3 - PUBLIC HEARING ANNUAL ACTION PLAN

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. Administrative Plan 4/1/16 . Page 6-6 provided documents are pay stubs, SAHA will make every effort to obtain current and consecutive pay stubs dated within the last 90 days. SAHA will obtain written and/or oral third-party verification in accordance with the verification requirements and policies in Chapter 7 in the following cases: • If EIV or other UIV data is not available, • If the family disputes the accuracy of the EIV employer data, and/or • If SAHA determines additional information is need. • In such cases, SAHA will review and analyze current data to anticipate annual income. • In all cases, the family file will be documented with a clear record of the reason for the decision, and a clear audit trail will be left as to how SAHA annualized projected income. When SAHA cannot readily anticipate income based upon current circumstances (e.g., in the case of seasonal employment, unstable working hours, or suspected fraud), SAHA will review and analyze historical data for patterns of employment, paid benefits, and receipt of others income and use the results of this analysis to establish annual income. Any time current circumstances are not used to project annual income, a clear rationale for the decision will be documented in the file. In all such cases, the family may present information and documentation to SAHA to show why the historic pattern does not represent the family’s anticipated income. Known Changes in Income If SAHA verifies an upcoming increase or decrease in income, annual income will be calculated by applying each income amount to the appropriate part of the 12-month period. Example: An employer reports that a full-time employee who has been receiving $8/hour will begin to receive $8.25/hour in the eighth week after the effective date of the reexamination. In such a case SAHA would calculate annual income as follows: ($8/hour × 40 hours × 7 weeks) + ($8.25 × 40 hours × 45 weeks). The family may present information that demonstrates that implementing a change before its effective date would create a hardship for the family. In such cases SAHA will calculate annual income using current circumstances and then require an interim reexamination when the change actually occurs. This requirement will be imposed even if SAHA’s policy on reexaminations does not require interim reexaminations for other types of changes. When tenant-provided third-party documents are used to anticipate annual income, they will be dated within the last 60 days of the reexamination interview date. Projecting Income In HUD’s EIV webcast of January 2008, HUD made clear that PHAs are not to use EIV quarterly wages to project annual income. 3-134