INTERPRETING VERIFICATIONS

							                        INTERPRETING VERIFICATIONS
                           Anne McCready – 9/10/09

Per SHHP’s Housing Choice Voucher Program Administrative Plan – 1/31/09:
      “SHHP must verify all information that is used to establish the family’s
      eligibility and level of assistance and is required to obtain the family’s
      consent to collect the information. Applicants and program participants
      must cooperate with the verification process as a condition of receiving
      assistance.”

“SHHP will follow the verification guidance provided by HUD in PIH Notice 2004-
1.”

Releases of Information

Authorization for the Release of Information/Privacy Act Notice (HUD-9886)
           Authorizes the Housing Authority (SHHP and its partner agencies)
              to request verification from current and former employers of salary
              and wages.
           Authorizes the Housing Authority to obtain wage information from
              state agencies, such as the Colorado Dept. of Labor (DOLE
              reports).
           Authorizes the Housing Authority to obtain certain tax return info
              from Social Security and IRS.
           Authorizes the Housing Authority to obtain information from
              financial institutions.
           Must be signed by all family members 18 years of age or older.
           Privacy Act Notice clarifies what the information will be used for and
              identifies entities that may have access to the information.
           New forms are required at every annual reexamination.
           Form expires after 15 months.

Authorization for the Release of Information (SHHP form)
           Authorizes the Housing Authority to obtain 3rd party information
              from a number of different sources in order to determine eligibility
              and amount of assistance.
           Must be signed by all family members 18 years of age or older.
           Form expires after 15 months.

Verification Tracking Form
            Contains the 5 levels of verifications.
            Use it to track when verifications are sent out and returned.




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Electronic Income Verifications

Five different electronic verifications available from SHHP
            Electronic Income Verification (EIV) - Information from HUD
               includes Social Security and Workers’ Comp amounts, as well as
               information on salaries and jobs. When a participant gets a new
               job, it is recorded in this database, and SHHP is notified.
            The Colorado Department of Labor and Employment (DOLE) - A
               database of all jobs in Colorado and the amount that employees
               earn. Workers’ Compensation benefits are also listed in DOLE’s
               database. EIV and DOLE information are a few months behind. If
               current information is need, use 3rd party verification or other
               sources.
            The Work Number - Tracks jobs, dates of employment, and wages
               earned for companies nationwide.
            The Colorado Benefits Management System (CBMS) - Contains
               information on Food Stamps and other welfare benefits such as
               Temporary Assistance for Needy Families (TANF), Old Age
               Pension (OAP), and Aid to the Needy Disabled (AND).
            The Family Support Registry - child support payments made in
               Colorado through the Registry. Not all payments are passed
               through the Registry.

Third Party Verifications

General information
           When completing the annual paperwork, ask participant for
             documents verifying income, assets, expenses, in case you are
             unable to obtain 3rd party verification.
           Participant must bring original documents. Coordinator will make
             copies.
           “Third Party” means the participant never touches it. The document
             goes directly from coordinator to person verifying the information
             back to coordinator. Don’t give the form to the participant.
           Always review the most recent 50058(s), especially the one
             completed for the last annual reexamination, before meeting with
             the participant. Always review the current Family Reporting Form
             after the family has completed it and signed it and compare it to last
             year’s form.
           Verifications must be signed by the family member about whom you
             are requesting information.
           Be sure to attach the signed HUD and SHHP Release of
             Information forms before sending the verifications out.



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             Type or stamp your information (so it’s legible) at the bottom,
              including your name and title, your agency name, fax number, and
              telephone number (in case the respondent wants to discuss the
              information).
             Do not give to tenant – fax or mail the verification directly to the
              company.
             Keep track of date that the verification was sent out by completing
              the verification tracking form. After 10 days, go to the next lower
              level of verification, generally oral.
             Oral 3rd party verification: Document whom you talked to, his or her
              position in the organization, and the date. Then initial it.
             Show your work – Write your calculations on the verification form.
             All verifications must be dated within 60 days of the interview or
              120 days of the effective date of the action.

When the verification is returned, review it and ask yourself the following
questions:
        Is the information legible?
        Does the information make sense?
        Is the information complete?
        Is there enough information to enter it on the 50058?

Verification of Employment
        No longer necessary if participant submits recent pay stubs, the
          information matches what is listed on EIV, and the participant doesn’t
          dispute the information on the EIV.
        Use to verify termination of employment.
        If a range of hours is listed, use the average: 20-25 hrs/wk = 22.5 hrs
          average.
        Pitfalls
              o Rate of pay doesn’t match what is listed on previous
                  verifications.
              o Tips not included.

Verification of Non-Wage Income/Assets
        SHHP is able to verify many of those listed under “Income Source” on
          the form. Your SHHP rep can run more recent reports, if you need
          them.
        Assets must be verified. 3rd party is generally preferable, but if original
          documents confirm that asset is valued at less than $500, 3rd party
          verification is not required.
        Pitfalls
              o Some banks charge for verifications. Keep a list of those and
                  don’t bother to send them. Use documents from participant and
                  make a note on the Verification Tracking Form.



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              o Bank accounts that the participant forgets to list but were open a
                 year ago.
              o Interest calculation example:
                      .25% interest - $1,000 in account = .0025 x 1000 =
                        $2.50/yr – enter on 50058 as asset income.
                      2% interest - $1,000 in account = .02 x 1000 = $20.00/yr
                      “interest accrued last quarter” - $2.00: $2.00 x 4 =
                        $8.00/yr.
              o If participant states that account is closed, this must be verified.
              o What happened to that $10,000 they had last year? Ask.
          Assets include checking and savings account, stocks, trusts. Refer to
           the Administrative Plan for more information.

Verification of Self-Employment
    Make sure that it is complete, that it makes sense, and that it is notarized
       or witnessed by someone in your agency who knows the person
       completing the form. If it costs money to have a form notarized, do not
       require the participant to get the document notarized.
    Participant should submit a copy of the previous year’s tax form.
    Use net income amount, after expenses are deducted.

Verification of Student Status
    Use for both students in high school who are 18 years of age or older and
       those in college or technical school.
    Pitfalls
          o Incomplete information.

Verification of Expenses
    Child Care
          o Pitfalls
                  Is the cost listed on the form what the participant pays out of
                     pocket?
                  Are others paying part of the cost? Children’s father or other
                     relative; Child Care Assistance Program (CCAP).
                  Are the costs reasonable?
                  Does the care enable a family member to work, look for
                     work, or attend school?

      Medical Expenses
         o Disabled or elderly families only (head, co-head, or spouse is
             disabled).
         o Refer to IRS Publication 502 for guidance on what medical
             expenses are countable go to www.irs.gov to print off the booklet.
         o Participant should obtain one-year printout from provider.
         o Costs must not be reimbursed by another source, such as
             insurance.


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          o Eligible costs include medical, dental, vision, mental health
            appointments, medical equipment, transportation to appointments
            etc.
          o Costs for the care and feeding of a companion animal are eligible.
          o If participant is paying on a medical debt, only actual payment
            amounts are eligible.
          o Use the Medical Calculation form, available on the SHHP website:
            Coordinators/Calculating Forms/Medical Calculation Form.
          o Pitfalls – numerous
                 One-time expenses. Eligible the following year or at interim.
                 Insurance reimbursement?
                 How often does the expense occur? Weekly, monthly,
                    quarterly, annually? How do you know?

Other forms
    Zero Income Reporting Form – must be completed monthly
         o Pitfall – must be reviewed and questioned. If Aunt Susie is paying
            the monthly cell phone bill, that is income.
    Verification of Disability/Handicapped Status
         o Pitfall - Required annually if head of household does not receive
            Social Security or SSI.
    Verification of Live-In Aide – must be completed by a medical provider.
         o Required annually, along with Request for Reasonable
            Accommodation form.
         o Pitfall – Rotating staff whose primary residence is NOT the assisted
            unit are not considered live-in aides, and an extra bedroom will not
            be subsidized for staff that are only in the home a few nights per
            week.




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