HCV / Public Housing Fraud Detection

1. HCV / Public Housing Fraud Detection

2. Presented By: The Pinellas County Housing Authority Ray DiRusso, Director of Compliance and Development Services Elisa Galvan, Housing Choice Voucher Director

3. United States Housing Act of 1937 • The administration of these programs rely on applicants and participants voluntary disclosures to determine eligibility and the amount of benefit • Experience has shown applicants and participants deliberately cheat • According to HUD ten to twelve percent of federal funds administered are received by ineligible households • These losses total billions of dollars • Families in need are denied housing while assistance is going to those who are self-sufficient

4. What is Section 8 and Public Housing Fraud

5. Falsify information • Knowingly providing inaccurate information • Leaving key details out of an application or annual recertification packet • Participants must include income, Social Security, disability, welfare assistance, child support and assets • The Public Housing Authority may prosecute for fraud if anything is left out • Must report changes in household size

6. Three types of fraud most likely to be uncovered or reported Unreported Income Unauthorized Persons Tax Fraud

7. OBSERVATION CONVERSATION DOCUMENTATION

8. Interviewing Techniques How does your Housing Authority do your recertification?

9. The purpose of the application or participant interview is to get complete and accurate information in order to establish their eligibility and level of assistance

10. Suggestions for Interviewing • Schedule enough time between appointments • Review past information via EIV and 50058 • Ask open ended questions • Ask follow-up questions • Secure signatures for all adults in household

11. Interviewing Ideas • Use broad questions • Use narrow questions to get specific responses • Use probing questions to follow-up • Avoid multiple questions • Allow time for a response • Avoid leads and cues • Use mirror questions • Ask the tough questions • Be an educator continually

12. RED FLAGS OF POSSIBLE FRAUD

13. Reporting Zero Income Complete a Zero Income Worksheet to compare expenses to income

15. No Income Statement I, ______hereby certify that I am not currently receiving income from any kind of wages or compensation, child support, family support, alimony, Social Security benefits, pensions, AFDC or any other kind of income or support. __________________ _____________ Signature Date I, ______understand that when I start receiving income from any source, it is my obligation to report this income change to the Pinellas County Housing Authority. I understand that all changes must be reported in writing, within ten (10) days of the change, for an appointment to be scheduled with my Housing Advisor. I understand that any failure on my part to report changes in my (or anyone in my household) income, may be cause for termination of the family’s, Choice Voucher rental subsidy. __________________ ____________ Signature Date

16. No Child Support Check your County’s local records • Notify the courts of non-payment which could lead to arrest • Participant should go back to court to lower the court ordered support based on person’s current income situation • If the participant does not have the child support payment lowered, the initial court ordered amount remains into effect Note: For all court ordered child support the participant only has two options if no longer receiving

17. Wages Remain Constant

18. Questionable benefits: TANF and Food Stamps

20. Questionable Social Security and Supplemental Security Income

21. Altered Documents

22. Participant or Applicant will only agree to interview during their lunch hours

23. Questionable Identification • Participant should have a current photo identification, such as their Florida Identification Card or Driver’s License • In the State of Florida, it is considered a felony, if the current resident address is not reflected on their license

24. Observations while conducting applicant and annual participant interviews

25. Train Staff in Detecting Fraud • Receptionist • HQS Inspectors • HVC Advisors • Property Managers • Maintenance Workers • Contracted Workers such as Pest Control

27. Tools to Assist in Detecting Potential Fraud • View Enterprise Income Verifications (EIV) • Look at income areas on EIV and hire dates • FREE online sites • Public records, property appraisers and who is in jail

28. Network with key County/City employees • Utility Company • Water Company • Networking with DCF, OIG and IRS employees • Purchase of contracted third party connecting to all public records – example: Lexis Nexis

29. Tax Fraud/Self Businesses

30. Tax Fraud/Self Businesses have become the most predominant fraudulent scheme at this time

31. Measures to Uncover Tax Fraud/Self Businesses • Implement Housing Authority Policy requesting tax returns for all heads of households with or without income • For fixed income families we will only request tax returns of those head of households employment income

32. Excerpt from Administrative Plan Regarding Tax Fraud If it is determined that the family reported self-employment income to IRS and failed to report the self-employment income to the HA, termination of assistance will occur with no exceptions.

33. If the family denies receiving the self-employment income and reported such income solely for the purposes of defrauding the IRS to receive a higher refund or credit, including Earned Income Tax Credit, and amended return, full restitution to the IRS of the unlawfully obtained credit/refund, and a signed stipulation acknowledging that any future IRS/Income Tax Fraud will result in termination of assistance without recourse, will be required prior to the termination date in order to continue assistance.

34. IRS Fraud Recovery Log

35. Jerry Arrington Revenue Agent Abusive Tax Promotion Specialist Employee ID 0484184 151 Patton Avenue, Suite 167 Asheville, NC 28801 Phone: 828-225-8408 Fax: 828-225-8441 Internal Revenue Service www.irs.gov

36. Report Waste, Fraudand Abuse You may wish to anonymously report your discoveries. Your best options would be to call the hotline or print and mail the form. Electronic Form: Click herewhere you can complete and sign the form. It will be emailed to a staff member for review. E-mail: Fill out the form below and an email will be sent to a staff member for review. Print: Click here, print, and submit this form. The address is located on the printed form. Call the fraud hotline at 727.489.0776 • Uncovering fraud is just not an internal process • We rely on community input Here is an example of our website’s contact information for Fraud:

38. Fraud Prosecution Provide accurate documentation on cases to the State Attorney or IRSErrors that can thwart prosecution • Errors in calculation regarding to Housing Assistance Payments (HAP) and over payment • Applying wrongrules and regulations to the letter of termination • Omitted signatures on required documents • Failure to have current HUD form 9886 (Release of information) • Personal Declaration must be completed in it’s entirety

42. Contacts • Jerry Arrington IRS Revenue Agent Abusive Tax Promotion Specialist Phone 828-225-8441 • Jamila Davis U.S. Department of Housing and Urban Development , Office of Inspector General Specialist Agent Phone 813-228-2026 ext. 2057 jdavis@hudoig.gov • Ray DiRusso Pinellas County Housing Authority Director of Compliance and Development Services Phone 727-443-7684 ext. 3069 rdirusso@pinellashousing.com • Elisa Galvan Pinellas County Housing Authority Housing Choice Voucher Director Phone 727-443-7684 ext. 3056 egalvan@pinellashosuing.com

43. Thank you Questions/Answers