On February 13, PHADA—along with NAHRO and the MTW Collaborative—wrote to HUD Principal Deputy Assistant Secretary Ben Hobbs to share our collective concerns regarding HUD’s recent guidance on the EIV-SAVE tenant matching report. A copy of the letter is available on PHADA’s website. The Association previously reported on the EIV-SAVE system in the February 4 edition of the Advocate.
The letter raises concerns about both the feasibility and the legality of the guidance. Regarding feasibility, it notes that completing required actions within HUD’s timeframe is impossible, and that the system’s data appear inaccurate and its terminology is unclear.
Concerning the legality of the guidance, the letter notes that requiring participants to provide evidence of eligible status more than once is contrary to Departmental regulations. It is also contrary to regulation to require individuals over age 62 to provide any documentation of their citizenship status beyond a signed declaration. The industry communication also notes that the guidance letter is vague because it provides “unclear or contradictory timeframes.”
PHADA will continue to advocate for maximum flexibility for HAs to comply with any new HUD guidance, and for that guidance to adhere to both regulation and statute. Members wishing to share their feedback on using the EIV-SAVE system may contact the PHADA policy team at: policy@phada.org.