INTRODUCTION The PHA must verify all information that is used to establish the family’s eligibility and level of assistance and is required to obtain written authorization from the family in order to collect the information. Applicants and program participants must cooperate with the verification process as a condition of receiving assistance. The PHA must not pass on the cost of verification to the family. The GFHA will follow the verification guidance provided by HUD in Notice PIH 2018-18 and any subsequent guidance issued by HUD. This chapter summarizes those requirements and provides supplementary GFHA policies.
PART I: GENERAL VERIFICATION REQUIREMENTS 7-I.A. FAMILY CONSENT TO RELEASE OF INFORMATION [24 CFR 982.516 AND 982.551, 24 CFR 5.230] The family must supply any information that the GFHA or HUD determines is necessary to the administration of the program and must consent to GFHA verification of that information [24 CFR 982.551].
Consent Forms It is required that all adult applicants and participants sign form HUD-9886, Authorization for Release of Information. The purpose of form HUD-9886 is to facilitate automated data collection and computer matching from specific sources and provides the family's consent only for the specific purposes listed on the form. HUD and the GFHA may collect information from State Wage Information Collection Agencies (SWICAs) and current and former employers of adult family members. Only HUD is authorized to collect information directly from the Internal Revenue Service (IRS) and the Social Security Administration (SSA). Adult family members must sign other consent forms as needed to collect information relevant to the family’s eligibility and level of assistance.
Penalties for Failing to Consent [24 CFR 5.232] If any family member who is required to sign a consent form fails to do so, the GFHA will deny admission to applicants and terminate assistance of participants. The family may request an informal review (applicants) or informal hearing (participants) in accordance with GFHA procedures.
7-I.B. OVERVIEW OF VERIFICATION REQUIREMENTS HUD’s Verification Hierarchy [Notice PIH 2018-18] HUD mandates the use of the EIV system and offers administrative guidance on the use of other methods to verify family information and specifies the circumstances in which each method will be used. In general HUD requires the GFHA to use the most reliable form of verification that is available and to document the reasons when the GFHA uses a lesser form of verification. In order of priority, the forms of verification that the GFHA will use are:
Up-front Income Verification (UIV) using HUD’s Enterprise Income Verification (EIV) system
Up-front Income Verification (UIV) using a non-HUD system
Written Third-Party Verification (may be provided by applicant or participant)
Written Third-party Verification Form
Oral Third-party Verification
Each of the verification methods is discussed in subsequent sections below.
Requirements for Acceptable Documents GFHA Policy Any documents used for verification must be the original (not photocopies) and generally must be dated within 60 days of the GFHA request. The documents must not be damaged, altered or in any way illegible.
Printouts from web pages are considered original documents.
The GFHA staff member who views the original document must make a photocopy.
Any family self-certifications must be made in a format acceptable to the GFHA and must be signed by the family member whose information or status is being verified.
File Documentation The PHA must document in the file how the figures used in income and rent calculations were determined. All verification attempts, information obtained, and decisions reached during the verification process will be recorded in the family’s file in sufficient detail to demonstrate that the PHA has followed all of the verification policies set forth in this plan. The record should be sufficient to enable a staff member or HUD reviewer to understand the process followed and conclusions reached.
GFHA Policy The GFHA will document, in the family file, the following:
Reported family annual income
Value of assets
Expenses related to deductions from annual income
Other factors influencing adjusted income
When the GFHA is unable to obtain third-party verification, the GFHA will document in the family file the reason that third-party verification was not available [24 CFR 982.516(a)(2); Notice PIH 2018-18].
7-I.C. UP-FRONT INCOME VERIFICATION (UIV) Up-front income verification (UIV) refers to the PHA’s use of the verification tools available from independent sources that maintain computerized information about earnings and benefits. UIV will be used to the extent that these systems are available to the GFHA.
There may be legitimate differences between the information provided by the family and UIV-generated information. If the family disputes the accuracy of UIV data, no adverse action can be taken until the GFHA has independently verified the UIV information and the family has been granted an opportunity to contest any adverse findings through the informal review/hearing process of the GFHA.
See Chapter 6 for the GFHA’s policy on the use of UIV/EIV to project annual income.
Upfront Income Verification Using HUD’s Enterprise Income Verification (EIV) System (Mandatory) PHAs must use HUD’s EIV system in its entirety as a third-party source to verify tenant employment and income information during mandatory reexaminations or recertifications of family composition and income in accordance with 24 CFR 5.236 and administrative guidance issued by HUD.
The EIV system contains data showing earned income, unemployment benefits, social security benefits, and SSI benefits for participant families. The following policies apply to the use of HUD’s EIV system.
EIV Income and Income Validation Tool (IVT) Reports The data shown on income and income validation tool (IVT) reports is updated quarterly. Data may be between 3 and 6 months old at the time reports are generated.
GFHA Policy The GFHA will obtain income and IVT reports for annual reexaminations on a monthly basis. Reports will be generated as part of the regular reexamination process.
Income and IVT reports will be compared to family-provided information as part of the annual reexamination process. Income reports may be used in the calculation of annual income, as described in Chapter 6-I.C. Income reports may also be used to meet the regulatory requirement for third party verification, as described above. Policies for resolving discrepancies between income reports and family-provided information will be resolved as described in Chapter 6-I.C. and in this chapter.
Income and IVT reports will be used in interim reexaminations to identify any discrepancies between reported income and income shown in the EIV system, and as necessary to verify earned income, and to verify and calculate unemployment benefits, Social Security and/or SSI benefits. EIV will also be used to verify that families claiming zero income are not receiving income from any of these sources.
Income and IVT reports will be retained in participant files with the applicable annual or interim reexamination documents.
When the GFHA determines through EIV reports and third-party verification that a family has concealed or under-reported income, corrective action will be taken pursuant to the policies in Chapter 14, Program Integrity.
EIV Identity Verification The EIV system verifies tenant identities against SSA records. These records are compared to PIC data for a match on social security number, name, and date of birth.
PHAs are required to use EIV’s Identity Verification Report on a monthly basis to improve the availability of income information in EIV [Notice PIH 2018-18].
When identity verification for a participant fails, a message will be displayed within the EIV system and no income information will be displayed.
GFHA Policy The GFHA will identify participants whose identity verification has failed by reviewing EIV’s Identity Verification Report on a monthly basis.
The GFHA will attempt to resolve PIC/SSA discrepancies by obtaining appropriate documentation from the participant. When the GFHA determines that discrepancies exist due to GFHA errors such as spelling errors or incorrect birth dates, the errors will be corrected promptly.
Upfront Income Verification Using Non-HUD Systems (Optional) In addition to mandatory use of the EIV system, HUD encourages PHAs to utilize other upfront verification sources.
GFHA Policy The GFHA will inform all applicants and participants of its use of the following UIV resources during the admission and reexamination process:
HUD’s EIV system
The Work Number and similar systems as needed
7-I.D. THIRD-PARTY WRITTEN AND ORAL VERIFICATION HUD’s current verification hierarchy defines two types of written third-party verification. The more preferable form, “written third-party verification,” consists of an original document generated by a third-party source, which may be received directly from a third-party source or provided to the GFHA by the family. If written third-party verification is not available, the GFHA must attempt to obtain a “written third-party verification form.” This is a standardized form used to collect information from a third party.
Written Third-Party Verification [Notice PIH 2018-18] Written third-party verification documents must be original and authentic and may be supplied by the family or received from a third-party source. Examples of acceptable tenant-provided documents include, but are not limited to: pay stubs, payroll summary reports, employer notice or letters of hire and termination, SSA benefit verification letters, bank statements, child support payment stubs, welfare benefit letters and/or printouts, and unemployment monetary benefit notices.
The GFHA is required to obtain, at minimum, two current and consecutive pay stubs for determining annual income from wages. The GFHA may reject documentation provided by the family if the document is not an original, if the document appears to be forged, or if the document is altered, mutilated, or illegible.
GFHA Policy Third-party documents provided by the family must be dated within 60 days of the GFHA request date.
If the GFHA determines that third-party documents provided by the family are not acceptable, the GFHA will explain the reason to the family and request additional documentation.
As verification of earned income, the GFHA will require the family to provide the two most current, consecutive pay stubs totalling at least 28 days of employment. At the GFHA’s discretion, if additional pay stubs are needed due to the family’s circumstances (e.g., sporadic income, fluctuating schedule, etc.), the GFHA may request additional pay stubs or a payroll record.
Written Third-Party Verification Form When upfront verification is not available and the family is unable to provide written third-party documents, the GFHA must request a written third-party verification form. HUD’s position is that this traditional third-party verification method presents administrative burdens and risks which may be reduced through the use of family-provided third-party documents.
PHAs may mail, fax, or email third-party written verification form requests to third-party sources.
GFHA Policy The GFHA will send third-party verification forms directly to the third party.
Third-party verification forms will be sent when third-party verification documents are unavailable or are rejected by the GFHA.
Oral Third-Party Verification [Notice PIH 2018-18] For third-party oral verification, GFHA contacts sources, identified by UIV techniques or by the family, by telephone or in person.
Oral third-party verification is mandatory if neither form of written third-party verification is available.
Third-party oral verification may be used when requests for written third-party verification forms have not been returned within a reasonable time—e.g., 10 business days.
PHAs should document in the file the date and time of the telephone call or visit, the name of the person contacted, the telephone number, as well as the information confirmed.
GFHA Policy In collecting third-party oral verification, GFHA staff will record in the family’s file the name and title of the person contacted, the date and time of the conversation (or attempt), the telephone number used, and the facts provided.
When any source responds verbally to the initial written request for verification the GFHA will accept the verbal response as oral verification but will also request that the source complete and return any verification forms that were provided.
When Third-Party Verification is Not Required [Notice PIH 2018-18] Third-party verification may not be available in all situations. HUD has acknowledged that it may not be cost-effective or reasonable to obtain third-party verification of income, assets, or expenses when these items would have a minimal impact on the family’s total tenant payment.
GFHA Policy If the family cannot provide original documents, the GFHA will pay the service charge required to obtain third-party verification, unless it is not cost effective in which case a self-certification will be acceptable as the only means of verification. The cost of verification will not be passed on to the family.
The cost of postage and envelopes to obtain third-party verification of income, assets, and expenses is not an unreasonable cost [VG, p. 18].
Primary Documents Third-party verification is not required when legal documents are the primary source, such as a birth certificate or other legal documentation of birth.
Imputed Assets HUD permits PHAs to accept a self-certification from a family as verification of assets disposed of for less than fair market value [HCV GB,p. 5-28].
GFHA Policy The GFHA will accept a self-certification from a family as verification of assets disposed of for less than fair market value.
Value of Assets and Asset Income [24 CFR 982.516(a)] For families with net assets totaling $5,000 or less, the PHA may accept the family’s declaration of asset value and anticipated asset income. However, the PHA is required to obtain third-party verification of all assets regardless of the amount during the intake process and at least every three years thereafter.
GFHA Policy For families with net assets totaling $5,000 or less, the GFHA will accept the family’s self-certification of the value of family assets and anticipated asset income when applicable. The family’s declaration must show each asset and the amount of income expected from that asset. All family members 18 years of age and older must sign the family’s declaration.
The GFHA will use third-party documentation for assets as part of the intake process, whenever a family member is added to verify the individual’s assets, and every three years thereafter.
7-I.E. SELF-CERTIFICATION When HUD requires third-party verification, self-certification or “tenant declaration,” is used as a last resort when the PHA is unable to obtain third-party verification.
Self-certification, however, is an acceptable form of verification when:
A source of income is fully excluded
Net family assets total $5,000 or less and the PHA has adopted a policy to accept self certification at annual recertification, when applicable
The PHA has adopted a policy to implement streamlined annual recertifications for fixed sources of income (See Chapter 11)
When the PHA was required to obtain third-party verification but instead relies on a tenant declaration for verification of income, assets, or expenses, the family’s file must be documented to explain why third-party verification was not available.
GFHA Policy When information cannot be verified by a third party or by review of documents, family members will be required to submit self-certifications attesting to the accuracy of the information they have provided to the GFHA.
The GFHA may require a family to certify that a family member does not receive a particular type of income or benefit.
The self-certification must be made in a format acceptable to the GFHA and must be signed by the family member whose information or status is being verified.