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Chapter IV: Income – Allowances, Assets, Expenses, Verifications and Calculations

Effective: September 2009

Introduction

Improving the integrity of income verification is vital for HUD and MSHDA. A recent analysis by HUD determined that only 29% of assisted households were paying the correct rent amount. Incorrect rents being charged to the participants result in inaccurate Housing Assistance Payments (HAP) being paid by MSHDA.

To prevent fraud and abuse in HUD programs, the United States Code (USC) and Code of Federal Regulations (CFR) allow HUD and PHA’s to obtain information about applicants and participants to determine their eligibility or level of benefits. Most importantly, the USC authorizes computer-matching agreements of income information known as Up-front Income Verification (UIV).

Below is a summary of laws and regulations that govern the use of UIV:

  • 24 CFR 5.234 (Requests for Information from SWICAs and Federal Agencies; Restrictions on Use) indicates that income information will generally be obtained through computer matching agreements between HUD and a SWICA or Federal Agency, or between a PHA and a SWICA.
  • 42 USC 3544©(2)(A) (Preventing Fraud and Abuse in Housing and Urban Development Programs) provides the legal basis for preventing fraud and abuse in HUD programs. The law allows HUD to require that applicants and participants sign a consent form to request the following: current or previous wages and salaries from employers, wage information and unemployment compensation from the State agency charged with the administration of the State unemployment law, and income information from the Commissioner of Social Security and the Secretary of the Treasury.

UIV replaces, to a large extent, the more time consuming and less accurate TPV process of contacting individual employers identified by the family or reviewing outdated income verification documents. If a UIV method is not available, an attempt to obtain written TPV must be made.

Compliance with the third party verification (TPV)process and calculating correct participant rent amounts directly affect MSHDA’s SEMAP performance on Indicators 3 (Determination of Adjusted Income) and 10 (Correct Tenant Rent Calculations).

Section A: Income Verification Requirements

1. Gather Applicant/Participant Information for Income Verification

When the income verification process is initiated at the time of initial contract or annual re-examination, the following forms are required to be completed by the Head of Household and every other household member age 18 and over:

  • Household, Income, Asset, and Expense Declaration (MSHDA 1890);
  • Authorization for Release of Information/Privacy Act Notice (HUD 9886);
2. Third Party Verification (TPV) Process

MSHDA HA’s must obtain TPV or document in the file why TPV was not available for the following factors:

  • Reported family annual income;
  • The value of assets;
  • Expenses related to deductions from annual income;
  • Other factors that affect the determination of adjusted income.

Federal Regulations require disclosure of income information and verification from all family members age 18 and over for all earned and unearned income for the household. HAs will verify the accuracy of the information and adjust the family’s household income, which affects the participant’s rent payment.

Each item marked “yes” on the MSHDA 1890 involving income, assets, or deductions must be verified using the TPV process. When reviewing the 1890 and discrepancies are noted between what is reported by the applicant/participant and what is verified through the TPV process, the correct information should be placed on the 1890 in a different colored ink with the date of the change and initials of the person making the correction. This includes adding information when questions on the 1890 were left blank and information needs to be added to the form upon receipt of TPV, or due to information obtained subsequently form the applicant/participant or another source.

HUD requires that income, assets, and deductions be verified through a third party such as an employer, financial institution, DHS caseworker, etc. A participant cannot hand carry documents to or from the verification source.

Verification documents for income, assets, and deductions must be dated within:

  • 60 days prior to the Voucher issuance date; and
  • 120 days prior to the effective date of the transaction (except SS information which must be dated within 60 days for all cases if the SS/SSI benefits cannot be verified for current participants and household members using EIV).

Note: TPV process and time limits do not apply to information that does not require re-verification (proof of age, Social Security cards, etc.) or information regarding the disposal of assets.

Third-Party Verification Hierarchy

HUD has identified a hierarchy of TPV verification. The five levels of verification, in order of acceptance to HUD, are identified below:

  1. Up-front income verification (UIV)
  2. Third party verification, written
  3. Third party verification, oral
  4. Review of original documents (tenant supplied documents)
  5. Family certification (MSHDA 488 or notarized statement)

See Appendix H, Third Party Verification Resources.

3. Up-Front Income Verification (UIV) System

Up-Front income verification (UIV) is the verification of income through an independent source that systematically and uniformly maintains income information in computerized form for a large number of individuals. It is the preferred method of income verification to be used.

Current UIV resources include the following:

  1. Enterprise Income Verification (EIV) System

    The EIV System is intended to provide a single-source of income related data to a PHA for use in verifying the income reported by participants who are being assisted under the various housing programs administered by HUD. The EIV System is required by HUD to be used as the first step in verifying income. The EIV System assists in the verification of income by comparing participant income data obtained from the HUD 50058 form, from data captured in the Public Housing Information Center (PIC), wage and unemployment information from State Wage Information Collection Agencies (SWICA) and Social Security and Supplemental Security Income from the Social Security Administration. The System is only to be used to verify a participant’s eligibility for participation in a HUD rental assistance program and/or determine the level of assistance the participant is entitled to receive. As a condition of receiving the EIV data, safeguards will be required to prevent unauthorized use of the information and to protect the confidentiality of that information.

    Reports which are generated through the HUD EIV system for use by MSHDA staff and housing agents which can be used for the comparison of data include:

    • Identity Verification status confirms tenant personal identifiers with Social Security administration.
    • The Tenant Income Data (TID) Reports which enable the user (HA) to compare current information provided by participant families to the most current state reported wage and unemployment benefit information data available on the EIV system.
    • New Hires report identifies tenants who have started a new job within the last six months.
    • Exceeds Threshold Reports (ETR) which compare PIC data with EIV data and generates a list of families with discrepancies exceeding a percentage selected by the user. This report will be generated and used primarily by the MSHDA EIV Discrepancy Coordinator.
    • Deceased tenant report identifies tenants who are deceased.
    • Multiple subsidy report identifies tenants and family members who may already be receiving rental assistance.

    The HUD EIV system is accessed via the Internet. It is a secure system and requires the use of a PIC ID and password to gain access. The PIC ID and password information is assigned to designated staff and HA’s by MSHDA’s WASS Coordinator.

    Note: When utilizing the EIV system avoid using the search and print functions “By Reexamination Month.” This function will generate verifications for all MSHDA’s residents, which is unnecessary for a HA to generate and will waste resources due to the excessive amount of data produced.

    Federal SSA and SSI: Use EIV as primary TPV. If no EIV, then follow the steps outlined in the TPV hierarchy beginning with the written step of TPV.

    All PHAs are required to use EIV to verify SS/SSI benefits of current participants and househould members. If benefit information is not available in the EIV system, the HA should request a current SSA benefit verification letter from each househould member that receives Social Security benefits. If the participant and/or household members are unable to provide the requested document(s), ask the participant/household member to call SSA at 1-800-772-1213 to request a benefit verification letter. The rquest for a benefit verification letter can also be made at the SSA Internet Website at www.ssa.gov. There is no cost for this verification letter to the participant. Follow the instructions on the page to complete the request for a benefit verification letter. Upon receipt, the participant/household member should provide the PHA with the original benefit verification letter. The PHA should make a photocopy of the original benefit verification letter, return the original benefit verification letter to the participant/household member, and maintain the photocopy of the benefit letter in the tenant file. In the event that third party verification is not available, the HA must document the tenant file as to why third party verification was not available on the Third Party Verification (TPV) Monitoring Form (MSHDA 78).

    A copy of the EIV form must be in every file and submitted with every annual re-examination, move, interim re-examination, and income change submission of paperwork.

  2. Private Sector Databases (e.g. The Work Number)

    You may use the website www.theworknumber.com to obtain UIV employment verification. See Appendix for instructions on accessing the website.

    The Work Number - Employment may be verified via “The Work Number,” an Internet source available to obtain TPV from registered employers. Once the HA accesses and registers with www.theworknumber.com, it is possible to obtain verifications via FAX in approximately five business days. Refer to Appendix, HUD Verification Requirements, for instructions on accessing the website.

    After completing the one-time registration, the HA can order verifications at any time by accessing the website and entering their FAX number, employer code number, and employee (tenant) Social Security number. All information provided is current as of the most recent pay period. There is no cost for the service. The HA must have incoming FAX capability and register as a “Social Services User” with an Agency Type identifier of “Housing Authority.” The Registration Agreement requires confidentiality with regard to any information obtained.

  3. Data Share between MSHDA and Michigan Department of Human Services (DHS).

    The Data Share is now available for receiving UIV information. This information is provided by using the Third Party Verification via Michigan Department of Human Services Database (MSHDA 1795) form. Information available on the MSHDA 1795 includes amounts for State Disability Allowance (SDA), Federal TANF and Federal TANF Sanction amounts, State Assistance Program, Refugee Assistance Program, Childcare paid to the provider; and Childcare paid to the DHS client. It also provides only a yes/no answer for wages reported to DHS, unearned income reported to DHS, Food Assistance Program, and Medicaid Program. Note: The DHS data share link is through the secure Citrix Log-in account.

    Follow these guidelines for using the Data Share:

    1. State Disability Allowance (SDA) – Use the MSHDA 1795 as primary TPV. If the 1795 is not available, then follow the steps outlined in the TPV hierarchy in Income Verification policy beginning with the written step of TPV. Note: If someone receives Federal SSI, check to see if they are receiving State SDA. If no State SDA, note why on the MSHDA 78.
    2. Federal TANF, Federal TANF Sanctions, and Cash Assistance Grant Amounts – Use the MSHDA 1795 as primary TPV. If the number of household members and the flat grant amounts matches the information on the MSHDA 1795, then a MSHDA 107 will not be required. If the information doesn’t match, then determine why. Document your findings on a MSHDA 77 and obtain TPV using the MSHDA 107. If a family member is receiving SSI and is not on TANF, and the SSI amount received matches the flat grant amount received (verify using Appendix Flat Grant Chart), then a MSHDA 107 is not required. If none of the amounts match, a MSHDA 107 is required. If the 1795 is not available, then follow the steps outlined in the TPV hierarchy in Income Verification policy beginning with the written step of TPV.
    3. Childcare paid to provider by DHS – Use the MSHDA 1795 as primary TPV. The MSHDA 1795 will provide the amount paid, effective date, number of children in care, and number of providers. If the data matches the MSHDA 1890, no MSHDA 107 is required. Refer to Chapter IV Expenses. . If the MSHDA 1795 is not available, then follow the steps outlined in the TPV hierarchy in Income Verification policy beginning with the written step of TPV.
    4. Childcare paid to client by DHS – Use MSHDA 1795 as primary TPV. The MSHDA 1795 will provide the amount paid, effective date, number of children in care, and number of providers. If data matches the MSHDA 1890, no MSHDA 107 is required. Refer to Chapter IV. Expenses. If the MSHDA 1795 is not available, then follow the steps outlined in the TPV hierarchy in Income Verification policy beginning with the written step of TPV.
    5. Food Assistance Program – Yes/No answer. This is for information only and cannot be used as a form of TPV. If the MSHDA 1795 is populated with a Yes, then notate on the MSHDA 78 that UIV is not available; and, written TPV using the MSHDA 107 is not permitted per DHS policy based on federal statute that the information cannot be provided. Follow the steps outlined in the TPV hierarchy beginning with tenant supplied documents.
    6. Medicaid Program, Wages reported to DHS and Unearned Income reported to DHS – Yes/No answer. These areas on the form are for information only and cannot be used as a form of TPV. If populated with a Yes on the MSHDA 1795, then make sure the participant has reported the Food Assistance Program, Medicaid information, or wages or unearned income on the MSHDA 1890. Follow the steps outlined in the TPV hierarchy beginning with the written step of TPV. Note the reason for no EIV on the Third Party Verification (TPV) Monitoring form (MSHDA 78).
    7. Child Support Rebates – Child Support Rebate information is no longer available on the datashare. When child support rebates are reported, follow the steps outlined in the TPV hierarchy in Income Verification policy beginning with the written step of TPV. Use of the MSHDA 107 will be required.
    8. DHS Refugee Assistance Program – Use MSHDA 1795 as primary TPV. If the MSHDA 1795 is not available, then follow the steps outlined in the TPV hierarchy in Income Verification policy beginning with the written step of TPV.

Guidelines for Projecting Annual Income When UIV Data is Available

When using a UIV system for verifying income, tenant supplied income documents are compared to the information received through the UIV system.

HUD has established the criteria for what constitutes a substantial difference in cases where UIV income data differs from tenant-provided and/or other verified income information.

  • HUD defines a substantial difference as one that has a gross income difference of $200 or more per month ($2400 per year).
  • Calculate the income from UIV and tenant-provided documentation into monthly amounts in order to compare the two. Show your calculations on the income forms.

In cases where UIV Income Data is Not Substantially Different than Tenant-Provided Income Information follow the guidelines below:

  • If UIV income data is less than current participant-provided documentation, MSHDA will use tenant-provided documents to calculate anticipated annual income.
  • If UIV income data is more than current tenant-provided documentation, MSHDA will use UIV income data to calculate anticipated annual income unless the tenant provides the HA with documentation of a change in circumstances (i.e. change in employment, reduction in hours, etc.). Upon receipt of acceptable participant-provided documentation of a change in circumstances, the HA will use tenant-provided documents to calculate anticipated annual income.
  • UIV will alleviate the need for TPV when there is not a substantial difference between UIV and participant-reported income.

In cases where UIV Income Data is Substantially Different than Tenant-Provided Income Information follow the guidelines below:

  • Request written TPV from the discrepant income source. If unable to obtain written TPV, try to obtain oral TPV. Refer to Section 4, Third Party Verification –Written and Section 5, Third Party Verification – Oral.
  • Review historical income data for patterns of employment, paid benefits, and/or receipt of other income, when the PHA cannot readily anticipate income, such as in cases of seasonal employment, unstable working hours, and suspected fraud.
  • Analyze all data (UIV data, TPV and other documents/information provided by the family) and attempt to resolve the income discrepancy.
  • Use the most current verified income data (and historical income data if appropriate) to calculate anticipated annual income.
  • In rare exceptions, TPV may not be available. When this occurs, the tenant must supply adequate documentation (in addition to the income documents already supplied from tenant) to explain the substantial difference between the UIV data and tenant-supplied data. If tenant is unable to provide adequate documentation, then the HA will use the UIV income data to calculate anticipated annual income.

Note: If the tenant disagrees with the UIV information, it is incumbent upon the tenant to disprove the UIV information.

See theAppendix of the PPM for examples of EIV verification and calculation.

Historical Data on EIV

In addition to projecting tenant income, the HA must review the historical data on the EIV form for unreported and under-reported income.

HA must pursue the verification of all unreported income that is discovered through UIV methods. If participant did withhold information at their last annual re-examination or failed to report additional income, the participant will be required to enter into a Repayment Agreement. Refer to Chapter XXVIII Processing Tenant Repayment Agreements.

If UIV shows a previously undisclosed income source or underreported income, HA will request documentation from the tenant (MSHDA 53) as well as obtain TPV.

If $10,000 or more of unreported household income in a one-year period is discovered and subsequently verified, the HA must contact the MSHDA Compliance Enforcement Coordinator (CEC) to determine an appropriate course of action.

If less than $10,000 of unreported household income in a one-year period is discovered and subsequently verified, the HA will pursue a Repayment Agreement. Failure to execute a Repayment Agreement by the family will result in termination. See Chapter XXVIII. Processing Tenant Repayment Agreements and/or Chapter XXVI. Mediations and Informal Hearings as needed.

If a UIV method is not available, or if there is an income discrepancy involving UIV, an attempt to obtain written TPV must be made.

4. Third Party Verification – Written

If a UIV is not available, or if there is an income discrepancy involving UIV, TPV must be used to verify information directly from the source. Written TPV can be requested from the source by first class mail, E-mail, FAX, or drop off at source, etc. Submit the first request for written TPV directly to each source. If the first request for written TPV is not received from the source within 14 days, a second request for written TPV directly to the source is made. Allow the source 7 days to respond to the second request for written TPV, for a total of 21 days.

Obtain applicant/participant release signatures at the top of the applicable verification forms, or attach a copy of the Authorization for Release of Information/Privacy Act Statement (HUD-9886) with the words “see attached authorization form” written on the signature line of the applicable verification form prior to sending to the source. Multiple forms may be needed to accommodate several sources, such as the need for a separate Verification of Resources (MSHDA 48) if the applicant/participant has three savings accounts at three different financial institutions. The signed verification forms (or a blank form with a copy of signed HUD-9886) are submitted directly to the verification source who then returns the document(s) directly back to the HA.

Requests for written TPV for income/assets/deductions must be made whether or not a MSHDA verification form exists.

If written TPV cannot be obtained (i.e. employer is out of business) then the HA will make the decision as to how best to obtain the required information. However, the TPV hierarchy must be followed, and written documentation must be recorded on the MSHDA 77 or 78 which “tells the story” of attempts at verification and answers received.

The applicant/participant CANNOT hand carry any verification documents to or from the source.

In order to be considered written TPV, the verification must come directly from the source, all required data is present, and the following:

  • Mailed verifications – When possible include the envelope as proof that the verification was received from the TPV source. If more than one verification was received in the envelope, the HAs should notate, date, and sign on each verification form that it was received with other verifications from the source.
  • FAXed verifications must identify the source’s name encoded on the FAX documents, or the cover sheet showing the source’s name must be stapled to the document.
  • E-mail verifications must identify the source’s name or notate, date and sign on the form that the verification came from source via E-mail.
  • Other verifications – for example, the HA stopped by a source’s place of business and picked up verification directly from source. HAs must notate on the form that the verification was picked up directly from the source by the HA, date and sign.

If the TPV received has an appearance that revisions have been made or has been tampered with in some way, then the verification is not acceptable. (Tampering of documents could be white outs, cross outs, different inks, different handwriting, suspicious letterhead or forms, suspicious information, etc.) If applicant/participant fraud is believed to have occurred, please discuss possible termination with your RS.

The TPV 21 day process clock begins on the day that the first attempt for written TPV is made to each source. Note: The TPV clock does not start with the request for required documents (MSHDA 53) to the applicant/participant.

Medical/Pharmacy Release of Information Exceptions: Due to HIPAA confidentiality reporting laws, it may be necessary to use verification/release of information forms provided by the source (i.e. Wal-Mart and K-Mart) instead of MSHDA forms, which the applicant/participant must sign requesting that the information be sent to MSHDA from the source. A Verification of Medical Expenses (MSHDA 100) should be sent to the source along with their forms.

Refer to the Exceptions noted in Section 8 Exceptions below for acceptable reasons for skipping either the first and/or second written attempts.

If UIV is not available and attempts to obtain written TPV were unsuccessful; the HA must originate oral TPV.

5. Third Party Verification – Oral

If UIV and written TPV is not obtained, HA must initiate contact with the source identified on the MSHDA 1890, (i.e. supervisor, personnel department, etc.) to obtain the necessary verification. The individual source’s name, the date/time contacted, HA signature, and all required data must be noted on the following verification document:

  • If a MSHDA verification form exists for the item(s) being verified, the entire form must be completed based on the conversation. (Note: The verification form does not require applicant/participant signature since this is oral TPV.)
  • If no MSHDA verification form exists for the item(s) being verified, document the required information on a Supplemental Information Form (MSHDA 77).

Refer to Section H. Exceptions noted below for acceptable reasons for skipping TPV oral attempt. In the event that attempts for oral TPV from the independent source have failed, the HA must pursue original documents provided by the family.

If UIV is not available and attempts to obtain written and oral TPV were unsuccessful; the HA must utilize documents provided by the family if the documents contain complete information.

6. Original Documents Provided by Family in Lieu of TPV

If UIV, written, and oral TPV is not obtained, the HA reviews the original documents provided by the family as verification of income/assets/deductions. If original documents have not been provided for review, a Request for Required Documents (MSHDA 53) must be sent requesting that the applicant/participant submit necessary original documents dated within the previous 60 days.

  • HAs may obtain the documents from the applicant/participant via mail or a personal visit.
  • Original letterhead documents must be used/viewed because photocopies may be more easily altered.
  • HAs must photocopy the original document and notate “viewed original document” and sign the copy of the applicant/participant-provided document.
  • Refer to Appendix for acceptable tenant-provided documents.

To be acceptable for this method of verification, documents must be original and authentic, (e.g. not FAXes or photocopies). HA must photocopy the original document. Notate “viewed original document” and sign and date the copy of the tenant-provided document.

Refer to Appendix (obtained from HUD Guidebook) for acceptable tenant-provided documents.

Internal Revenue Service (IRS) Letter 1722: An IRS letter 1722, also known as a tax account listing, shows the applicant/participant’s filing status, exemptions claimed, adjusted gross income, taxable income, taxes paid, etc. This is an acceptable form of TPV provided by a family. Individuals can obtain an IRS Letter 1722 by calling 1-800-829-1040.

Note: Financial institution statements that reflect direct deposit amounts are not acceptable verification until 28 days have passed and the third party did not respond. Since direct deposit financial documents do not identify gross amounts or deductions, specific information must still be obtained from the source for Medicare deductions, gross wages, etc.

Under no circumstances can a copy of a U.S. Treasury issued check be in a tenant file as documentation. See Appendix

In the event information cannot be verified by a review of documents, families will be required to submit family certification.

7. Family Certification (Notarized Statement)

If UIV is not available and attempts to obtain written and oral TPV were unsuccessful, and the family cannot provide original documents, then family certification is required. Family certification is a notarized statement signed under penalty of perjury in the presence of a witness. HA may accept a notarized statement or affidavit from the family that declares the family’s total monthly or annual income/assets/deduction verification. A completed and signed Household Living Expenses Questionnaire (MSHDA 488) would satisfy the certification requirement if the family has zero income.

This method should be used as a last resort when no other verification method is possible. If this method is used, there must be documentation in the tenant file as to why TPV was not available.

8. Exceptions to TPV

TPV Written: There are occasions when the HA may not be able to attempt written TPV. In those instances, the HA must explain on the MSHDA 78 (and/or MSHDA 77 if necessary) why they skipped this step in the hierarchy. For example, if an applicant/participant is unable to provide and the HA cannot obtain a mailing address for the source that can be used for written attempts for TPV, this step may be skipped and the HA would immediately go to the TPV oral step. The reason this was skipped must be thoroughly explained on the MSHDA 78 or 77.

TPV Oral: There are occasions when the HA may not be able to attempt oral TPV. In those instances, the HA must explain on the MSHDA 78 (and/or MSHDA 77 if necessary) why they skipped this step in the hierarchy. For example, if the applicant/participant is unable to provide and the HA cannot obtain a phone number for the source that can be used for oral TPV, the reason this was skipped must be thoroughly explained on the MSHDA 78 or 77.

Original Documents Provided by Family in Lieu of TPV: There are occasions when an applicant/participant may not be able to provide original documents. In those instances, the HA must explain on the MSHDA 78 (and/or MSHDA 77 if necessary) why they skipped this step in the hierarchy. For example, an applicant/participant is unable to provide documents to verify income/assets/ deductions. The reason that this was skipped must be thoroughly explained on the MSHDA 78 or 77. Note: skipping this step is rare.

Fee Requests from TPV Source:

  • MSHDA does not require the HA nor applicant/participants to pay a fee for verifications to the TPV source. If a service request fee is charged by the TPV source to complete a verification form, keep a copy of the fee request document or an e-mail from the source identifying the source name, address, phone number, and fee amount. Place a copy of the fee request/E-mail in the file. Note on the MSHDA 78 or 77 that MSHDA will not pay fees for such requested information. Go to the next level of TPV hierarchy.
  • A copy of the letter requesting a fee needs to be forwarded to the Policy Specialist for consideration as an acceptable exception letter.

Letters of Refusal to Provide Verification from TPV Source:

When a TPV source refuses to provide requested information and states the reason for refusal on a permanent basis, the letter of refusal must be forwarded to the Policy Specialist within the Office of Housing Voucher Programs for consideration of an acceptable exception letter. The Policy Specialist will determine if the refusal letter is sufficient to discontinue written or oral TPV for the cited applicant/participant (one time transaction) or for all applicant/participants in that area. All approved exception letters will be provided to the affected HA and must be retained for future use.

When skipping written and/or oral TPV, the approved exception letter must be included with each affected applicant/participant file. Document on the MSHDA 78 under written and oral TPV Remarks column “refer to attached approved exception letter.”

9. Third Party Verification (TPV) Monitoring, MSHDA 78

In order to monitor the TPV process and improve our TPV quality, the MSHDA 78 is required for all TPV. A well-documented MSHDA 78 verifies the TPV process. It does not excuse inadequate verification(s).

  • Refer to the MSHDA 1890 for the verification number. Write this number in after the A, B, C or D. Enter different account types on separate lines. Example: B-1 Checking; B-1 Savings. Write the family member name. You may record more than one family member’s name on the form.
  • Additional information can be made on a MSHDA 77 if necessary to further document attempts.
  • HA Initials Column – Agent and MSHDA office staff may use their initials.
  • If you skip a method, you must document the reason on the MSHDA 78. Example: Skipping UIV and Written TPV and using Oral TPV.
  • All applicable source information must be completed on the MSHDA 1890. Example: If the MSHDA 78 indicates a FAX was sent, then a FAX phone number must be on the MSHDA 1890.
  • All “yes” answers on the MSHDA 1890 that involve income, assets, or deductions must be documented on the MSHDA 78.
  • In the case of joint bank accounts, both names may appear on the same line of the MSHDA 78.
  • If there is more than one source for any one item on the MSHDA 1890, complete as separate entries on the MSHDA 78. Example A-2.1, A-2.2.
  • Unearned income of minors must be listed separately on the MSHDA 78; e.g. Social Security, SSI.
  • Federal and State SSI must be entered on separate lines.
  • Medicare premiums are generally verified on the Social Security verification and do not require a separate entry.
  • Line 6 must be completed to show date applicant/participant meets eligibility.

Zero Income households with no assets and no deductions do not require the completion of the MSHDA 78.

Calculations should be notated on the applicable verification form and not in the remarks column on the MSHDA 78.

Method 1: UIV

UIV Date/Method column:

If UIV is received, write the date it is received and appropriate UIV method used by selecting a code from the appropriate key to complete the box.

  • NA is used when there is no UIV method for that particular type of verification.
  • DNR is used when you did not receive UIV from an available UIV source.
  • If using “O”you must write what other UIV source was used.

UIV – UIV Codes column:

  • Circle the appropriate codes using the UIV key at the bottom of the form. One code must be selected for each half of the column.

Method 2: Written TPV

Written TPV – Written Request Sent column:

  • Write date of initial request to Third Party source.
  • Use Written TPV Key for method. If using “O” explain in this box what method was used, i.e. dropped off form.

Written TPV – Follow–up Sent column:

  • Write date of second request to Third Party source. This should be at least 14 days from date of first TPV attempt.
  • Use Written TPV Key for method. If using “O”, explain in this box what method was used, i.e. dropped off form.

Written TPV – Received column:

  • If received by third party source, write date and method of receipt. For example, if TPV is received in the mail, you enter “M”.
  • If no response, write NR and explain in Remarks section.

Written TPV – Remarks column:

  • Enter the date you are writing remark. This must be at least 21 days from first TPV written attempt.
  • Write explanation. If using a MSHDA 77, write “see MSHDA 77.”

Method 3: Oral TPV

Oral TPV column:

  • Write the date, time and person’s name that was contacted or attempted to contact and explain in the Remarks section or use the MSHDA 77.
  • Leave blank if unable to attempt the contact and explain in the Remarks section or use MSHDA 77.

Remarks column:

  • If an Oral TPV was completed, write, “see MSHDA 77” or “see MSHDA 49”, for example.
  • If an Oral TPV was not competed, write an explanation.

Method 4: Document Review

Document Review column:

  • Write the date that the tenant-supplied document was reviewed.
  • Applicant/participant supplied documents dated within 60 days of the effective date are acceptable.

Method 5: Tenant Declaration

Tenant Declaration column:

  • Write the date that the tenant affidavit or notarized statement was received.

Note: Once verification is received, no further notations are needed for that item. Notations must be present for each method taken. Example: If the verification came from the review of a Applicant/participant-supplied document (Column #4, Document Review) each column up to and including #4 would have notations, and column #5 would be blank.

Examples of acceptable notations to be written in the remarks column:

  • “NR (no response) from either attempt at written TPV resulted in the attempt of oral TPV” and date.
  • “See attached MSHDA 77.” (Attach MSHDA 77 that was used to provide more clarification to the MSHDA 78)
  • “See attached approved exception letter.” (Attach exception letter to MSHDA 78)
  • “Source (write source name) refused to give info over the phone, which resulted in the use of applicant/participant supplied verification.”
  • On Oral TPV in the Remark sections write – “See MSHDA 49” (use whatever applicable MSHDA form).
10. Calculating Annual Income

Annual income is determined by calculating a household’s anticipated total or gross income minus allowable deductions.

Use the family’s current income and expenses to predict the family’s expected annual income for the next year. Sporadically received income, or income where the amount received is not consistent must be treated as irregular income, and the procedures described below for annualizing irregular income must be used to anticipate annual income for the next year.

Use averages and estimated amounts when necessary.

Use gross income: include holiday pay in determining gross income. Do not deduct taxes or other payroll deductions from gross income.

Include all tips, bonuses, scheduled pay increases or other additional amounts. If TPV, indicate an expected change in income (i.e. pay increase), include the change in calculations to obtain the closest possible estimate. Multiple entries in Elite may be required. Example: a participant starts a new job and the employer indicates an anticipated increase after six months. Calculate and enter six months at one wage and six months at the increased wage to get the best estimate of the next twelve month’s earnings.

  • Compare Flat Grant information to the charts found in the Appendix of the PPM. Investigate and document any discrepancies to discover unreported income and/or unreported family member changes.

If verifications provided are not clear, the HA must obtain additional information before determining the tenant rent portion. HUD stresses the importance of avoiding errors made in calculating the tenant’s portion of the rent. Consistent errors of this type may cause problems in future audits by HUD.

Convert all income (and allowable expenses) to an annual figure by multiplying the pay rate by the frequency of payment.

  • Multiply hourly wages by the number of hours worked per year. Full-time employment (40 hours a week and no overtime) is 2,080 hours (40 hrs X 52 weeks = 2080 hours). (10 hours a week X 52 weeks = 520 hrs per year).
  • Multiply weekly wages by 52.
  • Multiply bi-weekly wages by 26.
  • Multiply semi-monthly wages by 24.
  • Multiply monthly wages by 12.
  • Multiply daily wages by 260 (full time/no overtime).
  • To convert monthly amount to weekly, divide by 4.3.
  • Round up to the nearest dollar at .50 and above (except SS payments, which are always rounded down).

Note: Federal and State wage laws require employers to pay time and a half in excess of 40 hours for most occupations. If earnings verification shows more than 40 hours worked but does not indicate overtime paid, verify with the employer if overtime is paid or not. Document this on MSHDA 77.

11. Verifying Student Eligibility and Income

A final rule published by HUD (FR-5036-F-01) entitled, “Eligibility of Students for Assisted Housing under Section 8 of the U.S. Housing Act of 1937” became effective on January 30, 2006. It states that if a student is enrolled at an institution of higher education is under the age of 24, is not a veteran, is unmarried and does not have a dependent child, is individually ineligible for Housing Choice Voucher assistance, or the student’s parents are, individually or jointly, ineligible for assistance, no HCV assistance can be provided to the student. See Link to FR-5036-F-01: edocket.access.gpo.gov/2005/pdf/05-24672.pdf

HUD issued Supplementary Guidance on April 10, 2006 to ensure that HCV assistance is provided to those truly in need and eligible for assistance. Here is a link to the HUD Supplemental Guidance which is in a question and answer format: edocket.access.gpo.gov/2006/pdf/06-3365.pdf

Further, HUD developed a Question/Answer chart regarding Eligibility of Students for Assisted Housing under Section 8 of the U.S. Housing Act of 1937. Here is the link to this HUD Questions and Answer Document: www.hud.gov/offices/pih/publications/studentruleqa.pdf

Following the documents and guidance above, the eligibility of a student seeking HCV assistance will be examined along with the income eligibility of the student’s parents. The new rules do not apply to students residing with their parents in an HCV assisted unit or who reside with parents who are applying to receive HCV assistance. The law and rules focus on students that are under the age of 24, are not veterans, are unmarried, or are without children who seek or receive HCV assistance separate from their parents.

Students residing with their parent(s)/guardian(s): Follow HCV income guidelines when verifying income for a family that includes a full-time high school or college student, 18-years of age or older, that lives with his/her parent/guardian(s). Verify relationship to head of household and dependent status. Verify student enrollment at high school or an institution of higher education using MSHDA School Verification Form (MSHDA 55). Verify the student is claimed as a dependent by the parent/guardian(s) and eligibility for the HCV program is based on the income of the parent/guardian(s) and all other adult members of the family. Verify family income, assets, expenses and allowances. See also Chapter IV. Income Allowances, Dependent Allowances; and Chapter IV. Income Includes.

Single and/or Head of Household Students (under the age of 24) enrolled at an institution of higher education: The HA must carefully screen/interview students who are single, or head of household students enrolled at an institution of higher education to verify they meet required eligibility criteria. See MSHDA PPM, Chapter II Waiting List. Verify student enrollment at an institution of higher education using the MSHDA 55. Verify family income, assets, expenses and allowances. It is suggested the HA conduct a detailed interview at admission and at annual or interim re-examinations about sources of income. Students who are not eligible must be terminated from the program or denied assistance. When verifying student eligibility criteria, it is suggested the following questions be asked:

  1. What are all of your sources of income?
  2. What type of scholarships, grants, Pell Grants, Loans do you receive for school?
  3. Do your parents claim you as a dependent when they file their annual Income Tax Return with IRS? Request a copy or copies to establish independence.
  4. Do you anticipate receiving any money or support from your parents/guardians for food, shelter, clothing, or personal items?
  5. Do you expect to receive regular contributions (i.e., steady or monthly assistance with bills, rent, car payments) or gifts from your parents/guardians?
  6. How do you pay for food, rent, clothes, utilities, entertainment?

The Household Living Expenses Questionnaire (MSHDA 488) generally used for gathering information on income sources for zero income households may also be used.

HA must also verify the Single, Head of Household Student is:

  1. Is of legal age or an emancipated minor under state law. Obtain proof of age such as a valid driver’s license, identification card issued by a federal, state, or local agency, identification issued by a medical insurance company, or birth certificate.
  2. Is income eligible for admission to the HCV program. Verify via independent third-party verification all sources of reported family income anticipated to be received during the 12-month period following admission and the effective date of the annual reexamination.
  3. Has established a household separate from his/her parent(s) or legal guardian(s) for at least one year prior to applying to the HCV program. Gather evidence of separate households by reviewing/verifying the address information that predates the student’s application by a minimum of one year.
  4. Is not claimed as a dependent by the parent(s) or legal guardian(s) on their Internal Revenue Services (IRS) tax return. This may be achieved by requesting a copy of the college student’s Form 1040EZ, 1040A, or 1040 tax returns for the prior year. Check the box that asks whether the student’s parents (or someone else) can claim him/her on their tax return (See box “5” for Form 1040EZ and box “6a” for Forms 1040A and 1040). The HA may also, if practicable, review the college student’s parents’ or guardians’ tax return. The college student must supply any information that MSHDA or HUD determines is necessary to verify this information.
  5. Does or does not anticipate receiving financial support from the student’s parent(s) or guardian(s) and the amount of that support by obtaining a written/signed certification from the student.

Independent Student: (As defined in the HUD Supplementary Guidance of April 10, 2006): To be an independent student, the student must meet one or more of the following criteria:

  1. be at least 24 years old by December 31 of the award year for which aid is sought;
  2. be an orphan or a ward of the court through the age of 18;
  3. be a veteran of the U.S. Armed Forces;
  4. have legal dependents other than a spouse; for example, dependent children or an elderly dependent parent
  5. be a graduate or professional student; or
  6. be married.

Follow stated HCV income guidelines when verifying income for independent college or post-secondary students (full or part-time) that are the single, head of household. Verify all family income, asset, expenses and allowances. Verify student status and enrollment at the institution of higher education using MSHDA 55.

Full-Time College Students with an Athletic Scholarship: In accordance with the FY 2005 Appropriations Act, it is required that the portion of any athletic scholarship assistance available for housing costs be verified with the third party income source by MSHDA and included in the determination of family adjusted income. MSHDA will deny housing assistance to those full-time college students receiving athletic scholarship assistance with $5,000 or more annually available for housing costs. Scholarship amounts must be verified.

12. Irregular Income

Irregular income is defined as income received in an unpredictable or sporadic manner, such as income from seasonal employment, temporary work agencies, child support, or alimony. If the family has a history of irregular income, you may use the family’s past income history to determine how to project such income forward.

When determining such income, use the most recent verification providing the required information available. Divide the year-to-date (YTD) total provided on the verification by the amount of actual weeks the total covers to receive an average weekly income. Multiply the weekly income amount by 52 (weeks).

Types of TPV vary, and it is often difficult to determine annual income based on the information provided. When such cases occur, it is necessary to contact the source of the income (i.e. employer for wages) to clarify information provided, then document the information received on a MSHDA 78 or MSHDA 77 as appropriate.

Convert the following irregular income to an annual figure to complete rent calculations as follows:

  • School Employment – Most schools are in session 37 weeks a year: calculate at 37 weeks worked and 15 weeks off unless verification documents specifically note otherwise. School employees usually have a choice of being paid their yearly salary spread out over 37 weeks or 52 weeks. Once an annual income figure is determined using either 37 weeks or 52 weeks as the basis of calculation, interim revisions for “zero income” during summer months are not an option. If not using 37 weeks worked and 15 not worked, write an explanation for using a different time period on the verification.
  • Unemployment Benefits – Multiply the gross weekly benefit by 52 weeks, regardless of the number of weeks they remain eligible to receive benefits. When the family reports the benefits have ceased, complete an Interim Re-examination to adjust annual income.
  • Irregular Wages – Use the most recent verification available. Divide the YTD amount by the number of actual weeks to receive an average weekly amount. Multiply the average weekly amount by 52 weeks.
  • Child Support – Annualize actual child support/alimony income received, rather than the court-ordered amount owed a client when payments are in arrears. The HA should directly ask the applicant/participant if there is an arrearage, and explain that calculations must be based on actual income received, rather than the court-ordered amount. The applicant/participant should provide the required year-to-date total needed to annualize income, since it is to the client’s benefit to provide accurate information in such cases.

    Additional child support information is located in Chap IV, Sec B3 of the PPM.

    If the HA determines and can appropriately verify that the tenant will receive a payment(s) within the next twelve months, the amount should be included in annual income. If the HA can verify through the tenant or agency making the payments that the tenant will not receive such payment(s) the following year, then this amount should not be included when calculating annual income.

Example:

Child Support check stub dated June 1, 2001 (22 weeks)

Total received (YTD total):$814.00

YTD divided by 22 weeks equals weekly average: 814/22 = $37.00

Weekly average x 52 weeks equals Annual average: 37 X 52 = $ 1924.00

(Round off to whole dollar amount)

13. Zero HAP

If initial calculations result in a Zero HAP (TTP equals or exceeds the Gross Rent or PS, whichever is applicable), a HAP Contract cannot be executed.

When Annual Re-examination calculations result in a Zero HAP, the family remains eligible for the program for six months. The HA must maintain a tickler file to contact the family to re-verify status and cancel the contract at the end of the six-month grace period if the family is still at Zero HAP. NOTE: This cancellation could occur before the end of the HAP Contract. Refer to Chapter VIII: Annual Re-Examinations regarding Zero HAP procedures.

If the family’s income subsequently decreases during the allowable time frame (six months), process an interim re-examination in accordance with Chapter IX: Interim Re-Examinations.

14. Zero Income

A Zero Income household is one in which an entire household claims no earned nor unearned income. A household with benefits or non-earned income (i.e. Social Security, child support, DHS, etc.) to minors (family members age 17 and under) is not considered a Zero Income household.

Upon completion of the Household Income, Asset, and Expense Declaration (MSHDA 1890) by all adult family members and it is noted that the entire household claims no income, the HA must then conduct a personal interview (either face-to-face or by telephone) with the head of household and complete a Household Living Expenses Questionnaire (MSHDA 488).

If it becomes apparent after review of the MSHDA 488 or during the interview that income exists, and/or if the family’s expenses exceed their known income, the HA must inquire as to the nature of the family’s accessible resources, contributions, and gifts. HA must have the family complete the Verification of Income from Contributions (MSHDA 486) to verify regular contributions to household income. The amount of regular contributions must then be converted to an annual income amount. Refer to Chapter IV. Income Includes.

If after completion of the MSHDA 488 it is determined there is no income, the head of household must sign the MSHDA 488 certifying lack of household income and a Verification of No Household Income (MSHDA 148) Form. A date for re-examination (three-month check-back date) must be inserted on the MSHDA 148 for check-back purposes. The MSHDA 1890 will suffice as verification of no income for all other adults in a Zero Income household.

Zero Income households with no assets and no deductions do not require the completion of the Third Party Verification Monitoring (MSHDA 78) form.

Any reported changes must be processed as an interim re-examination. Process all increases in income for Zero Income households, regardless of the amount.

If unreported income is discovered for a Zero Income household at any time the participant is receiving HAP, the participant must sign a Repayment Agreement (MSHDA 103) to pay back the inaccurate rent subsidy paid due to unreported income.

Check-Back Period

The household must check back with their HA three months from the effective date of the new/move/interim/annual re-examination, which resulted in zero-income for the entire household. (Example: for a 10/01/09 Initial, the check-back date is 01/01/10.) Although the participant is responsible to report back on the specified date, the HA must develop a tickler (i.e. follow-up) system to ensure compliance and to contact the participant by the fifth day of the check-back month if the participant has not contacted them. The Tenant Zero Income Report can be utilized to show tenants on zero income.

Check-Back Procedures

The MSHDA 148 requires the household to contact the HA on the applicable date. If the HA has not been contacted by the participant by the fifth day of the check back month, the HA should send a MSHDA 1890 and request completion within 14 days. For example, if the check-back month is August 2009 (and the participant has not initiated the contact), the forms must be forwarded by August 5, 2009.

  • Participants should be given a 14-day response deadline for form completion and notify them that failure to complete the form is a program violation.
  • If the form is not returned within the 14-day deadline, the HA must notify the participant of noncompliance with a program requirement and be canceled from the program.
  • The HA reviews the returned MSHDA 1890 to determine which TPV sources to contact when new or loss of income sources are reported.
  • If the entire household continues to have no income as verified by the newly submitted MSHDA 1890, the Head of Household should then complete a new MSHDA 488 with the HA if they claim no income again. Follow procedures as stated previously.
  • HA must submit an interim re-examination for proof of zero income documentation with each checkbox even if the tenant remains zero income. TPV of income must include current EIV report with interim re-examination paperwork. The interim re-examination will document continued zero income or an income change.
  • The HA forwards one copy of the MSHDA 148 form to the participant to notify them of the new three-month check back/interim re-examination date and forwards another copy to MSHDA for inclusion in the official MSHDA file.
15. Minimum Total Tenant Payment (TTP)

The minimum TTP for each household in the HCV Program administered by MSHDA is $0. A TTP is defined as the highest of the following amounts:

  • 30% of the family’s monthly adjusted income
  • 10% of the family’s monthly gross income
  • Minimum TTP ($0)

A family’s TTP will only become $0 when both 30% and 10% amounts are zero. If all the amounts are not zero, then the minimum TTP will become the highest of the 30% or 10% items listed above.

Example A

  • 30% of the family’s monthly adjusted income equals $35
  • 10% of the family’s gross income equals $15
  • Minimum TTP equals $0
  • The family’s new TTP equals $35 (30% is the highest)

Example B

  • 30% of the family’s monthly adjusted income equals $0
  • 10% of the family’s gross income equals $10
  • Minimum TTP equals $0
  • The family’s new TTP equals $10 (10% is the highest)

Example C

  • 30% of the family’s monthly adjusted income equals $0
  • 10% of the family’s gross income equals $0
  • Minimum TTP equals $0
  • The familys new TTP equals $0 (10% and 30% are both $0)

Notification to applicants and/or participants

Applicants for the HCV program should be notified of the minimum monthly TTP requirement during their initial briefing session.

Participants in the HCV program must be notified of the change to their minimum monthly TTP requirement when 30% of the family’s monthly adjusted income or 10% of the family’s monthly gross income falls to $0 using an Adjustment Notification (MSHDA 34).