HUD Working to Resolve EIV Data Issues
According to recently issued RHIIP ListServ Posting #411, HUD has been advised that a number of owners/agents are encountering old or missing data when attempting to view EIV reports for some or all of their sites. If you’re encountering these issues, for compliance monitoring purposes, copies of the incorrect EIV reports must be retained and proper verification must be conducted. HUD is aware of the errors and is working to correct the issues in the system.
Acceptable Forms of Verification
Owners experiencing these issues must refer to Chapter 5-13 of HUD Handbook 4350.3 for the hierarchy of acceptable forms of verification. According to the Handbook, acceptable methods of verification, in order of acceptability, are:
- Upfront-income verification (UIV) with use of EIV being mandatory and use of non-EIV UIV being optional;
- Third-party verification from source (written);
- Third-party verification from source (oral); and
- Family certification in the form of a notarized statement or signed affidavit.
Non-EIV UIV. UIV is verification of income before or during a certification and/or recertification, through an independent source that systematically and uniformly maintains income information in a computerized form. Owners may use other non-HUD UIV tools such as the work number and other state government databases, if available, to verify applicants’ income when no employment or income is available in EIV, or for other types of income received by the family.
Written third-party verification. The next tier in the verification hierarchy is written third-party verifications from sources. These are original or authentic documents generated by a third-party source that’s dated within 120 days from the date of receipt by the owner. Such documentation may be in possession of the tenant (or applicant), and commonly referred to as “tenant-provided documents.” These documents are considered third-party verification because they originated from a third-party source.
Examples of tenant-provided documentation that may be used includes, but is not limited to: pay stubs, payroll summary report, employer notice/letter of hire/termination, SSA benefit letter, bank statements, child support payment stubs, welfare benefit letters and/or printouts, and unemployment monetary benefit notices.
When using tenant-provided documentation, owners must consider whether the document is current, complete, and is an unaltered original. The greatest shortcoming of tenant-provided documents as a verification source is their susceptibility to undetectable change through the use of high-quality copying equipment. Documents with original signatures are the most reliable. Photocopied documents generally cannot be assumed to be reliable.
The next tier is written documentation sent directly by the third-party source by mail or electronically by fax, email, or Internet.
Streamlined Method of Determining Fixed Income
For project-based Section 8 sites, owners have the option of using a streamlined income determination for any family member with a fixed source of income [HUD Notice H-2016-09, Streamlining Administrative Regulations for Multifamily Housing Programs]. A streamlined income determination is made by applying, for each fixed-income source, either the verified cost of living adjustment (COLA) or the current rate of interest to the previously verified or adjusted-income amount. Any non-fixed sources of income must be verified using third-party verification as described above.
The term “fixed income” includes income from:
- Social Security payments, including Supplemental Security Income (SSI) and Supplemental Disability Insurance (SSDI);
- Federal, state, local, and private pension plans; and
- Other periodic payments received from annuities, insurance policies, retirement funds, disability or death benefits, and other similar types of periodic payments.
For example, when using Streamlined Determination of Fixed Income, check the file to see if EIV or third-party verification was obtained in 2017. If so, in the case of Social Security payments as the source of fixed income, make a copy of the 2017 Social Security verification information. Then, go to https://www.ssa.gov/news/press/releases/2017/#10-2017-1 and print the 2018 COLA FACT Sheet for the tenant file and calculate the new income by adding the COLA increase for 2018. Then file a copy of the 2017 verification and the 2018 COLA Fact Sheet in the tenant file.
Another option of verifying fixed income is to use information from a current award letter (no more than 120 days old from the date of receipt). Residents can request a copy of their award letter from the Social Security Administration by calling 800-772-1213 (TTY 800-325-0778) or by contacting the local office. You can also ask the resident to provide you with a current printout from her SSA account, if the resident is currently signed up at MySSA.gov.