Slide #1
© Copyright 2008 Nan McKay & Associates
Enterprise Income Verification
Annie Stevenson
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© Copyright 2008 Nan McKay & Associates
Welcome to Lunch N Learn!
 Upcoming topics for the occupancy series:
• 9/4/08: Public Housing Denials and
Terminations
• 9/5/08: HCV Reasonable Accommodation
Slide #3
© Copyright 2008 Nan McKay & Associates
Welcome to Lunch N Learn!
 Today’s topics:
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EIV data availability
Tenant income data processing
Income discrepancy report
EIV reports
Slide #4
© Copyright 2008 Nan McKay & Associates
Enterprise Income
Verification (EIV) System
Slide #5
© Copyright 2008 Nan McKay & Associates
HUD’S Rental Housing Integrity
Improvement Project (RHIIP)
 Priority Secretarial initiative designed to reduce
income and rent errors and improper subsidy
payments
 Comprehensive strategy to correct program
errors in HUD’s high-risk rental housing subsidy
programs
 HUD’s objective: ensure the correct amount of
assistance is provided to the families who need it
Slide #6
© Copyright 2008 Nan McKay & Associates
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
Slide #7
© Copyright 2008 Nan McKay & Associates
Statistics from 2001 Quality Control for
Rental Assistance Subsidies Study
 Approximately 70% of subsidy payment errors
are attributable to tenant under-reporting
and/or non-disclosure of income
• Intentional or unintentional
Slide #8
© Copyright 2008 Nan McKay & Associates
2001 Quality Control Report
 Families statistically most likely to conceal
income
• Families with 2 or more sources of earned
income
• Families with TANF and at least 1 source of
earned income
Slide #9
© Copyright 2008 Nan McKay & Associates
2001 Quality Control Report
 Most error-prone components of rent
calculation (PHA and tenant error)
• Earned income
• Social Security benefits
• Allowances and deductions
Slide #10
© Copyright 2008 Nan McKay & Associates
HUD’s Strategy to Reduce Tenant
Under-Reporting & Non-Disclosure of
Income
 Development and implementation of the
Enterprise Income Verification (EIV) System
 Encourage PHAs to implement UIV tools
 PHA resolution of substantial income
discrepancies disclosed through HUD UIV
systems
Slide #11
© Copyright 2008 Nan McKay & Associates
Upfront Income Verification
(UIV)
 What is it?
• The verification of income, before or
during a reexamination, through an
independent source that systematically
and uniformly maintains income
information in computerized form for a
large number of individuals
Slide #12
© Copyright 2008 Nan McKay & Associates
Upfront Income Verification
(UIV)
 UIV is an extremely effective tool for error
reduction
 Before UIV, PHAs obtained third-party
verification from income sources reported by
applicants and participants
Slide #13
© Copyright 2008 Nan McKay & Associates
Upfront Income Verification
(UIV)
 UIV enables PHAs to check a variety of
income sources for all family members
• Regardless of income sources reported by
applicants and participants
Slide #14
© Copyright 2008 Nan McKay & Associates
Use of UIV for Verification
 UIV is third-party verification
• Most preferred form
• Meets regulatory requirements
 UIV is intended to streamline the verification
process
• Eliminates the need for written third-party
verification in many cases
Slide #15
© Copyright 2008 Nan McKay & Associates
NEW! HUD Guidance on EIV
 HUD webcast 1/16/08 contained revised
guidance on use of EIV
• Previous guidance is obsolete and has been
removed from EIV website
$2400 discrepancy
Slide #16
© Copyright 2008 Nan McKay & Associates
NEW! HUD Guidance on EIV
 Webcast available at
http://www.hud.gov/webcasts/archives/ph.
cfm
 Training materials from webcast
• Powerpoints, case study & solution
• http://www.hud.gov/offices/pih/programs/ph/rhii
p/training.cfm
Slide #17
© Copyright 2008 Nan McKay & Associates
HUD Guidance on EIV
 EIV is sufficient as third-party verification
when:
• The family does not dispute the data, and
• Current tenant-provided documents (i.e.
paystubs) are available
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© Copyright 2008 Nan McKay & Associates
HUD Guidance on EIV
 The PHA MUST obtain additional thirdparty verification when the family
disputes EIV employer data
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© Copyright 2008 Nan McKay & Associates
HUD Guidance on EIV
 The PHA MAY obtain additional third-party
verification when the PHA determines that
additional information is necessary, such as:
• Effective dates of employment
• Pay rate, hours worked for new jobs
• Confirmation of a change in circumstances
(reduced hours, reduced rate of pay)
Slide #20
© Copyright 2008 Nan McKay & Associates
HUD Guidance on EIV
 Use tenant-provided documents to
project annual income, unless:
• The family disputes EIV employer data,
OR
• The PHA determines that additional
information is necessary
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© Copyright 2008 Nan McKay & Associates
HUD Guidance on EIV
 HUD recommends that tenant-provided
documents should be dated within 60
days of interview date
• Current and consecutive
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© Copyright 2008 Nan McKay & Associates
HUD Guidance on EIV
 Quote from webcast:
• “The PHA will use tenant-provided
documents or most current information
to calculate anticipated annual
income.”
 EIV quarterly wages are NOT used to
project annual income
Slide #23
© Copyright 2008 Nan McKay & Associates
HUD Guidance on EIV:
File Documentation
 If the family does not dispute EIV employer
data, and the PHA determines that
additional information is not necessary:
• EIV income details report
ICN in FL
• Tenant-provided documents
Slide #24
© Copyright 2008 Nan McKay & Associates
HUD Guidance on EIV:
File Documentation
 If the family disputes, or PHA requires
additional information:
• EIV printout (except in FL)
• Tenant-provided documents
• Third-party written verification
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© Copyright 2008 Nan McKay & Associates
EIV System Interactions
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© Copyright 2008 Nan McKay & Associates
Data Displayed by EIV
 Employment information (new hires)
 Quarterly wages
 Unemployment insurance
 Social Security benefits (SS)
• Dual entitlement
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© Copyright 2008 Nan McKay & Associates
Data Displayed by EIV
 Medicare data
 Supplemental Security (SSI) benefits
 Black Lung entitlement
 Disability information
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© Copyright 2008 Nan McKay & Associates
Data Displayed by EIV
 National Directory of New Hires (NDNH) data
replaced state SWICA data in October, 2005
• EIV now contains NATIONAL wage and
unemployment data
Slide #29
© Copyright 2008 Nan McKay & Associates
Authorization for Release of
Information/ Privacy Act Statement
(Form HUD-9886)
 Form 9886 is HUD’s authorization to perform
income-matching activities
 Form 9886 must be signed by:
• All adult family members (18 years of age)
• Head & spouse, regardless of age
Slide #30
© Copyright 2008 Nan McKay & Associates
EIV Modules
 Tenant Income Data
 Income Discrepancy Report
• Formerly Exceeds Threshold Report
 Different data for different purposes
Slide #31
© Copyright 2008 Nan McKay & Associates
EIV: Tenant Income Data
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© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
 Displays the most current data available
• 1 to 2 quarters old
 Review for all families at annual reexam
• Can also be used for interim reexams
 Meets regulatory requirement for third-party
verification
• Per HUD guidelines
Slide #33
© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
 Not available at admission
• Because family is not yet in PIC
• Data will be available within 90 days of
admission
 Data is updated quarterly
Slide #34
© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
 Navigate to Household Summary Report
screen
• Search by name, SSN or birth date
 Note 3 tabs at top of screen
• Summary Report
• Income Report
• Income Discrepancy Report (later)
Slide #35
© Copyright 2008 Nan McKay & Associates
Household Summary
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© Copyright 2008 Nan McKay & Associates
Identity Verification Status
 Displayed for each household member
• 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
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© Copyright 2008 Nan McKay & Associates
Identity Verification Status
• Failed: tenant SSN, last name and date
of birth combination verification failed by
SSA
• Deceased: according to SSA records, the
tenant with SSN, last name and date of
birth combination is deceased
Slide #38
© Copyright 2008 Nan McKay & Associates
Identity Verification
Slide #39
© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
 Click “Income Report” tab at top of screen
 Income data is displayed for all family
members
• Earned/Unemployment: Family members 18 &
over
• SSA/SSI: All family members
• No data displayed for live-in aide
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© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
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© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
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© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
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© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
• Verifies Medicare Part B buy-in amount for
medical expenses deduction
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© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
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© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
 Print the results
• “Printer Friendly Version” button
• Opens a pop-up window
 The printout is retained in the family’s file
(except in FL) as per the PHA’s record
retention policy
Slide #46
© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
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© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
Slide #48
© Copyright 2008 Nan McKay & Associates
Timing of Quarterly & Monthly
Income & Employment Data
 There are time frames associated with the
reporting of quarterly income and employment
data
 Employers and state unemployment offices
are required to report calendar quarter data
within specific timeframes
Slide #49
© Copyright 2008 Nan McKay & Associates
Income & Employment Data
Reporting Timeframes
 New Hire Employment Information
• Employers are required to transmit by 2
monthly transmissions
 Quarterly Wage (Non-Federal)
• States are required to transmit within 4
months after the end of the reporting period
Slide #50
© Copyright 2008 Nan McKay & Associates
Income & Employment Data
Reporting Timeframes
Quarterly Wage (Federal)
• Federal agencies are required to transmit
no later than 1 month after the end of the
reporting period
 Quarterly Unemployment Compensation
• States are required to transmit within 1
month after the end of the reporting period
Slide #51
© Copyright 2008 Nan McKay & Associates
EIV and Portability
 HUD recommends that initial PHA should print
EIV info and send to receiving PHA with
portability paperwork
 Receiving PHA will not have access until
receiving agency has control of record in PIC
Slide #52
© Copyright 2008 Nan McKay & Associates
Tenant Income Data:
Annual Reexam Processing
Slide #53
© Copyright 2008 Nan McKay & Associates
Data Processing Steps
 Use of EIV data may require changes in PHA
procedures for processing annual reexams
• Different for each PHA
 We’ll look at some basic processing steps
• “I have the printout – now what??”
Slide #54
© Copyright 2008 Nan McKay & Associates
Data Processing Steps
 Reexam packet mailed to families
• Add EIV informing notice
• Request paystubs per PHA policy
Last 60 days would be reasonable
Should be consistent among staff
• Request HUD-9886 for family members
turning 18
Slide #55
© Copyright 2008 Nan McKay & Associates
Data Processing Steps
 Reexam packets returned to PHA
 Print & distribute EIV data
 Compare EIV and tenant-supplied documents
(paystubs)
• Unreported employment?
• Other discrepancies?
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© Copyright 2008 Nan McKay & Associates
Evaluating EIV Data
 Annualize pay stubs
• Average weekly x 52 or
• Average bi-weekly x 26 or
• Average semi-monthly x 24, etc.
 May also consider year-to-date
 Need consistent method
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© Copyright 2008 Nan McKay & Associates
Evaluating EIV Data
 If family disputes EIV employment data:
• PHA must request third-party written
verification
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© Copyright 2008 Nan McKay & Associates
Evaluating EIV Data
 If the PHA determines that additional
information is necessary:
• PHA must request third-party written
verification
Effective dates of employment
Pay rate, hours worked for new jobs
Confirmation of a change in circumstances
(reduced hours, reduced rate of pay)
Slide #59
© Copyright 2008 Nan McKay & Associates
Evaluating EIV Data
 If family does not dispute EIV data and no
additional information is necessary:
• Calculate annual income using paystubs
Slide #60
© Copyright 2008 Nan McKay & Associates
Evaluating EIV Data
 If additional verification (such as employer
statement) is obtained:
• The PHA will use current tenant-provided
documents or most current information to
calculate anticipated annual income
Slide #61
© Copyright 2008 Nan McKay & Associates
Evaluating EIV Data
 File documentation
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•
•
•
EIV printout (except FL)
Tenant-provided documents (paystubs)
Written third-party if required
Remember to leave a clear audit trail
 Calculator tape, calculation worksheet, etc.
Slide #62
© Copyright 2008 Nan McKay & Associates
EIV:
Income Discrepancy Report
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© Copyright 2008 Nan McKay & Associates
Income Discrepancy Report
 Data is not current
 Used to identify families who may have failed
to report or under-reported income in the past
 Excludes families with discrepancies
< $2400 per year
• No substantial difference
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© Copyright 2008 Nan McKay & Associates
Income Discrepancy Report
 The report identifies families with a
discrepancy between:
• A 50058 in PIC, and
• EIV income for a prior period
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© Copyright 2008 Nan McKay & Associates
Income Discrepancy Report
 Our job is to analyze the discrepancy,
and to determine whether the family met
reporting responsibilities
 If family did NOT meet reporting
responsibilities, was subsidy overpaid?
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© Copyright 2008 Nan McKay & Associates
Income Discrepancy Report
 Some families on the report may have
concealed income
 Others are listed because they lost a
source of income, such as a job
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© Copyright 2008 Nan McKay & Associates
Key Concepts
 The 50058 under consideration may not
be the most recent 50058 in the case file
 No adverse action may be taken based
solely on the ETR
• Third-party confirmation required
Slide #68
© Copyright 2008 Nan McKay & Associates
Key Concepts
 Report compares EIV data with 50058 data
for only these income types:
• Earned: F, HA, M, W
• Social Security or SSI: S, SS
• Unemployment benefits: U
 Report shows PIC income as $0 when none
of these codes are present
Slide #69
© Copyright 2008 Nan McKay & Associates
Key Concepts
 It may be necessary to determine start
date and/or end date of employment in
order to determine whether reporting
responsibilities were met, and whether
subsidy was overpaid
Slide #70
© Copyright 2008 Nan McKay & Associates
Income Discrepancy Resolution
 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
Slide #71
© Copyright 2008 Nan McKay & Associates
Limitations of the Report
 Early results indicate that about 1/3 of the
households shown may have concealed or
under-reported income
• Very preliminary and based on only a few
PHAs
• Still good information for identifying program
abuse
Slide #72
© Copyright 2008 Nan McKay & Associates
Limitations of the Report
 A household is eliminated from the report:
• after a new 50058 submission (annual or
interim reexamination) resulting in an annual
income discrepancy less than $2400
• and after 3 months lapse to allow for EIV
reporting
Slide #73
© Copyright 2008 Nan McKay & Associates
Limitations of the Report
 This means that the PHA will need to identify
“false positive” results and track these
households until eliminated from the report
• Could be a year or more
• Prevent duplication of effort
Slide #74
© Copyright 2008 Nan McKay & Associates
EIV Policy Issues
 Some PHAs have established an “amnesty”
period to encourage full reporting
• Participants given limited period to come
forward if they have concealed income
 Will not be terminated from program
 Must repay overpaid subsidy
Slide #75
© Copyright 2008 Nan McKay & Associates
EIV Policy Issues
 Review admin plan policies for families who
commit program abuse
• For example, family didn’t report full-time student
daughter was working (how much income would
you have counted for her?)
 $480
 Was a sworn statement in the file? Was it false?
Slide #76
© Copyright 2008 Nan McKay & Associates
EIV Policy Issues
 What are the guidelines for deciding between:
• Demand for immediate repayment
• Repayment agreement
• Termination of assistance
• Legal action
 What if you have many families in this situation?
Are you going to terminate all?
Slide #77
© Copyright 2008 Nan McKay & Associates
More EIV Information
 HUD’s EIV page:
• http://www.hud.gov/offices/pih/programs/ph/rhiip/uiv
system.cfm
EIV User Manual (revised December 2007)
Privacy and Security Requirements
Security Procedures Guide
Fraud prosecutions as a result of UIV/EIV
Slide #78
© Copyright 2008 Nan McKay & Associates
EIV Reports
Slide #79
© Copyright 2008 Nan McKay & Associates
EIV Reports Module
 Existing tenant search
 Multiple subsidy report
• PIH and Multifamily
 Identity verification report
 Deceased tenant report
Slide #80
© Copyright 2008 Nan McKay & Associates
EIV Reports
 Reports available by reexam month
• Failed verification report
• No income report (no income in EIV)
• New hires report
 Family members hired in last 180 days
 Can select “all” months to see complete list
Slide #81
© Copyright 2008 Nan McKay & Associates
NMA Lunch ‘n’ Learn Seminar
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Slide #82
© Copyright 2008 Nan McKay & Associates
NMA Lunch ‘n’ Learn Seminar