EIV Policy for Tracking Repayment Agreements to HUD

What a burden these EIV reports are…now I got to track these repayment agreements???  How long does the tenant have to repay the amount they owe back to HUD?  What if the tenant owes a ton of money, can I just have a EIV policy which states a maximum amount in which an owner will enter into a repayment agreement?  All of these questions…it’s so overwhelming!!!!! 

As a tax payer I really appreciate the work of the O/A who through EIV is able to recover funds from improper payments.  Through the RHIIP initiative HUD has recovered over 1.9 billion in under and over payments.  But it has taken a lot of money and a lot of training.  That said, I think EIV has some room to grow.  First, I think the information is not as complete as it should be.  As of right now, EIV through SSA and the NDNH database only tracks Employment Income, Unemployment, SS and SSI benefit income.  What is missing is the income information to Welfare, Pension Income as well as Child Support payments.  I asked the lead person at HUD (at the last TRACS Industry meeting) if they were going to include that income information and I was told (a not very convincing) “Yes”.  The second part is tracking tenants who owe money back to HUD through the repayment agreements and perhaps some consequences to those who think they can walk away from their obligation to repay ill-gotten gains from their HUD subsidies.

At last TRACS 202D Industry meeting, it was suggested that properties would have to come up with a unique agreement ID# for tracking the repayment agreements.  This would need to be done in order to create an audit trail.  The debt needs to follow the tenant until their debt is repaid to HUD.  If it is not repaid to HUD in full, HUD is considering to block any and all federal financial benefits to the recipient.

This is how I envision it happening:  When a retroactive IR is processed the User is prompted by a question as to whether or not the IR is in response to improper payment of subsidy to a tenant.  If the answer is “yes” the MAT10 record is created and includes a flag as to alerting HUD that the IR needs to included in their repayment agreement tracking system database.  The vendor software should also prompt the “User” for the “agreed upon amount“ ,  the “expected payoff date“ and the “unique Agreement ID#” assigned to the repayment agreement.

At this point, there could also be an automated routine for the HAP Voucher process to include the adjustment with the offsetting manual adjustment utilizing the OARQ code.  TRACS could then keep track of these repayment agreements to assure that they are recapturing the funds that are due.

What if???  What happens if the original amount is wrong, or the agreement amount changes and there is a new balance? What if there was an incident where more information came to light and changed total?  What do you think?  What are your concerns?

To learn more about EIV, click on this link http://www.AHTCSonline.com/class_schedule.html