HUD Housing Notice § 2010-10
Enterprise Income Verification (EIV) System (HUD Housing Notices)
HUD guidance — not codified law
In Force
Verified 10/6/2026 · Next check 10/13/2026
effective 10/6/2026FederalAffordable Housing ProgramsOperative Text
HUD Housing Notice § 2010-10
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Special Attention of: NOTICE: H 2010-10
Multifamily Hub Directors Issued: July 1, 2010
Multifamily Program Center Directors
Rural Housing Services (RHS) Directors
Supervisory Housing Project Managers Expires: June 30, 2011
Housing Project Managers
Contract Administrators Cross References: 24 CFR §5.233;
Multifamily Owners and Management Agents §5.236; §5.659
Supersedes Notices H 2008-03 and
H 2009-20
SUBJECT: Enterprise Income Verification (EIV) System
CONTENTS
I. PURPOSE .......................................................................................................................... 4
II. APPLICABILITY ............................................................................................................. 4
III. BACKGROUND ............................................................................................................... 5
IV. EMPLOYMENT AND INCOME DATA AVAILABLE IN EIV ................................. 6
A. Social Security Administration ..................................................................................... 6
B. National Directory of New Hires (NDNH) ................................................................... 6
V. SCHEDULE FOR EIV DATA UPDATES ..................................................................... 6
A. Tenant Rental Assistance Certification Subsystem (TRACS) File............................... 6
B. Social Security Benefits Match ..................................................................................... 6
C. NDNH (New Hires (W-4), Wage and Unemployment Compensation) Match ............ 8
VI. REQUIREMENTS FOR USING EIV DATA ................................................................ 9
A. Updating O/A Requirements......................................................................................... 9
1. Tenant Selection Plan ............................................................................................. 9
2. Policies and Procedures .......................................................................................... 9
B. Consent for the Release of Information ........................................................................ 9
1. Applicants ............................................................................................................... 9
2. Tenants .................................................................................................................... 9
C. Consent to Disclose an Individual’s Information to Another Person or Entity .......... 10
D. Tenant Notification of Recertification ........................................................................ 11
E. Tenant Does Not Provide Requested Information or Information Not Acceptable .... 12
F. Independent Third Party Verification ......................................................................... 12
G. EIV Income Incorrect or Does Not Belong to the Tenant .......................................... 13
VII. USING EIV REPORTS .................................................................................................. 15
A. Income Reports ........................................................................................................... 16
1. Summary Report ................................................................................................... 16
2. Income Report ....................................................................................................... 18
a. Components of the Income Report ................................................................. 18
b. Required Documentation to Demonstrate EIV Compliance ........................... 19
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c. NDNH (New Hires (W-4), Wage and Unemployment Compensation) ......... 19
d. Social Security Benefits .................................................................................. 21
e. New Admissions ............................................................................................. 25
f. Applicants ....................................................................................................... 25
3. Income Discrepancy Report .................................................................................. 25
B. Other EIV Reports ...................................................................................................... 29
1. Additional Income Reports ................................................................................... 30
a. No Income Report ........................................................................................... 30
b. New Hires Report ........................................................................................... 30
2. Verification Reports .............................................................................................. 31
a. Existing Tenant Search ................................................................................... 32
b. Multiple Subsidy Report ................................................................................. 32
c. Identity Verification Reports .......................................................................... 34
d. Deceased Tenants Report ................................................................................ 36
VIII. SYSTEMATIC ALIEN VERIFICATION FOR ENTITLEMENTS (SAVE)
SYSTEM ACCESS ......................................................................................................... 38
IX. INVESTIGATING AND RESOLVING INCOME DISCREPANCIES .................... 38
A. Investigating Discrepancies ........................................................................................ 38
B. Unreported or Underreported Income ......................................................................... 39
C. Tenant Repayment of Unreported or Underreported Income ..................................... 39
1. Tenant’s Obligation to Reimburse ........................................................................ 39
2. Repayment Options ............................................................................................... 40
3. Repayment Agreements ........................................................................................ 40
4. Disposition of Funds Received by O/A ................................................................ 42
D. Over-reported Income ................................................................................................. 45
E. Errors Discovered During a Monitoring Review ........................................................ 45
X. RETENTION OF EIV REPORTS ................................................................................ 46
XI. PENALTIES FOR FAILURE TO HAVE ACCESS TO AND/OR USE EIV ........... 46
XII. SECURITY OF EIV DATA ........................................................................................... 47
A. Official Purpose Includes ............................................................................................ 47
B. Official Purpose Does NOT Include ........................................................................... 48
C. Disclosure to Persons Assisting Tenants with the Recertification Process ................ 49
D. Penalties for Willful Disclosure or Inspection of EIV Data ....................................... 50
E. Rules of Behavior (ROB)............................................................................................ 50
F. Security Training ........................................................................................................ 51
G. Safeguarding EIV Data ............................................................................................... 51
1. Technical Safeguarding of Data............................................................................ 51
2. Administrative Safeguards .................................................................................... 52
3. Physical Safeguards .............................................................................................. 52
XIII. TOOLS AND RESOURCES .......................................................................................... 53
XIV. PAPERWORK REDUCTION....................................................................................... 54
Attachment 1: Failed EIV Pre-screening Report Error Messages ........................................ 56
Attachment 2: Failed Verification Report (Failed the SSA Identity Test) Error
Messages........................................................................................................................... 57
Attachment 3: National Directory of New Hires (NDNH) Data Elements ........................... 59
Attachment 4: How EIV Calculates Income Discrepancies ................................................... 61
Attachment 5: Using EIV Data Flow Chart ............................................................................ 65
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Attachment 6: Use of EIV Reports ........................................................................................... 66
Attachment 7: EIV Income Report Information .................................................................... 75
Attachment 8: MOR Findings for EIV Compliance (List is not all inclusive) ..................... 76
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I. PURPOSE
The purpose of this Notice is to provide updated instructions for using EIV now that
use of the EIV system by Owners and Management Agents (O/As) is mandatory.
Effective January 31, 2010, O/As must use HUD’s EIV system in its entirety:
As a third party source to verify tenant employment and income information
during mandatory recertifications of family composition and income, in
accordance with §5.236, and administrative guidance issued by HUD; and
To reduce administrative and subsidy payment errors in accordance with HUD
administrative guidance. (24 CFR §5.233)
In addition to the mandatory use by O/As, EIV must also be used by Contract
Administrators (CAs) (Performance Based Contract Administrators (PBCAs),
Traditional Contract Administrators (TCAs) and HUD staff) for monitoring the O/A’s
compliance with obtaining access to and using the EIV system; and, EIV may be used
by independent public auditors (IPAs) auditing an owner’s compliance with verifying
income and the accuracy of rent/subsidy determinations; and, the Office of Inspector
General (IG) for auditing purposes. See Section XII, Security of EIV Data, for more
information on official use of EIV data.
Using the data in EIV will 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 Barack Obama on November 20, 2009.
II. APPLICABILITY
This notice applies to the following programs:
A. Project-based Section 8
1. 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)
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NOTE: This Notice does not apply to the Low Income Housing Tax Credit
(LIHTC) program for the O/A’s completion of the LIHTC Tenant Income
Certification (TIC) 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. See Section XII, Security of EIV Data, for
information on why this Notice is not applicable to these programs.
III. BACKGROUND
In 2001, OMB released the President’s Management Agenda which established the
reduction of erroneous payments as a key government-wide priority, evidenced by the
Eliminating Improper Payments initiative, which requires agencies to measure
improper payments annually, develop improvement targets and corrective actions,
and track results. At that time, HUD established the RHIIP initiative to address the
causes of errors and improper payments in HUD’s assisted housing programs and to
ensure that the right benefits go to the right persons.
What is an improper payment?
An improper payment is any payment that should not have been made or that was
made in an incorrect amount under statutory, contractual, administrative, or other
legally applicable requirements. Incorrect amounts are overpayments and
underpayments (including inappropriate denials of payment or service). An
improper payment includes any payment that was made to an ineligible recipient
or for an ineligible service, duplicate payments, payments for services not
received, and payments that are for the incorrect amount. In addition, when an
agency’s review is unable to discern whether a payment was proper as a result of
insufficient or lack of documentation, this payment must also be considered an
error.
To assist in meeting the RHIIP initiative goals, HUD developed and began
implementation of the Upfront Income Verification (UIV) system, now known as the
EIV system. The UIV system was originally only available to PHAs and provided
them with income information on wages and unemployment benefits provided
through matching agreements with individual states.
In 2004, HUD received statutory authority to negotiate a matching agreement with
the Department of Health and Human Services (HHS) to conduct computer matching
with National Directory of New Hires (NDNH) data. While the first matching
agreement between HUD and HHS only made the NDNH data available to PHAs, a
subsequent agreement was reached in FY 2007 making the information available to
Multifamily Housing’s O/As, CAs and the IG. HHS later approved disclosure of
NDNH information to IPAs (see Section XII, Security of EIV Data, for restrictions on
disclosure of NDNH information to IPAs). In addition to the NDNH data, the data
received from the Social Security Administration (SSA), formerly available for use
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by O/As through the Tenant Assessment Subsystem (TASS), was also made available
through the EIV system.
On December 29, 2009, the Refinement of Income and Rent Determination
Requirements in Public and Assisted Housing Programs: Implementation of the
Enterprise Income Verification System – Amendments; Final Rule was published in
the Federal Register, making use of the entire EIV system mandatory by PHAs and
O/As, effective January 31, 2010.
IV. EMPLOYMENT AND INCOME DATA AVAILABLE IN EIV
A. Social Security Administration
1. Social Security (SS) benefits
2. Supplemental Security Income (SSI) benefits
3. Dual Entitlement benefits
4. Medicare premium information
5. Disability status
B. National Directory of New Hires (NDNH)
1. New hires (W-4)
2. Quarterly wages for federal and non-federal employees
3. Quarterly unemployment compensation benefits
V. SCHEDULE FOR EIV DATA UPDATES
A. Tenant Rental Assistance Certification Subsystem (TRACS) File
Tenant information in EIV is data from the current, active form HUD-50059,
Owner’s Certification of Compliance with HUD’s Tenant Eligibility and Rent
Procedures, in TRACS.
A file consisting of tenant information from these active certifications is provided
to EIV each morning and the data is uploaded into the EIV system the following
evening. Therefore, there is a time lag of one day between the tenant data in
TRACS being uploaded into the EIV system.
Household members coded as a live-in aide in TRACS are excluded from the
TRACS file since their income is excluded from annual income. (See Chapter 5,
Figure 5-2 and Exhibit 5-1 of Handbook 4350.3 REV-1, Occupancy Requirements
of Subsidized Multifamily Housing Programs).
B. Social Security Benefits Match
1. A quarterly match is conducted against SSA records for tenants who pass the
SSA identity test to obtain SSA benefits, Medicare premium and disability
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status information. (See Section VII.B.2.c for information on the SSA
Identity Test.)
a. Each quarter the entire tenant population is matched with SSA. Each
month during a quarter, a group of tenants are matched based on their next
recertification month.
b. The SSA match process begins at the beginning of each month with all of
the data being loaded into EIV by the second week of the month.
c. Records that are new or that have been significantly updated are matched
in the next monthly SSA matching cycle.
d. EIV retains the last eight actions processed by SSA for a tenant.
2. The following chart shows when TRACS tenant data is submitted to SSA by
recertification month and when the data is refreshed in EIV.
Group Recertification Month Month Data Is Refreshed in EIV
I April, May, June, July January, April, July, October
II August, September, October, November February, May, August, November
III December, January, February, March March, June, September, December
For example, the SSA data for tenants with a recertification month of April,
May, June or July is refreshed in EIV in January, April, July and October.
3. The SSA cost of living adjustments (COLAs) are not available from SSA for
uploading into EIV until the end of the calendar year. When processing
recertifications effective January 1, February 1, March 1, and April 1, in order
to complete the Recertification Steps outlined in Figure 7-3 of Handbook
4350.3 REV-1 and provide the tenant with the required 30-day notice of any
increase in rent, the O/A must use one of the methods below for determining
the tenant’s income:
a. Use the benefit information reported in EIV that does not include the
COLA as third party verification as long as the tenant confirms that the
income data in EIV is what he/she is receiving;
b. Use the SSA benefit or award letter or Proof of Income Letter provided by
the tenant that includes the COLA adjustment if the date of the letter is
within 120 days from the date of receipt by the owner;
c. Determine the tenant’s income by applying the COLA increase percentage
to the current verified benefit amount and document the tenant file with
how the tenant’s income was determined; or
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d. Request third party verification directly from SSA when the income in
EIV does not agree with the income the tenant reports he/she is receiving.
(See Section VI.F)
e. All recertifications effective after April 1 must reflect the SSA benefit that
includes the COLA.
NOTE: The SSA has published notification that there will be no COLA
increases for 2010.
C. NDNH (New Hires (W-4), Wage and Unemployment Compensation) Match
1. Tenants who pass the identity match with SSA are matched with the
new hires (W-4), wage and unemployment benefit data contained in the
NDNH. (See Section VII.B.2.c for information on the SSA Identity Test.)
2. There are two types of matches conducted against the NDNH data:
a. The first is a Monthly match - the entire eligible tenant base is matched
with the new hires (W-4) data and newly admitted tenants are matched
with the wage and unemployment benefit data.
b. The second is a Quarterly match – the entire eligible tenant base is
matched with the new hires (W-4), wage and unemployment benefit data.
Month Type of Match
January Monthly
February Quarterly
March Monthly
April Monthly
May Quarterly
June Monthly
July Monthly
August Quarterly
September Monthly
October Monthly
November Quarterly
December Monthly
3. The new hires (W-4), wage and unemployment benefit data is loaded into EIV
by the 20th of each month.
4. EIV retains the last eight actions processed by HHS of the NDNH
employment and income data for a tenant.
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VI. REQUIREMENTS FOR USING EIV DATA
A. Updating O/A Requirements
1. Tenant Selection Plan
O/As must use the Existing Tenant Search in EIV as part of their screening
criteria for new tenants and must include written policies for using the search
in their Tenant Selection Plan. See Section VII.B.2.a for more information
on the Existing Tenant Search.
2. Policies and Procedures
O/As must have written policies and procedures for staff to follow for using
the EIV Income Report as third party verification of employment and income
and for using the other EIV reports, e.g., Income Discrepancy Report and the
EIV Verification Reports. See Section VII for instructions on using the EIV
reports. Also see Attachment 6 for a chart on the Use of EIV Reports.
Following written policies and procedures will ensure that applicants and tenants
are treated fairly and are not being discriminated against.
B. Consent for the Release of Information
1. Applicants
The form HUD-9887, Notice and Consent for the Release of Information,
signed by the applicant and each applicant family member 18 years of age and
older does not need to be on file in order to use the Existing Tenant Search in
EIV at the time of application processing and tenant screening. See Section
VII.B.2.a for instructions on using the Existing Tenant Search.
2. Tenants
a. Form HUD-9887 authorizes HUD, O/As and PHAs to:
(1) Use data obtained through computer matching with another agency for
verifying the individual’s income used for establishing the eligibility
for and level of benefits under HUD’s assisted housing programs.
(2) Request wage, new hire (W-4) and unemployment claim information
from current or former employers to verify information obtained
through computer matching.
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b. A current form HUD-9887 must be on file before accessing the
employment or income data contained in EIV for a tenant. The form must
be signed and dated by:
(1) Each adult member of a household regardless of whether he or she has
income.
(2) The head of household, spouse or co-head, regardless of age, and each
family member who is 18 years of age or older must sign and date the
form at move-in, at initial (when tenant begins receiving a subsidized
rent, e.g., Section 236 tenant begins receiving Section 8) and annual
recertification.
(3) A family member when he/she turns 18.
The form is valid for 15 months from the date of signature.
c. In addition to the form HUD-9887, a signed and dated form HUD-9887-A,
Applicant’s/Tenant’s Consent to the Release of Information, must also be
on file. This form authorizes the O/A to request information about the
tenant from a third party source.
d. The form HUD-9887 is not required for accessing the Verification Reports
(see Section VII.B.2 covering Using EIV Reports).
e. Both forms HUD-9887 and HUD-9887-A limit the O/A from requesting
information about a tenant to “within the last 5 years when the tenant
received assistance”.
f. If a tenant turns 18 and has not signed the form HUD-9887, the O/A must
not use the EIV Income Reports for that tenant until the form is signed.
O/As must address in their Policies and Procedures notification
requirements and timeframes for tenants who turn 18 between annual
recertifications to sign the consent forms (See Section VI.A.2). If the
tenant fails to sign the consent form(s), the household is in non-
compliance with their lease and assistance to, and the tenancy of, the
household may be terminated (24 CFR 5.232).
See Paragraphs 5-15 and 5-21 of HUD Handbook 4350.3 REV-1 for more
information on the HUD-9887 and HUD-9887-A forms.
C. Consent to Disclose an Individual’s Information to Another Person or Entity
The Federal Privacy Act (5 USC 552a, as amended) prohibits the disclosure of an
individual’s information to another person without the written consent of such
individual. As such, 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
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assisting the tenant with the recertification process, unless the individual has provided
written consent to disclose such information.
However, the O/A is not prohibited from discussing with the head of household and
showing the head of household how the household’s income and rent were
determined based on the total income reported and verified.
HUD will issue a Sample Tenant Consent to Disclose EIV Income Information for
use by the O/A in obtaining the tenant’s consent to disclose information to another
adult household member or to persons assisting the tenant with the recertification
process.
See Section XII.C for information on providing consent to disclose EIV data to
persons assisting tenants with the recertification process (e.g., translators, interpreters,
guardians, etc.).
D. Tenant Notification of Recertification
O/As are required to provide reminder notices to tenants informing them of their
responsibility to provide the O/A with information about changes in family income or
composition that are necessary to properly complete an annual recertification. The
notification must be in writing and must include a list of information that tenants are
required to bring with them to their recertification interview. This list must include
documentation needed to support the income they are receiving as well as
documentation to support any deductions they may be eligible to receive. For
example, elderly and disabled tenants should be requested to bring in information
related to Social Security benefits and medical expenses and tenants who are working
should be requested to bring in documentation to support the income they are
currently receiving.
Having the necessary documentation available at the time of the recertification
interview will save time in completing the recertification process. In addition,
asking the right questions at the time of the interview will ensure that the correct
information has been provided and will assist in reducing errors in income and
rent determinations.
See Chapter 7, Paragraph 7-7 and Exhibits 7-1, 7-2, 7-3 and 7-4 of Handbook 4350.3
REV-1 for additional information on the recertification notification requirements and
the Guide to Interviewing for Owners of HUD Subsidized Multifamily Housing
Projects posted on the Multifamily RHIIP website at
http://www.hud.gov/offices/hsg/mfh/rhiip/mfhrhiip.cfm for guidance on asking the
right questions during the recertification interview.
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E. Tenant Does Not Provide Requested Information or Information Not Acceptable
1. If the tenant does not provide requested information either because they do not
have the requested information or they refuse to provide the information, the O/A
must obtain verification of the information from the third party source.
The O/A should remind the tenant that he/she is required to supply, if available,
any information requested for use in a regularly scheduled recertification (annual
or interim) of income and family composition. (24 CFR §5.659)
The O/A may determine that the tenant is not in compliance with program
requirements and terminate assistance or tenancy, if the tenant fails to provide the
requested information in the timeframe established by the O/A.
NOTE: The O/A is also required to request third party verification from the
source when the tenant disputes the EIV information.
2. The O/A may reject any tenant-provided documentation, if they deem the
information to be unacceptable. Reasons the documentation may be rejected:
a. The document is not an original document; or
b. The original document has been altered, or not legible; or
c. The document appears to be a forged document (i.e. does not appear to be
authentic).
See Paragraph 5-13.C.3 of Handbook 4350.3 REV-1 for more information on
acceptability of documentation.
F. Independent Third Party Verification
1. O/As must obtain independent third party verification from the source which is
used to complement EIV data when:
a. The tenant is unable to provide acceptable and current employment and/or
income documentation to support the wage and unemployment income in
EIV;
b. The tenant disputes the EIV income information;
c. There is an EIV income discrepancy reported at the time of recertification
(annual or interim) or at other times as specified in the O/A’s policies and
procedures;
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d. There is incomplete EIV employment or income data for a tenant and the O/A
needs additional information. Examples of additional information include but
are not limited to:
(1) Effective date of income (i.e. employment, unemployment compensation,
or Social Security benefits).
(2) For new employment: pay rate, number of hours worked per week, pay
frequency, hire date (not required to be reported to state so it may not be in
EIV– see Attachment 3 for data elements that are optional for employers
to report to the state), etc.
(3) Confirmation of change in circumstances (i.e., reduced hours, reduced rate
of pay, temporary leave of absence, etc.); and,
e. There is no EIV employment or income data for a tenant.
See Chapter 5, Paragraph 5-13 of Handbook 4350.3 REV-1 for information on
acceptable verification methods.
2. When the O/A is unable to obtain third party verification, e.g., the third party does
not respond, the tenant file must contain documentation as to why third party
verification was not available. See Chapter 5, Paragraph 5-19.E of Handbook
4350.3 REV-1, for documentation requirements.
3. The O/A may accept self-certification from the tenant only if third party
verification cannot be attained. See Chapter 5, Paragraph 5-13.D of Handbook
4350.3 REV-1.
4. O/As always have the discretion to obtain additional third party verification of
income or verification of other EIV data based on circumstances encountered
during the recertification process.
G. EIV Income Incorrect or Does Not Belong to the Tenant
There may be times when the source or originator of EIV information makes an error
when submitting or reporting information about tenants. HUD cannot correct data
in the EIV system, only the originator of the data can correct the information.
When data is corrected by the source or the originator, HUD will obtain the updated
information with its next computer matching process. Below are the procedures to
follow regarding incorrect EIV information.
1. TRACS data reported in EIV originates from the O/A. Once data is corrected in
the O/A’s software, the corrected data must be transmitted to TRACS.
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2. Employment and wage information reported in EIV originates from the
employer. The employer reports this information to the local State Workforce
Agency (SWA), who in turn, reports the information to HHS’ NDNH database.
If the tenant disputes the accuracy of the information in EIV that was provided by
the employer and after additional third party verification is obtained by the O/A it
is determined that the information is not accurate, the tenant should contact the
employer directly, in writing, to dispute the employment and/or wage information
and request that the employer correct erroneous information. The tenant should
provide the O/A with a copy of this written correspondence to maintain in the
tenant file.
3. Unemployment benefit information reported in EIV originates from the local
SWA. If the tenant disputes the accuracy of the information in EIV that was
provided by the SWA and after additional third party verification is obtained by
the O/A it is determined that the information is not accurate, the tenant should
contact the SWA directly, in writing, to dispute the unemployment benefit
information, and request that the SWA correct erroneous information. The tenant
should provide the O/A with a copy of this written correspondence to maintain in
the tenant file.
4. SS and SSI benefit information reported in EIV originates from the SSA. If the
tenant disputes the accuracy of the information in EIV that was provided by the
SSA and after additional third party verification is obtained by the O/A it is
determined that the information is not accurate, the tenant should contact the SSA
at (800) 772-1213, or visit the local SSA office and request that the erroneous
information be corrected. SSA office information is available in the government
pages of the local telephone directory or online at http://www.socialsecurity.gov.
5. Identity Theft. Incorrect information in EIV may be a sign of identity theft.
Sometimes someone else may use an individual’s SSN, either on purpose or by
accident. SSA does not require an individual to report a lost or stolen SSN card,
and reporting a lost or stolen SSN card to SSA will not prevent the misuse of an
individual’s SSN. A person using an individual’s SSN can get other personal
information about that individual and apply for credit in that individual’s name.
If the tenant suspects someone is using his/her SSN, he/she should:
(a) Check their Social Security records to ensure their records are correct (call
SSA at 1-800-772-1213);
(b) File an identity theft complaint with the Federal Trade Commission (call FTC
at 1-877-438-4338, or visit their website at:
http://www.ftc.gov/bcp/edu/microsites/idtheft/); and
(c) Monitor his/her credit reports with the three national credit reporting agencies
(Equifax, TransUnion, and Experian).
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Tenants may request their credit report and place a fraud alert on their credit
report with the three national credit reporting agencies at:
http://www.annualcreditreport.com or by contacting the credit reporting
agency directly. Each agency’s contact information is listed below:
National Credit Reporting Agencies Contact Information
Equifax Credit Information Services, Inc.
P.O. Box 740241
Atlanta, GA 30374
Website: http://www.equifax.com
Telephone: (800) 685-1111
Experian
P.O. Box 2104
Allen, TX 75013
Website: http://www.experian.com
Telephone: (888) 397-3742
TransUnion
P.O. Box 6790
Fullerton, CA 92834
Website: http://www.transunion.com
Telephone: (800) 680-7289 or (800) 888-4213
VII. USING EIV REPORTS
Effective January 31, 2010, it is mandatory that O/As must use the EIV system in its
entirety (see Section I). O/As must use the:
EIV Income Report as a third party source to verify a tenant’s employment
and income during mandatory recertifications (annual and interim) of family
composition and income, and
Other EIV income reports (Income Discrepancy Report, New Hires Report
and No Income Report) to identify issues or discrepancies which may impact
a family’s assistance, and
EIV Verification Reports (Existing Tenant Search, Multiple Subsidy Report,
Identity Verification Reports, and Deceased Tenants Report) that further assist
in reducing subsidy payment errors.
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Use of the EIV Existing Tenant Search must be addressed in the O/A’s Tenant
Selection Plan. Use of all other EIV reports must be addressed in the O/A’s policies
and procedures (see Section VI.A).
O/As should refer to the EIV User Manual for Multifamily Housing Program Users
for information on accessing the reports and for further descriptions of the reports.
The manual is posted at: http://www.hud.gov/offices/hsg/mfh//rhiip/eiv/eivhome.cfm
A. Income Reports
When selecting the Income Report for an individual tenant, either from the list of
tenants for a particular project and/or contract or by querying by the head of
household’s SSN, there are three reports that must be used at the time of
recertification (annual and interim). The reports can be accessed by clicking on
the tab for a particular report.
Summary Report Income Report Income Discrepancy Report
1. Summary Report
This report provides a summary of information taken from the current, active
certifications contained in the TRACS file at the time of the income match. It
also provides the Identity Verification Status for each household member.
a. Identity Verification Status:
There are four verification statuses identified:
Verified – personal identifiers (last name, DOB, SSN) match the SSA database.
(1) Failed – personal identifiers do not match the SSA database.
(2) Not Verified – personal identifiers have not yet been sent by HUD to
SSA for validation or the validation is in process by SSA.
(3) Deceased – SSA’s records indicate the person is deceased.
Example 1: Individual(s) with an EIV Identity Verification Status of Verified
Household Members
Member Member First Member Last Identity Verification
Date of Birth Age Relationship
SSN Name Name Status
Head of
***-**-0000 SANDRA S XX/XX/1984 24 Verified
Household
***-**-0001 JOHN S XX/XX/2005 2 Child Verified
Example 2: Individual(s) with an EIV Identity Verification Status of Failed
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Example 3: Individual(s) with an EIV Identity Verification Status of Not Verified
Household Members
Member Member First Member Last Identity Verification
Date of Birth Age Relationship
SSN Name Name Status
Head of
***-**-0001 JOHN S XX/XX/1986 22 Not Verified
Household
Example 4: Individual(s) with an EIV Identity Verification Status of Deceased.
Household Members
Member SSN Member First Name Member Last Name Date of Birth Age Relationship Identity Verification Status
***-**-0001 JOHN S XX/XX/1932 77 Head of Deceased
b. O/As must use this report:
(1) At the time of recertification to review and resolve the status of any
household member(s) with a “failed” or “deceased” status.
NOTE: O/As do not have to do anything at the time of recertification
when the status is “Not Verified.” However, the O/A must check the
Failed SSA Identity Test report monthly as changes in the Identity
Verification Status for these tenants may occur.
(2) As verification that a tenant’s SSN has been “Verified” by SSA as
being a valid SSN.
c. O/As must retain in the tenant file:
(1) The Summary Report(s) as verification of the SSN for all household
members whose Identity Verification Status is “Verified”. If the
Summary Report in the tenant file shows an Identity Verification
Status of “Verified” for all household members required to have a
SSN, the Owner does not have to continue to print out the Summary
Report at recertification unless there is a change in household
composition or in a household member’s identity verification status.
NOTE: To minimize the risk of exposing a tenant’s SSN, O/As may
remove and destroy, at the time of recertification, copies of
verification documentation received from the tenant at the time of
disclosure of their SSN once the Identity Verification Status shows
“Verified”. O/As are encouraged to minimize the number of tenant
records that contain documents that display the full nine-digit SSN.
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O/As must not include the full nine-digit SSN for a tenant in emails or
other electronic communications.
(2) Any correspondence or documentation received to resolve the “Failed”
or “Deceased” status. See Section VII.B.2.c for more information on
tenants who fail the SSA identity test or are reported by SSA as being
deceased.
(3) Documentation for household members not required to disclose and
provide verification of a SSN:
Exempt from SSN disclosure and verification requirements:
Tenants who were 62 years of age or older as of January 31, 2010,
and whose initial determination of eligibility was begun before
January 31, 2010; and
Individuals who do not contend eligible immigration status.
These individuals will continue to have a TRACS generated
identification number in the SSN field. No employment or income
information will be provided in EIV for these individuals;
therefore, third party verification from the income source will have
to be obtained.
2. Income Report
O/As must use the Income Report at the time of recertification (annual and
interim) of family composition and income and may use it at other times as
indicated in their policies and procedures (see Section VI.A.2).
The Income Report:
Provides employment and income information reported in the NDNH
and SSA databases for each household member who passes the SSA
identity test.
Identifies household members who may be receiving multiple
subsidies by displaying the following message “This member may be
receiving multiple subsidies. See the Multiple Subsidy Tenant Report
for details.”
a. Components of the Income Report
(1) The Income Report provides a variety of information about each
member of a household. The components of the report are:
TRACS certification information and tenant personal identifiers
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Employment Information
Wages
Unemployment Benefits
Social Security Benefits
Dual Entitlement
Medicare Data
Supplemental Security Income Benefits
SSA Disability Status
See Attachment 7, EIV Income Report Information, for the types of
information contained in each of the components of the report.
(2) The Income Report does not include other income the household may
receive such as welfare benefits, most pensions, child support, etc. It
should also be noted that a tenant may have wages that the employer
did not report to the SWA and, therefore, these wages will not be
contained in the NDNH database.
b. Required Documentation to Demonstrate EIV Compliance
The following documentation is required to be in the tenant file to
demonstrate the O/A’s compliance with mandated use of EIV as the third
party source to verify tenant employment and income information (24
CFR §5.233(a)(2)(i)).
(1) No Dispute of EIV Information: EIV Income Report, current
acceptable tenant-provided documentation, and, if necessary (as
determined by the O/A), third party verification from the source.
(2) Disputed EIV Information: EIV Income Report and third party
verification from the source for the disputed information.
(3) Tenant-reported income not verified through the EIV System:
EIV Income Report, current acceptable tenant-provided documents
and/or third party verification from the source.
c. NDNH (New Hires (W-4), Wage and Unemployment Compensation)
(1) The Income Report identifying the NDNH employment, wage and
unemployment income information in EIV must be used as third party
verification of the tenant’s employment and is not to be used to
calculate the tenant’s income.
(2) The O/A must print the Income Report and use the report as third party
verification of the tenant’s employment and/or unemployment.
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(3) The O/A must confirm with the tenant that the employment and/or
unemployment information in EIV is correct. If the tenant agrees that
the employment and/or unemployment information in EIV is correct,
the O/A must:
(a) Request the tenant to provide documentation, e.g., four current,
consecutive check stubs that will support his/her current income
being received.
(b) Use the tenant provided documentation for determining the
tenant’s income unless additional information is needed or the O/A
has reason to reject the tenant provided documentation (see VI.E).
In these instances, third party verification must be obtained from
the income source.
(c) Annualize the tenant’s income using the current income projected
forward for the next 12 months.
Example:
EIV shows that the tenant is working at Jack’s Restaurant
and the tenant has reported he/she works at Jack’s
Restaurant. The tenant has brought in his/her four most
current, consecutive check stubs (see Paragraph 5-13.C.3.b
of Handbook 4350.3 REV-1). The O/A will use the Income
Report in EIV as third party verification that the tenant is
employed at Jack’s Restaurant and use the gross pay shown
on the check stubs provided by the tenant for determining
the tenant’s income.
Check stubs – gross pay 1) $120; 2) $145; 3) $125; 4) $130
$120 + $145 + $125 + $130 = $520
$520 / 4 = $130 average gross pay per week
$130 x 52 = $6,760 gross annual income
(d) Make copies of any tenant provided documents for the tenant file
and return the originals to the tenant.
(e) Retain the printed report and supporting documentation in the
tenant file along with the applicable form HUD-50059.
(f) If the tenant disputes the employment, wage or unemployment
information in EIV or when the tenant reports he/she is employed
or receiving unemployment but there is no information in EIV, the
O/A must obtain third party verification from the employer or
SWA.
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d. Social Security Benefits
(1) The Income Report identifying the Social Security benefit information
in EIV must be used as third party verification of the tenant’s income
and will be used to calculate the tenant’s income. A copy of the award
or benefit letter or Proof of Income Letter is not required unless the
tenant disputes the SSA information in EIV.
(2) The O/A must print the Income Report and use the report as third party
verification.
(3) The O/A must confirm with the tenant that the current benefit amount
in EIV is correct. If the tenant agrees that the Social Security benefit
information reported in EIV is correct, the O/A must:
(a) Use the gross benefit amount reported in EIV for calculating the
tenant’s income by annualizing the gross benefit amount projected
forward for the next 12 months.
Example One:
EIV shows the tenant is receiving a gross Social Security
benefit of $980.50 per month, net Social Security benefit
of $870, and the Medicare premium of $110.50 is being
paid by the tenant and the tenant agrees that this
information is accurate. The O/A will use the EIV Income
Report as the third party verification that the tenant is
receiving Social Security benefits and the gross benefit
amount from the Income Report for calculating the
tenant’s income. A copy of the award or benefit letter or
Proof of Income Letter is not required.
The data used for rent calculations is:
Gross annual income $11,766.00 ($980.50 x 12)
Medical expense $1,326.00 ($110.50 x 12)
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Example Two:
EIV shows the tenant is receiving a gross Social Security
benefit of $701 per month, net Social Security benefit of
$701, and the Medicare premium of $110.50 is being paid
by the state or another entity and the tenant agrees that this
information is correct. The O/A will use the EIV Income
Report as the third party verification that the tenant is
receiving Social Security benefits and the gross benefit
amount for calculating the tenant’s income. A copy of the
award or benefit letter or Proof of Income Letter is not
required.
The data used for rent calculations is:
Gross annual income $8,412 ($701 x 12)
Medical expense – None
NOTE: See Chapter 5, Paragraph 5-6.O of Handbook 4350.3
REV-1 for calculating the income for Intermediate Care
Facility/Mentally Retarded (ICF/MR) or Intermediate Care
Facility/Developmentally Disabled (ICF/DD) and Assisted Living
Units in Elderly Projects, and Paragraph 5-6.J of Handbook 4350.3
REV-1 for Adjustments to Prior Overpayments of Benefits.
(b) Include the Medicare premium in the medical expense deduction
calculation if the premium is being paid by the tenant. If the
Medicare premium is being paid by the tenant, the amount of the
premium is listed under “Premium” and an “N” is in the “Buy-in”
column of the Medicare Data section of the Income Report.
Example: Medicare premium paid by tenant
Premium Buy-in Buy-in Start Buy-in Stop
Hospital Insurance $0.00 N Not Available Not Available
Supp. Med. Insurance $110.50 N Not Available Not Available
(c) When the Medicare premium is being paid by the state or another
entity, there is a “Y” in the buy-in column and the date when the
third party started paying the tenant’s Medicare premium is
included in the “Buy-in Start” column of the Medicare Data
section of the Income Report.
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Example: Medicare premium paid by State or another entity
Premium Buy-in Buy-in Start Buy-in Stop
Hospital Insurance $0.00 N Not Available Not Available
Supp. Med. Insurance $110.50 Y 10/10/09 Not Available
(d) When the state or another entity stops paying the tenant’s Medicare
premium, there will be a date in the “Buy-in Stop” column of the
Medicare Data section of the Income Report.
Example: Medicare premium no longer paid by State or another entity
Premium Buy-in Buy-in Start Buy-in Stop
Hospital Insurance $0.00 N Not Available Not Available
Supp. Med. Insurance $110.50 Y 10/10/09 03/01/10
NOTE: The “Y” indicator in the buy-in column is information
received from SSA and is not always accurate. If the tenant
disputes the EIV data and the O/A verifies that the tenant is paying
the Medicare premium themselves, then the tenant file must be
documented with this additional information and the O/A must
include the Medicare premium in the tenant’s medical expense
deduction.
(e) Make copies of any tenant provided documents for the tenant file
and return the originals to the tenant.
(f) Retain the printed report in the tenant file along with the applicable
form HUD-50059.
(4) If the tenant disputes the SSA information in EIV or when the tenant
reports he/she receives SSA benefits but there is no SSA information
in EIV, the O/A must obtain third party verification by requesting the
tenant provide a copy of their benefit or award letter or Proof of
Income Letter, dated within the last 120 days from the date of receipt
by the owner.
The O/A must not send the tenant to the SSA office if they do not have
this information. Instead, the O/A must ask the tenant to request
benefit information from SSA using SSA’s website or toll-free
number.
(a) The O/A may assist the tenant in requesting benefit information
from SSA, if the tenant requests their assistance in accessing the
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SSA website or has questions on completing the request. To
request a Proof of Income Letter from SSA’s website go to
http://www.socialsecurity.gov. From the left side bar:
Select “What you can do online”
Select “If you get benefits”
Select “Request a Proof of Income Letter”
Tenants should check the box “All Benefit Information
Available” to make sure all benefits received are provided.
(b) To request a Proof of Income Letter from SSA’s toll-free
number call 1-800-772-1213.
(c) This information is free and the tenant should receive the letter
in the mail within 10 days. The tenant will provide the Proof
of Income Letter to the O/A for use in calculating their
income. A copy of the letter will be retained in the tenant’s
file and the original returned to the tenant for their records.
(5) While the SSA provides information on Medicare premiums it does
not provide as part of the computer matching, information on
additional deductions such as Medicare Part D (prescription drugs)
premiums or garnishments. Therefore, O/As need to request that
tenants disclose any deductions they may have from their SSA
benefits. For example, if the tenant is paying his/her Medicare
premium and the difference between the gross and net SS benefits
exceeds the amount of the Medicare premium, the O/A must discuss
this with the tenant to determine any deductions that may impact the
tenant’s income or allowable expenses, e.g., Medicare Part D
(prescription drugs) premiums are an allowable medical expense.
(6) The SSA Disability Status is not always accurate, therefore, it must not
be used for determining an applicant’s or tenant’s eligibility as
disabled for a HUD program or for receiving the elderly/disabled
household allowance.
(7) If the O/A finds it necessary to use some other alternative form of
verification, e.g., bank statements, it may be necessary to use more
than one document as third party verification. Documents such as
bank statements only disclose the net amount of Social Security
received and not the gross amount used for determining the tenant’s
annual income. This information will not support allowing inclusion
of the Medicare premium as a medical expense if the tenant claims
he/she is paying the Medicare premium. When alternative forms of
verification are used, the O/A must document the tenant’s file why
third party verification was not obtained. See Appendix 3, Acceptable
24
Forms of Verification, and Paragraph 5-19.E, Documenting Why
Third-Party Verification is Not Available, of Handbook 4350.3 REV-
1.
e. New Admissions
For all new admissions, the O/A must:
(1) Review the Income Report within 90 days after transmission of the
move-in certification to TRACS to confirm/validate the income
reported by the household.
(2) Resolve any income discrepancies with the household within 30 days
of the Income Report date.
(3) Print and retain the Income Report in the tenant file along with any
documentation received to resolve income discrepancies, if applicable.
f. Applicants
EIV only contains employment and income information for tenants
participating in Multifamily Housing’s rental assistance programs.
Therefore, the O/A must request third party verification from the income
source for determining the applicant’s income for eligibility and rent
calculation purposes.
For additional information on determining income and calculating rent, see
Chapter 5 of Handbook 4350.3 REV-1. Also, see Attachment 6 of this
Notice, Use of EIV Reports.
3. Income Discrepancy Report
a. The Income Discrepancy Report identifies households where there is a
difference of $2,400 or more annually in the wages, unemployment
compensation and/or Social Security benefit income reported by NDNH
and SSA and the wages, unemployment compensation and/or Social
Security benefit income reported in TRACS (from the form HUD-50059
in effect at the time of the computer match) for the period of income (POI)
used for the discrepancy analysis.
The report identifies tenants whose income may have been under- or over-
reported. Negative numbers on the report represent potential tenant under
reporting of income while a positive number represents a potential
decrease in a tenant’s income. In either case, O/As must investigate all
discrepancies identified to determine whether or not they are valid. As
discussed in Section III, Background, improper payments includes
25
payments for the incorrect amount; both overpayments and
underpayments.
See Attachment 4: Income Discrepancy Report, for a description of the
period of income used for discrepancy analysis. Also see Section IX,
Investigating and Resolving Income Discrepancies.
NOTE: Wage, unemployment and Social Security income in TRACS
includes:
TRACS
Type of Income
Income Code
B Business
F Federal Wage
M Military Pay
W Nonfederal Wage
U Unemployment
SS Social Security
SSI Supplemental Security Income
Other income the household receives, e.g., welfare benefits, most
pensions, child support, etc., may be reported in annual income in TRACS
but it is not used for the discrepancy analysis in EIV.
b. The Income Discrepancy Report is a tool to alert O/As that there may be a
discrepancy in the income reported by the tenant during the period of
income shown on the report. The O/A must investigate all discrepancies
identified on the report to determine whether or not the discrepancy is
valid. The O/A is not expected to reconcile dollar amounts to the penny
when resolving discrepancies.
26
Example 1: Valid discrepancy
The EIV Income Discrepancy Report shows the tenant had Reported Annual Wages and Benefits
during the period of income used for the discrepancy analysis. However, there are no Projected
Annual Wages or Benefits reported on the form HUD-50059. The O/A must investigate this to
determine if the tenant did not report his/her income at the time of recertification. If the tenant did
not report his/her income, this would be a valid discrepancy. The O/A must obtain third party
verification of the tenant’s income, process corrected form HUD-50059(s) to include any
unreported or underreported income, notify tenant of funds due and their obligation to reimburse
the O/A, collect funds due from tenant and/or enter into a repayment agreement and reimburse
HUD for funds collected from the tenant less the amount retained for pursuing collection. If not a
valid discrepancy, the O/A will document the file with the results of the investigation supporting
this determination. See Section IX.
Projected Annual Wages and Benefits from Form HUD-50059: $0
Period Of Income for Discrepancy Analysis 06/01/2008 - 05/31/2009
Discrepancy Analysis Actuals Annualized Last Quarter
Reported Annual Wages and Benefits from EIV Data: $22,018.70 $19,518.57
Amount of Annual Income Discrepancy: ($22,018.70) ($19,518.57)
Amount of Monthly Income Discrepancy: ($1,834.89) ($1,626.55)
Percentage of Income Discrepancy: (100%) (100%)
Example 2: Valid discrepancy
The EIV Income Discrepancy Report shows that the tenant had Reported Annual Wages and
Benefits during the period of income used for the discrepancy analysis of $15,957.03 actual and
$17,210.18 annualized. The Projected Annual Wages reported on the form HUD-50059 are
$14,472.00. The annualized last quarter income exceeds the $2,400 discrepancy threshold
($17,210.18-$14,472.00 = $2,738.18). The O/A must investigate this to determine if the tenant
should have reported a cumulative increase of $200 per month ($2,400 annually) or more in the
household’s income. If the tenant should have reported the increase in income as required by
his/her lease, this would be a valid discrepancy. If valid, the O/A would obtain third party
verification, process an interim recertification in accordance with Chapter 7, Paragraph 7-13.D of
Handbook 4350.3 REV-1, notify tenant of funds due and their obligation to reimburse the O/A,
collect funds due from tenant and/or enter into a repayment agreement and reimburse HUD for
funds collected from the tenant less amount retained for pursuing collection. If not a valid
discrepancy, the O/A will document the file with the results of the investigation supporting this
determination. See Section IX.
Projected Annual Wages and Benefits from Form HUD-50059: $14,472.00
Period Of Income for Discrepancy Analysis 06/01/2008 - 05/31/2009
Discrepancy Analysis Actuals Annualized Last Quarter
Reported Annual Wages and Benefits from EIV Data: $15,957.03 $17,210.18
Amount of Annual Income Discrepancy: ($1,485.03) ($2,738.18)
Amount of Monthly Income Discrepancy: ($123.75) ($228.18)
Percentage of Income Discrepancy: 9.31% 15.910000%
Example 3: Invalid discrepancy
The EIV Income Discrepancy Report shows that the tenant had Reported Annual Wages and
Benefits during the period of income used for the discrepancy analysis. However, there are no
Reported Annual Wages or Benefits on the form HUD-50059 for the same period of time. The
form HUD-50059 used in the discrepancy analysis was the tenant’s move-in form HUD-50059.
The O/A must investigate this discrepancy to determine if the tenant accurately reported his/her
income at the time of move-in. If verification is received that the tenant was not working at the
time of move-in and the wages reported on the EIV Income Report were earned prior to move-in,
this would be an invalid discrepancy. No action is required of the O/A except to document the
tenant’s file of the findings as a result of the investigation.
Projected Annual Wages and Benefits from Form HUD-50059: $0
Period Of Income for Discrepancy Analysis 06/01/2008 - 05/31/2009
Discrepancy Analysis Actuals Annualized Last Quarter
Reported Annual Wages and Benefits from EIV Data: $10,341.38 $7,507.72
Amount of Annual Income Discrepancy: ($10,341.38) ($7,507.72)
Amount of Monthly Income Discrepancy: ($861.78) ($625.64)
Percentage of Income Discrepancy: (100%) (100%)
c. O/As must:
(1) Print the Income Discrepancy Report at the same time they print the
Income Report, at annual and interim recertification or at other times
as indicated in their policies and procedures. It is important that the
Income Discrepancy Report be printed at the same time as the
Income Report as each week a completely new report is generated
based on the current information in the system for a tenant. The
old report is overwritten with the current data.
(2) Review and resolve any discrepancies in income reported on the
Income Discrepancy Report with the household at the time of
recertification or within 30 days of the EIV Income Report date. Any
unreporting, underreporting or over-reporting of income by the tenant
and reported on current or historical form HUD-50059s must be
identified.
(3) Retain the Income Discrepancy Report along with detailed information
on the resolution of the reported discrepancy in the tenant file. This
includes information on resolution of the discrepancy regardless of
whether the discrepancy was found to be valid or invalid.
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(4) Make sure that the information in TRACS agrees with the information
on the form HUD-50059 in the tenant’s file. Any discrepant
information must be corrected in the TRACS database. This is
important since the income discrepancies reported in EIV are
determined by comparing the wage, unemployment and Social
Security benefits income reported by NDNH and/or SSA with the
wage, unemployment and Social Security benefits income reported
by the household and transmitted to TRACS.
d. The O/A must follow the instructions in Section IX on Investigating and
Resolving Income Discrepancies.
NOTE: HUD regulation 24 CFR 5.236(2) prohibits O/As from taking
adverse action based solely on EIV information.
See Attachment 4 for detailed information on the Income Discrepancy Report
and a sample discrepancy; “Resolving Income Discrepancies between
Enterprise Income Verification (EIV) System Data and Tenant-Provided
Income Information” posted on the Multifamily EIV website at:
http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/reqnguide.cfm;
and, Chapter 8, Paragraph 8-17, Procedures for Addressing Discrepancies and
Errors, in Handbook 4350.3 REV-1.
O/As are also encouraged to view the latest EIV webcast for further
information on how to use the report for resolving discrepancies. The webcast
is posted at: http://www.hud.gov/webcasts/archives/multifamily.cfm
O/As can apply for access to TRACS at:
https://hudapps.hud.gov/public/wass/public/participant/partreg_page.jsp
B. Other EIV Reports
EIV contains the following stand-alone reports that identify potential issues which
may impact the family’s assistance. O/As must use these reports as discussed
below and at other times as established in their policies and procedures to reduce
subsidy payment errors. O/As must retain a “Master” file that contains a copy of
the report and documentation and/or notations as indicated in the report
discussions below.
Caution: Any detail reports retained in a tenant’s file must contain information
for members of that tenant’s household only. Many of the reports do not have
page breaks between households, therefore, O/As will need to separate the reports
by household by cutting the reports apart until page breaks are inserted in the EIV
system.
29
1. Additional Income Reports
There are two additional income reports that O/As must use: the No Income
Report and the New Hires Report. These reports are accessed from the
Monthly Summary Report when querying by project number and/or contract
number. If the report name is underlined, this indicates it is an active link.
Just click on the report name to obtain data about households identified where
no income was reported or where a household member is reported as having
new employment.
Monthly Report Summary
Contract(s) XX22111122
Recertification Month All
Report Type Number of Households Number of Members
Income Report 66 91
Income Discrepancy Report 22
No Income Report 1 2
New Hires Report 12 12
a. No Income Report
This report is a tool for O/As to use to identify tenants who passed the
identity match against SSA’s records but no employment or income
information was received from the match against either the SSA or NDNH
records.
(1) O/As must use this report only as identified and described in their
policies and procedures.
(2) Because no income was reported as a result of the match against SSA
and NDNH records does not mean that the tenant(s) does not have
income. The O/A must make sure that, at the time of recertification
interviews, the right questions are asked so that the tenants are given
the opportunity to disclose any income they receive.
(3) O/As are not required to retain copies of this report.
Note: It is recommended that O/As have a policy to re-verify the status of
tenants reporting zero income at least quarterly. As part of the procedures
for implementing the policy, the O/A must use the EIV Income Report to
determine if the tenant or any family members have income reported by
HHS or SSA.
b. New Hires Report
This report identifies tenants who have started new jobs within the last six
months. The information in this report is updated monthly.
30
(1) O/As must use this report at least quarterly to determine if any of their
tenants have started new employment whereby the tenant has not
reported a change in income to the O/A between recertifications and/or
the new employment was not reported at the time of recertification.
(2) Because tenants participating in one of Multifamily Housing’s rental
assistance programs are required to report changes in income when the
household’s income cumulatively increases by $200 or more per
month, O/As must reach out to their tenants to report the income
changes so that rent adjustments can be made in a timely manner, thus
eliminating/reducing the amount of retroactive rent repayments. (See
Handbook 4350.3 REV-1, Chapter 7, Paragraph 7-12.B.)
O/As must:
(a) Contact the tenant regarding his/her new employment.
(b) Confirm with the tenant that they have a new job and that the
employment information in EIV is correct. If the tenant agrees
that the employment information in EIV is correct, request the
tenant provide documents, e.g., four current, consecutive pay stubs,
employment confirmation letter specifying date of hire, rate of pay,
number of hours worked each week, pay frequency, for use in
determining the tenant’s income or, if necessary, request third
party verification from the employer.
If the tenant disputes the employment information in EIV, the O/A
must obtain third party verification from the employer.
(c) Process a recertification in accordance with program requirements
that includes the employment income.
(d) Retain the New Hires Summary Report in a master “New Hires
Report” file along with notations as to the outcome of the contact
with the tenant (e.g., J. Jones – interim recertification processed to
include income from new employment). A copy of the New Hires
Detail Report for the tenant along with any correspondence with
the tenant, third party verifications, etc. must be retained in the
tenant file.
See Paragraph 7-10.A and the HUD Model Leases in Appendix 4 of
Handbook 4350.3 REV-1 for change in income reporting requirements.
2. Verification Reports
The Verification Reports can be accessed from the EIV Homepage, left
sidebar.
Verification Reports
Existing Tenant Search
Multiple Subsidy Report
Identity Verification Report
Deceased Tenant Report
a. Existing Tenant Search
This report identifies applicants applying for assisted housing that may be
receiving rental assistance at the time of application processing at another
location.
O/As must:
(1) Use this report at the time they are processing an applicant for
admission to determine if the applicant or any applicant household
members are currently being assisted at another Multifamily Housing
or Public and Indian Housing (PIH) location.
(2) Discuss with the applicant if the report identifies that the applicant or a
member of the applicant’s household is residing at another location,
giving the applicant the opportunity to explain any circumstances
relative to his/her being assisted at another location. This may be a
case where the applicant wants to move from his/her present location
or where two assisted families share custody of a minor child.
(3) Follow up with the respective PHA or O/A to confirm the individual’s
program participation status before admission, if necessary, depending
on the outcome of the discussion with the applicant. The report gives
the O/A the ability to coordinate move-out and move-in dates with the
PHA or O/A of the property at the other location.
(4) Retain the search results with the application along with any
documentation obtained as a result of contacts with the applicant and
the PHA and/or O/A at the other location.
b. Multiple Subsidy Report
This report identifies individuals who may be receiving multiple rental
subsidies.
(1) O/As must:
(a) Use the Multiple Subsidy Report at least quarterly to identify any
tenants who are being assisted at another location. O/As must
follow up with tenants identified on the report where the
discrepancy was not identified and resolved at the time of
recertification.
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(b) Perform both of the search options shown below to determine if
possible multiple subsidies exist:
Search within MF
Search within PIH
(c) Discuss with the tenant if the results of either of the searches
shows that a tenant is being assisted at another location. The
tenant must be given the opportunity to explain any circumstances
relative to his/her being assisted at another location.
(d) Follow up with the respective PHA or O/A, if necessary, to
confirm that the tenant is being assisted at the other location.
Depending on the results of this investigation, the O/A may need to
take action to terminate the tenant’s assistance or tenancy. (See
Chapter 8, Section 1 and 2 of Handbook 4350.3 REV-1 for
procedures for terminating assistance and/or tenancy.)
(e) Print out and retain a copy of the Multiple Subsidy Summary
Report in a master “Multiple Subsidy Report” file along with
notations as to the outcome of contacts with the tenant and/or PHA
or owner (e.g., J. Jones – no multiple subsidies being paid. Section
236 tenant with Housing Choice Voucher (HCV)). A copy of the
Multiple Subsidy Detail Report for the tenant plus any
documentation supporting any contacts made or information
obtained to determine if a household and/or household member is
receiving multiple subsidies as well as documentation to support
any action taken if a household and/or a household member is
receiving multiple subsidies must be retained in the tenant file.
NOTES:
If a tenant’s multiple subsidies were discussed and resolved at the
time of recertification, this must be noted on the printed Multiple
Subsidy Summary Report and no further action is required.
HUD does not prohibit owners of partially subsidized projects
from housing tenants who are receiving assistance through the
Housing Choice Voucher program. While these tenants may
appear on the Multiple Subsidy Report, HUD does not consider
them as receiving double subsidy. (See Paragraph 3-21 of
Handbook 4350.3 REV-1 for a discussion on Applicants with
Housing Choice Vouchers.) In these instances, O/As must note on
that report that the tenant has a Housing Choice Voucher and is not
receiving double subsidy, e.g., tenant is residing in a Section 236
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unit and receiving rental assistance through the Housing Choice
Voucher program.
c. Identity Verification Reports
There are two reports that can be accessed from the Identity Verification
Report link. O/As must use both of these reports monthly to clear up any
invalid, discrepant or missing information in the TRACS database that
was not identified and corrected at the time of recertification. There will
not be any employment or income information in EIV for tenants who
fail either the EIV pre-screening or SSA identity test so it is essential
that any discrepancies are corrected within 30 days from the date of
the reports. O/As must conduct third party verifications to obtain
employment and income data for these tenants.
If the report name is underlined, this indicates it is an active link. Just
click on the report name to obtain data about household members who
failed the EIV pre-screening or SSA identity test.
Identity Verification Report Statistics
Number of households Failed 9
Failed EIV Pre-Screening 5
Failed Verification Report (Failed the SSA Identity Test) 4
Percentage of households Failed 13.43%
(1) Failed EIV Pre-Screening Report
This report identifies tenants who fail the EIV pre-screening test
because of invalid or missing personal identifiers (SSN, last name or
DOB). The tenants on this list will not be sent to SSA from EIV for the
SSA identity match until the personal identifier information is
corrected in TRACS.
O/As must:
(a) Use this report monthly to identify tenants that did not pass the
pre-screening test and the reason(s) they did not pass so that the
errors can be corrected. O/As must follow up with tenants
identified on the report where discrepant personal identifiers were
not corrected at the time of recertification.
(b) Before contacting the tenant, confirm accuracy of data entry in
TRACS, (e.g. has a number been transposed when entering the
SSN?).
(c) Confirm with the affected tenant their SSN, DOB and/or last name.
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(d) Obtain documentation from the tenant to verify any discrepant
personal identifiers.
(e) Correct any discrepant information in the TRACS system.
(f) Print and retain a copy of the report in a master “Failed EIV Pre-
screening Report” file. The report must be documented with
action taken to resolve invalid or discrepant personal identifiers.
See Attachment 1 for the EIV Failed Pre-screening Report Error
Messages and corrective action.
NOTE: This report will include those persons who are exempt from
the SSN disclosure and verification requirements. In these instances
the O/A will note on the copy of the report retained in the “Failed EIV
Pre-Screening Report” master file that the tenant(s) is exempt from
SSN requirements.
Exempt from SSN disclosure and verification requirements:
Tenants who were 62 years of age or older as of January 31, 2010,
and whose initial determination of eligibility was begun before
January 31, 2010; and
Individuals who do not contend eligible immigration status.
These individuals will continue to have a TRACS generated
identification number in the SSN field. No employment or income
information will be provided in EIV for these individuals.
(2) Failed Verification Report (Failed the SSA Identity Test)
This report identifies household members who failed the SSA identity
test because their personal identifiers (SSN, last name or DOB) do not
match SSA’s records as well as identifies deceased household
members.
(See Attachment 2 for the Failed Verification Report (Failed the SSA
Identity Test) Error Messages and corrective action, and d below for
instructions on tenants reported as being deceased.)
O/As must:
(a) Use this report monthly to identify those tenants that did not pass
the SSA identity verification test and the reason(s) they did not
pass so that the errors can be corrected. O/As must follow up with
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tenants identified on the report where discrepant personal
identifiers were not corrected at the time of recertification.
(b) Before contacting the tenant, confirm accuracy of data entry in
TRACS, (e.g. has a number been transposed when entering the
SSN?).
(c) Confirm with the affected tenant their SSN, DOB and/or last name.
(d) Obtain documentation from the tenant to verify any discrepant
personal identifiers.
(e) Correct any discrepant information in the TRACS system so that
the tenant will be included in the match against SSA and NDNH
data.
(f) Encourage the tenant to contact the SSA to correct any inaccurate
data in their databases if the personal identifiers on the form HUD-
50059 and in TRACS are accurate. The tenant can request SSA to
correct his/her record by completing and submitting form SS-5,
Application for a Social Security Card, to the local SSA office.
Also, see Section VI.G for instructions on contacting the SSA.
(g) Print and retain a copy of the report in a master “Failed the SSA
Identity Test” file. The report must be documented with action
taken to resolve invalid or discrepant personal identifiers.
NOTE: If a tenant’s information was corrected at the time of
recertification but the EIV data has not yet been updated, this must be
noted on the printed report and no further action is required.
d. Deceased Tenants Report
This report identifies tenants who are participating in one of Multifamily
Housing’s rental assistance programs who are reported by SSA as being
deceased.
(1) O/As must:
(a) Use this report at least quarterly to identify those tenants reported
by SSA as being deceased.
(b) Confirm, in writing, with the head-of-household, next of kin or
emergency contact person or entity provided by the tenant whether
or not the person is deceased.
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(c) If the person is deceased:
i. Update the family composition, and income and allowances, if
applicable, on the form HUD-50059. The effective date of the
form HUD-50059 should in accordance with Chapter 7,
Paragraph 7-13.D of Handbook 4350.3 REV-1.
ii. In the case of a deceased single member of a household,
process a Move-out using form HUD-50059-A. The effective
date of the form HUD-50059-A will be retroactive to the
earlier of 14 days after the tenant’s death or the date the unit
was vacated (see Chapter 9, Paragraph 9-12.E of Handbook
4350.3 REV-1).
Note: Single member deceased households are denoted on the
report with a red asterisk (*) after the member’s deceased date.
iii. Any overpayment of subsidy that was paid on behalf of the
deceased tenant must be repaid to HUD.
iv. Discrepant information must be corrected in the TRACS
system within 30 days from the date of the report.
(d) Encourage the tenant to contact the SSA to correct any inaccurate
data in their databases if the person shown as being deceased in the
SSA database is not deceased. See Section VI.G for instructions
on contacting the SSA.
(e) Print and retain a copy of the report in a master “Deceased Tenants
Report” file. The report must be documented with action taken to
resolve any discrepancies. All correspondence or action taken for
a particular tenant must be retained in the tenant file.
NOTE: If action was taken to remove the deceased tenant from the
household or a move-out processed if a single member household but
the EIV data has not yet been updated, this must be noted on the
printed report and no further action is required.
(2) The Deceased Tenants Report is updated every weekend. See
examples below addressing when a deceased individual will be
removed from the report.
Example 1: Mr. Jones was listed on the Deceased Tenants Report
dated December 14, 2009, with a deceased date of November 20,
2009. On December 1, 2009, the owner confirmed that Mr. Jones was
actually alive and advised Mr. Jones to visit his local SSA office to
have the error corrected. SSA corrected the error on December 20,
37
2009. When HUD conducted computer matching with SSA on
January 6, 2010, HUD obtained new SSA data which indicated that
Mr. Jones was not deceased. The Deceased Tenants Report was
updated on the weekend of January 8, 2010. When the owner accessed
the Deceased Tenants Report on January 11, 2010, Mr. Jones was no
longer on the report.
Example 2: Mr. Williams was listed on the Deceased Tenants Report
dated December 14, 2009, with a deceased date of June 10, 2009. On
January 6, 2010, the owner confirmed that Mr. Williams was deceased.
The owner then completed and submitted the move-out on form HUD-
50059-A on January 7, 2010. The Deceased Tenants Report was
updated on the weekend of January 8, 2010. When the owner accessed
the Deceased Tenants Report on January 11, 2010, Mr. Williams was
no longer on the report.
VIII. SYSTEMATIC ALIEN VERIFICATION FOR ENTITLEMENTS (SAVE)
SYSTEM ACCESS
Individuals who have approved access to the Department of Homeland Security’s
(DHS’) SAVE system for verifying the validity of citizenship documents provided by
applicants or tenants who are noncitizens and who claim eligible immigration status
may access the system through EIV. See Chapter 3, Paragraph 3-12.L of HUD
Handbook 4350.3 REV-1 for verifying information on immigration status.
The system can be accessed from the EIV Homepage, left sidebar under External
Links.
External Links
USCIS – SAVE System
See Chapter 3, Paragraph 3-12.H of HUD Handbook 4350.3 REV-1 for instructions
on obtaining access to the SAVE system.
IX. INVESTIGATING AND RESOLVING INCOME DISCREPANCIES
A. Investigating Discrepancies
1. O/As must investigate and confirm possible income discrepancies of $2,400
or more as disclosed on the EIV Income Discrepancy Report. They must also
investigate and confirm other possible errors that may result in over or
underpayment of HUD subsidy, e.g., tenants reported by SSA as being
deceased, tenants receiving multiple subsidies, etc.
2. O/As may not suspend, terminate, reduce, make a final denial of rental
assistance, or take any other adverse action against an individual based solely
on the data in EIV.
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3. When the tenant disputes the employment and income information in EIV, the
O/A must independently verify the disputed information by obtaining third
party verification directly from the third party source.
4. The O/A must notify the tenant of the results of any third party verification
and request the tenant come into the office, within 10 days of notification, to
discuss the results (see Chapter 8, Paragraph 8-17 of Handbook 4350.3 REV-
1). The tenant may contest the findings in the same manner as applies to
other information and findings relating to eligibility factors.
5. If the O/A determines that the tenant is in non-compliance with his/her lease
because he/she knowingly provided incomplete or inaccurate information, the
O/A must follow the guidance in Chapter 8, Section 3 of Handbook 4350.3
REV-1, for terminating the tenant’s tenancy and Chapter 8, Paragraph 8-18
for the requirements on filing a civil action against the tenant to recover
improper subsidy payments.
6. Where fraud is suspected, the O/A should report this to the HUD OIG Office
of Investigation in the District that has jurisdiction in the state the project is
located.
B. Unreported or Underreported Income
If the O/A determines the tenant unreported or underreported his/her income, the
O/A must go back to the time the unreported or underreporting of income started,
not to exceed the 5-year limitation that the tenant was receiving assistance
described on forms HUD-9887 and HUD-9887-A, and calculate the difference
between the amount of rent the tenant should have paid and the amount of rent the
tenant was charged. The O/A must notify the tenant of any amount due and their
obligation to reimburse the O/A. A record of this calculation must be provided to
the tenant and also retained in the tenant’s file. Tenants with unreported income
that goes back further than 5 years can be reported to the OIG for fraud. (See
Section IX.C on Tenant Repayment of Unreported or Underreported Income.)
The O/A must have the form HUD-50059(s) on file that was in effect during the
period(s) that the tenant had unreported or underreported income, along with any
supporting documentation, in order to calculate the amount the tenant must
reimburse to the owner. The form HUD-50059(s) is the document whereby the
tenant(s) certifies to the accuracy of the income included on the form. If the O/A
does not have this historical information, the O/A cannot go back to the tenant for
unreported or underreported income.
C. Tenant Repayment of Unreported or Underreported Income
1. Tenant’s Obligation to Reimburse
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Tenants are obligated to reimburse the O/A if they are charged less rent than
required by HUD’s rent formula due to underreporting or failure to report
income. The tenant is required to reimburse the O/A for the difference
between the rent that should have been paid and the rent that was charged.
(See Paragraph 18 of the HUD Model Lease for Subsidized Programs,
Paragraph 14 of the Section 202/8 and 202/162 PAC lease and Paragraph 12
of the Section 202 and Section 811 PRAC leases found in Appendix 4 and
Paragraph 8-13.A.5 of Handbook 4350.3 REV-1.)
Note: Tenants are not required to reimburse the O/A for undercharges
caused solely by the O/A’s failure to follow HUD’s procedures for
computing rent or assistance payments. (See Chapter 8, Paragraph 8-
20.B.2, of Handbook 4350.3 REV-1, addressing the O/A’s obligation to
reimburse HUD for overpayments of assistance due to the owner’s failure
to follow HUD’s procedures.)
2. Repayment Options
a. Tenants can repay amounts due:
(1) In a lump sum payment; or
(2) By entering into a repayment agreement with the O/A; or
(3) A combination of (1) and (2), above.
Example: A tenant may owe $1,000, make a lump
sum payment of $300 and enter into a repayment
agreement for the remaining $700.
b. Tenants who do not agree to repay amounts due in accordance with 2.a,
above, will be in non-compliance with their lease agreement and may be
subject to termination of tenancy. (See Paragraph 8-13.A.5 of Handbook
4350.3 REV-1.)
c. Tenants may also be required to repay funds to the O/A due to a:
(1) Civil action taken by the O/A, or
(2) Court action as a result of an OIG audit.
3. Repayment Agreements
a. The tenant and O/A must both agree on the terms of the repayment
agreement.
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The tenant may wish to consult with HUD’s Housing Counseling Agency
in their area to assist them in working with the O/A to reach agreeable
terms for the repayment agreement. See the Housing Counseling Agency
website for a listing of agencies for each state at
http://www.hud.gov/offices/hsg/sfh/hcc/hcs.cfm
(1) Monthly Payment
The tenant’s monthly payment must be what the tenant can afford to
pay based on the family’s income.
The monthly payment plus the amount of the tenant’s total tenant
payment (TTP) at the time the repayment agreement is executed
should not exceed 40 percent of the family’s monthly adjusted income.
Example:
Family’s monthly adjusted income is $1,230.
Family’s monthly total tenant payment (TTP) is $369 (30%
of the family’s monthly adjusted income).
40% of the family’s monthly adjusted income is $492.
The monthly payment for the repayment agreement should
not exceed $123 per month ($492 - $369 = $123)
($369 monthly TTP + $123 repayment = $492, 40% of the
family’s monthly adjusted income.)
(2) Repayment Time Period
The time period for repayment by the tenant of the amount owed.
Example: The tenant agrees to repay $1,000, and agrees to
monthly payments of $25. $1,000/$25 = 40 months (time
period).
b. Effective with the issuance date of this Notice, new repayment agreements
must:
(1) Include the total retroactive rent amount owed, the amount of lump
sum paid at time of execution of the agreement, if applicable, and the
monthly payment amount.
(2) Reference the paragraphs in the lease whereby the tenant is in non-
compliance and may be subject to termination of their lease.
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(3) Contain a clause whereby the terms of the agreement will be
renegotiated if there is a decrease or increase in the family’s income
of $200 or more per month.
(4) Include a statement that the monthly retroactive rent repayment
amount is in addition to the family’s monthly rent payment and is
payable to the O/A.
(5) Late and missed payments constitute default of the repayment
agreement and may result in termination of assistance and/or tenancy.
(6) Be signed and dated by the tenant and the O/A.
c. O/As must not apply a tenant’s monthly rent payment towards the
repayment amount owed that would result in an accumulation of late rent
payments. The monthly payment due on the repayment agreement is in
addition to the tenant’s monthly rent payment.
4. Disposition of Funds Received by O/A
a. O/As are required to reimburse funds collected from the tenant to HUD in
accordance with the requirements in Chapter 8, Paragraph 20 of Handbook
4350.3 REV-1.
(1) O/As should be familiar with their software’s capability that allows for
adding Miscellaneous Accounting Requests to the housing assistance
payments (HAP) voucher (form HUD-52670) as the procedures vary
from software to software. O/As should consult their software
documentation or software provider if assistance is required.
(2) After verifying the tenant’s income, the O/A must complete
corrections to a prior certification(s) affected by the income change.
O/As must not fail to correct the prior certification(s) in an attempt to
avoid having large negative adjustments appear on the HAP voucher.
(3) Voucher adjustments:
(a) If the tenant is able to pay the entire amount due in one lump sum
payment, no Miscellaneous Accounting Request is needed.
(b) If the tenant pays a lump sum payment and enters into a repayment
agreement for the remaining amount due, the O/A must first
reverse the adjustment created by correcting the prior
certification(s) less the lump sum payment by adding an O/A
initiated accounting adjustment (Owner Agent ReQuest -
OARQ) Miscellaneous Accounting Request to the voucher.
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Example: If the total adjustment is -$1,240 (indicating
that $1,240 in subsidy is being returned to HUD) and the
tenant pays $480 in a lump sum, the OARQ request is for
$760 ($1,240 - $480). The comment field must be
completed describing the transaction, e.g. “Reversal of
adjustments subject to repayment – Unit 1023 - John
Smith.”
(c) Adjustments for payments received from the tenant per the
repayment agreement are made as addressed in (e), below.
NOTE: The comment field allows for 78 characters to describe
the transaction.
(d) If the tenant is subject to a repayment agreement, the O/A must
first reverse the full amount of the voucher adjustment created by
correcting the prior certification(s).
Example: If the total of the adjustments is -$1,240
(indicating that $1,240 in subsidy is being returned to HUD),
the OARQ request will be for $1,240. This leaves the
voucher unaffected by the retroactive corrections to a
recertification(s). The comment field must be completed
describing the transaction, e.g., “Reversal of adjustments
subject to repayment – Unit 1023, John Smith.”
(e) As the tenant makes payments per the repayment agreement, the
O/A must enter them as negative amounts on the voucher as
OARQ Miscellaneous Accounting Requests.
Example: The tenant pays $50, the OARQ will be for
-$50. The comment field must be completed describing the
transaction, e.g., “Repayment – Unit 1023- John Smith.”
If the O/A is deducting his/her costs from the payment received
from the tenant, the OARQ Miscellaneous Accounting Request
will be for the amount collected from the tenant less the O/A’s
costs.
Example: The tenant pays $50 and the O/A’s costs are $8,
the OARQ would be for -$42. The comment field must be
completed describing the transaction, e.g., “Repayment –
Unit 1023 – John Smith - $50 collected less costs of $8.”
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(f) O/As should consult the TRACS Monthly Activity Transmission
(MAT) User’s Guide to obtain updated instructions on
Miscellaneous Accounting Requests.
b. O/As may retain a portion of the repayments they actually collect from the
tenants who have improperly reported their income at the time of
certification or recertification to help defray the cost of pursuing these
cases. This is no longer limited to cases where the O/A has determined
fraud.
O/As may only retain an amount to cover their actual costs, which is the
lesser of:
(1) Their actual costs, or
(2) 20 percent of the amount received from the tenant.
Example: Amount received from tenant $500. Actual
cost for pursuing and collecting amount due from
tenant $125. The O/A is entitled to retain $100.
20% of $500 = $100 which is less than the actual cost
of $125.
c. Amounts retained by O/As must be deposited into the project’s operating
account to offset the expenses incurred for these cases.
d. As with all income and expenses of the project, O/As must keep records of
the receipt and disbursement of all amounts collected from the tenant for
audit purposes. At a minimum, the owner must record:
(1) Date and amount(s) received from the tenant;
(2) Expenses incurred;
Examples of types of expenses incurred include staff time for verifying
the unreported income; meeting with tenant; drafting repayment
agreements; generating and sending monthly invoices to tenant;
generating manual voucher adjustments; collection agency fees, if
applicable; and, meeting state requirements.
(3) Amount(s) retained; and
(4) Voucher date(s) and amount(s) of reimbursement made to HUD.
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D. Over-reported Income
1. Tenants may report decreases in their income (see Paragraph 16.b of the HUD
Model Lease for Subsidized Programs, Paragraph 23.b for the Section 202/8
and Section 202/162 PAC lease and Paragraph 24.b for the Section 202 PRAC
and Section 811 PRAC leases). In these instances, O/As must process an
interim recertification in accordance with Handbook 4350.3 REV-1, Chapter
7, Paragraphs 7-11, 7-12 and 7-13.
2. If, at the time of recertification, there is an Income Discrepancy Report in EIV
that reflects a decrease of $2,400 or more in wage, unemployment and/or
Social Security income reported in EIV and the wage, unemployment and/or
Social Security income in TRACS for the period of income used for the
discrepancy analysis, the O/A must investigate the discrepancy.
(a) If, after investigating the discrepancy, the O/A determines that an error
was made in calculating the tenant’s income (e.g., third party verification
not obtained, third party verification received but an error was made in
calculating the tenant’s income) and the income was over-reported, the
O/A must complete corrections to the prior certification(s) affected by the
income change. Once the corrections have been made, the O/A will
determine the difference between the amount of rent the tenant paid and
the rent that the tenant should have paid.
(b) The O/A must reimburse the tenant the amount of overpayment of rent in
accordance with Chapter 8, Paragraph 8-21 of Handbook 4350.3 REV-1.
E. Errors Discovered During a Monitoring Review
If, during their review of the tenant files, the CA determines that an error was
made in the income calculation based on the income verifications on file that
results in an under- or over-payment of rent by the tenant, the O/A must make the
necessary adjustments to the tenant’s rent for the period the error occurred. This
will be a finding on the Management and Occupancy Review (MOR) and O/As
will have 30 days to mitigate.
(a) The O/A must complete corrections to the prior certification(s) affected by
the income change. Once the corrections have been made, the O/A will
determine the difference between the amount of rent the tenant paid and the
rent that the tenant should have paid.
(b) The O/A must follow the instructions in Chapter 8, Paragraphs 8-20 and 21
of Handbook 4350.3 REV-1 for reimbursement to the O/A by the tenant for
underpayment of rent and for reimbursement to the tenant by the O/A for
overpayment of rent.
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X. RETENTION OF EIV REPORTS
A. O/As must retain:
1. The Income Report, the Summary Report(s) showing Identity Verification
Status as “Verified” and the Income Discrepancy Report(s) and supporting
documentation must be retained in the tenant file for the term of tenancy plus
three years.
2. Any tenant provided documentation, or other third party verification of
income, received to supplement the SSA or NDNH data must be retained in
the tenant file for the term of tenancy plus three years.
3. Results of the Existing Tenant Search must be retained with the application:
(a) If applicant is not admitted, the application and search results must be
retained for three years.
(b) If applicant is admitted, the application and search results must be retained
in the tenant file for the term of tenancy plus three years.
4. The master files for the New Hires Report, Identity Verification Reports,
Multiple Subsidy Report and Deceased Tenants Report must be retained for
three years.
See Attachment 6, Use of EIV Reports.
B. Once the retention period has expired, O/As must dispose of the data in a manner
that will prevent any unauthorized access to personal information, e.g., burn,
pulverize, shred, etc.
XI. PENALTIES FOR FAILURE TO HAVE ACCESS TO AND/OR USE EIV
A. O/As will incur penalties if they:
1. Did not receive access to the EIV system by January 31, 2010, because they
did not submit a Coordinator Access Authorization Form (CAAF) to the
Multifamily Help Desk by December 15, 2009, and/or did not complete the
property assignment process by January 15, 2010, as instructed in Listserv and
iMAX messages posted beginning mid-November 2009;
2. Did not begin using EIV as of January 31, 2010; or
3. Are not using EIV at the time of a MOR.
B. Penalties
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The O/A:
1. Will receive a finding on the MOR report. See Attachment 8, MOR Findings
for EIV Compliance.
2. Will incur a penalty of a five percent decrease in the voucher payment for the
month following the date the violation was found.
3. Must make an adjustment on the next scheduled voucher to adjust for the five
percent decrease.
4. Will be monitored by the CA to ensure the adjustment is made.
C. The O/A will have 30 days to cure the finding.
1. The finding will be cured by obtaining access to and/or using EIV and the
O/A will make an adjustment to the next scheduled voucher to collect the
funds previously returned to HUD.
2. If the finding is not cured during the 30 day period, both the owner and the
management agent, if applicable, will be flagged in HUD’s Active Partners
Performance System (APPS). Once the finding is cured, the flag(s) will be
removed.
D. When there is a change in ownership or management at a property, the new owner
or management agent must obtain access to and begin using EIV within 90 days
from the date the owner takes possession of the property or the effective date of
the management agreement with the owner. Owners and/or management agents
who fail to obtain access and begin using EIV within this timeframe may be
subject to the penalties described above.
XII. SECURITY OF EIV DATA
The data in EIV contains personal information on individual tenants that is covered
by the Privacy Act. The information in EIV may only be used for limited official
purposes:
A. Official Purpose Includes
1. O/As, in connection with the administration of Multifamily Housing
programs, for verifying the employment and income at the time of
recertification and for reducing administrative and subsidy payment errors.
2. CAs (PBCAs and TCAs) and HUD staff for monitoring and oversight of the
access and mandatory use of the EIV system. (See Attachment 8, MOR
Findings for EIV Compliance, the Rent and Income Determination Quality
47
Control Monitoring Guide for Multifamily Housing Programs, and the most
recent EIV webcast for EIV monitoring requirements.)
3. IPAs, when hired by an owner to perform the financial audit of the project, for
use in determining the owner’s compliance with verifying income and
determining the accuracy of the rent and subsidy calculations.
Restrictions on disclosure requirements for IPAs:
(a) Can only access EIV income information within hard copy files and only
within the offices of the owner or management agent;
(b) Cannot transmit or transport EIV income information in any form;
(c) Cannot enter EIV income information on any portable media;
(d) Must sign non-disclosure oaths (Rules of Behavior for Non-system Users)
that the EIV income information will be used only for the purpose of the
audit; and
(e) Cannot duplicate EIV income information or re-disclose EIV income
information to any user not authorized by Section 435(j)(7) of the Social
Security Act to have access to the EIV income data.
Note: Independent public auditor means a Certified Public Accountant or
a licensed or registered public accountant, having no business relationship
with the private owner except for the performance of audit, systems work
and tax preparation. If not certified, the Independent Public Accountant
must have been licensed or registered by a regulatory authority of a State
or other political subdivision of the United States on or before December
31, 1970. In States that do not regulate the use of the title “public
accountant,” only Certified Public Accountants may be used.
4. OIG investigators for auditing purposes.
5. See Section VI.C for information on disclosure of EIV information to
individuals who are assisting in the recertification process and who are present
during the recertification interview and process.
B. Official Purpose Does NOT Include
1. Sharing the information with governmental entities not involved in the
recertification process used for HUD’s assisted housing programs, e.g., the
LIHTC program and RHS Section 515 program.
As previously stated in the Note in Section II, this Notice does not apply to the
LIHTC program for the O/A’s completion of the LIHTC Tenant Income
48
Certification (TIC) 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.
Disclosing the EIV information to O/As for use under the LIHTC and RHS
Section 515 programs is not allowed since neither the Internal Revenue
Service (IRS) nor RHS are a party to the computer matching agreements with
HHS and SSA. The fact that there is financing through other federal agencies
involved in a particular property under one of the authorized HUD programs
does not then permit that federal agency to use or view information in the EIV
system that is covered by the computer matching agreements. The computer
matching agreements are governed by the Privacy Act and the Social Security
Act. For example, Sections 453(j)(7)(E)(ii) and (iv) of the Social Security Act
limit disclosure of the data matched between HUD and HHS’ NDNH to public
housing agencies, the IG, the Attorney General, private owners, management
agents and CAs. HHS subsequently approved disclosure of NDNH
information to IPAs hired by an owner to conduct the financial audit of their
property.
2. Disclosure of the EIV information to Service Coordinators even though the
tenant signs a release of information consent form authorizing the Service
Coordinator 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. The statute authorizing the computer matching
identifies those parties to whom the information can be disclosed and the
statute does not include Service Coordinators.
C. Disclosure to Persons Assisting Tenants with the Recertification Process
With the written consent of the tenant, EIV data may be shared with persons
assisting the tenant with the recertification process. Tenants who require
assistance during the recertification process may have a representative present to
assist them in their ability to participate in the recertification process; this includes
review and explanation of the written third party income verifications. Disclosure
of EIV information to these parties must be employment or income information
pertaining only to the tenant who has provided his/her consent. These parties
must not have access to EIV information for any other household members.
Parties to whom the tenant can provide written consent include:
Service coordinators (only if they are present at and assisting the tenant with
the recertification process)
Translators/Interpreters
Individuals assisting an elderly individual or a person with a disability
Guardians
Powers of Attorney
49
Other Family Members
See Section VI.C, Disclosing an Individual’s Information to Another Person or
Entity.
D. Penalties for Willful Disclosure or Inspection of EIV Data
1. Unauthorized Disclosure – felony conviction and fine up to $5,000 or
imprisonment up to five (5) years, as well as civil damages.
2. Unauthorized Inspection – misdemeanor penalty of up to $1,000 and/or one
(1) year imprisonment, as well as civil damages.
E. Rules of Behavior (ROB)
1. With EIV System Access
All EIV users who have access to the EIV system must adhere to the EIV
ROB signed at the time of requesting access to the EIV system.
a. Instructions for requesting access to EIV for both internal HUD users and
external users are posted on the Multifamily EIV website at:
http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/eivapps.cfm
b. External users. The signed initial and current online (unsigned) access
authorization forms containing the ROB must be kept on file along with
the owner approval letters. Upon request, the forms must be made
available to the entity monitoring EIV compliance.
c. Internal users. A copy of the signed ROB will be kept on file by the
TRACS/EIV Security Officer and a signed copy should also be retained
by the EIV user.
d. Each HUD Program Center and Contract Administrator must have at least
two staff members with access to the EIV system who can provide other
staff members with EIV reports used for monitoring purposes.
2. Without EIV System Access
a. O/A staff, service bureau staff, HUD staff and CA staff who do not have
access to the EIV system but who view or use EIV data/reports provided
by authorized EIV Coordinators or EIV Users in order to perform their job
functions, must adhere to the EIV ROB posted on the Multifamily EIV
website at:
http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/rulesofbehavior.pdf.
50
The ROB must be signed and kept on file. Upon request, the signed ROB
must be made available to the entity monitoring EIV compliance.
NOTE: HUD staff will check the “CA” box at the bottom of the form.
b. IPAs hired by the owner to perform a financial audit must adhere to the
ROB posted on the Multifamily EIV website at:
http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/rulesofbehavior.pdf.
The ROB must be signed by the IPA and kept on file. Upon request, the
signed ROB must be made available to the entity monitoring EIV
compliance.
F. Security Training
1. EIV users are required to have security training annually. EIV users
authorized by owners to have access to EIV on their behalf must complete the
applicable online Security Awareness Training Questionnaire for Multifamily
Housing Programs upon initial access to the system and annually thereafter.
2. EIV users should:
a. Review Section 4 on Security contained in the Multifamily EIV User
Manual for Multifamily Housing Program Users posted at:
http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/usermanual.pdf,
b. Review the EIV Security Administration Manual posted at:
http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/securityadminmanual.pdf
c. View the Security training provided during the most recent EIV webcast,
posted at: http://www.hud.gov/webcasts/archives/multifamily.cfm, and
3. O/A staff who do not have access to EIV but who use EIV reports to perform
their job function must have security training annually.
NOTE: Security training as part of HUD’s most recent EIV webcast will satisfy
the annual security training requirements. HUD will not provide certificates for
completing the training. O/As and CAs must keep a file of who took the training
and when for auditing purposes.
G. Safeguarding EIV Data
1. Technical Safeguarding of Data
a. All individuals who have access to the EIV system must have a valid
WASS User ID and password and must use this ID and password for
accessing EIV. Upon receipt of the assigned WASS User ID, an
individual must then apply to be approved for access to the EIV system.
51
b. To assist in ensuring that only those individuals who have a need to use
the EIV system to perform their job function have access to the EIV
system, users must be certified to use the system:
(1) EIV Coordinators are certified at initial access and annually thereafter.
(2) EIV Users are certified at initial access and bi-annually thereafter.
If this certification is not made, the user’s EIV access is terminated.
c. A Security Awareness Training Questionnaire, which supplements
required annual security training, must be completed at the time of initial
access to the system and annually thereafter. The EIV system is designed
to block the entry of those individuals who have not successfully
completed the questionnaire (i.e., answered 90 percent of the questions
correctly).
2. Administrative Safeguards
a. 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.
b. EIV manuals and the instructions in this Notice should be reviewed when
implementing these administrative safeguards.
c. Posting of bulletins and flyers can assist in communicating how sensitive
EIV data is and how this data should be handled.
3. Physical Safeguards
Physical safeguarding of EIV data refers to steps that must be taken to help
ensure the data is safe when stored electronically or in hardcopy and when
transmitting data electronically.
a. Storing and Transmitting of Electronic EIV Data
(1) EIV data stored electronically must be in a restricted access directory
or, if placed on portable media, labeled appropriately and encrypted
using a NIST compliant vendor. Similarly, all emails containing EIV
data must be encrypted using a NIST compliant vendor. A list of
compliant vendors can be found at:
52
http://csrc.nist.gov/groups/STM/cmvp/documents/140-
1/1401vend.htm.
(2) The full nine-digit SSN for a tenant must not be included in emails or
other electronic communications.
Note: The downloading of EIV data to mobile devices is not allowed for
IPAs.
b. Hardcopy EIV Data
EIV data that is printed out must not be left unattended. The documents
should be retrieved as soon as they are printed and, if possible, use a
restricted printer, copier, or facsimile machine. When faxing EIV data,
ensure there is someone waiting and ready to retrieve the fax as soon as it
is received (printed).
c. Computer Security
The EIV system is set up to time out after 30 minutes of inactivity. This
automatic safeguard should not be the only security measure taken.
Individuals who use the EIV system should use a password protected
screensaver and lock their computer when leaving their workspace. A
user should not leave a computer unattended with EIV data displayed on
the screen. It is also recommended that the EIV system be exited using
the “X” at the top right of the screen which will remove the user from the
entire WASS system.
d. Destroying EIV data
EIV data must be destroyed as soon as it has served its purpose as
prescribed by HUD’s policies and procedures and in accordance with
HUD’s prescribed retention period. Shredding, burning or pulverizing are
all examples of acceptable ways to destroy EIV data.
XIII. TOOLS AND RESOURCES
Mf eiv comments@hud.gov mailbox
EIV Multifamily Help Desk
Telephone: 1-800-767-7588
Email: Mf_Eiv@hud.gov
Refinement of Income and Rent Determination Requirements in Public and
Assisted Housing Programs: Implementation of the Enterprise Income
Verification System – Amendments; Final Rule
http://edocket.access.gpo.gov/2009/pdf/E9-30720.pdf
Multifamily Housing EIV Website:
http://www.hud.gov/offices/hsg/mfh//rhiip/eiv/eivhome.cfm
53
Enterprise Income Verification System User Manual for Multifamily Housing
Program Users http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/usermanual.pdf
EIV Multifamily Housing Programs Security Administration Manual
http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/securityadminmanual.pdf
Rental Housing Integrity Improvement Project (RHIIP) website
http://www.hud.gov/offices/hsg/mfh/rhiip/mfhrhiip.cfm
“Resolving Income Discrepancies Between Enterprise Income Verification (EIV)
System Data and Tenant-Provided Income Information”
http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/resincdisc.pdf
Handbook 4350.3 REV-1, Occupancy Requirements of Subsidized Multifamily
Housing Programs
http://www.hud.gov/offices/adm/hudclips/handbooks/hsgh/4350.3/index.cfm
EIV Instructional Webcasts
http://portal.hud.gov/portal/page/portal/HUD/webcasts/archives/multifamily
EIV Training conducted on December 16 and December 17, 2008, and December
2009; PowerPoint presentation
http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/eivtraining.cfm
A Guide to Interviewing for Owners of HUD Subsidized Multifamily Housing
Programs
http://www.hud.gov/offices/hsg/mfh/rhiip/casestudy/app_4.pdf
HUD Notice H 2010-02 EIV & You Brochure – Requirements for Distribution
and Use
http://portal.hud.gov/portal/page/portal/HUD/program offices/administration/hud
clips/notices/hsg/files/10-02hsgn.doc
EIV & You Brochure:
http://www.hud.gov/offices/hsg/mfh/rhiip/eivbrochure.pdf
Rent and Income Determination Quality Control Monitoring Guide for
Multifamily Housing Programs
http://www.hud.gov/offices/hsg/mfh/rhiip/qcguide.pdf
If you have questions regarding this Notice or need more information on the EIV
system, please contact your local Contract Administrator or local HUD field office.
XIV. PAPERWORK REDUCTION
The information collection requirements contained in this notice have been approved
by the Office of Management and Budget (OMB) under the Paperwork Reduction Act
of 1995 (44 U.S.C. 3520) and assigned OMB Control Number 2502-0204. In
accordance with the Paperwork Reduction Act, HUD may not conduct or sponsor,
and a person is not required to respond to, a collection of information unless the
collection displays a currently valid OMB control number.
________________________________
54
David H. Stevens
Assistant Secretary for Housing -
Federal Housing Commissioner
Attachment 1 – Failed EIV Pre-screening Report Error Messages
Attachment 2 – Failed Verification Report (Failed the SSA Identity Test) Error Messages
Attachment 3 – NDNH data elements
Attachment 4 – Income Discrepancy Report
Attachment 5 – Using EIV Data Flow Chart
Attachment 6 – EIV Reports Chart
Attachment 7 – EIV Income Report Component Information
Attachment 8 – MOR Findings for EIV Compliance
55
Attachment 1: Failed EIV Pre-screening Report Error Messages
Failed EIV Pre-screening Report Error Messages
Error Message Description Explanation Corrective Action
1 Failed DOB check. The date of birth is blank or Enter DOB on line 42 of form
null in line 42 of form HUD- HUD-50059. Ensure only
50059. numbers are recorded.
2 Failed last name check. The last name is blank or null Enter last name on line 35 of form
in line 35 of form HUD-50059. HUD-50059. Ensure only alpha
characters are recorded.
3 Failed SSN check. The SSN is not numeric or all Enter valid SSN on line 45 of form
9s or LIKE (000%) or LIKE HUD-50059. Do not use
(__00%) or LIKE (%0000). repetitive numbers if tenant has
not disclosed a SSN. An alternate
ID will be generated by TRACS
for household members without a
SSN.
O/A must follow up with those
households with members with a
TRACS generated ID to obtain
documentation of the member’s
SSN, if applicable.
Tenants exempt from the SSN
requirements will continue to have
a TRACS generated ID in the SSN
field on form HUD-50059.
Exempt from SSN requirement:
Individuals who do not
contend eligible immigration
status, and
Tenants who were 62 years of
age or older on January 31,
2010, and whose initial
determination of eligibility was
begun before January 31,
2010.
4 Failed effective date check The effective date of action is Transmit a current recertification
more than 15 months old. to TRACS.
56
Attachment 2: Failed Verification Report (Failed the SSA Identity Test) Error Messages
Failed Verification Report (Failed the SSA Identity Test) Error Messages
Error Description Explanation Corrective Action
1 Verification failed – SSN not The tenant’s SSN recorded on line 45 Request original SSN card from
found in SSA’s records of form HUD-50059 is not a valid tenant or other acceptable form of
number issued by SSA or listed in documentation for verification of
Or
SSA records. SSN.
SSN is not in file
Confirm SSN displayed on the
Or card/verification document
The input SSN was not matches the SSN reported on line
verified 45 of form HUD-50059.
For continued SSN failures, notify
HUD OIG or other law
enforcement agency.
2 Verification failed – SSN not Tenant SSN recorded on line 45 of Update line 45 of form HUD-
found in SSA records form HUD-50059 is not a valid 50059 with the SSA provided
XXXXXXXXX number issued by SSA. However, SSN.
the SSN reflected in SSA records is
listed at the end of the error message.
3 Verification failed - Surname The DOB recorded on line 42 of form Ask tenant to provide
matched, but DOB did not HUD-50059 is not the same DOB documentation (i.e. birth
match reflected in SSA’s records. certificate or state issued
identification card) to verify DOB.
Update line 42 of form HUD-
50059 with the SSA provided
DOB
4 Verification failed – DOB The surname recorded on line 35 of Ask tenant to provide
matched but surname did not form HUD-50059 is not the same documentation (i.e. SSN card,
match with SSA records surname reflected in SSA’s records. birth certificate, state issued
identification card, marriage
or
license or court documents) of the
Surname does not match; other name he/she is using.
DOB was checked
Update line 35 of form HUD-
50059 with the correct surname.
5 Verification failed – SS/SSI Tenant is receiving SS/SSI benefits; Request the tenant provide a
benefits cannot be disclosed however, SSA cannot disclose the current SS/SSI benefit letter.
due to discrepancy in DOB benefit amount because the DOB Request tenant provide
MM/DD/YYYY recorded on line 42 of form HUD- documentation (i.e. birth
50059 is incorrect. The DOB certificate or state issued
57
Failed Verification Report (Failed the SSA Identity Test) Error Messages
Error Description Explanation Corrective Action
reflected in SSA’s records is listed at identification card) to verify
the end of the error message. DOB.
Update line 42 of form HUD-
50059 with the SSA provided
DOB, if applicable.
6 Verification failed – SS/SSI Tenant is receiving SS/SSI benefits; Request tenant provide a current
benefits cannot be disclosed however, SSA cannot disclose the SS/SSI benefit letter.
due to discrepancy in name. benefit amount because the surname Ask tenant to provide
recorded on line 35 of form HUD- documentation (i.e. SSN card,
50059 is not the same surname birth certificate, state issued
reflected in SSA records. identification card, marriage
license or court documents) of the
other name he/she is using.
Update line 35 of form HUD-
50059 with the correct surname.
7 Verification failed – surname The DOB recorded on line 42 of form Update line 42 of form HUD-
matched but DOB did not HUD-50059 is incorrect. However, 50059 with the SSA provided
match with SSA records the DOB reflected in SSA records is DOB.
MM/DD/YYYY listed at the end of the error message.
8 SSN is verified; individual is The tenant’s SSN has been verified Contact tenant’s adult family
deceased by SSA and the individual is member, next of kin or contact
deceased. person/entity provided by tenant
or
on form HUD-92006.
If a date follows the error message,
SSN is verified; individual is
this is the date of death as reflected in Upon confirmation of death,
deceased MM/DD/YYYY
SSA records. update family composition on
form HUD-50059, or a single
member household, take
appropriate action to terminate
tenancy in accordance with
program instructions and transmit
the move-out form HUD-50059-A
to TRACS. If applicable, return
any overpayment of assistance.
NOTE: If SSA records are wrong, only the tenant can request SSA to correct his/her record by
completing and submitting form SS-5, Application for a Social Security Card.
58
Attachment 3: National Directory of New Hires (NDNH) Data Elements
The following data elements are requested by HUD from the NDNH database. The following provides
information on those data elements that are optional for employers to provide to the various states. All
of these data elements may not be elements normally displayed in EIV. For those data elements that are
displayed in EIV, information may not be made available because the employer is not required to report
the data to the state, therefore, no information is available in the NDNH database.
Quarterly Wage File
Employee SSN
Employee Name
Employer Name
Employer Address
Quarterly employee wage amount
Date quarterly wage record processed by NDNH
Federal Employee Identification Number (EIN) (optional for an employer to report)
State EIN (optional for an employer to report)
Department of Defense indicator, if any
New Hire File
Employee SSN
Employee Last Name
Employee First Name
Employee Address (optional for an employer to report)
Employer Name
Employer Address
Employee Date of Hire (optional for an employer to report)
Employee State of Hire (optional for an employer to report)
Employer Federal EIN (optional for an employer to report)
Employer State EIN (optional for an employer to report)
Employer’s Second Address, if any (optional for an employer to report)
Department of Defense indicator, if any
Date New Hire Record processed by NDNH
Unemployment Insurance File
Claimant SSN
Claimant Last Name
Claimant First Name
Claimant’s Address (optional for an employer to report)
Benefit Amount
Unemployment reporting period
59
60
Attachment 4: How EIV Calculates Income Discrepancies
The Income Discrepancy Report compares the tenant’s projected next year’s income as
reported in TRACS to the actual income data compiled by EIV. The O/A is not expected to
reconcile dollar amounts to the penny when resolving discrepancies.
1. Identifying the Period of Income (POI) for Discrepancy Analysis
The period of income provides the timeline reference governing the collection of the data used
to determine whether or not a discrepancy exists between projected household income (as
reported in TRACS) and actual income (EIV income data that was available at the time the
projection was made). This period of income is determined in order to gather the actual income
data needed to make a comparison to the projected income and determine whether a
discrepancy exists.
The period of income uses the following timeline of events to assist in determining the specific
time span that is taken into consideration when collecting and calculating income data.
Effective Date of Action – This value represents the effective date appearing on the form
HUD-50059 reported in TRACS for the identified tenant. It is used to calculate the Period
of Income Start and End Date values selected for the Period of Income for Discrepancy
Analysis.
Period of Income Start Date – This date represents the starting point for the income
period. It is calculated by EIV based on the effective date associated with the form HUD-
50059 reported in TRACS for the tenant. It is assumed that the Period of Income Start date
is 15 months prior to the effective date on the form HUD-50059 reported in TRACS.
Period of Income End Date – This date represents the end of the period of income and is
assumed to be 3 months prior to the effective date on the form HUD-50059 reported in
TRACS. (This is the approximate time frame for the tenant interview.) The Period of
Income End Date is 12 months from the Period of Income Start Date.
2. Identifying Projected Income
Projected income information is used as the baseline for discrepancy calculations. It is derived
from the form HUD-50059 records stored in the TRACS database. The income projected
information is used to determine whether or not a given household should have an Income
Discrepancy Report. The determination is made using the following evaluation criteria.
Selected form HUD-50059 records will come directly from the current TRACS database.
There is no need to access the TRACS database to obtain projected household income
information.
EIV will review the current TRACS database to locate the most current form HUD-50059
record for a household that falls in the timeline of 3 to 15 months.
Prior to the Effective Date of Action. The most recent record falling within that timeline is
used as the source for projected income information.
61
Form HUD-50059 records in TRACS with an effective date that falls within the specified 3
to 15 months timeline, and includes an action type of MI, AR, IR or IC, is included in the
Income Discrepancy Report calculations.
Action Types –
Included in the
Income Discrepancy
Report Calculations Definition
MI Move In
AR Annual Recertification
IR Interim Recertification
IC Initial Certification
Data from households that lack SSA verification or that fails the SSA verification will
not be included in the calculations.
If a form HUD-50059 record in TRACS does not meet the qualification criteria, the
household is excluded from the Income Discrepancy Report.
3. Identifying the Actual Income Reported during the Period of Income
Actual income information is used to evaluate the accuracy of an income projection. It is
compared to the projected income value stored on the form HUD-50059 in TRACS associated
with the household. These values are:
Income Code Type of Income
B Business
F Federal Wage
M Military Pay
W Nonfederal Wage
U Unemployment
SS Social Security
SI Supplemental Security Income
Note: Other income the household receives, e.g., welfare benefits, most pensions, child
support, etc., may be reported in annual income in TRACS but it is not used for the discrepancy
analysis in EIV.
EIV income information is not considered to be conclusive proof if a tenant challenges that it is
not current or complete. One factor is time lag in the collection of SSA and NDNH data. In
such cases, the employment information, including the “new hires” information will help the
O/A research the tenant’s income.
4. Prorating Actual Income
When the period of income includes a Period of Income Start Date that coincides with income
reporting quarters, the income is simply added for those quarters. In those cases where an
62
income record overlaps the start or end of the period of consideration, the income is prorated,
based on the following calculation.
First Quarter income = (quarter income value / period of time) x length of time in period.
For example, if the income is within the period of consideration for 2 or 3 months, the
calculation would be (quarter income value / 3 months) x 2 months.
Sum the quarter income that occurs within the period of consideration. This should be 3
quarters of data.
Add the final quarter of income data. Quarter income = (quarter income value / period of
time) x (length of time considered).
5. Calculating Income Discrepancies
Once projected and actual income data have been captured, the discrepancy evaluation process
begins. EIV conducts two separate evaluations during the Income Discrepancy Report
generation process. The outcome determines whether or not the results should be included in
the Income Discrepancy Report.
Income discrepancies are calculated in the following manner:
Discrepancy 1 – Entire period of consideration versus income projected is calculated as
follows:
(Projected Annual Wages and Benefits from form HUD-50059 data in TRACS) –
(Reported Annual Wages and Benefits as derived from EIV data.)
Discrepancy 2 – Last quarter of period of consideration annualized against projection is
calculated as follows:
Actual EIV Income = final quarter income data (prorated as first and final quarter income in
calculating total income for period of income against projection) x 4 quarters.
Projected Annual Wages and Benefits from form HUD-50059 data in TRACS – Actual EIV
Income
6. Discrepancy Analysis
Once the income discrepancy calculations are completed, EIV analyzes the results to determine
whether an Income Discrepancy Report should be generated. The analysis compares the results
to a pre-defined EIV system value – Discrepancy Cutoff.
The Discrepancy Cutoff variable establishes the monetary value that the calculated discrepancy
must exceed in order for the household to be included on the Income Discrepancy Report. By
default, this value is set to $2,400. This means that the discrepancy between the actual annual
income value and the projected income must be at least $2,400 or greater in order for a
discrepancy report to be generated. (The $2,400 is based on the requirement that tenants must
report to the O/A when the family’s income cumulatively increases by $200 or more per month
63
– see Paragraph 7-10.A and the HUD Model Leases in Appendix 4 of Handbook 4350.3 REV-
1.)
For example, if the projected income for a household was $10,000 but the actual income was
$14,000, the difference of $4,000 is greater than the established cutoff value of $2,400,
qualifying it to appear on the report. Conversely, if the projected income for a household was
$10,000 but the actual income was $12,000, the difference of $2,000 is less than that of the
established cutoff value of $2,400, disqualifying it from appearing on the report.
The Discrepancy Analysis section of the Income Discrepancy Report provides results of the
income analysis process. It provides actual and annualized last quarter data. There is a column
for each type of data – Actual and Annualized Last Quarter Data.
Reported Annual Wages and Benefits from EIV Data – This field identifies the actual
income reported to EIV for the designated period of Income for Discrepancy Analysis.
Amount of Annual Income Discrepancy – This field identifies the value of the
discrepancy in the annual income that caused the household to be included in the report
data. Negative currency values are represented in parentheses. For example, -$800 is
represented as ($800). When this value caused the household to be included on the report,
it appears in a bold typeface.
Amount of Monthly Income Discrepancy – This field identifies the value of the
discrepancy in the monthly income that caused the household to be included in the report
data. Negative currency values are represented in parentheses. For example, -$800 is
represented as ($800). When this value causes the household to be included on the report, it
appears in a bold typeface.
Percentage of Income Discrepancy – This field identifies the percentage by which the
threshold cutoff value has been exceeded for this household. Negative percentage values
are represented in parentheses. For example, -75% is represented as (75%).
7. Report Generation
The Income Discrepancy Report data gathering and calculations are computed automatically on
a weekly basis. The data is collected, analyzed, and stored in the EIV database according to the
previously specified criteria. The obsolete data set is overwritten with the current data. Users
relying on data from a particular Income Discrepancy Report are advised to print that report
before it is overwritten.
64
Attachment 5: Using EIV Data Flow Chart
EIV
SSA DATA HHS DATA
O/A accesses data and compares O/A accesses data and compares
EIV income data to the income the EIV data to what tenant reports
tenant reports he/she receives he/she receives
Benefits reported in EIV If the benefits reported in Tenant agrees with Information in EIV does
agree with income EIV do not agree with the income/income source not agree with
tenant reports he/she amount the tenant reports reported in EIV – O/A uses source/amount the tenant
receives – O/A uses EIV receiving or if the tenant EIV as 3rd party verification reports receiving or
data as 3rd party disputes benefits reported and uses tenant provided tenant disputes
verification and to in EIV – O/A requests documents, e.g., pay stubs, income/income source
calculate tenant’s tenant to obtain Proof of to calculate tenant income. reported in EIV – O/A
income Income Letter from SSA obtains 3rd party
verification directly from
3rd party source. O/A
uses 3rd party verification
to calculate tenant’s
O/A reviews EIV data for previous years to
income.
determine any unreported income. If unreported
income is discovered for previous years, O/A
must discuss with tenant. O/A is limited to
requesting third party verification on income the
tenant may have received to the past 5 years for
which the tenant was assisted (see forms HUD-
9887 and HUD-9887-A).
If tenant does not dispute, O/A determines If tenant disputes, O/A must verify with
amount of under-payment of rent either by third party source. If unreported income,
obtaining 3rd party verification or using owner determines amount of under-
income data reported in EIV. O/A either payment of rent. O/A either requires
requires repayment in full or enters into a payment in full or enters into repayment
repayment plan with the tenant. O/A will plan with tenant. O/A will make an
make an adjustment to the voucher to return to adjustment to voucher to return to HUD
HUD amount(s) received from tenant minus amount(s) received from tenant minus
amount(s) retained to cover costs. See Section amount(s) retained to cover costs. See
IX.C.4 of this Notice. Section IX.C.4 of this Notice.
65
Attachment 6: Use of EIV Reports
USE OF EIV REPORTS
REPORT *UPDATE REPORT USE FILE DOCUMENTATION RETENTION
TSP P&P
Summary Report X Must be used at Summary Report(s) as Tenant file
recertification (annual verification of the SSN for all Summary Report and
Summary of and interim) household members whose supporting documentation must
household information Identity Verification Status is be retained in the tenant’s file
from the current, To validate a “Verified”. for term of tenancy plus 3
active certification in tenant’s SSN years.
the TRACS file at the Correspondence or
time of the income To review and documentation received to Note: O/As may remove and
match. resolve discrepant resolve a tenant’s “Failed” or destroy copies of verification
or invalid personal “Deceased” status. documentation received from
Provides Identity identifiers of the tenant to verify their SSN
Verification Status by tenants with a Documentation for household once the Identity Verification
identifying tenants “failed” or members identified as exempt Status shows “Verified”.
whose personal “deceased” status from disclosing and providing O/As are encouraged to
identifiers: verification of a SSN: minimize the number of tenant
Note: Nothing has to records that contain documents
Match the SSA be done at the time of Tenants who were 62 years that display the full nine-digit
database - recertification with of age or older as of SSN.
“Verified” those tenants with an January 31, 2010 and
Does not match Identity Verification whose initial determination
the SSA database Status of “Not of eligibility was begun
– “Failed” Verified”. However, before January 31, 2010;
Have not been the Failed SSA and
sent by HUD to Identity Test report Individuals who do not
SSA for validation must be checked contend eligible
or have not yet monthly as a change in immigration status
been matched by the Identity
SSA for validation Verification Status If the Summary Report in the
– “Not Verified” may occur. tenant file shows an Identity
SSA’s records Verification Status of
indicate the “Verified” for all household
person is deceased members required to have a
– “Deceased” SSN, the Owner does not have
to continue to print out the
See Section VII.A.1 Summary Report at
recertification unless there is a
change in household
composition or in a household
member’s identity verification
status
*TSP = Tenant Selection Plan P&P = Policies and Procedures
66
Attachment 6: Use of EIV Reports
USE OF EIV REPORTS
REPORT *UPDATE O/A REPORT USE FILE DOCUMENTATION RETENTION
TSP P&P
INCOME REPORTS
Note: A current, signed form HUD-9887 must be on file to view and/or use the income reports.
A current, signed form HUD-9887-A must be on file to obtain written third party verification of income.
Income Report X Mandatory use at No Dispute of EIV Tenant File
Recertification - Information: Retain copy of Income Report
Provides employment Annual and Interim EIV Income Report and supporting documentation
and income reported Current, acceptable tenant with applicable form HUD-
by HHS and SSA for May be used at other provided documents 50059 for term of tenancy plus
each household times as indicated in Third party verification 3 years.
member that passes the O/A’s policies and from the source, if
SSA identity test. procedures. necessary Note: The O/A must make
copies of any tenant provided
Identifies tenants who: Serves as third Disputed EIV Information: documents and return the
May not have party verification EIV Income Report originals to the tenant.
reported complete of employment Third party verification
and accurate and income. from the source for the
income disputed information
information New Admissions:
May be receiving Review new Tenant-reported income not
multiple subsidies admissions within verified through the EIV
90 days after the system:
See Section VII.A.2 move-in EIV Income Report
information is Current, acceptable tenant-
transmitted to provided documents,
TRACS to and/or
confirm/validate Third party verification
the income from the source
reported by the
household. Any correspondence with/from
tenant relating to disputes of
Resolve discrepancies the employment or income
in reported income reported in EIV.
with the family within
30 days of the EIV Form HUD-50059(s)
Income Report date.
*TSP = Tenant Selection Plan P&P = Policies and Procedures
67
Attachment 6: Use of EIV Reports
USE OF EIV REPORTS
REPORT *UPDATE O/A REPORT USE FILE DOCUMENTATION RETENTION
TSP P&P
INCOME REPORTS Cont’d.
Note: A current, signed form HUD-9887 must be on file to view and/or use the income reports.
A current, signed form HUD-9887-A must be on file to obtain written third party verification of income.
Income X Mandatory use at All correspondence to/from the Tenant file
Discrepancy Recertification - tenant regarding the income Retain copy of Income
Annual and Interim discrepancy. Discrepancy Report and any
Report documentation related to the
Report may be used at Documentation received to resolution of the discrepancy,
Identifies households other times as resolve the discrepancy, including any repayment
where there is a indicated in O/A’s including written third party agreements for term of tenancy
difference of $2,400 or policies and verification of income, if plus 3 years.
more in the wage, procedures. applicable.
unemployment and
SSA benefit Must print the The file must be documented
information reported report at the same regardless of whether the O/A
in EIV and wage, time the Income determines the discrepancy to
unemployment and Report is printed. be valid or invalid.
SSA benefit
information reported Discrepancies must be Corrected form HUD-50059(s),
in TRACS for the reviewed and resolved if applicable.
period of income used at the time of
for discrepancy recertification or Repayment Agreement, if
analysis. within 30 days of the applicable.
EIV Income Report
The report serves as a date.
tool to alert O/As that
there may be a Review data in
discrepancy in the TRACS to make sure
income reported by the agrees with the form
tenant during the HUD-50059 data.
period of income used Correct any discrepant
for the discrepancy data in the TRACS
analysis. database.
See Section VII.A.3
*TSP = Tenant Selection Plan P&P = Policies and Procedures
68
Attachment 6: Use of EIV Reports
USE OF EIV REPORTS
REPORT *UPDATE O/A REPORT USE FILE DOCUMENTATION RETENTION
TSP P&P
INCOME REPORTS Cont’d.
Note: A current, signed form HUD-9887 must be on file to view and/or use the income reports.
A current, signed form HUD-9887-A must be on file to obtain written third party verification of income.
No Income X As identified in O/A’s Third party verification from Tenant file
Report policies and income sources of other Any documentation or third
procedures. income reported by tenant, if party verifications for other
Interview tenants, applicable. income reported by the tenant
Identifies tenants who asking the right for term of tenancy plus 3
passed the SSA questions to provide Correspondence/documents years.
identity test but no the tenant the received for re-verification of
income was reported opportunity to disclose zero income tenants.
by HHS or SSA. any income.
This does not mean
that the tenant does not .
have any income. O/A
must obtain written
third party verification
of any income reported
by the tenant.
Recommend “zero”
income tenants be
required to disclose
and O/A re-verify
income at least
quarterly. These are
tenants who report no
income at all.
See Section VII.A.4
*TSP = Tenant Selection Plan P&P = Policies and Procedures
69
Attachment 6: Use of EIV Reports
USE OF EIV REPORTS
REPORT *UPDATE O/A REPORT USE FILE DOCUMENTATION RETENTION
TSP P&P
INCOME REPORTS Cont’d.
Note: A current, signed form HUD-9887 must be on file to view and/or use the income reports.
A current, signed form HUD-9887-A must be on file to obtain written third party verification of income.
New Hires Report X At least quarterly New Hires Report with Master file
notation of action(s) taken. Retain New Hires Summary
Identifies tenants who Contact tenant Report in a master “New Hires
have new employment regarding new No Dispute of EIV Report” file for 3 years.
within the last 6 employment Information:
months. Report is EIV Income Report Tenant file
updated monthly. Confirm new Current, acceptable tenant Retain New Hires Detail
employment with provided documents Report for the tenant along
See Section VII.A.5 tenant. Request tenant Third party verification with any correspondence with
provided documents to from the source, if tenant, third party verifications,
support current income necessary. form HUD-50059(s), etc., for
and/or third party term of tenancy plus 3 years.
verification from Disputed EIV Information:
employer, as EIV Income Report
applicable. Third party verification
from the source for
Process Interim disputed information
Recertification to
include new income, if Any correspondence with/from
applicable. tenant relating to new
employment and/or disputes of
the employment or income
reported in EIV.
Form HUD-50059(s)
.
*TSP = Tenant Selection Plan P&P = Policies and Procedures
70
Attachment 6: Use of EIV Reports
USE OF EIV REPORTS
REPORT *UPDATE O/A REPORT USE FILE DOCUMENTATION RETENTION
TSP P&P
VERIFICATION REPORTS
Note: A form HUD-9887 is not required to view and/or use verification reports.
Existing Tenant X At the time of Search results for each member Application file
Search processing an of the household. If not admitted – retain search
applicant for results and any supporting
Identifies applicants admission Results of any contact with documentation with the
who may be receiving applicant must be recorded on application for 3 years.
assistance at another Search each applicant and/or with the search results
Multifamily or PIH and applicant for affected household Tenant file
location. household member to member. If admitted – retain search
see if receiving results and any supporting
See Section VII.B.2.a assistance at another Results of any contact with documentation with the
location. PHA, owner, management application for term of tenancy
agent where applicant is plus 3 years.
Discuss with tenant reported as receiving assistance
regarding must be recorded on and/or
circumstances relative with the search results for
to being assisted at affected household member.
another Multifamily or
PIH property.
Follow up with
respective PHA or
O/A to confirm the
individual’s program
participation status
before admission.
Coordinate move-
in/out dates with PHA
or O/A.
*TSP = Tenant Selection Plan P&P = Policies and Procedures
71
Attachment 6: Use of EIV Reports
USE OF EIV REPORTS
REPORT *UPDATE O/A REPORT USE FILE DOCUMENTATION RETENTION
TSP P&P
VERIFICATION REPORTS Cont’d.
Note: A form HUD-9887 is not required to view and/or use verification reports.
Multiple Subsidy X At least quarterly Search results Master file
Report Retain Multiple Subsidy
Must search both Documentation supporting any Summary Report and
Identifies tenants who queries: contacts made or information supporting documentation in a
may be receiving Search within MF obtained to determine if master “Multiple Subsidy
rental assistance at Search within PIH household and/or household Report” file for 3 years.
more than one member is receiving multiple
location. Provide tenant subsidies. Tenant file
opportunity to explain Retain a copy of the Multiple
See Section VII.B.2.b any circumstances Documentation to support any Subsidy Detail Report for the
relative to his/her action taken if household tenant along with any
being assisted at and/or household member is documentation of action taken
another location. receiving multiple subsidies. for a household member for
term of tenancy plus 3 years.
Follow up with Note: If a tenant’s multiple
respective PHA or subsidies were discussed and
O/A, if necessary, to resolved at the time of
confirm tenant is being recertification, this must be
assisted at the other noted on the printed report and
location. Depending no further action is required.
on the results, may
need to take action to
terminate the
assistance or tenancy
and repay subsidy to
HUD.
*TSP = Tenant Selection Plan P&P = Policies and Procedures
72
Attachment 6: Use of EIV Reports
USE OF EIV REPORTS
REPORT *UPDATE O/A REPORT USE FILE DOCUMENTATION RETENTION
TSP P&P
VERIFICATION REPORTS Cont’d.
Note: A form HUD-9887 is not required to view and/or use verification reports.
Failed EIV Pre- X Monthly Failed EIV Pre-screening Master file
screening Report Report documented with action Retain copy of report in a
Follow up with tenants taken to resolve invalid or master “Failed EIV Pre-
Identifies tenants who identified on the report discrepant personal identifiers. screening Report” file for 3
have missing or where discrepant years.
invalid personal personal identifiers Note: This report will include
identifiers (last name, were not corrected at those persons who are exempt Tenant file
date of birth, SSN) in the time of from the SSN disclosure and Documentation to verify
TRACS. These recertification. verification requirements. In discrepant personal identifiers
tenants will not be sent these instances the O/A will for term of tenancy plus 3
to SSA from EIV for Check accuracy of note on the copy of the report years.
the SSA identity test. data entry, e.g., retained in the “Failed EIV
numbers not Pre-Screening Report” master
Identifies tenants who transposed in SSN. file that tenant(s) is exempt
need to disclose a from SSN requirements.
SSN, e.g., replace Contact tenant and
TRACS generated id confirm to verify Note: If a tenant’s information
number. discrepant personal was corrected at the time of
identifiers recertification but the EIV data
See Section has not yet been updated, this
VII.B.2.c.(1) Correct TRACS data must be noted on the printed
within 30 days of the report and no further action is
date of the report. required.
Failed X Monthly Failed Verification Report Master file
Verification (Failed SSA Identity Test) Retain copy of report in a
Follow up with tenants report documented with action mater “Failed EIV SSA
Report (Failed identified on the report taken to resolve invalid or Identity Test” file for 3 years.
SSA Identity where discrepant discrepant personal identifiers
Test) personal identifiers Tenant file
were not corrected at Note: If a tenant’s information Documentation to verify
Identifies tenants the time of was corrected at the time of discrepant personal identifiers
whose personal recertification. recertification but the EIV data for term of tenancy plus 3
identifiers (last name, has not yet been updated, this years.
date of birth, SSN) do Check accuracy of must be noted on the printed
not match the SSA data entry, e.g., report and no further action is .
database. numbers not required.
transposed in SSN.
See Section
VII.B.2.c.(2) Contact tenant and
confirm to verify
discrepant personal
identifiers.
Correct TRACS data
within 30 days of the
date of the report.
*TSP = Tenant Selection Plan P&P = Policies and Procedures
73
Attachment 6: Use of EIV Reports
USE OF EIV REPORTS
REPORT *UPDATE O/A REPORT USE FILE DOCUMENTATION RETENTION
TSP P&P
VERIFICATION REPORTS Cont’d.
Note: A form HUD-9887 is not required to view and/or use verification reports.
Deceased Tenants X At least quarterly Deceased Tenants Report Master file
Report Retain copy of report in a
Confirm, in writing, Documentation obtained to master “Deceased Tenants
Identifies tenants with head of resolve discrepancy. Report” file for 3 years.
reported by SSA as household, next of kin
being deceased. or contact person or Form HUD-50059 with change Tenant file
entity provided by the of family composition. Form HUD-50059 and/or form
See Section VII.B.2.d tenant to determine HUD-50059-A plus any other
whether or not the Form HUD-50059-A for move- documentation received for a
person is deceased. out. particular tenant must be
retained for term of tenancy
If deceased, within 30 Note: If action was taken to plus 3 years.
days from date of remove the deceased tenant
report: from the household or to
Update family terminate tenancy of a
composition, and, deceased single member of a
if applicable, household at the time of
income and recertification but the EIV data
allowance, on the has not yet been updated, this
form HUD-50059. must be noted on the printed
See Paragraph 7- report and no further action is
13D of Handbook required.
4350.3 REV-1 for
effective date.
Single member of
a household,
process move-out
using form HUD-
50059-A.
Effective date
retroactive to
earlier of 14 days
after date of death
or date unit
vacated.
Note: Overpayment
of subsidy must be
returned to HUD.
Any discrepant data in
TRACS must be
updated within 30 days
from the date of the
report.
Encourage tenant to
contact SSA if SSA’s
data is incorrect.
*TSP = Tenant Selection Plan P&P = Policies and Procedures
74
Attachment 7: EIV Income Report Information
a. TRACS certification information
b. Personal Identifiers: name, date of birth and SSN
c. Employment information
1. New Hire Information (W-4)
(a) Date hired
(b) Employer name
2. Employer name, address and employer identification number (current and past
employers)
3 Quarterly earnings
d. Quarterly unemployment compensation
e. Social Security benefit information
1. Social Security benefits (SS)
(a) Payment status code
(b) Date of current entitlement
(c) Current net monthly benefit amount (if payable)
(d) Gross monthly benefit history (last 8 changes in benefit amount)
(e) Lump sum payment amount and date
(f) Payee name and address
2. Dual Entitlement (Social Security benefits under another person’s SSN)
3. Supplemental Security Income (SSI)
(a) Payment status code
(b) Alien indicator
(c) Current net monthly benefit amount
(d) Current monthly state supplement benefit amount
(e) Gross monthly benefit history (last 8 changes in benefit amount)
(f) Payee name and address
4. Medicare data
(a) Payee name and address
(b) Monthly hospital insurance premium amount, buy-in status and buy-in start and
end dates
(c) Monthly supplemental medical insurance premium amount, buy-in status and
buy-in start and end dates
5. Disability status and onset date
All EIV Income Reports contain the date the report was generated and by whom and the date
EIV received each type of information.
75
Attachment 8: MOR Findings for EIV Compliance (List is not all inclusive)
What is considered a Management and Occupancy Review
(MOR) Finding?
(Mandatory EIV Use)
1. O/A does not have access to EIV
2. O/A is not using EIV for recertifications effective June 1, 2010
3. Missing/incomplete EIV documents as listed on the Addendum C.
(Email HUD Headquarters immediately to Terminate the coordinator’s/user’s
access at the following address: mf alert@hud.gov)
Name, property, MOR date and missing documentation
Advise O/A mitigate and contact CA to reinstate 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 use of Existing Tenant
Search
9. EIV Income Reports are not in tenant files as third party verification
10. Tenant files do not have documentation to support EIV income discrepancy
resolution
11. O/A is not using Existing Tenant Search
12. O/A is not reviewing New Hires Report
13. Unresolved Failed Verification (SSA Identity Test) and Pre-screening
discrepancies
14. Deceased Tenants Report has not been reviewed and/or errors corrected
15. Multiple Subsidy Report has not been reviewed and/or errors corrected
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
waiting list to move-in and at annual recertification
19. Individuals having access to the EIV system or data had annual security training
20 O/A is sharing access Ids and passwords
76
Source: Legislative text reproduced verbatim
Plain English
Housing Notice H 2010-10 makes use of HUD's Enterprise Income Verification (EIV) system mandatory for Owners and Management Agents (O/As) of covered multifamily housing programs, effective January 31, 2010. The system cross-references tenant-reported income against Social Security Administration and National Directory of New Hires data to help ensure that rental subsidies are calculated accurately. Unauthorized disclosure of EIV data carries criminal penalties, including fines and imprisonment, while failure to use the system can result in a five-percent reduction in voucher payments.
Written by anthropic/claude-sonnet-4.6 · Reviewed on October 7, 2026
Plain English — not legal advice.
For Property Managers
Under Housing Notice H 2010-10, compliant operators maintain active EIV access, incorporate the Existing Tenant Search into their Tenant Selection Plan, and document written policies for using all EIV reports. At each annual and interim recertification, operators print and retain the Income Report, Summary Report, and Income Discrepancy Report, and investigate any discrepancy of $2,400 or more. Operators who are found non-compliant during a Management and Occupancy Review face a five-percent voucher payment reduction and must cure the finding within 30 days to avoid being flagged in HUD's Active Partners Performance System.
General guidance for property managers — not legal advice for your specific situation. Consult an attorney for advice on your case.
For Tenants
Housing Notice H 2010-10 establishes that O/As may not take adverse action against a tenant based solely on EIV data; independent third-party verification is required before any rent adjustment or repayment demand is made. If EIV shows income that a tenant believes is inaccurate, the tenant can dispute it in writing, and the O/A must seek verification directly from the source. Tenants who believe their rights under this notice have been violated may contact their local HUD field office, consult a HUD-approved housing counseling agency, or seek guidance from a tenant-rights organization.
General guidance for tenants — not legal advice for your specific situation. Consult a tenant-rights organization or attorney for advice on your case.
Generated October 7, 2026 — auto-generated, not yet human-reviewed. See /transparency for methodology.
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