But did you verify it?
Because “they told me” is not a verification method.
There are certain phrases you hear so often in housing that they probably deserve their own coffee mugs.
“Is it documented?”
“Where’s the verification?”
“Did you check EIV?”
And, of course…
BUT DID YOU VERIFY IT?
It’s funny because every housing professional knows exactly how that conversation goes.
A resident tells us they stopped working.
Okay. No big deal...
But did you verify it?
Someone reports a new source of income.
But did you verify it?
The file contains a number somebody entered six months ago, everyone has been carrying it forward ever since, and nobody quite remembers where it originally came from.
Well…
But did you verify it?
Verification is woven into practically everything we do in assisted housing!
But as PHAs continue preparing for HOTMA, this is actually a really good time to stop and ask a bigger question:
Do our staff understand verification, or have we simply gotten really good at collecting paperwork?
Those are not necessarily the same thing.
A Thick File Isn’t Necessarily a Good File
One of the habits housing professionals can fall into is thinking that more documentation automatically equals better compliance.
Six pay stubs.
Three bank statements.
An EIV report.
A letter from the employer.
A handwritten statement from the family.
Maybe a screenshot for good measure.
At some point, we’re one step away from requesting a notarized statement from the applicant’s second-grade teacher. 😂
But the purpose of verification isn’t to see how much paper we can put into a tenant file.
The purpose is to obtain reliable information that supports the eligibility, income, asset, deduction, rent, or assistance determination we’re making.
So the question shouldn’t be:
How much documentation do we have?
The better question is:
Do we have the right documentation for the determination we’re making?
That’s a very different question.
EIV Is a Tool — You Still Have to Understand What It’s Telling You
EIV is one of the most valuable verification tools available to housing professionals.
But pulling an EIV report and putting it in the file isn’t the same thing as reviewing it.
Staff still need to understand:
What information is being reported?
Does it match what the family reported?
Is the information representative of current income?
Is there a discrepancy that needs to be resolved?
Is additional verification required?
What does our policy require us to do next?
And then, of course:
Did we document what we did?
Because the reviewer coming behind you shouldn’t need detective training to figure out why you calculated the family’s income the way you did.
HUD Verification Hierarchy
Start at the Top — But Know When the Rules Allow Something Different
HUD’s verification hierarchy generally ranks verification methods from Level 6, the highest level, down to Level 1.
But here’s the important part:
This does NOT mean staff should collect all six levels of verification.
The goal is to use the appropriate verification method for the information being verified and understand when HUD permits another method.
🟢 LEVEL 6 — HUD EIV Upfront Income Verification (UIV)
RANK: HIGHEST
What it is: Income information obtained through HUD’s Enterprise Income Verification (EIV) system.
Think: EIV Income Report and applicable HUD EIV data.
Staff Takeaway: EIV is a primary verification source for applicable existing families and transactions.
But staff still need to understand what the information establishes, whether it is representative of current income, whether there is conflicting information, and whether additional documentation is required.
Remember:
Simply printing an EIV report does not mean the verification process is complete.
🟢 LEVEL 5 — Non-EIV Upfront Income Verification (UIV)
RANK: HIGHEST
What it is: Income information obtained electronically from an independent source other than HUD EIV.
Examples may include: The Work Number or an applicable state-administered electronic benefit or income system.
Staff Takeaway: This is independently obtained electronic information and ranks very highly within HUD’s verification hierarchy.
🟢 LEVEL 4 — Written Third-Party Documentation
RANK: HIGH
What it is: Original or authentic documentation generated by a third-party source and provided to the PHA.
Examples may include:
Pay statements
Benefit letters
Bank statements
Pension statements
Other appropriate third-party-generated records
Level 4 can also include EIV + family self-certification in circumstances permitted by HUD when the family agrees that the EIV information is accurate and representative of current income.
Staff Takeaway: This is where a lot of everyday file verification happens.
But don’t automatically request five documents when appropriate documentation already satisfies the applicable requirement.
More paperwork does not automatically equal better verification.
🟡 LEVEL 3 — Written Third-Party Verification Form
RANK: MEDIUM
What it is: The PHA obtains written verification directly from the third-party source.
Examples: An employment verification sent directly to an employer or a verification request sent to a financial institution, benefit provider, or other third party.
Staff Takeaway:This method may be appropriate when acceptable higher-level verification is unavailable or when additional verification is required.
Make sure the file contains the documentation HUD and your agency’s procedures require to support why the method was used.
🟡 LEVEL 2 — Oral Third-Party Verification
RANK: MEDIUM
What it is: PHA staff obtain verification directly from the third-party source through oral communication.
Examples: Calling an employer, financial institution, benefit provider, or other appropriate third party to confirm information.
Staff Takeaway: If you verify something orally:
Document the conversation in the tenant file.
The documentation should allow another reviewer to understand who was contacted, when the contact occurred, and what information was verified.
🔴 LEVEL 1 — Self-Certification
RANK: LOWEST — BUT NOT ALWAYS “BAD”
What it is:The family provides a certification regarding the information being verified.
Staff Takeaway:Self-certification may generally be used when third-party verification cannot be obtained or when HUD specifically permits self-certification for the information involved.
That second part matters.
There are circumstances where HUD expressly allows self-certification.
So don’t automatically interpret:
Level 1 = noncompliant.
Instead ask:
Was self-certification an allowable verification method for this particular item and transaction?
WAIT
Don’t Turn This Into Another Checklist
Here’s where staff needs to be careful.
The hierarchy does not mean:
☐ Get EIV
☐ Get electronic verification
☐ Get pay stubs
☐ Send an employer verification
☐ Call the employer
☐ Get a self-certification
😂 Please don’t do that.
The purpose of the hierarchy is to establish the order of acceptability of verification methods, not to make staff collect six different versions of the same information!
There are also important exceptions and special rules, including circumstances involving Safe Harbor income determinations, permitted self-certifications, applicants, fixed income, interim reexaminations, and other program-specific requirements.
The better question is:
What am I verifying, what verification method does HUD require or permit for this situation, and does my file document how I reached the determination?
Annual Does Not Automatically Equal Interim
This is another area I want staff to pay attention to as HOTMA procedures are updated.
Don’t assume the verification procedure you use for an annual reexamination automatically applies exactly the same way to every interim reexamination.
HUD’s HOTMA guidance changed certain EIV requirements surrounding interim reexaminations.
That means an instruction someone learned years ago such as:
“Always print EIV.”
shouldn’t automatically become the procedure forever simply because that’s how the person was originally trained.
This is exactly why staff need to understand why they are performing a verification step instead of simply memorizing the step.
Your current HUD requirements and approved agency policies should drive the process.
Not institutional muscle memory.
“That’s How We’ve Always Done It” Is Not a HUD Citation
You knew this one was coming. 😂
Every organization has procedures that survive long after anyone remembers why they started.
Sometimes they’re completely appropriate.
Sometimes they’re established agency policy.
Sometimes HUD used to require them.
And sometimes…
"we’ve just been doing it for twelve years because Cheryl trained Denise, Denise trained Amanda, Amanda trained Marcus, and nobody has questioned Cheryl since 2014."
Someone had to say it!
Luckily, the only way to move forward now is to learn it the right way, and stop playing telephone of who said what, when, why, where, or how and get the facts from the source directly.
HOTMA gives agencies an excellent opportunity to revisit those practices.
When you’re updating your ACOP or Administrative Plan, don’t only ask:
What new HOTMA language needs to go into our policy?
Also ask:
Does what our policy says actually match what our staff does?
That gap can become a much bigger compliance problem than imperfect wording in a policy manual.
Let’s Talk About Pay Stubs
This is another great example.
Staff sometimes become attached to a particular number of pay stubs because that’s simply what they’ve always requested.
Instead, staff should understand the current HUD verification requirements, the applicable documentation standard, and their agency’s adopted verification procedures.
That doesn’t mean agencies should suddenly throw out their verification procedures.
It means you should know why you’re requesting what you’re requesting.
If your Administrative Plan or ACOP establishes a particular compliant procedure, staff need to follow it.
But if you’re collecting something solely because someone once said HUD required it…
Go find the requirement.
You may discover your procedure needs updating.
Three Verification Reminders Worth Bookmarking
EIV Isn’t Your Starting Point for Every Household or Every Transaction
For example, EIV is not used for applicants in exactly the same manner as it is for existing assisted families.
Staff need to follow the verification requirements applicable to the transaction they are actually processing.
Pay Attention to Level 4 Documentation
HOTMA guidance changed some of the rules surrounding acceptable written third-party documentation, including applicable document-age standards.
Don’t keep requesting documents solely because:
“That’s how we’ve always done it.”
Know what HUD currently requires and what your agency’s policies require.
Self-Certification Isn’t Automatically a Compliance Failure
HUD specifically permits self-certification in certain circumstances.
The real question is whether it was permitted for the information being verified and whether the file supports its use.
Verification Should Tell the Story of the Calculation
Here’s one of my favorite ways to QC a tenant file:
Pretend you know absolutely nothing about the family.
Open the file.
Then try to answer:
Who is in the household?
What income did the family report?
What did the agency verify?
What verification source was used?
Were there discrepancies?
How were they resolved?
What assets and deductions were considered?
How did we arrive at annual adjusted income?
How did that result in the rent or assistance determination?
You shouldn’t need the staff member who processed the file standing beside you explaining what happened.
The file should tell the story.
Good case notes help.
Good verification helps.
Consistent procedures help.
And good QC catches the places where that story doesn’t quite make sense.
The “But Did You Verify It?” Challenge
Here’s something simple you can do at your next staff meeting.
Pull three recently completed files.
This isn’t disciplinary.
It’s training.
Choose one income, asset, deduction, household-composition, or other determination from each file.
Then have the team answer:
1. What did the family report?
2. What did we determine?
3. What information actually required verification?
4. Which verification method did we use?
5. Was that verification method appropriate for this transaction?
6. Is the documentation current enough for the applicable HUD requirement?
7. Did we identify and resolve any discrepancies?
8. Does our ACOP or Administrative Plan support the procedure staff followed?
9. Could another staff member follow the file without asking the original processor what happened?
And finally…
10. BUT DID YOU VERIFY IT?
If everybody can confidently walk through those questions, fantastic.
If the room suddenly gets really quiet…
Congratulations.
You just found your next staff training topic. 😂
Coffee & Compliance Quick Check
As your agency continues preparing for HOTMA, take a look beyond the policy language.
Ask whether your verification process is:
✓ CURRENT
Based on current HUD requirements rather than outdated habits.
✓ CONSISTENT
Staff aren’t handling identical situations five different ways.
✓ SUPPORTED
Your ACOP or Administrative Plan reflects the procedures being used.
✓ APPROPRIATE
Staff are using the correct verification method for the information and transaction involved.
✓ DOCUMENTED
Another reviewer can understand what happened without guessing.
✓ EFFICIENT
You aren’t collecting unnecessary paperwork simply because you’ve always collected it.
The Part We Can’t Forget
Verification sounds incredibly administrative.
Reports.
Documents.
Calculations.
Signatures.
Screens.
Checklists.
But the information we’re verifying ultimately affects something very real:
A family’s housing.
That’s why getting it right matters.
We want files accurate enough to withstand review, procedures staff can actually follow, and documentation strong enough to support the decisions we’re making — without creating unnecessary administrative burden for staff or families.
Compliance shouldn’t mean collecting everything we possibly can.
It should mean knowing:
What do we need?
Why do we need it?
What does it tell us?
What are we supposed to do with it?
And when you’re not sure?
Well…
You already know what I’m going to ask.
BUT DID YOU VERIFY IT?
"I'm out of Coffee... see you next time!" ~ Lisa
HUD Reference & Compliance Note
Primary Reference: HUD PIH Notice 2023-27, Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016, including Section J.5 and Table J2, together with subsequent HUD HOTMA implementation guidance and FAQs.
Verification requirements may vary depending on the program, transaction type, information being verified, and subsequent HUD guidance. PHAs should consult current HUD regulations and guidance and their approved ACOP or Administrative Plan before changing verification procedures.
This article is intended for general educational purposes and does not replace HUD regulations, notices, program-specific guidance, or an agency’s approved policies.
☕ Coffee & Compliance with Lisa Housing talk, helpful tips & a little coffee and humor along the way.
Virginia Viles Services, LLC Turning Complex HUD Requirements into Confident Decisions.
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