Hillsdale Housing Commission
45 N. West Street � Hillsdale, MI  49242
Phone: (517) 439-1210 � Fax: (517) 439-9577 � E-mail: mail@hillsdalehousing.org

UIV/EIV Policy

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Policy

The Hillsdale Housing Commission will utilize HUD’s Upfront Income Verification/Enterprise Verification System (UIV/EIV) as the Commission’s preferred method of verifying income.  The procedures listed in this document are designed to supplement the HUD UIV/EIV System PHA Security Procedures.  The UIV/EIV system and related documents will only be used the purposes for which they were intended.  UIV/EIV data is subject to the provisions of the Federal Privacy Act (5 U.S.C. § 552, As Amended By Public Law No. 104-231, 110 Stat. 3048), The Freedom of Information Act (5 U.S.C. § 552, As Amended By Public Law No. 104-231, 110 Stat. 3048), and related amendments.

 In order to provide for proper security for data received through the UIV/EIV system, the following procedures are hereby established.

Procedures

Authorized Users

1. UIV/EIV users shall be authorized by the Executive Director on a need-to-know basis.  Persons not employed by the Hillsdale Housing Commission shall not be authorized, and only those whose job duties specifically relate to UIV/EIV shall be granted access to the systems and related documents.
2. Only the following types of authorized users shall be allowed access to the UIV/EIV system by the Executive Director:
   1. Persons whose job duties include the determination of rental payment charges
   2. Persons whose job duties include securing data obtained under UIV/EIV.
   3. Persons whose job duties include retrieving UIV/EIV data
   4. Persons whose job duties include reviewing UIV/EIV data for the purposes of performing UPCS and/or HQS inspections
3. The Executive Director will provide each user a User Access Form, and the user shall apply for a User ID and password as applicable. The Commission’s Acceptable Computer Use Policy, contains provisions specifically prohibiting sharing of User ID and Password data between users and is therefore hereby incorporated into this document by reference. 

Executive Director’s Responsibilities

1. The Executive Director shall serve as the UIV/EIV Security Officer.
2. The Executive Director shall authorize users for access to UIV/EIV systems and data only where necessary, and shall maintain a log of authorized users.  The Executive Director shall update this log on a periodic basis, at least once per calendar quarter.
3. The Executive Director shall conduct staff training and/or review of UIV/EIV security procedures on a period basis, to be completed at least annually.
4. The Executive Director shall be responsible for determining and reporting any instances of improper disclosure of UIV/EIV data and/or unauthorized access of UIV/EIV computerized systems.
   1. Upon noting a security breach, the Executive Director shall immediately contact appropriate HUD personnel for removal of the offending parties from the UIV/EIV system.
5. The Executive Director shall monitor UIV/EIV procedures to ensure ongoing compliance.  Procedures will be updated as needed. 

Disclosure, Data Security and Disposition

1. Staff shall document that the Hillsdale Housing Commission will make use of UIV/EIV systems at each annual recertification and to applicants during the application process.  This disclosure shall include the following:
   1. A brief explanation of the UIV/EIV system
   2. A brief explanation of how income discrepancies are identified, the potential effect on rental calculations, and penalties for committing fraud
   3. A brief explanation of how discrepancies are resolved
   4. A brief explanation of the actions the Hillsdale Housing Commission may take based on verified unreported or underreported income.
2. Each tenant and applicant file shall contain a properly completed, active HUD 9886 Form or equivalent, granting the Hillsdale Housing Commission access to UIV/EIV data.
3. UIV/EIV data shall be kept in (a) locked, fire-resistant fire filing cabinet(s), and only those staff members who have been previously authorized by the Executive Director may be given keys and/or access to the data.  The Executive Director shall maintain a list of users receiving keys.  The filing cabinet(s) shall in turn be secured behind a door locked whenever the office is closed.
4. Proper disposition of UIV/EIV data shall be performed by cross-shredding, and staff shall maintain a log of which documents were destroyed and the date of destruction.

Discrepancies

All household income regardless of source must be reported by the family to the Hillsdale Housing Commission, as specified in the Hillsdale Housing Commission’s Admissions and Continued Occupancy Policy and Dwelling Lease.  The Admissions and Continued Occupancy Policy and Dwelling Lease are therefore included in this document by reference. 

Where EIV/UIV data is substantially different from tenant-reported and/or third party-reported income, the following shall be observed: 

1. In any case where staff has relied solely on EIV/UIV data to document the discrepant income, staff shall submit a third-party verification form to the income source.
2. Staff shall review historical data for prior patterns of employment, benefit payments, and/or other income source histories.
3. Staff shall discuss the discrepancy with the tenant and the tenant shall be given the opportunity to resolve the discrepancy.  Such discussion shall either be verbally or in writing.
   1. Although the tenant shall be given the opportunity to resolve the discrepancy, the final arbiter shall be either third-party verification or UIV/EIV data, whichever is accurate, unless the tenant can provide documentation that one or both parties’ data is incorrect.
   2. If the tenant is able to produce sufficient documentation of incorrect third-party and/or UIV/EIV data, staff shall contact the proper personnel in charge of this data for resolution.

UIV/EIV Systems Use Acknowledgement

All adults, 18 and over, are required to sign this acknowledgement.

 By signing below, I understand that: 

1. I must report all changes of my income and changes of the income from persons living in my household within ten (10) days as specified in the Hilltop Apartments Dwelling Lease and related documents.

2. The Hillsdale Housing Commission uses electronic data matching, Upfront Income Verification (UIV), and other electronic and manual methods to verify reported income with independent sources.  Types of electronic verification may include, but are not limited to, employment and other earnings, social security benefits, unemployment, etc.  By signing this agreement, I hereby authorize the Hillsdale Housing Commission to make inquiries regarding my income as necessary.

3. If the Hillsdale Housing Commission becomes aware of income that I have not reported, or under reported income, as specified in the Hillsdale Housing Commission’s Dwelling Lease and related documents, I hereby acknowledge that I may be subject to certain penalties.  These penalties may include, but not be limited to, repayment, current and future program ineligibility, and civil and/or criminal prosecution.

4. If I am determined to be ineligible for housing assistance because I did not comply with the relevant portions of the Dwelling Lease and related documents in timely reporting of income and therefore must repay the Hillsdale Housing Commission under a properly executed Repayment Agreement, I hereby acknowledge that I may not be eligible for assistance from any other Housing Authority until I satisfy the offense by remitting the full amount listed in the Repayment Agreement in a timely manner.

5. If I disagree with the findings, I hereby acknowledge that I have the right to request a review of the income and circumstances which caused the discrepancy with a member of management.