Chapter 3. Data Collection, Analysis,
and Documenting the Rent Calculation
Process
1
Chapter 3. Section 1.
Introduction
Learning Objective
Gather, analyze and document information through
improved skill development in interviewing and
analysis
2
Introduction
• HUD programs rely greatly on voluntary
disclosure by family
• PHA actions to reduce vulnerability
– Critically analyze PHA intake and
reexamination processes
– Work on improving the interviewing skills of
their staff
– Train their staffs to analyze information
critically
3
Introduction
• PHA actions to reduce vulnerability
– Develop comprehensive data collection and
verification tools
– Adopt policies that require relevant
documents to be provided by families
– Make maximum use of UIV tools to prevent
and detect false statements and
underreporting of income
4
Introduction
• Steps in the rent calculation process:
– Gathering data
– Interviewing
– Verification
– Review and follow-up
– Data entry and calculation
– Maintaining files
5
Introduction
• The steps are determined by the answers
to three important questions:
– What information is needed for correct
rent calculations?
– How will the information be verified?
– How will the information be processed
and recorded?
6
Chapter 3. Section 2.
Step 1: Gathering Data
7
Gathering Data: Forms
• For most PHAs, the admission or reexamination
process begins when a “forms packet” is
provided to the family
• The forms used for initial and annual
certifications are most critical (application and
recertification forms)
• RIM reviewers have found that many application
and verification forms used by PHAs do not ask
ALL necessary questions or questions are too
vague to make accurate determinations of
income and rent
8
Gathering Data: Forms
• If the PHA’s forms do not ask ALL of the
right questions clearly, staff may be unable
to make correct income and rent
determinations
• Forms should be reviewed for the 4 C’s:
completeness, clarity, and compliance with
current requirements
9
Common Issues
• RIM reviewers have identified areas in
which PHA forms may fall short:
– Non-cash contributions: form only asks
about regular payment of a bill
– Disability assistance expenses: forms
ask only elderly/disabled families about
disabilities expenses or neglect to ask
about the expenses entirely
10
Common Issues
• RIM reviewers have identified areas in
which PHA forms may fall short:
– Medical expenses:
• PHA forms do not ask for anticipated medical
expenses
• Forms are unclear about what is to be considered
a medical expense
11
Common Issues
• The questions may be flawed in these
ways:
– Incomplete questions
• “Does any employed family member pay
child care expenses for work?”
12
Common Issues
• Missing questions:
– No questions about divested assets
– No question regarding qualifying factors
for EID purposes
• Vague/confusing questions
– “Do you anticipate medical expenses in
excess of 3% of your annual income for
the 12 months following admission or
reexamination?”
13
Common Issues
• Forms may be out of date
– Forms not revised to reflect changes in
regulations governing:
• The Earned Income Disallowance
• Training program income
• Imputed welfare income
14
PHA Application Form
• It should be comprehensive.
• It serves several important functions:
– Critical to effective interviewing
– Ensures same questions are asked of all families
– Provides paper trail for false statements
– Is “proof” that questions were asked
15
PHA Application Form
• Primary and secondary questions
– Application form should ask two types
of questions:
• Primary questions: These open up a topic
(i.e., a factor that affects income or rent)
• Secondary questions: For additional
information about a topic
16
PHA Application Form
• Sample application questions
– Example 1 (page 3-6)
• Review questions
• Each primary question is yes-or-no
• Secondary questions are answered only if
response to the primary question is yes
• Strength of this method is that applicant or
participant must declare an answer to the primary
question
17
PHA Application Form
• Sample application questions
– Example 2 (page 3-7)
• Review questions
• Uses a statement rather than a question to open a
table
• Uses a table to collect secondary information
• PHA interviewers must ensure that no items are
left blank
18
Sample Application Questions
• Review Sample Application Questions
(pages 3-8 through 3-11)
– Part 1: Income Information
– Part 2: Assets
– Part 3: Expenses
– Review all questions and mark the ones that
are not included on the application form in
your PHA. If you are not sure, compare when
you go home.
19
Sample Primary Questions by
Topic
• Part I: Income Information
• (Reexams only): Has anyone in your
household started a new job or had an
increase in earnings? If yes, answer the
following:
• Is this a person with a disability?
• Has this person been unemployed 1+ years?
• Is this person participating in any type of
economic self-sufficiency program?
• Has this person received TANF in the past six
months, including one-time cash payments? 20
Sample Primary Questions by
Topic
• Part I: Income Information
• Does any household member receive cash,
tips, bonuses, commissions, or any type of
compensation for providing any type of
services?
21
Sample Application Questions
• TIP:
– Many PHAs include questions pertaining to a
family’s current expenditures
• Rent, electric, gas, water, telephone car payment,
insurance, credit cards, medical bills, etc.
– Allows comparison between expenditures and
current income
– Creates opportunities for follow-up questions
when discrepancies and when families report
zero income
22
Gathering Data
• Learning Activity 3-1: Fix the Question
(page 3-13)
– Analyze Question #1 by responding to the
questions beneath it.
– Be prepared to report results to group.
– Questions #2 - #5: Take home
23
Chapter 3. Section 3.
Step 2: Interviewing
24
Interviewing
• Interviewing is the most important skill in
the housing process
• Interviews may either encourage or
discourage compliance, cooperation and
honest disclosure
• Initial eligibility interview is most crucial
interview of all
• Interview training essential
25
Interviewing
• To ensure consistency, interviewers
should use a checklist
• Interviewers should have a “planned
approach” to ensure consistency in the
process
– Pre-interview
– Data collection
– Analysis of the data collected
– Closing the interview . . .
26
Pre-Interview
• Interviewer sets the tone, builds trust
• Uses a checklist to establish ground rules
for the interview (see Pre-Interview
Checklist on page 3-20)
27
Data Collection
• Focuses solely on gathering information
from the family
• The interviewer asks all the questions
pertaining to eligibility
• Documents the answer to each question
28
Data Analysis
• The interviewer:
– Evaluates the information and documents
provided by family to determine what needs to
be verified
– Determines whether or not family must
provide any additional documents or
information
– Resolves any discrepancies between family’s
statements and any UIV or other verification
29
Closing the Interview
• The interviewer:
– Reviews all forms with family
– Obtains consent forms as needed
– Provides family with written instructions about
any further information or documents that
family must provide
– Answers any questions family may have
– Provides any information family may need to
understand program rules and requirements
30
Interviewing
• Some PHAs conduct reexaminations by
mail
– No regulatory requirement for face-to-face
interview
• If PHA does not interview family in person,
completeness of application and
reexamination forms is critical to income
and rent determinations
31
Interviewing
• Application or reexam form is generally
used as a “template” for interview
– Ask every question on form
– Make sure all questions are answered (Do not
use n/a)
– Make sure form is signed and dated by PHA
representative and family representative
32
Asking the Right Questions
• Use global (open-ended) questions to get
explanations. Who…? What…? Where..?
How do you…? Why……?
• Use closed questions to get specifics. Do
you? Is it? How much? How many?
33
Probing Questions
• Use probing questions to get additional
information about an issue
– Clarifying
– Resolving discrepancies
What do you mean by…..?
Could you explain how……?
Help me to understand this, how do you….?
34
Probing Questions
• Probing questions may be very relevant when
UIV conflicts with statements or documentation
provided by family
• Example: SWICA report shows family employed
last two quarters and family reports no
employment
– Where was the last place you worked?
– How long were you there?
– When did you leave?
– (If not resolved, then ask “Can you explain . . . ?”)
35
Avoid Multiple Questions
• Such as, “Do you have a checking or
savings account or any type of
investments such as an IRA or certificate
of deposit”?
• They confuse some people
• They give others the opportunity to select
the part of the question they want to
answer or avoid
36
Multiple Questions
• Break multiple questions down into simple
questions. For example:
– Where do you bank?
– What types of accounts do you have there?
– What is the account number?
– What is the account balance?
– Do you have any other type of accounts at
this bank?
– Are there any other banks you do business
with?
37
Avoid Leading Questions
• You don’t have any income, do you?
• Everything’s the same as last
year…right?
38
Use “Mirror” Questions
• Reflect or restate a response
• Reflect or restate a scenario
• The purpose of “mirroring” or “reflecting”
what an individual has said is to obtain
confirmation, correction, clarification or
amplification.
39
Other Tips
• Allow adequate time for response
• Don’t reword a question unless necessary
for accuracy or clarity
• Avoid technical language or jargon
• Educate while interviewing
• Learn to ask the tough questions in a non-
threatening way
– You don’t have to act tough to ask tough
questions
40
Discussion Questions
• Do interviewers have a planned approach
to the interview? (Pre-Interview Checklist)
• Do interviewers ask open-ended, inclusive
questions vs. specific questions when
exploring a topic?
• Do interviewers apply questions to all
family members, even those not present at
interviews?
41
Discussion Questions
• Do interviewers review all types of income
with families? For all family members?
• Do interviewers ask about excluded
income? For all family members?
• Do interviewers review all types of assets
with families? For all family members?
42
Discussion Questions
• Do interviewers make families aware of all
possible allowable expenses? For all
family members?
• Do interviewers ask secondary questions
regarding reimbursement of expenses
claimed?
43
Discussion Questions
• When increased earnings are reported,
does staff determine:
– Whether the individual meets any of the
criteria to qualify for earned income
disallowance?
– Whether the individual is enrolled in a
qualified training program?
44
Interviewing
• Learning Activity 3-2: Situational Analysis
(page 3-26)
45
Chapter 3. Section 4.
Step 3. Verification
46
Verification
• Interviewer must be able to decide:
– What additional documents are needed
– What additional information must the
applicant provide
– What must be verified to comply with HUD
requirements
– What type of verification is needed
47
Verification Forms
• Should be comprehensive, but not
complicated
• Should ask secondary questions (are
expenses reimbursed, etc)
• Should include a “false statement”
statement
• Must include a signed authorization for
release of information
48
Verification Forms
• Should capture name, position, telephone
number of information provider
• Should capture current and anticipated earnings
and fluctuating pay rates and hours
• May want to consider including self addressed
stamped envelope with each verification form
mailed out
49
Verification
• We will discuss verification requirements
in depth in the next session
50
Chapter 3. Section 5.
Step 4. Review and Follow-up
51
Review and Follow-Up
• Verifications received from up-front sources and
third parties must be compared to information
provided by the family at the interview or in the
application form
• In case of conflicting information, PHAs must:
– Resolve any discrepancies by following up, as
necessary, with the third party, the family, or both
– Document the resolution and leave a clear audit trail
52
Discussion Question
• What procedure does your PHA follow
when documents provided by the family
conflict with up-front or other third-party
verifications after the interview is over?
– Example: Third-party employer form shows 20
hours per week employment, pay stubs show
average of 25 weekly hours
53
Discussion Question
• Possible answers from PHAs:
– Always use the third-party verification
– Always use pay stubs
– Use the higher figure to avoid an overpayment
– Use the lower figure to benefit the applicant or
participant
• But what is the “right” answer???
• The answer you get as a result of resolving a
discrepancy based on the facts you get.
54
Review and Follow-Up
• When there is a conflict between family-
supplied information, up-front verification,
or written third-party verification, the PHA
must:
– Obtain additional information from family
and/or third party
– Resolve the discrepancy
– Document thoroughly to leave a clear audit
trail
55
Chapter 3. Section 6.
Step 5. Data Entry and
Calculation
56
Data Entry and Calculation
• Documentation is the key
– Anyone reviewing the file should be able to
understand how the rent was calculated
– Calculation documentation could include:
• Printout from software system showing
calculations
• Calculator tape
• Narrative entry explaining calculations
• Signed, dated notation attached to third-party or
UIV document if computer printout doesn’t show
calculations
57
Data Entry and Calculation
• PHAs should develop methods for
comparing information in file to staff’s rent
calculations
– Show relationship between figures on
verification forms and figures on 50058,
rent calculation worksheet or printout
58
Data Entry and Calculation
• HUD recommends having a printed 50058 form
in the file.
• Due to PHA policy or software issues, staff may
not be able to print one. Instead, it is:
– Advisable to print a worksheet or summary
– Essential to understand what is shown on the
printout and where those numbers come from
(which data entry fields)
59
Data Entry and Calculation
• Staff should verify each completed
calculation by comparing it to file data and
checking for:
– Data entry errors
– Transposed numbers
– Incomplete information (adult not coded as a
full-time student)
– Missing information (second source of
income)
– Carryover of previous errors (birth date, SSN)
60
Data Entry and Calculation
• A worksheet may be completed by hand
for comparison to a software calculation
for some or all staff
– Manual calculations sometimes catch errors
that otherwise might be overlooked
• Also provide hands-on experience with process of
rent determination
• PHAs should review and correct mistakes
identified in PIC error reports
61
Chapter 3. Section 7.
Step 6. Maintaining Files
62
Maintaining Files
• Rent calculation procedures should
include a standardized system for creating
and maintaining all case files
– Ensures consistency
– Easier for staff to fill in for one another during
vacations or other absences
– Saves time for supervisory reviews, audits
and/or monitoring visits
More…
63
Maintaining Files
• Every case file should follow a standard
format so that a reviewer can find the
same items in the same place in each file.
• Checking to ensure that staff members are
following the standard file format should
be part of a supervisory quality control
review.
64
Maintaining Files
• Considerations for file layout:
– How will you divide sections?
• Could divide sections for left & right sides of folder
• Could use tabs or colored pages to divide sections
– Will you place frequently-used items at the
front of the file or elsewhere?
– How will you delineate between reexams so it
is clear which documentation goes with which
reexam?
65
Chapter 3. Section 8.
Conclusion
66
Conclusion
• PHAs need to do a step-by-step review
and analysis of the rent calculation
process as an error-reduction strategy
– Identify policies, procedures and all other
tools involved in the rent calculation process
– Determine whether those policies, procedures
and tools support correct income and rent
determinations . . .
67
Conclusion
• PHAs need to do a step-by-step review
and analysis of the rent calculation
process as an error-reduction strategy
– Revise existing policies, procedures and tools
as needed
– Create new policies, procedures and tools
when necessary
– Ensure that staff is implementing policies &
procedures consistently and utilizing tools as
needed
68
Learning Objective
• Gather, analyze and document information
through improved skill development in
interviewing and analysis
69