Tips for Navigating EIV Access Issues
Use of the Enterprise Income Verification (EIV) system for public and multifamily housing providers receiving HUD rental assistance became mandatory on Jan. 31, 2010. Progress seemed bumpy earlier in the year, with lagging participation from some owners and agents, multiple system outages, functionality problems, and data anomalies, but HUD's EIV team has been working to troubleshoot and fix the issues.
There are still a few difficulties causing some confusion and frustration among owners and management agents trying to gain access to the system—many of which are related to time frames. “As critical as accessing EIV is to the property operations and compliance, unfortunately, the life of affordable housing staff is one of much detail and little time,” says Denise Murphy, principal of Murphy Consulting. “Site staff members have so many important details to handle that they often misstep in their rush or simply get frustrated by the unanticipated waiting periods inherent in the process.”
Murphy teaches an overview course on how to navigate the EIV access process, and offers a webinar on her Web site. We asked her for tips on getting started.
Five Steps to EIV Access
There are five steps to EIV access for Coordinators in the HUD Secure System:
1. Obtain a valid Coordinator WASS ID.
2. Log into the HUD Secure System with your WASS ID and assign yourself user roles.
3. Apply to HUD for initial Permission to access the EIV system (commonly referred to as a CAAF, Coordinator Access Authorization Form).
4. After HUD approval of the paper CAAF, assign the EIV role to the property in the HUD Secure System, under Property Assignment Maintenance.
5. Enter EIV, complete the acknowledgements, initial online Security Test, and an online Coordinator Authorization Request Form (also known as a CAAF, or e-CAAF). Then wait for HUD final approval.
“While it looks easy on paper, there are many stumbling blocks along the way,” Murphy says. “Steps 1, 3, and 5 have waiting periods that depend on HUD to respond to and/or approve. The folks at HUD, like many of us, have busy jobs with varied duties, so the turnaround times on these items can be unpredictable.”
To make matters more complicated, she adds, there are specific documentation requirements that must be reviewed by the contract administrator during annual Management and Occupancy Reviews to assure that each person with EIV access has gained his access lawfully. There are severe penalties for unapproved access or failing to provide adequate documentation.
“User access is much easier, although the strict documentation requirements remain in place,” Murphy says. “The same basic steps apply, but both the paper CAAF and the e-CAAF can be reviewed and approved by a property's established EIV Coordinator who has completed the five steps for EIV access.”
Keep in mind that the data available in EIV is sensitive personal income and employment information, she points out. “HUD has put into place strict security measures to ensure that no one can access this information without proper approval. Folks complain about the multilayered security required to gain access to EIV, and the annual and semiannual security steps required to maintain that access. I tell them I'm glad HUD is doing everything possible to protect this information—just think if it was your information out there. You'd want that type of protection.”
Murphy recommends that site staff review HUD's “Enterprise Income Verification (EIV 9.0) System User Manual For Multifamily Housing Program Users,” as well as attend a few of the numerous training sessions available on its Web site (http://www.hud.gov).
Here are a few more practical pointers:
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Update your Tenant Selection Plan to include the use of EIV.
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Prepare specific written company policies regarding the use of EIV and security procedures to protect the data.
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Do not share user IDs and passwords.
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Mark your calendar! There is no system notification to remind you that Step 5 (the e-CAAF) must be repeated annually for coordinators and semiannually for users.
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Sign up for the Listserv to receive important HUD announcements.
Insider Source
Denise Murphy: Principal, Murphy Consulting; (410) 821-6953; denise@murphyconsultingsvs.com; http://www.MurphyConsultingSvs.com.
Sidebar
Where to Find EIV Web Resources and Training
The following resources were compiled by Mary Ross, Ross Business Development (http://www.rbdnow.com).
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HUD's EIV Web Site for the Multifamily Housing Industry:
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HUD's EIV Training Outreach Web Site:
http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/eivtraining.cfm
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Multi-household Enterprise Income Verification Training, Dec. 29, 2009:
http://portal.hud.gov/portal/page/portal/HUD/webcasts/archives/multifamily
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EIV Detailed PowerPoint to Support the December 2009 EIV Webcast:
http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/training/eivpresentationdec2009.pdf
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EIV: Instructional Course for Multifamily Housing Programs, Feb. 25, 2010:
http://portal.hud.gov/portal/page/portal/HUD/webcasts/archives/multifamily
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The Mandatory Use of EIV Final Rule webcast (took place April 14, 2010), which discussed Housing Notice 10-08 Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Programs: Implementation of the Enterprise Income Verification System—Amendments; Final Rule:
http://portal.hud.gov/portal/page/portal/HUD/webcasts/archives
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The Supplemental PowerPoint slides for the April 14, 2010 Webcast:
http://www.hud.gov/offices/hsg/mfh/rhiip/eiv/eivtraining.cfm
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HUD's Rental Housing Integrity Improvement Web Site:
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Instructional Packet for Owners and Agents for Implementing the Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Programs: Implementation of EIV-Amendments; Final Rule:
http://www.hud.gov/offices/hsg/mfh/rhiip/instructionalpacketforoas.pdf
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HUD Notice 10-08: Implementation of Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Programs: Implementation of the Enterprise Income Verification System—Amendments; Final Rule:
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HUD Notice 10-02: Enterprise Income Verification (EIV) and You Brochure—Requirements for Distribution and Use:
http://portal.hud.gov/portal/page/portal/HUD/program_ offices/administration/hudclips/notices/hsg
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HUD Notice 09-20: Enterprise Income Verification (EIV) System, issued Dec. 29, 2009:
http://www.hud.gov/offices/adm/hudclips/notices/hsg/08hsg notices.cfm
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Resolving Income Discrepancies between Resident-Provided and Enterprise Income Verification (EIV) System Income Data, dated May 2008:
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Multi-household Enterprise Income Verification Training, Dec. 29, 2009:
http://portal.hud.gov/portal/page/portal/HUD/webcasts/archives/multifamily
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HUD Handbook 4350.3, Revision 1, Change 3:
http://www.hud.gov/offices/adm/hudclips/handbooks/hsgh/4350.3/index.cfm
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