hi and welcome to the navigate Tuesday tip I’m Pam kowz trainer for
navigate and today we’re going to be talking about eiv discrepancies as
part of our mastering the series one of the things that we have found in
findings is that a lot of housing managers are really unsure still of
how they are supposed to be documenting discrepancies so we going to
talk a little bit about what we mean when we talk about discrepancies
and then how to resolve them so discrepancies are conflicts with the
existing file information so you’re talking about something that you
found in your existing tenant search and the multiple subsidy report or
any of the other reports that you run normally so let’s look at the
existing tenant search first your existing tenant search is going to be
run before admission so this is the one that you run on your applicants
rather than on your tenants you’re going to file this whether or not
there is a hit so if you run this through and the report says there’s no
record of that person being in subsidized housing you’re still going to
print that page and put it in the file if there is a hit if it shows
that the person that’s listed is living in subsidized housing elsewhere
then your obligation is to invest investigate that and to document what
you find the new property so your property if the person is moving in
has the responsibility to confirm eligibility that means that if you
don’t you may be losing subsidy some of the ways that you’re going to do
this are you might call the housing provider and coordinate the move in
date with them or you’re going to ask your applicant to bring in
something that confirms that they properly moved out of the old facility
and you’re going to document everything in the file on that existing
tenant search printout so when you’re looking at the existing tenant
search you can see this particular social security number was not found
anywhere else with that one there’s nothing further that I need to do
other than to document if it showed that somebody was an existing tenant
somewhere else I would have notes and documentation based on what
actions I took to verify the next report that you’re going to look at is
you’re going to look at your multiple subsidy report this is run
periodically for your existing resident again just like with the other
one you’re going to file it whether or not there’s a hit if there is a
hit you’re going to document what you did to investigate the situation
so it might be calling the facility that they’re listed at um obviously
you’re going to meet with your tenant anytime you see a discrepancy
you’re going to have them come in you’re going to talk to them about it
if I meet with my tenant my tenant says absolutely not I’m not getting
subsidy anywhere else then you’re going to go farther you’re going to
get some permission to talk to the new facility you’re going to find out
you know when did they move in what documentation do you have it could
very well be that you’re looking at a situation where somebody is
fraudulently using a social security number and then what you’re going
to want to do is help your tenant address that Social Security theft so
you’re going to help them call you’re going to help them with providing
documentation from their file with their permission and document all of
your efforts in that tenant file on that multiple subsidy report this is
what it looks like for you again here you’re seeing one where nothing
else shows if there was a tenant who was receiving subsidy elsewhere
you’re going to see all sorts of information about what that facility is
now we start getting into the identity verification reports these are
run monthly so these are your monthly identity verification reports your
obligation is to resolve any errors in your track submissions for
instance you could get one of these showing up because there was an
error in the social security number if it’s a typo you’re going to
correct it in tracks and then you’re going to submit that and you can
document the file that you have resubmitted it and that now the error is
resolved if there is some sort of problem with what social security or
another agency has on file then you’re going to assist your tenant in
contacting that agency to get things corrected and again you’re going to
document all of the efforts everything that you’ve done should be
documented in that file so this is what the identity verification
reports look like when you go in to see these summary reports you’ll see
you know you have X amount of identity verification reports you have X
am that failed identity so if you click on those links that’ll bring you
to the actual report here is an identity verification report this is
what you’re going to see if there’s a problem you click on it and then
there it will tell you that there is an issue again these are not actual
tenants these are numbers and and dates for this presentation now your
deceased tenant report is another one of those reports that people find
confusing your deceased tenant report identifies tenants that have been
reported to the Social Security Administration as deceased uh
occasionally you will find somebody who is not deceased and has been
reported as deceased and then you get the experience of being able to
tell your tenant that Social Security thinks that they are no longer an
active tenant because theyve passed away so if they’re showing as
deceased and they actually are deceased there’s no issue if they’re
showing as deceased and they are not that’s when you’re going to need to
help them contact Social Security and advise that no they are not
deceased next one we’re going to look at is the new hires report the new
hires report is going to identify any employment that has not been
reported to you if the date and the amount match the file you can just
note the report that yes we know that we did assert to correct that or
to add that in March if it is reporting something that you have not been
advised of what you’re going to want to do is meet with that tenant
document the file as needed and you may need to do a corrected
certification or an interim Certification depending on when that new
hire happened the income discrepancy report is the next one and this is
changing a little with hotma uh actually a lot with hotma so preh hotma
we run these at annual with the income report we compare the noted time
frame with the most recent 59 so this is another area that tends to be
very confusing for people the income discrepancy report looks at a
period of time which sometimes is several months back I think it’s like
18 months or so back and it’s comparing those numbers with what you’ve
reported now so in some cases there can legitimately be a significant
difference if it’s not really a discrepancy for instance yes two years
ago my tenant was working they’re not working anymore so there’s no real
discrepancy you’re just going to note that report tenant you know quit
employment on X8 or tenant lost employment on X date all income verified
is accurate your name the date if it is a true discrepancy and it’s
something you’re not aware of then you need to investigate it take
whatever action you need to to resolve it which could be an interim or a
correction you’re going to send that through tracks as needed and make
sure that that is documented on that report and in the tenant file post
hotma this report because it uses that $200 threshold and hotma changes
that so post hotma this report is going to be suspended until further
notice they’ll let you know if we’re going to be using it and how we’re
going to be using it in the future but up to hotma takes effect you
still need to be resolving these discrepancies so good documentation
what makes good documentation and what are we looking for when we’re
looking at your tenant file well they traditionally say who what why
where and when you are documenting this file in such a way so that when
the reviewer comes to your site we can take a look at that piece of
paper and know exactly what happened did you investigate it what did you
find out when you investigated it and what actions if any needed to be
taken and then you’re also going to have documentation of those actions
you want to make sure you have the name and contact information for
anyone that you spoke with how did you contact them was it an email did
you call them if it’s an email do you have a copy of the email in the
file you’re going to note any relevant information this person was
confirmed to have stopped work on X date and the signature or initials
of the staff person also make sure you know the date that you’re making
that note is there as well one of the items that can be very confusing
is what do I keep in the master File versus what do I keep in the tenant
file so a copy of your periodic reports that things that you actually
pull down from eiv must be in the master file so your monthly reports
your new hires report your deceased tenant report a copy of all of those
is in the master file if there’s an issue you want to put a copy of any
report that has the issue and your efforts to resolve in the tenant file
so resolution efforts are always going to be in that tenant file um and
then reports run at re certification are kept in the tenant file your
existing tenant search that 90day for now income report and all of your
income reports reports that you run with annuals those are all going to
be kept in the tenant file so I hope that helps you with how to document
these discrepancies and resolve them if you have any questions you can
always reach out to me or to Vicky Bell our other corporate trainer and
I hope you’ve enjoyed this Tuesday tip and we’ll see you the next time