City of Culver City, California
Agenda Item Report
Meeting Date: 08/23/2010 Item Number: C-7
CITY COUNCIL AGENDA ITEM: Certification of the Section 8 Management
Assessment Program (SEMAP) and Enterprise Income Verification (EIV) Policies
and Procedures and Authorization to File the SEMAP with the U. S. Department of
Housing and Urban Development (HUD).
Contact Person/Dept.: Tevis Barnes,
Mona Kennedy- Community Development
Department/Housing Agency
Phone Number: (310) 253-5782
Fiscal Impact: Yes [] No [X] General Fund: Yes [] No [ X]
Public Hearing: [] Action Item: [] Attachments: [ X]
Commission Action Required: Yes [] No [ X] Date: _______________
Public Notification:
Agendas and Meetings – City Council (08/18/10)
Department Approval:
Sol Blumenfeld: (08/11/10)
City Attorney Approval:
Carol Schwab (by H. Baker) (08/18/10)
Chief Financial Officer Approval:Jeff Muir
(by M. Noller) (08/18/10)
City Manager Approval:
John M. Nachbar (08/18/10)
RECOMMENDATION:
Staff recommends the City Council:
1) Certify the Section 8 Management Assessment Program (SEMAP); and,
2) Authorize the Mayor and the City Manager to execute the SEMAP Certification
on behalf of the City and authorize its submission to the U.S. Department of
Housing and Urban Development (HUD); and,
3) Approve the Enterprise Income Verification (EIV) policies and procedures as
required by the U.S. Department of Housing and Urban Development.
BACKGROUND:
SEMAP:
On September 10, 1998, HUD established SEMAP. SEMAP was designed to assist
HUD with measuring the performance of Public Housing Agencies (PHAs) that
administer the Section 8 Housing Choice Voucher (HCV) Program. Under SEMAP,
PHA’s conduct a “self-evaluation” based on fourteen (14) HUD defined indicators (24
Code of Federal Regulations Section 985.1 – 985.3). A score of 60% or higher must
be received to remain in good standing with HUD. These indicators are as follows:
City of Culver City, California
Agenda Item Report
1. Selection of applicants from the waiting list
2. Reasonable rent
3. Determination of the adjusted income
4. Utility Allowance Schedule
5. Housing Quality Standard (HQS) Control Inspections
6. HQS Enforcement
7. Expanding housing opportunities
8. Payment Standards
9. Annual program participant reexamination
10. Correct tenant rent calculation
11. Pre-Contract HQS Inspection
12. Annual HQS Inspections
13. Lease-up
14. Family Self Sufficiency
PHA’s are required to transmit their SEMAP certification via the Internet within sixty
(60) calendar days of fiscal year end (or no later than August 29, 2010).
DISCUSSION:
The Culver City Housing Agency (CCHA) is required to perform its own self-
evaluation under SEMAP on an annual basis. In order to accurately complete this
certification, sixteen (16) randomly selected Section 8 HCV Program participant case
files were evaluated. The number of files and file selection methodology is defined
in 24 Code of Federal Regulations (CFR) section 985.2. In summary the CCHA self
certification score is 123 points out of 145 points or 85% (this score is above the
minimum required score of 60%). The scoring of each indicator is attached.
(Attachment 1).
ENTERPRISE INCOME VERIFICATION (EIV):
The Enterprise Income Verification (EIV) System was developed by HUD for the
primary purpose of reducing subsidy payment errors as a result of program participant
under and non-reporting of income and to ensure that limited federal resources serve as
many eligible families as possible. EIV facilitates more timely and accurate verification
of program participant -reported income at the time of mandatory annual and interim re-
examination of household income. EIV was also designed to maintain data quality,
integrity, and to prevent fraud and abuse.
The EIV System allows the CCHA to verify each working household member(s) wages
and employment information, unemployment compensation, and Social Security
Benefits (SS/SSI). EIV also assists the CCHA to:
• Detect abuse of the Section 8 HCV Program.
• Take administrative or legal actions to resolve past and current abuse. City of Culver City, California
Agenda Item Report
• Deter abuse by verifying the income of program participants at the time of
annual and interim re-examinations.
HUD has recommended the CCHA implement policies and procedures with
reference to the EIV system. The documentation attached has been recommended
by the HUD Los Angeles Area Field Office for implementation.
The EIV policies and procedures documentation includes the following information:
• Types of Upfront Verification of Income Provided by EIV
• What EIV Participant Data Is Used For
• Examples of Privacy Act Violations
• CCHA Security Officers
• Security Awareness Training
• Technical Safeguards
• Administrative Safeguards
• Physical Safeguards
• Reporting Improper Disclosures
• Safeguards Provided by the Privacy Act
FISCAL ANALYSIS:
HUD requires submission of SEMAP to ensure continued funding. For Calendar
Year 2010, the Section 8 HCV Program is budgeted for approximately $1.65 million.
These funds are recognized in Fund 426-Section 8 Fund.
ATTACHMENTS:
1) CCHA Indicator Scoring
2) SEMAP Certification (HUD Form 52648)
3) EIV Policies and Procedures
MOTION:
That the City Council:
1) Certify the Section 8 Management Assessment Program (SEMAP); and,
2) Authorize the Mayor and the City Manager to execute the SEMAP Certification
on behalf of the City and authorize its submission to the U.S. Department of
Housing and Urban Development (HUD); and,
3) Approve the Enterprise Income Verification (EIV) Policies and Procedures as
required by the U.S. Department of Housing and Urban Development.
Meeting Date: August 23, 2010
Agenda Item: Approval of the Certification and Submission of the
Section 8 Management Assessment Program (SEMAP)
and the Enterprise Income Verification (EIV) Policies and
Procedures to the United States Department of Housing
and Urban Development (HUD).
ATTACHMENTS
Pages
1. CCHA Indicator Scoring 1-3
2. SEMAP Certification 4-7
3. EIV Policies and Procedures 8-15
Culver City Housing Agency Indicator Scoring:
Indicator 1: Selection from the Waitlist- The CCHA has written policies in its
administrative plan for selecting applicants from the waiting list and therefore is in
full compliance for this indicator.
Indicator 2: Reasonable Rent - As required by HUD, all Section 8 HCV
Program files must contain information pertaining to comparable rents of each
leased unit. Of the files evaluated, each contained rent reasonableness
information and resulted in a score of 100%.
Indicator 3 – Determination of Adjusted Income – This evaluation resulted in
a one-hundred (100%) performance rating. This high score in calculating
adjusted income and calculating correct program participant rent is directly
related to the creation of an internal Rent Calculation Audit Worksheet for each
file managed by the housing staff. Additionally, the Housing Specialist, who
oversees the daily management of the Section 8 HCV Program, conducts a
quality control review of each file upon completion.
Indicator 4- Utility Allowance Schedule- The CCHA maintains an up-to-date
utility allowance schedule. The CCHA has reviewed the utility rate that were
obtained within the last 12 months, and adjusted the utility allowance schedule if
there was a change of 10% or more in a utility rate since the last time the utility
allowance was revised.
Indicator 5 – Housing Quality Standard (HQS) Control Inspections – The
CCHA remains in full compliance in FY 2009/2010 in terms of performing and
subsequently auditing annual inspections. The Structural Rehabilitation
Specialist and Housing Administrator re-inspected the units randomly selected
for the SEMAP evaluation to ensure HQS compliance. The result was a one
hundred percent (100%) performance rating.
Indicator 6- HQS Enforcement- The CCHA has not failed any units for 2009-
2010 that required action within 24 hours due to health and safety violations and
therefore did not have a quality control sample for this indicator. The result was
a one hundred percent (100%) performance rating.
Indicator 7 – Expanding Housing Opportunities - The CCHA strategy to
encourage owner participation was implemented by the CCHA’s increased efforts
to enhance property owner outreach. A strong relationship with property owners
is essential to maintaining existing and attracting greater property owner
participation which results in expanded housing opportunities. The activities
created to maintain and attract property owners to participate in the Section 8
ATTACHMENT 1
1HCV Program include small gestures like giving hand-written “thank you" notes
and making direct telephone calls to express CCHA gratitude to property owners
who participate in the Section 8 HCV Program. To maintain excellent customer
service, staff responds to owner and participants telephone calls within twenty-
four (24) hours. Inspections for new lease-ups or rent increases are also
scheduled either the same day or within twenty-four (24) to forty-eight (48) hours.
CCHA staff continues to seek out new strategies to improve owner participation.
Some of these new strategies include:
• Hosting a “Housing Authority Management Association” (HAMA) on May
27, 2010 where local Housing Authorities met and discussed different
program policies and procedures within the Industry.
• Hosting “The Art of ….Affordable Housing” on June 17, 2009 where local
developers and housing advocates met to help educate the public on
affordable housing.
• Creating the HQS Grant which allows qualified owners with failed
properties to participate in a $500.00 reimbursement towards the
improvement of their property.
• Informing property owners of our Neighborhood Preservation Program
(NPP) which provides grants to address deferred maintenance.
• Hosting an annual owner appreciation dinner.
• Presenting an award for “best owner of the year” through an essay
contest among Section 8 HCVP Program participants.
Our strategies to encourage property owners to continue participation in the
Section 8 HCV Program resulted in a 100% score for this Indicator.
Indicator 8- Payment Standards- This evaluation resulted in a one hundred
percent (100%) performance rating as the CCHA has adopted current payment
standards for the voucher program by unit size. As an example, the payment
standard for a two (2) bedroom is $1,497.00.
Indicator 9-Timely Annual Reexaminations- This evaluation resulted in a one
hundred percent (100%) performance rating as the CCHA has completed a
reexamination to determine income eligibility and affordable rent payments for
each participating family at least every 12 months.
Indicator 10 – Correct Tenant Rent Calculations – Compliance is at one
hundred percent (100%). To assure continued one hundred percent (100%)
ATTACHMENT 1
2compliance in this area, staff will be given ongoing training to stay abreast of any
changes in HUD rules and regulations in this area.
Indicators 11 and 12 – Pre contract HQS Inspections and Annual HQS
Inspections – One hundred percent (100%) of all units newly leased passed the
HQS inspection before the execution of a lease and Housing Assistance
Payment (HAP) contract. Additionally, one hundred percent (100%) of all units
undergo an annual inspection. Housing staff also guarantees that initial
inspections will be scheduled within forty-eight (48) hours.
Indicator 13 – Lease-Up – The CCHA continues to be challenged in this area.
The CCHA continues to strive towards improving the current lease up rate. It is
anticipated that with the downturn in the economy, more landlords will contact the
CCHA to list their unit and make it available to qualified program participants that
have received a Section 8 HCV Program Voucher.
Indicator 14-Family Self Sufficiency (FSS) - Since 1999 the CCHA has been
awarded approximately $521,900 to assist Section 8 HCVP participants achieve
their goal of self sufficiency. In April, 2010 the CCHA received notification from
HUD that it has received funding in the amount of $65,558 to continue FSS
Coordinator services that will be provided by Saint Joseph’s Center. On June 28,
2010 the City Council approved a contract with St. Joseph’s Center to provide
case management, needs assessment, job development services and supportive
service referrals for the FSS participants. Over the past year participation in the
FSS Program has increased and the FSS Coordinator continues to provide these
services. A total of forty-five (45) households have participated in FSS. Of this
number, fourteen (14) have graduated. There are currently nineteen (19)
households enrolled in the program.
ATTACHMENT 1
3form HUD-52648 (8/2000)
ref. 24 CFR Part 985 Page 1 of 4
Previous edition is obsolete
U.S. Department of Housing
and Urban Development
Office of Public and Indian Housing
Section 8 Management Assessment
Program (SEMAP)
Certification
OMB Approval No. 2577-0215 (exp. 1/31/2010)
Public reporting burden for this collection of information is estimated to average 12 hours per response, including the time for reviewing instructions,
searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. This agency may
not conduct or sponsor, and you are not required to respond to, a collection of information unless it displays a currently valid OMB control number.
This collection of information is required by 24 CFR sec 985.101 which requires a Public Housing Agency (PHA) administering a Section 8 tenant-based
assistance program to submit an annual SEMAP Certification within 60 days after the end of its fiscal year. The information from the PHA concerns the
performance of the PHA and provides assurance that there is no evidence of seriously deficient performance. HUD uses the information and other data
to assess PHA management capabilities and deficiencies, and to assign an overall performance rating to the PHA. Responses are mandatory and the
information collected does not lend itself to confidentiality.
Performance Indicators
1. Selection from the Waiting List. (24 CFR 982.54(d)(1) and 982.204(a))
(a) The PHA has written policies in its administrative plan for selecting applicants from the waiting list.
PHA Response Yes No
(b) The PHA’s quality control samples of applicants reaching the top of the waiting list and of admissions show that at least 98% of the families in the
samples were selected from the waiting list for admission in accordance with the PHA’s policies and met the selection criteria that determined their places
on the waiting list and their order of selection.
PHA Response Yes No
2. Reasonable Rent. (24 CFR 982.4, 982.54(d)(15), 982.158(f)(7) and 982.507)
(a) The PHA has and implements a reasonable written method to determine and document for each unit leased that the rent to owner is reasonable based
on current rents for comparable unassisted units (i) at the time of initial leasing, (ii) before any increase in the rent to owner, and (iii) at the HAP contract
anniversary if there is a 5 percent decrease in the published FMR in effect 60 days before the HAP contract anniversary. The PHA’s method takes into
consideration the location, size, type, quality, and age of the program unit and of similar unassisted units, and any amenities, housing services,
maintenance or utilities provided by the owners.
PHA Response Yes No
(b) The PHA’s quality control sample of tenant files for which a determination of reasonable rent was required shows that the PHA followed its written
method to determine reasonable rent and documented its determination that the rent to owner is reasonable as required for (check one):
PHA Response At least 98% of units sampled 80 to 97% of units sampled Less than 80% of units sampled
3. Determination of Adjusted Income. (24 CFR part 5, subpart F and 24 CFR 982.516)
The PHA’s quality control sample of tenant files shows that at the time of admission and reexamination, the PHA properly obtained third party verification
of adjusted income or documented why third party verification was not available; used the verified information in determining adjusted income; properly
attributed allowances for expenses; and, where the family is responsible for utilities under the lease, the PHA used the appropriate utility allowances for
the unit leased in determining the gross rent for (check one):
PHA Response At least 90% of files sampled 80 to 89% of files sampled Less than 80% of files sampled
4. Utility Allowance Schedule. (24 CFR 982.517)
The PHA maintains an up-to-date utility allowance schedule. The PHA reviewed utility rate data that it obtained within the last 12 months, and adjusted
its utility allowance schedule if there has been a change of 10% or more in a utility rate since the last time the utility allowance schedule was revised.
PHA Response Yes No
5. HQS Quality Control Inspections. (24 CFR 982.405(b))
A PHA supervisor (or other qualified person) reinspected a sample of units during the PHA fiscal year, which met the minimum sample size required by
HUD (see 24 CFR 985.2), for quality control of HQS inspections. The PHA supervisor’s reinspected sample was drawn from recently completed HQS
inspections and represents a cross section of neighborhoods and the work of a cross section of inspectors.
PHA Response Yes No
6. HQS Enforcement. (24 CFR 982.404)
The PHA’s quality control sample of case files with failed HQS inspections shows that, for all cases sampled, any cited life-threatening HQS deficiencies
were corrected within 24 hours from the inspection and, all other cited HQS deficiencies were corrected within no more than 30 calendar days from the
inspection or any PHA-approved extension, or, if HQS deficiencies were not corrected within the required time frame, the PHA stopped housing assistance
payments beginning no later than the first of the month following the correction period, or took prompt and vigorous action to enforce the family obligations
for (check one):
PHA Response At least 98% of cases sampled Less than 98% of cases sampled
Instructions Respond to this certification form using the PHA’s actual data for the fiscal year just ended.
PHA Name For PHA FY Ending (mm/dd/yyyy) Submission Date (mm/dd/yyyy)
Check here if the PHA expends less than $300,000 a year in Federal awards
Indicators 1 - 7 will not be rated if the PHA expends less than $300,000 a year in Federal awards and its Section 8 programs are not audited
for compliance with regulations by an independent auditor. A PHA that expends less than $300,000 in Federal awards in a year must still
complete the certification for these indicators.
ATTACHMENT 2
4form HUD-52648 (8/2000)
ref. 24 CFR Part 985 Page 2 of 4
Previous edition is obsolete
7. Expanding Housing Opportunities. (24 CFR 982.54(d)(5), 982.153(b)(3) and (b)(4), 982.301(a) and 983.301(b)(4) and (b)(12)).
Applies only to PHAs with jurisdiction in metropolitan FMR areas.
Check here if not applicable
(a) The PHA has a written policy to encourage participation by owners of units outside areas of poverty or minority concentration which clearly delineates
areas in its jurisdiction that the PHA considers areas of poverty or minority concentration, and which includes actions the PHA will take to encourage
owner participation.
PHA Response Yes No
(b) The PHA has documentation that shows that it took actions indicated in its written policy to encourage participation by owners outside areas of poverty
and minority concentration.
PHA Response Yes No
(c) The PHA has prepared maps that show various areas, both within and neighboring its jurisdiction, with housing opportunities outside areas of poverty
and minority concentration; the PHA has assembled information about job opportunities, schools and services in these areas; and the PHA uses the maps
and related information when briefing voucher holders.
PHA Response Yes No
(d) The PHA’s information packet for voucher holders contains either a list of owners who are willing to lease, or properties available for lease, under
the voucher program, or a list of other organizations that will help families find units and the list includes properties or organizations that operate outside
areas of poverty or minority concentration.
PHA Response Yes No
(e) The PHA’s information packet includes an explanation of how portability works and includes a list of neighboring PHAs with the name, address and
telephone number of a portability contact person at each.
PHA Response Yes No
(f) The PHA has analyzed whether voucher holders have experienced difficulties in finding housing outside areas of poverty or minority concentration
and, where such difficulties were found, the PHA has considered whether it is appropriate to seek approval of exception payment standard amounts in
any part of its jurisdiction and has sought HUD approval when necessary.
PHA Response Yes No
8. Payment Standards. The PHA has adopted current payment standards for the voucher program by unit size for each FMR area in the PHA jurisdiction
and, if applicable, for each PHA-designated part of an FMR area, which do not exceed 110 percent of the current applicable FMR and which are not
less than 90 percent of the current FMR (unless a lower percent is approved by HUD). (24 CFR 982.503)
PHA Response Yes No
Enter current FMRs and payment standards (PS)
0-BR FMR _________ 1-BR FMR _________ 2-BR FMR _________ 3-BR FMR ________ 4-BR FMR _________
PS _______________ PS _______________ PS _______________ PS _______________ PS _______________
If the PHA has jurisdiction in more than one FMR area, and/or if the PHA has established separate payment standards for a PHA-designated
part of an FMR area, attach similar FMR and payment standard comparisons for each FMR area and designated area.
9. Annual Reexaminations. The PHA completes a reexamination for each participating family at least every 12 months. (24 CFR 982.516)
PHA Response Yes No
10. Correct Tenant Rent Calculations. The PHA correctly calculates tenant rent in the rental certificate program and the family rent to owner in the rental
voucher program. (24 CFR 982, Subpart K)
PHA Response Yes No
11. Precontract HQS Inspections. Each newly leased unit passed HQS inspection before the beginning date of the assisted lease and HAP contract. (24 CFR
982.305)
PHA Response Yes No
12. Annual HQS Inspections. The PHA inspects each unit under contract at least annually. (24 CFR 982.405(a))
PHA Response Yes No
13. Lease-Up. The PHA executes assistance contracts on behalf of eligible families for the number of units that has been under budget for at least one year.
PHA Response Yes No
14a. Family Self-Sufficiency Enrollment. The PHA has enrolled families in FSS as required. (24 CFR 984.105)
Applies only to PHAs required to administer an FSS program.
Check here if not applicable
PHA Response
a. Number of mandatory FSS slots (Count units funded under the FY 1992 FSS incentive awards and in FY 1993 and later
through 10/20/1998. Exclude units funded in connection with Section 8 and Section 23 project-based contract
terminations; public housing demolition, disposition and replacement; HUD multifamily property sales; prepaid or
terminated mortgages under section 236 or section 221(d)(3); and Section 8 renewal funding. Subtract the number of
families that successfully completed their contracts on or after 10/21/1998.)
or, Number of mandatory FSS slots under HUD-approved exception
ATTACHMENT 2
5form HUD-52648 (8/2000)
ref. 24 CFR Part 985 Page 3 of 4
Previous edition is obsolete
b. Number of FSS families currently enrolled
c. Portability: If you are the initial PHA, enter the number of families currently enrolled in your FSS program, but who
have moved under portability and whose Section 8 assistance is administered by another PHA
Percent of FSS slots filled (b + c divided by a)
14b. Percent of FSS Participants with Escrow Account Balances. The PHA has made progress in supporting family self-sufficiency as measured by the
percent of currently enrolled FSS families with escrow account balances. (24 CFR 984.305)
Applies only to PHAs required to administer an FSS program.
Check here if not applicable
PHA Response Yes No
Portability: If you are the initial PHA, enter the number of families with FSS escrow accounts currently enrolled in your
FSS program, but who have moved under portability and whose Section 8 assistance is administered by another PHA
Deconcentration Bonus Indicator (Optional and only for PHAs with jurisdiction in metropolitan FMR areas).
The PHA is submitting with this certification data which show that:
(1) Half or more of all Section 8 families with children assisted by the PHA in its principal operating area resided in low poverty census tracts at the end of the last
PHA FY;
(2) The percent of Section 8 mover families with children who moved to low poverty census tracts in the PHA’s principal operating area during the last PHA FY
is at least two percentage points higher than the percent of all Section 8 families with children who resided in low poverty census tracts at the end of the last
PHA FY;
or
(3) The percent of Section 8 mover families with children who moved to low poverty census tracts in the PHA’s principal operating area over the last two
PHA FYs is at least two percentage points higher than the percent of all Section 8 families with children who resided in low poverty census tracts at the
end of the second to last PHA FY.
PHA Response Yes No If yes, attach completed deconcentration bonus indicator addendum.
I hereby certify that, to the best of my knowledge, the above responses under the Section 8 Management Assessment Program (SEMAP) are true and accurate
for the PHA fiscal year indicated above. I also certify that, to my present knowledge, there is not evidence to indicate seriously deficient performance that casts
doubt on the PHA’s capacity to administer Section 8 rental assistance in accordance with Federal law and regulations.
Warning: HUD will prosecute false claims and statements. Conviction may result in criminal and/or civil penalties. (18 U.S.C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802)
Executive Director, signature Chairperson, Board of Commissioners, signature
___________________________________________________________ _________________________________________________________
Date (mm/dd/yyyy) ____________________________________________ Date (mm/dd/yyyy) _________________________________________
The PHA may include with its SEMAP certification any information bearing on the accuracy or completeness of the information used by the PHA in providing its
certification.
ATTACHMENT 2
6form HUD-52648 (8/2000)
ref. 24 CFR Part 985 Page 4 of 4
Previous edition is obsolete
SEMAP Certification - Addendum for Reporting Data for Deconcentration Bonus Indicator
Date (mm/dd/yyyy) ____________________________
PHA Name ______________________________________________________________________________________
Principal Operating Area of PHA _____________________________________________________________________
(The geographic entity for which the Census tabulates data)
Special Instructions for State or regional PHAs. Complete a copy of this addendum for each metropolitan area or portion of a metropolitan area (i.e., principal
operating areas) where the PHA has assisted 20 or more Section 8 families with children in the last completed PHA FY. HUD will rate the areas separately
and the separate ratings will then be weighted by the number of assisted families with children in each area and averaged to determine bonus points.
1990 Census Poverty Rate of Principal Operating Area __________________________________________________
Criteria to Obtain Deconcentration Indicator Bonus Points
To qualify for bonus points, a PHA must complete the requested information and answer yes for only one of the 3 criteria below. However,
State and regional PHAs must always complete line 1) b for each metropolitan principal operating area.
1) __________ a. Number of Section 8 families with children assisted by the PHA in its principal operating area at the end of the last PHA
FY who live in low poverty census tracts. A low poverty census tract is a tract with a poverty rate at or below the overall
poverty rate for the principal operating area of the PHA, or at or below 10% whichever is greater.
__________ b. Total Section 8 families with children assisted by the PHA in its principal operating area at the end of the last PHA FY.
__________ c. Percent of all Section 8 families with children residing in low poverty census tracts in the PHA’s principal operating area
at the end of the last PHA FY (line a divided by line b).
Is line c 50% or more? Yes No
2) __________ a. Percent of all Section 8 families with children residing in low poverty census tracts in the PHA's principal operating area
at the end of the last completed PHA FY.
__________ b. Number of Section 8 families with children who moved to low poverty census tracts during the last completed PHA FY.
__________ c. Number of Section 8 families with children who moved during the last completed PHA FY.
__________ d. Percent of all Section 8 mover families with children who moved to low poverty census tracts during the last PHA fiscal
year (line b divided by line c).
Is line d at least two percentage points higher than line a? Yes No
3) __________ a. Percent of all Section 8 families with children residing in low poverty census tracts in the PHA's principal operating area
at the end of the second to last completed PHA FY.
__________ b. Number of Section 8 families with children who moved to low poverty census tracts during the last two completed PHA FYs.
__________ c. Number of Section 8 families with children who moved during the last two completed PHA FYs.
__________ d. Percent of all Section 8 mover families with children who moved to low poverty census tracts over the last two completed
PHA FYs (line b divided by line c).
Is line d at least two percentage points higher than line a? Yes No
If one of the 3 criteria above is met, the PHA may be eligible for 5 bonus points.
See instructions above concerning bonus points for State and regional PHAs.
ATTACHMENT 2
7
Enterprise Income Verification (EIV)
Security Policy and Procedures
The Enterprise Income Verification System (EIV)
The EIV system is intended to provide a single source of income-related data to
PHAs for use in verifying the income reported by participants in the various
assisted housing programs. The Office of Public and Indian Housing (PIH) is
responsible for administering and maintaining the EIV system.
A. Types of Upfront Verification of Income Provided by EIV
The EIV system compares the participant income data obtained from various
sources including:
o Participant-supplied income data captured on Form HUD-50058 and
maintained in the PIC databases;
o U.S. Department of Health and Human Services, National Directory of
New Hires (NDNH) data. NDNH becomes the single source for wage,
unemployment insurance benefit information, and the new hire
(employment) information;
o Social Security and Supplemental Security Income from the Social
Security Administration (information formerly accessed through TASS);
and
o User profile information from the PIC database.
B. What EIV Participant Data Is Used For
EIV data is the first level in the hierarchy of income verification. The EIV data
may be used in the following way:
o To verify a participant’s eligibility for participation in a HUD rental
assistance program and to determine the level of assistance the
participant is entitled to receive; and
o No adverse action can be taken against a participant until the PHA has
independently verified the EIV, and the participant has been granted an
opportunity to contest any adverse findings through the established
grievance hearing or other legal procedures.
ATTACHMENT 3
8
Applicability
The procedures in this document apply to all Culver City Housing Agency
(CCHA) staff that access EIV data.
Purpose
The purpose of this document is to establish the CCHA policies and procedures
to assure that the practices, controls and safeguards used by the CCHA are in
compliance with the Federal laws regarding the protection of this information.
Privacy Act
The data provided via the EIV system will be protected to ensure that it is only
used for official purposes and not disclosed in any way that would violate the
privacy of the individuals represented in the system data. Privacy of data and
data security for computer systems are covered by a variety of Federal laws and
regulations. The Privacy Act of 1974 as amended, 5 U.S.C. 552 (a), is one such
regulation. The full text of the Privacy Act can be accessed at
http://www.usdoj.gov/fo is/privstat.htm.
C. Examples of Privacy Act Violations
The CCHA will not rely entirely upon staff to read and understand the Privacy
Act. To ensure that staff has a complete understanding of the Privacy Act and
how seemly harmless actions may be violations, examples of Privacy Act
violations will be provided during security awareness training. The following
example of a security violation was explained during the HUD Satellite Broadcast
introducing the EIV system:
EIV data can only be viewed by authorized PHA staff and the individual adult
who the information pertains to. This means that EIV data for an adult household
member in a participant family cannot be shared with another adult household
member of the participant family (even the head of household) unless that family
member is present or signs a waiver authorizing the other family member to view
their EIV information. The Privacy Act protects the privacy of each adult family
member from any unauthorized person viewing their EIV data, even another
family member. However, EIV data for minor children may be viewed by the head
of household.
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D. CCHA Security Officer(s)
A CCHA EIV Security Officer(s) is responsible for ensuring that proper technical,
physical, and administrative safeguards are in place and enforced. The duties of
the CCHA EIV Security Officer(s) are as follows:
o Conducts quarterly reviews of all User IDs issued to determine if the users
still have a valid need to access the EIV data and modifies or revokes
access rights as appropriate;
o At the request of the Director, updates the EIV Security Policy and
Procedures;
o Maintains a key control log or audits the key control log to ensure that one
is properly maintained (CCHA locking file cabinets);
o Maintains a list of users who can access the restricted areas;
o Assures that a copy of Form HUD-9886 has been signed by each member
of the household, age 18 years or older, and is in the household file;
o Ensures compliance with the PHA security policies and procedures
outlined in this document;
o Communicates security information and requirements to appropriate
personnel, including coordinating and conducting security awareness
training sessions;
o Ensures that any infractions of security procedures are promptly reported
to Department Director for investigation and enforcement; and
o Ensures that all EIV records and forms (i.e. signed user agreements) are
kept and updated as needed.
E. Security Awareness Training
Security awareness training is a crucial aspect of ensuring the security of the EIV
system and data. Users and potential users will be made aware of the
importance of respecting the privacy of data, following established procedures to
maintain privacy and security, and notifying management in the event of a
security or privacy violation.
In addition to security awareness training, the CCHA EIV Security Officer(s) will
communicate security information and requirements to appropriate personnel.
Security awareness training will be provided to each employee upon granting
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access to the EIV system. Thereafter, annual security awareness refresher
training will be provided to each employee with EIV access.
The Public Housing EIV Security Officer(s) will conduct security awareness
training in the following manner:
o The trainer and the employee will both sign a certification that EIV security
training has been provided. The training certification and a record of the
training material provided at the awareness training will be kept in the
Public Housing EIV Security Binder;
o At the end of the training, each employee will also sign the EIV Rules of
Behavior and User Agreement Form. One copy will be given to the
employee to be placed in their desk manual and one copy will be retained
in the CCHA EIV Security Binder. The forms will be updated once a year
at the refresher training;
o The CCHA EIV Security Officer(s) will limit the security awareness training
to security awareness and compliance issues only. Instructing staff on
how to navigate in the EIV modules and how to run reports or to interpret
data is the responsibility of the Supervisor or designated trainer; and
o Examples of potential Privacy Act and security violations will be provided
during the training.
F. Technical Safeguards
The purpose of these technical safeguards is as follows:
• To reduce the risk of a security violation related to the EIV system’s
software, network, or applications;
• To identify and authenticate all users seeking access to the EIV system;
• To deter and detect attempts to access the system without authorization;
• To monitor the user activity of the EIV system;
• Each user is required to have their own User ID and Password;
• The User ID identifies the PHA’s and tenant information that the user is
authorized to access;
• Passwords are encrypted and the password file is protected from
unauthorized access;
• The system forces all user to change their password every 21 days and
limit the reuse of previous passwords;
• After three unsuccessful attempts to log in, the User ID is locked and the
user must contact the HUD System Administrator to have the password
reset; and
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• Online warning messages that inform the user of the civil and criminal
penalties associated with unauthorized use of the EIV system will be
displayed.
In addition, the CCHA will follow the following technical security requirement:
• The CCHA will not save EIV data to a computer hard drive or any other
automated information system (i.e. network drive, disk or CD);
• CCHA staff will not leave their computer unattended with EIV data
displayed on the screen; and
• CCHA staff will not log in on another user’s ID.
G. Administrative Safeguards
The Public Housing EIV Security Officer(s) will maintain security-related records
and monitor programmatic security issues. They will also adhere to the following
administrative safeguards:
• Ensure that all users who have access to EIV data have an Access
Authorization Form signed by the Director of Housing on file;
• Ensure that all users who access the EIV system have a current signed
Rules of Behavior and User Agreement on file;
• Conduct quarterly reviews of all User IDs to determine if the user still has
a valid need to access the EIV data; and
• Ensure the access rights are modified or revoked as appropriate.
The Public Housing EIV Security Officer(s) will maintain the following EIV
security records and forms:
• EIV Rules of Behavior and User Agreement Forms;
• EIV Access Authorization Forms;
• EIV Disposal Records List;
• EIV security violation information;
• Key control logs for secure areas or filing cabinets;
• EIV Security Awareness Training Records;
• Records of internal audits to ensure that Form HUD-9886 has been signed
by each adult member of the household and is kept in the Confidential
Resident File; and
• A record of all users who have approved access to EIV data, including the
date access was granted and the date access was terminated.
H. Physical Safeguards
The purpose of physical safeguards is to provide barriers between
unauthorized persons and documents containing private data.
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Confidential Participant Files
All EIV data will be printed and saved in the “Confidential” participant file. Each
participant file will be clearly labeled on the front cover as “Confidential”. This
alerts staff that this file contains EIV data that must be protected at all times
when not in use.
Locking File Cabinets for Confidential Files
Even though the CCHA has a monitored office building, persons unauthorized to
view EIV data, such as maintenance staff, janitorial staff, or temporary staff, have
access to the office spaces. In office settings where any staff other than the staff
responsible for the participant file or their supervisor has access to the office, all
confidential participant files will be kept in locking file cabinets. The cabinets will
be locked whenever the responsible staff leaves the workspace.
Hard Copy Security Violations
The CCHA will handle EIV data in such a manner that it does not become
misplaced or available to unauthorized personnel. Any marked confidential
participant file will contain EIV data. Therefore the file cannot be viewed by any
personnel that are not expressly authorized (i.e. staff in charge of the file, the
supervisor of the staff in charge of the file, the CCHA EIV Security Officer(s), or
the CCHA Housing Internal Auditor) and who do not have both an Access
Authorization Form and a Rules of Behavior and User Agreement on file with the
CCHA EIV Security Officer(s).
Viewing the EIV information of a participant outside of a staff’s caseload
assignment is considered a security violation for both the staff unlawfully viewing
the EIV information and for the staff that left the information unattended. Unless a
supervisor has specifically authorized staff to view another staff’s EIV data, this is
expressly prohibited.
Disposal of EIV Information
EIV data should be destroyed as soon as it has served its purpose or as
prescribed by the program administrators’s policy and procedures. All EIV
originals and any documents created in association with their use should be
shredded to prevent the reconstruction of the contents. Large amounts of
shredded paper should not be allowed to accumulate in the bin. It is important
that a log or register be maintained of all documents shredded or destroyed.
I. Reporting Improper Disclosures
Recognition, reporting and disciplinary action in response to security violations
are crucial to successfully maintaining the security and privacy of the EIV system.
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Security violations may include the following:
• Disclosure of private data;
• Attempts to access unauthorized data; and
• Sharing of User IDs and passwords.
Upon discovery of a possible improper disclosure of EIV information or another
security violation by a Public Housing Employee or any other person, the
individual making the observation or receiving the information should contact the
CCHA EIV Security Officer(s). The CCHA EIV Security Officer(s) will document
all improper disclosures in writing on a security disclosure form, providing details
including who was involved, what was disclosed, how the disclosure occurred,
and where it occurred.
The following contacts will be made:
• The CCHA EIV Security Officer(s) will contact and provide the Director of
Public Housing with the written documentation of the security violation;
• The Administrator or his designee will provide the HUD Field Office Public
Housing Director with the written documentation; and
• The HUD Field Office Public Housing Director, upon receipt of the
documentation, will make a determination regarding the referral and
provision of the written documentation to the Headquarters EIV
Coordinator and/or Public Housing EIV Security Officer(s) for further
review and follow-up action.
J. Safeguards Provided by the Privacy Act
The Privacy Act provides safeguards for individuals against invasion of
privacy by requiring Federal agencies, except as otherwise provided by law
or regulation, to:
1. Permit individuals to know what records pertaining to them are collected,
maintained, used or disseminated;
2. Allow individuals to prevent records pertaining to them (obtained for a
particular purpose) from being used or made available for another
purpose without their consent;
3. Permit individuals to gain access to information pertaining to them, obtain
a copy of all or any portions thereof, and correct or amend such records;
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4. Collect, maintain, use or disseminate personally identifiable information in
a manner that ensures the information is current and accurate, and that
adequate safeguards are provided to prevent misuses of such
information;
5. Permit exemption from the requirements of the Act only where an
important public policy need exists as determined by specific statutory
authority; and
6. Be subject to a civil suit for any damages that occur as a result of action
that violates any individual’s rights under this Act.
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