HUD PIH Notice § 2010-19
Administrative Guidance for Effective and Mandated Use of the Enterprise Income Verification (EIV) System (HUD PIH Notices)
HUD guidance — not codified law
In Force
Verified 10/14/2026 · Next check 10/21/2026
effective 10/14/2026FederalAffordable Housing ProgramsOperative Text
HUD PIH Notice § 2010-19
____________________________________________________________________________
__
Special Attention of: Notice PIH 2010 - 19
(HA)
Public Housing and Section 8 Program Administrators,
Public Housing Hub Office Directors; Public Housing Issued: May 17,
2010
Resident Management Corporations; Resident Councils;
Applicants and Participants of Public Housing, Housing
Choice Voucher, Section 8 Moderate Rehabilitation, Expires: May 31, 2011
and Project-Based Certificate and Voucher Programs
_____________________________
Cross References: 24 CFR
§5.233,
24 CFR §5.236, 24 CFR §908.101
SUBJECT: Administrative Guidance for Effective and Mandated Use of the
Enterprise Income Verification (EIV) System
1. Purpose: This Notice provides Public Housing Agencies (PHAs) with
administrative guidance related to the mandated use of HUD’s Enterprise
Income Verification (EIV) system, as required in accordance with the new
HUD regulation, 24 CFR §5.233, as issued in the Final Rule: Refinement
of Income and Rent Determination Requirements in Public and Assisted
Housing Programs: Implementation of the Enterprise Income Verification
System-Amendments, effective January 31, 2010, as published at 74 FR
68924, on December 29, 2009.
2. Applicability: This Notice applies to the following HUD-PIH rental
assistance programs: Public Housing, Section 8 Moderate Rehabilitation,
Project-Based Voucher, Project-Based Certificate, and Housing Choice
Voucher (HCV) Programs.
3. Background: On December 29, 2009, HUD issued the final rule entitled
Refinement of Income and Rent Determination Requirements in Public and
Assisted Housing Programs: Implementation of the Enterprise Income
Verification (EIV) System-Amendments, which requires PHAs to use the EIV
system in its entirety to verify tenant employment and income information
during mandatory reexaminations of family composition and income; and
reduce administrative and subsidy payment errors in accordance with 24
CFR §5.236 and administrative guidance issued by HUD.
Using EIV as an upfront income verification (UIV) technique will be
valuable in validating tenant-reported income during interim and annual
reexaminations of family income; as well as streamlining the income
verification process. This will result in less administrative burden in
complying with third party verification requirements. Additionally, EIV
will help to identify and cure inaccuracies in housing subsidy
determinations, which will benefit PHAs, tenants, and taxpayers by
ensuring that the level of benefits provided on behalf of families is
proper and will prevent fraud and abuse within Public and Indian Housing
(PIH) rental assistance programs.
4. Effective Date: This Notice is effective as of issuance date.
5. The New HUD Regulation: 24 CFR 5.233. Effective January 31, 2010, all
PHAs are required to use the EIV system in its entirety. This means that
PHAs must use all features of the EIV system to:
a. Verify tenant employment and income information during mandatory
reexaminations of family composition and income in accordance with
24 CFR §5.236, and HUD administrative guidance; and
b. Reduce administrative and subsidy payment errors in accordance with
HUD administrative guidance.
6. What is the EIV System? The EIV System is a web-based application,
which provides PHAs with employment, wage, unemployment compensation and
social security benefit information of tenants who participate in the
Public Housing and various Section 8 programs under the jurisdiction of
the Office of Public and Indian Housing (PIH). This system is available
to all PHAs nationwide. Information in EIV is derived from computer
matching programs initiated by HUD with the Social Security
Administration (SSA) and the U.S. Department of Health and Human Services
(HHS), for all program participants with valid personal identifying
information (name, date of birth (DOB), and social security number (SSN))
reported on the form HUD-50058.
All PHAs are required to review the EIV Income Report of each family
before or during mandatory annual and interim reexaminations of family
income and/or composition to reduce tenant under reporting of income and
improper subsidy payments. EIV is classified as an UIV technique (or
automated written third party verification), which helps to identify
income sources and/or amounts that the tenant may not have disclosed.
This UIV technique in many instances will reduce the need to mail or fax
third party verification request forms to an income source. EIV also
provides various reports to assist PHAs with the following:
a. Identifying tenants whose reported personal identifiers do not match
the SSA database;
b. Identifying tenants who need to disclose a SSN;
c. Identifying tenants whose alternate identification number (Alt ID)
needs to be replaced with a SSN;
d. Identifying tenants who may not have reported complete and accurate
income information;
e. Identifying tenants who have started a new job;
f. Identifying tenants who may be receiving duplicate rental
assistance;
g. Identifying tenants who are deceased and possibly continuing to
receive rental assistance;
h. Identifying former tenants of PIH rental assistance programs who
voluntarily or involuntarily left the program and have a reportable
adverse status and/or owe money to a PHA or Section 8 landlord.
7. How to obtain access to the EIV System. All PHA staff (including PHA-
hired management agents), who have a need to access the EIV system, is
required to complete and submit the EIV Access Authorization Form & Rules
of Behavior and User Agreement to their designated EIV Coordinator in the
local HUD office.
The form is available online at:
http://www.hud.gov/offices/pih/programs/ph/rhiip/uivsystem.cfm.
The user’s access must be approved by the PHA Executive Director or
designee in order for the local HUD office to process all EIV access
requests. Individuals who will not directly access the EIV system, but
will have access to the EIV data in printed or electronic form is also
required to complete the EIV Access Authorization Form & Rules of
Behavior and User Agreement and maintain on file (do not submit the form
to the local HUD office).
8. The Verification Hierarchy. PHAs should begin with the highest level of
verification techniques.
PHAs are required to access the EIV system and obtain an Income Report
for each household. The PHA is required to maintain the Income Report in
the tenant file along with the form HUD-50058 and other supporting
documentation to support income and rent determinations for all mandatory
annual reexaminations of family income and composition.
If the Income Report does not contain any employment and income
information for the family, the PHA should attempt the next lower level
verification technique, as noted in the below chart.
|Level|Verification Technique |Ranking |
|6 |Upfront Income Verification |Highest (Mandatory) |
| |(UIV) using HUD’s Enterprise| |
| |Income Verification (EIV) | |
| |system (not available for | |
| |income verifications of | |
| |applicants) | |
|5 |Upfront Income Verification |Highest (Optional) |
| |(UIV) using non-HUD system | |
|4 |Written third Party |High (Mandatory to supplement |
| |Verification |EIV-reported income sources and when |
| | |EIV has no data; Mandatory for |
| | |non-EIV reported income sources; |
| | |Mandatory when tenant disputes |
| | |EIV-reported employment and income |
| | |information and is unable to provide |
| | |acceptable documentation to support |
| | |dispute) |
|3 |Written Third Party |Medium-Low (Mandatory if written |
| |Verification Form |third party verification documents |
| | |are not available or rejected by the |
| | |PHA; and when the applicant or tenant|
| | |is unable to provide acceptable |
| | |documentation) |
|2 |Oral Third Party |Low (Mandatory if written third party|
| |Verification |verification is not available) |
|1 |Tenant Declaration |Low (Use as a last resort when unable|
| | |to obtain any type of third party |
| | |verification) |
Note: This verification hierarchy applies to income determinations for
applicants and participants. However, EIV is not available for
verifying income of applicants.
Verification Technique Definitions
Third Party Verification Techniques
Upfront Income Verification (UIV) (Level 6/5): The verification of
income before or during a family reexamination, through an independent
source that systematically and uniformly maintains income information in
computerized form for a number of individuals.
It should be noted that the EIV system is available to all PHAs as a UIV
technique. PHAs are encouraged to continue using other non-HUD UIV
tools, such as The Work Number (an automated verification system) and
state government databases, to validate tenant-reported income.
Written Third Party Verification (Level 4): An original or authentic
document generated by a third party source dated either within the 60-day
period preceding the reexamination or PHA request date. Such
documentation may be in the possession of the tenant (or applicant), and
is commonly referred to as tenant-provided documents. It is the
Department’s position that such tenant-provided documents are written
third party verification since these documents originated from a third
party source. The PHA may, at its discretion, reject any tenant-provided
documents and follow up directly with the source to obtain necessary
verification of information.
Examples of acceptable tenant-provided documentation (generated by a
third party source) include, but are not limited to: pay stubs, payroll
summary report, employer notice/letter of hire/termination, SSA benefit
verification letter, bank statements, child support payment stubs,
welfare benefit letters and/or printouts, and unemployment monetary
benefit notices.
Current acceptable tenant-provided documents must be used for income and
rent determinations.
The PHA is required to obtain at a minimum, two current and consecutive
pay stubs for determining annual income from wages. For new income
sources or when two pay stubs are not available, the PHA should project
income based on the information from a traditional written third party
verification form or the best available information.
Note: Documents older than 60 days (from the PHA interview/determination
or request date) is acceptable for confirming effective dates of income.
Written Third Party Verification Form (Level 3): Also, known as
traditional third party verification. A standardized form to collect
information from a third party source. The form is completed by the
third party by hand (in writing or typeset). PHAs send the form directly
to the third party source by mail, fax, or email.
It is the Department’s position that the administrative burden and risk
associated with use of the traditional third party verification form may
be reduced by PHAs relying on acceptable documents that are generated by
a third party, but in the possession of and provided by the tenant (or
applicant). Many documents in the possession of the tenant are derived
from third party sources (i.e. employers, federal, state and/or local
agencies, banks, etc.).
The Department recognizes that third party verification request forms
sent to third party sources often are not returned. In other instances,
the person who completes the verification form may provide incomplete
information; or some tenants may collude with the third party source to
provide false information; or the tenant intercepts the form and provides
false information.
The Department requires PHAs to rely on documents that originate from a
third party source’s computerized system and/or database, as this process
reduces the likelihood of incorrect or falsified information being
provided on the third party verification request form. The use of
acceptable tenant-provided documents, which originate from a third party
source, will improve the integrity of information used to determine a
family’s income and rent and ultimately reduce improper subsidy payments.
This verification process will also streamline the income verification
process.
Oral Third Party Verification (Level 2): Independent verification of
information by contacting the individual income/expense source(s), as
identified through the UIV technique or identified by the family, via
telephone or in-person visit. PHA staff should document in the tenant
file, the date and time of the telephone call (or visit to the third
party), the name of the person contacted and telephone number, along with
the confirmed information.
This verification method is commonly used in the event that the
independent source does not respond to the PHA’s faxed, mailed, or e-
mailed request for information in a reasonable time frame, i.e., ten (10)
business days.
Non-Third Party Verification Technique
Tenant Declaration (Level 1): The tenant submits an affidavit or
notarized statement of reported income and/or expenses to the PHA. This
verification method should be used as a last resort when the PHA has not
been successful in obtaining information via all other verification
techniques. When the PHA relies on tenant declaration, the PHA must
document in the tenant file why third party verification was not
available.
Exceptions to Third Party Verification Requirements
HUD is aware that in some situations, third party verification is not
available for a variety of reasons. Oftentimes, the PHA may have made
numerous attempts to obtain the required verifications with no success, or
it may not be cost effective to obtain third party verification of income,
assets, or expenses, when the impact on total tenant payment is minimal.
In these cases, the PHA is required to document in the family file the
reason(s) why third party verification was not available.
The exception to third party verification can be found at 24 CFR
§960.259(c)(1) and §982.516(a)(2), which states, “The PHA must obtain and
document in the family file third party verification of the following
factors, or must document in the file why third party verification was
not available.”
9. Third party verification requirements. In accordance with 24 CFR
§960.259(c)(1) and 24 CFR §982.516(a)(2) for the Public Housing and the
HCV programs, respectively, the PHA must obtain and document in the
tenant file third party verification of the following factors, or must
document in the tenant file why third party verification was not
available: (i) reported family annual income; (ii) the value of assets;
(iii) expenses related to deductions from annual income; and (iv) other
factors that affect the determination of adjusted income.
10. How to comply with and reduce administrative burden of third party
verification requirements of family annual income. PHAs can comply with
and reduce administrative burden of third party verification requirements
for employment, wage, unemployment compensation and social security
benefits, and any other information that is verifiable using EIV by:
a. Reviewing the EIV Income Report to confirm/validate tenant-
reported income; and
b. Printing and maintaining an EIV Income Report (or an EIV
Individual Control Number (ICN) page for interim reexaminations
as prescribed in Section 12 of this Notice) in the tenant file;
and
c. Obtaining current acceptable tenant-provided documentation to
supplement EIV information; and
d. Using current tenant-provided documentation and/or third party
verification to calculate annual income.
Note: Social Security benefit information in EIV is updated every
three months. If the tenant agrees with the EIV-reported
benefit information, PHAs do not need to obtain or request a
benefit verification letter from the tenant. See PIH Notice 2010-
03 for guidance on verifying Social Security benefit income
through the EIV system.
The PHA may also reduce the administrative burden of obtaining third
party verification by relying on acceptable documents that are generated
by a third party, but provided by the tenant. Many documents in the
possession of the tenant are derived from third party sources (i.e.
employers, federal, state and/or local agencies, banks, etc.).
11. When the PHA is required to request written third party verification
The PHA must request written third party verification under the following
circumstances:
a. When the tenant disputes the EIV information and is unable to
provide acceptable documentation to support his/her dispute (24 CFR
§5.236(b));
b. When the PHA requires additional information that is not available
in EIV and/or the tenant is unable to provide the PHA with current
acceptable tenant-provided documentation. Examples of additional
information, includes but is not limited to:
i. Effective dates of income (i.e. employment, unemployment
compensation, or social security benefits)
ii. For new employment: pay rate, number of hours worked per
week, pay frequency, etc.
iii. Confirmation of change in circumstances (i.e. reduced hours,
reduced rate of pay, temporary leave of absence, etc.)
Note: 24 CFR §5.236(a), prohibits PHAs from taking adverse action based
solely on EIV information.
12. Type of file documentation required to demonstrate PHA compliance with
mandated use of EIV as a third party source to verify tenant employment
and income information (24 CFR §5.233(a)(2)(i)).
A. For each new admission (form HUD-50058 action type 1), the PHA is
required to do the following:
i. Review the EIV Income Report to confirm/validate family-
reported income within 120 days of the PIC submission date;
and
ii. Print and maintain a copy of the EIV Income Report in the
tenant file; and
iii. Resolve any income discrepancy with the family within 60 days
of the EIV Income Report date.
B. For each historical adjustment (form HUD-50058 action type 14), the
PHA is required to do the following:
i. Review the EIV Income Report to confirm/validate family-
reported income within 120 days of the PIC submission date;
and
ii. Print and maintain a copy of the EIV Income Report in the
tenant file; and
iii. Resolve any income discrepancy with the family within 60 days
of the EIV Income Report date.
C. For each interim reexamination (form HUD-50058 action type 3) of
family income and composition, the PHA is required to have the
following documentation in the tenant file:
i. ICN Page when there is no household income discrepancy noted
on the household’s Income Discrepancy Report tab or Income
Discrepancy Report. (PHAs have the discretion to print the
EIV Income report, however, only the ICN page is required.)
See sample screen shot below.
[pic]
Note: The ICN Page is available from the Summary Report tab.
See sample
screen shot below:
[pic]
ii. EIV Income Report when there is an income discrepancy noted
on the household’s Income Discrepancy Report tab or Income
Discrepancy Report. See sample screen shot below.
[pic]
D. For each annual reexamination of family income and composition,
the PHA is required to have the following documentation in the
tenant file:
i. No Dispute of EIV Information: EIV Income Report, current
acceptable tenant-provided documentation, and if necessary
(as determined by the PHA), traditional third party
verification form(s). See examples 1 and 3 below.
ii. Disputed EIV Information: EIV Income report, current
acceptable tenant-provided documentation, and/or traditional
third party verification form(s) for disputed information.
See example 2 below.
iii. Tenant-reported income not verifiable through EIV system:
Current tenant-provided documents, and if necessary (as
determined by the PHA), traditional third party verification
form(s). See example 3 below.
Example 1: No Disputed EIV Information & Tenant Provided Documents
You are conducting an annual reexam with tenant, Mary Jones. Ms.
Jones reports that she is employed at the ABC Box Company. You pull up
the EIV income report for the Jones family, which shows quarterly
wages from the ABC Box Company for the full year of 2008, and the
first two quarters of 2009. Last year’s (2009) annual reexam reflects
wages from the same employer. There is no other income information on
the report.
The PHA may streamline the income verification process by requesting
Ms. Jones provide current pay stubs dated within the last 60 days of
the interview or PHA request date. The PHA must obtain a minimum of
two current and consecutive pay stubs from Ms. Jones. Since there is
no disparity between tenant-reported and EIV-reported income, the PHA
may obtain original and current tenant-provided pay stubs to calculate
annual income.
The PHA may not use quarterly EIV wage (or unemployment benefit)
information to calculate annual income since this information is at
least six months old and more current income information (from pay
stubs) is available.
Example 2: Disputed EIV Information & No Tenant-Provided Documents
You are conducting an annual reexam with tenant, Bob Miller. Mr.
Miller reports that his only source of income is monetary support from
his sister, Betty Miller. You pull up the EIV income report for the
Miller family, which shows quarterly wages from the Home Depot for the
full year of 2008, and the first two quarters of 2009. There is no
other income information on the EIV report. Last year’s (2009) annual
reexam reflects no wage information and only source of income is other
non-wage income (monetary support from family member).
You inform Mr. Miller that the EIV system shows wages from the Home
Depot and ask him to provide you with current pay stubs. Mr. Miller
states that he does not work there and has no pay stubs.
Because Mr. Miller disputes the EIV-reported income and is unable to
provide documents to support his dispute, the PHA must request written
third party verification from Home Depot. You mail a third party
verification request form to the address listed for Home Depot.
A few days later, you receive the third party verification request
form back from Home Depot, which indicates that Mr. Miller has been
employed there since January 5, 2008, and a payroll summary report,
showing Mr. Miller’s bi-weekly gross and net pay since January 2008.
Since the disputed EIV information has been confirmed to be correct by
the independent third party source (Home Depot), the PHA will use the
income information from the payroll summary report to calculate annual
income. The PHA would also calculate the retroactive rent (using the
information provided by Home Depot) since Mr. Miller failed to
disclose his employment at the 2008 and 2009, annual reexams. The PHA
would also inform Mr. Miller of this retroactive rent and take action
according to PHA-established policies.
Example 3: Tenant Unreported Income, Income not Verifiable through
EIV & Tenant- Provided Documents
You are conducting an annual reexam with tenant, Sharon Duvet. Ms.
Duvet reports that her only source of income is child support and
provides you with four current and consecutive child support pay
stubs. You pull up the EIV Income Report for the Duvet family, which
shows: hire date at the District Police Department effective January
9, 2005; quarterly wages from the District Police Department for the
full years of 2005, 2006, 2007, and 2008, and the first two quarters
of 2009. There is no other income information on the EIV Income
Report. Last year’s (2009) annual reexam reflects income from only
child support. You inform Ms. Duvet that the EIV system is showing
wages from the District Police Department and you ask her to provide
you with current pay stubs. Ms. Duvet admits that she has been
working at the District Police Department and indicates that she can
provide you with current pay stubs. You inform Ms. Duvet that you will
also have to calculate her retroactive rent for the previous years in
which she did not disclose her employment. You go over the EIV-
reported wages with Ms. Duvet and she indicates that she does not
dispute the information.
Since Ms. Duvet does not dispute the EIV-reported information, the PHA
may use the tenant provided documents to calculate income and rent for
the 2010 annual reexam, and use the EIV-reported earnings for years
2005 through 2008, to calculate the retroactive rent Ms. Duvet will
owe. The PHA should require Ms. Duvet to provide her last pay stub
from 2009, or her 2009 W- 2, to calculate the retroactive rent for
2009. The PHA will use the tenant-provided child support pay stubs
(child support income is not available in EIV) to calculate annual
income from this source.
13. What if the tenant does not provide the PHA with requested information?
If the tenant does not provide the requested information, the PHA may
mail or fax a third party verification request form to the third party
source. The PHA is required to request third party verification when the
tenant disputes EIV information and the tenant is unable to provide
acceptable documentation to support disputed information. However, the
PHA should also remind the tenant that s/he is required to supply any
information requested by the PHA for use in a regularly scheduled annual
or interim reexamination of family income and composition.
The PHA may determine that the tenant is not in compliance with program
requirements and terminate tenancy or assistance, or both, if the tenant
fails to provide the requested information in a timely manner (as
prescribed by the PHA).
14. How to use EIV to reduce administrative and subsidy payment errors.
EIV has the ability to identify other potential issues which may impact a
family’s level of assistance. EIV contains stand-alone reports, which a
PHA may generate at any time (i.e. Deceased Tenants Report, New Hires
Report, Multiple Subsidy Report, Identity Verification Report, Income
Discrepancy Report, Debts Owed to PHAs & Termination Report, and
Immigration Report). However, it should be noted that the information
from these stand-alone reports are contained in the Income Report for
each household. PHAs are required to address any and all potential
issues at the time of the annual or interim reexam, as conveyed in the
Income Report.
PHAs may use the stand-alone reports to monitor staff’s progress in
reducing the following administrative and subsidy payment errors by using
the listed reports:
a. Incorrect/invalid SSNs/name/date of birth – Identity Verification
Report
b. Follow-up with families who need to disclose a SSN – Immigration
Report
c. Duplicate rental assistance – Multiple Subsidy Report
d. Unreported increase in income – Income discrepancy Report
e. Improper payments on behalf of deceased tenants – Deceased Tenants
Report
f. Unreported new employment (PHAs with interim increase policy) – New
Hires Report
g. Adverse Termination/Outstanding Debt to PHA – Debts Owed to PHAs &
Termination Search
In order to ensure PHAs are aware of potential subsidy payment errors,
PHAs are required to monitor the following EIV reports on a monthly
basis:
1. Deceased Tenants Report
2. Identity Verification Report
3. Immigration Report
In order to ensure PHAs are aware of potential subsidy payment errors,
PHAs are required to monitor the following EIV reports on a quarterly
basis:
1. Income Discrepancy Report
2. Multiple Subsidy Report
3. New Hires Report (if your agency has an interim increase policy)
15. How to use the EIV Income Report as a third party source to verify
tenant employment and income information. The EIV Income Report provides
a variety of information about each household member of the family. The
report contains the following information for each household member:
a. Personal identifiers: name, date of birth, and SSN
b. Identity verification status (pending, verified, deceased, or
failed)
c. Employment information
1. New Hire Information (W-4)
i. Date hired
ii. Employer name
2. Employer name, address, and employer identification number of
current and past employers
3. Quarterly earnings
d. Quarterly unemployment compensation
e. Social Security benefit information
1. Social Security (SS) benefits
i. Payment status code
ii. Date of current entitlement
iii. Current net monthly benefit amount (if payable)
iv. Gross monthly benefit history (last 8 changes in benefit
amount)
v. Lump sum payment amount and date
vi. Payee name and address
2. Dual Entitlement (Social Security benefits under another
person’s SSN)
i. Claim Number (the other person’s SSN)
ii. Payment status code
iii. Date of current entitlement
iv. Current net monthly benefit amount (if payable)
v. Gross monthly benefit history (last 8 changes in benefit
amount)
vi. Payee name and address
3. Supplemental Security Income (SSI)
i. Payment status code
ii. Alien indicator
iii. Current net monthly benefit amount
iv. Current monthly state supplement benefit amount (if
available)
v. Gross monthly benefit history (last 8 changes in benefit
amount)
vi. Payee name and address
4. Medicare data
i. Payee name and address
ii. Monthly hospital insurance premium amount, buy-in
status, and buy-in start and end dates
iii. Monthly supplemental medical insurance premium amount,
buy-in status, and buy-in start and end dates
f. Disability status and onset date
g. Identity verification status
h. Indicator of possible multiple rental subsidy
i. Indicator of debt and/or termination information from another PHA
(effective September 2010)
All EIV Income Reports contain the date the report was generated and by
whom; and the date EIV received each type of information.
To minimize tenant underreporting of income, PHAs are required to obtain
an EIV Income Report for each family any time the PHA conducts an annual
or interim reexamination of family income and composition.
In accordance with 24 CFR §5.236(b)(2)(3), PHAs are required to compare
the information on the EIV report with the family-reported information.
If the EIV report reveals an income source that was not reported by the
tenant or a substantial difference in the reported income information,
the PHA is required to take the following actions:
1. Discuss the income discrepancy with the tenant; and
2. Request the tenant to provide any documentation to confirm or
dispute the unreported or underreported income and/ or income
sources; and
3. In the event the tenant is unable to provide acceptable
documentation to resolve the income discrepancy, the PHA is
required to request from the third party source, any information
necessary to resolve the income discrepancy; and
4. If applicable, determine the tenant’s underpayment of rent as a
result of unreported or underreported income, retroactively*; and
5. Take any other appropriate action as directed by HUD or the PHA’s
administrative policies.
*The PHA is required to determine the retroactive rent as far back as the
existence of complete file documentation (form HUD-50058 and supporting
documentation) to support such retroactive rent determinations.
Note: A substantial difference is defined as an amount equal to or
greater than $2,400, annually.
The tenant must be provided an opportunity to contest the PHA’s
determination of tenant rent underpayment. HUD regulations require PHAs
to promptly notify tenants in writing of any adverse findings made on the
basis of the information verified through the aforementioned income
discrepancy resolution process. The tenant may contest the findings in
accordance with the PHA’s established grievance procedures, as required
by HUD. The PHA may not terminate, deny, suspend, or reduce the family’s
assistance until the expiration of any notice or grievance period.
When there is an unsubstantial or no disparity between tenant-reported
and EIV-reported income information, the PHA is required to obtain from
the tenant, any necessary documentation to complete the income
determination process. As noted previously, the PHA may reject any
tenant-provided documentation, if the PHA deems the documentation
unacceptable. The PHA may reject documentation provided by the tenant
for only the following HUD-approved reasons:
1. The document is not an original; or
2. The original document has been altered, mutilated, or is not
legible; or
3. The document appears to be a forged document (i.e. does not appear
to be authentic).
The PHA should explain to the tenant, the reason(s) the submitted
documents are not acceptable and request the tenant to provide additional
documentation. If at any time, the tenant is unable to provide
acceptable documentation that the PHA deems necessary to complete the
income determination process, the PHA is required to submit a traditional
third party verification form to the third party source for completion
and submission to the PHA.
If the third party source does not respond to the PHA’s request for
information, the PHA is required to document the tenant file of its
attempt to obtain third party verification and that no response to the
third party verification request was received.
The PHA should then pursue lower level verifications in accordance with
the verification hierarchy listed in section 8 of this notice.
16. Tenant Repayment Agreement. Tenants are required to reimburse the PHA
if they were charged less rent than required by HUD’s rent formula due to
the tenant’s underreporting or failure to report income. The tenant is
required to reimburse the PHA for the difference between the tenant rent
that should have been paid and the tenant rent that was charged. This
rent underpayment is commonly referred to as retroactive rent. If the
tenant refuses to enter into a repayment agreement or fails to make
payments on an existing or new repayment agreement, the PHA must
terminate the family’s tenancy or assistance, or both. HUD does not
authorize any PHA-sponsored amnesty or debt forgiveness programs.
All repayment agreements must be in writing, dated, signed by both the
tenant and the PHA, include the total retroactive rent amount owed,
amount of lump sum payment made at time of execution, if applicable, and
the monthly repayment amount. At a minimum, repayment agreements must
contain the following provisions:
a. Reference to the paragraphs in the Public Housing lease or Section
8 information packet whereby the tenant is in non-compliance and
may be subject to termination of tenancy or assistance, or both.
b. The monthly retroactive rent repayment amount is in addition to the
family’s regular rent contribution and is payable to the PHA.
c. The terms of the agreement may be renegotiated if there is a
decrease or increase in the family’s income.
d. Late and missed payments constitute default of the repayment
agreement and may result in termination of tenancy and/or
assistance.
PHAs are required to determine retroactive rent amount as far back as
the PHA has documentation of family reported income. For example, if
the PHA determines that the family has not reported income for a
period of five years and only has documentation for the last three
years, the PHA is only able determine retroactive rent for the three
years for which documentation is available.
The monthly retroactive rent payment plus the amount of rent the
tenant pays at the time the repayment agreement is executed should be
affordable and not exceed 40 percent of the family’s monthly adjusted
income. However, PHAs have the discretion to establish thresholds and
policies for repayment agreements in addition to HUD required
procedures.
Example:
• Family’s monthly adjusted income is $1,230.
• Family’s monthly rent payment 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 ($369 monthly rent + $123 repayment = $492, 40% of
the family’s monthly adjusted income.)
Repayment Time Period. The period in which the retroactive rent
balance will be repaid is based on the monthly payments and original
retroactive balance.
Example: The tenant agrees to repay $1,000, by making a monthly
payment of $25 for 40 months.
Repayment Options. Tenants have the option to repay the retroactive rent
balance as follows:
1. In a lump sum payment; or
2. Monthly installment; or
3. A combination of 1 and 2, above
a. For example, a tenant may owe $1,000, make a lump sum payment
of $300 and enter into a repayment agreement for the
remaining balance of $700.
17. How long should the PHA maintain EIV printouts in a tenant file? The
PHA’s record retention policy will determine the length of time the PHA
should maintain EIV printouts in a tenant file. PHAs are authorized to
maintain the EIV Income Report in the tenant file for the duration of
tenancy and no longer than three years from the end of participation
(EOP) date. In accordance with revised regulation, 24 CFR §908.101, PHAs
are required to maintain at a minimum, the last three years of the form
HUD-50058, and supporting documentation for all annual and interim
reexaminations of family income. All records are to be maintained for a
period of at least three years from the effective date of the action.
18. Disclosure of an Individual’s EIV Information. 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, unless the individual has provided written consent to disclose
such information.
However, the PHA is not prohibited from discussing with the head of
household (HOH) and showing the HOH how the household’s income and rent
were determined based on the total family income reported and verified.
EIV information and any other information obtained by the PHA for the
purpose of determining eligibility and level of assistance for a PIH
rental assistance program may not be disclosed to third parties for any
reason (even for similar verifications under other programs, such as
eligibility for low income housing tax credit units, other federal or
state assistance programs), unless the tenant has authorized such
disclosure in writing.
19. What to do if the EIV Information is incorrect.
Sometimes the source or originator of EIV information may make 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 the originator corrects the data, HUD will
obtain the updated information with its next computer matching process.
Below are the procedures tenants and PHAs should follow regarding
incorrect EIV information.
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’
National Directory of New Hires (NDNH) database.
If the tenant disputes this information, s/he 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 PHA with this written correspondence so
that it may be maintained in the tenant file. If employer resolution is
not possible, the tenant should contact the local SWA for assistance.
Unemployment benefit information reported in EIV originates from the
local SWA. If the tenant disputes this information, s/he 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 PHA with this written correspondence so that it
may be maintained in the tenant file.
SS and SSI benefit information reported in EIV originates from the SSA.
If the tenant disputes this information, s/he should contact the SSA at
(800) 772–1213, or visit the local SSA office. SSA office information is
available in the government pages of the local telephone directory or
online at http://www.socialsecurity.gov.
Note: The tenant may also provide the PHA with third party documents
which are in the tenant’s possession to support their dispute of
EIV information. The PHA, with the tenant’s consent, is required
to submit a third party verification form to third party sources
for completion and submission to the PHA, when the tenant disputes
EIV information and is unable to provide documentation to validate
the disputed information. The tenant’s failure to sign the consent
form is grounds for termination of tenancy and/or assistance in
accordance with 24 CFR §5.232.
Debts owed to PHAs and termination information reported in EIV originates
from the PHA. If a current or former tenant disputes this information,
s/he should contact the PHA (who reported the information) directly in
writing to dispute this information and provide any documentation that
supports the dispute. If the PHA determines that the disputed information
is incorrect, the PHA will update or delete the record from EIV. Former
tenants may dispute debt and termination information for a period of up
to three years from the end of participation date in the PIH program.
Identity Theft. Seemingly 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. However, a
person using an individual’s SSN can get other personal information about
that individual and apply for credit in that individual’s name. So, if
the tenant suspects someone is using his/her SSN, s/he should check their
Social Security records to ensure their records are correct (call SSA at
(800) 772-1213); file an identity theft complaint with the local police
department and/or Federal Trade Commission (call FTC at (877) 438-4338,
or visit their website at:
http://www.ftc.gov/bcp/edu/microsites/idtheft/); and s/he should also
monitor their credit reports with the three national credit reporting
agencies (Equifax, TransUnion, and Experian). The tenant should provide
the PHA written documentation of filed identity theft complaint. (Refer
back to paragraph on Employment and wage information regarding disputed
EIV information related to identity theft).
Tenants may request their credit report and place a fraud alert on their
credit report with the three national credit reporting agencies at:
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: www.equifax.com
Telephone: (800) 685-1111
Experian
P.O. Box 2104
Allen, TX 75013
Website: www.experian.com
Telephone (888) 397-3742
TransUnion
P.O. Box 6790
Fullerton, CA 92834
Website: www.transunion.com
Telephone: (800) 680-7289 or (800) 888-4213
20. Security of EIV Data. The data in EIV contains personal
information on individual tenants
which is protected under the Federal Privacy Act. The information in EIV
may only be used for limited official purposes, as noted below.
Official Purposes Include:
1. PHAs, in connection with the administration of PIH
programs, for verifying the employment and income at the time
of interim and annual reexaminations.
2. HUD staff for monitoring and oversight of PHA compliance
with HUD program requirements.
3. Independent Auditors hired by the PHA or HUD to perform a
financial audit for use in determining the PHA’s compliance
with HUD program requirements, including verifying income and
determining the accuracy of the rent and subsidy
calculations.
Restrictions on disclosure requirements for
Independent Auditors:
a) May only access EIV income information within family
files and only within the offices of the PHA or PHA-hired
management agent;
b) May not transmit or transport EIV income information in
any form;
c) May not enter EIV income information on any portable
media;
d) Must sign non-disclosure oaths that the EIV income
information will be used only for the purpose of the
audit; and
(e) May not 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.
B. Official Purposes Does NOT Include:
1. Sharing the information with governmental or private entities
not involved in the reexamination process specifically used
for PIH rental assistance programs.
Disclosing the EIV information to other private or public
entities for purposes other than determining eligibility and
level of assistance for PIH rental assistance programs is
prohibited since these entities are not a party to the
computer matching agreements with the HHS and SSA. The fact
that these entities may find the EIV beneficial for similar
eligibility and determination purposes for other low-income
housing programs or public benefits, does not permit these
entities 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. Specifically, sections
453(j)(7)(E)(ii) and (iv) of the Social Security Act (42 USC
§653j) limit disclosure of the data matched between HUD and
HHS’ National Directory of New Hires (NDNH) database to PHAs,
Independent Auditors, the Inspector General (IG) and Attorney
General, private owners, management agents, and contract
administrators of Multifamily Housing programs.
C. 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.
21. Penalties for Noncompliance with Mandated EIV System Use. PHAs may be
subject to sanctions and/or the assessment of disallowed costs associated
with any resulting incorrect subsidy or tenant rent calculation or both.
It should be noted that HUD may impose a sanction on any PHA who does not
have access to the EIV system or the PHA
has access to the system, however, has not used the system within the
last six months. To avoid sanctions or disallowed costs, PHAs should
follow all formal and informal guidance provided to PHAs via webcast
trainings, PIH Rental Housing Integrity Improvement Project (RHIIP)
periodic electronic mailings, and any other HUD Headquarters’-generated
guidance.
EIV System Tip Sheets (ETS). PHAs are required to comply with guidance
provided via ETS and HUD Headquarters-sponsored EIV training, via webcast
and satellite. PIH will also post ETS to the PIH RHIIP technical
assistance web pages at:
http://www.hud.gov/offices/pih/programs/ph/rhiip/training.cfm, and send
via email to all subscribers of the PIH RHIIP mailing list. ETS is
designed to explain effective use of the EIV system to ensure PHAs’
compliance with the third party verification requirements and reduce
administrative and subsidy payment errors, so that PHAs may avoid
penalties for failure to use the EIV system in its entirety.
22. EIV System Training Information. As a condition of initial and
continued access to the EIV System, HUD and PHA staff are required to
complete Annual Security Awareness training and EIV system training
(initial (complete system training) and update (interim system changes)
training) when offered by HUD Headquarters (HHQ). This training
requirement also applies to those individuals who will not access EIV,
but will view or handle printed and/or electronic EIV data. Individuals
who will view and/or handle printed EIV information are required to
complete only annual Security Awareness training (EIV system training is
optional for these individuals). EIV training provided by third parties
(other than HUD Headquarters) does not fulfill the mandatory EIV training
requirement.
HHQ offers training in Washington, DC and via webcast at least once a
year. EIV system users who need to complete EIV training may view EIV
training webcasts at: http://www.hud.gov/webcasts/archives/iv.cfm. HUD
offers a Certificate of Completion for a period of six months following
the broadcast date, for those who desire confirmation of completed
training.
However, it should be noted that a certificate is not required in order
for an individual to be granted access to the EIV system or be certified
for continued EIV system access. The most recent PIH RHIIP/EIV training
was held on January 28, 2010. EIV system users may request a Certificate
of Completion for this training through October 30, 2010.
Training information is posted at the following websites:
http://www.hud.gov/offices/pih/programs/ph/rhiip/training.cfm and is
emailed to all subscribers of the PIH RHIIP mailing list. To subscribe
to this mailing list, paste the following URL into your browser, enter
your email address, and click OK:
http://www.hud.gov/subscribe/signup.cfm?listname=Public%20and%20Indian%20H
ousing%20Rental%20Housing%20Integrity%20Improvement%20Project&list=PIH-
RHIIP-L
Instructions for requesting a Certificate of Completion is posted at
http://www.hud.gov/webcasts/archives/iv.cfm or
http://www.hud.gov/offices/pih/programs/ph/rhiip/training.cfm, and is
automatically emailed to all subscribers of the PIH RHIIP mailing list.
EIV system users must complete HHQ-offered training as follows:
|Training Offered |Training Must be Completed |
| |By |
|October 1st – March 31st|April 29th |
|April 1st – September |October 30th |
|30th | |
New employees, who begin employment after March 31st, are required to
complete the training by October 30th.
New employees, who begin employment after September 30th, are required to
complete the training by April 29th, of the following year.
Note: Employees must complete the training prior to accessing the EIV
system and/or printed EIV reports.
23. Updating of PHA Policies and Procedures. PHAs are required to
immediately implement all new and modified regulatory requirements of the
Refinement of Income and Rent Determination Requirements in Public and
Assisted Housing Programs: Implementation of the Enterprise Income
Verification System-Amendments.
The Department recognizes that many PHAs have already begun to modify
existing policies and procedures to reflect use of EIV during all
mandatory annual and interim reexams. PHAs should immediately update
their policies and procedures to reflect these new regulatory provisions.
24. Notice to Applicants and Tenants. PIH is providing PHAs with the
attached EIV system information guide that PHAs may provide to applicants
and tenants of PIH rental assistance programs. PHAs are not required to
distribute this document. However, PHAs are strongly encouraged to
provide applicants and tenants with the What You Should Know About EIV
Guide to educate families about EIV and inform them of how it affects
their family.
There are two versions of the document: 1) with a signature block; and 2)
without a signature block. HUD does not require applicants or tenants to
acknowledge receipt of the document; however, PHAs may, at their
discretion, require the family to acknowledge receipt of the guide. If
your PHA will require families to acknowledge receipt of the guide,
provide the family with a copy of the guide to take with them, and
maintain a signed copy in the family file folder.
The guide is a two page document or one double-side printed document. To
print the file on one page (if your printer has two-sided printing
capability), select Print Properties when printing the document, select 2-
Sided Print, Flip on Short Edge, and then print. This document is not
available for ordering from HUD. Simply click and print the guide.
[pic]
Currently, the guide is only available in English, however, in the future;
HUD may make this document available in other languages. As a subscriber
to the PIH RHIIP mailing list, you will automatically receive the guide in
other languages, when they become available.
Tip: Print on color paper to add a little flare!
25. Rental Housing Integrity Improvement Project (RHIIP)/EIV Resources.
For your convenience, PIH EIV information is available on the web at the
below listed URLs. Many of your questions can be answered by viewing
information that is posted on the HUD web pages. Bookmark these pages:
Overview of Upfront Income Verification (UIV) Technique:
http://www.hud.gov/offices/pih/programs/ph/rhiip/uiv.cfm
Training and Technical Assistance (including webcast training
materials):
http://www.hud.gov/offices/pih/programs/ph/rhiip/training.cfm
EIV System, Access Authorization Form, and User Manuals:
http://www.hud.gov/offices/pih/programs/ph/rhiip/uivsystem.cfm
Subscribe to PIH RHIIP Mailing list:
http://www.hud.gov/subscribe/signup.cfm?listname=Public%20and%20Indian%20H
ousing%20Rental%20Housing%20Integrity%20Improvement%20Project&list=PIH-
RHIIP-L
PIH EIV Webcasts Archives:
http://portal.hud.gov/portal/page/portal/HUD/webcasts/archives/iv
Latest EIV News:
http://www.hud.gov/offices/pih/programs/ph/rhiip/uivnewsflash.cfm
Income Discrepancy Resolution:
http://www.hud.gov/offices/pih/programs/ph/rhiip/indisres.cfm
Public Notices:
http://www.hud.gov/offices/pih/programs/ph/rhiip/pubnotices.cfm
Report Fraud, Waste & Abuse to HUD OIG:
http://www.hud.gov/offices/pih/programs/ph/rhiip/uivreporting.cfm
PIH Notices: http://www.hud.gov/offices/pih/publications/notices/
26. 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 USC §3520) and
assigned OMB control number(s) 2577-0083 and 2577-0266. 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.
27. For inquiries about this Notice contact: the designated EIV
Coordinator in the local HUD field office or Nicole Faison of HUD
Headquarters’ Office of Public and Indian Housing at (202) 475-7949, or
via email at PIH.RHIIP.TA@HUD.GOV.
/s/
Sandra B. Henriquez, Assistant Secretary for
Public and Indian Housing
Attachments:
1. What You Should Know About EIV Guide (with signature block)
2. What You Should Know About EIV Guide (without signature block)
-----------------------
[pic]
U.S. Department of Housing and Urban Development
Office of Public and Indian Housing
Click here to generate printer-friendly ICN page
Source: Legislative text reproduced verbatim
Plain English
PIH Notice 2010-19 requires Public Housing Agencies (PHAs) to use HUD's Enterprise Income Verification (EIV) system in its entirety, as mandated by 24 CFR §5.233, effective January 31, 2010. The system cross-references tenant-reported employment and income data against records from the Social Security Administration and the Department of Health and Human Services. When discrepancies arise, PHAs must follow a structured resolution process, and tenants who underreported income may owe retroactive rent. Unauthorized disclosure of EIV data can result in criminal penalties under Section 20 of the notice.
Written by anthropic/claude-sonnet-4.6 · Reviewed on October 14, 2026
Plain English — not legal advice.
For Property Managers
Under PIH Notice 2010-19, compliant PHAs pull an EIV Income Report for every household before or during each annual and interim reexamination, retain that report in the tenant file alongside form HUD-50058, and follow the six-level verification hierarchy described in Section 8. When EIV shows an income discrepancy of $2,400 or more annually, operators discuss the finding with the tenant, request supporting documentation, and pursue third-party verification if needed. PHAs that fail to use EIV as required risk sanctions and disallowed costs under Section 21 of the notice.
General guidance for property managers — not legal advice for your specific situation. Consult an attorney for advice on your case.
For Tenants
PIH Notice 2010-19 gives participants in Public Housing, Housing Choice Voucher, and related Section 8 programs the right to be notified in writing of any adverse income findings and to contest those findings through the PHA's grievance procedures before assistance is reduced or terminated. If EIV shows income information a tenant believes is wrong, Section 19 of the notice outlines steps for disputing data directly with the originating source—such as an employer, state workforce agency, or SSA. Tenants may consult a local tenant-rights organization or HUD-approved housing counselor to understand available options.
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 14, 2026 — auto-generated, not yet human-reviewed. See /transparency for methodology.
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