MULTIFAMILY HOUSING OCCUPANCY TRAINING FOR PROJECT-BASED ASSISTED PROPERTIES

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Section 1The Rent and Income Integrity Problem

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What Is the Overall Problem?

• A 2001 Office of Policy Development and Research
  (PDR) study found that HUD
• Overpaid 2.6 billion in annual housing subsidies
• 1.7 billion in administrative/component errors
• 600 to 900 million in unreported tenant income
• Underpaid 634 million in annual housing
  subsidies

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Error Measurement Estimates from 2001 QC Study
and Income Matching
HUD Rental Program Excess Subsidy-Unreported Earnings Excess Subsidy-Unreported Unearned Excess Subsidy-POA Error Subsidy Shortfall-POA Error Net Total QC/Income Match Error
Public Housing 280 14 431 201 524
HCV/ Mod Rehab 369 49 876 256 1,038
Section 8- Project Based 199 67 362 177 451
Total 848 130 1,669 634 2,013

• This chart includes a breakdown of the various
  subsidy determination errors by program groupings
  in millions. The first two columns of data come
  from income matching, the third and fourth from
  the QC study.

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Presidential Management Initiative 10 Mandate

• HUD mandated to reduce errors by 50 by 2005
• HUDs Annual Performance Plan set interim goals
• A 15 reduction in the dollar amount of error by
  FY 2003
• A 30 reduction by FY 2004

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Rental Housing Integrity Improvement Project
(RHIIP)

• Comprehensive approach that identifies the best
  methods of reducing program errors
• Addresses the root causes of income and rent
  errors in public housing and Section 8 HCV
  programs
• Takes action to ensure the right benefits go to
  the right persons

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RHIIP Formula for Success

• HUD and PHAs must work together to reduce errors
  and ensure fundamental fairness among families.

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RHIIP Components

• Error measurement
• Program guidance
• Training and technical assistance
• Program simplification
• Up-front income verification (UIV)
• Rental integrity monitoring (RIM)
• Consequences and Fraud

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Section 2Update on HUD RHIIP Activities

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Section 2AError Measurement

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2003 PDR Quality Control Rental Assistance
Subsidies Study

• HUD PDR measurement of progress in reducing
  number/dollar amount of rent calculation errors
  for FY 2003
• Data collected from 2,700 households at 600 sites
  (Section 8, Section 811, Section 202, public
  housing)
• Information from tenant files in-person
  interviews

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2003 PDR Quality Control Rental Assistance
Subsidies Study

• Data collection completed in early Summer 2003
  for first half of FY 2003 with results available
  late 2003 for the Performance and accountability
  Report and Financial Statement Audit
• Additional data collected in the last six months
  of FY 2003, with results available in mid-2004.

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Section 2B Program Guidance

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PIH Guidance Materials

• Pubic Housing Occupancy Guidebook
• Housing Choice Voucher Program Guidebook
• Program Fact Sheets
• Forthcoming Verification Guidance for HUD Field
  Offices and Public Housing Authorities

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PIH RHIIP Web Site

• Source for information and links to critical
  documents, HUD regulations, guidebooks, and fact
  sheets
• FAQs on RHIIP, RIM, verifications, and income and
  rent
• Training materials and presentations
• PIH RHIIP website location
• http//www.hud.gov/offices/pih/programs/
  ph/rhiip/index.cfm

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Section 2CTraining and Technical Assistance

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TrainingHUD Field Office Staff

• Purpose To Enhance occupancy knowledge and
  skills of HUD staff
• Focus Basic occupancy with emphasis on
  eligibility, income, rent, and subsidy
  calculations
• Spring 2002 Field Office basic rent and income
  training
• June 17, 2002 RIM satellite training
• May 5-9, 2003 RHIIP Training Conference

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TrainingPHA Staff

• PIH Rental Integrity Summits
• Orlando, Florida
• January 26-28, 2004
• January 28-30, 2004
• Anaheim, California
• February 2-4, 2004
• February 4-6, 2004
• Look for registration details on RHIIP Web Site!

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Technical Assistance

• PIH has a contract with MDStrum Housing Services
  to
• Provide technical assistance to challenged PHAs
• Identify and address root causes of error
• Perform HUD-Form 50058 software analysis
• To date, onsite TA has been provided to 8
  selected sites

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Section 2D Program Simplification

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Simplification Plans

• Statutory proposals
• Moving-to-Work
• Regulatory options

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Section 2EUp-front Income Verification

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Up-front Income Verification

• Definition Verification of income through an
  independent source making use of income
  information databases maintained systematically
  and uniformly, such as those maintained by the
  State Wage Information Collection Agencies
  (SWICAs), the Social Security Administration
  (SSA), and private vendors before and during a
  family reexamination.
• Key strategy for reducing the error rate

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Current Sources for UIV Data

• Social Security (SS) and Supplemental Security
  Income (SSI) information accessed via a secure
  Internet facility (TASS)
• State Wage Information Collection Agencies
  (SWICAs)
• State TANF systems
• Private sector databases (e.g., The Work Number)

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HUDs Tenant Assessment Subsystem (TASS)

• The system compares tenant-reported information
  to other HUD systems with income data stored in
  the SSA and the IRS databases
• HUD strongly encourages PHAs to systematically
  use the system to reduce incidents of undisclosed
  SS and SSI income
• HUD TASS website location
• http//www.hud.gov/offices/reac/online/reasyst.cf
  m

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UIV System Pilot

• Commenced on August 18, 2003
• Participants Select PHAs in Florida and Texas
• The UIV application was deployed as part of the
  HUD Tenant Assessment Subsystem (TASS)

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UIV System Pilot (cont.)

• Objectives
• Obtain feedback on how wage and benefit data is
  displayed
• Identify and assess implications of accessing
  SWICA data

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HUD UIV System Rollout Schedule

• August through October 2003 TASS/PASS UIV System
  Pilot
• Late 2003 Selected PHAs will participate in
  pilot of UIV System
• Early 2004 UIV System available to all PHAs
  within states where HUD received income data

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Coming Soon HUD UIV System

• Will make integrated income data available to
  PHAs from one source via the Internet
• Allows PHAs to view quarterly wage,
  weekly/bi-weekly unemployment, and monthly SS
  benefit information for tenants in their
  jurisdiction

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UIV System

• Provides wage and benefit information through a
  data matching process for households covered by a
  HUD Form 50058
• For tenant recertifications, not new admissions,
  as wage and benefit data is pulled from existing
  Social Security Numbers (SSNs) in the PIC system
• PHAs may not view the tenant data without a
  signed Authorization for the Release of
  Information/Privacy Act Notice (e.g., Form
  HUD-9886) in the households file

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UIV System Discrepancy Reports

• Compares total benefits reported by tenant to
  total benefits reported by SSA and SWICAs
• Shows if the tenants SSN-date of birth-surname
  combination does not match SSA records
• Shows if tenants claim was denied or benefits
  terminated

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UIV System Privacy Requirements

• Data must only be used for verification of tenant
  income and eligibility
• Data must not be disclosed in any way that would
  violate the privacy of the individuals
  represented in the system
• Tenants must be provided with access to their
  records and an opportunity to correct or
  challenge their contents

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UIV System Security

• Ensures that access rights, roles and
  responsibilities within PHAs are appropriately
  and adequately assigned and monitored
• Quarterly reviews conducted for all User IDs to
  determine if user still needs access to UIV data
• Maintain security-related records
• Conduct security awareness training

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Section 2FRental Integrity Monitoring (RIM)

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Rental Integrity Monitoring (RIM)

• In June of 2002, HUD Headquarters directed HUD
  Field Offices to conduct onsite monitoring of
  PHAsRIM reviewsto
• Detect and reduce errors in income and rent
  calculations at targeted PHAs
• Reduce rent underpayments and overpayments by
  residents
• Maximize HUDs limited housing resources

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What Is a RIM Review?

• Onsite monitoring of PHA policies and procedures
  related to income and rent determinations,
  performed by Field Office reviewers, including
• Review of randomly selected sample tenant files
• Gathering of PHA income and rent information
• Assessment of PHA policies and procedures
• Identification of income and rent errors
• Analysis of income and rent errors to establish
  root causes/recommended corrective actions
• Recording of income and rent findings and errors

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RIM Review Close-Out

• HUD Field Offices will
• Meet and discuss preliminary finds and
  observations/concerns with PHA staff
• Discuss strategies for corrective action
• Gives PHAs an opportunity to discuss RIM review
  finds and observations/concerns

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Post Review Activities

• HUD Field Offices
• Issue RIM review reports to PHAs on findings,
  concerns, observations, and recommended actions
• Monitor PHAs progress in correcting findings and
  errors
• Provide ongoing technical assistance
• Close findings when required actions are
  completed
• Submit error reports to HUD Headquarters

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Corrective Action Plans (CAPs)

• Required if a finding is not resolved by the time
  a PHA responds to a RIM report (within 45 days)
• Finding A condition not in compliance with
  handbook, regulatory, or statutory requirements
• Systemic Finding A pattern of deficient PHA
  performance in one or more areas of income and
  rent determination

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Baseline for RIM Review Results Report

• 368 reviews conducted between June 2002 and
  January 2003
• 144 of the 368 reviews involved large PHAs that
  comprise over 25 of HUDs subsidies
• Income and rent errors recorded on Error Tracking
  Reports for each RIM review formed the baseline
  results

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Second Round of RIM Reviews

• April 2003 through September 2003
• 346 targeted PHAs administering public housing
  and HCV programs, covering 55 of HUD subsidies
  paid
• RIM Review Results Report to be completed early
  2004

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Baseline RIM Review Results

• Errors found in Public Housing and Housing Choice
  Voucher programs in initial 368 reviews divided
  into two categories
• Component Errors Errors in specific income and
  expense components used to calculate rent (e.g.,
  earned income, Social Security, pensions,
  dependent allowance, etc.)
• Administrative Errors Errors in procedures,
  including calculation and transcription errors
  and failure to verify information

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Top Three Component Errors

• Public Housing
• Calculation of earned income (wages)
• Calculation of pensions, public assistance
  other income
• Application of allowable deductions
• Housing Choice Voucher
• Calculation of earned income (wages)
• Calculation of pensions, public assistance
  other income
• Using incorrect utility allowance schedule

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Top Three Administrative Errors

• Public Housing
• Improper transfer of 50058 data from file to PIC
• Lack of quality control
• Lack of verification of income/deductions
• Housing Choice Voucher
• Lack of verification of income/deductions
• Lack of quality control
• Improper transfer of 50058 data from file to PIC

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Re-reviews

• PHAs receiving initial review in the first two
  rounds will receive a re-review to ensure
  corrective actions were implemented
• Approximately 20 re-reviews completed to date,
  remaining conducted during FY 2004
• Study of 50 PHAs undergoing re-reviews to be
  included in FY2003 Performance and Accountability
  Report

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Section 2GConsequences and Fraud

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Consequences of Program Errors

• RIM
• Follow-up by HUD Field Offices and the Inspector
  General
• May impact several performance indicators found
  under the Section Eight Management Assessment
  Program (SEMAP)
• Expect PHAs to implement CAPs in timely manner to
  prevent adverse action

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Consequences of Program Errors (cont.)

• UIV
• HUD will examine discrepancy reports for large
  numbers of errors in wage and benefit
  determination
• HUD will target PHAs with multiple errors for
  further action

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Letter to CPAs

• August 26, 2003 letter from PIH Assistant
  Secretary Liu to CPAs who audit PHAs
• Outreach to independent auditors to
  assess/mitigate PHA program risk and to identify
  and report improper calculation of subsidy
  payments
• Errors identified during the RIM reviews are
  being compared to the income and rent findings
  identified in the PHAs audit reports

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• OFFICE OF INSPECTOR GENERAL U.S. Department
  of Housing and Urban Development WASHINGTON,
  D.C. 20410-4500
• 
  HOTLINE COMPLAINT INTAKE FORM
• COMPLAINT INFORMATION
• Date_______
• COMPLAINANT CONTACT INFORMATION
• PHA Name________________________
• Point of Contact Name______________________
• Address___________________________
• (Street)
• ___________________ _____________
  _______________

Reporting Fraud Hotline [phone] Fax
202-708-4829
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United States Attorney
Southern District of New York FOR IMMEDIATE
RELEASE CONTACT U.S. ATTORNEYS OFFICEJUNE
3, 2003 MARVIN SMILON, HERBERT HADAD,
MICHAEL KULSTAD PUBLIC INFORMATION
OFFICE [phone]  BARBARA
GUSS [phone] 31 CHARGED WITH
FEDERAL HOUSING FRAUD THAT COST THE
GOVERNMENT MORE THAN 650,000 JAMES B.
COMEY, the United States Attorney for the
Southern District of New York RUTH A. RITZEMA
the Special Agent in Charge of the New York/New
Jersey Office of the Inspector General of the
U.S. Department of Housing and Urban Development
(HUD) and CHARLES A. COLA, the Commissioner of
the Yonkers Police Department, announced that 31
defendants were charged with obtaining private
housing rental subsidies to which they were not
entitled. Twenty-seven were arrested and 4 others
were being sought. The defendants were
charged in 14 separate criminal Complaints
unsealed in White Plains federal court and were
presented in Court today before United States
Magistrate Judge George A. YANTHIS. The
defendant fraud is alleged to have costthe
federal government more than 650,000.
Reporting Fraud
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• Yonkers housing fraud bust nets charges against
  31
• By WILL DAVID THE JOURNAL NEWS (Original
  publication June 4, 2003)
• YONKERS A federal and local investigation aimed
  at stamping out fraud in the Yonkers Municipal
  Housing Authority's Section 8 rent subsidy
  program culminated yesterday with the arrests of
  27 people, and four others are being sought in
  connection with the probe, authorities said.
• The 31 people charged in the investigation all
  but two from Yonkers are accused of obtaining
  private housing rental subsidies they were not
  entitled to because their incomes were too high,
  said James B. Comey, the U.S. attorney for the
  Southern District of New York.

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Section 3PHAs Role in RHIIP

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PHAs and RHIIP

• HUD is committed to its error reduction goals,
  but we need PHA cooperation and support to
  succeed in all our RHIIP initiatives!

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PHA ActionUIV

• Use the TASS system now to verify benefit
  information and reduce incidents of undisclosed
  income
• Use the UIV system, when it is operational, to
  ensure all wage and benefit income is disclosed
• Implement controls that encourage follow up on
  significant income discrepancies

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PHA ActionUIV System

• PHAs should review policies, practices, and SWICA
  regulations in preparation for availability of
  wage information and possibility of increases in
  cases of undisclosed income. Policies include
• Criteria for repayment agreements
• Thresholds for legal action related to fraud
• Zero income policies
• Interim reexamination thresholds

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PHA ActionUIV System (cont.)

• Maintain, communicate, and enforce standard
  operating procedures for UIV data
• Emphasize to staff the importance of carefully
  and accurately entering tenant data into PIC HUD
  Form 50058 for accessing wage and benefit
  information
• Ensure all staff accessing UIV System have a
  current signed user agreement and PIH Access
  Authorization Form on file
• Inform tenants that your PHA has access to wage,
  SS, and unemployment benefit information

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PHA ActionRIM

• Develop/implement an internal quality control
  system to ensure income and rent determination
  policies/procedures are followed consistently and
  accurately
• Address concerns raised during RIM reviews and
  create and execute corrective action plans to
  address all findings
• Use UIV sources and/or third party verification
  to verify wage/benefit data

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PHA ActionRIM (cont.)

• Review competency of occupancy specialists and
  train as needed on income and rent determination
• Update policies and procedures and interview
  forms
• Ensure consistency between policy and practice
  (e.g., occupancy file, Form 50058, administrative
  plan/ACOP)
• Document, document, document!

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General Recommendations

• Know resources available, including
• 24 Code of Federal Regulations (24 CFR)
• PIH notices and Federal Registers
• Public Housing Occupancy Guidebook
• Housing Choice Voucher Guidebook
• Rental Integrity Monitoring Guide

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General Recommendations

• Bookmark the PIH RHIIP Web Site and check it
  often for program updates, new guidance, and new
  FAQs
• Keep in contact with your HUD Field Office

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Conclusion

• Working together, HUD and PHAs can reduce income
  determination and rent calculation errors and
  ensure that theres more housing money for those
  who need it the most.

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Questions and Answers