The Enterprise Income Verification EIV System North Tampa

The Enterprise Income Verification (EIV) System North Tampa Housing Development Corporation FAHSA Jacksonville, FL September 21, 2010

Dorothy Swayze Local Services Supervisor – Jacksonville/Tallahassee Regions North Tampa Housing Development Corporation Contact Information: CGI Federal/NTHDC 2608 Gillis St. Palatka, FL 32177 Phone: (386) 325 -1176 Email: dorothy. swayze@cgifederal. com NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Session Instructor

• EIV Requirements Overview NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Session Agenda • Update on New Requirements as a Result of HUD Notice 2010 -10 • Reports Available In EIV • What they are for • How to run them • How to follow up on discrepancies • Common issues found during MORs

EIV Requirements Overview North Tampa Housing Development Corporation

EIV Became Mandatory on 1/31/2010 • Federal Register, Final Rule on Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Programs: Implementation of the Enterprise Income Verification System—Amendments • Requires EIV be implemented in its entirety • Available at: http: //edocket. access. gpo. gov/2009/pdf/E 9 -30720. pdf NORTH TAMPA HOUSING DEVELOPMENT CORPORATION EIV Requirements Overview

EIV is Intended to: • Be used as a 3 rd party source to verify tenant employment and income information • Reduce administrative and subsidy payment errors • Assist HUD in meeting the Rental Housing Integrity Improvement Project’s (RHIIP’s) goal of ensuring that the right benefits go to the right persons, and supports Executive Order 13520, Reducing Improper Payments, signed by President Obama on November 20, 2009 NORTH TAMPA HOUSING DEVELOPMENT CORPORATION EIV Requirements Overview

Owner/Agents are Required to: NORTH TAMPA HOUSING DEVELOPMENT CORPORATION EIV Requirements Overview • Have access to EIV • Maintain all required EIV forms and documents • Use all Income & Verification Reports available in EIV • Update Policies and Procedures to include the use & frequency of reports in EIV • Establish Policies and Procedures to maintain and continue to maintain EIV data in accordance with the security safeguards of Privacy Act Data within EIV

Update on New Requirements as a Result of HUD Notice 2010 -10 North Tampa Housing Development Corporation

• When there is a change in Owner or Agent; the O/A has 90 days to obtain access and begin using EIV for that property or be subject to financial and administrative penalties • When a household member turns 18 between certifications, they must come in and sign a 9887/9887 A at that time • O/As must address in their Policies and Procedures notification requirements and timeframes for tenants who turn 18 between recertifications to sign the consent forms NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Requirements Update

• The EIV data of an adult household member may not be shared (or a copy provided or displayed) with another adult household member or to a person assisting the tenant with the recertification process, unless the individual has provided written consent to disclose such information • O/A is not prohibited from discussing with the HOH and showing the HOH how the household’s income and rent were determined based on the total income reported and verified NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Requirements Update

• Once a household member is listed as “Verified” on the Summary Report, The O/A may (not must) remove and destroy SSN verification from the file • The Summary Report with the status of “Verified” will serve as SSN verification • O/As must not include the full SSN for a tenant in emails or other electronic communications NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Requirements Update • O/As must provide security training to Users, Coordinators and all O/A staff required to sign a Rules of Behavior • MUST keep a file of who took the training and when for auditing purposes

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Requirements Update • EIV reports that were previously recommended are now required; and all reports are now required to be printed and maintained each time they are generated • The only exception is the No Income report which is still recommended quarterly • Summary, Income, and Discrepancy reports must be run/reviewed/printed 90 days after MI 50059 submission • All discrepancies on any EIV report must be resolved within 30 days from the date of the EIV report listing the discrepancy

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Requirements Update • Master reports must be maintained for each Monthly and Quarterly EIV report with notations of resolution steps taken • Detail Reports and individual household documentation obtained to resolve discrepancies must be maintained in the tenant file • O/A must process corrections for decreases of more than $200 per month revealed through the use of EIV that were the result of O/A miscalculation • This does not include decreases due to tenant failure to report a decrease

• Once required retention period expires, O/A must dispose of the EIV data • Must dispose of Master File reports 3 years after date of report • Must dispose of Individual EIV reports maintained in tenant files 3 years after termination of tenancy • Repayment Agreements must contain certain information (as described on page 41 of the HUD Notice 2010 -10) NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Requirements Update

EIV Reports North Tampa Housing Development Corporation

EIV Reports NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Reports Available in EIV Income Reports Verification Reports • Summary • Income • Discrepancy • No Income • New Hires • Existing Tenant Search • Identity Verification • Failed EIV Prescreening • Failed Verification • Multiple Subsidy • Deceased Tenant

Individual Household Reports North Tampa Housing Development Corporation

Existing Tenant Search Report North Tampa Housing Development Corporation

Existing Tenant Search • MUST generate this report prior to move-in • System searches for a match based on SSN in both Public Housing and Multifamily Properties • Identifies applicant members that are currently receiving subsidy to help avoid Double Subsidy problems • Use of the report must be included in the Tenant Selection Plan NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Existing Tenant Search

• Must be run for all household members including dependents – one at a time • Print each result for each member and place them in the tenant file or with application • Retain report for 3 years after move-out or with application if they do not move-in for 3 years NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Existing Tenant Search

No Issues for this applicant! NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Existing Tenant Search

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Existing Tenant Search

If there is a household member that is listed in EIV as being an existing tenant: 1. Discuss the result with applicant 2. Contact the manager at the other property to verify applicant is a tenant there 3. Coordinate the move-out / move-in dates to avoid double subsidy problems 4. Maintain documentation of all follow up actions taken including contact with applicant and other property NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Existing Tenant Search

Common Issues found during the MOR regarding the Existing Tenant Search Include: NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Existing Tenant Search 1. Report not being run for all household members including dependents 2. Not maintaining documentation of all follow up actions taken including contact with applicant and other property 3. Tenant Selection plan not updated to specifically mention using the Existing Tenant Search during the application/MI process

Summary, Income, and Discrepancy Reports North Tampa Housing Development Corporation

Summary, Income, & Discrepancy Reports • All 3 reports are automatically generated each time the Income Report is ran in EIV • System searches for available personal identifiers and income data for each member and matches that data to information listed on the last 50059 submitted to TRACS • Must generate these reports within 90 days after MI 50059 submission to TRACS • Must generate these reports at each AR & IR (and other times if so outlined in O/A procedures) NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Summary, Income, and Discrepancy Reports

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Summary, Income, and Discrepancy Reports There are 2 possible ways to generate these reports in EIV 1. By SSN for Head of Household • Will only generate these reports for that individual’s household 2. By Contract Number and specified recertification month • Will generate these reports for all households with an anniversary date for the specified month

By SSN for Head of Household 1. Click on “By Head of Household” on the left side of the EIV screen under Income Information 2. Enter Head’s SSN 3. Select Contract 4. Click Go NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Summary, Income, and Discrepancy Reports

• Summary, Income, and Discrepancy Reports will appear for that household • When you generate the reports in this way there is a “Print-All” feature in the top right of the EIV screen that will allow you to view and print all 3 reports at once for that household NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Summary, Income, and Discrepancy Reports

By Contract Number and specified recertification month 1. Click on “By Contract Number” 2. Select Contract 3. Select Re-Certification Month 4. Click Go NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Summary, Income, and Discrepancy Reports

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Summary, Income, and Discrepancy Reports • A summary of what was generated will appear • Click on Income Report and a list of the households up for recertification in the specified month will appear • Click on each name individually on the list to get to the reports for that household

• Summary, Income, and Discrepancy Reports will appear for that household NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Summary, Income, and Discrepancy Reports • When you generate the reports in this way there is NOT a “Print-All” feature in the top right of the EIV screen; therefore you will have to click on each report tab and print each report separately for each household on the list

Summary Report • Lists all members of the household with their personal identifiers and Identity Verification Status • Status will be either: 1. Verified – info on 50059 matches SSA 2. Failed – member info does not match 3. Not Verified – member 50059 info has not been sent to EIV 4. Deceased – member reported by SSA as deceased NOTE: EIV will only have income info for tenants whose status is Verified NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Summary Report

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Summary Report

• Must review the Summary Report each time the Income Report is generated NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Summary Report • Must print and retain the Summary Report in tenant file for term of tenancy and 3 years after move-out • If all members have a status of “Verified” the report does not have to be printed again unless there is a change in family composition or the listed status of a member changes • Must continue to print and maintain in the tenant file all Summary Reports that do not list all members as “Verified”

• Must resolve the status of any member with a Failed or Deceased status • Correct 50059 data entry errors and resubmit the 50059 • Encourage tenant to contact SSA to correct incorrect data from SSA • call or visit local office NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Summary Report • Must maintain file notes and documentation of all follow up action taken to resolve the status • Includes maintaining documentation of verified exemption for any member of the household that is exempt from providing a SSN

Common Issues found during the MOR regarding the Summary Report Include: NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Summary Report 1. Not printing and maintaining the report 2. Not maintaining documentation of all follow up actions 3. Procedures not properly updated with when to run the report, how to review the report, and where to maintain the report and follow up documentation

Income Report • Income Report includes information for each household member for: • Wages • Unemployment benefits • Social Security benefits • SSI • Dual Entitlements • Medicare NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report will not have information on income from other sources such as: • • • Child Support Welfare Family Contributions Pensions Income from Assets

Wages • Information is updated quarterly - approximately 1 to 2 months after the end of the calendar quarter NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report • Income Report is 3 rd party verification that tenant is employed • If information on report matches tenant reported information no other 3 rd party verification is necessary • Must obtain 4 consecutive, recent paystubs from tenant to calculate income • Wage information in EIV can not be used to calculate income

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report - Wages

Obtain traditional 3 rd party verification of employment if: • Tenant insists they are not employed but wage information is listed in EIV • Tenant reports recently gaining or losing a job • Tenant reports they are working but no wage information is in EIV NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report - Wages

Unemployment Benefits • Information is updated quarterly - approximately 1 - 2 months after the end of the calendar quarter • EIV serves as 3 rd party verification that tenant is receiving unemployment benefits • If information on report matches tenant reported information no other 3 rd party verification is necessary • Must obtain 4 consecutive benefit “paystubs” or benefit letter from tenant to calculate income • Information in EIV can not be used to calculate income NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Unemployment Benefits

Example of how Unemployment Benefits are reported in EIV: NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Unemployment Benefits

Obtain traditional 3 rd party verification of Unemployment Benefits if: NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Unemployment Benefits • Tenant insists they are not receiving unemployment, but benefit information is listed in EIV • Tenant reports they are receiving unemployment, but no benefit information is in EIV

Social Security Benefits NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Social Security Benefits • Information is updated quarterly - approximately 1 to 2 months after the end of the calendar quarter • EIV serves as third party verification and can be used to calculate annual income from SSA benefits as long as the tenant agrees with the information • SSA COLA is not available in EIV until the end of the calendar year • For AR’s effective 1/1 – 4/1, O/A must use 1 of 3 methods for determining the tenant’s income (all AR’s after 4/1 must reflect SSA COLA)

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Social Security Benefits 1. Use the undisputed gross income reported by EIV if tenant agrees that is the amount being received 2. Use an SSA letter inclusive of the COLA adjustment that is dated within 120 days 3. Apply the COLA increase to the verified current amount of income or obtain third party verification from SSA if EIV information is disputed NOTE: Policies and Procedures need to be updated to outline what the implemented procedure is to ensure all tenants are treated uniformly

Obtain traditional 3 rd party verification of SSA Benefits if: NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Social Security Benefits • Tenant disagrees with information in EIV • The difference between the gross benefit and the net benefit cannot be explained by Medicare Part A or Part B payments • Tenant reports they are paying for Medicare Part D (prescription drug coverage)

• If tenant agrees with EIV; Gross benefit $702 x 12 = $8424 annual income NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Social Security Benefits

Medicare Data in EIV • Tenant may be paying for Medicare or may have Medicare premiums paid for by the state • EIV will not have information on Medicare Part D (prescription drug plan) • If tenant reports paying for Part D, additional verification (SS award letter) is required NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Social Security Benefits

Medicare Data in EIV: • Buy-In Indicator = Y • Buy-In Start has a date • Buy-In Stop date is Not Available Tenant is not paying for Medicare Part B NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Social Security Benefits

Medicare Data in EIV: • Buy-In Indicator = Y • Buy-In Start has a date • Buy-In Stop also has a date Tenant may or may not be paying for Medicare Part B NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Social Security Benefits

Medicare Data in EIV: • Buy–In Indicator = N • Buy-In Start and Stop dates = Not Available Tenant may be paying for Medicare Part B NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Social Security Benefits

• Gross benefit and net benefit are the same ($702) – tenant is not paying for Medicare NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Social Security Benefits

• Difference between Gross benefit and net benefit is $96. 50 – tenant is paying for Medicare NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Social Security Benefits

• Difference between Gross and Net is $131. 50; Medicare is $96. 40; further verification is needed NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report – Social Security Benefits

• Must review the Income Report at each AR, IR, and 90 days after MI 50059 as well as at other times as specified in Owner/Agent’s policies and procedures • Must print and retain the Income Report in tenant file for term of tenancy and 3 years after move-out • Must resolve possible instances of unreported or underreported income • Must maintain Income Report in file with all required supporting documentation NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report • Tenant agrees with EIV: Income Report, current acceptable tenant-provided documentation, and, if necessary third party verification • Tenant Disputes EIV: Income Report and third party verification of the disputed information • Income not able to be verified through the EIV System: Income Report, third party verification • Possible unreported/underreported income: file notes, contact with tenant, verifications, corrected/ additional 50059 s, repayment agreement etc…

Common Issues found during the MOR regarding the Income Report Include: 1. Not following up on possible unreported or underreported income 2. Not maintaining documentation of all follow up actions 3. Procedures not updated to include generating Income Report 90 days after MI 50059 submission NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Report

Income Discrepancy Report NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Discrepancy Report • EIV compares the income from the 50059 with income reported from NDNH and SSA • Income from sources such as child support, family contributions, and income from assets is not included in the comparison • An Income Discrepancy will be reported if the annual income in TRACS is different from the actual or annualized income in EIV by more than $2400 per year (higher or lower) for the period of income (POI) listed on the report

• Period of Income (POI) will be a 12 month period beginning 15 months prior to the effective date of the last 50059 in TRACS • The 50059 income is compared to: 1. The actual EIV reported income for the POI 2. The annualized amount from the last quarter of the POI • All discrepancies identified on the report must be investigated by the O/A to determine whether or not the discrepancy is valid NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Discrepancy Report

• Must print the Income Discrepancy Report every time the Income Report is printed even if there are no listed discrepancies NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Discrepancy Report

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Discrepancy Report

An Income Discrepancy Report be may be caused by: • Tenant did not report income • Tenant did not report a change in income of more than $200 per month (increase or decrease) • Owner/Agent made an error in calculation of annual income or in data entry on the 50059 • A false alarm – there really is no discrepancy NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Discrepancy Report

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Discrepancy Report Examples of Owner/Agent errors that may cause a discrepancy: • Tenant’s wages are paid every 2 weeks, but Owner/Agent multiplied wages by 52 instead of by 26 • Tenant has income from child support, but on the 50059 it is recorded as income from wages

Examples of a false alarm: • Tenant had their hours worked reduced shortly before certification • Tenant lost job or became employed shortly before certification NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Discrepancy Report

If a tenant has a discrepancy listed on the Income Discrepancy Report: 1. Within 30 days from the date of the report review and resolve the discrepancy • Determine if O/A error, tenant error (unreported/underreported), or false alarm • Review the file, verifications, and 50059(s) • Check for verification, miscalculation, or data entry errors • If necessary, send notice to tenant and discuss the possible discrepancy with them • If necessary, obtain 3 rd party verification - required if unreported/underreported income NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Discrepancy Report

• If Owner/Agent error: i. NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Discrepancy Report Process a corrected 50059 retroactive for all 50059 s affected by the error (MI, IR, GR, etc…) ii. Make the necessary voucher adjustments iii. For deceases due to O/A error, refund the tenant for over-payment in rent for the entire affected period iv. For increases due solely to O/A error (there was no unreported or underreported income by the tenant), the tenant can not be charged back rent

• If tenant error (unreported/underreported): i. NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Discrepancy Report Process a corrected 50059 retroactive for all 50059 s affected by the error (MI, IR, GR, etc…) • Must go back to point unreported/ underreported income began up to 5 years from the date of the 9887/9887 A ii. Send notice to the tenant iii. Require repayment of total overpayment in assistance for the affected period • Must allow tenant to enter into a repayment agreement if unable to pay in full

iv. If warranted, terminate tenancy, file civil action and notify HUD OIG Office of suspected fraud • If false alarm: i. Make clear and complete file notations fully describing why it is a false alarm and maintain all supporting documentation collected NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Discrepancy Report

2. Must maintain Income Discrepancy Report in the tenant file with documentation of all follow up action taken to resolve possible unreported or underreported income including file notes, contact with tenant, verifications, corrected/additional 50059 s, repayment agreement etc… NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Discrepancy Report

Common Issues found during the MOR regarding the Income Discrepancy Report Include: NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Income Discrepancy Report 1. Not printing and maintaining the report even no discrepancies are reported 2. Not maintaining documentation of all follow up actions 3. Procedures not updated to include printing and maintaining the report every time Income Report is printed include 90 days after MI 50059 submission

Property-Wide Reports North Tampa Housing Development Corporation

Identity Verification Reports North Tampa Housing Development Corporation

Identity Verification Report Identifies members that have discrepancies with personal identifiers (name, DOB, SNN) • Consists of 2 parts: • Failed EIV Prescreening Report • Failed Verification Report • MUST generate both reports monthly • Generate these reports by Contract Number and specified recertification month NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Identity Verification Report

• MUST select “All” when running this report for monthly requirements NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Identity Verification Report

• Click on each report individually to view/print each report • If 0 households listed for one or both of the reports, print this screen as your monthly report NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Identity Verification Report

Failed EIV Prescreening Report NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Failed EIV Prescreening Report • Identifies household members with invalid or missing SSN, Last Name, or Date of Birth in TRACS (information will not be sent to SSA from EIV) • EIV will not have any income data for any tenant listed on the Failed EIV Prescreening Report • Income report will state Income information cannot be displayed as the tenant identity has not been verified. • Most common error – SSN on 50059 is a temporary number

• Report will indicate what personal identifier did not pass the prescreening NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Failed EIV Prescreening Report

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Failed EIV Prescreening Report If a tenant is listed on Failed EIV Prescreening: 1. Within 30 days resolve the issue • Check information in tenant file against the info on the 50059 • Correct all 50059 data that was incorrectly entered and submit the corrected 50059 to TRACS • If necessary follow up with the tenant to confirm the personal identifier listed on the report and obtain additional info/documentation of the correct info • Correct all 50059 data that was incorrect and submit the corrected 50059

2. Notate on the report if corrections for a listed member has already been made and EIV data has not yet been updated 3. Notate on the report if a SSN is missing and the member is a verified exempt member (not required to provide SSN) 4. Maintain documentation of all follow up actions taken including file notes, contact with tenant, corrected 50059 NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Failed EIV Prescreening Report

• Must print and retain the report even if 0 results are found • Failed EIV Prescreening Report with notations of follow up action taken in the Master file for Failed EIV Prescreening Reports for 3 years from date of report • Corrected 50059 s and other documentation of follow up in the tenant file for term of tenancy plus 3 years NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Failed EIV Prescreening Report

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Failed EIV Prescreening Report Common Issues found during the MOR regarding the Failed EIV Prescreening Report Include: 1. Not selecting “All” as the recertification month when generating this report 2. Not printing and maintaining the report in a Master file even when 0 results found 3. Not notating the report with follow up actions 4. Procedures not properly updated with where to maintain the report and follow up documentation

Failed Verification Report NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Failed Verification Report • Identifies household members with SSN, Last Name, or Date of Birth that does not match the info reported by SSA for that member • EIV will not have any income data for any tenant listed on the Failed Verification Report • Income report will state Verification failed - Date of birth matched, but surname did not match with SSA records.

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Failed Verification Report • Report will indicate what personal identifier did not pass the verification with SSA records

If a tenant is listed on Failed Verification Report: 1. Within 30 days resolve the issue • Check information in tenant file against the info on the 50059 • If necessary follow up with the tenant to confirm the personal identifier listed on the report and obtain additional info/documentation of the correct info • Correct all 50059 data that was incorrect and submit the corrected 50059 • Encourage tenant to contact SSA to correct incorrect data from SSA NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Failed Verification Report

2. Notate on the report if corrections for a listed member has already been made and EIV data has not yet been updated 3. Maintain documentation of all follow up actions taken including file notes, contact with tenant, corrected 50059 NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Failed Verification Report

• NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Failed Verification Report Must print and retain the report even if 0 results are found • Failed Verification Report with notations of follow up action taken in the Master file for Failed EIV Prescreening Reports for 3 years from date of report • Corrected 50059 s and other documentation of follow up in the tenant file for term of tenancy plus 3 years

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Failed Verification Report Common Issues found during the MOR regarding the Failed Verification Report Include: 1. Not selecting “All” as the recertification month when generating this report 2. Not printing and maintaining the report in a Master file even when 0 results found 3. Not notating the report with follow up actions 4. Procedures not properly updated with where to maintain the report and follow up documentation

New Hires Report North Tampa Housing Development Corporation

New Hires Report NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Hires Report • Identifies tenants who have started a job in the last 6 months • MUST generate this report at least quarterly (or more frequently as outlined in the Owner/Agent’s EIV procedures) • There is not an individual tab on the left side of the EIV screen for the New Hires Report • Generate this report by generating the Income report by Contract Number and specified recertification month

Income Information “By Contract Number” • MUST select “All” when running this report for quarterly requirements NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Hires Report

• A summary of what was generated will appear • Click on New Hires Report and a list of the households on this report will appear • If 0 households listed for the New Hires Report, print this screen as your quarterly report NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Hires Report

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Hires Report • There is a Summary Report tab (shown) and Detail Report tab that will appear • Click on each name individually on the list on the Summary Report tab to get to the Summary, Income, and Income Discrepancy Report for that household

• Click on the Detail Report tab to receive the details of the new employment for each listed person (hire date, name of employer) NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Hires Report

If any tenants are listed on the New Hires Report: 1. Determine if tenant has reported the change 2. Contact the tenant and confirm the employment • If tenant confirms the info is correct: • Obtain check stubs, employer letter, or 3 rd party verification to calculate income • Process an IR 50059 if income is more than $200 per month • Retroactive effective date for unreported income • Require tenant to payback any overpayment • Allow repayment agreement if needed NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Hires Report

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Hires Report • If tenant disputes the info: • Obtain 3 rd party verification from the employer • If 3 rd party confirms there is in fact unreported income over $200 per month: • Process an IR 50059 • Retroactive effective date • Require tenant to payback any overpayment • Allow repayment agreement if needed

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Hires Report 3. Maintain documentation of all follow up actions taken including file notes, contact with tenant, verifications, IR 50059, repayment agreement… • Must print and retain report generated even if 0 results are found • Summary Report tab for New Hires Report with notations of follow up action taken in the Master file for New Hires Reports for 3 years from date of report • Detail Report tab for New Hires Report in the tenant file with the follow up documentation for term of tenancy plus 3 years

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION New Hires Report Common Issues found during the MOR regarding the New Hires Report Include: 1. Not selecting “All” as the recertification month when generating this report 2. Not printing and maintaining the report in a Master file even when 0 results found 3. Not maintaining documentation of all follow up actions 4. Procedures not properly updated with when to run the report, how to review the report, and where to maintain the report and follow up documentation

Multiple Subsidy Report North Tampa Housing Development Corporation

Multiple Subsidy Report NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Multiple Subsidy Report • Identifies tenants who may be receiving assistance at another property • MUST generate this report at least quarterly (or more frequently as outlined in the Owner/Agent’s EIV procedures) • Generate this report by Contract Number • Must be run twice each time report is generated • Once to search Multi Family (MF) properties • Once to search Public and Indian Housing (PIH) properties

• Select all household members when running this report for quarterly requirements NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Multiple Subsidy Report

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Multiple Subsidy Report

• When there are members receiving multiple subsidy, a summary report and detail report will also generate NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Multiple Subsidy Report

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Multiple Subsidy Report

If any tenants are listed on the Multiple Subsidy Report: 1. Discuss the result with the tenant 2. Contact the manager at the other property to verify tenant is receiving assistance there 3. Owner/Agents at both properties must determine at which property subsidy should be terminated 4. Maintain documentation of all follow up actions taken including file notes, contact with tenant and other property, and termination of assistance (if applicable) NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Multiple Subsidy Report

• Must print and retain both of the reports generated even if 0 results are found • Summary Report tab for Multiple Subsidy Report with notations of follow up action taken in the Master file for Multiple Subsidy Reports for 3 years from date of report • Detail Report tab for Multiple Subsidy Report in the tenant file with the follow up documentation for term of tenancy plus 3 years NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Multiple Subsidy Report

Common Issues found during the MOR regarding the Multiple Subsidy Report Include: NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Multiple Subsidy Report 1. Not printing and maintaining the report in a Master file even when 0 results found 2. Not maintaining documentation of all follow up actions 3. Procedures not properly updated with when to run the report, how to review the report, and where to maintain the report and follow up documentation

Deceased Tenant Report North Tampa Housing Development Corporation

Deceased Tenant Report • Identifies tenants who may be deceased at your property (reported as deceased by SSA) • MUST generate this report at least quarterly (or more frequently as outlined in the Owner/Agent’s EIV procedures) • Generate this report by Contract Number and specified recertification month NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Deceased Tenant Report

• MUST select “All” when running this report for quarterly requirements NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Deceased Tenant Report

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Deceased Tenant Report

• When there are members listed on the report as deceased, an additional list will appear listing personal identifiers of the member and the date they are reported as becoming deceased NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Deceased Tenant Report

If any tenants are listed on the Deceased Tenant Report: NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Deceased Tenant Report 1. Confirm in writing the member is deceased • HOH, next of kin, emergency contact etc… 2. Within 30 days resolve the issue • If member is deceased, process a: • MO 50059 for single household • IR 50059 to remove the deceased member • If member is not deceased: • Correct any incorrect data in TRACS • Encourage tenant to contact SSA to correct incorrect data from SSA

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Deceased Tenant Report 3. Maintain documentation of all follow up actions taken including file notes, contact with HOH, next of kin emergency contact, etc. . and IR or MO 50059 • Must print and retain the report even if 0 results are found • Deceased Tenant Report with notations of follow up action taken in the Master file for Deceased Tenant Reports for 3 years from date of report • 50059 s other documentation of follow up in the tenant file for term of tenancy plus 3 years

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Deceased Tenant Report Common Issues found during the MOR regarding the Deceased Tenant Report Include: 1. Not selecting “All” as the recertification month when generating this report 2. Not printing and maintaining the report in a Master file even when 0 results found 3. Not maintaining documentation of all follow up actions 4. Procedures not properly updated with when to run the report, how to review the report, and where to maintain the report and follow up documentation

No Income Report North Tampa Housing Development Corporation

No Income Report • HUD Recommends Owner/Agents have a policy to re-verify the status of tenants reporting zero income at least quarterly • This report will identify tenants with no reported income in EIV • Owner/Agents must use this report only as identified and described in their policies and procedures • As part of procedures for using this report, Owner/ Agent must include using Income Report to determine if there is income NORTH TAMPA HOUSING DEVELOPMENT CORPORATION No Income Report

• There is not an individual tab on the left side of the EIV screen for the No Income Report • Generate this report by generating the Income Information by Contract Number and specified recertification month of “All” NORTH TAMPA HOUSING DEVELOPMENT CORPORATION No Income Report

• If there are households listed for this report, the report will be in red and underlined • Click on No Income Report and a list of the households on this report will appear NORTH TAMPA HOUSING DEVELOPMENT CORPORATION No Income Report

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION No Income Report Common Issues found during the MOR regarding the No Income Report Include: 1. Not using this report as outlined in the policies and procedures 2. Procedures not properly updated with when to run the report, how to review the report, and where to maintain the report and follow up documentation

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Questions? ? ?

LCS Conducting the MOR Will Review: • Owner/Agent Access to EIV • EIV Forms and Documents • EIV Policies and Procedures • Tenant Selection Plan • Tenant Files • EIV Income and Verification Reports and All Discrepancy Follow Up Documentation • Secured Environment of EIV Data NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will Be Reviewed During MOR

Owner/Agent Access to EIV • Has the Owner/Agent established access • Who has access to EIV • Who are the Users • Who is the Coordinator • Who is not a User or Coordinator but has access to the EIV data NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will Be Reviewed During MOR

EIV Forms and Documents *IMPORTANT NOTE: EIV Forms must be available for review during the MOR. If one or more forms are not available for review during the MOR, HUD must be notified and EIV access will be terminated until the required forms are provided* NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will Be Reviewed During MOR

EIV Forms and Documents • Owner Approval Letter(s) • CAAF(s)- Coordinator Access Authorization Form • Initial hardcopy Approved (HUD signed) CAAF • Current CAAF * IMPORTANT NOTE: Must have the initial approved (HUD signed) CAAF. Any Coordinator that does not have the original HUD signed approved CAAF form needs to contact the EIV helpdesk and request a copy of it regardless of when the initial form was approved. * NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will Be Reviewed During MOR

• UAAF(s)-User Access Authorization Form • Initial hardcopy Approved (signed) UAAF • Current form • Rules Of Behavior Forms NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will Be Reviewed During MOR • For all individuals without access to the EIV system but access to the EIV data. This includes service bureaus and IPA’s. * Important Note: Owner/Agents do not obtain a Rules of Behavior Form from MOR reviewers. PBCA’s were required to have their employees sign this form and are responsible for maintaining it.

EIV Policies and Procedures Written Procedures must include: NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will Be Reviewed During MOR • How to use EIV employment and income data and EIV verification reports at the time of each AR and IR, and within 90 days after MI 50059 is submitted • Running reports; following up on discrepancies; how/where to maintain the data • How and when to use each of the Income Reports and each of the Verification Reports • Running reports; following up on discrepancies; how/where to maintain the data • The frequency for each report must be outlined • (Monthly, Quarterly etc…) • Notification requirements and timeframes for members who turn 18 to sign the 9887/9887 A

• Security Procedures that will maintain safeguards designed to prevent unauthorized use of the EIV information and protect the confidentiality of that information • Information on Security can be found at: • EIV System Security Measures posted at: http: //www. hud. gov/offices/hsg/mfh//rhiip/eiv/security. cfm • Section XII of HUD Notice H 2010 -10 posted at: http: //portal. hud. gov/portal/page/portal/HUD/program_offi ces/administration/hudclips/notices/hsg NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR

• Policies and procedures must be established to govern the use of the EIV system. These procedures should address: (1) Authorized use of the EIV system; (2) How to handle security breaches; and (3) Destruction of EIV data NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR Security Training must be provided annually and documentation of this training must made available for auditing purposes • Looking for a file/log with the Names, Dates, and type of training that was provided

Tenant Selection Plan • Must be updated to include: • Use of the EIV Existing Tenant Search as a part of the applicant screening process NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR

Tenant Files • 9887/9887 A for each adult household member • EIV and You Brochure during screening process and at each AR • Summary, Income, and Discrepancy Reports for each AR, IR, and 90 days after MI submission • Documentation of follow up on all unreported/ underreported income and supporting documentation of all discrepancy resolutions • Documentation of termination and/or steps taken for fraud NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR

EIV Income and Verification Reports & All Discrepancy Follow Up Documentation NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR • LCS will be looking to ensure that each of the EIV Income Reports and Verification Reports available in EIV are being generated at the required times, printed, reviewed, discrepancies followed up on and resolved, and documentation maintained in accordance with both HUD regulations and Owner/Agent established written procedures.

• Summary; Income; and Discrepancy Reports • Required to be printed, reviewed, followed up on, and maintained for each AR and IR; within 90 days after submission of MI 50059; and at times other than recertification if so outlined in the policies and procedures • Looking for: • Documentation they are printed, reviewed, and followed up on at the frequency outlined in the policies and procedures • Reports and all follow up documentation to be maintained in tenant files for term of tenancy and 3 years after MO NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR

Follow up documentation (if discrepancy and/or unreported/underreported income is found) includes: • Notice to the tenant and all related correspondence • 3 rd party verifications • Additional tenant provided documents • File notes • Documentation of resolution even if there is no discrepancy or unreported/underreported income • Corrected 50059 s and/or additional retroactive 50059 as necessary • Documentation of tenant repayment or copy of repayment agreement • Voucher adjustments • Additional file notes NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR

No Income Report NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR • Required to be reviewed and followed up on as outlined in the owner/agent policies and procedures (HUD recommends using this report quarterly for all no income tenants) • Looking for: • Documentation they are reviewed and followed up on at the frequency outlined in the policies and procedures by having applicable follow up documentation maintained in tenant files for term of tenancy and 3 years after MO

New Hire; Multiple Subsidy; and Deceased Tenant Reports NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR • Required to be printed, reviewed, and followed up on no less than quarterly • Looking for: • Documentation they are printed, reviewed, and followed up on at the frequency outlined in the policies and procedures • Summary Reports to be maintained in a Master file for 3 years • Detail Reports and all follow up documentation to be maintained in tenant files for term of tenancy and 3 years after MO

Identity Reports (Failed EIV Pre-screening & Failed Verification Reports) NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR • Required to be printed, reviewed, and followed up on Monthly • Looking for: • Documentation they are printed, reviewed, and followed up on Monthly • Reports to be maintained in a Master file for 3 years • All follow up documentation to be maintained in tenant files for term of tenancy and 3 years after MO

Existing Tenant Search Report • Required to be printed, reviewed, and followed up on for each household member during the application process • Looking for: • Documentation they are printed, reviewed, and followed up on prior to move-in • Reports and all follow up documentation to be maintained in tenant files for term of tenancy and 3 years after MO; or with the application for 3 years after removal from waiting list NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR

Secured Environment of EIV Data Looking for: • File storage area to see if the area is secure with access limited to only authorized staff • Do filing cabinets lock • Does door to filing area lock • Who has keys • Evidence that security procedures, retention policies, and disposal methods followed consistently • How EIV reports are generated/printed and how/where they are maintained NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR

• Who is accessing EIV system and from where • Are staff sharing access IDs and passwords • Is EIV data being shared with other entities not authorized to view EIV data (e. g. , state officials monitoring tax credit projects, Rural Housing staff monitoring Section 515 projects, or Service Coordinators) NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR NOTE: Disclosure of EIV data to Service Coordinators even though the tenant signs a release of information consent form authorizing them to have access to their file is not allowed unless the Service Coordinator is present during the interview and assisting the tenant with the recertification process.

Preparing for your MOR NORTH TAMPA HOUSING DEVELOPMENT CORPORATION What Will be Reviewed During MOR EIV is now mandatory so all Owner/Agents should already have access in EIV for each property with current approved coordinators and users; be using EIV in its entirety (using all of the EIV reports); have written procedures in place; and should have provided training for staff on how to use EIV and maintain the security of the data. If you have not done or more of these items, take the necessary steps to do so immediately prior to your next MOR.

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Possible EIV Findings 1. O/A does not have access to EIV 2. O/A is not using EIV for recertification 3. Missing/incomplete EIV documents as listed on the Addendum C. (must also email HUD Headquarters immediately to terminate the coordinator’s/ user’s access) 4. Rules of Behavior for non-system users missing where applicable 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 6. EIV data not kept secure 7. O/A has not updated Policies and Procedures to include EIV use

8. O/A has not updated Tenant Selection Plan to include of Existing Tenant Report 9. EIV Income Reports are not in tenant files 10. Tenant files that do not have documentation to support EIV discrepancy resolution 11. Not Using the Existing Tenant Search Report 12. Not reviewing New Hires Report 13. Unresolved Failed Verification and Pre-screening Discrepancies 14. Deceased Tenant Report has not been reviewed and/or errors corrected 15. Multiple Subsidy Report has not been reviewed and/or errors corrected NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Possible EIV Findings

NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Possible EIV Findings 16. O/A is not following HUD’s record retention requirements 17. Missing/Incomplete form HUD-9887 18. O/A is not providing tenants with the EIV & You brochure when selected from the waiting list for move in and at AR 19. Not completing Annual Security Awareness Training 20. O/A is sharing access IDs and passwords

If during an MOR it is determined Owner/ Agent: NORTH TAMPA HOUSING DEVELOPMENT CORPORATION Penalties For Not Using EIV • Does not have access to EIV or is not using EIV • Did not submit its CAAF to the Multifamily Help Desk by December 15, 2009; and/or • Did not complete the property assignment process by January 15, 2010 • A 5% voucher penalty will be required • Owner/Agent must make an adjustment on its next scheduled voucher to adjust for the 5% decrease • NTHDC must monitor the Owner/Agent to ensure the adjustment is made

EIV HUD NOTICE: H 2010 -10 Issued 7/1/2010 is available at: http: //portal. hud. gov/portal/page/portal/HUD/program_offices/adm inistration/hudclips/notices/hsg December 2009 HUD EIV webcast 12/29/2009 is available at: http: //portal. hud. gov/portal/page/portal/HUD/webcasts/archives/m ultifamily EIV: Instructional Course for Multifamily Housing Programs, February 25, 2010 is available at: http: //portal. hud. gov/portal/page/portal/HUD/webcasts/archives/m ultifamily EIV User Manual for Multifamily Housing Program Users is available at: http: //www. hud. gov/offices/hsg/mfh/rhiip/eiv/usermanual. pdf NORTH TAMPA HOUSING DEVELOPMENT CORPORATION EIV Guidance

Multifamily Housing EIV web site: http: //www. hud. gov/offices/hsg/mfh//rhiip/eivhome. cfm EIV Multifamily Help Desk Telephone: 202 -708 -7588 Email: Mf_Eiv@hud. gov Questions should be sent via email to: mf_eiv_comments@hud. gov Resolving Income Discrepancies Between Enterprise Income Verification (EIV) System Data and Tenant-Provided Income Information” http: //www. hud. gov/offices/hsg/mfh/rhiip/eiv/reqnguide. cfm NORTH TAMPA HOUSING DEVELOPMENT CORPORATION EIV Guidance

Rent and Income Determination Quality Control Monitoring Guide for Multifamily Housing Programs http: //www. hud. gov/offices/hsg/mfh/rhiip/qcguide. pdf EIV & and You Brochure HUD NOTICE: H 2010 -02 Issued 1/11/2010 is available at: http: //portal. hud. gov/portal/page/portal/HUD/program_offices/admi nistration/hudclips/notices/hsg New EIV & You Brochure is available at: http: //www. hud. gov/offices/hsg/mfh/rhiip/eivbrochure. pdf New Rules of Behavior Acknowledgement form is available at: http: //www. hud. gov/offices/hsg/mfh/rhiip/eiv/rulesofbehavior. pdf NORTH TAMPA HOUSING DEVELOPMENT CORPORATION EIV Guidance

Tenants who need to request a current Award Letter may request a new letter from SSA by calling 1 -800 -772 -1213 (TTY 1 -800 -325 -0778) or by requesting it over the internet at: https: //secure. ssa. gov/apps 6 z/isss/main. html. NOTE: On 4/14/2010 HUD conducted a webcast regarding the implementation of the Final Rule and also released a Notice regarding implementation EIV HUD NOTICE: H 2010 -08 dated 4/13/2010 is available at: http: //portal. hud. gov/portal/page/portal/HUD/program_offic es/administration/hudclips/notices/hsg And this webcast is available at: http: //portal. hud. gov/portal/page/portal/HUD/ webcasts/archives/multifamily NORTH TAMPA HOUSING DEVELOPMENT CORPORATION EIV Guidance