The Latest on EIV

I really am beginning to think there's a reason my spellcheck suggests "evil" as the correction every time I type an email containing "EIV."  It's another of HUD's moving targets - the guidance changes frequently, and there are numerous parts to remember.  If you thought the guidance was done with the last memo, think again.  HUD has issued a new memo regarding EIV, and there are some very important elements.

By way of overview, HUD Notice 2013-06 does the following:

*     Advises that Section 811 Project Rental Assistance Demonstration units under 
      a Rental Assistance Contract are now under EIV requirements (Section II)

*     Includes a description of the active link found in the Identity Verification Report 
      Statistics.  The resulting report identifies the number of households represented 
      as not-verified (verification in process) (Section VII).

*     The "No Income Report" is now the "No Income Reported by HHS or SSA" report
      (Section VII).

*     Adds a new report - "No Income Reported on 50059" and discusses how the 
      report should be used (Section VII).

*     Identifies the New Hires report as a Verification Report and its location in the 
      Income Reports section of the system (Section VII).

*     Allows a violation for an owner/agent not having access and/or not using the 
      EIV system in its entirety to be identified and the penalty to be assessed 
      outside the scope of the MOR (Section XI).

Be sure to read the whole notice.  Perhaps the most important elements are the new report and the advisory on penalties, so I'll go into those a little more here.

The "No Income Reported on 50059" Report (p. 30 of Notice):
This report is located in the Monthly Summary Report when querying by Project Number or Contract Number.  If the text is underlined, it is an active link.  Print the summary page. 

Although HUD does not require you to keep a copy of this report on file, EHM does.  The EIV policy and attending documents will be revised shortly to reference this report, and will require the following:

*  The report must be run monthly as with your other EIV reports

*  If there are no "No Income Reported" reports, just file the summary page

*  If there are "No Income Reported" reports, print them and file. 

* Be sure to verify income status with households reporting zero income every 90 days by     
  means of the Zero Income Questionnaire.

For a screenshot of what the page looks like, click here.

Penalties:
If you do not have the CAAF on site, signed by HUD and the Owner, it is a significant issue.  Your reviewer will actually stop the review to get up and notify HUD of this, and your EIV access will be immediately cut off.

Any EIV violation results in a significant negative impact on the outcome of your review.  Be sure you know what the rules are, and follow them.

Remember that you must have EIV training yearly.  It is your responsibility to arrange for such training, unless you are informed that we will be doing an EIV training in-house.