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1. Question: What process should a PHA use to verify income and expenses?
Answer: PHAs should begin with the highest level of verification methods. The use of lower level verification methods will place a higher burden on the PHA to justify use of that particular verification method, rather than a higher method. Following is the established verification hierarchy, from the most reliable to the least:
For complete guidance on the verification process, see the new Notice PIH 2004-01, Verification Guidance for Public Housing Agencies (Adobe PDF).
2. Question: Does TASS compare tenant-reported information with Social Security (SS) data stored in the Social Security Administration (SSA)?
Answer: Yes. Extracting data from the PIH Information Center (PIC), TASS compares tenant-reported Social Security (SS) and Supplemental Security Income (SSI) to income data that HUD receives from SSA.
3. Question: Where can PHAs and HUD staff get more information on TASS and its uses?
Answer: Information on TASS and its uses can found via the Real Estate Assessment Center (REAC) website at: http://www.hud.gov/offices/reac/products/prodtass.cfm
4. Question: Can PHAs require an assisted family to sign multiple consent forms and show proof of unemployment and provide bank statements so the PHA can verify the family's financial hardship, income, and information?
Answer: Yes. In accordance with 24 CFR 960.259(a) and 24 CFR 982.551(b), the family must supply any information that the PHA or HUD determines necessary in the administration of public housing and Section 8 programs. In accordance with 24 CFR 5.230, the family must execute and submit consent forms authorizing HUD and/or PHAs to obtain the following information: wages, unemployment compensation, and unearned income (i.e. interest and dividends), necessary to verify a participant's/ applicant's household income in order to ensure and determine a household's eligibility for assisted housing benefits and that these benefits are set at the correct level.
5. Question: If any member of an assisted family household is unable to provide the PHA with a Social Security Number (SSN), what is HUD's prescribed procedure for verifying information?
Answer: As defined in 24 CFR 5.216, PHAs are required to verify a complete and accurate SSN assigned to the applicant and to each member in the applicant's or participant's household, who is at least six years of age, to determine eligibility for assisted housing benefits.
In the event an applicant or participant, who is at least six years of age, has not been assigned an SSN, the household member (or guardian, if the member is under the age of 18) must execute a certification that states the household member was not assigned an SSN.
6. Question: Does HUD require a PHA to obtain copies of government issued photo IDs, for applicants, to establish legal identity/citizenship?
Answer: No. The regulations (24 CFR 5.508) do not require this type of verification to establish legal identify/citizenship. However, pursuant to 24 CFR 5.508(b)(1), PHAs have the discretion to determine what appropriate documentation an applicant or participant is required to furnish. However, 24 CFR 5.510(b) requires a PHA to review and photocopy original INS documents to verify eligible immigration status.
7. Question: What type of documentation can a PHA use to verify a family's medical expenses?
Answer: As with any income or expense (including medical expenses), the process of verifying information supplied by an applicant or tenant family must follow the hierarchy of verification as described in Question 1 above.
That said, with increasing privacy law requirements (Health Insurance Portability and Accountability Act (HIPAA) of 1996), PHAs may have difficulty in verifying unreimbursed medical expenses. The Public Housing Occupancy Guidebook and the Housing Choice Voucher Guidebook provide sample verification forms that PHAs may use to obtain third-party verification of unreimbursed medical expenses.
In the event the health care provider does not respond to the PHAs verification request, the PHA may review tenant-provided documents, and document in the tenant file why third-party verification was not available (24 CFR 960.259 and 24 CFR 982.516). The PHA should review these documents with scrutiny to ensure that expenses are not counted twice and ineligible expenses are not counted.
8. Question: What type of verification is required in order for a PHA to consider over-the-counter medications as a medical expense for an elderly or disabled family?
Answer: The PHA's policy must state what verification and/or documentation will be required to support medical expenses (24 CFR 903.7(d)). A good standard for a PHA to use, but one that is not required, is to require the tenant to provide receipts. Please keep in mind that the PHA may not inquire about an applicant's or participant's diagnosis or details of treatment for a disability or extent or nature of disability. If the PHA receives a verification document that provides such information, the PHA should not place this information in the tenant file; it should destroy the document. If the PHA does not obtain third-party verification, in accordance with 24 CFR 960.259(c)(1) for public housing and 24 CFR 982.516(a)(2) for the Section 8 HCV program, the PHA must document why it was not available.
9. Question: If a family member claims he or she is seeking employment, what types of verification should a PHA require to determine if a family qualifies for the childcare deduction?
Answer: It may be a challenge to verify that a family member is actively seeking work, if he/she is not doing so as required under certain programs such as Welfare to Work, continued collection of unemployment compensation, or other state programs. Typically, adequate verification of a family member actively seeking work may consist of written or oral third-party verification from a local or state government agency that governs work-related activities.
In the event that third-party verification is not available, acceptable documentation may include a tenant-provided record of companies contacted, their business addresses, phone numbers, and dates on which employment was sought. And, as always, document in the family file why third-party verification was not available.
10. Question: Does excluded income have to be verified?
Answer: PHAs should obtain adequate documentation to reasonably determine the excluded amount of income. HUD requires the PHA to obtain third-party verification of reported family annual income and assets, expenses, and other factors that affect the determination of adjusted income or income-based rent (24 CFR 960.259(c) and 24 CFR 982.516(2)). Depending on the circumstances, any or all of the following may need to be verified: source of excluded income, circumstances that qualify a family member's income to be excluded, and the amount of the exclusion.
Examples:
Payments received under Title V of the Older Americans Act of
1985: Only source of income would need to be verified.
Wages of a
child under 18: The age of the child would need to be verified.
Earned
Income Disallowance or Qualifying State or Local employment training
programs: The source, individual circumstances, and amount of income would
all need to be verified.
11. Question: Is it a regulatory violation if a PHA uses its own release of information form instead of the Form HUD-9886?
Answer: As long as the form meets the minimum requirements in 24 CFR 5.230(c), it is not a violation.
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