DASH Compliance

A recurring theme that was expressed by many attendees at the majority of the trainings I have been to this year has been…what do we do about EIV.  Even though HUD gave all of us plenty of warning that implementation and use of EIV would be mandatory at the end of January, many of us are still struggling to put the pieces together.  Here is a simple breakdown of what owners/agents are required to do:

·         First and foremost gain access to EIV

If your company does not already have an EIV Coordinator, this can be especially time consuming.  The recent EIV outstands have slowed the process down considerably.  Visit www.hud.gov/reac for specific information on how to gain access and take steps to get this done immediately.  If you have an EIV Coordinator, but your users are not set up, this process does not take much time and can be done by the current EIV Coordinator.  If you aren’t sure how to do this, please call someone to help. 

·         Maintain a complete EIV file 

This file is required to include the following information:

Coordinator Access Authorization Form (CAAF) with HUD approval (both initial and current)

                User Access Authorization Forms (UAAF) (both initial and current)

                Security Awareness Questionnaires for both Coordinator and all Users

Signed Authorization from the owner giving the EIV Coordinator permission to access the community

Signed Rules of Behavior forms for persons that review files that do not have access to EIV (i.e. auditors)

We strongly recommend that the annual Security Awareness testing is printed and saved as well.

·         Create comprehensive EIV Policies and Procedures 

These procedures should include at least the following: 

How staff members will gain access to EIV

How access (including user IDs and passwords) will be kept secure

How EIV will be used (including how often reports will be run)

Who will be responsible for recertification of users and should be notified of any breaches in security (usually this is the EIV coordinator)

Administrative, Technological, and Physical safeguards that are in place to secure information in EIV

Policy for destroying information obtained through EIV – this should include method of destruction as well as time frames for destruction of information

·         Begin using EIV on a consistent basis 

EIV is only as beneficial if it is used.  Your policies and procedures should determine what reports should be run and how often.  The following is a sample breakdown of available information and a recommendation of how often each report can be run.  Keep in mind that only senior management representatives should make changes to current policy and procedures.

• Monthly – Print and Review

Identity Verification Reports (Failed EIV Pre-screening and Failed Verification Report)

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  • Take action on any failed verifications and resubmit necessary corrections through TRACS
  • File in the office in a file labeled “EIV Reports”
  • If any residents are listed, also file in resident file with the documentation related to corrections processed

• Quarterly – Print and Review

New Hire Report

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  • Compare with resident files as necessary to confirm that all income has been accurately reported
  • Maintain copy in file labeled “EIV Reports”
  • File in resident file with the 50059 if one was created or in correspondence section

Multiple Subsidy Report

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  • If any residents are listed immediately contact resident to determine necessary corrections
  • Maintain copy in file labeled “EIV Reports”
  • If any residents are listed, document actions taken on report and file a copy in the resident file

Deceased Tenants Report

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  • Confirm that any resident listed has been removed from 50059 and subsidy has been terminated
  • Document actions taken on report and file in a file labeled “EIV Reports”
  • Maintain copy in resident file for any resident’s listed

• Annually (at time of recertification)
• At Interim
• Within 90 days after move in– Print and Review:

Income Report

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  • Use as documentation of employment or verification of social security income (for wage verification be sure to get additional documentation of income)
  • Compare to resident file to ensure that all sources of income have been accurately reported
  • File with Annual 50059

Income Discrepancy Report

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  • Compare with resident file to see if there is a legitimate reason for discrepancy
  • Meet with resident to discuss discrepancy and take steps to verify income and create retroactive 50059 if necessary
  • File with Annual 50059 and with any additional 50059s created

No Income Report

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  • Maintain copy in resident file – note:  a no income report does not mean the resident has no income, they just have no income that has been reported to EIV
  • File with Annual 50059

• As needed (at the time of application processing)

Existing Tenant Search

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  • Print and review on applicant household members during application processing
  • File with Application

Hopefully, with these tips, navigating EIV will not be as difficult or time-consuming and can become the helpful tool that HUD has intended for it to be.