How to Maintain Your Site’s EIV Master File

HUD’s Enterprise Income Verification (EIV) system contains a number of reports used to verify employment and income of applicants and residents. HUD asks owners to use EIV to monitor compliance of existing residents. Every month, owners and agents are required to view and catalog certain reports periodically in a separate “Master File.” This file is separate from the tenant file, which contains detailed reports for members of that tenant’s household, copies of notices, verification documents, and new certifications.

The purpose of having the master file is to demonstrate to HUD that resident compliance is being reviewed periodically. HUD believes that regular review of the reports to be included in the master file helps reduce “assistance paid in error.”

The master file should be maintained in the same secured fashion as your tenant files. The EIV Master File must be kept for three years [HUD Handbook 4350.3, par. 9-14 (A)(4)]. And, once the retention period has expired, owners and agents must dispose of the data in a manner that will prevent any unauthorized access to personal information, such as burning, pulverizing, shredding, etc. [HUD Handbook 4350.3, par. 9-14(B)].

What to Include

The EIV Master File includes:

Identity Verification Reports (Failed Pre-Screening and Failed Verification). These reports must be reviewed monthly [HUD Handbook 4350.3, par. 9-12(C)(1)(a)]. The Failed Pre-Screening Report identifies household members who have missing or invalid personal identifiers such as last name, date of birth, or Social Security number (SSN) in TRACS [HUD Handbook 4350.3, par. 9-12(C)(1)]. And the failed verification report identifies household members whose last name, date of birth, or SSN don’t match the SSA database [HUD Handbook 4350.3, par. 9-12(C)(2)].

New Hires Report. Members are required to report increases in household income that are equal to $200 per month or more [HUD Handbook 4350.3, par. 9-11(D)(1)(c)(2)]. This report helps ensure that changes in income are being properly reported by identifying members who have new employment within the last six months [HUD Handbook 4350.3, par. 9-11(D)(1)(c)]. The report is updated monthly and the report should be run at least quarterly [HUD Handbook 4350.3, par. 9-11(D)(1)(c)(1)].

You should retain a copy of the report in a master “New Hires Report” file for three years along with notes of the outcome of the contact with the household member.

Multiple Occupancy Report. This report identifies household members who may be receiving rental assistance at more than one location [HUD Handbook 4350.3, par. 9-12(B)]. This report provides ongoing checks to ensure members don’t get multiple subsidies. It allows checks on households after they’ve moved in, so the owner could possibly discover that a household’s composition has changed or that someone moved to another subsidized site without informing the manager. HUD requires that this report be run on a quarterly basis [HUD Handbook 4350.3, par. 9-12(B)(1)(a)]. You should keep a copy of the Multiple Subsidy Summary Report and supporting documentation in a master “Multiple Subsidy Report” file for three years.

Deceased Tenant Report. Families of deceased household members are expected to report the death promptly. In cases in which families don’t report the death promptly, households may collect rental assistance fraudulently or in error. This report identifies members reported by SSA as being deceased [HUD Handbook 4350.3, par. 9-12(D)].

HUD requires that this report be run on a quarterly basis [HUD Handbook 4350.3, par. 9-12(D)(1)(a)]. And you should place the report in your site’s master file.