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IHFA Management and Occupancy Review (MOR) Process: Initial MOR Notification Letter Desk Review by IHFA pre- MOR Day of the MOR MOR Report Follow-up by IHFA or the

Owner/Agent (O/A) Records Retention Requirements

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On a conference call with HUD on April 8, 2009 IHFA was informed that HUD will be publishing a revised version of chapter 6 of the 4350.1. (chapter on MOR processes) When this is published it may effect some of these processes.

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This letter (form #1) will request (if you currently have EIV access) that you make available for review, the following security related forms: EIV Coordinator Access Authorization Forms

(link #1) EIV User Access Authorization Forms (link #2) EIV Owner Approval Letter (form #2) Security Awareness Training Questionnaires

(link #3)

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This letter will also request that you make available for review on-site: Development Policy and Procedure

Manual(s)▪ The EIV Policy and Procedure Manual will be

reviewed at the time of the MOR.

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The security file documentation will be reviewed at MOR. IHFA suggests that the coordinator keep the following files: A file that contains all the original/initial

and current required security forms . A file that contains historic documents

and/or terminated user information. Please ensure that the files are available for

review on the day of the MOR. The files should contain forms for anyone that has/had access to EIV for this site.

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The desk review process is completed by the IHFA Compliance Auditor prior to conducting the MOR: The auditor will run the following reports

regardless of site access to EIV:▪ Failed Verification Report▪ Deceased Tenant Report▪ Multiple Subsidy Report▪ If there are any discrepancies on any of these reports,

the auditor will take these reports to the MOR and give to the on-site manager for follow-up/resolution.

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IHFA will run a report from iREMS, (HUD secure system for PBCA’s) or ask HUD to run this report for them (for those sites that we are not granted access) that will show everyone with EIV access roles.

This report will be taken to the MOR and used to ensure all coordinators/users with access have the appropriate security documentation on file.

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If the O/A has EIV access, the auditor will also run the following reports: Income Discrepancy Report No Income Report New Hire Report▪ These reports will be used to assist in

choosing units for audit as well as alert IHFA to any red flags regarding income reporting discrepencies at the property.

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Policies and Procedures will be reviewed.

The 3 non-income related reports will be given to the O/A for resolution. (if applicable)

The EIV security file will be audited and compared to the report from iREMS/HUD. (form #6)

The O/A will be interviewed regarding security of the data. (form #7 and #8)

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A sample of tenant files will be audited to ensure the correct 9887 and 9887A are completed and in file.

The tenant files will be reviewed for applicable EIV reports and supporting documentation to verify resolution of discrepancies. (if applicable) Note: IHFA may request additional files for

this purpose.

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EIV data/reports will be reviewed to ensure compliance with established Polices and Procedures.

Any Discrepancies/Observations/Findings will be discussed in the exit interview.

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Per the HUD webinar conducted December 17 and 18, 2008, link: http://www.hud.gov/webcasts/index.cfm, the following Observations/Findings will be taken/issued: Note: We understand that this will

change when EIV becomes mandatory effective September 30, 2009 . The following is applicable for the 2009 audit year only. 16

If the O/A has no EIV access: Nothing will be communicated on the

MOR report. If the 9887 and/or 9887 A are not

completed and in file: A Finding will be issued, regardless of

EIV access, in accordance with the HUD Handbook 4350.3 Rev-1 Chg. 2 guidance.

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If the O/A has access to EIV and any of the 4 required security file documents are not completed and/or missing for any current coordinator/user: An Observation will be issued and: IHFA will e-mail HUD ”immediately” and

access to EIV could be terminated. If the O/A submits the required documents to IHFA, a second e-mail will be sent to HUD and access will be reinstated.

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The following is an example of the observation that will be issued: O/A did not provide CAAF, UAAF, EIV Owner

Certification, or Security Awareness Training Questionnaires for EIV access, yet O/A is using the system to verify income of tenants.  As directed by HUD, an email has been sent to the Director of the Housing Assistance Policy Division at HUD Headquarters to report the missing documentation. HUD may terminate user and/or coordinator access.

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If the O/A has access to EIV and is using the system, but does not have established Polices and Procedures: An Observation will be issued.▪ Example: Owner/Agent must establish

policies and procedures that provide instruction and information on the acceptable use, disposition and storage of data obtained through the Enterprise Income Verification (EIV) system.  

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If the O/A has access to EIV and is not resolving the income discrepancies listed on the Income Discrepancy Report obtained in EIV: (form #9) A Finding will be issued.▪ Please note that resolution does not

necessarily mean an increase in the resident’s rent.

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If the O/A has access to EIV and is not using EIV data as the preferred method of verification, before other acceptable verification methods are attempted: A Finding will be issued.▪ Example: An O/A is currently using EIV to

verify SSA data but does not use NDNH or other income data.

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If the O/A has access to EIV and is not resolving discrepancies between EIV data and second party verification: A Finding will be issued.▪ Example: EIV shows that the resident makes

$300.00 per month but the second party documentation provided supports $550.00 per month. Third party verification was not obtained to clarify this discrepancy.

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There are very specific time frames attached to the retention of the data that is obtained from EIV. They are as follows: Social Security Benefit Data▪ Term of tenancy plus 3 years

National Directory of New Hires (NDNH) data▪ 2 years

If you have a report that contains both, the NDNH data must be cut off and removed from the file after the 2 year period.

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NDNH data must be destroyed at annual recertification of the second year.

When it is destroyed, the file must be noted as such as well as the date of destruction.(form #10) The first date to destroy data for

residents will be January 2010.

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Tax Credit auditorsUSDA/RD auditors Internal auditors such as your CPA

firm that prepares your Annual Financial Statements.

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In order to ensure that you are destroying this data according to HUD requirements, and to ensure no access is given to unauthorized individuals, IHFA is suggesting that a second file, separate from the tenant file, be kept that contains only the EIV data.

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EIV Quick Start (form #11) Complete step-by-step instructions on

getting set upQuarterly Recertification Instructions

(form #12)Sample EIV Notice to Residents

(form #13)

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HUD EIV Website: http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/eivhome.cfm

IHFA Website: http://www.ihfa.org/multifamily_section8.asp

Ross Business Development: http://www.rbdnow.com/eiv.htm

Sample forms packet provided today30

HUD RHIIP Website: http://www.hud.gov/offices/hsg/mfh/rhiip/mfhrhiip.cfm

EIV Notice: http://www.hud.gov/offices/adm/hudclips/notices/hsg/08hsgnotices.cfm 

RHIIP Q and A’s: http://www.hud.gov/offices/hsg/mfh/rhiip/qnaon4350pt3.pdf

Course materials from this class on the Idaho AHMA website: http://www.idahoahma.org/events/course-materials.html

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Misty Schafte: Misty.schafte@hud.gov 971-222-2656

Sheryl Putnam: sherylp@ihfa.org 331-4821

Heather Wiedenfeld: heatherw@ihfa.org 331-4868

Noel Gill: ngill@nwrecc.org

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