The Processing of HUD (Fraud) Repayments Edgewood Management PresentationAPRIL 2012

Goals of this Webinar

•How to process new fraud certifications

•How to complete a repayment agreement

•How to post payments to HAP repayment ledgers

•View the HAP process•How to add ‘existing fraud balances’

If you find a discrepancy how do you proceed• In compliance with HUD guidelines, all Tenant income is to be

verified through the EIV system within 90 days of move in and at all annual and interim re-certifications.

• Any income discrepancy greater than $2,400 in a year must be fully investigated, the correct Tenant income determined, and any overpaid subsidy recovered from the resident.

• Overpaid subsidy cases will result either in a repayment plan, termination of subsidy or referral to the HUD Office of Inspector General for prosecution.

• It is our policy to not suspend, terminate, reduce, make a final denial of rental assistance or take any other adverse action against an individual based solely on the data in EIV. We are required to look carefully into any discrepancy and confirm or deny the information we get from EIV.

• Therefore, it is imperative that we determine the accuracy of what we believe may be resident misreporting and follow the proper steps to determine the accuracy of the information.

Steps to follow once a discrepancy has been confirmed:

•Tenants can repay amounts due (1) in a lump sum payment; (2) by entering into a repayment agreement with the O/A; or (3) a combination of (1) and (2).•Adjust the Tenant Rent to the proper rent for the first of the month following thefinal meeting with Tenant.•The tenant and O/A must both agree on the terms of the repayment agreement.•Monthly payment: the tenant's monthly payment must be what the tenant can afford to pay based on the family's income. •The monthly payment plus the amount of the tenant's total payment (TTP) at the time the repayment agreement is executed should not exceed 40% of the family's monthly adjusted income.(30% = current month rent + 10%= repayment amount)•Repayment time period is the length of time for repayment by the tenant of the amount owed. Example- the tenant agrees to repay $1,000, and agrees to monthly payments of $25; $1,000/$25= 40 months (time period).•We have the right to terminate subsidy if in our judgment and program rules the Tenant should lose their subsidy. •All subsidy terminations have to be approved by the RPM/AVP/VP. •Our policy is to use subsidy terminations as a last enforcement tool given the legal expenses and time delays such an action will incur.

Actual process-In all Fraud Cases:•You must first correct the financial

information or family composition information that has been misreported on either the financial summary tab or the summary tab for member information.

•This information must be loaded with the absolute correct dates that the actual information changed.

•Effective dates are important as it ties to which type of certification you are going to perform.

There are three types of certifications.

•Termination Fraud Certification-TF

•Correction to a prior Certification due to tenant misreporting *

•Interim certification required due to the date of the tenant misreporting

Termination Fraud Certification

•A termination fraud (TF) certification is a result of a resident moving to program or market rent as a result of an income discrepancy that would make the resident ineligible for the affordable program they originally were eligible for.

•This is the ‘type’ of certification that you would choose in OneSite to process if this were the case.

Type 1=The Termination Fraud certification

Process the certification from the resident at a glance page choose view, then certification tab

Select Termination Fraud (TF) type from the drop down box

The effective date of the certification is the last day of the month before the date of the income discrepancy.

The certification must be final before any repayment agreement can be prepared in the system.

You will be given two options to complete the repayment plan once the certification is finalized. Finish the cert without the plan or initiate the HUD repayment plan at this point.

When you select the Initiate HUD repayment plan option, a pending repayment plan is added to the Repayment plan schedule for the resident. You will need to complete the information and activate the schedule. This repayment plan and ledger will be available using the View repayment ledger link located at the resident’s Certifications tab and the Ledger tab

Type 2=Correction to a prior certification• From the

certification tab you would choose to correct the certification that contains the same date as the information discrepancy date

• Choose More and choose correct beside the incorrect certification.

Must choose ‘Corrects tenant misreporting’

• In order to initiate a repayment plan you must choose this option.

• Remember to check the box ‘initiate repayment’

• Remember to finalize the certification in order to populate the repayment plan information.

• Complete the certification normally

Type 3- Insert a new certification (effective date is not tied to any certification)

• The inserted certification drop down menu does not give the ‘corrects tenant misreporting’ option.

• Therefore, you must mark the ‘initiate repayment plan’ box to force the cert to show in the fraud calculations on the HAP.

• .

Inserted IR-must choose this boxMust check this box ! Choosing What’s this ?

Once all certifications are final:

•The TF, Corrected prior certifications; and Interim certifications that are marked to be included in a repayment plan will be included on the next available HAP as adjustments (P. 3) and also reverse themselves automatically (P. 4).

•Please check these calculations as they will not include 1 month of adjustments as you are working in the future on that particular hap.

Page 3 ADJUSTMENT

PAGE 4 Manual Adjustment Page

The HAP Repayment Plan

• To complete the HAP repayment plan you will choose ‘view repayment ledger’ from the certification tab.

HUD Repayments are located in a separate ledger. They do not affect the resident or subsidy ledger. The plan appears as pending until activated.

• A resident can have multiple repayment plans

• Certification types send information to the repayment plan ledger.

• It appears similar to the miscellaneous income ledger with the plan at the top and transactions posted to the plan at the bottom.

Must Edit the plan to calculate the agreement.

• Choose ‘edit’ beside the pending plan

• The repayment plan calculation window will appear.

Calculation Window-repayment plan.

• The amount defaults from the certification calculations

• Fill in the number of months for the term

• Leave the cost associated with the payment field blank as each month you will change this amount to reflect the 20% fee we will keep.

• Fill in the collection cost % (20) by choosing the link

• Fill in the description with dates of the tenant misreporting so you can refer to it later, or can be separated from multiple agreements.

Calculate the Plan

• Once all information is included and populates you must choose the calculate button in order for the process to complete.

The monthly payment plus the amount of the tenant's total payment (TTP) at the time the repayment plan is executed should not exceed 40% of the family's monthly adjusted income.

• The system calculates for you based on the term and the costs associated with the payments*

• It will show each month of the term of the payments listed in the bottom window.

• Check each month and total to make sure it is correct and matches total to be repaid by resident

Must Activate the Plan• After you Save the

repayment term calculations

• Choose the more link beside the plan and choose activate.

• Once the plan is active you will then choose to print the repayment plan for the resident to sign

Print the Repayment Plan by choosing ‘more’ beside the agreement

The select a letter window appears

• Choose subsidized programs repayment agreement.

• The system takes the information from the calculated fraud certification and repayment window and populates it into the agreement for the resident’s signature.

View and Print the agreement from the letters and notices tab-general.

You can view the agreement from the ledger tab as well.

To process the payment to the ledger made by the resident

• Go to the resident at a glance page

• View the resident and choose the ledger tab

Choose view the repayment ledger link

Populate the data fields with the correct information*Remember-you cannot scan payments for HAP repayments-post manually!!

Choose view to correct the payment if needed

• The only option on the transaction list is view.

• You would choose view if you had to edit the transaction

• This enables you to return the check nsf, edit the payment to another ledger or reverse the payment if needed

HAP repayment ledger

Transactions can be viewed from the Hudrepay ledger

View of the HUDREPAY Journal

Transactions can be edited from the ledger.

You can view the ‘cost’ associated with the transaction that will appear also on your HAP. This is a charge!

•The certifications have been completed and HAP adjustments have already repaid the assistance- this means that the resident owes the property the money.

•This means that no manual adjustment was made to the HAP (P.4) and repayment occurred on the HAP from certification adjustments (P.3).

•All adjustments to the ledgers must remain.•All money due the property should remain as

‘RENT’ owed to the property.

‘Existing Fraud Balances (old fraud)

Existing Fraud Balances•OneSite gives us the opportunity to add all of

our ‘old’ fraud cases that we are accepting payments on and repaying HUD, into the new process.

• It is imperative that you know the distinction between existing fraud and those that you have already repaid all of the overpayments back on.

•Existing fraud balances are being paid on and posted to a ‘fraud’ journal and you are adding it manually to the HAP each month in order to repay to HUD.

Adding the Existing Fraud• Major points1. You will add the total amount of the original

fraud charge.2. You will be adding every payment, every cost

kept, and the HAP date from the final HAP reconciliation these are shown on.

3. You will then be reversing all information from the fraud ledger.

4. All property fraud cases that are being transferred to new hap repayment processing need RPM signed authorization.

Start with printing current fraud ledger

To be successful you will need:

• The original HAP reconciliation where the original fraud repayment was reported and adjusted. You need this date.

• Each Final HAP reconciliation where each payment was repaid.

• Each cost of processing kept (total payment made minus the 20% kept = what should have been taken back on your final HAP reconciliation)

• You will be matching these repayments with your old fraud ledger.

Transferring transactions• Post the total amount of fraud balance by adding an

existing repayment agreement.• Research each transaction to find the HAP the

payments were actually taken back on.• Remembering that the actual payment by the tenant

would not normally be reported until a future HAP-they must match what was actually repaid. (50.00 pd 1/10/2012= $40.00 repaid 3/2012 HAP)

• Note this HAP date on the printed current fraud ledger.

• Use these notes to post the reported on HAP date on the HAP repayment ledger.

Transferring the transactions

•Make sure your ‘notes’ on the printed ledger card are correct. (Get your RPM’s approval)

•Post each transaction from the ‘old fraud’ ledger to the ‘existing fraud agreement’ from the show transactions link.

•Be sure to ‘edit’ the cost kept from the ‘edit cost link

•Be sure to complete the ‘reported on HAP date from your notes.

HAP repayment ledger•Make sure that you have all transactions listed.•Make sure you have SUBRECFEE showing

(which is the cost the property kept to collect it).

•Make sure that the balance owed the site is the same as appearing on the ‘old fraud ledger.’

•Go back to the ‘old fraud ledger’ and reverse each transaction including the initial charge to FRAUD.

•Keep all notes related to the transition.

Posting payments•From this point forward all payments related

to this resident will be posted manually to the show transaction link at the repayment agreement.

•You will not manually insert the HAP dates from this point forward, this processing will now post automatically to your HAP.

•Make sure you are tracking all payments and editing the costs correctly so that the transaction will post correctly to your financials.

IMPORTANT

•Once you have completed the ‘existing repayment agreement’ remember that the minimum payment may change due to our Fraud policy. 10% + 30% of adjusted monthly income = the maximum amount of rent plus repayment that we are permitted to charge.

•You may need a new repayment agreement with your resident.