Note: Please also see Admission and Occupancy (Related to EID), General Income and Rent Determination, Verification, and RIM Reviews FAQs for questions/answers on income and rent issues.

1. Question: What is a RIM review?

Answer: RIM reviews are a key component of the Rental Housing Integrity Improvement Project (RHIIP) initiative to reduce income and rent errors and improper payments in the administration of both the public housing and housing choice voucher (HCV) programs. RIM reviews are designed to identify the root causes of error and improper payments in meeting HUD's goal of a 50 percent reduction in the number and dollar amount of errors by fiscal year 2005.

2. Question: What, specifically, do HUD Field Office reviewers do when conducting a RIM review?

Answer: While performing a RIM review, HUD Field Office reviewers will:

• Review sample tenant files
• Assess PHA policies, procedures, and forms
• Interview PHA staff
• Identify and record income and rent errors (both systemic and isolated errors)
• Analyze income and rent errors to establish root causes
• Provide technical assistance
• Identify findings and concerns/observations, and require corrective actions as appropriate.

It is important to note that although RIM reviews are limited in scope, a Field Office may, as part of its routine monitoring process and responsibility, decide to review other functions of the PHA while conducting a RIM review.

3. Question: How many RIM reviews did the Field Offices conduct in 2003?

Answer: In FY 2003, the Field Offices completed over 700 RIM reviews covering PHAs administering 80 percent of PIH's rental assistance funding.

4. Question: Must HUD Field Office reviewers send the PHA a RIM review report on its income and rent performance?

Answer: Yes. A written RIM review report will be sent to the PHA no later than 45 calendar days from the completion of onsite work.

5. Question: What type of information will be included in the review report?

Answer: A review report should identify performance problems, diagnose the causes of the problems, and offer valuable recommendations for corrective action. Each review report must follow the HUD Monitoring Desk Guide, which calls for a clear delineation between "findings" and "concerns" (also referred to as "observations"). The report will also include specific tenant file errors that were discovered as a result of the review.

6. Question: Are PHAs given a chance to respond to the review report?

Answer: Yes. PHAs have 45 days from the date of the review report to respond to the report, but 30 days is recommended to the extent possible.

7. Question: Can a Field Office grant a PHA an extension beyond the 45-day period if it needs more time to prepare a correction action plan (CAP) in response to the review report?

Answer: Requests for extensions beyond the 45-day period will be considered on a case-by-case basis, and will be for a maximum period of 30 days.

8. Question: How does the HUD Monitoring Desk Guide distinguish "findings" and "concerns"?

Answer: As provided by the HUD Monitoring Desk Guide, a finding is a violation of statutory, regulatory, or valid handbook requirements. Findings should include the condition, criteria, cause, consequence (effect), and the required corrective action. A concern or observation is defined as a deficiency in performance, which should be brought to the attention of the program participant, but is not based on a regulatory or statutory requirement. Concerns should include the condition, cause and effect, and recommended corrective actions.

9. Question: How does HUD staff know when to write an error as a finding or a concern?

Answer: A finding must be traced back to statute, regulation, or other explicit HUD requirement. HUD staff must use judgment when determining whether a requirement exists, and whether the PHA has, in fact, violated the requirement, or whether the PHA has choices and options as stated in their current policies and is exercising the discretion granted them under the regulations. Another issue to consider is the extent to which several different errors are related, or are apart of a larger pattern or problem. Single or isolated errors, by themselves, may not constitute a finding. However, when taken together, several errors may rise to the level of a finding. (See HUD guidance on systemic findings vs. non-systemic findings for a detailed discussion.)

10. Question: As a result of a RIM review, a Field Office reviewer assigns a category of risk based on the findings. How do Field Office reviewers assign risk-ranking categories to PHAs?

Answer: The risk ranking is decided after the RIM review is completed, and is based on the judgment of the reviewer and the established risk factors of the Field Office.

11. Question: What requirements can HUD impose as a result of RIM review findings?

Answer: As with any other HUD monitoring review, a PHA that is found to be in non-compliance with HUD requirements will be required to implement a CAP to resolve findings. See the HUD Monitoring Desk Guide for additional guidance on policies and procedures for program oversight.

12. Question: What if a PHA fails to develop and implement a CAP as required by the RIM review report?

Answer: If a PHA fails to identify and implement corrective actions, or correct income and rent determination errors in meeting program requirements of the RIM review, HUD will impose sanctions on the PHA and seek to recover disallowed costs, in accordance with Notice PIH-2003-34, Rental Integrity Monitoring (RIM) Disallowed Costs and Sanctions under the Rental Housing Integrity Improvement Project (RHIIP) initiative.

13. Question: Do RIM Field Office reviewers take a PHA's comments into consideration in making their findings final?

Answer: Yes. Field Office reviewers must consider a PHA's comments and responses to RIM review results. If the PHA and Field Office are unable to come to an agreement regarding Field Office determinations, the PHA may submit RIM review findings, errors, corrective actions, etc. within 30 calendar days from receipt of the PHA Review Summary Report (MS-Excel). (See the RIM Review Dispute Process for details.)

14. Question: Is it a violation of HUD regulations if a PHA does not have an adequate application/re-exam package to determine income and deductions? For example, a PHA has no proof that they are asking elderly families about medical expenses or families if they have childcare expenses.

Answer: Yes. If a PHA cannot document that they are requesting information that is required to accurately calculate income and rent, HUD will be unable to verify that adjusted income is being calculated in accordance with 24 CFR 5.611. This would qualify as a systemic finding. (See HUD guidance on systemic findings vs. non-systemic findings for a detailed discussion.)

15. Question: If a PHA's policy doesn't state how they will determine the value of asset income amounts for checking and savings accounts and each Occupancy Specialist is doing it differently, is this a finding? For example, some are using the current account balances and others are using the average balance for the past three months.

Answer: Yes. If a PHA does not have a written policy and there is evidence that occupancy staff are using different methods to determine the value of assets, for RIM purposes, this should be listed as a violation of 24 CFR 903.7(d). A PHA must amend its policy to specifically state the method to be used to determine the value of assets, and must ensure that practice is consistent with PHA policy.

16. Question: What if all occupancy staff is using the same method to calculate asset income from checking and savings accounts, even though it is not outlined in the PHA's policies?

Answer: The report to the PHA should list this as a finding (24 CFR 903.7(d) and 24 CFR 982.54) and require the PHA take corrective action, amending its policies to reflect the method used. For RIM purposes, HUD staff should follow the PHA's practice/method to determine the value of assets.

17. Question: If a PHA has not adopted a policy on medical expenses, what should a RIM reviewer do?

Answer: At a minimum, the RIM reviewer should require a PHA to amend its (ACOP) and/or Section 8 Administrative Plan (24 CFR 982.54) to address medical expenses, both in terms of what will be considered eligible and how it will be verified. A reviewer should try to determine how the PHA is calculating and verifying medical expenses, and whether the caseworkers are consistent in their approach. For RIM purposes, if caseworkers were not consistent in their approach then it would be a violation of 24 CFR 5.611(a)(3)(i) because HUD would be unable to verify that unreimbursed medical expenses are being calculated consistently and properly.

18. Question: : If a PHA is not following its own policies, as adopted in its Annual Plan, Administrative Plan, and Admissions and Continued Occupancy Plan (ACOP), is that a finding?

Answer: Yes. The regulations on annual plans (24 CFR 903.25) state that a "PHA must comply with the rules, standards, and policies established in the plans." A supporting document to the Annual Plan, the regulations on HCV program administrative plans (24 CFR 982.54(c)) state that a "PHA must administer the program in accordance with the PHA administrative plan." Regarding the ACOP, also a supporting document to the PHA's Annual Plan, the PHA must comply with policies adopted in this plan.

19. Question: Is there a regulation requiring PHAs to maintain a copy of the HUD Form-50058 Family Report in the tenant's file?

Answer: No. There is no regulatory requirement that states PHAs must maintain a paper copy of the Form HUD-50058 in the tenant's file. However, HUD strongly recommends that PHAs retain a hard copy of the form in the tenant's file, in addition to the electronic copy.

20. Question: Do PHAs have to keep all file information on active HCV and PH participants, including original application data, citizenship declaration, SSN verification data, birth certificates, etc.? Can this data be purged after the family has moved out of the unit for three years?

Answer: For all active participants, PHAs must retain all records that are necessary to document the family's initial and continued eligibility, as well as any information that is needed to determine family composition and income. All file data for inactive participants must be retained for at least three years, following the family's departure from the HCV or PH program.