CAREFUL READING OF RHIIP NOTICE 241

It appears that a recent RHIIP notice (#241) has caused some consternation/confusion among housing professionals...including myself.

Many are taking this notice to mean that Social Security award letters should no longer be in the files, and I've gotten emails to this effect from owners/agents, contract administrators and PBCA's. Indeed, this was also my impression.

But as I reflected on this, it didn't make sense to me. Many people are getting benefits under the SSN of a deceased spouse, so an exclusive focus on EIV was going to potentially miss this. Moreover, award letters have information about Medicare D...which EIV does not have.

So, I went back and read the RHIIP notice again and, paying careful attention to the wording, found it says something quite different. What it says is that residents cannot be directed to go to the local Social Security Administration office to obtain verification of income (benefits). Instead, they can do this "online or by telephone" and the current benefits statement will be sent to them.

Of course, residents may still choose to go to a Social Security office, and that is their right. Housing professionals cannot mandate, require or direct them to do that, however when there is a less potentially onerous method to get the information.

That makes sense.

Comments

[Dale Becker]

Mark - Interesting take on the notice - but then how are you reading these parts of Housing Notice 10-10?

(1) The Income Report identifying the Social Security benefit information in EIV must be used as third party verification of the tenant’s income and will be used to calculate the tenant’s income. A copy of the award or benefit letter or Proof of Income Letter is not required unless the tenant disputes the SSA information in EIV

…

(3) The O/A must confirm with the tenant that the current benefit amount in EIV is correct. If the tenant agrees that the Social Security benefit amount in EIV is correct. If the tenant agrees that the Social Security benefit information reported in EIV is correct, the O/A must:

(a) Use the gross benefit amount reported in EIV for calculating the tenant’s income by annualizing the gross benefit amount projected forward for the next 12 months.

Example 1:

EIV shows the tenant is receiving a gross Social Security benefit of $980.50 per month, net Social Security benefit of $870, and the Medicare premium of $110.50 is being paid by the tenant and the tenant agrees that this information is accurate. The O/A will use the EIV Income Report as the third party verification that the tenant is receiving Social Security benefits and the gross benefit amount from the Income Report for calculating the tenant’s income. A copy of the award or benefit letter or Proof of Income Letter is not required.

[Anne Cleveland]

EIV information is not accurate and therefore it is important to verify with the tenant so that the income is calculated correctly. The medicare portion of EIV is wrong so in the case of New York state EIV shows $1152 annulized and the actual amount according to the award letter is $1158.

As for tenants who recieve benefits from a deceased spouse, in EIV they show no income and we were told in a training last week that the tenant had to go to social security and have the benefit award switched to their own social security number. Social Security laughed and said if they do that the tenant wont get any benefits.

And then there is the case of tenants who show as terminated in EIV yet they are active and have TRACS files when they were certified.

The list goes on and we are supposed to take what EIV says as the gospel?

At least with the award letters we had the most current information within days and it was correct.