HUD’s Enterprise Income Verification System

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Registration & Set Up

◦ All property staff dealing with move-in, annual and interim certifications and recertifications must have their own WASS ID; which will allow access to HUD’s Secure System. Steps for registering for a WASS ID are on page 8 of Edgewood’s EIV Policy, as well as in the Policy & Procedures Manual; Volume I, Section I, page 61.

◦ EMC Intranet www.emcnet.biz

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http://portal.hud.gov/hudportal/HUD?src=/program_offices/housing/mfh/trx/trxsum

TRACS – The Vouchering system to get sites paid.

EIV – Income Verification systems to verify incomes.

PASS – Physical Assessment Subsystems

iMAX- Integrated Multifamily Access Exchange

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What is EIV? ◦ The Enterprise Income Verification (EIV) system

is a web-based system that contains resident wage and benefit data for use by owners and management agents, service bureaus, and contract administrators. The data is used to assist HUD’s business partners in accurately determining resident income (“income verification”) in order to calculate the amount of subsidy to be paid on behalf of the resident for a unit on a HUD assisted property, to include the following programs: Project Based Section 8, Rent Supplement, RAP, Section 202 PAC, Section 202 PRAC, Section 811 PRAC, Section 236 and Section 221(d)(3) BMIR.

◦ EIV is part of HUD’s RHIIP (Rental Housing Integrity Improvement Project) initiative. HUD is responsible for ensuring that the proper subsidy is provided to each household. This system will address causes of errors and improper payments and ensure the right benefits go to the right persons.

◦ EIV data is received from the Social Security Administration, the Department of Health and Human Services, and the National Directory of New Hires.

◦ EIV use is mandatory and the requirements are incorporated into the EIV & HUD’s “Final Rule” which was implemented on January 31st, 2010. This is why it is required that all residents disclose a valid SSN.

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EIV will be used in the following instances:

◦ To determine if an applicant currently receives assistance through another Multifamily Housing location at the time of application or move-in.

◦ To verify frequency and amount of benefits from the Social Security Administration, as well as the Department of Health and Human Services.

◦ To verify employment status and determine if residents have started new employment within the past months; as well as identify cases of unreported income.

◦ To determine if a resident is using an invalid ID or SSN.◦ To help determine if administrative or legal action should be taken

against residents who did not report income.

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EIV will not be used in the following instances:

◦ To certify applicants or recertify residents under the Low Income Housing Tax Credit Program, nor will any information be disclosed to the State Tax Credit Monitoring Agencies.

◦ To certify applicants or recertify residents under the Section 515 Rural Housing Program, nor will any information be disclosed to the RHS (Rural Housing Services) staff monitoring the 515 program.

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EIV Certification & Recertification

◦ In order to begin using EIV, each User must first be certified. Follow steps on page 9 of Edgewood’s EIV Policy. Once your request is pending, contact Traci Wallace to approve the request. You must also print a copy of the approved “UAAF” for the property Master EIV File.

◦ In addition, all Users must be recertified on a semi-annual basis. Make a note of your certification expiration date so you know when you will be due for recertification. You must then complete the steps on page 9 again for EIV “Recertification”.

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Security Exam

◦ You will also be prompted to complete the EIV Security Exam the first time you attempt to access EIV. You will not be permitted to access EIV until you have passed the exam. Once you have passed, the exam will be available for you to print from the left column menu. This is also where the approved UAAF will be available to print.

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Requirements for Using EIV Data:

◦ Tenant Selection Plan- O/A’s must use the Existing Tenant Search in EIV as part of their screening criteria for new residents, and must include written policies for using the search in their Tenant Selection Plan.

◦ Policies and Procedures- O/A’s must have written policies and procedures for staff to follow for using the EIV Income Report as third party verification of employment and income, and for using the other EIV Reports (Income Discrepancy Report & EIV Verification Reports).

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MOR Requirements:

1. O/A must have access to EIV. 2. O/A must be using EIV for recertifications effective 6/1/10. 3. Missing/incomplete EIV documents (Email HUD

Headquarters immediately to Terminate coordinator’s/user’s access at the following address: mf_alert@hud.gov. Name, property, MOR date and missing documentation. Advise O/A mitigate and contact CA to reinstate access). 4. Rules of Behavior for non-system users must be used

whereapplicable.

5. EIV data being shared with other entities, e.g., state officials monitoring tax credit projects, rural Housing staff monitoring Section 515 projects, or Service Coordinators.

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MOR Requirements cont.: 6. EIV data must be kept secure. 7. O/A must update Policies and Procedures to include EIV

use. 8. O/A must update Tenant Selection Plan to include use of

Existing Tenant Search. 9. EIV Income Reports must be in tenant files as third party

verification. 10. Tenant files must have documentation to support EIV

income discrepancy resolution. 11. O/A must use Existing Tenant Search. 12. O/A must review New Hires Report. 13. O/A must resolve Failed Verification (SSA Identity Test)

and Pre-Screening discrepancies.

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MOR Requirements cont.:

14. Deceased Tenants Report must be reviewed and errors corrected.

15. Multiple Subsidy Report must be reviewed and errors corrected.

16. O/A must follow HUD’s record retention requirements. 17. Missing/Incomplete form HUD-9887. 18. O/A must provide tenants with the EIV & You Brochure

when selected from waiting list to move-in, and at annual recertification.

19. Individuals having access to the EIV system or data must have annual security training.

20. O/A must NOT share WASS ID’s and passwords.

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Consent for the Release of Information:

◦ Applicants: The form HUD-9887 Notice & Consent for Release of Information signed by the applicant and each applicant household member 18 years of age or older does not need to be on file in order to use the Existing Tenant Search in EIV at the time of application processing and tenant screening.

◦ Residents- A current form HUD-9887 must be on file before accessing the employment or income data contained in EIV for a resident. The form must be signed and dated by each adult member of the household; regardless of whether he or she has income.

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Consent for the Release of Information cont.:

◦ If a resident turns 18, and has not signed the 9887, you must not use the Income Reports until the form is signed. Anyone turning 18 must come to the management office to sign the 9887 immediately. If the HUD 9887 has not been signed within 30 days of the household member turning 18, the household is in noncompliance with their lease, and assistance and/or tenancy may be terminated.

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Employment & Income Data Available in EIV

◦ Social Security Administration-

Social Security (SS) benefits Supplemental Security Income (SSI) benefits Dual Entitlement benefits Medicare premium information Disability status

◦ National Directory of New Hires (NDNH)-

New Hires (W-4) Quarterly wages for federal and non-federal employees Quarterly unemployment compensation benefits

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Using EIV Reports

• The EIV Income Report must be used as a 3rd party source to verify a resident’s employment and income during mandatory recertifications (annual & interim).

• The EIV Income Discrepancy Report (along with the New Hires & No Income Reports) assists in identifying issues or discrepancies which may impact the household’s assistance.

• When selecting the Income Report for an individual resident, there are 3 options that must be used at the time of recertification (annual or interim):

• Summary Report, Income Report, Income Discrepancy Report

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Summary Report:The Summary Report provides a summary of information

taken from the current active certification in the TRACS file at the time of the income match. This also provides the Identity Verification Status for each household member.

◦ Verified- personal identifiers (last name DOB, SSN) match the SSA database.

◦ Failed- personal identifiers do not match the SSA database. ◦ Not verified- personal identifiers have not yet been sent by

HUD to SSA for validation or the validation is in process. ◦ Deceased- SSA’s records indicate the person is deceased.

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Income Report: The income report provides a variety of information about

each member of a household. The components of the report are:

◦ TRACS Certification Information and personal identifiers ◦ Employment information ◦ Wages◦ Unemployment benefits ◦ Social Security benefits ◦ Dual Entitlements ◦ Supplemental Security Income benefits ◦ SSA Disability Status

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The following documentation is required to be in the resident file to demonstrate the Owner’s compliance with mandated use of EIV as the 3rd party source to verify employment and income information.

◦ No dispute of EIV Information- EIV Income Report, and current resident provided documentation.

◦ Disputed EIV Information- EIV Income Report and 3rd party

verification from the source of the disputed information.

◦ Resident reported income not verified through EIV- EIV income report, current acceptable resident-provided documents and/or 3rd party from source.

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The income report identifying the employment is to be used as 3rd party verification of employment and NOT to be used to calculate income.

If the resident agrees that the employment/unemployment information in EIV is correct, request the resident to provide 6 consecutive pay stubs (minimum of 4) to support the current income being received.

If the resident disputes the employment or unemployment information, or when a resident reports employment and there is no information in EIV, obtain 3rd party verification from the source.

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The Income Report identifying the Social Security benefit information in EIV must be used as 3rd party verification of the resident’s income and must be used to calculate the income.

A copy of the award letter is not required unless the resident disputes the SSA information in EIV.

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Income Discrepancy Report:

◦ Identifies households where there is a difference of $2,400 or more in the wage, unemployment and SSA benefit information reported in EIV and TRACS. This report must be used at recertification.

◦ This report must be printed at the same time the income report is printed.

◦ Resolve discrepancies within 30 days of the EIV Income Report date.

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Existing Tenant Search:

◦ This report identifies applicants who may be receiving assistance at another Multifamily or PIH location.

◦ This report should be run at the time of processing an applicant for admission.

◦ Retention- Applicant file- if not admitted, retain search results and

any supporting documentation with the application for 3 years. Note: you are not required to run the Existing Tenant Search on an applicant already deemed ineligible by another applicant screening factor.

Resident File- if admitted, retain search results and any supporting documentation with the application for term of tenancy, plus 3 years.

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Penalties for Failure to use EIV as Required:

◦ If an O/A is not using EIV at the time of MOR, the O/A will: Receive a finding on the MOR Report. Incur a penalty of a 5% decrease in the voucher

payment for the month following the date the violation was found.

Be required to make an adjustment on the next scheduled voucher to adjust for the 5% decrease.

Be monitored by the CA to ensure the adjustment was made.

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Penalties for Failure to use EIV as Required:

◦ The O/A will have 30 days to cure the finding. ◦ If the finding is not cured during the 30 day period,

both the Owner and Management Agent will be flagged in HUD’s Active Partner’s Performance System (APPS). Once the finding is cured, the flag will be removed.

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Master EIV File :

◦ Each property is required to maintain a Master EIV Folder containing the following documents:

UAAF (User Access Authorization Form)- an original and current form must be in the folder for each User at the property, as well as for all of the Compliance Specialists. Compliance Department UAAF’s are on the intranet. Your original UAAF is the handwritten form, and the current UAAF can be printed directly from EIV. Once you have logged into EIV select the link for “Authorization Form” from the left column menu to print your form.

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Master EIV File cont.

CAAF- (Coordinator Access Authorization Form)- an original and current form must be in the folder for both Edgewood Coordinators; Fred Mifflin & Traci Wallace. The original and current CAAF forms are on the intranet for both Coordinators.

User Security Awareness Exam- an original and current Security Awareness Exam must be in the folder for all Users at the property. The original is the handwritten form, and the current can be printed directly from EIV. Once you have logged into EIV select the link for “Security Exam Report” from the left column menu to print your exam. You must also have the Security Awareness Exams for the Compliance Specialists. These forms are on the intranet.

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Master EIV File cont.

Coordinator Security Awareness Exam- an original and current exam must be in the folder for both Edgewood Coordinators; Fred Mifflin & Traci Wallace. The original and current Security Awareness Exams are on the intranet for both Coordinators.

Owner Approval Letter- Each property must have an Owner Approval Letter for both Fred Mifflin & Traci Wallace. These are currently being updated, and all Owner Approval Letters will be placed on the intranet.

Rules of Behavior- this form must be in your EIV Folder for those accessing EIV who are non-system Users.

EIV Policy- a copy of Edgewood’s full EIV Policy must be in your EIV Folder for review.

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Master File of EIV Verification Reports:

◦ Sites are required to maintain a Master File of EIV Verification Reports. The reports should be maintained in a 3 ring binder, separated by report. It is recommended to use a separate 3 ring binder for each report type; which would be 4 binders total.

Identity Verification Reports- Monthly Failed EIV Pre-Screening Report Failed EIV SSA Identity Report

Deceased Tenant Report- Quarterly New Hires Report- Quarterly Multiple Subsidy Report- Quarterly

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EIV & TRACS: Regular review of EIV reports helps reduce errors

with assistance payments. Owners/Agents are required to ensure that:

Data recorded in TRACS is correct

Information provided by residents is correct

Residents are complying with reporting requirements

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If there’s no current active 50059 in TRACS, there will be no EIV data for that household.

If the resident’s most recent certification isn’t in TRACS, the Income Discrepancy Report will be inaccurate.

If the Certification shows incorrect identifiers for a resident, EIV information will be missing.

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Review the information in TRACS regularly.

You MUST use the Tenant Certification Query to ensure each household has a current and active certification in TRACS.

Make sure it’s the most recent 50059.

Work with your CA to ensure all certifications are in TRACS. Some CA’s prefer to retransmit missing certifications themselves.

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EIV Responsibilities- Traci Wallace sets up users and is the Corporate

EIV coordinator The principal responsibility for running EIV Reports

and using EIV rests with the Community Manager Compliance can’t see what reports are being run,

or not run. Each site and Regional Manager is responsible for monitoring use of the system

Ongoing Security training and site security operations is the responsibility of the Community Manager.

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Wrap-up & Reminders:

◦ Review the Updated Edgewood EIV Policy on the intranet.

◦ Make certain you have implemented and are using all required policies, forms and reports.

◦ Review HUD EIV Instruction Update Notice 11-21 for detailed information regarding how to use, and interpret all EIV Reports and requirements.

◦ Contact Traci Wallace twallace@emcmgmt.com with any questions regarding EIV.

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