Enterprise Income Verification
The EIV system
HUD developed the EIV (Enterprise Income Verification) system as a tool to meet the objective of assuring that the "right benefits go to the right persons." The EIV system is a federal database that provides quick, easy access to resident income information. The intent of the EIV system is to streamline and simplify the income verification process at the time of recertification, by providing an independent source that systematically and uniformly maintains income information.
Deadline to implement EIV
On December 29, 2009 HUD published the Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Programs Final Rule (http://edocket.access.gpo.gov/2009/pdf/E9-30720.pdf). The Final Rule became effective January 31, 2010 and includes the mandatory use of the EIV system. As a result, Owners/Agents must use the EIV system as a third party source to verify tenant employment and income information during any recertification/reexamination of family composition and/or income.
When conducting an MOR, SHCC will follow HUD Notice H 10-08 regarding a 5% penalty properties will incur if one of the following occur:
- An O/A did not complete all required steps to obtain access to the EIV system by the January 31, 2010 deadline:
- Submit a hardcopy CAAF to the Multifamily Helpdesk by December 15, 2009, and
- Submit the online EIV certification request by January 15, 2010
- Document follow-up with the Multifamily Help Desk if access has not been obtained
- Begin implementing use of EIV immediately upon receiving access
- An O/A is not using EIV in accordance with the EIV Housing Notice, HUD Notice H 09-20.
- An O/A is not using EIV as outlined in the property's Tenant Selection Plan and EIV Policies and Procedures.
The 5% penalty that will be assessed is detailed in HUD Notice H 10-08, Paragraph V (D)(2). To view a copy of HUD Notice H 10-08, click here.
Data contained in the EIV system
Resident income information obtained from the Social Security Administration (SSA) and Department of Health and Human Services (HHS) is available in the EIV system. The SSA information includes Social Security benefits, Supplemental Security Income (SSI) benefits, Dual Entitlement benefits, and Medicare Insurance Premiums. The HHS information includes data from the National Directory of New Hires (NDNH), and provides you with information on new hires, employment wages per quarter, and unemployment compensation benefits.
Through the use of the EIV system you are able to:
- Identify cases of unreported or under-reported resident income
- Identify potential cases of current residents who are receiving HUD subsidy under multiple rental housing assistance programs
- Check whether an applicant is already receiving rental housing assistance from another subsidized source
Accessing EIV
To obtain access to HUD's EIV system, visit http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/applyforeivaccess.pdf and follow the required steps for sign-up. Questions regarding accessing EIV can be submitted to HUD's Multifamily Help Desk at 1-800-767-7588 or mf_eiv@hud.gov.
Maintaining EIV Access Documentation
Upon obtaining EIV access, the following documents must be retained and made available to HUD/SHCC upon request:
- Written authorization from the owner to access EIV data for the property
- List of EIV Coordinator(s) and EIV User(s) who currently have access to the EIV system
- HUD approved EIV Coordinator Access Authorization Form(s) (CAAFs) for each EIV Coordinator assigned to the property (original and current)
- EIV Coordinator approved EIV User Access Authorization Form(s) (UAAFs) for each employee assigned access to EIV data for the property (original and current)
- Signed Rules of Behavior document for each person that does not have access to the EIV system, but will be reviewing EIV data for authorized purposes
EIV Policies/Procedures
The Owner/Agent is required to develop policies and procedures regarding the use of EIV data and securing EIV data. These policies, at a minimum, must include the following:
- A description of when each of the EIV system reports will be used, to include:
- The frequency or timeframes that each of the EIV Income Reports will be accessed or utilized (during any recertification/reexamination of family composition and/or income).
- The frequency or timeframes that each of the EIV Verification Reports will be accessed or utilized: Existing Tenant Search, Identity Verification Report (required on a monthly basis), Multiple Subsidy Report, and Deceased Tenant Report.
- A System Security portion that describes the Technical, Administrative, and Physical Safeguards that have been implemented to safeguard EIV data. For additional information, click here.
- EIV access may only be granted to individuals with a need to access the data.
- A current, signed, and dated HUD-9887/9887A must be on file before EIV data is accessed for a resident.
- EIV use must be restricted to official business purposes only.
- To view an SHCC EIV Policy Checklist (based on HUD guidance as of 2/25/10) click here.
EIV Training
HUD EIV Webcasts:
- On December 16-17, 2008 HUD held a two-day EIV instructional course via webcast. This training covered topics ranging from gaining and continuing EIV access, using EIV income information and verification reports, resolving tenant income discrepancies, and PBCA/HUD monitoring of Owner/Agent EIV use during the annual MOR.
- On December 29, 2009 HUD posted an EIV Instructional Course via webcast. This training focuses on the practical use of the EIV system and system security.
- On February 25, 2010 HUD held an EIV Q&A webcast, answering questions that arose from the December 29, 2009 webcast.
- On April 14, 2010 HUD held an EIV webcast, Implementing Instructions for the Mandatory use of EIV.
- These four webcasts, as well as supplemental Power Point presentations, can be found at:
http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/eivtraining.cfm
and
http://portal.hud.gov/portal/page/portal/HUD/webcasts/archives/multifamily
HUD Notice H 2010-10:
- On July 1, 2010, HUD issued an updated EIV system Housing Notice (H 2010-10). The Notice is informative and provides guidance on how to use EIV income data and verification reports. This Notice supersedes HUD's previous Notices on EIV (H 2008-03 and H 2009-20). To view a copy of HUD Notice H 2010-10, click here.
