PART II: VERIFYING FAMILY INFORMATION 7-II.A. VERIFICATION OF LEGAL IDENTITY GFHA Policy The GFHA will require families to furnish verification of legal identity for each household member.
If a document submitted by a family is eligible for any reason or otherwise questionable, more than one of these documents may be required. If none of the above is available, other documentation may be accepted by the GFHA at the GFHA’s sole discretion.
Legal identity will be verified for all applicants at the time of eligibility determination and in cases where the GFHA has reason to doubt the identity of a person representing him or herself to be a participant.
7-II.B. SOCIAL SECURITY NUMBERS [24 CFR 5.216, Notice PIH 2018-24] The family must provide documentation of a valid social security number (SSN) for each member of the household, with the exception of individuals who do not contend eligible immigration status. Exemptions also include existing program participants who were at least 62 years of age as of January 31, 2010, and had not previously disclosed an SSN.
Note that an individual who previously declared to have eligible immigration status may not change his or her declaration for the purpose of avoiding compliance with the SSN disclosure and documentation requirements or penalties associated with noncompliance with these requirements. Nor may the head of household opt to remove a household member from the family composition for this purpose.
The GFHA must accept the following documentation as acceptable evidence of the social security number:
An original SSN card issued by the Social Security Administration (SSA)
An original SSA-issued document, which contains the name and SSN of the individual
An original document issued by a federal, state, or local government agency, which contains the name and SSN of the individual
The GFHA may only reject documentation of an SSN provided by an applicant or participant if the document is not an original document or if the original document has been altered, mutilated, is illegible, or appears to be forged.
GFHA Policy The GFHA will explain to the applicant or participant the reasons the document is not acceptable and request that the individual obtain and submit acceptable documentation of the SSN to the GFHA within 90 days.
In the case of Moderate Rehabilitation Single Room Occupancy (SRO) individuals, the required documentation must be provided within 90 calendar days from the date of admission into the program. The GFHA must grant one additional 90-day extension if it determines that the applicant’s failure to comply was due to circumstances that were beyond the applicant’s control and could not have been reasonably foreseen.
If an applicant family includes a child under 6 years of age who joined the household within the 6 months prior to the date of voucher issuance, an otherwise eligible family may be admitted to the program and the family must provide documentation of the child’s SSN within 90 days of the effective date of the initial HAP contract. A 90-day extension will be granted if the GFHA determines that the participant’s failure to comply was due to unforeseen circumstances and was outside of the participant’s control.
GFHA Policy The GFHA will grant one additional 90-day extension if needed for reasons beyond the applicant’s control, such as delayed processing of the SSN application by the SSA, natural disaster, fire, death in the family, or other emergency.
When a participant requests to add a new household member who is at least 6 years of age, or who is under the age of 6 and has an SSN, the participant must provide the complete and accurate SSN assigned to each new member at the time of reexamination or recertification, in addition to the documentation required to verify it. The GFHA may not add the new household member until such documentation is provided.
When a participant requests to add a new household member who is under the age of 6 and has not been assigned an SSN, the participant must provide the SSN assigned to each new child and the required documentation within 90 calendar days of the child being added to the household. A 90-day extension will be granted if the GFHA determines that the participant’s failure to comply was due to unforeseen circumstances and was outside of the participant’s control. During the period the GFHA is awaiting documentation of the SSN, the child will be counted as part of the assisted household.
GFHA Policy The GFHA will grant one additional 90-day extension if needed for reasons beyond the participant’s control such as delayed processing of the SSN application by the SSA, natural disaster, fire, death in the family, or other emergency. Social security numbers must be verified only once during continuously-assisted occupancy.
GFHA Policy The GFHA will verify each disclosed SSN by:
Obtaining documentation from applicants and participants that is acceptable as evidence of social security numbers
Making a copy of the original documentation submitted, returning it to the individual, and retaining a copy in the file folder
Once the individual’s verification status is classified as “verified,” the PHA may, at its discretion, remove and destroy copies of documentation accepted as evidence of social security numbers. The retention of the EIV Summary Report or Income Report is adequate documentation of an individual’s SSN.
GFHA Policy Documentation accepted as evidence of social security numbers will generally be retained by GFHA, but may be removed and destroyed by the GFHA upon request from the household.
7-II.C. DOCUMENTATION OF AGE A birth certificate or other official record of birth is the preferred form of age verification for all family members. For elderly family members an original document that provides evidence of the receipt of social security retirement benefits is acceptable.
GFHA Policy The GFHA will require the family to submit documents that support the reported age of the family member (e.g., school records, driver's license if birth year is recorded) and to provide a self-certification.
Age must be verified only once during continuously-assisted occupancy.
7-II.D. FAMILY RELATIONSHIPS Applicants and program participants are required to identify the relationship of each household member to the head of household. Definitions of the primary household relationships are provided in the Eligibility chapter.
GFHA Policy Family relationships are verified only to the extent necessary to determine a family’s eligibility and level of assistance.Certification by the head of household normally is sufficient verification of family relationships.
Separation or Divorce GFHA Policy Certification by the head of household is normally sufficient verification. If the GFHA has reasonable doubts about a separation or divorce, the GFHA will require the family to provide documentation of the divorce or separation.
A certified copy of a divorce decree, signed by a court officer, is required to document that a couple is divorced.
A copy of a court-ordered maintenance or other court record is required to document a separation.
If no court document is available, documentation from a community-based agency will be accepted.
Absence of Adult Member GFHA Policy If an adult member who was formerly a member of the household is reported to be permanently absent, the family must provide evidence to support that the person is no longer a member of the family (e.g., documentation of another address at which the person resides such as a lease or utility bill) if the GFHA requests.
Foster Children and Foster Adults GFHA Policy Third-party verification from the state or local government agency responsible for the placement of the individual with the family is required.
7-II.E. VERIFICATION OF STUDENT STATUS General Requirements GFHA Policy The GFHA requires families to provide information about the student status of all students who are 18 years of age or older. This information will be verified only if:
The family reports full-time student status for an adult other than the head, spouse, or cohead.
The family reports child care expenses to enable a family member to further his or her education.
The family includes a student enrolled in an institution of higher education.
Restrictions on Assistance to Students Enrolled in Institutions of Higher Education This section applies only to students who are seeking assistance on their own, separately from their parents. It does not apply to students residing with parents who are seeking or receiving HCV assistance.
GFHA Policy In accordance with the verification hierarchy described in section 7-1.B, the GFHA will determine whether the student is exempt from the restrictions in 24 CFR 5.612 by verifying any one of the following exemption criteria:
The student is enrolled at an educational institution that does not meet the definition of institution of higher education in the Higher Education Act of 1965 (see section Exhibit 3-2).
The student is at least 24 years old.
The student is a veteran, as defined in section 3-II.E.
The student is married.
The student has at least one dependent child, as defined in section 3-II.E.
The student is a person with disabilities, as defined in section 3-II.E, and was receiving assistance prior to November 30, 2005.
If the GFHA cannot verify at least one of these exemption criteria, the GFHA will conclude that the student is subject to the restrictions on assistance at 24 CFR 5.612. In addition to verifying the student’s income eligibility, the GFHA will then proceed to verify either the student’s parents’ income eligibility (see section 7-III.J) or the student’s independence from his/her parents (see below).
Independent Student GFHA Policy The GFHA will verify a student’s independence from his/her parents to determine that the student’s parents’ income is not relevant for determining the student’s eligibility by doing all of the following:
Either reviewing and verifying previous address information to determine whether the student has established a household separate from his/her parents for at least one year, or reviewing and verifying documentation relevant to determining whether the student meets the U.S. Department of Education’s definition of independent student (see section 3-II.E)
Reviewing the student’s prior year income tax returns to verify the student is independent or verifying the student meets the U.S. Department of Education’s definition of independent student (see section 3-II.E)
Requesting and obtaining written certification directly from the student’s parents identifying the amount of support they will be providing to the student, even if the amount of support is $0, except in cases in which the GFHA determines that the student is a vulnerable youth (see section 3-II.E)
7-II.F. DOCUMENTATION OF DISABILITY The PHA must verify the existence of a disability in order to allow certain income disallowances and deductions from income. The PHA is not permitted to inquire about the nature or extent of a person’s disability [24 CFR 100.202(c)]. The PHA may not inquire about a person’s diagnosis or details of treatment for a disability or medical condition. If the PHA receives a verification document that provides such information, the PHA will not place this information in the tenant file. Under no circumstances will the PHA request a participant’s medical record(s). For more information on health care privacy laws, see the Department of Health and Human Services’ website at http://www.hhs.gov/ocr/privacy/. The above cited regulation does not prohibit the following inquiries, provided these inquiries are made of all applicants, whether or not they are persons with disabilities [VG, p. 24]:
Inquiry into an applicant’s ability to meet the requirements of ownership or tenancy
Inquiry to determine whether an applicant is qualified for a dwelling available only to persons with disabilities or to persons with a particular type of disability
Inquiry to determine whether an applicant for a dwelling is qualified for a priority available to persons with disabilities or to persons with a particular type of disability
Inquiring whether an applicant for a dwelling is a current illegal abuser or addict of a controlled substance
Inquiring whether an applicant has been convicted of the illegal manufacture or distribution of a controlled substance
Family Members Receiving SSA Disability Benefits Verification of the receipt of disability benefits from the Social Security Administration (SSA) is sufficient verification of disability for the purpose of qualifying for waiting list preferences (if applicable) or certain income disallowances and deductions [VG, p. 23].
GFHA Policy For family members claiming disability who receive disability benefits from the SSA, the GFHA will attempt to obtain information about disability benefits through the HUD Enterprise Income Verification (EIV) system. If documentation from HUD’s EIV System is not available, the GFHA will request a current (dated within the last 60 days) SSA benefit verification letter from each family member claiming disability status. If the family is unable to provide the document(s), the GFHA will ask the family to request a benefit verification letter by either calling SSA at 1-800-772-1213, or by requesting it from www.ssa.gov. Once the applicant or participant receives the benefit verification letter they will be required to provide it to the GFHA.
Family Members Not Receiving SSA Disability Benefits Receipt of veteran’s disability benefits, worker’s compensation, or other non-SSA benefits based on the individual’s claimed disability are not sufficient verification that the individual meets HUD’s definition of disability in 24 CFR 5.403.
GFHA Policy For family members claiming disability who do not receive disability benefits from the SSA, a knowledgeable professional must provide third-party verification that the family member meets the HUD definition of disability. See the Eligibility chapter for the HUD definition of disability. The knowledgeable professional will verify whether the family member does or does not meet the HUD definition.
7-II.G. CITIZENSHIP OR ELIGIBLE IMMIGRATION STATUS [24 CFR 5.508] Overview Housing assistance is not available to persons who are not citizens, nationals, or eligible immigrants. Prorated assistance is provided for "mixed families" containing both eligible and ineligible persons. A detailed discussion of eligibility requirements is in the Eligibility chapter. This verifications chapter discusses HUD and PHA verification requirements related to citizenship status.
The family must provide a certification that identifies each family member as a U.S. citizen, a U.S. national, an eligible noncitizen or an ineligible noncitizen and submit the documents discussed below for each family member. Once eligibility to receive assistance has been verified for an individual it need not be collected or verified again during continuously-assisted occupancy. [24 CFR 5.508(g)(5)]
U.S. Citizens and Nationals HUD requires a declaration for each family member who claims to be a U.S. citizen or national. The declaration must be signed personally by any family member 18 or older and by a guardianfor minors.
The PHA may request verification of the declaration by requiring presentation of a birth certificate, United States passport or other appropriate documentation.
GFHA Policy Family members who claim U.S. citizenship or national status will not be required to provide additional documentation unless the GFHA receives information indicating that an individual’s declaration may not be accurate.
Eligible Immigrants Documents Required All family members claiming eligible immigration status must declare their status in the same manner as U.S. citizens and nationals.
The documentation required for eligible noncitizens varies depending upon factors such as the date the person entered the U.S., the conditions under which eligible immigration status has been granted, age, and the date on which the family began receiving HUD-funded assistance. Exhibit 7-1 at the end of this chapter summarizes documents family members must provide.
PHA Verification [HCV GB, pp. 5-3 and 5-7] For family members age 62 or older who claim to be eligible immigrants, proof of age is required in the manner described in 7-II.C. of this plan. No further verification of eligible immigration status is required.
For family members under the age of 62 who claim to be eligible immigrants, the PHA must verify immigration status with the United States Citizenship and Immigration Services (USCIS).
The PHA will follow all USCIS protocols for verification of eligible immigration status.
7-II.H.VERIFICATION OF PREFERENCE STATUS The PHA must verify any preferences claimed by an applicant that determined placement on the waiting list.
GFHA Policy The GFHA will offer a preference to any family that has been terminated from its HCV program due to insufficient program funding. The GFHA will verify this preference using the GFHA’s termination records.
The GFHA also offers a preference for victims of domestic violence, dating violence, sexual assault, or stalking, who are seeking an emergency transfer from a covered housing program operated by the GFHA (as described in Section 4-III.C). To verify that applicants qualify for the preference, the GFHA will follow documentation requirements outlined in Section 16-IX.D.
The GFHA offers a working preference (this preference is currently suspended). The GFHA will verify this preference through 3rd party verification. When appropriate, disabled or elderly status will be verified in accordance with 7-II.C. and 7-II.F. of this Chapter.
The GFHA offers a residency preference. The GFHA will verify through review of the following documents and in accordance with the GFHA Local Residency Preference Form. Acceptance or rejection of alternate forms of verification may occur at the discretion of GFHA.
Residency: two of the below documents reflecting address :
Utility bill with family name
Mail from the SSA
Unemployment benefits letter
Letter from social service organization
Financial institution documentation
Educational or school record
Current Driver’s License or state issued Identification Card
Work: Employment record or letter reflecting the work address is within the GFHA’s Local Residency Preference jurisdiction
Hired to work: Letter of hire reflecting the work address as within the GFHA’s Local Residency Preference jurisdiction
Homeless applicants: documentation from a local homeless shelter, health or homeless services entity, social security administration, or law enforcement or other government entity reflecting the individual/family is homeless within the GFHA’s jurisdiction.
The GFHA offers a Chronically Homeless preference. The GFHA will verify through: review of third party referrals and/or verification of status as an individual/household experiencing chronic homelessness. Generally, this information would be provided by health or homeless services entities, law enforcement, or other government entities reflecting the individual/family meets the definition of chronically homeless. Acceptance or rejection of alternate forms of verification may occur at the discretion of GFHA.
The GFHA offers a Transitional Housing preference. The GFHA will verify through: review of third party referrals and/or verification of status as an individual/household transitioning out of an institutionalized setting. Generally, this information would be provided by health or homeless services entities, law enforcement, or other government or charitable entities reflecting the individual/family meets the requirements of the Transitional Housing preference. Acceptance or rejection of alternate forms of verification may occur at the discretion of GFHA.