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Chapter 3. Data Collection, Analysis, and Documenting the Rent Calculation Process

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Title: Chapter 3. Data Collection, Analysis, and Documenting the Rent Calculation Process


1
Chapter 3. Data Collection, Analysis, and
Documenting the Rent Calculation Process
2
Chapter 3. Section 1. Introduction
  • Learning Objective
  • Gather, analyze and document information through
    improved skill development in interviewing and
    analysis

3
Introduction
  • HUD programs rely greatly on voluntary disclosure
    by family
  • PHA actions to reduce vulnerability
  • Critically analyze PHA intake and reexamination
    processes
  • Work on improving the interviewing skills of
    their staff
  • Train their staffs to analyze information
    critically

4
Introduction
  • PHA actions to reduce vulnerability
  • Develop comprehensive data collection and
    verification tools
  • Adopt policies that require relevant documents to
    be provided by families
  • Make maximum use of UIV tools to prevent and
    detect false statements and underreporting of
    income

5
Introduction
  • Steps in the rent calculation process
  • Gathering data
  • Interviewing
  • Verification
  • Review and follow-up
  • Data entry and calculation
  • Maintaining files

6
Introduction
  • The steps are determined by the answers to three
    important questions
  • What information is needed for correct rent
    calculations?
  • How will the information be verified?
  • How will the information be processed and
    recorded?

7
Chapter 3. Section 2. Step 1 Gathering Data
8
Gathering Data Forms
  • For most PHAs, the admission or reexamination
    process begins when a forms packet is provided
    to the family
  • The forms used for initial and annual
    certifications are most critical (application and
    recertification forms)
  • RIM reviewers have found that many application
    and verification forms used by PHAs do not ask
    ALL necessary questions or questions are too
    vague to make accurate determinations of income
    and rent

9
Gathering Data Forms
  • If the PHAs forms do not ask ALL of the right
    questions clearly, staff may be unable to make
    correct income and rent determinations
  • Forms should be reviewed for the 4 Cs
    completeness, clarity, and compliance with
    current requirements

10
Common Issues
  • RIM reviewers have identified areas in which PHA
    forms may fall short
  • Non-cash contributions form only asks about
    regular payment of a bill
  • Disability assistance expenses forms ask only
    elderly/disabled families about disabilities
    expenses or neglect to ask about the expenses
    entirely

11
Common Issues
  • RIM reviewers have identified areas in which PHA
    forms may fall short
  • Medical expenses
  • PHA forms do not ask for anticipated medical
    expenses
  • Forms are unclear about what is to be considered
    a medical expense

12
Common Issues
  • The questions may be flawed in these ways
  • Incomplete questions
  • Does any employed family member pay child care
    expenses for work?

13
Common Issues
  • Missing questions
  • No questions about divested assets
  • No question regarding qualifying factors for EID
    purposes
  • Vague/confusing questions
  • Do you anticipate medical expenses in excess of
    3 of your annual income for the 12 months
    following admission or reexamination?

14
Common Issues
  • Forms may be out of date
  • Forms not revised to reflect changes in
    regulations governing
  • The Earned Income Disallowance
  • Training program income
  • Imputed welfare income

15
PHA Application Form
  • It should be comprehensive.
  • It serves several important functions
  • Critical to effective interviewing
  • Ensures same questions are asked of all families
  • Provides paper trail for false statements
  • Is proof that questions were asked

16
PHA Application Form
  • Primary and secondary questions
  • Application form should ask two types of
    questions
  • Primary questions These open up a topic (i.e., a
    factor that affects income or rent)
  • Secondary questions For additional information
    about a topic

17
PHA Application Form
  • Sample application questions
  • Example 1 (page 3-6)
  • Review questions
  • Each primary question is yes-or-no
  • Secondary questions are answered only if response
    to the primary question is yes
  • Strength of this method is that applicant or
    tenant must declare an answer to the primary
    question

18
PHA Application Form
  • Sample application questions
  • Example 2 (page 3-7)
  • Review questions
  • Uses a statement rather than a question to open a
    table
  • Uses a table to collect secondary information
  • PHA interviewers must ensure that no items are
    left blank

19
Sample Application Questions
  • Review Sample Application Questions (pages 3-8
    through 3-11)
  • Part 1 Income Information
  • Part 2 Assets
  • Part 3 Expenses
  • Review all questions and mark the ones that are
    not included on the application form in your PHA.
    If you are not sure, compare when you go home.

20
Sample Primary Questions by Topic
  • Part I Income Information
  • (Reexams only) Has anyone in your household
    started a new job or had an increase in earnings?
    If yes, answer the following
  • Has this person been unemployed 1 years?
  • Is this person participating in any type of
    economic self-sufficiency program?
  • Has this person received TANF in the past six
    months, including one-time cash payments?

21
Sample Primary Questions by Topic
  • Part I Income Information
  • Does any household member receive cash, tips,
    bonuses, commissions, or any type of compensation
    for providing any type of services?

22
Sample Application Questions
  • TIP
  • Many PHAs include questions pertaining to a
    familys current expenditures
  • Rent, electric, gas, water, telephone, car
    payment, insurance, credit cards, medical bills,
    etc.
  • Allows comparison between expenditures and
    current income
  • Creates opportunities for follow-up questions
    when discrepancies and when families report zero
    income

23
Gathering Data
  • Learning Activity 3-1 Fix the Question (page
    3-13)
  • Analyze Question 1 by responding to the
    questions beneath it.
  • Be prepared to report results to group.
  • Questions 2 - 5 Take home

24
Chapter 3. Section 3. Step 2 Interviewing
25
Interviewing
  • Interviewing is the most important skill in the
    housing process
  • Interviews may either encourage or discourage
    compliance, cooperation and honest disclosure
  • Initial eligibility interview is most crucial
    interview of all
  • Interview training essential

26
Interviewing
  • To ensure consistency, interviewers should use a
    checklist
  • Interviewers should have a planned approach to
    ensure consistency in the process
  • Pre-interview
  • Data collection
  • Analysis of the data collected
  • Closing the interview . . .

27
Pre-Interview
  • Interviewer sets the tone, builds trust
  • Uses a checklist to establish ground rules for
    the interview (see Pre-Interview Checklist on
    page 3-20)

28
Data Collection
  • Focuses solely on gathering information from the
    family
  • The interviewer asks all the questions pertaining
    to eligibility
  • Documents the answer to each question

29
Data Analysis
  • The interviewer
  • Evaluates the information and documents provided
    by family to determine what needs to be verified
  • Determines whether or not family must provide any
    additional documents or information
  • Resolves any discrepancies between familys
    statements and any UIV or other verification

30
Closing the Interview
  • The interviewer
  • Reviews all forms with family
  • Obtains consent forms as needed
  • Provides family with written instructions about
    any further information or documents that family
    must provide
  • Answers any questions family may have
  • Provides any information family may need to
    understand program rules and requirements

31
Interviewing
  • Some PHAs conduct reexaminations by mail
  • No regulatory requirement for face-to-face
    interview
  • If PHA does not interview family in person,
    completeness of application and reexamination
    forms is critical to income and rent
    determinations

32
Interviewing
  • Application or reexam form is generally used as a
    template for interview
  • Ask every question on form
  • Make sure all questions are answered (Do not use
    n/a)
  • Make sure form is signed and dated by PHA
    representative and family representative

33
Asking the Right Questions
  • Use global (open-ended) questions to get
    explanations. Who…? What…? Where..? How do
    you…? Why……?
  • Use closed questions to get specifics. Do you? Is
    it? How much? How many?

34
Probing Questions
  • Use probing questions to get additional
    information about an issue
  • Clarifying
  • Resolving discrepancies
  • What do you mean by…..?
  • Could you explain how……?
  • Help me to understand this, how do you….?

35
Probing Questions
  • Probing questions may be very relevant when UIV
    conflicts with statements or documentation
    provided by family
  • Example SWICA report shows family employed last
    two quarters and family reports no employment
  • Where was the last place you worked?
  • How long were you there?
  • When did you leave?
  • (If not resolved, then ask Can you explain . . .
    ?)

36
Avoid Multiple Questions
  • Such as, Do you have a checking or savings
    account or any type of investments such as an IRA
    or certificate of deposit?
  • They confuse some people
  • They give others the opportunity to select the
    part of the question they want to answer or
    avoid

37
Multiple Questions
  • Good example of how to break down the questions
  • Where do you bank?
  • What types of accounts do you have there?
  • What is the account number?
  • What is the account balance?
  • Do you have any other type of accounts at this
    bank?
  • Are there any other banks you do business with?

38
Avoid Leading Questions
  • You dont have any income, do you?
  • Everythings the same as last year…right?

39
Use Mirror Questions
  • Reflect or restate a response
  • Reflect or restate a scenario
  • The purpose of mirroring or reflecting what
    an individual has said is to obtain confirmation,
    correction, clarification or amplification.

40
Other Tips
  • Allow adequate time for response
  • Dont reword a question unless necessary for
    accuracy or clarity
  • Avoid technical language or jargon
  • Educate while interviewing
  • Learn to ask the tough questions in a
    non-threatening way
  • You dont have to act tough to ask tough questions

41
Discussion Questions
  • Do interviewers have a planned approach to the
    interview? (Pre-Interview Checklist)
  • Do interviewers ask open-ended, inclusive
    questions vs. specific questions when exploring a
    topic?
  • Do interviewers apply questions to all family
    members, even those not present at interviews?

42
Discussion Questions
  • Do interviewers review all types of income with
    families? For all family members?
  • Do interviewers ask about excluded income? For
    all family members?
  • Do interviewers review all types of assets with
    families? For all family members?

43
Discussion Questions
  • Do interviewers make families aware of all
    possible allowable expenses? For all family
    members?
  • Do interviewers ask secondary questions regarding
    reimbursement of expenses claimed?

44
Discussion Questions
  • When increased earnings are reported, does staff
    determine
  • Whether the individual meets any of the criteria
    to qualify for earned income disallowance?
  • Whether the individual is enrolled in a qualified
    training program?

45
Interviewing
  • Learning Activity 3-2 Situational
    Analysis (page 3-26)

46
Chapter 3. Section 4. Step 3. Verification
47
Verification
  • Interviewer must be able to decide
  • What additional documents are needed
  • What additional information must the applicant
    provide
  • What must be verified to comply with HUD
    requirements
  • What type of verification is needed

48
Verification Forms
  • Should be comprehensive, but not complicated
  • Should ask secondary questions (are expenses
    reimbursed, etc)
  • Should include a false statement statement
  • Must include a signed authorization for release
    of information

49
Verification Forms
  • Should capture name, position, telephone number
    of information provider
  • Should capture current and anticipated earnings
    and fluctuating pay rates and hours
  • May want to consider including self-addressed
    stamped envelope with each verification form
    mailed out

50
Verification
  • We will discuss verification requirements in
    depth in the next session

51
Chapter 3. Section 5. Step 4. Review and
Follow-up
52
Review and Follow-Up
  • Verifications received from up-front sources and
    third parties must be compared to information
    provided by the family at the interview or in the
    application form
  • In case of conflicting information, PHAs must
  • Resolve any discrepancies by following up, as
    necessary, with the third party, the family, or
    both
  • Document the resolution and leave a clear audit
    trail

53
Discussion Question
  • What procedure does your PHA follow when
    documents provided by the family conflict with
    up-front or other third-party verifications after
    the interview is over?
  • Example Third-party employer form shows 20 hours
    per week employment, pay stubs show average of 25
    weekly hours

54
Discussion Question
  • Possible answers from PHAs
  • Always use the third-party verification
  • Always use pay stubs
  • Use the higher figure to avoid an overpayment
  • Use the lower figure to benefit the applicant or
    tenant
  • But what is the right answer???
  • The answer you get as a result of resolving a
    discrepancy based on the facts you get.

55
Review and Follow-Up
  • When there is a conflict between family-supplied
    information, up-front verification, or written
    third-party verification, the PHA must
  • Obtain additional information from family and/or
    third party
  • Resolve the discrepancy
  • Document thoroughly to leave a clear audit trail

56
Chapter 3. Section 6. Step 5. Data Entry and
Calculation
57
Data Entry and Calculation
  • Documentation is the key
  • Anyone reviewing the file should be able to
    understand how the rent was calculated
  • Calculation documentation could include
  • Printout from software system showing
    calculations
  • Calculator tape
  • Narrative entry explaining calculations
  • Signed, dated notation attached to third-party or
    UIV document if computer printout doesnt show
    calculations

58
Data Entry and Calculation
  • PHAs should develop methods for comparing
    information in file to staffs rent calculations
  • Show relationship between figures on verification
    forms and figures on 50058, rent calculation
    worksheet or printout

59
Data Entry and Calculation
  • HUD recommends having a printed 50058 form in the
    file.
  • Due to PHA policy or software issues, staff may
    not be able to print one. Instead, it is
  • Advisable to print a worksheet or summary
  • Essential to understand what is shown on the
    printout and where those numbers come from (which
    data entry fields)

60
Data Entry and Calculation
  • Staff should verify each completed calculation by
    comparing it to file data and checking for
  • Data entry errors
  • Transposed numbers
  • Incomplete information (adult not coded as a
    full-time student)
  • Missing information (second source of income)
  • Carryover of previous errors (birth date, SSN)

61
Data Entry and Calculation
  • A worksheet may be completed by hand for
    comparison to a software calculation for some or
    all staff
  • Manual calculations sometimes catch errors that
    otherwise might be overlooked
  • Also provide hands-on experience with process of
    rent determination
  • PHAs should review and correct mistakes
    identified in PIC error reports

62
Chapter 3. Section 7. Step 6. Maintaining Files
63
Maintaining Files
  • Rent calculation procedures should include a
    standardized system for creating and maintaining
    all case files
  • Ensures consistency
  • Easier for staff to fill in for one another
    during vacations or other absences
  • Saves time for supervisory reviews, audits and/or
    monitoring visits
  • More…

64
Maintaining Files
  • Every case file should follow a standard format
    so that a reviewer can find the same items in the
    same place in each file.
  • Checking to ensure that staff members are
    following the standard file format should be part
    of a supervisory quality control review.

65
Maintaining Files
  • Considerations for file layout
  • How will you divide sections?
  • Could divide sections for left right sides of
    folder
  • Could use tabs or colored pages to divide
    sections
  • Will you place frequently-used items at the front
    of the file or elsewhere?
  • How will you delineate between reexams so it is
    clear which documentation goes with which reexam?

66
Chapter 3. Section 8. Conclusion
67
Conclusion
  • PHAs need to do a step-by-step review and
    analysis of the rent calculation process as an
    error-reduction strategy
  • Identify policies, procedures and all other tools
    involved in the rent calculation process
  • Determine whether those policies, procedures and
    tools support correct income and rent
    determinations . . .

68
Conclusion
  • PHAs need to do a step-by-step review and
    analysis of the rent calculation process as an
    error-reduction strategy
  • Revise existing policies, procedures and tools as
    needed
  • Create new policies, procedures and tools when
    necessary
  • Ensure that staff is implementing policies
    procedures consistently and utilizing tools as
    needed

69
Learning Objective
  • Gather, analyze and document information through
    improved skill development in interviewing and
    analysis
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