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Slide #1 © Copyright 2008 Nan McKay & Associates Annie Stevenson Managing EIV © Copyright 2008 Nan McKay & Associates.

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Presentation on theme: "Slide #1 © Copyright 2008 Nan McKay & Associates Annie Stevenson Managing EIV © Copyright 2008 Nan McKay & Associates."— Presentation transcript:

1 Slide #1 © Copyright 2008 Nan McKay & Associates Annie Stevenson Managing EIV © Copyright 2008 Nan McKay & Associates

2 Slide #2 © Copyright 2008 Nan McKay & Associates Welcome to Lunch N Learn!  Today’s topics: EIV update Annual reexam processing EIV reports HUD compliance monitoring

3 Slide #3 © Copyright 2008 Nan McKay & Associates Introduction

4 Slide #4 © Copyright 2008 Nan McKay & Associates Upfront Income Verification (UIV)  What is it? The verification of income, before or during a reexamination, through an independent source that systematically and uniformly maintains income information in computerized form for a large number of individuals

5 Slide #5 © Copyright 2008 Nan McKay & Associates Upfront Income Verification (UIV)  UIV is an extremely effective tool for error reduction  Before UIV, PHAs obtained third-party verification from income sources reported by applicants and participants

6 Slide #6 © Copyright 2008 Nan McKay & Associates Upfront Income Verification (UIV)  UIV enables PHAs to check a variety of income sources for all family members Regardless of income sources reported by applicants and participants

7 Slide #7 © Copyright 2008 Nan McKay & Associates Use of UIV for Verification  UIV is third-party verification Most preferred form Meets regulatory requirements  UIV is intended to streamline the verification process Eliminates the need for written third-party verification in many cases

8 Slide #8 © Copyright 2008 Nan McKay & Associates UIV Resources  UIV resources include: HUD’s EIV System State Wage Information Collection Agencies State TANF systems Credit Bureau Association (CBA) credit reports Internal Revenue Service (IRS) – Tax transcript  Request with IRS form 4506-T Private sector databases

9 Slide #9 © Copyright 2008 Nan McKay & Associates EIV Update

10 Slide #10 © Copyright 2008 Nan McKay & Associates HUD Guidance on EIV  2 HUD training webcasts on EIV 1/16/08 8/26/08  Webcasts are archived at m m

11 Slide #11 © Copyright 2008 Nan McKay & Associates HUD Guidance on EIV  Training materials from webcasts Powerpoints Case studies & solutions p/training.cfmhttp://www.hud.gov/offices/pih/programs/ph/rhii p/training.cfm

12 Slide #12 © Copyright 2008 Nan McKay & Associates HUD Guidance on EIV  8/26/08 webcast Comprehensive training on “Effective Use of EIV” Extensive discussion of EIV reports and their usage EIV sign-on now includes certification of EIV & security training

13 Slide #13 © Copyright 2008 Nan McKay & Associates 8/26/08 Webcast  Clarification that EIV is sufficient verification of SS/SSI if family agrees  PH flat rent families now excluded from income discrepancy report  Discussion of identity theft  Guidance on use of income discrepancy report

14 Slide #14 © Copyright 2008 Nan McKay & Associates NEW! HUD Guidance on EIV  HUD webcast 1/16/08 contained revised guidance on use of EIV Previous guidance is obsolete and has been removed from EIV website Webcast available at cfm cfm  4 hours

15 Slide #15 © Copyright 2008 Nan McKay & Associates HUD Guidance on EIV  EIV is sufficient as third-party verification when: The family does not dispute the data, and Current tenant-provided documents (i.e. paystubs) are available

16 Slide #16 © Copyright 2008 Nan McKay & Associates HUD Guidance on EIV  The PHA MUST obtain additional third- party verification when the family disputes EIV employer data

17 Slide #17 © Copyright 2008 Nan McKay & Associates HUD Guidance on EIV  The PHA MAY obtain additional third-party verification when the PHA determines that additional information is necessary, such as: Effective dates of employment Pay rate, hours worked for new jobs Confirmation of a change in circumstances (reduced hours, reduced rate of pay)

18 Slide #18 © Copyright 2008 Nan McKay & Associates HUD Guidance on EIV  Use tenant-provided documents to project annual income, unless: The family disputes EIV employer data, OR The PHA determines that additional information is necessary

19 Slide #19 © Copyright 2008 Nan McKay & Associates HUD Guidance on EIV  HUD recommends that tenant-provided documents should be dated within 60 days of interview date Current and consecutive

20 Slide #20 © Copyright 2008 Nan McKay & Associates HUD Guidance on EIV  Quote from webcast: “The PHA will use tenant-provided documents or most current information to calculate anticipated annual income.”  EIV quarterly wages are NOT used to project annual income

21 Slide #21 © Copyright 2008 Nan McKay & Associates HUD Guidance on EIV: File Documentation  If the family does not dispute EIV employer data, and the PHA determines that additional information is not necessary: EIV income details report  ICN in FL Tenant-provided documents

22 Slide #22 © Copyright 2008 Nan McKay & Associates HUD Guidance on EIV: File Documentation  If the family disputes, or PHA requires additional information: EIV printout (except in FL) Tenant-provided documents Third-party written verification

23 Slide #23 © Copyright 2008 Nan McKay & Associates EIV: Annual Reexams

24 Slide #24 © Copyright 2008 Nan McKay & Associates EIV Modules  Tenant Income Data  Income Discrepancy Report  Different data for different purposes

25 Slide #25 © Copyright 2008 Nan McKay & Associates Disclosure of EIV Data  PHAs may not disclose EIV data to any third parties (UIV data is property of HUD and protected by Federal Privacy Act)  PHAs in FL may not maintain HUD-provided UIV data in tenant files  PHAs may provide EIV data to the individual (only) to whom the record pertains  EIV data of minors may be provided to the minor’s parent or guardian

26 Slide #26 © Copyright 2008 Nan McKay & Associates EIV Tenant Income Data  Displays the most current data available 1 to 2 quarters old  Review for all families at annual reexam Can also be used for interim reexams  Meets regulatory requirement for third-party verification Per HUD guidelines

27 Slide #27 © Copyright 2008 Nan McKay & Associates EIV Tenant Income Data  Not available at admission Because family is not yet in PIC Data will be available within 90 days of admission  Data is updated quarterly

28 Slide #28 © Copyright 2008 Nan McKay & Associates EIV Tenant Income Data  Navigate to Household Summary Report screen Search by name, SSN or birth date  Note 3 tabs at top of screen Summary Report Income Report Income Discrepancy Report

29 Slide #29 © Copyright 2008 Nan McKay & Associates Household Summary

30 Slide #30 © Copyright 2008 Nan McKay & Associates Identity Verification Status  Displayed for each household member Verified: tenant SSN, last name, and date of birth combination has been verified by SSA Not Verified: tenant record has not been sent to SSA for verification yet

31 Slide #31 © Copyright 2008 Nan McKay & Associates Identity Verification Status Failed: tenant SSN, last name and date of birth combination verification failed by SSA Deceased: according to SSA records, the tenant with SSN, last name and date of birth combination is deceased

32 Slide #32 © Copyright 2008 Nan McKay & Associates Identity Verification

33 Slide #33 © Copyright 2008 Nan McKay & Associates EIV Tenant Income Data  Click “Income Report” tab at top of screen  Income data is displayed for all family members Earned/Unemployment: Family members 18 & over SSA/SSI: All family members No data displayed for live-in aide

34 Slide #34 © Copyright 2008 Nan McKay & Associates EIV Tenant Income Data

35 Slide #35 © Copyright 2008 Nan McKay & Associates EIV Tenant Income Data

36 Slide #36 © Copyright 2008 Nan McKay & Associates EIV Tenant Income Data

37 Slide #37 © Copyright 2008 Nan McKay & Associates EIV Tenant Income Data Verifies Medicare Part B buy-in amount for medical expenses deduction

38 Slide #38 © Copyright 2008 Nan McKay & Associates EIV Tenant Income Data

39 Slide #39 © Copyright 2008 Nan McKay & Associates Data Processing Steps  Use of EIV data may require changes in PHA procedures for processing annual reexams Different for each PHA  We’ll look at some basic processing steps “I have the printout – now what??”

40 Slide #40 © Copyright 2008 Nan McKay & Associates Data Processing Steps  Reexam packet mailed to families Add EIV informing notice Request paystubs per PHA policy  Last 60 days would be reasonable  Should be consistent among staff Request HUD-9886 for family members turning 18

41 Slide #41 © Copyright 2008 Nan McKay & Associates Data Processing Steps  Reexam packets returned to PHA  Print & distribute EIV data  Identify unreported employment/earnings  Compare EIV and tenant-supplied documents (paystubs)

42 Slide #42 © Copyright 2008 Nan McKay & Associates Evaluating EIV Data  Annualize pay stubs Average weekly x 52 or Average bi-weekly x 26 or Average semi-monthly x 24, etc.  May also consider year-to-date  Need consistent method

43 Slide #43 © Copyright 2008 Nan McKay & Associates Evaluating EIV Data  If family disputes EIV employment data: PHA must request third-party written verification

44 Slide #44 © Copyright 2008 Nan McKay & Associates Evaluating EIV Data  If the PHA determines that additional information is necessary: PHA must request third-party written verification  Effective dates of employment  Pay rate, hours worked for new jobs  Confirmation of a change in circumstances (reduced hours, reduced rate of pay)

45 Slide #45 © Copyright 2008 Nan McKay & Associates Evaluating EIV Data  If family does not dispute EIV data and no additional information is necessary: Calculate annual income using paystubs

46 Slide #46 © Copyright 2008 Nan McKay & Associates Evaluating EIV Data  If additional verification (such as employer statement) is obtained: The PHA will use current tenant-provided documents or most current information to calculate anticipated annual income

47 Slide #47 © Copyright 2008 Nan McKay & Associates Evaluating EIV Data  File documentation EIV printout (except FL) Tenant-provided documents (paystubs) Written third-party if required Remember to leave a clear audit trail  Calculator tape, calculation worksheet, etc.

48 Slide #48 © Copyright 2008 Nan McKay & Associates EIV Reports

49 Slide #49 © Copyright 2008 Nan McKay & Associates EIV Reports Module  Existing tenant search  Multiple subsidy report PIH and Multifamily  Identity verification report  Deceased tenant report

50 Slide #50 © Copyright 2008 Nan McKay & Associates EIV Reports  Reports available by reexam month Failed verification report No income report (no income in EIV) New hires report  Family members hired in last 180 days  Can select “all” months to see complete list

51 Slide #51 © Copyright 2008 Nan McKay & Associates HUD Monitoring

52 Slide #52 © Copyright 2008 Nan McKay & Associates Consolidated Reviews  Program areas under review: RIM UIV SEMAP PHAS Management Assessment (MASS) Civil rights

53 Slide #53 © Copyright 2008 Nan McKay & Associates Consolidated Reviews  HUD UIV Monitoring Report Implementation review Security assessment Income discrepancy review  5 highest dollar discrepancies per program

54 Slide #54 © Copyright 2008 Nan McKay & Associates UIV Monitoring Report  Implementation Has the PHA accessed EIV within 30 days? Which UIV tools are used by the PHA?

55 Slide #55 © Copyright 2008 Nan McKay & Associates UIV Monitoring Report: Security Assessment  Designated security officer  Security policies/procedures document  Enforcement  Record-keeping  Separate user ID/password for each user

56 Slide #56 © Copyright 2008 Nan McKay & Associates UIV Monitoring Report: Security Assessment  Signed authorizations & user agreements  Key log for secure areas  Log of destroyed documents OR records retention policy  Valid 9886 forms

57 Slide #57 © Copyright 2008 Nan McKay & Associates UIV Monitoring Report: Security Assessment  Procedure for documentation of improper disclosures  Procedure for reporting security breaches  Physical security measures  Method of document disposal

58 Slide #58 © Copyright 2008 Nan McKay & Associates NMA Lunch ‘n’ Learn Seminar NEXT TOPIC…

59 Slide #59 © Copyright 2008 Nan McKay & Associates NMA Lunch ‘n’ Learn Seminar

60 Slide #60 © Copyright 2008 Nan McKay & Associates Upcoming Lunch ‘n’ Learn Sessions…..  Nov 21, 2008 Community Service  Dec 2, 2008 Effective Interviewing & Fraud Prevention  Dec 10, 2008 Repositioning Public Housing Assets


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