Rental Housing Integrity Improvement
Project (RHIIP) Initiative
Secretarial initiative designed to reduce
income and rent errors and improper subsidy
payments
A comprehensive strategy to address 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‖ 2
Background
The 2001 Office of Policy Development and
Research (PD&R) Quality Control for Rental
Assistance Subsidies Determination (QC)
study found that HUD overpaid $2.6 billion
and underpaid $634 million in annual
housing subsidies
The QC study estimated that 60% of all rent
and subsidy calculations contained some
type of error
3
Presidential Management Initiative
#10
Mandated HUD to reduce the processing
(administrative errors) error and improper
payment rate by 50%, from 60% to 30% by
2005
HUD set aggressive interim goals in its Annual
Performance Plan:
A 15% reduction by FY 2003
A 30% reduction by FY 2004 4
Improper Payments Information
Act of 2002
Requires agencies to:
Annually review all programs susceptible to
significant erroneous payments
Measure the number and dollar amounts of
errors and track progress towards reducing
those errors
Report to the President and Congress, if the
amount of improper payments exceeds $10
million 5
2003 PD&R Quality Control Rental
Assistance Subsidies Study
Methodology
HUD PD&R measurement of progress in
reducing errors during FY 2003
Data collected from over 2,400 households at
600 sites
Information from tenant files & in-person
interviews
6
2003 PD&R Quality Control Rental
Assistance Subsidies Study Results
Rental Assistance FY 2003 Estimates of FY 2000 Estimates of % Reduction
Program Errors/Gross Erroneous Errors/Gross in Gross
Payments Erroneous Payments Errors
Public Housing $356,040 $631,776 43.6%
Vouchers & Mod $797,508 $1,132,560 29.6%
Rehab
Total PHA $1,153,548 $1,764,336 34.6%
Administered
Project-based $395,796 $539,160 26.6%
Assistance
Total $1,549,344 $2,303,496 32.7%
(+/– $229,000) (+/– $275,000)
7
* – All values are presented in the thousands.
FY 2003 Performance and
Accountability Report, Note 17
Reports that HUD has exceeded its interim
2003 goal of a 15% reduction in administrative
errors, based on study results for the first half
of FY 2003
Describes the methodology used for updating
the 2000 baseline error measurement
Discusses the corrective actions HUD has taken
to address the causes of erroneous subsidy
8
payments
RIM Review Case Studies
Examined 37 large PHAs who had RIM reviews
and follow-up reviews
Concluded that significant errors still existed,
particularly regarding:
Verification of income
Improper calculations, including problems with
utility allowances, deductions, and expenses 9
Accomplishments
Accomplishments for 2003—Error
Reduction Efforts
Exceeded HUD’s interim FY 2003 goal of a 15%
reduction in estimated program administrator errors
Worked and coordinated with the Inspector General
(IG) on fraud cases
Issued a letter to Certified Public Accountants
(CPAs) to assess, mitigate, & report PHA improper
calculation of subsidy payments
Presented the strategic goals and RHIIP objectives
at over 30 conferences/meetings to industry group11
leaders
Accomplishments for 2003—
Monitoring/Reporting
Conducted over 700 RIM reviews at PHAs
managing over 80 percent of PIH's funding
Exceeded the goal of an 85 percent PIC
reporting rating -- 89 percent for public
housing and 98 percent for HCV
12
Accomplishments for 2003—
Income Matching
Developed and began to test pilot the Upfront
Income Verification (UIV) System at 40 PHAs in
7 pilot states
Established agreements with 24 states to allow
computer matching of tenant income and State
wage data
Legislation was introduced in Congress to
access and use the National Directory of New
Hires Database to detect unreported income 13
Accomplishments for 2003—
Guidance/Staff Training
Released the first Public Housing Occupancy
Guidebook in over 20 years
Issued the Notice PIH 2003-34, Rental Integrity
Monitoring (RIM) Disallowed Costs and
Sanctions under RHIIP
Launched the new PIH RHIIP website
Provided occupancy training to Field Office
staff and scheduled two regional trainings in
occupancy for PHA: 1/26 to 1/30 and 2/2 to 2/6 14
Policy/Guidance
PIH Policy and Guidance
Program Simplification Proposals
Pubic Housing Occupancy and HCV Program
Guidebooks, June 2003
Fact Sheet on Income and Rent Determinations,
November 2002
Notice PIH 2003-34, Rental Integrity Monitoring
(RIM) Disallowed Costs and Sanctions under
RHIIP, December 19, 2003
16
Verification Guidance for PHAs (early 2004)
Up-front Income Verification
(UIV)
Current Sources for UIV Data
Social Security (SS) and Supplemental
Security Income (SSI) information accessed
via the Tenant Assessment Subsystem (TASS)
State Wage Information Collection Agencies
(SWICAs)
State Temporary Assistance for Needy
Families (TANF) systems
Private sector databases (e.g., The Work
Number) 18
HUD’s 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
Displays gross and net benefits for any Social
Security Number (SSN) that is subsidized by HUD
HUD strongly encourages PHAs to systematically
use the system to reduce incidents of undisclosed
SS and SSI income 19
HUD’s Tenant Assessment
Subsystem (cont.)
HUD TASS Point of Contact (POC): Myra Newbill
202-708-4932 ext. 3211
HUD TASS website location:
http://www.hud.gov/offices/reac/products/pro
dtass.cfm
20
UIV System Pilot
Commenced on August 18, 2003
Participants: 40 PHAs in 8 states, with over
400 users
Currently testing release 3.0.1
21
UIV System Pilot (cont.)
Objectives:
Obtain feedback on how wage and benefit
data is displayed
Identify and assess implications of
accessing SWICA data
22
UIV System
For tenant recertifications, not new admissions--
wage and benefit data is pulled for existing
Social Security Numbers (SSNs) in the PIC
system
PHAs may not view the tenant data without a
signed Form HUD-9886, Authorization for the
Release of Information/Privacy Act Notice in the
tenant’s file
23
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
Provides wage and benefit information through
a data matching process for households
covered by HUD Form 50058 24
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 25
UIV System Security
PHA Responsibilities:
Ensure that access rights, roles and
responsibilities within PHAs are appropriately and
adequately assigned and monitored
Conduct 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 26
Fraud
OFFICE OF INSPECTOR GENERAL
U.S. Department of Housing and Urban Development
WASHINGTON, D.C. 20410-4500
Reporting
HOTLINE COMPLAINT INTAKE FORM
COMPLAINT INFORMATION
Fraud
Date:_______
COMPLAINANT CONTACT INFORMATION
PHA Name:________________________
Point of Contact Name:______________________
Hotline: 800-347-3735 Address:___________________________
(Street)
___________________ _____________ _______________
(City) (State) (Zip Code)
Fax: 202-708-4829 Telephone: (Work)___________ (Cell Phone)_________________
Email:___________________________
SUBJECT INFORMATION
Note: Incidents of Subject Name or Name of Business:_____________________________________
Subject Address (If known) __________________, _________, ______ _________
fraud may be followed- (Street) (City)
COMPLAINT SUMMARY (Attach additional pages if necessary):
(State) (Zip Code)
up by HUD Field Loss Amount:
Offices and the Nature of Allegation:
Initial Certification:________Recertification:________
Inspector General U.S. Department of Housing and Urban Development
WASHINGTON, D.C. 20410-4500
28
United States Attorney
Reporting Southern District of New York
Fraud FOR IMMEDIATE RELEASE
JUNE 3, 2003
CONTACT: U.S. ATTORNEY’S OFFICE
MARVIN SMILON, HERBERT HADAD,
MICHAEL KULSTAD
PUBLIC INFORMATION OFFICE
(212) 637-2600
BARBARA GUSS
(914) 993-1903
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 cost
the federal government more than $650,000.
29
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. 30
Rental Integrity Monitoring (RIM)
Re-reviews
Purpose of Re-reviews
Confirm whether the PHA has implemented
corrective actions as outlined in its approved
corrective action plan (CAP)
Verify that the implementation of corrective
actions has led to a reduction of errors
Determine whether errors identified during the
initial RIM review have been corrected
32
Scheduling of Re-reviews
Field offices must perform re-reviews to PHAs
that received initial reviews during periods:
Baseline I (completed prior to 1/31/03). Re-
reviews to be completed by 4/30/04
Baseline II (completed after 4/21/03 guidance).
Re-reviews for PHA programs requiring CAP or
when systemic errors were found to be completed
by 9/30/04
33
Re-review Protocol
Field Offices must:
Review approved PHA CAP; verify implementation and
establishment of internal controls
Review initial and newly selected tenant files to ensure
errors are corrected and determine accuracy of
income/rent calculations after CAP implementation
Take appropriate action when PHA fails to comply with
initial RIM review requirements 34
Re-review Reporting Requirements
All re-reviewed PHAs receive a report that:
Details whether all corrective actions have been
implemented
Lists findings, required corrective actions, observations
& recommendations from review of new file sample
Details results of re-review of initial RIM review tenant
files
Explains any actions/sanctions to be taken against the
PHA
35
Re-review Reporting
Requirements (cont.)
PHAs are provided with final written report
within 45 days of completion of re-review
PHAs are required to respond to the review
report within 30 days, but not later than 45
days
Response must address problems found or
enter into CAP; any disagreements with findings
or proposed corrective actions must be 36
addressed with the FO at this time
Re-review Reporting
Requirements (cont.)
If systemic or material findings exist, a copy of
the review report should be sent to the PHA’s
Independent Public Accountant (IPA) auditor
If actions must be taken against a PHA for
failure to address deficiencies from the first
RIM review, Field Offices must advise the
Financial Management Center (FMC) to take
appropriate action 37
Sanctions
Sanctions Notice PIH 2003-34
Highlights the importance of timely and
accurate income and rent determinations by
PHAs and establishes consequences for
failure to identify and correct deficiencies
An concerted approach to ensuring improved
government performance and proper subsidy
determinations in HUD’s rental programs
39
Sanctions Notice PIH 2003-34 (cont.)
Applies to Public Housing and Section 8 HCV
Program
Issued December 19, 2003 and its
application became mandatory for all RIM
actions—including reviews, required PHA
responses, and corrective actions—
subsequent to December 31, 2003
40
Sanctions Notice—Areas Addressed
Incentives, disallowed costs, and collection of
excess subsidies paid
Sanctions for failure to timely respond to the
RIM Review Report and to implement a CAP
Adjustment of Section 8 Management
Assessment Program (SEMAP) scores when
inconsistent with RIM review findings
Self-assessment reviews
Appeals 41
Disallowed Costs
Relate to PHA errors uncovered during RIM
reviews resulting in HUD overpayment of
subsidy
Subsidy overpayments must be returned to
HUD
Note: Disallowed costs due to HUD shall be
forgiven if amounts are less than or equal to
$2,500 per PHA program review
42
Disallowed Costs/Excess
Subsidies—HCV Program
Tenant Fraud
Overpayments: PHAs who enter into a repayment
agreement with the family, initiate litigation against
the family to recover excess subsidies, or initiate
termination from the program may keep 50% of
HCV funds collected if certain conditions are met.
PHAs that do not do any of the above actions must
return to HUD all amounts that constitute a subsidy
overpayment
Underpayments: Not applicable 43
Disallowed Costs/Excess
Subsidies—HCV Program (cont.)
PHA Errors
Overpayments: PHA reimburses HUD for 50% of
disallowed costs in excess of $2,000 dating from
latest reexamination. PHA must correct tenant
records and ensure accurate rent payments
Underpayments: PHA may only be reimbursed for
current fiscal year not yet settled in HUDCAPS. PHA
reimburses tenant according to PHA policy
44
Disallowed Costs/Excess
Subsidies—Public Housing Program
Tenant Fraud
Overpayments: If PHAs detect tenant fraud and
enter into a repayment agreement with the family,
sue the family to recover excess subsidies, or
initiate eviction (public housing), they may keep
100% of fraud collections. PHAs that do not do any
of the above actions must return to HUD all
amounts that constitute a subsidy overpayment
Underpayments: Not applicable
45
Disallowed Costs/Excess Subsidies—
Public Housing Program (cont.)
PHA Errors
Overpayments: If the errors affect the rent roll used
for operating subsidy calculation, HUD will calculate
disallowed costs based on subsidy overpayment
Underpayments: PHAs will not be reimbursed by
HUD. PHA reimburses tenant according to PHA
policy
46
Sanctions
If a PHA does not respond to a RIM Review Report
within 45 days or does not implement corrective
actions within approved timeframes, the Field Office
can withhold:
10% of its monthly scheduled HCV administrative
fee
5% of its monthly scheduled Public Housing
operating subsidy
Withholding begins with the month the sanction is
imposed and lasts until the PHA complies with
program requirements 47
SEMAP Indicator 3
A RIM review may serve as a SEMAP confirmatory
review
If a RIM review doesn’t support a PHA’s self-
certification of SEMAP Indicator 3 (Determination of
Adjusted Income) the Field Office must adjust the
SEMAP score, regardless of its impact on the PHA’s
performance designation
If a RIM review finds other indicators are not
supported by file or other documentation, the
SEMAP score for those indicators shall be adjusted
48
Self-Assessment Reviews
During FY 2004 and FY 2005, HUD will conduct
targeted and random RIM reviews of PHAs
managing over 250 combined units of public
housing and vouchers
HUD strongly encourages PHAs to conduct self-
assessment reviews to quality control and ensure
that the PHA’s income and rent determination
process is in compliance with program
requirements
RIM reference materials are available at:
http://www.hud.gov/offices/pih/programs/ph/rhiip
/index.cfm 49
Sanctions Notice—Appeals
A PHA may appeal a sanction/disallowed
cost to its Field Office within 30 days of
imposition of adverse action(s)
Written appeals must provide material
evidence or justification of any arguments or
additional facts and data concerning the
action
The Field Office must respond within 30 days
from the receipt of a request for an appeal
or the appeal is automatically granted 50
Sanctions Notice—Appeals (cont.)
If the Field Office denies the appeal, the PHA
has 15 days to appeal to the PIH Assistant
Secretary
If the appeal is denied by the Assistant
Secretary, there are no further appeals
permitted for that sanction/disallowed cost
Note: For adjustments of SEMAP scores as a
result of a RIM review, please refer to the
SEMAP appeals process
51
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!
52
PHA Action: The Key to a
Successful 2004!
Know and refer to HUD guidance materials
Follow-up on RIM review findings
Implement TASS and UIV to the extent possible
Visit the new PIH RHIIP website often at:
http://www.hud.gov/offices/pih/programs/ph/
rhiip/index.cfm
Run your program like a business!
53
Resolution for 2004
To continue to work together to further reduce
errors in 2004 and ensure that there’s more
housing money for those who need it the most.
54
Questions and Answers
55