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Chapter 7
VERIFICATION
[24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230]
INTRODUCTION
The PHA must verify all information that is used to establish the family’s eligibility and level of
assistance and is required to obtain the family’s consent to collect the information. Applicants
and program participants must cooperate with the verification process as a condition of receiving
assistance. The PHA must not pass on the cost of verification to the family.
The PHA will follow the verification guidance provided by HUD in PIH Notice 2010-19 and any
subsequent guidance issued by HUD. This chapter summarizes those requirements and provides
supplementary PHA policies.
Part I describes the general verification process. More detailed requirements related to individual
factors are provided in subsequent parts including family information (Part II), income and assets
(Part III), and mandatory deductions (Part IV).
Verification policies, rules and procedures will be modified as needed to accommodate persons
with disabilities. All information obtained through the verification process will be handled in
accordance with the records management policies of the PHA.
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PART I. GENERAL VERIFICATION REQUIREMENTS
7-I.A. FAMILY CONSENT TO RELEASE OF INFORMATION [24 CFR 982.516 AND
982.551, 24 CFR 5.230]
The family must supply any information that the PHA or HUD determines is necessary to the
administration of the program and must consent to PHA verification of that information [24 CFR
982.551].
Consent Forms
It is required that all adult applicants and participants sign form HUD-9886, Authorization for
Release of Information. The purpose of form HUD-9886 is to facilitate automated data collection
and computer matching from specific sources and provides the family's consent only for the
specific purposes listed on the form. HUD and TCHAO may collect information from State
Wage Information Collection Agencies (SWICAs) and current and former employers of adult
family members. Only HUD is authorized to collect information directly from the Internal
Revenue Service (IRS) and the Social Security Administration (SSA). Adult family members
must sign other consent forms as needed to collect information relevant to the family’s eligibility
and level of assistance.
Penalties for Failing to Consent [24 CFR 5.232]
If any family member who is required to sign a consent form fails to do so, TCHAO will deny
admission to applicants and terminate assistance of participants. The family may request an
informal review (applicants) or informal hearing (participants) in accordance with TCHAO
procedures.
7-I.B. OVERVIEW OF VERIFICATION REQUIREMENTS
HUD’s Verification Hierarchy
HUD authorizes the PHA to use six methods to verify family information and specifies the
circumstances in which each method will be used. In general HUD requires the PHA to use the
most reliable form of verification that is available and to document the reasons when the PHA
uses a lesser form of verification.
TCHAO Policy
In order of priority, the forms of verification that the TCHAO will use are:
Up-front Income Verification (UIV) using HUD's Enterprise Income Verification
(EIV) system
Up-front Income Verification (UIV) using a non-HUD system
Written Third-party Verification (may be provided by applicant or participant)
Written Third-Party Verification Form
Oral Third Party Verification
Self-Certification
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To the greatest extent possible TCHAO will try to complete the verification process
within 30 calendar days using HUD’s verification hierarchy.
Each of the verification methods is discussed in subsequent sections below.
Notice PIH 2013-03 (HA)
Due to the economic downturn, in verifying income HUD has given PHAs the option to use
either actual past income or projected future income to increase administrative flexibility (among
other things). TCHAO has adopted the following policy:
Income
Benefits from the EIV report for the past year may be used by applying the published
Cost of Living Adjustment (COLA) for fixed income elderly and disabled families whose
income is derived solely from SS, SSI, and/or SSDI.
The same amount can be used year-to-year for fixed income of elderly and disabled
families from federal, state, local, private pensions, annuities, insurance, retirement
funds, and death benefits.
TCHAO may use wages from EIV from the past year, if there is no change in jobs of
actual income (and it is not necessary to request paycheck stubs, payroll summary report,
unless the family disputes the income).
If a tenant lost his/her job, changed jobs or reduced hours, in the months after the period
covered by the EIV, TCHAO must use, at the tenant's request, the more recent income
verified by the tenant such as pay stubs, payroll summary report, unemployment benefit
notice.
TCHAO shall continue to verify income not listed in the EIV.
Assets
All assets must be documented with supportive documentation e.g., bank statement, etc.
Requirements for Acceptable Documents
TCHAO Policy
Any documents used for verification must be the original (not photocopies) and generally
must be dated within 60 calendar days of the date they are provided to TCHAO. The
documents must not be damaged, altered or in any way illegible.
Print-outs from Web pages are considered original documents.
At the appropriate time staff members who receive and/or view original documents shall
scan the document into the TCHAO tenant file. The system reflects the date, time and
name of the staff person who received/viewed the document once it has been scanned.
Any family self-certifications must be made in a format acceptable to TCHAO and must
be signed in the presence of a TCHAO representative or PHA notary public.
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File Documentation
TCHAO must document in the file how the figures used in income and rent calculations were
determined. All verification attempts, information obtained, and decisions reached during the
verification process will be recorded in the family’s file in sufficient detail to demonstrate that
TCHAO has followed all of the verification policies set forth in this plan. The record should be
sufficient to enable a staff member or HUD reviewer to understand the process followed and
conclusions reached.
TCHAO Policy
The TCHAO will document, in the family file, the following:
Reported family annual income
Value of assets
Expenses related to deductions from annual income
Other factors influencing the adjusted income or income-based rent determination
When the PHA is unable to obtain 3rd party verification, the PHA will document in the family
file the reason that third-party verification was not available (24 CFR 960.259(c)(1); Notice PIH
2010-19).
7-I.C. UP-FRONT INCOME VERIFICATION (UIV)
Up-front Income Verification (UIV) refers to the PHA’s use of the verification tools available
from independent sources that maintain computerized information about earnings and benefits.
UIV will be used to the extent that these systems are available to the PHA.
There may be legitimate differences between the information provided by the family and UIV-
generated information. If the family disputes the accuracy of UIV data, no adverse action can be
taken until the PHA has independently verified the UIV information and the family has been
granted an opportunity to contest any adverse findings through the informal review/hearing
process of the PHA.
See Chapter 6 for the TCHAO policy on the use of UIV/EIV to project annual income.
UIV tools used by the PHA
TCHAO Policy
The following lists the UIV tools used by TCHAO during and/or after mandatory re-
examinations of household income: 1) The Child Support Interactive website allows a
client to use the TCHAO internet during the interview, using their Case Identification
Number and SSN to obtain EIV for TCHAO. The Work Number, Advanced HR
Solutions, TASS, Social Security Death Index and EIV Wage and Benefit Report.
There may be legitimate differences between the information provided by the family and EIV
generated information. No adverse action can be taken against a family until the PHA has
independently verified the EIV information and the family has been granted an opportunity to
contest any adverse findings through the informal review/hearing process of the PHA.
See Chapter 6 for the TCHAO's policy on the use of EIV to project annual income.
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Upfront Income Verification Using HUD’s Enterprise Income Verification (EIV) System
(Mandatory)
HUD’s EIV system contains data showing earned income, unemployment benefits, Social
Security benefits and SSI benefits for participant families. HUD requires the PHA to use the EIV
system in its entirety. The following policies apply to the use of HUD’s EIV system.
EIV Income Reports
The data shown on income reports is updated quarterly. Data may be between 3 and 6 months
old at the time reports are generated.
TCHAO Policy
The TCHAO will obtain EIV income reports within 90 days of each new admission, if
available.
The TCHAO will obtain income reports for annual reexaminations on a monthly basis.
Reports will be generated as part of the regular reexamination process.
Income reports will be compared to family-provided information as part of the annual
reexamination process. Income reports may be used in the calculation of annual income,
as described in Chapter 6.I.C. Income reports may also be used to meet the regulatory
requirement for third party verification, as described above. Policies for resolving
discrepancies between income reports and family-provided information will be resolved
as described in Chapter 6.I.C. and in this chapter.
Income reports will be used in interim reexaminations to identify any discrepancies
between reported income and income shown in the EIV system, and as necessary to
verify and calculate earned income, unemployment benefits, Social Security and/or SSI
benefits. EIV will also be used to verify that families claiming zero income are not
receiving income from any of these sources.
Income reports will be retained in participant files with the applicable annual or interim
reexamination documents.
When the TCHAO determines through income reports and third party verification that a
family has concealed or under-reported income, corrective action will be taken pursuant
to the policies in Chapter 14, Program Integrity.
EIV Discrepancy Reports
The EIV discrepancy report is a tool for identifying families who may have concealed or under-
reported income. Data in the discrepancy report represents income for past reporting periods and
may be between 6 months and 30 months old at the time reports are generated.
Families who have not concealed or under-reported income may appear on the discrepancy
report in some circumstances, such as loss of a job or addition of new family members.
Income discrepancies may be identified through use of the EIV “Income Discrepancy Report” or
by review of the discrepancy tab for the individual family.
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TCHAO Policy
The TCHAO will generate the Income Discrepancy Report at annual recertification.
The TCHAO will review the EIV discrepancy tab during processing of annual and
interim reexaminations.
When it appears that a family may have concealed or under-reported income, the
TCHAO will request third-party written verification of the income in question.
When the TCHAO determines through file review and third party verification that a
family has concealed or under-reported income, corrective action will be taken pursuant
to the policies in Chapter 14, Program Integrity.
EIV Identity Verification
The EIV system verifies tenant identities against SSA records. These records are compared to
PIC data for a match on Social Security number, name, and date of birth.
PHAs are required to use EIV's Identity Verification Report on a monthly basis to improve the
availability of income information in EIV (Notice PIH 2010-3).
When identity verification for a participant fails, a message will be displayed within the EIV
system and no income information will be displayed.
TCHAO Policy
The TCHAO will identify participants whose identity verification has failed by reviewing
EIV's Identity Verification Report on a monthly basis.
The TCHAO will attempt to resolve PIC/SSA discrepancies by obtaining appropriate
documentation from the participant. When the TCHAO determines that discrepancies
exist due to TCHAO errors such as spelling errors or incorrect birth dates, the errors will
be corrected promptly.
Upfront Income Verification Using Non-HUD Systems (Optional)
In addition to mandatory use of the EIV system, HUD encourages PHAs to utilize other upfront
verification sources.
PHA Policy
The PHA will inform all applicants and participants of its use of the following UIV
resources during the admission and reexamination process:
HUD’s EIV system
7-I.D. THIRD-PARTY WRITTEN AND ORAL VERIFICATION
HUD’s current verification hierarchy defines two types of written third-party verification. The
more preferable form, “written third-party verification,” consists of an original document
generated by a third-party source, which may be received directly from a third-party source or
provided to the PHA by the family. If written third-party verification is not available, the PHA
must attempt to obtain a “written third-party verification form.” This is a standardized form used
to collect information from a third party.
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Written Third-Party Verification [Notice PIH 2010-19]
Written third-party verification documents must be original and authentic and may be supplied
by the family or received from a third-party source.
Examples of acceptable tenant-provided documents include, but are not limited to: pay stubs,
payroll summary reports, employer notice or letters of hire and termination, SSA benefit
verification letters, bank statements, child support payment stubs, welfare benefit letters and/or
printouts, and unemployment monetary benefit notices.
The PHA is required to obtain, at minimum, two current and consecutive pay stubs for
determining annual income from wages.
The PHA may reject documentation provided by the family if the document is not an original, if
the document appears to be forged, or if the document is altered, mutilated, or illegible.
PHA Policy
Third-party documents provided by the family must be dated within 60 days of the PHA
request date.
If the PHA determines that third-party documents provided by the family are not
acceptable, the PHA will explain the reason to the family and request additional
documentation.
As verification of earned income, the PHA will request pay stubs covering the 60-day
period prior to the PHA’s request.
Written Third-Party Verification Form
When upfront verification is not available and the family is unable to provide written third-party
documents, the PHA must request a written third-party verification form. HUD’s position is that
this traditional third-party verification method presents administrative burdens and risks which
may be reduced through the use of family-provided third-party documents.
A written third-party verification form is mandatory when there is an unreported source of
income or a substantial difference in reported income ($2400 annually or more) and there is no
UIV or tenant-provided documentation to support the income discrepancy.
PHAs may mail, fax, or e-mail third-party written verification form requests to third-party
sources.
PHA Policy
The PHA will send third-party verification forms directly to the third party.
Third-party verification forms will be sent when third-party verification documents are
unavailable or are rejected by the PHA.
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Oral Third-Party Verification [Notice PIH 2010-19]
For third-party oral verification, PHAs contact sources, identified by UIV techniques or by the
family, by telephone or in person.
Oral third-party verification is mandatory if neither form of written third-party verification is
available.
Third-party oral verification may be used when requests for written third-party verification forms
have not been returned within a reasonable time—e.g., 10 calendar days.
PHAs should document in the file the date and time of the telephone call or visit, the name of the
person contacted, the telephone number, as well as the information confirmed.
PHA Policy
In collecting third-party oral verification, PHA staff will record in the family’s file the
name and title of the person contacted, the date and time of the conversation (or attempt),
the telephone number used, and the facts provided.
When any source responds verbally to the initial written request for verification the PHA
will accept the verbal response as oral verification but will also request that the source
complete and return any verification forms that were provided.
When Third-Party Verification is Not Required [Notice PIH 2010-19]
Third-party verification may not be available in all situations. HUD has acknowledged that it
may not be cost-effective or reasonable to obtain third-party verification of income, assets, or
expenses when these items would have a minimal impact on the family’s total tenant payment.
PHA Policy
If the family cannot provide original documents, the PHA will pay the service charge
required to obtain third-party verification, unless it is not cost effective in which case a
self-certification will be acceptable as the only means of verification. The cost of
verification will not be passed on to the family.
The cost of postage and envelopes to obtain third-party verification of income, assets, and
expenses is not an unreasonable cost [VG, p. 18].
Primary Documents
Third-party verification is not required when legal documents are the primary source, such as a
birth certificate or other legal documentation of birth.
Imputed Assets
HUD permits PHAs to accept a self-certification from a family as verification of assets disposed
of for less than fair market value [HCV GB, p. 5-28].
PHA Policy
The PHA will accept a self-certification from a family as verification of assets disposed
of for less than fair market value.
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7-I.E. SELF-CERTIFICATION
Self-certification, or "tenant declaration," of income is used as a last resort when the PHA is
unable to obtain third-party verification.
When the PHA relies on a tenant declaration for verification of income, assets, or expenses, the
family's file must be documented to explain why third-party verification was not available.
TCHAO Policy
When information cannot be verified by a third party or by review of documents, family
members will be required to submit self-certifications attesting to the accuracy of the
information they have provided to the TCHAO.
The PHA may require a family to certify that a family member does not receive a
particular type of income or benefit.
The self-certification must be made in a format acceptable to the PHA and must be
signed by the family member whose information or status is being verified. All self-
certifications must be signed in the presence of a PHA representative or PHA notary
public.
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PART II. VERIFYING FAMILY INFORMATION
7-II.A. VERIFICATION OF LEGAL IDENTITY
TCHAO Policy
The TCHAO will require families to furnish verification of legal identity for each
household member.
Verification of Legal Identity for Adults
Verification of Legal Identity for
Children
Certificate of birth, naturalization papers
Church issued baptismal certificate
Current, valid driver's license or
Department of Motor Vehicles
identification card
U.S. military discharge (DD 214)
U.S. passport
Employer identification card
Certificate of birth
Adoption papers
Custody agreement
Health and Human Services ID
School records
If a document submitted by a family is illegible or otherwise questionable, more than one
of these documents may be required.
If none of these documents can be provided and at the PHA’s discretion, a third party
who knows the person may attest to the person’s identity. The certification must be
provided in a format acceptable to the PHA and be signed in the presence of a PHA
representative or PHA notary public.
Legal identity will be verified on an as needed basis.
7-II.B. SOCIAL SECURITY NUMBERS [24 CFR 5.216 and Notice PIH 2010-3]
The family must provide documentation of a valid social security number (SSN) for each
member of the household, with the exception of individuals who do not contend eligible
immigration status. Exemptions also include, existing program participants who were at least 62
years of age as of January 31, 2010, and had not previously disclosed an SSN.
The PHA must accept the following documentation as acceptable evidence of the social security
number:
An original SSN card issued by the Social Security Administration (SSA);
An original SSA-issued document, which contains the name and SSN of the individual;
An original document issued by a federal, state, or local government agency, which
contains the name and SSN of the individual, along with other identifying information of
the individual;
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Such other evidence of the SSN as HUD may prescribe in administrative instructions.
The PHA may only reject documentation of an SSN provided by an applicant or participant if the
document is not an original document, if the original document has been altered, mutilated, or is
not legible, or if the document appears to be forged.
PHA Policy
The PHA will explain to the applicant or participant the reasons the document is not
acceptable and request that the individual obtain and submit acceptable documentation of
the SSN to the PHA within 90 days.
If a family member has a legal name change due to marriage, divorce, court order or any
other reason, the family member must notify TCHAO within ten (10) calendar days. The
family member has a maximum of sixty (90) days to present to TCHAO a new social
security card showing the new name.
TCHAO, in its discretion, may grant an extension however, failure to provide a new
social security card, within the stated timeframe, without an extension, could result in
termination of assistance.
In the case of Moderate Rehabilitation Single Room Occupancy (SRO) individuals, the required
documentation must be provided within 90 calendar days from the date of admission into the
program. The PHA must grant one additional 90-day extension if it determines that the
applicant’s failure to comply was due to circumstances that were beyond the applicant’s control
and could not have been reasonably foreseen.
PHA Policy
The PHA will grant one additional 90-day extension if needed for reasons beyond the
participant’s control such as delayed processing of the SSN application by the SSA,
natural disaster, fire, death in the family, or other emergency. If the individual fails to
comply with SSN disclosure and documentation requirements upon expiration of the
provided time period, the PHA will terminate the individual’s assistance.
When the participant requests to add a new household member who is at least 6 years of age, or
who is under the age of 6 and has an SSN, the participant must provide the complete and
accurate SSN assigned to each new member at the time of reexamination or recertification, in
addition to the documentation required to verify it. The PHA may not add the new household
member until such documentation is provided.
When a participant requests to add a new household member who is under the age of 6 and has
not been assigned an SSN, the participant must provide the SSN assigned to each new child and
the required documentation within 90 calendar days of the child being added to the household. A
90-day extension will be granted if the PHA determines that the participant’s failure to comply
was due to unforeseen circumstances and was outside of the participant’s control. During the
period the PHA is awaiting documentation of the SSN, the child will be counted as part of the
assisted household.
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PHA Policy
The PHA will grant one additional 90-day extension if needed for reasons beyond the
participant’s control such as delayed processing of the SSN application by the SSA,
natural disaster, fire, death in the family, or other emergency.
Social security numbers must be verified only once during continuously-assisted occupancy.
PHA Policy
The PHA will verify each disclosed SSN by:
Obtaining documentation from applicants and participants that is acceptable as evidence
of social security numbers
Making a copy and scanning the original documentation submitted, returning it to the
individual, and retaining a copy in the data base/file folder
Once the individual’s verification status is classified as “verified,” the PHA should remove
and destroy copies of documentation accepted as evidence of social security numbers by no
later than the next reexamination.
PHA Policy
Once an individual’s status is classified as “verified” in HUD’s EIV system, the PHA
will remove and destroy copies of documentation accepted as evidence of social security
numbers by no later than the next reexamination.
7-II.C. DOCUMENTATION OF AGE
A birth certificate or other official record of birth is the preferred form of age verification for all
family members. For elderly family members an original document that provides evidence of the
receipt of social security retirement benefits is acceptable.
TCHAO Policy
If an official record of birth or evidence of social security retirement benefits cannot be
provided, the TCHAO will require the family to submit other documents that support the
reported age of the family member (e.g., school records, birth year is recorded).
Age must be verified only once during continuously-assisted occupancy.
7-II.D. FAMILY RELATIONSHIPS
Applicants and program participants are required to identify the relationship of each household
member to the head of household. Definitions of the primary household relationships are
provided in the Eligibility chapter.
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TCHAO Policy
Family relationships are verified only to the extent necessary to determine a family’s
eligibility and level of assistance. Certification by the head of household normally is
sufficient verification of family relationships.
Marriage
TCHAO Policy
Certification by the head of household is normally sufficient verification. If the PHA has
reasonable doubts about a marital relationship, the PHA will require the family to
document the marriage.
A marriage certificate generally is required to verify that a couple is married.
In the case of a common law marriage, the couple must demonstrate that they hold
themselves to be married (e.g., by telling the community they are married, calling each
other husband and wife, using the same last name, filing joint income tax returns).
Separation or Divorce
TCHAO Policy
Certification by the head of household is normally sufficient verification, If the PHA has
reasonable doubts about a separation or divorce, the
TCHAO will require the family to document divorce, or separation.
A certified copy of a divorce decree, signed by a court officer, is required to document
that a couple is divorced.
Court-ordered maintenance or other court records are required to document a legal
separation.
If no court documents are available, documentation from a community-based agency will
be accepted.
Absence of Adult Member
TCHAO Policy
If an adult member who was formerly a member of the household is reported to be
permanently absent, the family must provide evidence to support that the person is no
longer a member of the family (e.g., documentation of another address at which the
person resides such as a lease or utility bill).
Foster Children and Foster Adults
TCHAO Policy
Third-party verification from the state or local government agency responsible for the
placement of the individual with the family is required.
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7-II.E. VERIFICATION OF STUDENT STATUS
General Requirements
TCHAO Policy
TCHAO requires families to provide information about the student status of all
individuals who are 18 years of age or older. This information will be verified only if:
The family reports full-time student status for an adult other than the head, spouse,
or co-head,
The family reports child care expenses to enable a family member to further his or her
education.
The family includes a student enrolled in an institution of higher education.
Restrictions on Assistance to Students Enrolled in Institutions of Higher Education
This section applies only to students who are seeking assistance on their own, separately from
their parents. It does not apply to students residing with parents who are seeking or receiving
HCV assistance.
PHA Policy
In accordance with the verification hierarchy described in Section 7-1.B, the PHA will
determine whether the student is exempt from the restrictions in 24 CFR 5.612 by
verifying any one of the following exemption criteria:
The student is enrolled at an educational institution that does not meet the
definition of institution of higher education in the Higher Education Act of 1965
(see Section Exhibit 3-2).
The student is at least 24 years old.
The student is a veteran, as defined in Section 3-II.E.
The student is married.
The student has at least one dependent child, as defined in Section 3-II.E.
The student is a person with disabilities, as defined in Section 3-II.E, and was
receiving assistance prior to November 30, 2005.
If the PHA cannot verify at least one of these exemption criteria, the PHA will conclude
that the student is subject to the restrictions on assistance at 24 CFR 5.612. In addition to
verifying the student’s income eligibility, the PHA will then proceed to verify either the
student’s parents’ income eligibility (see Section 7-III.J) or the student’s independence
from his/her parents (see below).
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Independent Student
PHA Policy
The PHA will verify a student’s independence from his/her parents to determine that the
student’s parents’ income is not relevant for determining the student’s eligibility by doing
all of the following:
Both review and verify previous address information to determine whether the
student has established a household separate from his/her parents for at least one
year or reviewing and verifying documentation relevant to determining whether
the student meets the U.S. Department of Education’s definition of independent
student (see Section 3-II.E)
Reviewing prior year income tax returns to verify whether a parent has claimed
the student as a dependent
Requesting and obtaining written certification directly from the student’s parents
identifying the amount of support they will be providing to the student, even if the
amount of support is $0.
7-II.F. DOCUMENTATION OF DISABILITY
The PHA must verify the existence of a disability in order to allow certain income disallowances
and deductions from income. The PHA is not permitted to inquire about the nature or extent of a
person’s disability [24 CFR 100.202(c)]. The PHA may not inquire about a person’s diagnosis or
details of treatment for a disability or medical condition. If the PHA receives a verification
document that provides such information, the PHA will not place this information in the tenant
file. Under no circumstances will the PHA request a participant’s medical record(s). For more
information on health care privacy laws, see the Department of Health and Human Services’
website at www.os.dhhs.gov.
The above cited regulation does not prohibit the following inquiries, provided these inquiries are
made of all applicants, whether or not they are persons with disabilities [VG, p. 24]:
Inquiry into an applicant’s ability to meet the requirements of ownership or tenancy
Inquiry to determine whether an applicant is qualified for a dwelling available only to
persons with disabilities or to persons with a particular type of disability
Inquiry to determine whether an applicant for a dwelling is qualified for a priority available
to persons with disabilities or to persons with a particular type of disability
Inquiring whether an applicant for a dwelling is a current illegal abuser or addict of a
controlled substance
Inquiring whether an applicant has been convicted of the illegal manufacture or distribution
of a controlled substance
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Family Members Receiving SSA Disability Benefits
Verification of the receipt of disability benefits from the Social Security Administration (SSA) is
sufficient verification of disability for the purpose of qualifying for waiting list preferences (if
applicable) or certain income disallowances and deductions (VG, p.23).
TCHAO Policy
For family members claiming disability who receive disability benefits from the SSA, the
TCHAO will attempt to obtain information about disability benefits through the HUD
Enterprise Income Verification (EIV) system. If documentation from HUD's EIV System
is not available, the TCHAO will request a current (dated within the last 60 days) SSA
benefit verification letter from each family member claiming disability status. If the
family is unable to provide the document(s), the TCHAO will ask the family to request a
benefit verification letter by either calling SSA at 1-800-772-1213, or by requesting it
from www.ssa.gov. Once the applicant or participant receives the benefit verification
letter they will be required to provide it to the PHA.
Family Members Not Receiving SSA Disability Benefits
Receipt of veteran’s disability benefits, worker’s compensation, or other non-SSA benefits based
on the individual’s claimed disability are not sufficient verification that the individual meets
HUD’s definition of disability in 24 CFR 5.603.
TCHAO Policy
For family members claiming disability who do not receive disability benefits from the
SSA, the TCHAO will attempt to obtain information about disability benefits through the
HUD Enterprise Income Verification (EIV) system or HUD's Tenant Assessment
Subsystem (TASS). If documentation from HUD's EIV system or TASS is not available,
the TCHAO will request a current (dated within the last 60 days) SSA benefit verification
letter from each family member claiming disability status. If the family is unable to
provide the document(s), the TCHAO will ask the family to request a benefit verification
letter by either calling SSA at 1-800-772-1213, or by requesting it from www.ssa.gov.
Once the applicant or participant receives the benefit verification letter they will be
required to provide it to the TCHAO.
7-II.G. CITIZENSHIP OR ELIGIBLE IMMIGRATION STATUS [24 CFR 5.508]
Overview
Housing assistance is not available to persons who are not citizens, nationals, or eligible
immigrants. Prorated assistance is provided for "mixed families" containing both eligible and
ineligible persons. A detailed discussion of eligibility requirements is in the Eligibility chapter.
This verifications chapter discusses HUD and PHA verification requirements related to
citizenship status.
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The family must provide a certification that identifies each family member as a U.S. citizen, a
U.S. national, an eligible noncitizen or an ineligible noncitizen and submit the documents
discussed below for each family member. Once eligibility to receive assistance has been verified
for an individual it need not be collected or verified again during continuously-assisted
occupancy [24 CFR 5.508(g)(5)]
U.S. Citizens and Nationals
HUD requires a declaration for each family member who claims to be a U.S. citizen or national.
The declaration must be signed personally by any family member 18 or older and by a guardian
for minors.
The PHA may request verification of the declaration by requiring presentation of a birth
certificate, United States passport or other appropriate documentation.
TCHAO Policy
Family members who claim U.S. citizenship or national status will not be required to
provide additional documentation unless the TCHAO receives information indicating that
an individual’s declaration may not be accurate.
Eligible Immigrants
Documents Required
All family members claiming eligible immigration status must declare their status in the same
manner as U.S. citizens and nationals.
The documentation required for eligible noncitizens varies depending upon factors such as the
date the person entered the U.S., the conditions under which eligible immigration status has been
granted, age, and the date on which the family began receiving HUD-funded assistance. Exhibit
7-2 at the end of this chapter summarizes documents family members must provide.
PHA Verification [HCV GB, pp. 5-3 and 5-7]
For family members age 62 or older who claim to be eligible immigrants, proof of age is
required in the manner described in 7-II.C. of this plan. No further verification of eligible
immigration status is required.
For family members under the age of 62 who claim to be eligible immigrants, the PHA must
verify immigration status with the United States Citizenship and Immigration Services (USCIS).
The PHA will follow all USCIS protocols for verification of eligible immigration status.
7-II.H. VERIFICATION OF PREFERENCE STATUS
The PHA must verify any preferences claimed by an applicant.
PHA Policy
The TCHAO will offer a preference to any family that has been terminated from its
HCV program due to insufficient program funding. The PHA will verify this preference
using the PHA's termination records.
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PART III. VERIFYING INCOME AND ASSETS
Chapter 6, Part I of this plan describes in detail the types of income that are included and
excluded and how assets and income from assets are handled. Any assets and income reported by
the family must be verified. This part provides PHA policies that supplement the general
verification procedures specified in Part I of this chapter.
7-III.A. EARNED INCOME
Tips
TCHAO Policy
Unless tip income is included in a family member’s W-2 by the employer, persons who
work in industries where tips are standard will be required to sign a certified estimate of
tips received for the prior year and tips anticipated to be received in the coming year.
7-III.B. BUSINESS AND SELF EMPLOYMENT INCOME
TCHAO Policy
Business owners and self-employed persons will be required to provide:
An audited financial statement for the previous fiscal year if an audit was conducted.
If an audit was not conducted, a statement of income and expenses must be submitted
and the business owner or self-employed person must certify to its accuracy.
All schedules completed for filing federal and local taxes in the preceding year.
If accelerated depreciation was used on the tax return or financial statement, an
accountant's calculation of depreciation expense, computed using straight-line
depreciation rules.
TCHAO will provide a format for any person who is unable to provide such a statement
to record income and expenses for the coming year. The business owner/self-employed
person will be required to submit the information requested and to certify to its accuracy
at all future reexaminations.
At any reexamination TCHAO may request documents that support submitted financial
statements such as manifests, appointment books, cash books, or bank statements.
If a family member has been self-employed less than three (3) months, TCHAO will
accept the family member's certified estimate of income and schedule an interim
reexamination in three (3) months. If the family member has been self-employed for three
(3) to twelve (12) months TCHAO will require the family to provide documentation of
income and expenses for this period and use that information to project income.
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7-III.C. PERIODIC PAYMENTS AND PAYMENTS IN LIEU OF EARNINGS
Social Security/SSI Benefits
TCHAO Policy
To verify the SS/SSI benefits of applicants, TCHAO will request a current (dated within
the last 60 days) SSA benefit award letter from each family member that receives social
security benefits. If the family is unable to provide the document(s), TCHAO will help
the applicant request a benefit verification letter from SSA's Web site at
www.socialsecurity.gov or ask the family to request one by calling SSA at 1-800-772-
1213. Once the applicant has received the benefit verification letter they will be required
to provide it to TCHAO.
To verify the SS/SSI benefits of participants, TCHAO will obtain information about
social security/SSI benefits through the HUD EIV System and confirm with the
participant(s) that the current listed benefit amount is correct. If the participant disputes
the EIV-reported benefit amount, or if benefit information is not available in HUD
systems, TCHAO will request a current SSA benefit verification letter from each family
member that receives social security benefits. If the family is unable to provide the
document(s) TCHAO will help the participant request a benefit verification letter from
SSA's Web site at www.socialsecurity.gov or ask the family to request one by calling
SSA at 1-800-772-1213, Once the participant has received the benefit verification letter
they will be required to provide it to TCHAO.
7-III.D. ALIMONY OR CHILD SUPPORT
TCHAO Policy
The way the TCHAO will seek verification for alimony and child support differs
depending on whether the family declares that it receives regular payments.
If the family declares that it receives regular payments, verification will be
sought in the following order:
Copy of the last six (6) payment stubs or receipts;
Third Party verification form from the state or local child support enforcement
agency;
Third-party verification form from the person paying the support;
Family's self-certification of amount received and of the likelihood of support
payments being received in the future, or that support payments are not being
received.
If the family declares that it receives irregular or no payments, in addition to the
verification process listed above, the family will be asked to provide evidence that it has
taken all reasonable efforts to collect amounts due. This may include:
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A statement from any agency responsible for enforcing payment that shows
the family has requested enforcement and is cooperating with all enforcement
efforts.
If the family has made independent efforts at collection, a written statement is
required from the attorney or other collection entity that has assisted the
family in these efforts.
Note: Families are not required to undertake independent enforcement action.
7-III.E. ASSETS AND INCOME FROM ASSETS
Assets Disposed of for Less than Fair Market Value
The family must certify whether any assets have been disposed of for less than fair market value
in the preceding two years. The PHA needs to verify only those certifications that warrant
documentation [HCV GB, p. 5-28].
TCHAO Policy
The PHA will verify the value of assets disposed of only if:
The PHA does not already have a reasonable estimation of its value from
previously collected information, or
The amount reported by the family in the certification appears obviously in error.
Example 1: An elderly participant reported a $10,000 certificate of deposit at the last
annual reexamination and TCHAO verified this amount. Now the person reports that she
has given this $10,000 to her son. TCHAO has a reasonable estimate of the value of the
asset; therefore, reverification of the value of the asset is not necessary.
Example 2: A family member has disposed of its 1/4 share of real property located in a
desirable area and has valued her share at approximately 5,000. Based upon market
conditions, this declaration does not seem realistic. Therefore, TCHAO will verify the
value of this asset.
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7-III.F. NET INCOME FROM RENTAL PROPERTY
TCHAO Policy
The family must provide:
A current executed lease for the property that shows the rental amount or certification
from the current tenant.
A self-certification from the family members engaged in the rental of property
providing an estimate of expenses for the coming year and the most recent IRS Form
1040 with Schedule E (Rental Income). If schedule E was not prepared, the PHA will
require the family members involved in the rental of property to provide a self-
certification of income and expenses for the previous year and may request
documentation to support the statement including: tax statements, insurance invoices,
bills for reasonable maintenance and utilities, and bank statements or amortization
schedules showing monthly interest expense.
7-III.G. RETIREMENT ACCOUNTS
TCHAO Policy
The PHA will accept written third-party documents supplied by the family as evidence of
the status of retirement accounts.
The type of original documents that will be accepted depends upon the family member's
retirement status.
Before retirement, TCHAO will accept an original document from the entity
holding the account with a date that shows it is the most recently scheduled
statement for the account but in no case earlier than 6 months from the effective
date of the examination.
Upon retirement, TCHAO will accept an original document from the entity
holding the account that reflects any distributions of the account balance, any
lump sums taken and any regular payments.
After retirement, TCHAO will accept an original document from the entity
holding the account dated no earlier than 12 months before that reflects any
distributions of the account balance, any lump sums taken and any regular
payments.
7-III.H. INCOME FROM EXCLUDED SOURCES
A detailed discussion of excluded income is provided in Chapter 6, Part I.
The PHA must obtain verification for income exclusions only if, without verification, the PHA
would not be able to determine whether the income is to be excluded. For example: If a family’s
16 year old has a job at a fast food restaurant, the PHA will confirm that PHA records verify the
child’s age but will not send a verification request to the restaurant. However, if a family claims
the earned income disallowance for a source of income, both the source and the income must be
verified.
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TCHAO Policy
TCHAO will reconcile differences in amounts reported by the third party and the family
only when the excluded amount is used to calculate the family share (as is the case with
the earned income disallowance). In all other cases TCHAO will report the amount to be
excluded as indicated on documents provided by the family.
7-III.I. ZERO ANNUAL INCOME STATUS
TCHAO Policy
The TCHAO will check UIV sources and/or request information for third-party sources
to verify that certain forms of income such as unemployment benefits, TANF, SSI, etc.
are not being received by families claiming to have zero annual income.
7-III.J. STUDENT FINANCIAL ASSISTANCE
Any financial assistance, in excess of amounts received for tuition, that a person attending an
institution of higher education receives under the Higher Education Act of 1965, from private
sources, or from an institution of higher education must be considered income unless the student
is over the age of 23 with dependent children or is residing with parents who are seeking or
receiving HCV assistance [24 CFR 5.609(b)(9) and FR 4/10/06].
For students over the age of 23 with dependent children or students residing with parents who are
seeking or receiving HCV assistance, the full amount of student financial assistance is excluded
from annual income [24 CFR 5.609(c)(6)]. The full amount of student financial assistance is also
excluded for students attending schools that do not qualify as institutions of higher education (as
defined in Exhibit 3-2). Excluded amounts are verified only if, without verification, the PHA
would not be able to determine whether or to what extent the income is to be excluded (see
Section 7-III.H).
PHA Policy
For a student subject to having a portion of his/her student financial assistance included
in annual income in accordance with 24 CFR 5.609(b)(9), the PHA will request third-
party written verification of both the source and the amount. Family-provided documents
from the educational institution attended by the student will be requested, as well as
documents generated by any other person or entity providing such assistance, as reported
by the student.
In addition, the PHA will request written verification of the student’s tuition amount.
If the PHA is unable to obtain third-party written verification of the requested
information, the PHA will pursue other forms of verification following the verification
hierarchy in Section 7-I.B.
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7-III.K. PARENTAL INCOME OF STUDENTS SUBJECT TO ELIGIBILITY
RESTRICTIONS
If a student enrolled at an institution of higher education is under the age of 24, is not a veteran,
is not married, and does not have a dependent child, the income of the student’s parents must be
considered when determining income eligibility, unless the student is determined independent
from his or her parents in accordance with PHA policy [24 CFR 5.612 and FR 4/10/06,
p. 18146].
This provision does not apply to students residing with parents who are seeking or receiving
HCV assistance. It is limited to students who are seeking or receiving assistance on their own,
separately from their parents.
PHA Policy
If the PHA is required to determine the income eligibility of a student’s parents, the PHA
will request an income declaration and certification of income from the appropriate
parent(s) (as determined in Section 3-II.E). The PHA will send the request directly to the
parents, who will be required to certify to their income under penalty of perjury. The
parents will be required to submit the information directly to the PHA. The required
information must be submitted (postmarked) within 10 calendar days of the date of the
PHA’s request or within any extended timeframe approved by the PHA.
The PHA reserves the right to request and review supporting documentation at any time
if it questions the declaration or certification. Supporting documentation may include, but
is not limited to, Internal Revenue Service (IRS) tax returns, consecutive and original pay
stubs, bank statements, pension benefit statements, benefit award letters, and other
official and authentic documents from a federal, state, or local agency.
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PART IV. VERIFYING MANDATORY DEDUCTIONS
7-IV.A. DEPENDENT AND ELDERLY/DISABLED HOUSEHOLD DEDUCTIONS
The dependent and elderly/disabled family deductions require only that the PHA verify that the
family members identified as dependents or elderly/disabled persons meet the statutory
definitions. No further verifications are required.
Dependent Deduction
See Chapter 6 (6-II.B.) for a full discussion of this deduction. The PHA will verify that:
Any person under the age of 18 for whom the dependent deduction is claimed is not the head,
spouse, or cohead of the family and is not a foster child
Any person age 18 or older for whom the dependent deduction is claimed is not a foster adult
or live-in aide, and is a person with a disability or a full time student
Elderly/Disabled Family Deduction
See Eligibility chapter for a definition of elderly and disabled families and Chapter 6 (6-II.C.) for
a discussion of the deduction. The PHA will verify that the head, spouse, or cohead is 62 years of
age or older or a person with disabilities.
7-IV.B. MEDICAL EXPENSE DEDUCTION
Policies related to medical expenses are found in 6-II.D. The amount of the deduction will be
verified following the standard verification procedures described in Part I.
Amount of Expense
TCHAO Policy
Medical expenses will be verified through:
Written third-party documents provided by the family, such as pharmacy printouts
or receipts.
The TCHAO will make a best effort to determine what expenses from the past are
likely to continue to occur in the future. The TCHAO will also accept evidence of
monthly payments or total payments that will be due for medical expenses during
the upcoming 12 months.
Written third-party verification forms, if the family is unable to provide
acceptable documentation.
If third-party or document review is not possible, written family certification as to
costs anticipated to be incurred during the upcoming 12 months.
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In addition, the TCHAO must verify that:
The household is eligible for the deduction.
The costs to be deducted are qualified medical expenses.
The expenses are not paid for or reimbursed by any other source.
Costs incurred in past years are counted only once.
Eligible Household
The medical expense deduction is permitted only for households in which the head, spouse, or
cohead is at least 62, or a person with disabilities. The PHA will verify that the family meets the
definition of an elderly or disabled family provided in the Eligibility chapter and as described in
Chapter 7 (7-IV.A.) of this plan.
Qualified Expenses
To be eligible for the medical expenses deduction, the costs must qualify as medical expenses.
See Chapter 6 (6-II.D.) for the PHA’s policy on what counts as a medical expense.
Unreimbursed Expenses
To be eligible for the medical expenses deduction, the costs must not be reimbursed by another
source.
TCHAO Policy
The family will be required to certify that the medical expenses are not paid or
reimbursed to the family from any source.
Expenses Incurred in Past Years
TCHAO Policy
When anticipated costs are related to on-going payment of medical bills incurred in past
years, TCHAO will verify:
The anticipated repayment schedule
The amounts paid in the past, and
Whether the amounts to be repaid have been deducted from the family’s
annual income in past years
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7-IV.C. DISABILITY ASSISTANCE EXPENSES
Policies related to disability assistance expenses are found in 6-II.E. The amount of the deduction
will be verified following the standard verification procedures described in Part I.
Amount of Expense
Attendant Care
TCHAO Policy
The PHA will accept written third-party documents provided by the family.
If family-provided documents are not available, TCHAO will provide a third-party
verification form directly to the care provider requesting the needed information.
Expenses for attendant care will be verified through:
Written third-party documents provided by the family, such as receipts or
cancelled checks.
Third-party verification form signed by the provider, if family-provided
documents are not available.
If third-party verification is not possible, written family certification as to costs
anticipated to be incurred for the upcoming 12 months
Auxiliary Apparatus
TCHAO Policy
Expenses for auxiliary apparatus will be verified through:
Written third-party documents provided by the family,
Billing statements for the purchase of auxiliary apparatus, or other evidence of
monthly payments or total payments that will be due for the apparatus during the
upcoming 12 months.
If third-party verification is not possible, written family certification of estimated
apparatus costs for the upcoming 12 months
In addition, TCHAO must verify that:
The family member for whom the expense is incurred is a person with disabilities (as
described in 7-II.F above).
The expense permits a family member, or members, to work (as described in 6-II.E.).
The expense is not reimbursed from another source (as described in 6-II.E.).
Family Member is a Person with Disabilities
To be eligible for the disability assistance expense deduction, the costs must be incurred for
attendant care or auxiliary apparatus expense associated with a person with disabilities. The PHA
will verify that the expense is incurred for a person with disabilities (See 7-II.F.).
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Family Member(s) Permitted to Work
The PHA must verify that the expenses claimed actually enable a family member, or members,
(including the person with disabilities) to work.
TCHAO Policy
TCHAO will request third-party verification from a Rehabilitation Agency or
knowledgeable medical professional indicating that the person with disabilities requires
attendant care or an auxiliary apparatus to be employed, or that the attendant care or
auxiliary apparatus enables another family member, or members, to work (See 6-II.E.).
This documentation may be provided by the family.
If third-party verification has been attempted and is either unavailable or proves
unsuccessful, the family must certify that the disability assistance expense frees a family
member, or members (possibly including the family member receiving the assistance), to
work.
Unreimbursed Expenses
To be eligible for the disability expenses deduction, the costs must not be reimbursed by another
source.
TCHAO Policy
The family will be required to certify that attendant care or auxiliary apparatus expenses
are not paid by or reimbursed to the family from any source.
7-IV.D. CHILD CARE EXPENSES
Policies related to child care expenses are found in Chapter 6 (6-II.F). The amount of the
deduction will be verified following the standard verification procedures described in Part I of
this chapter. In addition, the PHA must verify that:
The child is eligible for care.
The costs claimed are not reimbursed.
The costs enable a family member to pursue an eligible activity.
The costs are for an allowable type of child care.
The costs are reasonable.
Eligible Child
To be eligible for the child care deduction, the costs must be incurred for the care of a child
under the age of 13. The PHA will verify that the child being cared for (including foster
children) is under the age of 13 (See 7-II.C.).
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Unreimbursed Expense
To be eligible for the child care deduction, the costs must not be reimbursed by another source.
TCHAO Policy
The family will be required to certify that the child care expenses are not paid by or
reimbursed to the family from any source.
Pursuing an Eligible Activity
The PHA must verify that the family member(s) that the family has identified as being enabled to
seek work, pursue education, or be gainfully employed, are actually pursuing those activities.
TCHAO Policy
Information to be Gathered
TCHAO will verify information about how the schedule for the claimed activity relates to
the hours of care provided, the time required for transportation, the time required for
study (for students), the relationship of the family member(s) to the child, and any special
needs of the child that might help determine which family member is enabled to pursue
an eligible activity.
Seeking Work
Whenever possible, TCHAO will use documentation from a state or local agency that
monitors work-related requirements (e.g., welfare or unemployment). In such cases
TCHAO will request verification from the agency of the member’s job seeking efforts to
date and require the family to submit to TCHAO any reports provided to the other
agency.
In the event third-party verification is not available, TCHAO will provide the family with
a form on which the family member must record job search efforts. TCHAO will review
this information at each subsequent reexamination for which this deduction is claimed.
Furthering Education
TCHAO will request third-party documentation to verify that the person permitted to
further his or her education by the child care is enrolled and provide information about
the timing of classes for which the person is registered. Documentation may be provided
by the family.
Gainful Employment
TCHAO will seek verification from the employer of the work schedule of the person who
is permitted to work by the child care. In cases in which two or more family members
could be permitted to work, the work schedules for all relevant family members may be
verified. Documentation may be provided by the family.
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Allowable Type of Child Care
The type of care to be provided is determined by the family, but must fall within certain
guidelines, as discussed in Chapter 6.
TCHAO Policy
TCHAO will verify that the type of child care selected by the family is allowable, as
described in Chapter 6 (6-II.F).
TCHAO will verify that the fees paid to the child care provider cover only child care
costs (e.g., no housekeeping services or personal services) and are paid only for the care
of an eligible child (e.g., prorate costs if some of the care is provided for ineligible family
members).
TCHAO will verify that the child care provider is not an assisted family member.
Verification will be made through the head of household’s declaration of family members
who are expected to reside in the unit.
Reasonableness of Expenses
Only reasonable child care costs can be deducted.
TCHAO Policy
The actual costs the family incurs will be compared with TCHAO’s established standards
of reasonableness for the type of care in the locality to ensure that the costs are
reasonable.
If the family presents a justification for costs that exceed typical costs in the area, the
PHA will request additional documentation, as required, to support a determination that
the higher cost is appropriate.
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EXHIBIT 7-1: SUMMARY OF DOCUMENTATION REQUIREMENTS
FOR NONCITIZENS [HCV GB, pp. 5-9 and 5-10]
All noncitizens claiming eligible status must sign a declaration of eligible immigrant status
on a form acceptable to the PHA.
Except for persons 62 or older, all noncitizens must sign a verification consent form
Additional documents are required based upon the person's status.
Elderly Noncitizens
A person 62 years of age or older who claims eligible immigration status also must provide
proof of age such as birth certificate, passport, or documents showing receipt of SS old-age
benefits.
All other Noncitizens
Noncitizens that claim eligible immigration status also must present the applicable USCIS
document. Acceptable USCIS documents are listed below.
Form I-551 Alien Registration Receipt
Card (for permanent resident aliens)
Form I-94 Arrival-Departure Record
annotated with one of the following:
“Admitted as a Refugee Pursuant to
Section 207”
“Section 208” or “Asylum”
“Section 243(h)” or “Deportation
stayed by Attorney General”
“Paroled Pursuant to Section 221 (d)(5)
of the USCIS”
Form I-94 Arrival-Departure Record with
no annotation accompanied by:
A final court decision granting asylum
(but only if no appeal is taken);
A letter from a USCIS asylum officer
granting asylum (if application is filed
on or after 10/1/90) or from a USCIS
district director granting asylum
(application filed before 10/1/90);
A court decision granting withholding
of deportation; or
A letter from an asylum officer granting
withholding or deportation (if
application filed on or after 10/1/90).
Form I-688 Temporary Resident Card
annotated “Section 245A” or Section 210”.
Form I-688B Employment Authorization Card
annotated “Provision of Law 274a. 12(11)” or
“Provision of Law 274a.12”.
A receipt issued by the USCIS indicating that an application for issuance of a replacement
document in one of the above listed categories has been made and the applicant’s entitlement
to the document has been verified; or
Other acceptable evidence. If other documents are determined by the USCIS to constitute
acceptable evidence of eligible immigration status, they will be announced by notice
published in the Federal Register
