Taking New Clients
TRACS software changes
EIV Coordinator
- MEMO EIV Coordinator
- Approval Letter
- Coordinator Access Authorization from Owner
- HUD NOTICE EIV 09-20
- EIV User Manual 09 2009
- EIV Update Memo Final
- EIV - Quick Start Final - 7 2008
EIV MANDATORY
New EIV Housing Notice
On December 7, 2009, HUD released HUD Notice 09-20 – the Enterprise
Income Verification System. You can find the notice on HUD's web site
at http://portal.hud.gov/portal/page/portal/HUD/program_offices/administration/
hudclips/notices/hsg
The purpose of the Notice is to provide updated instruction about EIV to owners and agents (OAs) of the following programs.
A. Project-based Section 81. New Construction
2. State Agency Financed
3. Substantial Rehabilitation
4. Section 202/8
5. Rural Housing Services (RHS) Section 515/8
6. Loan Management Set-Aside (LMSA)
7. Property Disposition Set-Aside (PDSA)
B. Section 101 Rent Supplement
C. Section 202/162 Project Assistance Contract (PAC)
D. Section 202 Project Rental Assistance Contract (PRAC)
E. Section 811 PRAC
F. Section 236
G. Section 236 Rental Assistance Payments (RAP)
H. Section 221(d)(3) Below Market Interest Rate (BMIR)
NOTE:
This Notice does not apply to the Low Income Housing Tax Credit
(LIHTC) program for O/A's completion of the LIHTC certification or for LIHTC compliance monitoring by state officials. It also does not apply to the RHS Section 515 program for certification of tenants who do not receive Section 8 assistance or for compliance monitoring by RHS staff for tenants receiving Section 8 assistance.
Written Policies
In addition to providing a synopsis on how resident data is obtained,
the Notice clarifies some OA requirements regarding written policies.
O/As using EIV must have written policies and procedures for using the
EIV employment and income data and EIV verification reports at the time
of recertification. In addition, O/As who elect to use any of the reports
at times other than at recertification, e.g., the Income Discrepancy Report
and/or the New Hires Report, must also include in their policies and procedures
information for staff to follow for using the reports and data.
(Note from RBD: We have created a CD that contains samples of such policies
with supporting resident notices. The CD is now being updated to incorporate
changes included in this notice and changes described in the EIV Training
webcast.)
O/As, who have incorporated the EIV Existing Tenant Search as part of
their applicant screening, must include a description of how the report
is used in the Resident Selection Plan.
Note from RBD: We have provided sample verbiage to help you get an idea
of the language you might use to describe use of the Existing Tenant Report:
All Applicants MUST disclose if they are currently receiving HUD housing assistance. The owner/agent will not knowingly assist applicants who will maintain a residence in addition to the HUD-assisted unit or who attempt to receive HUD assistance in two separate residences.
HUD provides the owner/agent with information about an applicant's current status as a HUD housing assistance recipient. The owner/agent will use the Enterprise Income Verification System (EIV) to determine if the applicant or any member of the applicant household is currently receiving HUD assistance.
Nothing prohibits a HUD housing assistance recipient from applying to this property. However, the applicant must move out of the current property and/or forfeit any voucher before HUD assistance on this property will begin. Special consideration applies to
1) Minor children where both parents share 50% custody
2) Recipients of HUD assistance in another unit who are moving to establish a new household when other family/household members will remain in the original unit
If the applicant or any member of the applicant household fails to fully and accurately disclose rental history, the application may be denied based on the applicant's “misrepresentation” of information.
This information will be reviewed on an annual basis, at each annual certification. If any household member receives or attempts to receive assistance in another HUD assisted unit while receiving assistance on this property, the household member will be required to reimburse HUD for assistance paid in error. This is considered a material lease violation and may result in penalties up to and including eviction and pursuit of fraud charges.
Using EIV Reports
The EIV notice provides a lot of information regarding the various reports
available in EIV. Information in the Notice includes when OAs should run
certain reports and information about the data represented in certain
reports. Samples are included in the notice.
Please be sure to note when HUD instruction indicates that OAs must use certain reports and when OAs should use certain reports.
Repayment Agreements
The Notice contains a lot of new information regarding unreported income
and how to handle the return of “assistance paid in error”.
New information includes but is not limited to:
How correction certifications should be submitted
How to calculate repayment amounts for repayment agreements (while the
notice suggests that repayment should not exceed 10% of adjusted income,
HUD clarifies, in the webcast, that the repayment can be higher if the
resident agrees)
Information about verbiage that must be included in repayment agreements
Instruction about how to reverse voucher adjustments and how to apply
repayment amounts
How to recoup expenses incurred while trying to reconcile the affects
of unreported income
While the Notice is pretty long (49 pages), it is a “must read!”
Some of the instruction drives changes to current EIV Use and Security
Policies.
EIV Implementation Deadline
Please note that HUD has released several RHIIP ListServs reminding you
that the EIV implementation deadline is January 31, 2010.
In order to meet the deadline for using EIV and to avoid penalties relating to non-compliance with the Rent Refinement Final Rule, owners and management agents who do not have access to EIV must act now.
The EIV and You Brochure
On January 11, HUD released HUD Notice 10-02 Enterprise Income Verification
(EIV) & You Brochure - Requirements for Distribution and Use which
can be found at http://portal.hud.gov/portal/page/portal/HUD/program_offices/administration/
hudclips/notices/hsg/files/10-02hsgn.doc .
This notice provides instruction for owner/agents using the EIV system. It states that owner/agents must provide each resident household with the EIV & You brochure at the time of annual recertification along with a copy of the HUD Fact Sheet “How Your Rent is Determined”.
Owner/agents must also provide applicant households who have been selected from the waiting list for screening and final application processing with a copy of the EIV & You brochure.
Owner/agents can order the EIV & You brochure for English speaking households from the online HUD Direct Distribution Center at http://www.hud.gov/offices/adm/dds/index.cfm or by telephone at (800) 767-7468 (800) 767-7468 .
Quantities ordered should be sufficient to cover distribution to existing residents and applicants who may participate in the final eligibility interview over the next twelve months. The brochure is also available for download at the Multifamily RHIIP website at http://hud.gov/offices/hsg/mfh/rhiip/mfhrhiip.cfm .
The brochure will be translated into thirteen languages for distribution to non-English speaking households. Translated versions of the brochure for non-English speaking households will be posted to the Multifamily RHIIP website once the translations are completed. These versions will not be available for order through the HUD Direct Distribution Center.
Benefits Of Implementation
Residents and applicants selected for final screening and application
processing have a right to know that an owner/agent has access to a system
containing personal and financial information about them.
If HUD expectations are met, the following benefits will be achieved:
If residents accurately report their income then the right amount of
rental assistance will be paid on their behalf, thus allowing more families
to receive the rental assistance they need.
The administrative workload on O/As will be significantly reduced because
they will not have to set up repayment agreements with tenants to recover
rental assistance that was inappropriately paid on their behalf and
discovered through use of the EIV system.
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.
The potential for fraud, waste and abuse in HUD's rental assistance
programs will be diminished.
The notice does not establish an implementation deadline so we suggest
that owner/agents who currently use EIV implement this new requirement
as quickly as possible. Obviously, the EIV implementation deadline is
January 31, 2010, and all EIV policies and procedures should be in place
at that time.
No Social Security Cost-of-Living Adjustment (COLA) for 2010
On October 15, the Social Security Administration released information
about the Cost-of-Living Adjustment for 2010. 2010 will be the first
year without an automatic COLA increase since 1975. You can print the
COLA Fact Sheet by accessing the Social Security Administration web
site at http://www.ssa.gov/pressoffice/factsheets/colafacts2010.htm.
For additional information about the 2010 COLA, go to http://www.socialsecurity.gov/cola/
Most people will continue to pay the 2009 Part B premium of $96.40
in 2010. The law contains a “hold harmless” provision that
protects about 93 percent of Social Security beneficiaries from paying
a higher Part B premium, in order to avoid reducing their net Social
Security benefit. Those not protected include higher income beneficiaries
subject to an income-adjusted Part B premium and beneficiaries newly
entitled to Part B in 2010.
With the new 202C some questions need to be addressed.
Question: I have a rent change effective 4/8/09 will it still be able to be put on the May HAP?
No. The new 202C Compliance regulations have restricted which voucher month can be effected by tenant changes refer to Appendix H Calculation Guidance section 8 http://www.hud.gov/offices/ hsg/mfh/trx/pdf/appdxh.pdf to see the chart and explanation on this issue.
Question: I had a move in 3/07/2009 and did not see them on my April HAP and was wondering why?
Refer to previous answer.
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