Office of Public Housing

1
Office of Public Housing and Voucher
Programs NAHRO Detroit Conference Detroit,
Michigan
July 16, 2004
2
Table of Contents

• Welcome and Introduction
• Section I. Rental Housing Integrity Improvement
  Project (RHIIP)
• Section II. Income and Rent Problem
• Section III. Overview of Upfront Income
  Verification (UIV)
• Section IV. UIV System Roll Out Implementation
• Section V. Using the UIV System
• Section VI. Office of Inspector General (OIG)
  Role
• Section VII. PHA Perspective on UIV
• Section VIII. Other RHIIP Initiatives
• Section IX. RHIIP and You

3
Section I

• Rental Housing Integrity Improvement Project
• Our Strategy for Improving Income Integrity

4
Rental Housing Integrity Improvement Project
(RHIIP)

• Initiated in 2001
• Addresses root causes of errors and improper
  payments
• Department-wide effort to ensure that the right
  benefits go to the people who need it most

• Notes
• Initiated in 2001, after the release of the 2001
  (QC) study. Comprehensive strategy designed to
  reduced income and rent errors in public housing
  and HCV programs. Program Office Participants
  include Office of Multifamily Housing Programs,
  Office of Policy Development and Research (PDR),
  and the Office of Chief Financial Officer (CFO).

5
Section II

• Income and Rent Problem

6
2001 Quality Control for Rental Assistance
Subsidies Determination Study

• The 2001 (QC) study found that
• HUD overpaid 2.6 billion
• Underpaid 634 million in annual housing
  subsidies
• Estimated that 60 of all rent and subsidy
  calculations contained some type of error

Source 2001 Office of Policy Development and
Research (PDR) Quality Control for Rental
Assistance Subsidies Determination study
7
Most Common Sources of Errors

• Administrative
• Calculation errors
• Failure to verify income/expenses
• Failure to use UIV techniques
• Component
• Incorrect income and deduction amounts (i.e.,
  earned income, pension income, and medical
  allowances)

8
Improper Payments Information Actof 2002

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

9
Presidential Management Agenda

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

10
Section III

• Overview of Upfront Income Verification (UIV)
• The Biggest Bang for the Buck!

11
UIV

• Highest form of income verification
• Verification Guidance, Notice PIH 2004-01 (see
  attachment)
• Verification of income, before or during, a
  family re-certification through an independent
  source

Notes HUD strongly recommends PHAs make use of
the Tenant Assessment Subsystem (TASS), now, to
verify tenant-reported income. PHAs may also
obtain UIV through the following methods (1)
computer matching agreements with a Federal,
State, or local government agency, or a private
agency and (2) submit direct requests for income
verifications to a Federal, State, or local
government agencies or a private agency.
12
Why Is UIV Important?

• To
• Ensure that more eligible families have an
  opportunity to benefit from HUDs rental
  assistance programs
• Increase the accuracy of rent and income
  determinations
• Reduce incidents of underreported and unreported
  household income

13
UIV Overall Impact

• Integral to meeting the 50 error reduction goal
  by FY 2005
• Will reduce incidents of underreported and
  unreported household income
• Will replace the more time-consuming and less
  accurate third-party verification process

14
UIV Dollar Impact

• Of the 2.6 billion in overpayment errors, per
  the 2001 QC study, 1.8 billion (69) was
  attributed to unreported and earned
  income-related errors.

860 Other
33.1
130 Million Excess Subsidy Unreported Unearned
Income
5
31.1
32.6
848 Million Excess Subsidy Unreported Earnings
809 Million Macro Earned Income Related Errors
15
2001 Study Results
Dollars in Millions
Col. 1 Col. 2 Col. 3 Col. 4 Col. 5 Col. 6 Col. 7
Excess Subsidy Unreported Earnings Excess Subsidy Unreported Unearned Excess Subsidy POA Error Excess Subsidy POA Error Excess Subsidy POA Error Total Subsidy Overpayments Total Subsidy Underpayments Net Subsidy Error
IRS/SSA Match (REAC) IRS Match (REAC) Macro SSA/SSI/ Asset/Other Income and Deduction, Exclusion, Calculation Errors Macro Earned Income Related Errors Total Macro, Inc. Columns 1, 2 and 5 Macro, Inc. Columns 6 and 7
Public Housing 280 14 195 236 431 725 (201) 524
HCV/Mod Rehab 369 49 493 383 876 1,294 (256) 1,038
S8 Project Based 199 67 172 190 362 628 (177) 451
TOTAL 848 130 860 809 1,669 2,647 (634) 2,013
16
Section IV

• UIV System Roll Out Implementation
• Making it Happen!

17
UIV System

• Integrated data available through HUDs
  secure-system via the Internet
• Provides wage, unemployment compensation,
  Supplemental Security Income (SSI) and Social
  Security (SS) benefit information
• Provides income discrepancy reports

• Notes
• Allows PHAs to view quarterly wage, employer,
  weekly/bi-weekly unemployment benefit payments,
  monthly Social Security (SS) and Supplemental
  Security Income (SSI) benefits, and Medicare
  deductions and/or buy-ins for tenants in the
  PHAs Jurisdictions. Provides income discrepancy
  reports to identify families who may have
  substantially underreported household income.
  Users must have a valid Form HUD-9886,
  Authorization for the Release of
  Information/Privacy Act, signed by all household
  members who are at least 18 years of age to view
  income data in the system alternative consent
  forms are not acceptable for PHA use.

18
Benefit of the UIV System

• Replaces the more time consuming income
  verification process
• Available on-line at staff level
• Provides for integrity in HUD programs
• Under the FVP, can lead to higher income to PHAs

19
UIV System

• Wage and benefit data is pulled for existing
  Social Security Numbers (SSNs) in the PIC system
  (i.e. Form HUD-50058)
• PHAs must not view the tenant data without a
  signed Form HUD-9886, Authorization for the
  Release of Information/Privacy Act Notice in the
  tenants file

20
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

21
UIV System Roll out

• System goes live in August 2004, with phased
  implementation, NY first
• Satellite training was held on 6/28/04, available
  at http//www.hud.gov./webcasts/archives/ph.cfm

22
Executed Computer Matching Agreements with SWICAs
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 West Virginia

23
States In Production

• Florida
• Iowa
• Illinois
• Indiana
• Kansas
• Louisiana
• Michigan
• Minnesota
• Missouri
• North Carolina

• North Dakota
• Nebraska
• New Mexico
• New York
• Ohio
• Pennsylvania
• Rhode Island
• South Carolina
• Texas
• Vermont

24
UIV System Getting Ready

• PHAs should be
• Determining who will need access to the system
• Reviewing and revising policies as a result of
  implementing UIV into PHAs operations
• Concluding how the PHA will include UIV as a part
  of the reexamination process
• Reviewing policies impacted by the prospect of
  underreported and unreported income
• Note
• Questions regarding UIV should be directed to
  UIV_help_at_hud.gov

25
UIV Security Management

• Review internal security procedures
• Ensure PHAs ability to safeguard UIV data
• Conduct periodic reviews of all User IDs to
  determine if the user still needs access
• File and maintain UIV data in a secure area
• Conduct security awareness training for
  authorized UIV system users

26
Section V

• Using the UIV System
• The KEY to reducing income and rent errors

27
UIV System Web Sitehttp//www.hud.gov./offices/p
ih/programs/ph/rhiip/uivsystem.cfm
28
Accessing the UIV System

• From your PC, open a web browser, for example,
  Internet Explorer 4.0 or Netscape 4.0

• Type the Uniform Resource Locator (URL)
• or web address of the UIV Logon screen

29
UIV System Preview
30
Welcome Page
31
Youre In!

• Along the left-hand side of the Welcome Page, see
  navigation commands
• Log Off
• Search Income Records
• By Head of Household Information
• Exceeds Threshold Reports
• User Manual

32
Search for Head of Household Information
33
Household Summary and Income Records Status
34
Household Income Details
35
Discrepancy Reports

• Includes
• Total wages, unemployment compensation, and SS
  benefits reported to HUD by the tenant
• Total wages, unemployment compensation, and SS
  benefits reported to HUD by the SSA/SWICA

36
UIV Case Study 1 Valid Wage Discrepancy

• PHA staff interviewed Mr. and Ms. Jones on
  6/12/03
• The projected anticipated annual income was taken
  from HUD Form-50058 (effective date 9/01/03)
• The actual annual income from UIV is for the
  period of 1/01/03 through 12/31/03
• HA receives a UIV Wage Discrepancy Report on
  5/7/04

37
Potential Income Discrepancy
Household Member Name Date of Birth Relationship Reported Income Source Projected Anticipated Annual Income Actual Annual Income Confirmed Using UIV (or Third Party Verification) Potential Income Discrepancy
Jones, Mary 05/14/1951 Head Income In-kind 1,200 1,200 0.00
Jones, Harold 12/08/1971 Adult None 0.00 48,800 (48,800)
Totals 1,200 50,000 (48,800)
38
Potential Income Discrepancy cont.

• Potential income discrepancy for the Jones
  family
• 48,800
• Tenant Reported Income 0
• UIV Reported Income 48,800

39
What Should You Do?

• Action 1
• Obtain UIV Household Income Details Report from
  the UIV system or interim manual UIV Wage Report.
• Action 2
• Compare UIV data to tenant-reported income to
  determine if the tenant failed to report income
  at the time of the re-exam interview.

40
Things to Consider

• Does the UIV data indicate earnings during
  Quarter 4 of 2002, or Quarter 1 or 2 of 2003?
• Did the discrepant household member sign a
  declaration of no income?
• Did the household member fail to provide
  documentation of earnings?
• Is the household entitled to an EID and is it
  correctly reflected on the 50058?

41
Whats Next?

• Action 3
• Contact the tenant to discuss the discrepancy.
• Request current income documents from the tenant.
  
• If the tenant disputes the UIV data, request
  written third-party verification of UIV data.

42
Whats Next? cont.

• Action 4
• Upon validation or confirmation of discrepancy,
  calculate the correct total tenant payment (TTP)
  and retroactive rent payment due to the agency.
• Inform the tenant of retroactive rent due and
  execute a repayment agreement with the tenant.
• Action 5
• Determine the type of adverse action that will be
  taken as a result of lease violation.

43
Adverse Action(s) as Appropriate

• Execute repayment agreement
• Lease termination
• Referral to the OIG
• Other

44
UIV Case Study 2 Invalid Wage Discrepancy

• HA receives a UIV Wage Discrepancy Report for its
  PH program on 5/14/04
• Projected anticipated annual income was taken
  from Form HUD Form-50058 (effective date 11/01/03
• The actual annual income from UIV is for the
  period of 1/01/03 through 12/31/03

45
Potential Income Discrepancy
Household Member Name Date of Birth Relationship Reported Income Source Projected Anticipated Annual Income Actual Annual Income Confirmed Using UIV (or Third Party Verification) Potential Income Discrepancy
Smith, Ray 12/01/1972 Head Wages 26,000 40,000 14,000
Smith, Amy 01/25/1998 Youth
Smith, Rob 04/11/2000 Youth
Smith, Dee 08/12/2002 Youth
Totals 26,000 40,000 (14,000)
46
Things to Consider

• PHA completed Mr. Smiths annual re-exam on
  07/05/03
• PHA does not require tenants to report increases
  in income between annual re-rexams
• Based on tenant-reported pay stubs and
  independent third-party verification, the PHA
  projected the Smiths annual household income at
  26,000
• At the time of the re-exam interview, the
  following UIV data was available

47
Available UIV Wage Data

• Quarter 1 - 2003 6,200
• Quarter 4 - 2002 6,800
• Quarter 3 - 2002 6,500
• Quarter 2 - 2002 6,500

48
Additional UIV Wage Data Attached to UIV Wage
Discrepancy Report

• Quarter 2 - 2003 6,600
• Quarter 3 - 2003 9,100
• Quarter 4 - 2003 18,100

49
What Should You Do?

• Action 1
• Obtain UIV Household Income Data Report from the
  UIV system or interim manual UIV Wage Report.
• Action 2
• Compare UIV data to tenant-reported income, based
  on documents submitted to complete the re-exam.

50
What Should You Do? cont.

• Action 3
• Determine if the tenant failed to report income
  at the time of the re-exam interview.
• Action 4
• In cases where the PHA is uncertain of whether or
  not the increase in income occurred prior to the
  re-exam interview date, the PHA may obtain
  independent third-party verification of the UIV
  reported wages by an employment verification
  request form to the employer listed in the UIV
  system.

51
Results No Adverse Action(s) Necessary

• Based on the review of independent third-party
  verification documentation, it appears that Mr.
  Smith experienced an increase in wages after the
  annual re-exam interview date.
• No adverse action(s) required.

52
Exceeds Threshold Report

• Critical tool for pursuing undisclosed income
• Compares income sources reported in UIV with the
  Form HUD-50058
• Produces an Exceeds Threshold Report for PHA
  inquiry
• PHAs will determine their own Exceeds Threshold
  Report percentage

53
Exceeds Threshold Report
Set Threshold of discrepancy between Household
50058 income vs. UIV Income from wage SSA match
54
PHA Exceeds Threshold Report
55
Exceeds Threshold Report
Detailed Household Report
56
Projecting Annual Income When UIV Data is
Available

• HUD has established the criteria for consistently
  and uniformly resolving both substantial and
  non-substantial income differences between
  tenant-provided and UIV data
• Substantial difference one that is 200 or more
  per month
• Non-substantial difference one that is less than
  200 per month

57
Projecting Annual Income When UIV Data is
Available cont.

• When UIV data is not substantially different than
  tenant-reported income
• If UIV data lt tenant-reported income, use
  tenant-provided documents to calculate
  anticipated annual income
• If UIV data gt tenant-reported income, use UIV
  data to calculate anticipated annual income,
  unless tenant can provide the PHA with acceptable
  documentation to verify a change in
  circumstances.

58
Projecting Annual Income When UIV Data is
Available cont.

• When UIV data is substantially different than
  tenant-reported income
• PHA must request written third party verification
  from the discrepant income source 24 CFR
  5.236(3)(I)
• PHA should review all historical and current
  income data. The PHA may consider historical
  patterns of income in the calculation of annual
  income along with the most current verified
  income.

59
For Help with UIV
UIV_Help_at_HUD.gov Or Contact the RHIIP
Coordinator at your HUD Local Field Office
60
Section VI

• Office of Inspector General (OIG) Role
• Maintaining integrity in HUD programs

61
OIG Role

• Detect, prevent, and investigate allegations of
  PHA and tenant fraud in HUD programs
• Seek administrative sanctions, civil recoveries,
  and/or prosecution of those responsible for fraud
• Keep the Secretary, Congress, and the American
  people fully informed

Note See PIHs RHIIP website for information on
reporting fraud, waste, and abuse in HUD
programs http//www.hud.gov./offices/pih/programs
/ph/rhiip/uivreporting.cfm
62

• 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
63
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
64

• 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.

65
PHA hits possible fraud cases By Araceli
ArreolaThe Paris News Published February 16,
2004 Paris Housing Authority is the first in the
state to use a new trial system designed to catch
and prosecute public housing residents who lie
about their income. Four residents, Teresa
Parkington, Crystle Mooneyham, Ethel Davis and
Hobbie Davis, were indicted Thursday before a
grand jury on securing execution of documents by
deception, County Attorney Mark Burtner said.
Together, these four residents allegedly owe
35,000 in rent due to misrepresentation, he
said.Texas is one of nine states to use Up
Front Income Verification System (UIV), developed
by the Department of Housing and Urban
Development. Other housing authorities plan to
implement it by March 2004.UIV, a secure
Internet-based system, provides housing
authorities with information from the states
wage income agency and Social Security
Administration. That information is then matched
with income certifications, provided by public
housing residents. The certifications, filled
out yearly, are used to determine a residents
rent. Residents must report all income and
employment. After yearly certifications,
residents have 10 days to report any changes to
earnings or new employment. Any unreported
income ... we are now privy to that information,
Denny Head, executive director of Paris Housing
Authority, said. Weve needed this for a long,
long time.
PHA Hits Possible Fraud Cases
 
Notes The Paris News article website
address http//web.theparisnews.com/story.lasso?w
cd11487
66
Section VII

• A PHA Perspective
• Tampa Housing Authority (THA) Fort Worth
  Housing Authority (FWHA)

67
THA Guidelines for Third-Party Verification

• Direct verification methods
• Upfront income verification
• How to use UIV
• How to use The Work Number
• Online child support payments
• Use of third-party verification to supplement UIV

68
THA Guidelines for Third-Party Verification cont.

• Third-party written verification
• Third-party oral verification
• Review of documents
• Self-certification/self-declaration

69
THA Guidelines for Income Discrepancies with UIV
System

• When UIV income data is not substantially
  different than tenant-provided income information
• When income data is substantially different than
  tenant-provided income information

70
Using UIV System Data

• How to determine allowable medical expenses
• When the tenant pays the monthly Medicare premium
  that is deducted from monthly social security
  benefit payment
• When there is a Medicare Buy-in

71
Scenario 1 - Tenant-Paid Medicare Premium
Difference is 66.60 is
Tenant pays Medicare premium.
72
Scenario 1 Tenant-Paid Medicare Premium cont.

• In this case, the tenant pays the Medicare
  premium of 66.60, which is deducted from the
  tenants gross benefit amount, resulting in a net
  social security payment of 587 (653.60 -
  66.60).
• Since N is indicated under Buy-in, the tenant
  pays his/her own Medicare premium. The household
  is entitled to a medical expense deduction,
  subject to 3 of annual income.

73
Scenario 2 Medicare Buy-in
Gross Net benefit is the same. Tenant does not
pay Medicare premium.
Medicare premium is paid by a third party on
behalf of the tenant.
74
Scenario 2 Medicare Buy-in cont.

• In this case, a third party pays the Medicare
  premium of 66.60 on behalf of the tenant. This
  is indicated by a Y under Buy-in. Thus the
  tenants gross and net payment is the same
  (338).
• The 66.60 monthly payment on behalf of the
  tenant is counted as income, however, 100 of
  this income is excluded under 24 CFR 5.609(c)(4),
  since this income is specifically for the cost of
  medical expenses. The household is not entitled
  to a medical expense deduction.

75
THA Guidelines for Verifying Assets

• Family Assets
• Assets disposed of for less than Fair Market
  Value (FMV)
• Savings or checking account interest and dividend
  income
• Interest income from mortgages and similar
  arrangements
• Net rental income from property owned by the
  family

76
Implementing UIV at FWHA

• In September 2003, FWHA began participating in
  the HUD Upfront Income Verification
  (UIV)computer verification program

77
Internal Procedures for Staff Use

• Pull UIV reports approximately sixty (60) days
  prior to annual recertification date
• Pull reports for all persons with zero income
• Compare report with file information
• Calculate any retro rent amount owed
• Notify tenant of rent change and/or any retro owed

78
Internal Procedures for Staff Use cont.

• Enter into repayment agreement and update client
  data, or terminate housing assistance
• Prepare data for OIG on all retro rent owed
• Recommended threshold 2,500
• Each agency should set the thresholds for OIG
  referrals in ACOP and Administrative Plans

79
Tenant Notification

• Send mass notices to all tenants
• Send special notice along with recertification
  letters

80
Staff Training

• Staff attends all satellite broadcasts provided
  by HUD
• 08-19-03 and 06-28-04
• Staff attends all UIV training offered by HUD,
  NAHRO or other training providers
• 04-19-04
• 05-11-04
• 06-03-04

81
Advantages of the System

• System provides past income information
• Unreported and underreported income is discovered
• Staff can determine if a tenant has committed
  fraud
• Incentive for tenant to be forthcoming about all
  household income
• PHA has access to OIG for legal action

82
Retro Cases Confirmed(As of 06-30-04)
PH SEC 8
Total No. of Retro Accounts Confirmed to Date 36 27
Total Retro Amount Owed 83,379 61,773
Repayment Defaults 3 2
Eviction/Assistance Termination for Failure to Enter into Repayment Agreement 1 2
FWHA is processing 5 Public Housing cases and 11
Housing Choice Voucher cases for amounts of
42,542 and 43,656, respectively.

83
FWHA Guidance

• Statistical data must be maintained to assure
  that the PHA collects monies owed to the agency
  (50 HUD 50 PHA)
• PHA must maintain contact and follow-up with OIG
  representative for case disposition.

84
Preparing Your Agency

• Technical (computers, Internet connections, etc.)
• Implementation policies (grace periods)
• Training staff
• Communicating your new policy with residents
  (newsletters, formal letters)

85
Results

• Logistics and overall impressions
• Statistics
• Repayment agreements
• Prosecuting fraud
• Impact on fraud
• Administrative implications

86
Moving Forward Overcoming the Barriers of the
UIV System

• Time delay in UIV wage, unemployment
  compensation, and benefit data
• Logistics

87
Section VIII

• Other RHIIP Initiatives
• A comprehensive approach

88
RHIIP Components

• Rental Integrity Monitoring (RIM)
• Sanctions
• Program Simplification
• Program Guidance
• Training and Technical Assistance
• Error Measurement

Note Information on Program Guidance, Training
and Technical Assistance, and Error Measurement
available at http//www.hud.gov./offices/pih/prog
rams/ph/rhiip/index.cfm
89
Rental Integrity Monitoring (RIM)

• Onsite monitoring of PHA policies and procedures
  related to income and rent determinations by the
  Field Office
• Seeks to improve PHA internal quality control
  systems and procedures for gathering data

90
RIM Reviews Purpose

• Opportunity to
• Detect and address root causes in income and rent
  calculations
• Examine quality control procedures that impact
  the accuracy of rent determinations
• Provide technical assistance, as needed
• Minimize HUDs limited housing resources

91
RIM Re-reviews Purpose

• To determine if
• CAP has been implemented
• Corrective action has led to reduced errors
• Errors discovered during initial review have been
  corrected

Notes The purpose of the onsite RIM re-review
is to confirm whether the PHA has implemented
corrective actions as outlined in its approved
corrective action plan (CAP) verify that the
implementation of corrective action has led to a
reduction of errors determine whether errors
identified during the initial RIM review have
been corrected. The RIM initiative represents an
approach that focuses directly on a PHAs income
and rent calculations and those activities (e.g.,
quality control procedures) that directly impact
the accuracy of income and rent calculations.
92
RIM Re-reviews FY 2004

• As of April 30, 2004, Headquarters has
• Completed 467 RIM reviews of large PHAs,
  comprising of 826 total separate programs (362
  for public housing and 464 for the HCV program)
• Conducted 223 additional reviews at smaller PHAs
  identified as high risk

Notes The Field Office will review sample of new
and old tenant files. Files will be selected at
random.
93
RIM Re-reviews FY 2004 cont.

• RIM re-reviews (follow-up review) of 112 PHAs,
  comprising 175 separate programs (public housing
  and HCV) were conducted by FOs
• Of the 720 re-reviews scheduled for FY 2004, only
  220 re-reviews remain (as of 6/04)
• All field work, to the extent possible, will be
  completed by 9/04

Notes The Field Office will review sample of new
and old tenant files. File selection will be
selected using random selection methodology.
94
Sanctions

• Notice PIH 2003-34, Rental Integrity Monitoring
  (RIM) Disallowed Costs and Sanctions under RHIIP
• Issued December 19, 2003
• Applies to Public Housing and Section 8 HCV
  Programs
• Establishes consequences for failure to identify
  and correct deficiencies
• A concerted approach to ensuring proper subsidy
  determinations in HUDs rental programs

95
Program Simplification

• Rent Simplification Goals
• Minimize the administrative burden and costs on
  PHAs
• Less intrusion in the lives of applicants and
  tenants
• Promote resident self-sufficiency
• Address errors and improper payments as mandated
  by GAO and IG

96
Program Simplification Rent Options

• Income-Based
• Tiered Flat
• Block grant

97
Section IX

• RHIIP and You

98
PHAs Your Role

• Ensure that your PIC reporting rates are high
  (100)
• Notify stakeholders such as tenants, resident
  advisory boards, tenant councils, and others of
  your implementation of UIV
• Investigate tenant income discrepancies

99
Headquarters What were doing

• Providing guidance on UIV and tools such as the
  UIV and TASS systems to obtain tenant income and
  benefits data
• Ensuring full UIV implementation through RIM
  reviews discrepancy reports
• Determining the overall and dollar impact of UIV
  on error reduction goals

100
UIV Tools and Resources

• Tenant Assessment Subsystem (TASS)
• Notice PIH 2004-01, Verification Guidance
• UIV Operations Manual
• UIV System User Manual
• UIV Training Webcast
• UIV Web Site http//www.hud.gov./offices/pih/prog
  rams/ph/rhiip/uivtools.cfm

101
Other Tools and Resources

• Notice PIH 2003-34, Disallowed Costs/Sanctions
• Public Housing Occupancy and HCV Program
  Guidebooks
• Fact Sheet on Income/Rent Determinations
• RHIIP Web Site http//www.hud.gov./offices/pih/pr
  ograms/ph/rhiip/index.cfm

102
Conclusion

• HUD and PHAs must work together to meet the
  presidential mandate and ensure fundamental
  fairness among families.

Cooperation
Commitment
The right benefits for the right persons
Initiative
103
Questions and Answers