Four Tips to Follow When Navigating HUD's EIV System

The Enterprise Income Verification (EIV) system is a Web-based computer system implemented by HUD. It contains employment and income information on individuals participating in HUD's rental assistance programs. This information is used to meet HUD's requirement to independently verify employment and income when a resident recertifies for continued rental assistance.

Site owners and managers are able to use the EIV system to determine if residents correctly reported their income and the income of a spouse or other household member. It's also used to determine if a resident used a false Social Security number or if the resident is receiving rental assistance at another site.

The following are four tips for owners and managers to follow when navigating the EIV system. Following these tips may help minimize findings listed on your management and occupancy reviews.

Tip #1: Double Check Social Security Numbers at Every Step

One of our biggest issues is failed verification, says compliance specialist Mark Chrzanowski. “We train our managers to double check Social Security numbers and other information to ensure the correct information is sent to TRACS (Tenant Rental Assistance Certification System) and thereby EIV,” he says. Having someone else audit the file prior to sending it has eliminated many of these issues.

HUD generally requires you to get Social Security numbers (SSNs) for all members of an applicant household who are at least 6 years old. And HUD requires you to get proof of those numbers and specifies which documents you can accept as proof.

The following documents are acceptable proof of a household member's SSN:

• Original Social Security card;

• Driver's license;

• Identification card issued by a federal, state, or local agency, a medical insurance provider, or an employer or trade union;

• Earnings statements on payroll stubs;

• Bank statement;

• Form 1099;

• Benefit award letter;

• Life insurance policy; or

• Court records [HUD Handbook 4350.3, app. 3].

If the proof is any document except the original Social Security card, you must also get an additional document from the household member. This will be a special certification that the document he's giving you to prove his SSN is “complete and accurate” [Handbook 4350.3, par 3-31(C)]. To satisfy this requirement, you can use our Model Form_Get Certification from Applicant Who Provides Alternative Document for SSN.

HUD management consultant Roxie Munn recommends that you put a copy of the document the household member gave you to prove his SSN in the household file. Sometimes you may use the document that the member gave you for another purpose. Suppose a household member gave you a savings account statement to prove his SSN, but you also used that statement to verify the cash value of his savings account. In this case, put two copies of the document in the household file so that it's clear it was used for both purposes, advises Munn.

EDITOR'S NOTE: Individuals who applied for legalization under the Immigration Reform and Control Act of 1986 will be able to disclose their Social Security numbers but unable to supply cards for documentation. Social Security numbers are assigned to these persons when they apply for amnesty. The cards go to the Department of Homeland Security (DHS) until the individuals are granted temporary lawful resident status. Until that time, their acceptable documentation is a letter from the DHS indicating that Social Security numbers have been assigned.

Tip #2: Investigate and Document All Income Discrepancies

Income discrepancies are another common issue. It's important to identify the time period for which the discrepancy is being reported. This information is very useful in determining whether a discrepancy exists and whether the resident's current assistance is affected, or if the discrepancy occurred prior to move-in. Having this information also helps determine if there was other income reported that EIV would not be tracking, such as child support or income from an outside source like parents or friends, says Chrzanowski.

Owners and management agents who find discrepancies in the EIV system should use traditional third-party verification. However, HUD warns that when traditional third-party verification is used, the EIV documents must still be printed and placed in the household file, along with a note indicating why the EIV data was not used. By documenting each EIV report, alternate verification, and whether or not verification occurred, you can show that you used the EIV system first and that you have made all efforts to be in compliance.

Social Security benefits and employment income require verification. To verify your residents' Social Security benefits, you will use the EIV system unless there is no data, some data is missing, or the resident disputes the data. In these cases, you must obtain alternative verification, such as an award or benefit letter that is no more than 120 days old.

HUD reminds owners and management agents that they should not be sending residents to local Social Security Administration (SSA) offices to obtain proof of their Social Security income. Instead, they should ask residents to request benefit information from SSA using the SSA's toll-free number (1-800-772-1213), or by going to the SSA's Web site, www.socialsecurity.gov. On the left-hand side, the resident should select: “What you can do online,” click on “If you get benefits,” select “Request a Proof of Income Letter,” then check the box “All Benefit Information Available” to make sure that information for all the benefits the resident receives is provided. The proof of income information is free, and the resident will receive a letter in the mail within 10 days.

Verifying employment income with EIV data is a challenge because employer information in the system is historical. If you are unable to use EIV to confirm employer information, or if the resident doesn't provide you with paycheck stubs, you can use the traditional methods of verification such as W-2 forms and calling the employer.

Tip #3: Perform Existing Tenant Search Before Move-In

There's an option in the EIV system called “Existing Tenant Search.” This option allows a manager to key in the SSN of any applicant to determine if the applicant is already receiving Section 8 assistance. And according to Chrzanowski, this is a good tool for tracking possible dual subsidy issues.

Although it's nearly impossible to eliminate all instances of dual subsidy, the search allows sites to educate its applicants. Applicants need to be informed of the prohibition on receiving assistance on more than one unit and the obligation to repay assistance if this occurs.

All positive “hits” should be investigated. If a move-out hasn't been recorded in TRACS, then the applicant looks like she's still receiving assistance. By performing the Existing Tenant Search far enough before the move-in, there will be enough time to investigate and check with the resident and even the current owner to avoid any dual subsidy issues.

Tip #4: Provide Residents with “EIV & You” Brochure

Owners and managing agents must provide each household with the EIV & You brochure at the time of annual recertification, when applicants have been selected from the waiting list for screening, and at move-in or final application processing.

Owners may order the EIV & You brochure for English-speaking households from the online HUD Direct Distribution Center at www.hud.gov/offices/adm/dds/index.cfm or by telephone at 1-800-767-7468. The brochure is also available for download at the Multifamily RHIIP Web site at www.hud.gov/offices/hsg/mfh/rhiip/mfhrhiip.cfm.

It's important for residents and applicants selected for final screening and application processing to know that the owner and manager have access to a system containing personal and financial information about them. It will encourage residents to accurately report their income, which will lead to fewer repayment agreements with residents to recover rental assistance that was inappropriately paid on their behalf and discovered through use of the EIV system. Also, there will be fewer residents moving out of their units while still owing back rent, because the right amount of rental assistance will have been paid from the beginning.

Insider Sources

Mark Chrzanowski: Compliance Support Administrator, Gene B. Glick Co. Inc., 8425 Woodfield Crossing Blvd., Indianapolis, IN; www.genebglick.com.

Roxie Munn, CPM: President, Roxie Munn, Inc., 117 Kingsland Way, Piedmont, SC 29673; www.roxiemunn.com.

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