Upfront Income Verification using EIV System (Mandatory)

EIV is used to verify income for recertification, annual, interim and change of dwelling, or on a random basis.

The EIV system also will be utilized to verify information such as family members’ personal identifier information (name, date of birth and social security numbers).

PHA will comply with the most recent HUD guidance on verification requirements. PHA will utilize the verification guidelines under PIH Notice 2010-19 (issued May 17, 2010 and as extended by 2012-26 and 2012-26), Verification Guidance, and PIH 2010-03 (issued January 21, 2010), Verification of Social Security and Supplemental Security Income benefits, as applicable, and any subsequent guidelines and regulations issued by HUD.

Administration of Verification Levels below Level 4

preferable form, “written third-party verification” (LEVEL 4), consists of an original document generated by a third-party source, which may be received directly from a third-party source or provided to the PHA by the family. If written party verification is not available, the PHA must attempt to obtain a “written third-party verification form” (LEVEL 3). This is a standardized form used to collect information from a third party.

Written Third Party Verification (LEVEL 4)

[Notice PIH 2010-19]

Written third-party verification documents consist of an original document generated by a third-party source, which may be received directly from a third-party source or provided to the PHA by the family.

Examples of acceptable tenant-provided documents include, but are not limited to: pay stubs, payroll summary reports, employer notice or letters of hire and termination, SSA benefit verification letters, bank statements, child support payment stubs, welfare benefit letters and/or printouts, and unemployment monetary benefit notices.

The PHA is required to obtain, at minimum, two current and consecutive pay stubs for determining annual income from wages. All income related documents must be dated less than 60 days preceding the determination date (eligibility interview) and continues to be valid an additional 60 days following the request date. If income related documents expire, the applicant or resident will be required to provide new documents.

The PHA may reject documentation provided by the family if the document is not an original, if the document appears to be forged, or if the document is altered, mutilated, or illegible.

If third party income verification is not otherwise available, a copy of the most recent federal income tax return shall be submitted, including any W-2 information, or at least two (2) consecutive pay stubs or earnings statements. As stated above, notarized statements or affidavits are the least desirable forms of verifications and shall be accepted only when all other types of verification attempted have failed.

Written Third Party Verification Form (LEVEL 3)

When upfront verification is not available and the family is unable to provide written third-party documents, the PHA must request a written third-party verification form. HUD’s position is that this traditional third-party verification method presents administrative burdens and risks which may be reduced through the use of family-provided third party documentation.

A written third-party verification form is mandatory when there is an unreported source of income or a substantial difference in reported income ($2400 annually or more – refer to 7.24) and there is no UIV or tenant-provided documentation to support this income discrepancy.

PHAs may mail, fax, or e-mail third-party written verification form requests to third-party sources.

At least two (2) documented attempts must be made for written third party verification before obtaining oral (telephone or in person) third party verifications.

Oral Third-Party Verification (LEVEL 2)

[Notice PIH 2010-19]

Oral third-party verification is mandatory if neither form of written third-party verification is available. This type of verification will be used when written verification is not obtained within 15 days from the date that

the written verification was mailed, faxed or e-mailed directly to the independent source.

PHA should document in the file the date and time of the telephone call or visit, the name of the person contacted, the telephone number, as well as the information confirmed.

If oral third party verification cannot be obtained, PHA must document in the file the reason the third party verification was not available.

Self-Certification (LEVEL 1)

Self-Certification or “tenant declaration” is used as a last resort when the PHA is unable to obtain third-party verification.

When the PHA relies on a tenant declaration for verification of income, assets, or expenses, the family’s file must be documented to explain why third-party verification was not available.

The self-certification must be made in a format acceptable to the PHA and must be signed by the family member whose information or status is being verified. All self-certifications must be notarized.





Verification Process for Annual Recertification

The PHA will utilize EIV for annual and interim recertifications. For each annual recertification of family income and composition, the PHA is required to have the following documentation in the participant file:

a. No Dispute of EIV Information:

EIV Income Report.

b. Substantial Difference in or Disputed EIV Information:

EIV Income report, current acceptable participant-provided documentation, and/or third party verification form(s) for disputed information.

c. Participant-Reported Income Not Verifiable Through EIV System or Participant Request to Use Anticipated Income:

Current participant-provided documents, and if necessary (as determined by the PHA), third party verification form(s).

The PHA will follow guidance set forth PIH Notice 2010-19 as may be amended by 2013-03, 2013-03 FAQs and 2013-04 regarding documentation required to be kept in the participant file for interim

recertifications, historical readjustments and new admission income verifications as well as processes to address incorrect information found in the EIV system.

When Third Party Verification is required

The PHA must require third party verification under the following circumstances:

a. When the participant 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 participant is unable to provide the PHA with current acceptable participant-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.).

The PHA will obtain as much information as possible about employment income, such as start date (new employment), termination date (previous employment), pay frequency, pay rate, anticipated pay

increases in the next twelve months, year-to-date earnings, bonuses, overtime, company name, address and telephone number, name and position of the person completing the employment verification form.

Unreported Income or Substantial Difference in Participant-Reported Income and EIV-Reported Income

If the EIV Report reveals an income source that was not reported by the participant or a substantial difference in the reported income information, the PHA must take the actions set forth below.

A substantial difference is defined as an amount equal to or greater than $200 per month or $2,400 per year.

The PHA must:

a. Discuss the income discrepancy with the participant; and

b. Request the participant to provide any documentation to confirm or dispute the unreported or underreported income and/ or income sources; and

c. In the event the participant 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

d. Review historical income data for patterns of employment, paid benefits, or receipt of other income when the PHA cannot readily anticipate income, such as in cases of seasonal employment, unstable working hours, and suspected fraud.

e. Analyze all data (EIV data, third party verification and other documents/information provided by the family) and attempt to resolve the income discrepancy.

f. Use the most current verified income data (and historical income data if appropriate) to calculate anticipated annual income.

g. If applicable, determine the participant’s underpayment of rent as a result of unreported or underreported income, retroactively (see below discussion of Repayment Agreement); and h. Take any other appropriate action as directed by HUD or the PHA’s administrative policies.

Unsubstantial Differences in Reported Income and EIV Report

In cases in which the participant requests that anticipated income be used to determine annual income and the EIV income data is not substantially different than current participant-provided income

documentation, the following guidelines for projecting annual income will be used:

a. If EIV income data is less than current participant-provided documentation, the PHA will use participant provided documents to calculate anticipated income.

b. If EIV income data is more than current participant-provided documentation, the PHA will use EIV income data to calculate anticipated annual income unless the participant provides the PHA with documentation of a change in circumstances (i.e., change in employment, reduction in hours,

etc.). Upon receipt of acceptable participant-provided documentation of a change in

circumstances, the PHA will use participant-provided documents to calculate anticipated annual income.

Participant Opportunity for Informal Hearing

The participant must be provided an opportunity to contest the PHA’s determination of participant rent underpayment. HUD regulations require PHAs to promptly notify participants in writing of any adverse findings made on the basis of the information verified through the aforementioned income discrepancy resolution process. The participant 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.