Transcript Slide 1
Slide #1
© Copyright 2008 Nan McKay & Associates
Enterprise Income Verification
Annie Stevenson
Slide #2
© 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:
•
•
•
•
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
Slide #18
© Copyright 2008 Nan McKay & Associates
HUD Guidance on EIV
The PHA MUST obtain additional thirdparty verification when the family
disputes EIV employer data
Slide #19
© 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
Slide #21
© 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
Slide #22
© 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
Slide #25
© Copyright 2008 Nan McKay & Associates
EIV System Interactions
Slide #26
© Copyright 2008 Nan McKay & Associates
Data Displayed by EIV
Employment information (new hires)
Quarterly wages
Unemployment insurance
Social Security benefits (SS)
• Dual entitlement
Slide #27
© Copyright 2008 Nan McKay & Associates
Data Displayed by EIV
Medicare data
Supplemental Security (SSI) benefits
Black Lung entitlement
Disability information
Slide #28
© 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
Slide #32
© 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
Slide #36
© 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
Slide #37
© 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
Slide #40
© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
Slide #41
© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
Slide #42
© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
Slide #43
© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
• Verifies Medicare Part B buy-in amount for
medical expenses deduction
Slide #44
© Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
Slide #45
© 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
Slide #47
© 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?
Slide #56
© 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
Slide #57
© Copyright 2008 Nan McKay & Associates
Evaluating EIV Data
If family disputes EIV employment data:
• PHA must request third-party written
verification
Slide #58
© 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
•
•
•
•
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
Slide #63
© 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
Slide #64
© 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
Slide #65
© 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?
Slide #66
© 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
Slide #67
© 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
NEXT TOPIC…
Slide #82
© Copyright 2008 Nan McKay & Associates
NMA Lunch ‘n’ Learn Seminar