The Trainer — October 2014
Using EIV Reports; Passing REAC Inspections After Updated Rules
In this month’s feature, we discussed how to use the HUD-mandated reports generated by the Enterprise Income Verification (EIV) system. These reports are designed to eliminate household fraud, and site owners and managers are required to use them in specific ways.
In this issue’s Compliance article, we discussed the major changes in HUD’s recently issued Real Estate Assessment Center Compilation Bulletin. The bulletin provides updated guidance to Real Estate Assessment Center (REAC) inspectors, answers some of the most common questions received from inspectors in the field, and clarifies certain areas of the inspection protocol to further ensure that physical inspections are objective and conducted in accordance with the Uniform Physical Condition Standards (UPCS) and HUD’s inspection protocol. Site owners and managers need to be aware of these changes to increase their sites’ chances of passing REAC inspections.
QUIZ
QUESTION #1
You must run an EIV Income Report within 90 days after the move-in information is transmitted to TRACS and at each annual and interim recertification. True or false?
a. True.
b. False.
QUESTION #2
You need to run a New Hires report only when a household member reports an increase of $200 or more a month in household income. True or false?
a. True.
b. False.
QUESTION #3
You can run an Existing Tenant Search report without getting a signed 9887/9887-A release of information form from the household. True or false?
a. True.
b. False.
QUESTION #4
To identify current residents who are receiving rental assistance at more than one location, which of these reports should you run?
a. Existing Tenant Search.
b. Multiple Subsidy Report.
c. Summary Report.
d. All of the above.
QUESTION #5
How often should you run a Deceased Tenant Report?
a. Monthly.
b. Quarterly.
c. Semiannually.
d. Annually.
QUESTION #6
Sites are required to retain the EIV reports they run on tenants for the term of the tenancy plus how many years?
a. Three.
b. Five.
c. Seven.
d. Ten.
QUESTION #7
Under the new REAC guidance, model units must always be considered part of the unit count for inspection, not part of the building’s common area. True or false?
a. True.
b. False.
QUESTION #8
If a closet door in a unit has a lock or chain on it, an inspector will consider that a deficiency. True or false?
a. True.
b. False.
ANSWERS & EXPLANATIONS
QUESTION #1
Correct answer: a
True. You must also run an Income Report at any other times indicated in your EIV policies and procedures.
QUESTION #2
Correct answer: b
False. The report should also be run at least quarterly. 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 he provide documents to support current income or, if necessary, request third-party verification from the employer. Next, process an interim recertification to include the new income.
QUESTION #3
Correct answer: a
True. This is the only EIV report you can run without first getting a signed release of information form.
QUESTION #4
Correct answer: b
Unlike the Existing Tenant Search report generated prior to move-in, the Multiple Subsidy Report provides ongoing checks to ensure that residents 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.
QUESTION #5
Correct answer: b
HUD requires that this report be run on a quarterly basis [HUD Handbook 4350.3, par. 9-12(D)(1)(a)].
QUESTION #6
Correct answer: a
In general, HUD requires owners and managers to retain EIV reports run on tenants for the term of the tenancy plus three years.
QUESTION #7
Correct answer: b
False. If the owner or manager states that a model unit is not for rent, it should be considered part of the building’s common area and inspected if that building is selected in the sample. If the owner or manager states that the model unit is available for rent if requested over another vacant unit, then it should be included in the unit count and treated as a vacant unit.
QUESTION #8
Correct answer: b
True. A closet door is considered primary egress from the closet area. Any lock, chain, damaged hardware, or other device that prevents egress from a floor area, which includes all doors on all floors, is considered a blocked egress. However, a padlock or any other locking mechanism used by the site to secure the unit mechanical closet won’t be recorded as a blocked egress. Additionally, similar locking mechanisms, whether installed by the resident or site, to secure the unit’s exterior storage closet or shed won’t be recorded as a blocked egress.