HUD, HHS Ease EIV Paperwork Headache

In June, HUD announced that it is finalizing an agreement with the Department of Health and Human Services (HHS) to allow you to retain printed Enterprise Income Verification (EIV) reports in tenant files for the term of tenancy plus three years after the termination of tenancy. According to HUD, HHS has agreed to allow HUD property owners and managers to keep EIV New Hires data in tenant files much longer than before. An earlier HUD-HHS agreement required owners to destroy the EIV printed reports with New Hires data in tenant files when the reports were two years old. HHS provides employment and income data on HUD program participants for the EIV system from the National Directory of New Hires. According to HUD, when the agreement is finalized, the Department will issue a revision of HUD Notice H2008-3, which details EIV requirements.

HUD has not announced any other EIV policy changes. Use of EIV in multifamily programs becomes mandatory on Sept. 30, 2009. To facilitate HUD's computer data matching with HHS and other agencies, on that date, you will be required to collect and verify Social Security numbers for all household members (including children) who declare themselves to be U.S. citizens, U.S. nationals, or eligible noncitizens. The disclosure requirement does not apply to individuals in mixed families who do not contend eligible immigration status under HUD's noncitizen rules.

One important paperwork requirement remains unchanged: You must have on file for all applicants and residents a current form HUD-9887 and 9887-A. The forms must be signed and dated not just by the head of household, but by all adult household members, even if they claim no income.