Overview of the Reports Generated by HUD's EIV System

The Enterprise Income Verification (EIV) system is a web-based computer system implemented by HUD that owners have been required to use since January 2010. It contains employment and income information on individuals participating in HUD’s rental assistance programs. It derives data from HUD’s Multi-Family and Public Housing databases, the Social Security Administration (SSA), and the Department of Health and Human Services’ (HHS’) National Directory of New Hires [HUD Handbook 4350.3, par. 9-6(A)].

The information generated by the EIV system is designed to eliminate household fraud. It meets HUD’s requirement to independently verify employment and income when a resident recertifies for continued rental assistance. Site owners and managers are able to use the EIV system to determine if residents correctly reported their income and the income of a spouse or other household member and to determine if a resident used a false Social Security number or if the resident is receiving rental assistance at another site.

To help minimize instances of fraud, the EIV system generates several mandatory reports. Each EIV-generated report can be categorized as an income report, verification report, or a summary report. We’ll discuss the requirements surrounding each of these reports.

[] Summary Report

This report provides a summary of the household information taken from the current, active certifications contained in the Tenant Rental Assistance Certification System (TRACS) at the time the income reports are run. It also shows the four identity verification statuses for each household member: Verified, Failed, Not Verified, and Deceased [HUD Handbook 4350.3, par. 9-12(A)(1)].

Report use. Owners use this report to validate a household member’s Social Security number review and to resolve the status of any household member(s) with a “failed” or “deceased” status.

The report should be printed and placed in the tenant file until each member of the household has the status of “Verified.” Reports run during future recertifications don’t need to be printed unless there’s a household composition change or there’s a change in status for one of the household members.

Frequency. Owners must use this report at the time of recertification (annual and interim) [HUD Handbook 4350.3, par. 9-12(A)(2)].

Retention. Summary report and supporting documentation must be retained in the tenant’s file for the term of tenancy plus three years [HUD Handbook 4350.3, par. 9-12(A)(3)].

[] Income Report

This report provides employment and income information for each household member from HHS and the SSA. The different components of the report are TRACS certification information, employment information, wages, unemployment benefits, Social Security benefits, dual entitlement, Medicare data, and Supplemental Security Income benefits [HUD Handbook 4350.3, par. 9-12(A)(1)].

Report use. The report identifies household members who may not have reported complete and accurate income information and may be receiving multiple subsidies.

The report serves as third-party verification of employment and income. If a tenant agrees that the information in the EIV system is correct with regard to wage and unemployment benefits, the member must provide supporting information such as paycheck stubs or a benefit letter. If the household member disputes the information in the report, third-party verification must be obtained.

For Social Security and Supplemental Social Security benefits, if the tenant agrees the information in the EIV system is correct, no further documentation is required. But if the tenant disputes the information in the report, information of a benefit or award letter must be obtained.

Frequency. This report should be run within 90 days after the move-in information is transmitted to TRACS, at each annual and interim recertification, and at other times indicated in your EIV policies and procedures [HUD Handbook 4350.3, par. 9-12(B)(5)].

Retention. Retain a copy of this report and supporting documentation with the applicable Form HUD-50059 for the term of tenancy plus three years. You must make copies of any tenant-provided documents and return the originals to the tenant [HUD Handbook 4350.3, par. 9-11(B)(2)].

[] Income Discrepancy Report

This report is a tool to alert owners and managers that there may be a discrepancy in the income reported by the household member during the period of income used for the discrepancy analysis. The report identifies households where there’s a difference of $2,400 or more in the wage, unemployment wage, and SSA benefit information reported in EIV and what was reported by the household through Form HUD-50059 in TRACS [HUD Handbook 4350.3, par. 9-11(C)(1)].

Report use. This report must be printed at the same time as the income report. Discrepancies must be reviewed and resolved at the time of recertification or within 30 days of the income report date [HUD Handbook 4350.3, par. 9-11(C)(3)(a-b)].

Be sure to review data in TRACs to make sure it agrees with the HUD-50059 data in the tenant’s file. If it’s found that the information is different, correct the discrepant data in the TRACS database.

Frequency. HUD requires that this report be run at least for every annual and interim recertification. The report may also be used at other times as indicated in an owner’s EIV policies and procedures.

Retention. Place a copy of the Income Discrepancy Report and any documentation related to the resolution of the discrepancy, including any repayment agreements, in the tenant file for the term of tenancy plus three years [HUD Handbook 4350.3, par. 9-11(C)(3)(c)].

[] No Income Reported in 50059

Owners and managers use this report to identify household members who passed the identity match against SSA’s records but don’t have any income represented in the TRACS system [HUD Handbook 4350.3, par. 9-11(D)(1)(a)].

Frequency. Owners run this report as often as identified in the site’s policies and procedures [HUD Handbook 4350.3, par. 9-11(D)(1)(a)(1)].

Retention. You would retain any correspondence or documents received when re-verifying zero-income tenants. Owners are not required to retain copies of this report [HUD Handbook 4350.3, par. 9-11(D)(1)(a)(2)].

[] No Income Reported by HHS or SSA

This report identifies household members who passed the SSA identity test but no income was reported by HHS or SSA. This doesn’t mean that the household member doesn’t have any income. The owner must make sure that, at the time of recertification interviews, the right questions are asked so that the members are given the opportunity to disclose any income they receive. In addition, the owner must obtain written third-party verification of any income reported by the member [HUD Handbook 4350.3, par. 9-11(D)(1)(b)].

Frequency. Owners run this report as often as identified in the site’s policies and procedures [HUD Handbook 4350.3, par. 9-11(D)(1)(b)(1)].

Retention. You would retain any correspondence or documents received when re-verifying zero-income tenants. Owners are not required to retain copies of this report [HUD Handbook 4350.3, par. 9-11(D)(1)(b)(4)].

[] New Hires Report

Members are required to report increases in household income that are equal to $200 per month or more [HUD Handbook 4350.3, par. 9-11(D)(1)(c)(2)]. This report helps ensure that changes in income are being properly reported by indentifying members who have new employment within the last six months [HUD Handbook 4350.3, par. 9-11(D)(1)(c)]. The report is updated monthly.

Report use. If the report shows new employment, contact the household member regarding the new employment. Then confirm the new employment with the member and request that the member provide documents to support current income or, if necessary, request third-party verification from the employer. Next, the owner should process an interim recertification to include the new income, if applicable.

Frequency. The report should be run at least quarterly [HUD Handbook 4350.3, par. 9-11(D)(1)(c)(1)].

Retention. Retain a copy of the report in a master “New Hires Report” file for three years along with notes of the outcome of the contact with the household member. In the tenant file for any pertinent cases, you would retain the New Hires Detail Report for the member along with any correspondence with the member, third-party verifications, and Form HUD-50059(s) for the term of the tenancy plus three years [HUD Handbook 4350.3, par. 9-11(D)(1)(c)(3)(d)].

[] Existing Tenant Search

This report is generated for all applicants including minors to determine if any of the applicants are currently receiving assistance in another subsidized unit [HUD Handbook 4350.3, par. 9-12(A)].

Report use. After running a report, if nobody is found in either HUD’s multifamily database or public housing database, no action is needed. However, if an applicant is found in one of the databases, you must contact the applicant and discuss the circumstances and give the applicant an opportunity to explain being assisted at another site. For example, a shared custody situation could result in a child showing up in two different units.

You should then follow up and confirm the individual’s program participation status before admission and coordinate move-in and move-out dates with the other subsidized site [HUD Handbook 4350.3, par. 9-12(A)(3)].

Frequency. This report is run at the processing of an application for admission. And this is the only report that can be run without a signed 9887/9887-A release of information form [HUD Handbook 4350.3, par. 9-12(A)(1)].

Retention. If not admitted, retain search results and any supporting documentation with the application for three years. If admitted, retain search results and documentation with the application for the term of the tenancy plus three years [HUD Handbook 4350.3, par. 9-12(A)(4)].

[] Multiple Subsidy Report

This report identifies household members who may be receiving rental assistance at more than one location [HUD Handbook 4350.3, par. 9-12(B)]. Unlike the Existing Tenant Search report generated prior to move-in, this report provides ongoing checks to ensure members don’t get multiple subsidies. It allows checks on households after they’ve moved in, so the owner could possibly discover that a household’s composition has changed or that someone moved to another subsidized site without informing the manager.

Report use. If a match is found in one of the databases, you need to obtain more information. You should contact the member to discuss the result and give the member an opportunity to explain. Then you would contact the public housing authority or other owner, if necessary, to confirm that the member is receiving assistance at that site. Depending on the results, you may need to take action to terminate the assistance or tenancy.

Frequency. HUD requires that this report be run on a quarterly basis [HUD Handbook 4350.3, par. 9-12(B)(1)(a)].

Retention. Keep a copy of the Multiple Subsidy Summary Report and supporting documentation in a master “Multiple Subsidy Report” file for three years. In the tenant file, you would place a copy of the Multiple Subsidy Detail Report for the household member along with any supporting documentation of action taken for a household member for the term of tenancy plus three years [HUD Handbook 4350.3, par. 9-12(B)(1)(e)].

[] Failed EIV Pre-Screening Report

This report identifies household members who have missing or invalid personal identifiers such as last name, date of birth, or Social Security number in TRACS [HUD Handbook 4350.3, par. 9-12(C)(1)].

Report use. If identified in the report, you should follow up with household members and verify the personal identifiers. You should also check the accuracy of data entry. If the data was entered incorrectly in the TRACS system, simply correct the information in the system and document what action was taken. If data was entered correctly, obtain documentation from the member and correct incorrect data and resend it through the TRACS system.

This report will also include those household members who are 62 years of age or older as of Jan. 31, 2010, and whose initial determination of eligibility was begun before Jan. 31, 2010, and those individuals who do not claim eligible immigration status who are exempt from the SSN Disclosure and Identification requirements. If this is the case, make a note on the report that this household member is exempt from SSN requirements.

Frequency. HUD requires that this report be generated on a monthly basis [HUD Handbook 4350.3, par. 9-12(C)(1)(a)].

Retention. You should retain a copy of the report in a master file for three years. In the tenant file, place the documentation to verify discrepant personal identifiers for the term of tenancy plus three years [HUD Handbook 4350.3, par. 9-12(C)(1)(f)].

[] Failed Verification Report

This report identifies household members whose last name, date of birth, or SSN don’t match the SSA database [HUD Handbook 4350.3, par. 9-12(C)(2)].

Report use. If a household member shows up on this report, check the accuracy of data entry. Then contact the member and confirm to verify his or her personal identifiers.

If there’s incorrect data in the system, correct TRACS data within 30 days of the date of the report. If the data is determined to be correct, encourage the member to contact the SSA to correct any inaccurate data in the SSA database.

Frequency. HUD requires that this report be generated on a monthly basis [HUD Handbook 4350.3, par. 9-12(C)(2)(a)].

Retention. You should retain a copy of the report in a master file for three years. In the tenant file, place the documentation to verify discrepant personal identifiers for the term of tenancy plus three years [HUD Handbook 4350.3, par. 9-12(C)(2)(h)].

[] Deceased Tenant Report

Families of deceased household members are expected to report the death promptly. In cases in which families don’t report the death promptly, households may collect rental assistance fraudulently or in error. This report identifies members reported by SSA as being deceased [HUD Handbook 4350.3, par. 9-12(D)].

Report use. If this report identifies one of your residents, confirm in writing with the head of the household, next of kin, or contact person provided by the household member to determine whether or not the person is deceased.

If deceased, within 30 days from the date of the report, complete a new recertification updating household composition, income, and assets. If the deceased is the only member of the household, you’ll need to process a move-out using the Form HUD-50059-A. The date of the move-out must be retroactive to the earlier of 14 days after the date of death or date the unit was vacated. In addition, any overpayment of subsidy on behalf of the deceased member must be repaid to HUD and you must have corrected all discrepant information in HUD’s TRACS within 30 days from the date you run the report [HUD Handbook 4350.3, par. 9-12(D)(1)].

Frequency. HUD requires that this report be run on a quarterly basis [HUD Handbook 4350.3, par. 9-12(D)(1)(a)].

Retention. Place the report in your site’s master EIV file. Form HUD-50059 and/or Form HUD-50059-A, plus any documentation received for a deceased tenant, must be retained in the tenant file for the term of tenancy plus three years [HUD Handbook 4350.3, par. 9-12(D)(1)(f)].