

## THA Guidelines for Third-Party Verification

- Direct verification methods
- Upfront income verification
- How to use UIV
- How to use The Work Number
- Online child support payments
- Use of third-party verification to supplement UIV

## THA Guidelines for Third-Party Verification cont.

- Third-party written verification
- Third-party oral verification
- Review of documents
- Self-certification/self-declaration

## THA Guidelines for Income Discrepancies with UIV System

- When UIV income data is not substantially different than tenant-provided income information
- When income data is substantially different than tenant-provided income information

## Using UIV System Data

- How to determine allowable medical expenses:
- When the tenant pays the monthly Medicare premium that is deducted from monthly social security benefit payment
- When there is a Medicare Buy-in

## Scenario #1 - Tenant-Paid Medicare Premium

**Difference is $66.60**
- is

**Tenant pays Medicare premium.**

## Scenario #1 – Tenant-Paid Medicare Premium cont.

- In this case, the tenant pays the Medicare premium of $66.60, which is deducted from the tenant’s gross benefit amount, resulting in a net social security payment of $587 ($653.60 - $66.60).
- Since “N” is indicated under “Buy-in,” the tenant pays his/her own Medicare premium.  The household is entitled to a medical expense deduction, subject to 3% of annual income.

## Scenario #2 –  Medicare Buy-in

**Gross & Net benefit is the same. Tenant does not pay Medicare premium.**

**Medicare premium is paid by a third party on behalf of the tenant.**

## Scenario #2 –  Medicare Buy-in cont.

- In this case, a third party pays the Medicare premium of $66.60 on behalf of the tenant.  This is indicated by a “Y” under “Buy-in.” Thus the tenant’s gross and net payment is the same ($338).
- The $66.60 monthly payment on behalf of the tenant is counted as income, however, 100% of this income is excluded under 24 CFR 5.609(c)(4), since this income is specifically for the cost of medical expenses.  The household is _not _entitled to a medical expense deduction.**  **

## THA Guidelines for Verifying Assets

- Family Assets
- Assets disposed of for less than Fair Market Value (FMV)
- Savings or checking account interest and dividend income
- Interest income from mortgages and similar arrangements
- Net rental income from property owned by the family

## Implementing UIV at FWHA

- In September 2003, FWHA began participating in the HUD Upfront Income Verification (UIV)computer verification program

## Internal Procedures for Staff Use

- Pull UIV reports approximately sixty (60) days prior to annual recertification date
- Pull reports for all persons with zero income
- Compare report with file information
- Calculate any retro rent amount owed
- Notify tenant of rent change and/or any retro owed

## Internal Procedures for Staff Use cont.

- Enter into repayment agreement and update client data, or terminate housing assistance
- Prepare data for OIG on all retro rent owed
- Recommended threshold $2,500
- Each agency should set the thresholds for OIG referrals in ACOP and Administrative Plans

## Tenant Notification

- Send mass notices to all tenants
- Send special notice along with recertification letters

## Staff Training

- 08-19-03 and 06-28-04
- Staff attends all UIV training offered by HUD, NAHRO or other training providers
- 04-19-04
- 05-11-04
- 06-03-04

**Staff Training**

## Advantages of the System

- System provides past income information
- Unreported and underreported income is discovered
- Staff can determine if a tenant has committed fraud
- Incentive for tenant to be forthcoming about all household income
- PHA has access to OIG for legal action

## Retro Cases Confirmed(As of 06-30-04)

- 			                       PH            SEC 8

| Total No. of Retro Accounts Confirmed to Date | 36 | 27 |
| --- | --- | --- |
| Total Retro Amount Owed | $83,379 | $61,773 |
| Repayment Defaults | 3 | 2 |
| Eviction/Assistance Termination for Failure to Enter into Repayment Agreement | 1 | 2 |

- FWHA is processing 5 Public Housing cases and 11 Housing Choice Voucher cases for amounts of $42,542 and $43,656, respectively.

## FWHA Guidance

- Statistical data must be maintained to assure that the PHA collects monies owed to the agency (50% HUD – 50% PHA)
- PHA must maintain contact and follow-up with OIG representative for case disposition.

## Preparing Your Agency

- Technical (computers, Internet connections, etc.)
- Implementation policies (grace periods)
- Training staff
- Communicating your new policy with residents (newsletters, formal letters)

## Results 

- Logistics and overall impressions
- Statistics
- Repayment agreements
- Prosecuting fraud
- Impact on fraud
- Administrative implications

## Moving Forward: Overcoming the Barriers of the UIV System

- Time delay in UIV wage, unemployment compensation, and benefit data
- Logistics

## Section VIII

- Other RHIIP Initiatives
*A comprehensive approach*

## RHIIP Components

- Rental Integrity Monitoring (RIM)
- Sanctions
- Program Simplification
- Program Guidance
- Training and Technical Assistance
- Error Measurement

**Note:**
**Information on Program Guidance, Training and Technical Assistance, and Error Measurement available at:**
- _[http://www.hud.gov./offices/pih/programs/ph/rhiip/index.cfm](http://www.hud.gov./offices/pih/programs/ph/rhiip/index.cfm)_

## Rental Integrity Monitoring (RIM)

- Onsite monitoring of PHA policies and procedures related to income and rent determinations by the Field Office
- Seeks to improve PHA internal quality control systems and procedures for gathering data

## RIM Reviews – Purpose

- Opportunity to:
- Detect and address root causes in income and rent calculations
- Examine quality control procedures that impact the accuracy of rent determinations
- Provide technical assistance, as needed
- Minimize HUD’s limited housing resources

## RIM Re-reviews – Purpose

- To determine if:
- CAP has been implemented
- Corrective action has led to reduced errors
- Errors discovered during initial review have been corrected

**Notes:**
**The purpose of the onsite RIM  re-review is to confirm whether  the PHA has implemented corrective actions as outlined in its approved corrective action plan (CAP); verify that the implementation of corrective action has led to a reduction of errors; determine whether errors identified during the initial RIM  review have been corrected. The RIM initiative represents an approach that focuses directly on a PHAs income and rent calculations and those activities (e.g., quality control procedures) that directly impact the accuracy of income and rent calculations. **

## RIM Re-reviews – FY 2004

- As of April 30, 2004, Headquarters has:
- Completed 467 RIM reviews of large PHAs, comprising of 826 total separate programs (362 for public housing and 464 for the HCV program)
- Conducted 223 additional reviews at smaller PHAs identified as high risk

**Notes:**
**The Field Office will review sample of new and old tenant files. Files will be selected at random.**

## RIM Re-reviews – FY 2004 cont.

- RIM re-reviews (follow-up review) of 112 PHAs, comprising 175 separate programs (public housing and HCV) were conducted by FOs
- Of the 720 re-reviews scheduled for FY 2004, only 220 re-reviews remain (as of 6/04)
- All field work, to the extent possible, will be completed by 9/04

**Notes:**
**The Field Office will review sample of new and old tenant files. File selection will be selected using random selection methodology.**

## Sanctions

- Notice PIH 2003-34, *Rental Integrity Monitoring (RIM) Disallowed Costs and Sanctions under RHIIP*
- Issued December 19, 2003
- Applies to Public Housing and Section 8 HCV Programs
- Establishes consequences for failure to identify and correct deficiencies
- A concerted approach to ensuring proper subsidy determinations in HUD’s rental programs

## Program Simplification

- Rent Simplification Goals:
- Minimize the administrative burden and costs on PHAs
- Less intrusion in the lives of applicants and tenants
- Promote resident self-sufficiency
- Address errors and improper payments as mandated by GAO and IG

## Program Simplification – Rent Options

- Income-Based
- Tiered Flat
- Block grant

##  Section IX

- RHIIP and You

## PHAs – Your Role

- Ensure that your PIC reporting rates are high (100%)
- Notify stakeholders such as tenants, resident advisory boards, tenant councils, and others of your implementation of UIV
- Investigate tenant income discrepancies

## Headquarters – What we’re doing...

- Providing guidance on UIV and tools such as the UIV and TASS systems to obtain tenant income and benefits data
- Ensuring full UIV implementation through RIM reviews discrepancy reports
- Determining the overall and dollar impact of UIV on error reduction goals

## UIV Tools and Resources

- Tenant Assessment Subsystem (TASS)
- Notice PIH 2004-01, Verification Guidance
- UIV Operations Manual
- UIV System User Manual
- UIV Training Webcast
- UIV Web Site: _[http://www.hud.gov./offices/pih/programs/ph/rhiip/uivtools.](http://www.hud.gov./offices/pih/programs/ph/rhiip/uivtools.cfm)__[cfm](http://www.hud.gov./offices/pih/programs/ph/rhiip/uivtools.cfm)_

## Other Tools and Resources 

- Notice PIH 2003-34, Disallowed Costs/Sanctions
- Public Housing Occupancy and HCV Program Guidebooks
- Fact Sheet on Income/Rent Determinations
- RHIIP Web Site: _[http://www.](http://www.hud.gov./offices/pih/programs/ph/rhiip/index.cfm)__[hud](http://www.hud.gov./offices/pih/programs/ph/rhiip/index.cfm)__[.](http://www.hud.gov./offices/pih/programs/ph/rhiip/index.cfm)__[gov](http://www.hud.gov./offices/pih/programs/ph/rhiip/index.cfm)__[./offices/](http://www.hud.gov./offices/pih/programs/ph/rhiip/index.cfm)__[pih](http://www.hud.gov./offices/pih/programs/ph/rhiip/index.cfm)__[/programs/ph/](http://www.hud.gov./offices/pih/programs/ph/rhiip/index.cfm)__[rhiip](http://www.hud.gov./offices/pih/programs/ph/rhiip/index.cfm)__[/index.](http://www.hud.gov./offices/pih/programs/ph/rhiip/index.cfm)__[cfm](http://www.hud.gov./offices/pih/programs/ph/rhiip/index.cfm)_

## Conclusion

- HUD and PHAs must work together to meet the presidential mandate and ensure fundamental fairness among families.

**Cooperation**

**Commitment**

**Initiative**

**The right benefits for the right persons**

## Questions and Answers