How to Avoid 3 Timing Mistakes During the Verification Process
To calculate and verify household income, applicants and tenants who are at least 18 years of age and each family head, spouse, or co-head regardless of age must provide the site with certain information specified by HUD. To make sure that the assistance is used properly, owners must verify the information that’s used to determine eligibility and the amount of rent a household pays.
Households give consent to the release of this information by signing the form HUD-9887, the form HUD-9887-A, and the individual verification and consent forms that apply to the household. When verifying income, time limits apply to verification forms and the verification process, but many managers may not be aware of HUD rules on the timing of verifications. Not all timing rules appear on the verification forms themselves. However, the rules are discussed in Chapter 5 of HUD Handbook 4350.3.
For example, HUD rules limit how long the household’s signed consent on a verification form remains effective, when during the certification process verification forms must be sent, and how long you may rely on verified information. To help you avoid verification errors, we’ll identify and discuss three common verification timing mistakes.
Mistake #1: Seeking Verification with Stale Forms
Sometimes site managers keep on file copies of verification forms that households signed, but which were never sent to verification sources. When managers have to verify year after year the same information about households with the same sources, they may be tempted to simply pull out the verification form the household signed the prior year, photocopy it, and send it to sources. But that is a mistake.
HUD says owner-created verification forms and the forms HUD-9887 and HUD-9887-A expire 15 months after they are signed. This is intended to cover the period beginning 120 days prior to certification and ending on the last day of the one-year certification period. Individual verification forms signed by households more than 15 months ago are not valid for use in verifying information with third parties [HUD Handbook 4350.3, Par. 5-16(A)].
What to do. Have residents sign new copies of all necessary verification forms at every certification meeting. Never use verification forms that households signed at prior certifications or recertifications.
Mistake #2: Verifying After Certification
When households have a proven track record of truthfulness or site staff are buried under a backlog of paperwork, you may be tempted to recertify households before you receive verification of the information they’ve given you. But that is a mistake.
HUD says form HUD-9887-A and individual verification forms can be used during the 120 days before the certification period [HUD Handbook 4350.3, par. 5-16(A)(1)]. HUD’s purpose in requiring this is to encourage certifications that are based on accurate and verified information, not on faith.
What to do. Send out verification forms immediately after households sign them and well before you certify the household. That way, you leave yourself time to send another copy if, as sometimes happens, the verification source loses the form.
The only exception to this rule is if the initial verification response is inconsistent in some way with the information provided by household members. Only then, HUD says, may you contact verification sources after certification to resolve or clarify the discrepancy.
Mistake #3: Seeking Verification of Information More than 12 Months Old
Sometimes managers are tempted to go beyond the information that’s strictly necessary for certification. For example, managers may be tempted to ask verification sources for additional information because they have a vague suspicion that households may not be telling the truth. But HUD limits how far back in time your inquiries can go in the absence of verified information consistent with what household members have told you.
Under ordinary circumstances, HUD prohibits owners and managers from asking verification sources for information that’s more than 12 months old [Handbook 4350.3, par. 5-16(A)(2)(a)].
Keep in mind that HUD specifically requires or suggests that owners and managers verify some information even though doing so seems to violate this rule. For example, HUD says, employment verification forms should ask when household members were first employed, even though household members might have gotten their jobs more than one year ago. And, in most cases, verifying birth dates and Social Security numbers as HUD requires also involves getting information that’s more than 12 months old. But unless HUD rules specifically authorize you to do so, don’t ask for verification of information more than one year old.
What to do. All questions on your individual verification forms should seek current information or information that’s no more than one year old. For example, you risk violating privacy laws by asking banks (for certification purposes) to give you information on households’ bank accounts going back several years. The only exception is if you have already received verification from third parties indicating that members may have lied to you about bank accounts, in which case you may seek to verify information up to five years old [Handbook 4350.3, par.5-16(A)(2)(b)].