Idaho Housing and Finance Association IHFA Monitoring of EIV Use

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Idaho Housing and Finance Association (IHFA)
Monitoring of EIV Use
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Topics covered today

• IHFA Management and Occupancy Review (MOR)
  Process
• Initial MOR Notification Letter
• Desk Review by IHFA pre- MOR
• Day of the MOR
• MOR Report
• Follow-up by IHFA or the Owner/Agent (O/A)
• Records Retention Requirements

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IHFA Note

• On a conference call with HUD on April 8, 2009
  IHFA was informed that HUD will be publishing a
  revised version of chapter 6 of the 4350.1.
  (chapter on MOR processes) When this is published
  it may effect some of these processes.

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Initial Notification Letter

• This letter (form 1) will request (if you
  currently have EIV access) that you make
  available for review, the following security
  related forms
• EIV Coordinator Access Authorization Forms (link
  1)
• EIV User Access Authorization Forms (link 2)
• EIV Owner Approval Letter (form 2)
• Security Awareness Training Questionnaires (link
  3)

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Initial Notification Letter (continued)

• This letter will also request that you make
  available for review on-site
• Development Policy and Procedure Manual(s)
• The EIV Policy and Procedure Manual will be
  reviewed at the time of the MOR.

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IHFA Note

• The security file documentation will be reviewed
  at MOR. IHFA suggests that the coordinator keep
  the following files
• A file that contains all the original/initial and
  current required security forms .
• A file that contains historic documents and/or
  terminated user information.
• Please ensure that the files are available for
  review on the day of the MOR. The files should
  contain forms for anyone that has/had access to
  EIV for this site.

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Questions?
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Desk Review

• The desk review process is completed by the IHFA
  Compliance Auditor prior to conducting the MOR
• The auditor will run the following reports
  regardless of site access to EIV
• Failed Verification Report
• Deceased Tenant Report
• Multiple Subsidy Report
• If there are any discrepancies on any of these
  reports, the auditor will take these reports to
  the MOR and give to the on-site manager for
  follow-up/resolution.

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Desk Review (continued)

• IHFA will run a report from iREMS, (HUD secure
  system for PBCAs) or ask HUD to run this report
  for them (for those sites that we are not granted
  access) that will show everyone with EIV access
  roles.
• This report will be taken to the MOR and used to
  ensure all coordinators/users with access have
  the appropriate security documentation on file.

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Desk Review (continued)

• If the O/A has EIV access, the auditor will also
  run the following reports
• Income Discrepancy Report
• No Income Report
• New Hire Report
• These reports will be used to assist in choosing
  units for audit as well as alert IHFA to any red
  flags regarding income reporting discrepencies at
  the property.

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Questions?
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Day of the MOR

• Policies and Procedures will be reviewed.
• The 3 non-income related reports will be given to
  the O/A for resolution. (if applicable)
• The EIV security file will be audited and
  compared to the report from iREMS/HUD. (form 6)
• The O/A will be interviewed regarding security of
  the data. (form 7 and 8)

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Day of the MOR (continued)

• A sample of tenant files will be audited to
  ensure the correct 9887 and 9887A are completed
  and in file.
• The tenant files will be reviewed for applicable
  EIV reports and supporting documentation to
  verify resolution of discrepancies. (if
  applicable)
• Note IHFA may request additional files for this
  purpose.

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Day of the MOR (continued)

• EIV data/reports will be reviewed to ensure
  compliance with established Polices and
  Procedures.
• Any Discrepancies/Observations/Findings will be
  discussed in the exit interview.

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Questions?
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MOR Report

• Per the HUD webinar conducted December 17 and 18,
  2008, link http//www.hud.gov/webcasts/index.cfm,
  the following Observations/Findings will be
  taken/issued
• Note We understand that this will change when
  EIV becomes mandatory effective September 30,
  2009 . The following is applicable for the 2009
  audit year only.

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MOR Report (continued)

• If the O/A has no EIV access
• Nothing will be communicated on the MOR report.
• If the 9887 and/or 9887 A are not completed and
  in file
• A Finding will be issued, regardless of EIV
  access, in accordance with the HUD Handbook
  4350.3 Rev-1 Chg. 2 guidance.

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MOR Report (continued)

• If the O/A has access to EIV and any of the 4
  required security file documents are not
  completed and/or missing for any current
  coordinator/user
• An Observation will be issued and
• IHFA will e-mail HUD immediately and access to
  EIV could be terminated. If the O/A submits the
  required documents to IHFA, a second e-mail will
  be sent to HUD and access will be reinstated.

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MOR Report (continued)

• The following is an example of the observation
  that will be issued
• O/A did not provide CAAF, UAAF, EIV Owner
  Certification, or Security Awareness Training
  Questionnaires for EIV access, yet O/A is using
  the system to verify income of tenants.  As
  directed by HUD, an email has been sent to the
  Director of the Housing Assistance Policy
  Division at HUD Headquarters to report the
  missing documentation. HUD may terminate user
  and/or coordinator access.

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MOR Report (continued)

• If the O/A has access to EIV and is using the
  system, but does not have established Polices and
  Procedures
• An Observation will be issued.
• Example Owner/Agent must establish policies and
  procedures that provide instruction and
  information on the acceptable use, disposition
  and storage of data obtained through the
  Enterprise Income Verification (EIV) system.  

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MOR Report (continued)

• If the O/A has access to EIV and is not resolving
  the income discrepancies listed on the Income
  Discrepancy Report obtained in EIV (form 9)
• A Finding will be issued.
• Please note that resolution does not necessarily
  mean an increase in the residents rent.

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MOR Report (continued)

• If the O/A has access to EIV and is not using EIV
  data as the preferred method of verification,
  before other acceptable verification methods are
  attempted
• A Finding will be issued.
• Example An O/A is currently using EIV to verify
  SSA data but does not use NDNH or other income
  data.

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MOR Report (continued)

• If the O/A has access to EIV and is not resolving
  discrepancies between EIV data and second party
  verification
• A Finding will be issued.
• Example EIV shows that the resident makes
  300.00 per month but the second party
  documentation provided supports 550.00 per
  month. Third party verification was not obtained
  to clarify this discrepancy.

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Questions?
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Records Retention

• There are very specific time frames attached to
  the retention of the data that is obtained from
  EIV. They are as follows
• Social Security Benefit Data
• Term of tenancy plus 3 years
• National Directory of New Hires (NDNH) data
• 2 years
• If you have a report that contains both, the NDNH
  data must be cut off and removed from the file
  after the 2 year period.

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Records Retention (continued)

• NDNH data must be destroyed at annual
  recertification of the second year.
• When it is destroyed, the file must be noted as
  such as well as the date of destruction.(form
  10)
• The first date to destroy data for residents will
  be January 2010.

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Who does not have access to EIV data

• Tax Credit auditors
• USDA/RD auditors
• Internal auditors such as your CPA firm that
  prepares your Annual Financial Statements.

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IHFA Suggestion

• In order to ensure that you are destroying this
  data according to HUD requirements, and to ensure
  no access is given to unauthorized individuals,
  IHFA is suggesting that a second file, separate
  from the tenant file, be kept that contains only
  the EIV data.

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Other EIV Forms/Guidance

• EIV Quick Start (form 11)
• Complete step-by-step instructions on getting set
  up
• Quarterly Recertification Instructions (form 12)
• Sample EIV Notice to Residents (form 13)

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Resources

• HUD EIV Website http//www.hud.gov/offices/hsg/mf
  h/rhiip/eiv/eivhome.cfm
• IHFA Website http//www.ihfa.org/multifamily_sect
  ion8.asp
• Ross Business Development http//www.rbdnow.com/e
  iv.htm
• Sample forms packet provided today

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Resources (continued)

• HUD RHIIP Website http//www.hud.gov/offices/hsg/
  mfh/rhiip/mfhrhiip.cfm
• EIV Notice http//www.hud.gov/offices/adm/hudclip
  s/notices/hsg/08hsgnotices.cfm 
• RHIIP Q and As http//www.hud.gov/offices/hsg/mf
  h/rhiip/qnaon4350pt3.pdf
• Course materials from this class on the Idaho
  AHMA website http//www.idahoahma.org/events/cour
  se-materials.html

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Resources (continued)

• Misty Schafte Misty.schafte_at_hud.gov 971-222-2656
  
• Sheryl Putnam sherylp_at_ihfa.org 331-4821
• Heather Wiedenfeld heatherw_at_ihfa.org 331-4868
• Noel Gill ngill_at_nwrecc.org

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Final Questions?