How to Handle Verification When Source Doesn't Return Form
Sometimes verification sources don't return the forms that you send them to verify certain information such as a household member's income or student status. In these situations, you must try to verify the information by telephoning the sources. To stay in tax credit compliance, you're required to keep a written record of these telephone calls, the people to whom you spoke, and the information obtained during the calls [HUD Handbook 4350.3, par. 5-19].
But some managers don't keep a formal record of these telephone calls. They just jot down the information they get and use it to certify a household. This practice may lead to trouble because if you don't keep a formal record that you made the required calls, you won't be able to show your state housing agency that you tried hard enough to get source verification.
To help you, we'll detail a procedure to follow when verification sources don't return forms to you. We've also created a Model Form: Document Telephone Contact with Verification Source, that you can use to keep a record of telephone contacts to show that you made phone calls to verification sources.
Obtain Telephone Number
Whenever you ask household members for the name and address of a source to whom you must send a verification form, also ask for the source's phone number. This will allow you to follow up if the source doesn't return the form. If the source is a large organization such as a bank, also ask for the name of a contact person you can call.
When to Call
There's no hard-and-fast rule as to how long you should wait for a source to return a verification form before you make a call. You should allow enough time for the source to have a chance to get the form, fill it out, and return it to you. If your time frame is tight because you're trying to fill a vacancy, you can call sooner than you would otherwise.
Keep Record of Call
Before you call a source, fill out some basic information on the Model Form. Fill in your name, the household member's name and address, and the source's name and telephone number.
The form lets you record information about several phone calls to the source. That's because you may not reach the person you want to speak to the first time you call. For example, if you call a company to verify employment income, you may have to leave a message with a receptionist asking the human resources director to return your call. And even if you reach the right person, she may not have the information you need at her fingertips.
Each time you call a source or a source returns your call, record the following information:
The date and time of the call;
The name and title of the person you spoke with;
The result of the call such as “left message” or “spoke to source and got requested information.”
What to Tell Source
When you call the source, introduce yourself and explain that a household member has told you that the source can verify information relating to the household member's income. Specify the household member's name and relationship to the source. Say that you sent the source a verification form to fill out but haven't yet gotten it back. Tell the source that he or she can give you the required information over the phone.
Here's an example of what you might say:
My name is Jane Manager. I manage a housing tax credit site called Maverick Landing. One of your employees, John James, is applying for a unit at the site. To determine his eligibility to live at the site, we must verify the income he earns from you. To get this information, we sent you a form to fill out about 12 days ago. Since we haven't gotten back the form, we're required to call you to get the information. If you have a moment, we can handle this over the phone. I can tell you the information we need to know.
If sources say that they've already mailed the form to you, thank them and tell them they needn't repeat the information to you over the phone. If sources say that you've called at a bad time, try to schedule a good time to call back to get the information. If sources say it's a good time to speak, ask them about the information you must verify.
Be sure you have a copy of the relevant verification form on hand when you call the source. This will help ensure that you ask for all the required information. And record the source's responses directly on the verification form. Doing so will give you the formal record you will need if you must show your state housing agency that the household's eligibility is based on accurate information. Then you can staple the verification form to the phone record form. Keep the two forms together in the household's file.
In some instances, you and the source may agree during a telephone conversation to use a fax or email correspondence to verify the requisite information. It may be easier for the source to send a document this way. If this is the case, note the owner's intended action on the Model Form and relay to the source that the fax should include the company name and fax number and the email address should include the name of the source and firm. Once the verification document is received, you can place these along with the relevant verification form and the phone record form in the household file.
If Source Doesn't Call Back
If you leave a message when you call the source but the source doesn't return your call, wait a few days and call again. If you still haven't received verification within two weeks of its request, you may stop calling and consider original documents submitted by the household. The deadline is spelled out in the HUD Handbook, which the IRS says you should follow when certifying households [HUD Handbook 4350.3, par. 5-13].
When you get no response, you must get documentation from the household member to back up income and expense disclosures. For example, if after making several calls to the employer with no return call, you may use a review of documents such as pay stubs for verification. You should insist on a series of consecutive, recent pay stubs and should have a standard policy indicating the number of consecutive pay stubs required.
In the telephone conversations, sometimes the source may simply refuse to provide you with the information, claiming privacy or some other concern. In this case, you probably don't have to wait the full two weeks before you submit substitute documentation, says Ruth Theobald Probst, president of TheoPro Compliance and Consulting. General industry practice is to submit the other documentation and proceed immediately to certification. The state agencies seem to be accommodating in this case as long as you have “meaningful proof that the household is qualified,” says Probst.
Ruth L. Theobald Probst, CPM, HCCP, SHCM: President, TheoPRO Compliance and Consulting, Inc., 21150 W. Capitol Dr., Pewaukee, WI 53072; www.theopro.com.
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