The most recent post to my Compliance Close Up blog focused on RHIIP Notice #241, which stated that owners/agents could not demand that residents go to the local Social Security Administration office to get documentation of benefits because this information could be obtained by resident’s either going online to www.ssa.gov or by calling the Social Security Administration’s toll-free number.
One of the responses that post elicited was from a housing professional who, in essence, said that because owners/agents must use EIV to document Social Security benefits, getting documentation from the Social Security Administration was no longer required.
The point is well-taken, and I’ll return to it because it deserves attention. But it also made me think about the issue in much broader terms: Do we do things because HUD requires them, or because they’re good ideas?
There are many things in life where action isn’t required, but we do it because it’s a good idea on any number of levels. Personally, for instance, I make a point of acknowledging the birthday’s of friends, even if I haven’t seen or spoken to them in many months or years. I am certainly not required to do so, but it never seems to me to be a bad idea to let someone know they’ve not been forgotten.
In HUD terms, there are entire areas of housing management where the owner/agent is responsible for well-crafted, effective and efficient policy. And good management companies have acted appropriately, even though HUD doesn’t require action on their part.
It is true that with the mandatory usage of EIV, having a resident obtain documentation isn’t “required.” However, a resident can dispute the information provided by EIV, and documentation of income will be of key importance. And EIV will not give us information about Medicare D premiums, only Medicare B. And suppose EIV shows no income because the benefits are provided for under the number of a deceased spouse?
EIV is an important system. But it’s not perfect. That’s why supporting documentation may not be “required” per se, but it is a very, very good idea.