and Rent Determination FAQs
1. Question: Exemplified in the Calculation
Problem Areas (Section 2, pgs. 7-23) PowerPoint presentation slides from the
training, does the family have the right to choose between the two acceptable
methods for calculating seasonal employment income, or can the PHA adopt in its
policies one over the other method?
Answer: The PHA should lay
out both scenarios to the tenant, project income under both methods, and let the
family decide which method to select. Tenants with seasonal employment should
be informed of the PHA's policy regarding the two acceptable methods:
Method 1: The PHA annualizes current income (e.g., $2,000
per month x 12 months), and when seasonal employment ends, it conducts an interim
Method 2: The PHA calculates anticipated income from
all known sources for the entire year (e.g., $2,000 per month x 8 months, $400
per month x 4 months) and conducts no interim reexamination.
the family selects Method 1, the family should know that an interim reexamination
will be conducted; and if the family selects Method 2, the family should
know that an interim reexamination will not be conducted.
Regarding child support payments, when the child turns 18 and is still receiving
payments for arrears, would the PHA count this as annual income?
Yes. Pursuant to 24
CFR 5.609, annual income means all amounts, monetary or not, which goes to,
or on the behalf of, the family head or to any other family member, that are anticipated
to be received from a source outside the family during the 12-month period following
admission or the annual reexamination effective date.
3. Question: If
a family receives different amounts each month (e.g., $500 - $700) in child support
payments, and, for one month, receives a lump-sum payment of $10,000 for arrears,
must the PHA project annual income including the $10,000?
For the year in question, the $10,000 is income received for child support and
should be counted as usual.
Answer: See Question# 5, under Annual
Income-What Is Included, on the General
Income and Rent Determination Web Page, for the answer to this question.
Question: When a State is paying the Medicare premium, what amount is used to
calculate income, gross or net benefits? Should a PHA add Medicare premium to
gross before calculating?
Answer: In the calculation of annual
CFR 5.609), the full amount or gross amount, including Medicare premiums should
Annual Income-What Is Excluded
Question: What is the difference between delayed and deferred Social Security
(SS) and/or Supplemental Security Income (SSI) payments? The regulation (24 CFR
5.609) uses both terms.
Answer: Under 24
CFR 5.609(b)(4), what is included in annual income, the term "delayed"
means periodic benefit payment amounts, for which a public housing or HCV applicant
or tenant is eligible, that are not received timely. These are scheduled
benefit amounts that are due to the applicant or tenant, but are simply late.
CFR 5.609(c)(14), what is excluded from annual income, the term "deferred"
means postponed by SSA to a later date. For example, the applicant or tenant
receives a $32,000 deferred SS benefit payment, following a lengthy eligibility
Annual Income-Earned Income Disallowance
6. Question: Can a PHA receive a waiver from HUD from the lifetime
48-month exclusionary period for a disabled family member who requests an exemption,
claiming disability-related reasons? Would this be considered a "reasonable
accommodation" for disabled persons?
Answer: Although Title
V, Sec. 508(b) of the 1998 QHWRA does not impose a time limit on the availability
of the income disregard, the Changes
to Admissions and Occupancy Requirements in the Public Housing and Section 8 Housing
Assistance Programs Federal Register (March 29, 2000) limits the EID exclusion
to a lifetime period of 48 months. This is a regulatory requirement that applies
to all families and persons applying for or residing in public housing
or applying for or receiving Section 8 assistance. HUD is not in favor of waiving
this requirement, as the intent of the exclusion is to promote self-sufficiency.
Question: What about income disallowances for "Welfare-to-Work" programs?
Is it still in effect for qualified families?
Answer: Yes. Pursuant
CFR 5.617(b)(3) for HCV and 24
CFR 960.255(a)(iii) for public housing, a family member, whose annual income
increases, during or within six months after receiving benefits, services, or
assistance under a State administered temporary assistance for needy families
(TANF) or Welfare-to-Work (WTW) program, as determined by the PHA in consultation
with the local TANF agency, is qualified for the income disallowance.
Question: Has HUD developed a form to help PHAs calculate the amount excluded
under the EID and track the time someone qualifies for the exclusion?
While there is no tracking form available, an Excel-based calculator that can
be used to collect information on EID family members is currently available. The
and worksheet (MS-Excel) can be accessed at the Earned
Income Disallowance (EID) Worksheet and Calculator Web Page. Also available
are EID in-depth examples and training materials from the January
and February Rental Integrity Summit trainings, held in Orlando, FL and Anaheim,
9. Question: If a PHA's policy states it does not do interim reexaminations,
and adjustments to rent only occur at the family's annual reexamination, why must
a PHA process the EID for family's, beginning on the first of the following month
after the increase in earnings?
Answer: Pursuant to the regulation,
CFR 960.255 and 24
CFR 5.617, the exclusion begins on the date a member of a qualified family
is first employed or the family first experiences an increase in annual income
attributable to employment. As this is both a regulatory and statutory requirement,
the PHA must perform an interim reexamination, processing the EID for the qualified
family member accordingly.
10. Question: A non-disabled, public housing
resident receiving an EID is relocated under Hope VI with a voucher. If after
receiving for four years the voucher under Hope VI, the resident returns to public
housing, can the resident resume his or her remaining months of EID or does the
resident loose his or her remaining months?
Answer: The resident
will loose his or her remaining months. The EID is limited to one 48-month period
from the beginning of the first month after commencement of the qualifying employment
of a family member. If the period of increased income does not last for 12 consecutive
months, the disallowance period may be resumed at any time within the 48-month
period. Since this resident did not return to public housing before the end of
the 48-month period, the resident is no longer eligible for EID.
Question: An eligible participant, who is a sporadic wage earner begins work on
the sixteen day of the month, and then quits five days later, on the twenty-first.
Since EID would typically go into effect on the first day of the month following
the increase in annual income due to employment, does the participant loose one
month of the disallowance? Or, does the "clock" ever start?
In this case, the EID should not be processed for the participant. The "clock"
should not be started for this family member.
12. Question: What is
the baseline income for an eligible family member who is earning $600 per month
in a HUD funded training program (entire amount is excluded), and then gets a
job while in the training program, earning $1,000 per month, and then graduates
from the program?
Answer: In this case, the family member's
baseline income is $0. The baseline income is the amount of the family member's
income before the EID qualifying event. Since the family member's earnings under
the HUD funded training program (24
CFR 5.609(c)(8)(i)) are excluded in the calculation of annual income, and
the participant had no other income from wages or benefits, the baseline income
is $0. For examples provided at the Rental Integrity Summit (RIS) training, see
the PH - Calculation
Problem Areas, Section 4, Earned Income Disallowance (EID) and the HCV-
Calculation Problem Areas, Section 4, Earned Income Disallowance (EID) PowerPoint
13. Question: Under the HCV program, PHAs are only required
to keep tenant files for a period of three years (24
CFR 982.158(e)). What if an EID participant leaves the HCV program and then
returns 3 ½ years later, after the PHA has already purged his or her previous
Answer: In order for the PHA to be aware of the individual's
prior receipt of EID and the number of months he or she received the exclusion,
the individual would have had to report the information, or the PHA would have
had to retain a record of the individual's participation for longer than the HUD
required three-year period. Because HUD regulations limit a participant's exclusionary
period to 48-months in a lifetime, the Department strongly recommends all
PHAs carefully track and retain the records of EID participants for as long as
necessary. HUD also recommends PHAs (1) adopt policies that require relevant documents
to be provided by former participants claiming they received EID in years' prior;
(2) improve the interviewing skills of their staffs; (3) develop comprehensive
data collection tools; (4) and make the maximum use of up-front
income verification (UIV) tools to prevent and detect false statements.
being said, if after being re-admitted into the HCV program, or into public housing,
the individual qualifies for EID and he or she cannot provide evidence of the
prior EID, and the PHA has not been able to locate and verify the individual's
prior record, the PHA must give the individual the EID, starting from the
date the he or she experiences an increase in annual income as a result of one
of the three qualifying factors.
14. Question: If a PHA incorrectly
determined the amount of the exclusion under EID, and therefore too much income
was excluded, can the PHA collect the overpayment from the family? If not, will
the PHA be sanctioned for this overpayment?
Answer: If the PHA
incorrectly determined the tenant's rent, as a result of PHA error, the PHA would
be required to correct the tenant records and ensure accurate rent payment, prospectively.
In accordance with Notice
PIH 2003-34, if the PHA does not implement corrective actions or rectify errors
in meeting program requirements uncovered during a RIM review, the Field Office
will impose sanctions and seek to recover amounts due to HUD in disallowed costs.
Tenants are not responsible for rent underpayments (PHA overpayments) due to
15. Question: How much latitude or flexibility does a
PHA have in defining "participation" in an economic self-sufficiency
program (for purposes of determining whether someone qualifies for EID)? For example,
can a PHA define "participation" to mean that a person must participate
in an activity for a minimum number of hours per week/month?
The regulation, 24
CFR 5.603(b), provides the definition of an economic self-sufficiency program.
Beyond the definition of the types of activities, there is no guidance on defining
"participation." A PHA should rely on program sponsors to provide established
and written guidelines that define satisfactory participation in an economic self-sufficiency
program and include the PHA's policies and procedures.
Can a PHA that did not have ceiling rents already established as of October 1,
1999 establish ceiling rents now, in 2004? If not, on what policy is this based?
No. PHAs that did not have ceiling rents as of October 1, 1999, the effective
date of the 1998 QHWRA, cannot establish traditional ceiling rents now. Pursuant
523(B) of the 1998 QHWRA, allowable rent structures include flat rents (24
CFR 960.253(b)) and income-based rents (24 CFR 960.253 (c)). However, the
1998 statute (Section
523(B)(ii)(II)) and the regulation (24 CFR 960.253(d)), give PHAs the discretion
to impose (establish) a ceiling on income-based rents, but they must be adjusted
to the level required for flat rents and comply with rent option requirements
under 24 CFR 960.253(a).
17. Question: What if a PHA that had ceiling
rents as of October 1, 1999 misunderstood the statutory requirement, and, as a
result, discontinued their ceiling rents. Can a PHA reinstate them now, as long
as they are at the flat rent level?
Answer: Yes. Pursuant to
523(A)(ii) of the 1998 QHWRA, if a PHA had ceiling rents as of October 1,
1999, and later, discontinued ceiling rents, it can reinstate them now, so long
as they are adjusted to the level required for flat rents (24
CFR 960.253(b)). Ceiling rents, however, are subject to the rent option requirement
under provision 24 CFR 960.253(a).
Assets And Income
18. Question: The slide (pg. 114) in Calculation
Problem Areas, Section 5, Assets and Asset Income states that the PHA can
establish a minimum threshold for counting assets disposed of for less than fair
market value. Is this true or false?
Answer: The regulation (24
CFR 5.603(b)) does not specify a minimum threshold for counting assets disposed
of for less than fair market value. Consistent with Handbook
4350.3 - Rev 1, Occupancy Requirements of Subsidized Housing Programs (Chapter
5, 5-7), PHAs may establish a threshold in its Administrative Plan (24
CFR 982.54) or Annual Plan (24
CFR 903.7) that will enable them to ignore small amounts such as charitable
contributions (e.g., cash donations to the local food bank, church, etc.).
Question: Is a PHA required to pay for a formal appraisal in order to determine
the net cash value of real estate property?
Answer: No. However,
the PHA must use a reasonable basis for assigning value to real estate property.
For example, third-party verification, such as online sources (e.g., HomeValueHunt.com,
is an acceptable means for obtaining the value of property assets for families
reporting real estate property at reexaminations. In some cases, it is acceptable
for the PHA to review original documents provided by the tenant. However, before
implementation, the PHA is required to state in its Annual Plan (24
CFR 903.7(d)) and/or Administrative Plan (24
CFR 982.54) the PHA's policy for determining the value of family assets; and,
during interim and annual reexaminations, if third-party verification is not obtained,
the PHA must document in the family's file why third-party verification was not
CFR 982.516(a)(2) and 24
HUD is aware that in some situations the asset or
expense to be verified may not be cost effective to obtain third-party verification
when the impact on the total tenant payment (TTP) is minimal. That said, PHAs
should always begin with the highest level of verification (up-front
income verification (UIV)), in accordance with Notice
PIH 2004-1, Verification
Guidance, issued March 9, 2004.
20. Question: How should a PHA determine
the cash value of a retirement account, such as a 401(k), if it is unable to obtain
verification of the cash value of the account?
Answer: If the
PHA is unable to verify the tenant's 401(k) account balance, the penalty for premature
withdrawal (usually 10 percent), and tenant and employer contributions with the
independent source (i.e., employer), the PHA may use tenant supplied documentation
to determine and verify the cash value of the asset. However, the PHA must document
in the tenant's file why third-party verification was not available (24 CFR 982.516
and 24 CFR 960.259). See the Notice
PIH 2004-01, Verification Guidance for a complete discussion on HUD-established
verification policies for income, assets, and expenses.
Regarding stocks and mutual funds, is the asset income equal to the appreciated
share value, dividends paid, or both?
Answer: As stated in the
CFR 5.609(b)(3)), when the family has net family assets in excess of $5,000,
the asset income is the greater of the actual income derived (e.g., interest or
dividends earned) from all net family assets or a percentage of the value of such
assets based on the current passbook savings rate. When net family assets are
$5,000 or less, the asset income is the actual income from assets. For a complete
discussion and examples, see the Housing
Choice Voucher Program Guidebook, Chapter 5, 5.4 and the Public
Housing Occupancy Guidebook, Chapter 10, pgs. 121-122)
If there are two sisters, both living in public housing although in separate units,
and both sisters' names are on both sisters' savings accounts, how is this handled
when calculating income from assets? Are both savings accounts counted for each
Answer: Yes. If both sisters living in public housing,
although in separate units, have access to amounts derived from each sister's
savings account, then both assets (i.e., savings accounts) would be considered
when calculating income from assets for both households (24
23. Question: Since there is limited guidance
on the treatment of trust accounts under the provisions for public housing and
CFR 5.603(b)) programs, can PHAs use the guidance provided in HUD Handbook
4350.3 Rev - 1, Occupancy Requirements of Subsidized Multifamily Housing Programs?
Answer: Yes. For a complete discussion on the treatment of assets in determining
income from assets, PHAs may refer to HUD
Handbook 4350.3 Rev - 1, Occupancy Requirements of Subsidized Multifamily Housing
Programs (Chapter 5, 5-7G).
24. Question: If a broker refuses
to give a PHA the broker's fee, can a PHA establish a set broker's fee (based
on an average) that will be used in determining the net cash value of real property?
Answer: In accordance with the new Notice PIH 2004-01, Verification Guidance,
if the PHA is unable to obtain third-party verification because the independent
source will not facilitate the PHA's request, the PHA may review tenant provided
documents (i.e., broker's fee, settlement costs for real estate transactions,
legal fees, etc.) to determine the net cash value of real property.
Question: If a tenant sells his house to his son, but holds the deed of trust
while the son makes monthly payments, how is this handled when determining assets?
Answer: As provided in the regulation (24
CFR 5.609), annual income includes amounts derived from assets, during the
12-month period, to which a family member has access. Since the tenant
has access to amounts derived from the house, it is considered an asset and used
in the determination of annual income.
26. Question: If a mother is
listed on the title of her daughter's home in order for her daughter to qualify
for a loan, is the home considered an asset to the mother who is residing in public
Answer: See Question 27 above.
27. Question: On the public housing lease agreement with tenants,
do utilities have to be specified exactly? Or, is it acceptable to state, "electric,
water, sewer, trash, gas, as applicable"?
CFR 966.4(a)(iv)), the lease must state what utilities, services, and equipment
are to be supplied by the PHA and what utilities and appliances are to be paid
for by the tenant. When maintaining a utility allowance schedule for all tenant-paid
CFR 982.517(b)(ii)), the PHA must classify utilities and other housing services
according to the following general categories: space heating; air conditioning;
cooking; water heating; water; sewer; trash collection (disposal of waste and
refuse); other electric; refrigerator (cost of tenant-supplied refrigerator);
range (cost of tenant-supplied range); and other specified housing services. The
cost of each utility and housing service category must be stated separately.
Question: If the owner charges the household for water, does the utility have
to be sub-metered (or check-metered) for the tenant to get the allowance?
Answer: No. There are two basic ways to determine utilities allowances:
(1) Engineering based-allowances based on calculations, standardized consumption
tables for a given area, or in-house information (e.g., derived from energy audit);
or (2) Consumption based method-allowances are determined using actual consumption
data (check-meters and/or individual-meters) from dwelling units in the PHAs portfolio.
For specific on how to calculate, go to http://www.hud.gov/offices/pih/programs/ph/phecc/allowances.cfm
Question: If a PHA is doing an interim reexamination in the HCV program and the
utility allowance has changed since the last annual reexamination, should the
PHA use the old or new utility allowance?
Answer: Pursuant to
CFR 982.517(d)(2), the PHA must use its current utility allowance schedule
If an INS verification (SAVE System) shows "status = pending," does
the PHA prorate assistance for an applicant or participant?
No. Pursuant to 24
CFR 5.514(b)(i) and 24
CFR 5.14(2), an applicant or a tenant's assistance cannot be delayed, denied,
or reduced when the immigration status of the family member has not been determined
Adjusted Income-Childcare Expenses
Question: If a family has a child under the age of five and chooses to put the
child into a pre-school instead of a daycare, does the family get the much higher
pre-school rate (i.e., childcare expense deduction)? Or, should a PHA only deduct
what the daycare amount would have been had the child been enrolled in a daycare?
Answer: Pursuant to the new Notice
PIH 2004-01, Verification Guidance, the PHA may not choose the type of childcare
to be provided for the head of household's child(ren). If provisions are met under
CFR 5.603(b), then the family must be given the childcare expense deduction,
pursuant to 24
Question: Can a PHA set a policy to conduct interim reexaminations only for FSS
participants? What about only FSS participants who have increases in income?
Answer: Yes. Pursuant to 24
CFR 960.257(c) and 24
CFR 982.516(b), the PHA has discretion to set a policy to conduct interim
reexaminations only for family self-sufficiency (FSS) participants, including
those who have increases in income. However, the PHA's policy must be written
in its ACOP or Administrative Plan (24
CFR 982.54) and Annual Plan (24
CFR 903.7) and consistently applied to all FSS participants.
Question: Is it mandatory for the annual reexamination date to always match the
admission date? For example, the family was admitted on January 2, 2003, so the
annual reexamination must be conducted for January 2, 2004.
No. Although PHAs must conduct a reexamination of family income and composition
at least annually (24
CFR 960.257(a) and 24
CFR 982.516(a)), PHA's have the discretion to set and establish in its Annual
CFR 903.7 and Administrative Plan (24
CFR 982.54) when and under what circumstances they will conduct such reexaminations.
And, considering a family may request, at any time, an interim reexamination
of family income or composition because of any changes since the last determination
(e.g., annual reexamination), the date of admission and the date of the annual
reexamination will more than likely be different.
34. Question: If a
PHA has a different interim reexamination policy for residents receiving EID,
would the policy be considered to be discriminatory against disabled individuals?
Answer: Similar to Question 34, the same rule applies. The PHA has
discretion to set a policy to conduct interim reexaminations only for EID participants.
However, the PHA's policy must be written in its Administrative Plan (24
CFR 982.54) and Annual Plan (24
CFR 903.7) and consistently applied to both public housing (any
eligible family member) and HCV (only eligible disabled family members) program
35. Question: What if a third-party verification is returned
after the effective date of the annual reexamination? Does the PHA have to consider
it and recalculate rent? If yes, is this considered an interim reexamination for
purposes of the action code on the Form HUD-50058? Is the answer the same irrespective
of my interim reporting policy?
Answer: If a third-party verification
is returned after the effective date of the annual reexamination, the PHA must
conduct an interim reexamination, considering the data, and recalculate the tenant's
rent, if the data is different from what was used at the annual reexamination.
The PHA would record the new data on Form
HUD-50058, as an action code 3 = Interim Reexamination.
Form-50058 (New Topic)
36. Question: The regulation (24
CFR 5.609(b)(2)) states that the net income from the operation of a business
is included in annual income and that when determining net income expenditures
for business expansion or amortization of capital indebtedness shall not be deducted.
The regulation goes on to state that an allowance for depreciation of assets used
in a business may be deducted, based on straight-line depreciation.
HUD-50058 Instruction Booklet seems to conflict with the regulation. It instructs
PHAs to list expenditures for business expansion, amortization of capital indebtedness,
and an allowance for depreciation as "exclusions" from income in column
7e. This appears to be incorrect. Although these three items are considered in
determining net income, they are not exclusions from income. Should PHAs disregard
the HUD Form-50058 instructions, in this instance?
In this case, you should use the regulatory policy. The booklet will be modified
to clarify this matter.
37. Question: Is it acceptable for a PHA to
record an application for housing assistance in the computer, while the applicant
is present, and have him or her sign the printout?
If the PHA is using its computer system to receive data from an applicant for
housing assistance, and instead of collecting the data on paper, the PHA Intake
Specialist enters the data into the computer system, prints it off, and the tenant
signs it, this would be acceptable to HUD.
Question: What is the status of the automated rent calculator designed by the
Office of Policy Development and Research?
Answer: The automated
rent calculator project has been discontinued.
39. Question: Will HUD require verification of the amount of income
that is excluded?
Answer: Yes. In accordance with 24
CFR 960.259(c)(1)(i) and 24
CFR 982.516(2)(i), PHAs must obtain adequate documentation to reasonably determine
the excluded amount of income. If without that verification, a PHA would not be
able to determine whether the income is to be excluded when calculating annual
income. Depending on the circumstances, any or all of the following may need to
be verified: source of excluded income, circumstances that qualify a family member's
income to be excluded, and the amount of the exclusion.
Will HUD be providing a template for documenting third-party oral verifications?
Answer: Yes. HUD has provided examples of file documentation of third-party
oral verifications (See the new Notice
PIH 2004-01, Verification Guidance). The documentation of oral third-party
verification should include the date and time of the oral verification, along
with the organization name, employee name and title, telephone number, and information
verified by the individual.
41. Question: We have a problem with obtaining
food stamp data from the local TANF agency; it is reluctant to release this data,
due to its established, written polices. Since the tenant does not always know
how much he or she receives monthly, how can the PHA verify TANF payments, services,
Answer: In the event the PHA does not receive
a written or oral response to third-party verification requests, the PHA may review
original tenant-provided documents. For example, the TANF benefit letter, or the
current TANF benefit amount for the appropriate household size listed on the State's
current TANF payment schedule. However, in accordance with 24
CFR 960.259 and 24
CFR 982.516, the PHA must document in the family file why third-party verification
was not available.
42. Question: Since PHAs cannot pass the cost of
doing business to the family (e.g. obtaining verification, notarizations), can
the PHA claim reimbursement from HUD through the housing assistance payment (HAP)
Answer: No. The PHA may not claim a reimbursement
from HUD through the HAP account for verification costs. HUD provides PHAs with
administrative fees to cover the cost of doing business (24
43. Question: Why must PHAs request and verify income
of minors that are excluded? Many jobs such as snow removal, lawn care, or babysitting
are difficult to verify. The tenant will have a difficult time providing an amount,
which is not even counted in the calculation of annual income. This would upset
some tenants because PHAs are asking for the amounts, but not counting them. Should
PHAs limit minor wages to what the minor would actually receive on a W-2?
Answer: The PHA has the responsibility of establishing procedures that
are appropriate and necessary to assure that income data provided by the applicant
or participant families is complete and accurate. HUD requires the PHA to obtain
third-party verification of reported family annual income in accordance with 24
CFR 960.259(c)(1)(i) and 24
44. Question: Can a PHA amend Form HUD-9886 to
include additional sources of income?
Answer: No. A PHA may
not amend Form
HUD-9886 to include additional sources of income. The Form HUD-9886 specifically
authorizes HUD to obtain third-party verification of income information from the
Social Security Administration (SSA) and income return information from the Internal
Revenue Service (IRS). The HUD Form 9886 also specifically authorizes the PHA
to obtain third-party verification of income information from State Wage Information
Collection Agencies (SWICAs) and income information from previous and current
45. Question: What should a PHA do if a State is unresponsive
to requests for third-party verification of unemployment or workers compensation?
Answer: In the event the PHA does not receive a written or oral response
to third- party verification requests, the PHA may review original tenant-provided
documents. If the tenant is unable to provide the PHA with original documents,
as a last resort, the PHA may accept a tenant declaration. In accordance with
CFR 960.259 and 24
CFR 982.516, the PHA must document in the family file why third-party verification
is not available.
46. Question: Does a PHA have to run
a criminal background or credit check, and check the Enterprise Income Verification
(EIV) System for an eligible non-citizen, who just entered the U.S., if the non-citizen
has proof that he or she just came from another country? Can the non-citizen just
provide the INS document, showing he or she just entered the U.S.?
Answer: The PHA has the responsibility of preventing crime in federally
assisted housing. The PHA should complete a criminal background check and should
use the SAVE system on all applicants, regardless of their arrival date into the
United States. Once the applicant has been admitted into a HUD-assisted unit,
the PHA should utilize all up-front income verification
(UIV) tools and the EIV system to verify accurate
disclosure of income by the family. The PHA must establish procedures that are
appropriate and necessary to assure that income data provided by the applicant
or participant families is complete and accurate(24
CFR 982.516(f) and 24
47. Question: Can a PHA use IRS Form 4506 instead
of IRS Letter 1722? The IRS Form 4506 permits the mailing of the return to a third-party,
which would be the PHA.
Answer: The IRS Letter 1722 is no longer
in existence. PHAs may use IRS
Form 4506 to request a copy of a tax return. However, there is a fee of $39
for this service. It may take up to 60 calendar days for the IRS to complete a
request for a tax return.
PHAs may request a transcript of a tax return
by completing IRS
Form 4506-T at no cost. Most requests will be processed within 10 business
days. However, if the information requested relates to information from a return
filed more than four years ago, it may take up to 30 days. On either form, the
PHA may specify that the information be mailed to the PHA directly (i.e., third-party
48. Question: How does HUD feel about blanket verification
and generic consent forms?
Answer: HUD does not encourage the
use of blanket consent forms. However, HUD regulations (24
CFR 5.230(c)) do not prohibit the use of such forms. PHAs should consult with
their legal counsel to ensure that local and state laws do not prohibit the use
of blanket consent forms.
49. Question: Does HUD require a notarized
statement from each head of household stating the household's "total household
income" on one statement? If so, will a PHA be required to obtain these documentations
more than once? Are school emergency cards required?
No. HUD regulations (24
CFR 960.259 and 24
CFR 5.240) do not require notarized statements from households that declare
the "total household income," nor do they require school emergency cards.
PHAs are, however, required to conduct a reexamination of family income and composition
at least annually and verify tenant-supplied documentation (24
CFR 960.257(a) and 24
CFR 982.516(a)). If the PHA decides to require these types of documents from
tenants, it must be written its Administrative Plan (24
CFR 982.54 and/or Annual Plan 24
50. Question: Is a picture ID required, if there is
a birth certificate in the adult tenant's file for establishing legal identity?
Answer: A birth certificate does not establish an adult's legal
identity in determining citizenship for eligibility. Therefore, a PHA may request
a picture ID from an adult for this purpose. HUD regulations (24
CFR 5.508(b)(1)) give PHAs the discretion to determine what appropriate documentation
an applicant or participant is required to furnish to the PHA. Although not inclusive,
the following are acceptable documents to establish identity:
- Certificate of U.S. Citizenship (INS Form N-560 or N-561)
Certificate of Naturalization (INS Form N-550 or N-570)
- Valid foreign
passport, with I-551 stamp or attached INS Form I-94 indicating unexpired employment
- Permanent Resident Card or Alien Registration Receipt
Card with photograph (INS Form I-151 or I-551)
- Valid Employment Authorization
Card (INS Form I-688)
- Valid Reentry Permit (INS Form I-571)
Valid Employment Authorization Document issued by INS, which contains a photograph
(INS Form I-688B)
- Driver's license or ID card issued by a state or outlying
possession of the United States
51. Question: It is clear that
verification documents cannot be older than 60 days for new admissions and 120
days for reexaminations. What is not clear is age of documents from the effective
date of action? Is it from the effective date of the annual reexamination, if
a voucher is not issued; the date of voucher issuance for new admissions and portables;
or is it from the date of the interview with the client or the day the file is
Answer: The age of verification is determined
by using the interview date in which the information is provided to the PHA. Pursuant
PIH 2004-01, Verification Guidance (pg. 10), verification documents must not
be more than 60 days old from the interview date.
52. Question: Based
on the Verification Guidance Notice that is soon to be issued, will PHAs be required
to attempt written third-party prior to oral, as opposed to the regulations, which
don't distinguish between the two types of third-party verifications?
Answer: Yes. While the regulations (24
CFR 960.259(c) and 24
CFR 982.516(a)) do not specify what type of third-party verification is required,
through the issuance of Notice
PIH 2004-01, Verification Guidance, HUD requires PHAs to follow the hierarchy
of verification methods. If UIV is not available, the PHA is expected to pursue
written third-party verification and if the PHA does not receive a response to
its written request for information, the PHA may then resort to oral third-party
53. Question: Are there any benefits to having families
provide notarized statements?
Answer: The only benefit that
a notarized statement has is that the identity of the signer is verified.
Question: A PHA receives UIV data and conducts a recertification; after which,
data is returned from a third-party. The third-party shows that a tenant will
make more than anticipated using UIV, but the increase is below the $200 per month
threshold, as allowable per HUD
guidance. Can a PHA set a threshold amount for conducting interim reexaminations,
based on the receipt of the third-party verification?
Yes. A PHA may set a threshold amount by which the PHA will require an interim
CFR 960.257(c) and 24
CFR 982.516(b)), as a result of an increase in family household income. This
policy must be incorporated in the PHA Administrative Plan (24
CFR 982.54) or Admissions and Continued Occupancy Plan (ACOP).
Question: A family declares that it has received a "loan" from a family
member who resides outside of the assisted family household. The family member
who loaned the money has signed a declaration certifying the amount and terms
of the loan. Is this "loan" excluded from annual income? Can a PHA establish
a policy that requires a tenant to provide documentation that they are actually
repaying the loan in order for the loan amount not to be considered annual income?
Answer: In response to the first question, a loan is excluded from annual
income, as it is a debt that must be repaid (24
CFR 5.609(c)(9)). In the event that the debt is unpaid or forgiven, the loan
is considered nonrecurring or sporadic income and is still excluded from annual
income. In response to the second question, the family must supply any information
that the PHA or HUD determines is necessary in administration of public housing
or HCV programs (24
CFR 5.659 and 24
CFR 960.259). As such, the PHA may establish a policy to specify what documents
a tenant must provide to the PHA, as long as the requested documents are applicable
to the administration of the programs.
56. Question: If a third party
(e.g., employer, banking institution, school, etc.) has notified the PHA that
it charges the tenant a fee for providing third-party verification, does the PHA
have to request from that source for each tenant file? Or, is it sufficient to
have a written statement in the file documenting the requirement to pay a fee?
Answer: If a third party source charges a fee for verification, the PHA
may simply make a photocopy of the letter or statement from the source that confirms
the imposition of a verification fee and place a copy of the letter or statement
in each tenant file in which the fee is applicable.
57. Question: If
a local SSA has informed a PHA that it will not provide third-party verification
directly to the PHA, does the PHA have to notate every tenant file explaining
the circumstances, or can the PHA establish one central file that contains the
Answer: The local SSA will no longer provide verification
of SS benefits, so the PHA must use the EIV system to verify benefits. If the
information is not available in EIV, the PHA must document in each tenant file
the reason third-party verification was not available. Below are some examples
of acceptable file documentation:
(Question Numbers 57-65 are reserved for later use.)
- New admission, information
not available in EIV
- New tenant, information not available in EIV
Current tenant, information not available in EIV due to a change in the re-examination
- Current tenant, information not available in EIV due to discrepancy
with name, date of birth, or SSN in SSA file
Rental Integrity Monitoring (RIM) FAQs
66. Question: If up-front
income verification (UIV) or the EIV is not currently included in the PHA's
Admissions and Continued Occupancy Plan (ACOP) or Administrative Plan in the hierarchy
of verifications, will HUD consider this to be a RIM finding at the time of the
re-review? Can a PHA begin to use the new verification guidance prior to formally
revising its policies?
Answer: The PHA must first amend its
ACOP or Administrative Plan (24
CFR 982.54) to reflect the new verification procedures prior to implementing
UIV or EIV requirements. Notice
PIH 2004-01, Verification Guidance, issued March 9, 2004, requires all PHAs
to include verification procedures in the ACOP or Administrative Plan. The absence
of a UIV policy will not warrant a finding for RIM reviews conducted through FY
2004, as the Verification Guidance Notice was just released. However, the PHA
must demonstrate that it is in the process of revising its ACOP and/or Administrative
Plan to reflect the revised verification procedures. In addition, it is suggested
that PHAs notify residents, in writing, of the new verification procedures in
67. Question: Will RIM reviewers review files of tenants
who are no longer receiving assistance?
Answer: Perhaps. Once
onsite, the HUD reviewer may find that the review of additional tenant file samples,
beyond the regular sample of current tenant files, are necessary to get a complete
picture of PHA income and rent determinations. Additional files could include
applicants, rejected applicant files, former tenants, terminated tenant files,
and tenant files where the PHA has taken lease enforcement actions related to
income and rent, etc. See
the Rental Integrity Monitoring (RIM) Guide for Public Housing and Housing Choice
68. Question: Will RIM reviewers be looking at
issues related to limited English proficiency (LEP) and an LEP family's ability
to understand rules for calculating their subsidy?
RIM reviewers may assess the PHA's policies and procedures for explaining requirements
and providing information to residents and applicants.
If a PHA believes that a Field Office's requirements are more stringent than a
regulation, what are the procedures for challenging the requirement?
Answer: If a PHA believes a Field Office's requirements are outside the
purview of the regulation (and it results in a finding, observation, error, etc.),
the PHA may submit its concerns to the jurisdictional HUD Field as part of a RIM
Review Dispute. See the RIM page for the procedures for
70. Question: What should a PHA do if they are unable
to come to an agreement with the Field Office regarding the RIM report findings
that result in sanctions and/or recovery of disallowed costs?
A PHA has a right to dispute RIM review report findings, errors, corrective actions,
observations and recommendations identified and prescribed by the HUD Field Office,
in writing within thirty (30) calendar days from the receipt of the PHA Review
Summary Report. See the RIM Review Dispute Process on the RIM
page for processing information.
71. Question: Are PHAs required
to address "concerns" or "observations" in their written response
to the Field Office's RIM review report?
Answer: No. PHAs are
not required to respond in writing to Field Office "concerns" or "observations."
However, if it is discovered during the conduction of the RIM
re-review, the "concern" or "observation" was not addressed
at the PHA (i.e., PHA did not update its policies, procedures, and current practices)
and they resulted in errors, the PHA may be issued a finding and sanctions may
be imposed pursuant to Notice
PIH 2003-34. PHAs should take into account, "concerns" and "observations,"
as they will generally lead to better processes and procedures that will reduce
72. Question: Why doesn't HUD's RIM procedure require a control
sheet, including a listing of all the names associated with the tenant file error
Answer: HUD's RIM procedure does not require a control
sheet, including this information, because the first and last name of the head-of-household,
as well as the household address is identified on the Tenant
File Error Report (MS-Excel).
73. Question: When will re-reviews
be scheduled? What files will field offices look at on re-reviews?
Answer: RIM reviews will be scheduled and completed as follows:
Baseline I: The scheduling of RIM re-reviews, to the extent possible, will
allow for fieldwork to be completed by April 30, 2004.
The scheduling of RIM re-reviews, to the extent possible, will allow for fieldwork
to be completed by September 30, 2004. Field Offices will not perform onsite re-reviews
for PHAs where a CAP was not required and systemic errors were not identified.
Field Offices will be looking at newly selected tenant files to determine
the accuracy of income and rent calculations made after the corrective actions
were to have been in place. If the review of the new files shows no new errors
and the Field Office has received sufficient evidence from the PHA to close out
findings related to the files from the initial review, the review of old files
may not be reviewed. However, if the review of the new tenant files shows systemic
errors that are similar to or the same as errors found during the initial RIM
review, the Field Office will review the tenant file errors identified in the
initial review to assure prior discrepancies have been corrected.
are findings or errors that do not impact the entire universe of tenants (e.g.
earned income disallowance (EID), calculation of assets, medical expenses, child
care expenses, etc.), the Field Office will pull a sample of new files targeted
at the specific areas of concern. There is no minimum sample size requirement
in the case of targeted samples. It is left to the Field Office's discretion to
determine the number of files that should be reviewed to confirm that corrective
actions have resolved previously identified problems.
and Sanctions FAQs
74. Question: If a PHA received a RIM review report
prior to the issuance of the Sanctions Notice, and the RIM report required the
PHA to go back three, four, or five years to identify amounts due to tenants,
and then reimburse tenants, is this still required now that the Sanctions Notice
has provided, "PHAs are required to reimburse residents for overpayment of
tenant rent in accordance with PHA policy"?
RIM directives issued by the Field Office prior to the publishing of the Notice
PIH 2003-34, Rental Integrity Monitoring (RIM) Disallowed Costs and Sanctions
under RHIIP will prevail.
75. Question: What is PIH considering for program simplification?
Answer: To simplify the delivery of rental subsidies for low-income families
and allow for greater administrative flexibility to PHAs, the new flexible voucher
program (FVP) will replace the housing choice voucher (HCV) program. Under FVP,
HUD is proposing to switch from a unit-based to a dollar-based grant approach,
including administrative costs as part of the total grant. PHAs will continue
to receive a set dollar amount, adjusted annually for inflation, from the Housing
Certificate Fund; however, PHAs will have the freedom to adjust subsidy levels
based on local market conditions rather than having HUD set these for every market
in the Nation. PHAs will have the autonomy to develop and implement their own,
more simplified, rent policies that are easier for PHAs to understand, administer,
and explain to the residents they serve.
Under HUD's proposed Freedom to
House demonstration program, PHAs will have full discretion to develop their own
rent policies and funding initiatives, including merging or "block granting"
their operating subsidy, modernization, and HCV subsidies without seeking regulatory
waiver from HUD. PHAs may implement flat rents, step rents, rent caps, or any
other reasonable method for determining rent that they believe will simplify their
programs and reduce operating expenses and program errors. PHAs will have the
freedom to adjust the program to the unique and changing needs of their community,
including the ability to set their own subsidy levels based on local market conditions.
See the President's
FY 2005 Budget proposal under Reform Low-Income Housing Assistance.
Up-front Income Verification (UIV) FAQs
76. Question: In trying
to reconcile a question or problem, can PHAs now expect the UIV system to follow
past examples and develop into a reference source, such as the 24
CFR, HUDCLIPS, PIH
notices, housing quality standard (HQS) Manual, FAQs,
PIC, and the Housing
Choice Voucher and Public Housing Occupancy Guidebook.
Answer: Since the UIV system is new, HUD has developed, and will continue
to develop, UIV training materials and provide additional UIV guidance such as
PIH 2004-01, Verification Guidance and HUD
Guidelines for Projecting Annual Income When UIV Data is Available. More information
and tools and resources can be found on PIH's UIV RHIIP
web page: http://www.hud.gov./offices/pih/programs/ph/rhiip/uiv.cfm
Question: UIV shows old UIV Medicare deductions. SSA & SSI letters presented
by tenants show a higher deduction. The "more" than current and "less"
than current rule for calculating anticipated income would have to be applied
in reverse. Correct?
Answer: In the event that a current SSA
benefit verification letter (dated within the last 60 days of the interview date)
indicates a different amount than the EIV benefit history report, the PHA should
use the current tenant-provided benefit verification letter and attach the EIV
benefit history report to the tenant-provided documentation to show that third-
party verification was obtained, but tenant provided documentation was used to
calculate anticipated annual income.
78. Question: Can the UIV system
include HUD Form-50058 information from a past PHA?
No. The UIV system will include Form
HUD-50058 information for all current and active PHAs. The UIV system will
not include archived Form HUD-50058 information from a past PHA.
Question: Are sample SWICA agreements available to PHAs?
No. HUD does not have sample SWICA computer matching agreements for PHAs. The
PHA should contact their local SWICA to obtain the SWICAs standard computer matching
agreement. Please note that once UIV is implemented in that State, the PHA will
no longer be able to obtain wage and unemployment information from the SWICA.
Its agreement with the SWICA will be void, and the PHA will be required to obtain
all wage and unemployment information from HUD's UIV system.
80. Question: Which States currently have agreements with HUD to provide
SWICA data? What States are HUD currently negotiating with or planning to negotiate
Answer: HUD has executed agreements with the following
states: District of Columbia, Florida, Iowa, Illinois, Indiana, Kansas, Kentucky,
Louisiana, Massachusetts, Michigan, Minnesota, Missouri, North Carolina, North
Dakota, Nebraska, New Mexico, New York, Ohio, Pennsylvania, Rhode Island, South
Carolina, South Dakota, Texas, Vermont, and West Virginia. HUD is currently negotiating
agreements with: Arkansas, Maine, Montana, Tennessee, Utah, Virginia and Wyoming.
See the HUD Agreements with SWICAs page for continual
81. Question: How will HUD's implementation of UIV impact PHAs
that already have working relationships and agreements with TANF agencies and
SWICAs? Will those agreements become void, if and when HUD signs agreements with
Answer: No. HUD's implementation of UIV will not
impact a PHAs' working relationships with TANF agencies, since HUD does not receive
welfare benefit information from the local agencies. However, in States where
HUD has executed a computer matching agreement with the local SWICA, PHAs will
no longer be able to obtain wage and unemployment information from the SWICA.
PHAs will be required to obtain all wage and unemployment information from HUD's
UIV system. PHA agreements with local SWICAs will
become void once UIV is implemented in that State.
82. Question: Will
PHA staff that currently does not have access to PIC be able to get access to
the UIV system?
Answer: Yes. However, in order for PHA staff
to access the UIV system, the staff person must have a PIC ID. The PHA must authorize
the assignment of a PIC ID for each staff person that will need access to the
83. Question: Will UIV data show the address of participants
as reported by their employer?
Answer: No. UIV data will not
show the address participants report to employers. However, UIV data will show
the address reported to the SSA for payment of SS benefits.
Will PHAs be able to get UIV data from a neighboring state(s), if it has program
participants who work in neighboring state(s)?
Answer: No. At
this time, UIV data will not be available for tenants who live in one state, but
work in another. There are plans to make this information available in the future.
Question: Under the "HUD
Guidelines for Projecting Annual Income When UIV Data is Available,"guidance
is provided about projecting income when UIV income data is not "substantially
different" than "tenant-provided" income information. What is meant
by "tenant-provided" documents: pay stubs, bank statements, tenant declarations,
Answer: Tenant-provided documents are any
documents that the tenant provides to the PHA (i.e., pay stubs, letters sent directly
to the tenant, bank statements, award letters, etc.).
86. Question: Will
non-PHA, contracted staff be able to access UIV?
HUD will allow PHAs and PHA-designated individuals (administrators of public housing
and HCV programs) to access the UIV system.
87. Question: When will UIV
be rolled-out to all of the PHAs within States that have entered into agreements
Answer: HUD plans to roll out the UIV system to those
States for which data is available by Summer 2004.
88. Question: Will
TANF be rolled into UIV eventually?
Answer: There are no plans
to include TANF benefits in the UIV system.
89. Question: When the UIV
system is compared to information on the Form HUD-50058 (under the Exceeds Threshold
Report), is total income compared, or only those sources of income on which UIV
Answer: The Exceeds Threshold Report will only compare
income sources reported in UIV and on the Form
HUD-50058. There will be a comparison of reported wages, unemployment benefits,
social security benefits, and supplement security income benefits.
Question: What happens if the UIV system is "unavailable" at the time
that a PHA checks? How often should PHAs check the system's unavailability? What
documentation would be necessary to show that the system was unavailable? How
will HUD handle this?
Answer: There will always be UIV data
available for each participant. Data will be updated on a quarterly basis. The
UIV system will display a notification of when new information is available. In
the event that the PHA receives a notification that the UIV system is not available,
or data is not available, the PHA shall print the screen displaying the unavailability
of the system and/or data and place it in the tenant's file to support justification
for relying on tenant provided documents. HUD recommends the PHA check the system
daily to obtain the income data.
91. Question: Why is the SWICA data
in New York State two quarters old?
Answer: Due to the processing
of quarterly data, UIV data will be at least one quarter old. As of March 10,
2004, UIV will display data as of the fourth-quarter of 2003. First-quarter 2004
data will not be available until approximately June 2004.
Regarding UIV discrepancy reports, what will HUD do if a PHA's policy is not to
process interims (few exceptions) with increases? Will a PHA have to change its
Answer: No. Presently, HUD does not require PHAs to process
interim reexaminations (24
CFR 960.257 and 24
CFR 982.516), as a result of increased income. However, the PHA may determine
that based on the review and analysis of income discrepancies, there is a need
to revise the PHA's policy on interim reexaminations for increases in income.
Question: Will HUD take into consideration the PHA Annual Plan when reviewing
the UIV discrepancy reports?
Answer: Yes. HUD will take into
consideration the PHA's Annual plan (24
CFR 903.7), policies, and procedures when reviewing UIV discrepancy reports.
For example, if the PHA's Annual Plan, and/or policies, and/or procedures do not
require interim reexamination for increases, HUD will not expect rent adjustments,
based on increases in income, until the next reexamination.
Will the SWICA information generate an error when there is earned income disallowance
Answer: No. An income discrepancy will not be generated
as a result of the EID. UIV data is compared to Form
HUD-50058 income data before the exclusion. It is imperative that PHAs
report the gross wage and the excluded wages on the Form HUD-50058 to reduce the
level of income discrepancies reported on UIV Exceeds Threshold Reports.
Question: Do PHAs have to request third-party verification from the discrepant
income source, or can the PHA just compare the UIV income data with Form
HUD-50058 to resolve?
Answer: Pursuant to 24
CFR 5.236(3)(i), PHAs must obtain written third-party verification from the
discrepant income source when the tenant-provided income data differs substantially
from that received from his or her employer. As provided by HUD guidance, "HUD
Guidelines for Projecting Annual Income When UIV Data is Available,"
a substantial difference is one that is $200 or more per month.
Question: It can take a participant several months from the date of voucher issuance,
determination of affordability, to executing the housing assistance payment (HAP).
The regulations 24
CFR 982.201 require documentation to be no older than 60 days from the time
of affordability determination. HUD Notice
PIH 2004-01, Verification Guidance mandates documentation to be no older than
60 days from date of "PHA interview date" How do these dates and time
Answer: The regulation (24
CFR 982.201(2)(e)) does not require that documents be no older
than 60 days old from date of affordability determination. It requires the PHA
to receive information verifying that an applicant is eligible: (1) meets
the PHA's definition of "family"; (2) a very-low, low, or moderate-income
family; and (3) a citizen or a non-citizen who has eligible immigration status
as determined by 24
CFR 5.508 within the period of 60 days before the PHA issues a voucher to
the applicant. The forethought is that at the point in time, when the PHA is calculating
anticipate annual income (24
CFR 5.609), the PHA should not rely on documents that are older than 60 days
from the date of this determination.
97. Question: Is Maryland
one of the UIV test sites?
Answer: No. Maryland is not one of
the UIV test sites. Please check the HUD Agreements with SWICAs
web page, regularly, for updates.
98. Question: When there is not
a substantial difference (less than $200 per month) between UIV data and tenant
provided income information, HUD guidance states that PHAs may use the higher
of the UIV data or the tenant provided information to project income, unless the
tenant can provide documentation that the higher amount is no longer accurate
due to a change in circumstances. Can this same philosophy be applied to project
income when there is no substantial difference between third-party verification
and tenant provided income information?
Answer: Yes. "HUD
Guidelines for Projecting Annual Income When UIV Data is Available" philosophy
can be used in situations where there is a difference between tenant-reported
income and income data from third-party verification.
99. Question: Will
independent contractors, working for a PHA, have the ability to access the UIV
Answer: PHAs may request access to UIV for independent
contractors who are responsible for program administration. HUD will authorize
access to UIV by independent contractors only if there is a need for them to access
the information. Independent contractors must still comply with privacy requirements
when using the system. See the UIV System web page
100. Question: Will the Exceeds Threshold Report compare
Public and Indian Housing Information Center (PIC) and UIV data according to current
program rules? For example, will both systems exclude from the comparison, employment
income of a 16-year old?
Answer: The Exceeds Threshold Report
does not consider program rules when identifying household with income discrepancies,
nor will the system exclude any income in accordance with program rules.
Question: Is there a way for the UIV system to include information that a family
has completed the maximum exclusion period under the earned income disallowance
Answer: No. The UIV system is only designed to display
income data and income discrepancies. The system will not include information
on families that have completed the maximum exclusion period under the earned
income disallowance. See the UIV System web page for
system uses and capabilities.
102. Question: What type of action will
HUD take when it appears that a PHA is not following up on discrepancies identified
by the Exceeds Threshold Report? For example, if a PHA does not require tenants
to report interim changes in income, will HUD assume that PHA is not following
up on underreported income?
Answer: The PHA will be subject
to disallowed costs as a result of PHA errors uncovered during RIM reviews that
result in HUD overpayment of subsidy as emphasized in Notice
PIH 2003-34. However, as described in the example, HUD will not assume that
a PHA is not following-up on the unreported income, because the PHA's policies
do not require interim examinations.
103. Question: If a person has
a new last name that has not yet been reported to SSA, will a PHA still be able
to get income information from UIV on the tenant?
a tenant has a new last name and has not reported this information to SSA, and
the PHA records the new name on the Form
HUD-50058, the PHA will not be able to obtain income information from SSA.
The exact name, DoB, and SSN in PIC must match SSA's records. The PHA will be
able to obtain wage information despite the difference in name because only the
SSN is matched against the State Wage Information Collection Agency (SWICA) database.
Question: Will HUD's UIV system include TANF and court-ordered child support payments?
Answer: No. The UIV system will not contain TANF and child support income
because HUD does not have an agreement with local TANF agencies and child support
offices to obtain such information. There is no statute that requires these agencies
to provide HUD this information.
105. Question: Will PHA staff that
want to have access to UIV have to provide their SSN in order to get access?
Answer: Yes. HUD requires disclosure of the SSN for each person who will
access the UIV system.
106. Question: How current will the information
in HUD's UIV system be? Will it contain historical data?
Data in HUD's UIV system will be updated quarterly. Thus, at any give time, the
data will be as recent as the last quarter (i.e. fourth quarter requests for income
data will contain third quarter data). UIV will contain two years of wages and
unemployment data and the last eight changes in SS benefits.
Will the UIV system include the name of the employer?
Yes. The UIV system will include the name of the employer.
Will PHAs have access to UIV information for tenant's who work in a bordering
Answer: Not currently, no. However, there are plans for
future enhancement to the current UIV system to provide wages of tenants that
work outside of the State in which they reside.
109. Question: Will PHAs
only have access to their own tenant's income data or will they be able to access
information for other PHA jurisdictions as well?
will only be able to access income data of those tenants, within their PHA's jurisdiction;
they will not be able to access tenant data for other jurisdictions.
Question: On the Exceeds Threshold Report, will HUD be setting or recommending
the threshold percentage for PHAs to use? If so, what is the recommended or established
Answer: HUD recommends PHAs set the exceeds threshold
percentage high enough to where the most potentially egregious cases are addressed
first, and then move down to a lower percentage, based on PHA available resources.
Alternatively, the PHA may set the Exceeds Threshold Report percentage, based
on the PHA's interim increases policy.
111. Question: When will PIC error
guides be updated so that PHAs are able to correct errors? This will impact the
PHA's ability to successfully utilize UIV.
Answer: HUD is working
on the update to PIC error guides. HUD understands that successful implementation
of UIV is contingent upon accurate, timely, and successful submission into PIC.
Question: Will Field Office staff be trained on the UIV system prior to implementation,
so that they will be able to assist PHAs?
Answer: Yes. Field
Offices will be trained on the UIV system prior to implementation.
Question: After a family is terminated from PH or HCV, how long will family data
continue to appear in the UIV system?
Answer: Data for a terminated
family from public housing or the housing choice voucher (HCV) program will appear
in the UIV system for 60 days after termination, but will be available in HUD's
archived system (HUD review only) for three years.