Integrity Monitoring (RIM) Reviews Frequently Asked Questions (FAQs)
Note: Please also
see Admission and
Occupancy (Related to EID), General
Income and Rent Determination, Verification,
and RIM Reviews FAQs for questions/answers
on income and rent issues.
1. Question: What is a RIM review?
Answer: RIM reviews are a key component
of the Rental Housing Integrity Improvement Project (RHIIP) initiative
to reduce income and rent errors and improper payments in the administration
of both the public housing and housing choice voucher (HCV) programs.
RIM reviews are designed to identify the root causes of error and
improper payments in meeting HUD's goal of a 50 percent reduction
in the number and dollar amount of errors by fiscal year 2005.
2. Question: What, specifically, do HUD Field Office reviewers
do when conducting a RIM review?
Answer: While performing a RIM review, HUD Field Office
sample tenant files
PHA policies, procedures, and forms
and record income and rent errors (both systemic and isolated
income and rent errors to establish root causes
findings and concerns/observations, and require corrective actions
It is important to note that although RIM reviews are limited in
scope, a Field Office may, as part of its routine monitoring process
and responsibility, decide to review other functions of the PHA
while conducting a RIM review.
3. Question: How many RIM reviews did the Field Offices conduct
Answer: In FY 2003, the Field Offices completed over 700
RIM reviews covering PHAs administering 80 percent of PIH's rental
4. Question: Must HUD Field Office reviewers send the PHA a
RIM review report on its income and rent performance?
Answer: Yes. A written RIM review report will be sent to
the PHA no later than 45 calendar days from the completion of onsite
5. Question: What type of information will be included in the
Answer: A review report should identify performance problems,
diagnose the causes of the problems, and offer valuable recommendations
for corrective action. Each review report must follow the HUD
Monitoring Desk Guide, which calls for a clear delineation between
"findings" and "concerns" (also referred to as "observations").
The report will also include specific tenant file errors that were
discovered as a result of the review.
6. Question: Are PHAs given a chance to respond to the review
Answer: Yes. PHAs have 45 days from the date of the review
report to respond to the report, but 30 days is recommended to the
7. Question: Can a Field Office grant a PHA an extension beyond
the 45-day period if it needs more time to prepare a correction
action plan (CAP) in response to the review report?
Answer: Requests for extensions beyond the 45-day period
will be considered on a case-by-case basis, and will be for a maximum
period of 30 days.
8. Question: How does the HUD Monitoring Desk Guide distinguish
"findings" and "concerns"?
Answer: As provided by the HUD Monitoring
Desk Guide, a finding is a violation of statutory, regulatory,
or valid handbook requirements. Findings should include the condition,
criteria, cause, consequence (effect), and the required corrective
action. A concern or observation is defined as a deficiency in performance,
which should be brought to the attention of the program participant,
but is not based on a regulatory or statutory requirement. Concerns
should include the condition, cause and effect, and recommended
9. Question: How does HUD staff know when to write an error
as a finding or a concern?
Answer: A finding must be traced back to statute, regulation,
or other explicit HUD requirement. HUD staff must use judgment when
determining whether a requirement exists, and whether the PHA has,
in fact, violated the requirement, or whether the PHA has choices
and options as stated in their current policies and is exercising
the discretion granted them under the regulations. Another issue
to consider is the extent to which several different errors are
related, or are apart of a larger pattern or problem. Single or
isolated errors, by themselves, may not constitute a finding. However,
when taken together, several errors may rise to the level of a finding.
(See HUD guidance on systemic
findings vs. non-systemic findings for a detailed discussion.)
10. Question: As a result of a RIM review, a Field Office reviewer
assigns a category of risk based on the findings. How do Field Office
reviewers assign risk-ranking categories to PHAs?
Answer: The risk ranking is decided after the RIM review
is completed, and is based on the judgment of the reviewer and the
established risk factors of the Field Office.
11. Question: What requirements can HUD impose as a result of
RIM review findings?
Answer: As with any other HUD monitoring review, a PHA that
is found to be in non-compliance with HUD requirements will be required
to implement a CAP to resolve findings. See the HUD
Monitoring Desk Guide for additional guidance on policies and
procedures for program oversight.
12. Question: What if a PHA fails to develop and implement a
CAP as required by the RIM review report?
Answer: If a PHA fails to identify and implement corrective
actions, or correct income and rent determination errors in meeting
program requirements of the RIM review, HUD will impose sanctions
on the PHA and seek to recover disallowed costs, in accordance with
PIH-2003-34, Rental Integrity Monitoring (RIM) Disallowed Costs
and Sanctions under the Rental Housing Integrity Improvement Project
13. Question: Do RIM Field Office reviewers take a PHA's comments
into consideration in making their findings final?
Answer: Yes. Field Office reviewers must consider a PHA's
comments and responses to RIM review results. If the PHA and Field
Office are unable to come to an agreement regarding Field Office
determinations, the PHA may submit RIM review findings, errors,
corrective actions, etc. within 30 calendar days from receipt of
Review Summary Report (MS-Excel). (See the RIM
Review Dispute Process for details.)
14. Question: Is it a violation of HUD regulations if a PHA
does not have an adequate application/re-exam package to determine
income and deductions? For example, a PHA has no proof that they
are asking elderly families about medical expenses or families if
they have childcare expenses.
Answer: Yes. If a PHA cannot document that they are requesting
information that is required to accurately calculate income and
rent, HUD will be unable to verify that adjusted income is being
calculated in accordance with 24
CFR 5.611. This would qualify as a systemic finding. (See HUD
guidance on systemic
findings vs. non-systemic findings for a detailed discussion.)
15. Question: If a PHA's policy doesn't state how they will
determine the value of asset income amounts for checking and savings
accounts and each Occupancy Specialist is doing it differently,
is this a finding? For example, some are using the current account
balances and others are using the average balance for the past three
Answer: Yes. If a PHA does not have a written policy and
there is evidence that occupancy staff are using different methods
to determine the value of assets, for RIM purposes, this should
be listed as a violation of 24
CFR 903.7(d). A PHA must amend its policy to specifically state
the method to be used to determine the value of assets, and must
ensure that practice is consistent with PHA policy.
16. Question: What if all occupancy staff is using the same
method to calculate asset income from checking and savings accounts,
even though it is not outlined in the PHA's policies?
Answer: The report to the PHA should list this as a finding
CFR 903.7(d) and 24
CFR 982.54) and require the PHA take corrective action, amending
its policies to reflect the method used. For RIM purposes, HUD staff
should follow the PHA's practice/method to determine the value of
17. Question: If a PHA has not adopted a policy on medical expenses,
what should a RIM reviewer do?
Answer: At a minimum, the RIM reviewer should require a
PHA to amend its (ACOP) and/or Section 8 Administrative Plan (24
CFR 982.54) to address medical expenses, both in terms of what
will be considered eligible and how it will be verified. A reviewer
should try to determine how the PHA is calculating and verifying
medical expenses, and whether the caseworkers are consistent in
their approach. For RIM purposes, if caseworkers were not consistent
in their approach then it would be a violation of 24
CFR 5.611(a)(3)(i) because HUD would be unable to verify that
unreimbursed medical expenses are being calculated consistently
18. Question: : If a PHA is not following its own policies,
as adopted in its Annual Plan, Administrative Plan, and Admissions
and Continued Occupancy Plan (ACOP), is that a finding?
Answer: Yes. The regulations on annual plans (24
CFR 903.25) state that a "PHA must comply with the rules, standards,
and policies established in the plans." A supporting document to
the Annual Plan, the regulations on HCV program administrative plans
CFR 982.54(c)) state that a "PHA must administer the program
in accordance with the PHA administrative plan." Regarding the ACOP,
also a supporting document to the PHA's Annual Plan, the PHA must
comply with policies adopted in this plan.
19. Question: Is there a regulation requiring PHAs to maintain
a copy of the HUD Form-50058 Family Report in the tenant's file?
Answer: No. There is no regulatory requirement that states
PHAs must maintain a paper copy of the Form
HUD-50058 in the tenant's file. However, HUD strongly recommends
that PHAs retain a hard copy of the form in the tenant's file, in
addition to the electronic copy.
20. Question: Do PHAs have to keep all file information on active
HCV and PH participants, including original application data, citizenship
declaration, SSN verification data, birth certificates, etc.? Can
this data be purged after the family has moved out of the unit for
Answer: For all active participants, PHAs must retain all
records that are necessary to document the family's initial and
continued eligibility, as well as any information that is needed
to determine family composition and income. All file data for inactive
participants must be retained for at least three years, following
the family's departure from the HCV or PH program.