MULTIFAMILY HOUSING OCCUPANCY TRAINING FOR PROJECT-BASED ASSISTED PROPERTIES

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Rental Housing Integrity Improvement Project
(RHIIP) Initiative

• Secretarial initiative designed to reduce income
  and rent errors and improper subsidy payments
• A comprehensive strategy to address root causes
  of income and rent errors in public housing and
  Section 8 HCV programs
• Takes action to ensure the right benefits go to
  the right persons

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Background

• The 2001 Office of Policy Development and
  Research (PDR) Quality Control for Rental
  Assistance Subsidies Determination (QC) study
  found that HUD overpaid 2.6 billion and
  underpaid 634 million in annual housing
  subsidies
• The QC study estimated that 60 of all rent and
  subsidy calculations contained some type of error

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Presidential Management Initiative 10

• Mandated HUD to reduce the processing
  (administrative errors) error and improper
  payment rate by 50, from 60 to 30 by 2005
• HUD set aggressive interim goals in its Annual
  Performance Plan
• A 15 reduction by FY 2003
• A 30 reduction by FY 2004

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Improper Payments Information Act of 2002

• Requires agencies to
• Annually review all programs susceptible to
  significant erroneous payments
• Measure the number and dollar amounts of errors
  and track progress towards reducing those errors
• Report to the President and Congress, if the
  amount of improper payments exceeds 10 million

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2003 PDR Quality Control Rental Assistance
Subsidies Study Methodology

• HUD PDR measurement of progress in reducing
  errors during FY 2003
• Data collected from over 2,400 households at 600
  sites
• Information from tenant files in-person
  interviews

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2003 PDR Quality Control Rental Assistance
Subsidies Study Results
Rental Assistance Program FY 2003 Estimates of Errors/Gross Erroneous Payments FY 2000 Estimates of Errors/Gross Erroneous Payments Reduction in Gross Errors
Public Housing 356,040 631,776 43.6
Vouchers Mod Rehab 797,508 1,132,560 29.6
Total PHA Administered 1,153,548 1,764,336 34.6
Project-based Assistance 395,796 539,160 26.6
Total 1,549,344 (/ 229,000) 2,303,496 (/ 275,000) 32.7
All values are presented in the thousands.
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FY 2003 Performance and Accountability Report,
Note 17

• Reports that HUD has exceeded its interim 2003
  goal of a 15 reduction in administrative errors,
  based on study results for the first half of FY
  2003
• Describes the methodology used for updating the
  2000 baseline error measurement
• Discusses the corrective actions HUD has taken to
  address the causes of erroneous subsidy payments

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RIM Review Case Studies

• Examined 37 large PHAs who had RIM reviews and
  follow-up reviews
• Concluded that significant errors still existed,
  particularly regarding
• Verification of income
• Improper calculations, including problems with
  utility allowances, deductions, and expenses

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Accomplishments

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Accomplishments for 2003Error Reduction Efforts

• Exceeded HUDs interim FY 2003 goal of a 15
  reduction in estimated program administrator
  errors
• Worked and coordinated with the Inspector General
  (IG) on fraud cases
• Issued a letter to Certified Public Accountants
  (CPAs) to assess, mitigate, report PHA improper
  calculation of subsidy payments
• Presented the strategic goals and RHIIP
  objectives at over 30 conferences/meetings to
  industry group leaders

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Accomplishments for 2003 Monitoring/Reporting

• Conducted over 700 RIM reviews at PHAs managing
  over 80 percent of PIH's funding
• Exceeded the goal of an 85 percent PIC reporting
  rating -- 89 percent for public housing and 98
  percent for HCV

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Accomplishments for 2003 Income Matching

• Developed and began to test pilot the Upfront
  Income Verification (UIV) System at 40 PHAs in 7
  pilot states
• Established agreements with 24 states to allow
  computer matching of tenant income and State wage
  data
• Legislation was introduced in Congress to access
  and use the National Directory of New Hires
  Database to detect unreported income

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Accomplishments for 2003 Guidance/Staff Training

• Released the first Public Housing Occupancy
  Guidebook in over 20 years
• Issued the Notice PIH 2003-34, Rental Integrity
  Monitoring (RIM) Disallowed Costs and Sanctions
  under RHIIP
• Launched the new PIH RHIIP website
• Provided occupancy training to Field Office staff
  and scheduled two regional trainings in occupancy
  for PHA 1/26 to 1/30 and 2/2 to 2/6

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Policy/Guidance

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PIH Policy and Guidance

• Program Simplification Proposals
• Pubic Housing Occupancy and HCV Program
  Guidebooks, June 2003
• Fact Sheet on Income and Rent Determinations,
  November 2002
• Notice PIH 2003-34, Rental Integrity Monitoring
  (RIM) Disallowed Costs and Sanctions under RHIIP,
  December 19, 2003
• Verification Guidance for PHAs (early 2004)

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Up-front Income Verification (UIV)

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Current Sources for UIV Data

• Social Security (SS) and Supplemental Security
  Income (SSI) information accessed via the Tenant
  Assessment Subsystem (TASS)
• State Wage Information Collection Agencies
  (SWICAs)
• State Temporary Assistance for Needy Families
  (TANF) systems
• Private sector databases (e.g., The Work Number)

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HUDs Tenant Assessment Subsystem (TASS)

• The system compares tenant-reported information
  to other HUD systems with income data stored in
  the SSA and the IRS databases
• Displays gross and net benefits for any Social
  Security Number (SSN) that is subsidized by HUD
• HUD strongly encourages PHAs to systematically
  use the system to reduce incidents of undisclosed
  SS and SSI income

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HUDs Tenant Assessment Subsystem (cont.)

• HUD TASS Point of Contact (POC) Myra Newbill
• 202-708-4932 ext. 3211
• HUD TASS website location
• http//www.hud.gov/offices/reac/products/prodtass
  .cfm

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UIV System Pilot

• Commenced on August 18, 2003
• Participants 40 PHAs in 8 states, with over 400
  users
• Currently testing release 3.0.1

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UIV System Pilot (cont.)

• Objectives
• Obtain feedback on how wage and benefit data is
  displayed
• Identify and assess implications of accessing
  SWICA data

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UIV System

• For tenant recertifications, not new
  admissions--wage and benefit data is pulled for
  existing Social Security Numbers (SSNs) in the
  PIC system
• PHAs may not view the tenant data without a
  signed Form HUD-9886, Authorization for the
  Release of Information/Privacy Act Notice in the
  tenants file

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Coming Soon HUD UIV System

• Will make integrated income data available to
  PHAs from one source via the Internet
• Allows PHAs to view quarterly wage,
  weekly/bi-weekly unemployment, and monthly SS
  benefit information for tenants in their
  jurisdiction
• Provides wage and benefit information through a
  data matching process for households covered by
  HUD Form 50058

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UIV System Privacy Requirements

• Data must only be used for verification of tenant
  income and eligibility
• Data must not be disclosed in any way that would
  violate the privacy of the individuals
  represented in the system
• Tenants must be provided with access to their
  records and an opportunity to correct or
  challenge their contents

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UIV System Security

• PHA Responsibilities
• Ensure that access rights, roles and
  responsibilities within PHAs are appropriately
  and adequately assigned and monitored
• Conduct quarterly reviews conducted for all User
  IDs to determine if user still needs access to
  UIV data
• Maintain security-related records
• Conduct security awareness training

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Fraud

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• OFFICE OF INSPECTOR GENERAL U.S. Department
  of Housing and Urban Development WASHINGTON,
  D.C. 20410-4500
• 
  HOTLINE COMPLAINT INTAKE FORM
• COMPLAINT INFORMATION
• Date_______
• COMPLAINANT CONTACT INFORMATION
• PHA Name________________________
• Point of Contact Name______________________
• Address___________________________
• (Street)
• ___________________ _____________
  _______________

Reporting Fraud Hotline [phone] Fax
202-708-4829 Note Incidents of fraud may be
followed-up by HUD Field Offices and the
Inspector General
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United States Attorney
Southern District of New York FOR IMMEDIATE
RELEASE CONTACT U.S. ATTORNEYS OFFICEJUNE
3, 2003 MARVIN SMILON, HERBERT HADAD,
MICHAEL KULSTAD PUBLIC INFORMATION
OFFICE [phone]  BARBARA
GUSS [phone] 31 CHARGED WITH
FEDERAL HOUSING FRAUD THAT COST THE
GOVERNMENT MORE THAN 650,000 JAMES B.
COMEY, the United States Attorney for the
Southern District of New York RUTH A. RITZEMA
the Special Agent in Charge of the New York/New
Jersey Office of the Inspector General of the
U.S. Department of Housing and Urban Development
(HUD) and CHARLES A. COLA, the Commissioner of
the Yonkers Police Department, announced that 31
defendants were charged with obtaining private
housing rental subsidies to which they were not
entitled. Twenty-seven were arrested and 4 others
were being sought. The defendants were
charged in 14 separate criminal Complaints
unsealed in White Plains federal court and were
presented in Court today before United States
Magistrate Judge George A. YANTHIS. The
defendant fraud is alleged to have costthe
federal government more than 650,000.
Reporting Fraud
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• Yonkers housing fraud bust nets charges against
  31
• By WILL DAVID THE JOURNAL NEWS (Original
  publication June 4, 2003)
• YONKERS A federal and local investigation aimed
  at stamping out fraud in the Yonkers Municipal
  Housing Authority's Section 8 rent subsidy
  program culminated yesterday with the arrests of
  27 people, and four others are being sought in
  connection with the probe, authorities said.
• The 31 people charged in the investigation all
  but two from Yonkers are accused of obtaining
  private housing rental subsidies they were not
  entitled to because their incomes were too high,
  said James B. Comey, the U.S. attorney for the
  Southern District of New York.

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Rental Integrity Monitoring (RIM) Re-reviews

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Purpose of Re-reviews

• Confirm whether the PHA has implemented
  corrective actions as outlined in its approved
  corrective action plan (CAP)
• Verify that the implementation of corrective
  actions has led to a reduction of errors
• Determine whether errors identified during the
  initial RIM review have been corrected

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Scheduling of Re-reviews

• Field offices must perform re-reviews to PHAs
  that received initial reviews during periods
• Baseline I (completed prior to 1/31/03).
  Re-reviews to be completed by 4/30/04
• Baseline II (completed after 4/21/03 guidance).
  Re-reviews for PHA programs requiring CAP or when
  systemic errors were found to be completed by
  9/30/04

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Re-review Protocol

• Field Offices must
• Review approved PHA CAP verify implementation
  and establishment of internal controls
• Review initial and newly selected tenant files to
  ensure errors are corrected and determine
  accuracy of income/rent calculations after CAP
  implementation
• Take appropriate action when PHA fails to comply
  with initial RIM review requirements

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Re-review Reporting Requirements

• All re-reviewed PHAs receive a report that
• Details whether all corrective actions have been
  implemented
• Lists findings, required corrective actions,
  observations recommendations from review of new
  file sample
• Details results of re-review of initial RIM
  review tenant files
• Explains any actions/sanctions to be taken
  against the PHA

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Re-review Reporting Requirements (cont.)

• PHAs are provided with final written report
  within 45 days of completion of re-review
• PHAs are required to respond to the review report
  within 30 days, but not later than 45 days
• Response must address problems found or enter
  into CAP any disagreements with findings or
  proposed corrective actions must be addressed
  with the FO at this time

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Re-review Reporting Requirements (cont.)

• If systemic or material findings exist, a copy of
  the review report should be sent to the PHAs
  Independent Public Accountant (IPA) auditor
• If actions must be taken against a PHA for
  failure to address deficiencies from the first
  RIM review, Field Offices must advise the
  Financial Management Center (FMC) to take
  appropriate action

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Sanctions

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Sanctions Notice PIH 2003-34

• Highlights the importance of timely and accurate
  income and rent determinations by PHAs and
  establishes consequences for failure to identify
  and correct deficiencies
• An concerted approach to ensuring improved
  government performance and proper subsidy
  determinations in HUDs rental programs

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Sanctions Notice PIH 2003-34 (cont.)

• Applies to Public Housing and Section 8 HCV
  Program
• Issued December 19, 2003 and its application
  became mandatory for all RIM actionsincluding
  reviews, required PHA responses, and corrective
  actionssubsequent to December 31, 2003

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Sanctions NoticeAreas Addressed

• Incentives, disallowed costs, and collection of
  excess subsidies paid
• Sanctions for failure to timely respond to the
  RIM Review Report and to implement a CAP
• Adjustment of Section 8 Management Assessment
  Program (SEMAP) scores when inconsistent with RIM
  review findings
• Self-assessment reviews
• Appeals

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Disallowed Costs

• Relate to PHA errors uncovered during RIM reviews
  resulting in HUD overpayment of subsidy
• Subsidy overpayments must be returned to HUD
• Note Disallowed costs due to HUD shall be
  forgiven if amounts are less than or equal to
  2,500 per PHA program review

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Disallowed Costs/Excess SubsidiesHCV Program

• Tenant Fraud
• Overpayments PHAs who enter into a repayment
  agreement with the family, initiate litigation
  against the family to recover excess subsidies,
  or initiate termination from the program may keep
  50 of HCV funds collected if certain conditions
  are met. PHAs that do not do any of the above
  actions must return to HUD all amounts that
  constitute a subsidy overpayment
• Underpayments Not applicable

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Disallowed Costs/Excess SubsidiesHCV Program
(cont.)

• PHA Errors
• Overpayments PHA reimburses HUD for 50 of
  disallowed costs in excess of 2,000 dating from
  latest reexamination. PHA must correct tenant
  records and ensure accurate rent payments
• Underpayments PHA may only be reimbursed for
  current fiscal year not yet settled in HUDCAPS.
  PHA reimburses tenant according to PHA policy

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Disallowed Costs/Excess SubsidiesPublic Housing
Program

• Tenant Fraud
• Overpayments If PHAs detect tenant fraud and
  enter into a repayment agreement with the family,
  sue the family to recover excess subsidies, or
  initiate eviction (public housing), they may keep
  100 of fraud collections. PHAs that do not do
  any of the above actions must return to HUD all
  amounts that constitute a subsidy overpayment
• Underpayments Not applicable

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Disallowed Costs/Excess SubsidiesPublic Housing
Program (cont.)

• PHA Errors
• Overpayments If the errors affect the rent roll
  used for operating subsidy calculation, HUD will
  calculate disallowed costs based on subsidy
  overpayment
• Underpayments PHAs will not be reimbursed by
  HUD. PHA reimburses tenant according to PHA
  policy

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Sanctions

• If a PHA does not respond to a RIM Review Report
  within 45 days or does not implement corrective
  actions within approved timeframes, the Field
  Office can withhold
• 10 of its monthly scheduled HCV administrative
  fee
• 5 of its monthly scheduled Public Housing
  operating subsidy
• Withholding begins with the month the sanction is
  imposed and lasts until the PHA complies with
  program requirements

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SEMAP Indicator 3

• A RIM review may serve as a SEMAP confirmatory
  review
• If a RIM review doesnt support a PHAs
  self-certification of SEMAP Indicator 3
  (Determination of Adjusted Income) the Field
  Office must adjust the SEMAP score, regardless of
  its impact on the PHAs performance designation
• If a RIM review finds other indicators are not
  supported by file or other documentation, the
  SEMAP score for those indicators shall be
  adjusted

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Self-Assessment Reviews

• During FY 2004 and FY 2005, HUD will conduct
  targeted and random RIM reviews of PHAs managing
  over 250 combined units of public housing and
  vouchers
• HUD strongly encourages PHAs to conduct
  self-assessment reviews to quality control and
  ensure that the PHAs income and rent
  determination process is in compliance with
  program requirements
• RIM reference materials are available at
  http//www.hud.gov/offices/pih/programs/ph/rhiip/i
  ndex.cfm

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Sanctions NoticeAppeals

• A PHA may appeal a sanction/disallowed cost to
  its Field Office within 30 days of imposition of
  adverse action(s)
• Written appeals must provide material evidence or
  justification of any arguments or additional
  facts and data concerning the action
• The Field Office must respond within 30 days from
  the receipt of a request for an appeal or the
  appeal is automatically granted

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Sanctions NoticeAppeals (cont.)

• If the Field Office denies the appeal, the PHA
  has 15 days to appeal to the PIH Assistant
  Secretary
• If the appeal is denied by the Assistant
  Secretary, there are no further appeals permitted
  for that sanction/disallowed cost
• Note For adjustments of SEMAP scores as a result
  of a RIM review, please refer to the SEMAP
  appeals process

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PHAs and RHIIP

• HUD is committed to its error reduction goals,
  but we need PHA cooperation and support to
  succeed in all our RHIIP initiatives!

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PHA Action The Key to a Successful 2004!

• Know and refer to HUD guidance materials
• Follow-up on RIM review findings
• Implement TASS and UIV to the extent possible
• Visit the new PIH RHIIP website often at
  http//www.hud.gov/offices/pih/programs/ph/rhiip/i
  ndex.cfm
• Run your program like a business!

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Resolution for 2004

• To continue to work together to further reduce
  errors in 2004 and ensure that theres more
  housing money for those who need it the most.

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Questions and Answers