EIV INCOME DISCREPANCIES [DON'T GO CRAZY

EIV Income Discrepancies:Don’t Go Crazy – It’s a Tool!

©2019 GWEN VOLK INFOCUS, INC. 1

EIV INCOME DISCREPANCIES [DON’T GO CRAZY – IT’S A TOOL]Gwen Volk CPM, NAHP-e, RAM , FHC, SHCM, HCCP

Not all EIV discrepancies can be fixed but . . . All EIV discrepancies can be explained

©2019 GWEN VOLK INFOCUS, INC.

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Reality Check: “Do as they say, not as they do”

• Chapter 9 of the 4350.3 says that EIV uses the most current 50059 in TRACs that occurred within the Period of Income (POI) analyzed.

• In practice EIV uses the 50059 with the Date of Effective Action listed on the Income Report

• In investigating discrepancies, the Owner should use the most current 50059 in TRACs that occurred within the POI analyzed.


Reality Check: Effective Date of Action vs Period of Income


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Reality Check: 50059 Reported in EIV02/01/2017 “Effective Date of Action”

Period of Income: 11/01/2015 – 10/31/2016

What’s wrong with this picture?


Realty: 50059 Date

• Obtain the most current MI, AR, IR or IC 50059 that falls within the POI

• That will (usually) not be the one on the Income Discrepancy Report


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Reality Check:EIV Does Not Report All Sources of Income Reported on the 50059


Apples to Apples ( Not Apples to Oranges)

50059 Income

EIV Income

BCSFGIMN

PESISSTUW• Employment

• Social Security Income• Dual Entitlement Income• SSI


Reality Check:

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Reality: Income Sources• Not all sources of income are reported in EIV

• While working the discrepancy, disregard the non-reported sources of income and focus on the ones EIV does report.

• The non-reported sources are not the ones causing the discrepancy.

• Non-reported sources will, of course, be needed for an accurate file, but they will not “offset” the discrepancies reported by EIV.


Investigating and Resolving False Discrepancies


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EIV Often Reports False Discrepancies

• Obvious • Not-So-Obvious


False Discrepancy #1: HUD Compares Data to a 50059 That Falls Outside the POI


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Cause: HUD compared EIV data to a 50059 that falls outside of the POI

Investigate: Compare EIV data to the most current MI, AR, IR or IC 50059 that falls within the POI

Determine: If Projected Income is less than $2400 than both EIV Actual Income and EIV Annualized Last Quarter Income

Resolve: If so, there is no discrepancy. Write detailed explanation for file.

Resolving False Discrepancy #1


False Discrepancy #2: EIV Reports “Excluded” Income

Cause: EIV doesn’t take into consideration allowable exclusions for which a household may be eligible

Investigate: : Compare sources of income listed on EIV report to sources of income on the most current MI, AR, IR or IC 50059 that falls within the POI

Determine: If tenant file shows that a source of income reported in EIV was excluded per program requirements



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False Discrepancy #3:EIV Codes Pensions as Wages

Cause: EIV codes pensions as wages (veterans pensions, military retirement, income from other pensions and annuities). But these are coded as PE on the 50059.

Investigate: Compare the coding of sources of income on the most current MI, AR, IR or IC 50059 that falls within the POI to the way income was reported in EIV

Determine: If a coding by EIV accounts for the discrepancy.



False Discrepancy #4: EIV Ignores Notice Requirements

Cause: EIV doesn’t take into consideration that residents are entitled to a 30-day notice of rent increase when new income or increase in income is reported in a timely manner.

Investigate: Review documentation for the most current MI, AR, IR or IC 50059 that falls within the POI and all documentation

Determine: Whether the discrepancy was the result of a proper delay of implementing an increase



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Investigating and Resolving True Discrepancies


Causes of True Discrepancies

• The resident fails to disclose income• The resident fails to report changes• Staff made errors in working the file:

– Miscalculation– Missed income

• Data was not entered correctly into TRACs


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How HUD Calculates the Discrepancy


Income Report Analysis for POI: HOH


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Income Report Analysis for POI: Dependent


Income Report Analysis for POI: Co-Head


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Quarter Month Income for Quarter Income for Month

Q4 2015 November $4067+$2296/3 = $2,121

Q4 2015 December $4067 + 2296/3 = $2,121

Q1 2016 January 0 0

Q1 2016 February 0 0

Q1 2016 March 0 0

Q2 2016 April $3355 +1845/3 = $1,733

Q2 2016 May $3355 +1845/3 = $1,733

Q2 2016 June $3355 +1845/3 = $1,733

Q3 2016 July $2759 + 1222/3= $1,327

Q3 2016 August $2759 + 1222/3= $1,327

Q3 2016 September $2759 + 1222/3= $1,327

Q4 2016 October $5239 + 5388/3 = $3,542

Total Calculation $16,964

Actual Income in EIV for Period of Income

EIV shows $16,884 ©2019 GWEN VOLK INFOCUS, INC.

Last “Quarter” of Income in POI Annualized

Last 3 Months of POI Income in EIVAugust 2016 $1,327

September 2016 $1,327October 2016 $3,542Total for “Quarter” $6,196

X 4Total Calculation $24,784

EIV shows $24,496


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Compare Sources

• Compare EIV data to the most current MI, AR, IR or IC 50059 that falls within the POI

• Did the resident report the types of income that are reported in EIV?

• Compare these sources to the information in EIV


Finding the Correct 50059 for POI 11/1/2015 – 10/31/2016Report was generated June 2017The following 50059’s are in the file:• Move-In 50059 5/1/2015• Annual 50069 5/1/2016• Interim 50059 2/1/17 (Effective Date of Action)

• Annual 50059 5/1/2017


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Quarter Month Wages EIV Wages 59 SS EIV SS 59 Etc.

Q4 2015 Nov $2,121

Q4 2015 Dec $2,121

Q1 2016 Jan 0

Q1 2016 Feb 0

Q1 2016 Mar 0

Q2 2016 Apr $1,733

Q2 2016 May $1,733

Q2 2016 June $1,733

Q3 2016 July $1,327

Q3 2016 Aug $1,327

Q3 2016 Sept $1,327

Q4 2016 Oct $3,542

$16,964

Compare EIV Income to the 5/1/16 50059


Determine the Problem

• Does documentation in file support the incomes that were calculated for the 50059?

• Are the calculations in the file for the 50059 correct?

• Do the calculations differ from the 50059 – is there a data entry error?

• If answers to any of the above are no, correct the problem.


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Resolve the Discrepancy

• Correct the calculations and submit a corrected 50059 and/or

• Correct the data entry error in TRACs and/or• Contact the resident to review

– Unreported income– Unreported loss of or reduction in income– Verifications that differ from amounts shown in

EIV


Meeting with the Resident

• If resident agrees with EIV– Obtain any documentation needed to calculate

income– Perform calculations – Prepare and submit a corrected 50059 or 50059’s to

TRACs• If resident disagrees with EIV

– Obtain 3rd party verification directly from the source to support or deny resident’s claims

– Proceed in accordance with what the verifications show


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The Five-Year Requirement

• When a discrepancy is ‘true”, HUD requires you to investigate information for the previous five years or for all of the certifications in the file if they have not lived in the property for five years

• This is a one-time analysis• Corrections will have to made if this

investigation reveals “true” discrepancies in any of the files reviewed


It Can Get Complicated

• If a resident has had numerous interims during the POI, you will need to reflect that in the comparison you do to the EIV Income (see Slide 27)

• This can and often will result in corrections to more than one 50059

• Repayment Agreement may be required• Refunds to residents may be required


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• Look for the obvious• Look for the obvious1

• Research the not-so-obvious• Research the not-so-obvious2

• Document the file• Document the file3

• Tell the story• Tell the story4

Discrepancy Tips


QUESTIONS?


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GWEN VOLKCPM, NAHP-E, RAM, FHC, SHCM, HCCP

GWEN VOLK INFOCUS, [email protected]



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EIV INCOME DISCREPANCIES [DON'T GO CRAZY

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