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What should be included in the EIV “Master File?”

Let us discuss which EIV reports should be maintained in the file. There is no doubt that HUD’s RHIIP initiative (through EIV) has done a great job to reduce over-payments and underpayments to HUD. On the other hand, a great responsibility has been added to the O/A in regard to HUD reporting. I must say, though, that the “good” definitely out-weighs the “bad.” This initiative has revealed and reduced over-payments to an estimated 1.9 billion of US tax dollars.This EIV process, as performed during the course of the processing month, has assisted with the employment and verification process. It is mandatory for O/A’s to use EIV to monitor compliance of existing residents. Every month, O/A’s are required to view certain reports periodically. Part of this monthly routine requires running several reports and retaining some of them in a separate file called the “Master File” (aside from the tenant file), which must include the following Reports:
• Identity Verification Reports – Monthly
• Deceased Tenant Report– At least quarterly and as indicated in the property’s EIV policies
• New Hires Report – At least quarterly and as indicated in the property’s EIV policies
• Multiple Occupancy Report – At least quarterly and as indicated in the property’s EIV policies

As part of the RHIIP Initiative, HUD maintains that regular review of these reports helps to reduce “assistance paid in error,” requiring O/A’s to ensure that:
1. Data recorded in TRACS is correct
2. Information provided by residents is correct
3. Residents are complying with reporting requirements
Depending on your “filing system”– whether you use binders (my preference) or regular folding files– I would strongly urge you to keep these reports organized and separate from the tenant files. Run these reports during or about the same period that you would run your HAP and make/send your TRACS files to HUD or your CA. The “Master File” also should be maintained in the same secured fashion as your tenant files. The EIV Master File must be kept for three years. Owner/agents must document the file as to when and how the EIV records were destroyed and to which records they pertained.
The intention of having the “Master File” is to demonstrate to HUD that resident compliance is being reviewed periodically. The owner/agent should make notes on the reports in the master file, while maintaining copies of notices, verification documents, new certifications, etc. in the resident files.  Take our EIV class to find out more: http://www.AHTCSonline.com/class_schedule.html

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