Slide #1 © Copyright 2008 Nan McKay & Associates Annie Stevenson Managing EIV © Copyright 2008 Nan McKay & Associates
Slide #1 © Copyright 2008 Nan McKay & Associates
Annie Stevenson
Managing EIV
© Copyright 2008 Nan McKay & Associates
Slide #2 © Copyright 2008 Nan McKay & Associates
Welcome to Lunch N Learn!
Today’s topics:• EIV update• Annual reexam processing• EIV reports• HUD compliance monitoring
Slide #4 © 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 #5 © 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 #6 © 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 #7 © 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 #8 © Copyright 2008 Nan McKay & Associates
UIV Resources
UIV resources include:• HUD’s EIV System• State Wage Information Collection Agencies • State TANF systems• Credit Bureau Association (CBA) credit reports• Internal Revenue Service (IRS) – Tax transcript
Request with IRS form 4506-T• Private sector databases
Slide #10 © Copyright 2008 Nan McKay & Associates
HUD Guidance on EIV
2 HUD training webcasts on EIV• 1/16/08• 8/26/08
Webcasts are archived at http://www.hud.gov/webcasts/archives/index.cfm
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HUD Guidance on EIV
Training materials from webcasts• Powerpoints• Case studies & solutions• http://www.hud.gov/offices/pih/programs/ph/rhii
p/training.cfm
Slide #12 © Copyright 2008 Nan McKay & Associates
HUD Guidance on EIV
8/26/08 webcast• Comprehensive training on “Effective Use of
EIV”• Extensive discussion of EIV reports and their
usage• EIV sign-on now includes certification of EIV &
security training
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8/26/08 Webcast
Clarification that EIV is sufficient verification of SS/SSI if family agrees
PH flat rent families now excluded from income discrepancy report
Discussion of identity theft Guidance on use of income discrepancy report
Slide #14 © 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• Webcast available at
http://www.hud.gov/webcasts/archives/ph.cfm4 hours
Slide #15 © 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 #16 © Copyright 2008 Nan McKay & Associates
HUD Guidance on EIV
The PHA MUST obtain additional third-party verification when the family disputes EIV employer data
Slide #17 © 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 #18 © 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 #19 © 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 #20 © 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 #21 © 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 #22 © 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 #24 © Copyright 2008 Nan McKay & Associates
EIV Modules
Tenant Income Data Income Discrepancy Report Different data for different purposes
Slide #25 © Copyright 2008 Nan McKay & Associates
Disclosure of EIV Data
PHAs may not disclose EIV 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 EIV data to the individual (only) to whom the record pertains
EIV data of minors may be provided to the minor’s parent or guardian
Slide #26 © 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
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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 #28 © 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
Slide #30 © 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 #31 © 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 #33 © 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 #37 © Copyright 2008 Nan McKay & Associates
EIV Tenant Income Data
• Verifies Medicare Part B buy-in amount for medical expenses deduction
Slide #39 © 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??”
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Data Processing Steps
Reexam packet mailed to families• Add EIV informing notice • Request paystubs per PHA policy
Last 60 days would be reasonableShould be consistent among staff
• Request HUD-9886 for family members turning 18
Slide #41 © Copyright 2008 Nan McKay & Associates
Data Processing Steps
Reexam packets returned to PHA Print & distribute EIV data Identify unreported employment/earnings Compare EIV and tenant-supplied documents
(paystubs)
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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 #43 © Copyright 2008 Nan McKay & Associates
Evaluating EIV Data
If family disputes EIV employment data:• PHA must request third-party written
verification
Slide #44 © 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 employmentPay rate, hours worked for new jobsConfirmation of a change in circumstances
(reduced hours, reduced rate of pay)
Slide #45 © 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 #46 © 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 #47 © 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 #49 © Copyright 2008 Nan McKay & Associates
EIV Reports Module
Existing tenant search Multiple subsidy report
• PIH and Multifamily Identity verification report Deceased tenant report
Slide #50 © 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 #52 © Copyright 2008 Nan McKay & Associates
Consolidated Reviews
Program areas under review:• RIM• UIV• SEMAP• PHAS Management Assessment (MASS)• Civil rights
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Consolidated Reviews
HUD UIV Monitoring Report• Implementation review• Security assessment• Income discrepancy review
5 highest dollar discrepancies per program
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UIV Monitoring Report
Implementation• Has the PHA accessed EIV within 30
days?• Which UIV tools are used by the
PHA?
Slide #55 © Copyright 2008 Nan McKay & Associates
UIV Monitoring Report: Security Assessment
Designated security officer Security policies/procedures document Enforcement Record-keeping Separate user ID/password for each user
Slide #56 © Copyright 2008 Nan McKay & Associates
UIV Monitoring Report: Security Assessment
Signed authorizations & user agreements Key log for secure areas Log of destroyed documents OR records
retention policy Valid 9886 forms
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UIV Monitoring Report: Security Assessment
Procedure for documentation of improper disclosures
Procedure for reporting security breaches Physical security measures Method of document disposal