Boston Housing Authority

Policies > Section 8 Admin Plan Ch 4: Communications & Verification

Section 8 Admin Plan

Chapter 4:Communications & Verification

“Communication” includes both standard forms used by the BHA to obtain information from an Applicant/Participant or an Owner and information provided to an Applicant/Participant or an Owner about the program. It is the goal of the BHA to communicate well with Owners and Applicant/Participants because they are less likely to commit errors, fraud, or abuse when they have a much better understanding of program requirements and BHA expectations.
The following chapter describes the standards of communication and verification required and expected of the BHA, an Applicant or Participant, and an Owner.

4.1       Communication Preference

The BHA prefers that all communication between Families and the BHA and between Owners and the BHA be in writing.  The BHA will attempt to create well designed forms to effectuate proper communication to Families and Owners and to collect all required information.  The BHA will communicate with persons who have limited English ability in accordance with section 1.3.4 of this Administrative Plan. 

4.1.1    Communication between Applicants and the BHA

It is the responsibility of each Applicant to inform the BHA in writing of any change in address, telephone number, Family Composition, change in Priority and or Preference, or other information, which may affect the status of the application while on the waiting lists. For an Applicant with no fixed address, such as a Homeless Applicant, the address of a social service agency may be used for BHA contacts; however, if the Applicant finds housing, the address must be reported to the BHA. Failure to report a change may result in withdrawal from the waiting list.
BHA will communicate with an Applicant by first class mail, except when an Applicant who is a Disabled Person requests some other form of communication (e.g., a telephone call, communication with a designated third party, etc.).  A person who is Homeless and an Applicant may request that the BHA communicate with a designated third party. Failure to respond to BHA communication in the required time period may result in withdrawal of an Applicant from all waiting lists.

4.1.2    Communication between a Participant and the BHA                      

A Participant should communicate with the BHA in writing. It is the responsibility of the Participant to report a change in income or Family Composition in accordance with this Administrative Plan.  A Participant also has an obligation to supply all required documentation for eligibility and Recertification purposes.  It is in the best interest of the Participant to retain copies of any communication with BHA.
Failure to respond to BHA communication in the required time period may result in termination of the Participant’s subsidy in accordance with Chapter 13 of this Administrative Plan.

4.2       Misrepresentation of Information or Fraud

The BHA considers falsification, misrepresentation, or failure to disclose information related to Admission, initial eligibility, participation, or Recertification grounds for denying Admission or terminating assistance from the HCVP.  If the BHA determines that an Applicant has acted as described above, the Applicant will be precluded from re-applying for assistance with the BHA for three years from the date of the determination.

4.3       Verification Requirements

The BHA must verify and document all information concerning an Applicant/Participant’s Family Composition, Annual Income, Priority status, and Preferences.

4.3.1    Verification Documentation

The BHA will maintain all documents related to eligibility/Recertification in the Applicant/Participant’s file folder. Documentation used as part of the verification process may include but is not limited to:
(a)        Copies of documents, where law or regulation does not require the original.
(b)        Verification forms completed and signed by third parties and/or Applicant/Participant.
(c)        Upfront Income Verification (UIV)

UIV is the verification of a Family’s income, before or during a Recertification, through an independent source that systematically and uniformly maintains income information in computerized form for a large number of individuals.   The BHA will maintain UIV data according to applicable Federal, State, and local law and BHA policy. 

(d)        Reports of all relevant interviews, telephone conversations or personal contact with or regarding the Applicant/Participant including date of the conversation, source of the information, name and position of the individual contacted, name and position of staff member receiving information and a written summary of the information received.
(e)        All correspondence received for or on behalf of the Applicant.

4.3.2    Verification Preference

The BHA will accept verification of eligibility information in the following order of preference:
(a)        Upfront Income Verification (UIV)
The BHA will use UIV procedures to obtain verification of tenant-reported (unreported or underreported) income.
(1)        Types of Income that may be verified through UIV:

(i)         Gross Wages and Salaries (Including overtime pay, commission, fees, tips, bonuses, and other compensation for personal services)
(ii)        Unemployment Compensation
(iii)       Welfare Benefits
(iv)       Social Security Benefits (including Federal and State benefits, Black Lung benefits, and dual benefits)
            (A)       Social Security
            (B)       Supplemental Security Income (SSI)

(2)        The BHA may obtain UIV through the following methods:

(i)         Computer matching agreement with a federal, state, local government agency, or a private agency; or
(ii)        Use of HUD’s Tenant Assessment Subsystem (“TASS”) or Enterprise Income Verification (“EIV”); or
(iii)       Submission of direct request for income verifications to a federal, State, or local government agencies or a private agency. 

(3)        UIV Standards

(i)         If UIV income data is less than current tenant-provided documentation, the BHA will use tenant-provided documents to calculate anticipated annual income.
(ii)        If UIV income data is more than current tenant-provided documentation, the BHA will use UIV income data to calculate anticipated Annual Income unless the tenant provides the PHA with documentation of a change in circumstances (i.e. change in employment, reduction in hours, etc.). Upon receipt of acceptable tenant-provided documentation of a change in circumstances, the PHA will use tenant-provided documents to calculate anticipated annual income.

(b)        Written Third Party Verification 
Written verification by a third party is always preferred. The BHA will also accept Third Party Verification from reputable online systems, including EIV and TASS, which may verify employment income or other sources of regular income. See also section 4.3.4 for more information on Third Party Verification.
(c)        Oral Third Party Verification
Independent verification of income and/or expenses by contacting the individual income/expense source(s) supplied by the Applicant/Participant, via telephone or in-person visit. BHA staff will document in the tenant file, the date and time of the telephone call, the name of the person contacted and telephone number, along with the confirmed verified information.
This verification method is commonly used in the event that the independent source does not respond to the BHA’s faxed, mailed, or e- mailed request for information in a reasonable time frame, i.e., ten (10) business days.
The BHA shall verify information by telephone when written third-party verification is incomplete or unclear.
(d)        Verification by Applicant/Participant supplied documents.  
The BHA will review documents submitted by the Applicant when: (i) the information requested does not require Third-Party Verification (for example rent receipts, canceled checks for rental payments, Lease agreements and monthly utility bills) or (ii) third-party fax or telephone verification is impossible. BHA may copy documents into the Applicant’s file or list the documents and the information contained in them.
(e)        Verification by Applicant/Participant certification
With the approval from the Administrator or his/her designee, the BHA may choose to accept an affidavit from an Applicant regarding housing and employment history only when verification by a third party or verification by documents is impossible to obtain.

4.3.3    Validity of Documentation and Verification

(a)        Information Supplied by Applicant/Participant. Documents supplied by an Applicant/Participant should be dated within sixty days (60) of the eligibility/Recertification interview[1]
(b)        Verification at Recertification. Verification obtained for Recertification must be no older than 120 days at the effective date.
(c)        Information not subject to change.  BHA will verify this information (e.g. verification of age or place of birth) only once during the eligibility/Recertification process.

(d)        Verification of Eligibility must be no more than 60 days from Voucher issuance.  The BHA must receive information verifying that an applicant is eligible within the period of 60 days before the BHA issues a voucher to the Applicant.  24 C.F.R. § 982.201(e)

(e)        Maximum Family Share at initial Occupancy.  At initial occupancy the Family Share must not exceed 40 percent of the Family’s gross income. The determination of adjusted monthly income must be based on verification information received by the BHA no earlier than 60 days before the BHA issues a voucher to the family.

4.3.4    Third Party Verifications

BHA will send third party verifications directly to the third party. The BHA may fax a verification form to a third party and request a return fax to the BHA after the form is completed. Each BHA verification form sent to a third party will include the following: 
(a)        Authorization from the Applicant to release the information on the BHA’s General Release Form (HUD 9886) or Income Verification Form, and
(b)        BHA Third-Party Verification form.

4.4       Missed Appointments

The BHA considers it a failure to attend an appointment and is not required to hold a scheduled meeting if an individual is more than one-half (1/2) an hour late for a scheduled appointment. 
The BHA does not consider it a failure to keep an appointment if an individual contacts the BHA prior to the appointment to reschedule or has a reasonable excuse for missing the appointment. The BHA may use discretion to determine whether or not an excuse is reasonable.  The BHA may ask the Family to supply documentation to verify their inability to attend the appointment. 

[1] See HUD Verification Guidance for the Public Housing And Housing Choice Voucher Programs (March 2004)