Program Integrity Q&A

Program Violations and Fraud (Program Integrity)

Why Catching Program Violations and Fraud is Important
What are Program Violations and Fraud?
How violations and fraud are investigated
Penalties for Committing Violations and Fraud
Reporting Violations and Fraud

Why Catching Program Violations and Fraud is Important

The federal government allocates a fixed amount of funds to the Housing Authority with which it is to provide rental assistance to as many families as possible. When a participating family receives more rental assistance than it is due, those additional rental assistance funds are not available to assist another family.

Each family is asked to spend approximately 30% of its income towards its rent. This is a reasonable amount to be asked to pay, few families on the private market pay so small a percentage of their income for rent.

By misrepresentation, not declaring income or otherwise engaging in program violations, the person doing so is not only cheating tax payers and the federal government, he or she is cheating another low income family out of assistance.

The vast majority of families currently receiving rental assistance, as well as many thousands of families on the waiting list, are honest, adhere to the rules and appreciate their rental assistance when they receive it.

The Housing Authority of the County of Santa Cruz is committed to eliminating fraud and dishonesty from its programs and has created a special investigative unit called the Program Integrity unit with a staff trained in investigation.

If you suspect a program violation or fraud is happening, you are encouraged to report it to the Program Integrity unit.

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What are Program Violations and Fraud?

Some misconceptions about the Housing Authority programs lead people to assume program violation or fraud is occurring when it is not. Families do not have to be on welfare to qualify for the program; in fact, families are encouraged to work, increase their income and eventually move off the program.

People who live together as a stable household but are not married are eligible for the program, as are families without children, single people, the elderly and persons with disabilities. However, all people living in the household and the income of all people in the household must be reported to the Housing Authority promptly.

Some examples of program violations or fraud by a program participant or tenant:

  • Misstatements of facts
  • Omission of facts
  • Making false statements
  • Lying on personal declaration forms
  • Failure to comply with program requirements.
  • Failure to report all income and/or assets.
  • Falsifying document and/or signatures.
  • Failure to report promptly changes in income or household composition.
  • Allowing additional people to live in the home without approval from the Housing Authority and landlord.
  • Subleasing all or part of the rental unit.
  • Paying more rent to the landlord than the amount stated on the Tenancy Addendum to the Lease (also called “side payments”).
  • Charging a live-in aide rent.
  • Committing a serious criminal act.
  • Owning or having a financial interest in the rental unit.

Some examples of program violations or fraud by a landlord:

  • Collecting additional payments from the family beyond that stated in the Tenancy Addendum to the lease (also called “side payments”).
  • Accepting Housing Assistance payments for a vacant unit.
  • Living in the same rental unit as the program participant.

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How violations and fraud are investigated

The Housing Authority has many sources and investigative methods at its disposal. Friends and neighbors may be interviewed or surveillance of activities undertaken.

Government data bases that provide records of income, assets, places of residence, criminal background and other information may also be used.

The Housing Authority also works closely with law enforcement and other public agencies to conduct joint investigations and cooperates fully in criminal and civil prosecutions.

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Penalties for Committing Program Violations and Fraud

Penalties range from losing rental assistance to prosecution and imprisonment. Violators may be fined and also be required to repay all overpaid rental assistance.

Under the Section 8 program, if a violation is determined, the Housing Authority might stop rental assistance but the landlord may allow the violator to remain in the rental unit. The Housing Authority cannot evict or remove the violating family from the home, only the landlord may evict.

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Reporting Program Fraud and Violations

By phone: information may be given confidentially by calling the Program Integrity unit at 454-9455, extension 251. If the Program Integrity Officer is not available, a message can be left in the secure voice mail box accessed by only the Program Integrity Officer.

Electronically: a report may also be made confidentially via this web site by completing the Program Violation Reporting Form. This form goes directly from the web site to the Program Integrity Officer.

In writing: the Program Violation Reporting Form can also be printed from the web site and mailed to, or dropped off at, the Housing Authority, 2160 41st Avenue, Capitola, CA 95010, attention: Program Integrity Officer/Confidential Information.

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All reports of program violations and fraud are held in strict confidence.

Based on information received confidentially, the Housing Authority Program Integrity Officer will undertake an independent investigation and will not reveal the name of the person providing the information. If the Program Integrity Officer finds that a case cannot be proven without using information that would reveal the identity of the informant, the Program Integrity Officer will contact the informant for permission to use identifying information. If permission is not given, the informant’s name will not be used but the case may not be able to go forward.

Because of confidentiality requirements, the Housing Authority will not be able to make any statements regarding the status of investigations or results. Investigations, then the process of termination and/or prosecution can be lengthy; it should not be assumed that no action is being taken simply because the family remains in the home.

Income Verification & Deductions Q&A

Documenting and Verifying Your Family’s Income

What kind of income should I report to the Housing Authority:

  • First, you MUST report ALL income that anyone in your family receives, and ALL assets that anyone in your family has.
  • The Housing Authority reviews the information and requires you to provide documentation to verify all of your income and assets.
  • Some types of income or assets may not be included in your rent calculation, but you are still required to report them.

What kind of income should I report to the Housing Authority?

You are required to report all income to us, even if you think we already know about it, or even if you think it “doesn’t count” for our programs. This includes, but is not limited to:

  • Wages, salary, and tips
  • Welfare, Social Security, and other benefits, even if the benefits are intended for a child.
  • Child support, alimony, and other support from friends or family, including someone who pays bills, buys groceries, or provides other non-cash assistance
  • Financial aid and student loans
  • Self-employment income and work for cash, including side jobs like yard care, child care, selling merchandise at the flea market, etc.
  • Workers compensation, unemployment, disability payments, etc.

What kind of assets should I report?

You must report all assets owned by anyone in your family to the Housing Authority.

Generally, the value of the asset does not count as income. Only the income (such as interest) produced by the asset will count. If the asset does not produce any income, like money in a non-interest bearing checking account, the Housing Authority will use an assumed interest rate to estimate income.

Assets you must report include, but are not limited to:

  • Bank accounts
  • Pension and retirement accounts
  • Real estate and other property
  • Trusts, including special needs trusts
  • Settlements, inheritance, and other lump sum cash awards
  • Ownership in a business or partnership

How will you verify the income I report?

We will require that you provide documentation of all of your income and assets. Most documentation must be in the form of original documents, so make photo copies to keep for your records. Required documents include pay stubs, bank statements, benefits letters, tax returns, etc. You will be given a specific list of the type of documents needed.

We will also obtain direct verification from an online database maintained by HUD, called EIV. This database includes income and benefit information about you and your household. We will use the database to confirm the information you have provided to us. For more information about EIV, see the brochure called “What You Should Know About EIV” available at the Housing Authority office and website.

Finally, if we still need more information we may contact an employer, bank, agency, etc. directly and ask them to fill out a form verifying your income or assets and return that form directly to us.

How do I document self-employment or cash income?

If you are self-employed, work for cash, or receive money or other support from friends or family, you must still document this income.

  • For self-employment (child care, yard care, freelance work, etc.), provide an income and expense statement or use our Self-Employment Verification Form.
  • Keep a written log of cash received, including dates, amounts, and who provided the cash.
  • Show bank statements that document that cash was deposited.
  • Keep records throughout the entire year, and be prepared to provide this information to the Housing Authority annually.
  • Provide names and contact information for the persons who provided the income to you. We may contact them directly for verification.

What happens if someone in my family fails to report their income or assets?

The head of household is responsible for making sure that everyone in the family fully reports their income and assets.

Failure to report this information, as well as any changes, can result in your family being required to repay subsidy, and/or being terminated from the program, among other penalties. See the Program Fraud Q&A for more information.

Annual Recertification Q&A

About the Annual Recertification Process

Why does the Housing Authority conduct annual recertifications?

The Department of Housing and Urban Development (HUD) requires us to review the income, assets, and family composition of each family we assist once a year.

You are required to provide all the information we need to recertify your family annually. Most families receive several thousand dollars’ worth of assistance each year; in return, we ask that you comply with program rules and provide this information annually.

From time to time, the Housing Authority may change the date of your annual recertification. However, a full annual recertification will be conducted once every year.

What if I provided all the information last year and there have been no changes?

Even if nothing about your situation has changed, you are still required to provide all the information we request.

What if I recently reported some changes to my income? Do I still need to complete the annual recertification?

Yes. Even if we have recently conducted an “interim” income recertification based on changes you reported to us, we must still complete the full annual recertification for everyone in your family.

Can’t you get information about my income from other sources?

It is your responsibility to report all income to us, and we will confirm this information with federal and state agencies that collect income data. For more information, see the Income Verification Q&A.

There are now two options for completing your annual recertification (AR):

1) electronically,
2) using paper documentation

What if it doesn’t work for me to complete my AR electronically?

Call us at (831) 454-5955 or email us at [email protected] to let us know. Arrangements will be made to mail you a paper AR packet.

If electronically: You will be contacted via email, 3-4 months prior to the due date of the AR. Follow the prompts on the On-line Portal to register. All annual recertification information will then be entered though this portal.

If by paper: Your packet will arrive in the mail about 3-4 months before your annual recertification date.  Plan for this and have your paperwork organized. Further details will be included in the packet.

For either option
Complete and submit your completed packet by the due date.  Your assistance may be terminated if you do not.

  • If we request original documents, make copies for yourself.
  • If you fax a document, send it by mail as well.  Some faxes can be hard to read.

How do I know if you received what I sent you?

We will send you a letter if we are missing any documents. Please don’t call immediately after sending documents to us to ask if we received them, as this will only slow down the document review process.

What if I am expecting a change to my income, assets, or family composition?

Please tell us, in writing, as much as possible about any changes that may take place during your annual recertification. For more information, see our Reporting Changes Q&A.

What if I am planning on moving?

If you are planning to move during your annual recertification process, it is important that you let us know your plans as soon as possible. See our Transfer Q&A for more information about moving to another unit.

Will there be changes to my rent as a result of the annual recertification?

There could be changes to the rent you pay if:

  • Your income or assets have changed.
  • Your landlord has requested a rent increase.
  • Someone has moved in or out of your household, which affects the number of bedrooms you are eligible for.
  • The payment standard or utility allowances that the Housing Authority uses to calculate your subsidy has changed.

You will be notified by mail of any rent change.

Most Housing Authority programs are designed so that families pay about a third of their income in rent. The federal government considers this to be an affordable amount for any family to pay for housing.

What if I am not able to gather all the information by the deadline?

The Housing Authority’s deadline for submittal of annual recertification documents is firm. Failure to comply with deadlines could result in termination of your assistance.

We encourage you to plan ahead and keep income and asset information for everyone in your family on file to make it easier to submit the packet by the deadline. If there is a crisis that causes a delay, contact us immediately.

Special Needs Q&A

What kind of assistance do you offer for persons with disabilities?

The Housing Authority of the County of Santa Cruz has special voucher programs for disabled persons meeting certain eligibility criteria. For a list of all special voucher programs, please  our website at  Additionally, if you are homeless or at risk of homelessness, please reach out to or call 831-454-4122 or 2-1-1.

You might consider contacting  the caseworker you have through the County or other Agency that is not the Housing Authority, to discuss options for you.

What other options might be available?

When you apply for or begin receiving assistance from the Housing Authority, our staff can help with special needs such as:

  • Authorizing someone else to speak to us, receive mail, or sign papers on your behalf.
  • Requests for extensions of important deadlines if the delay was related to a disability.
  • Requests for a live-in aide, which is a person that is required by your disability to live in your home and assist you.
  • Requests to rent a unit from a relative if you are unable to find another unit with the special features you require.
  • Requests for an extra bedroom to store oversized medical equipment or provide extra space related to the disabilities.
  • Other special needs

How Do I Make a Request?

Complete the appropriate Special Request Form, which you can download from our website, or call our Info Line (# below) to request a form or to make your request verbally if you cannot complete the form.

Make your request as early as possible so that processing time will not interfere in your housing needs.

Be specific about what you are asking for.

Once we get the request, we will send a form directly to your health care provider, social worker or other knowledgeable professional to verify the need.  Please make sure that person is aware of your needs and understands how important it is to provide as much detail as possible on our form and return it quickly.  Your health care provider , social worker or other knowledgeable professional cannot give the form to you—he or she must send it directly to us.

When will I know if my request has been approved?

This depends on how long it takes your health care provider, social worker or other knowledgeable professional to respond.  Most requests take over 30 days to process.  We will send you a letter notifying you of our decision

Approving a special request can result in you receiving more rental assistance that would otherwise be used to help another family.

For this reason, we require thorough documentation of the need and we will verify that the accommodation is being used.

What are the requirements for live-in aides?

  • A live-in aide (LIA) cannot be someone who would normally live with you as part of your family or support you financially. A LIA is an employee who you hire to provide care.
  • Your health care provider or social worker must verify that you need a LIA to perform essential tasks related to your disability during nighttime hours. The Housing Authority will confirm this need.
  • You may not charge rent to a LIA.
  • A LIA does not have any rights to the voucher and is not considered part of the assisted household.
  • A LIA’s income is not counted as part of your household income.
  • A LIA must live with you full-time and document that he/she does not have another residence.
  • You do not need our approval for daytime help, only for a LIA to live with you.

What are the requirements for renting from a relative?

You are only allowed to rent from a relative if:

  • Your health care provider, social worker or other knowledgeable professional verifies that you need special features due to a disability, and
  • You complete a Housing Search Form to show that you tried to find another unit and that your needs can be met only by your relative’s unit.

How can I get a larger unit or an extra bedroom?

Granting extra bedrooms mean that you get more rental assistance that could otherwise help another family. Extra bedrooms are approved in limited situations for:

  • Large medical equipment
  • Certain conditions that make it impossible for two people to share a room.

When can I get an extension of my voucher expiration date?

Extensions due to a disability are only granted if your health care provider, social worker or other knowledgeable professional documents the dates when your disability prevented you from searching for a rental. There is no guarantee that extensions will be granted. If you do not lease up by the deadline, you could lose your voucher. Continue your housing search and document every unit you contact on a Housing Search Form.

If you are searching for a unit, do not assume that your request will be approved! Continue your housing search. You might not get an extension on your voucher simply because you were waiting for approval of your request.

Si desea una traducción en español, por favor llame al (831) 454-9455.

How Annual Income is Determined

Information about How Your Income is Counted in the Section 8 Housing Choice Voucher

Definition of Annual Income

HUD defines Annual Income as all amounts, monetary or not, which: go to, or on behalf of, the family head or spouse (even if temporarily absent) or to any other family member; or are anticipated to be received from a source outside the family during the 12-month period following admission or annual reexamination effective date; and which are not specifically excluded. Annual income also means amounts derived (during the 12- month period) from assets to which any member of the family has access. For HUD’s complete definition of Annual Income, including a listing of all income exclusions, see 24CFR5.609.

How the Housing Authority Verifies Income – Overview

As a condition of housing assistance under the program, the Housing Authority requires the family to complete a detailed Initial Application and an annual Personal and Financial Statement listing all sources of income, assets, and other information needed to determine the appropriate level of subsidy. Additionally, family members must sign a consent form, authorizing any financial institution, employer, Federal, State or local agency, etc. to release information to the Housing Authority.

HUD requires that all income, assets, and other family information must be verified according to the following levels of priority.

Upfront Income Verification: Upfront Income Verification is the verification of income, before or during a family re-examination, through an independent source that systemically and uniformly maintains income information in computerized form for a large number of individuals. In an effort to minimize HAP overpayments due to tenant misreporting and non-reporting of income, HUD has launched an upfront income verification tool called Enterprise Income Verification (EIV). EIV contains data regarding wages and benefits received by all program participants with valid Social Security Numbers.

Written Third Party Verification (Tenant Documents): Written third party verification (tenant documents) are current, original documents generated by a third party source.

Written Third Party Verification Form (HA Form): In cases where the tenant is unable to provide documentation, or where the tenant provided documentation is not sufficient, the Housing Authority will contact the income source directly, in writing, to obtain the verification information.

Verbal Third Party Verification: If the income source does not respond to a written request for information or provides incomplete or unclear information, the Housing Authority staff may contact the source by phone to request clarification on incomplete information.

Tenant Declaration (Self Certification): If no other verification is available, staff will note the reason in the file and require the tenant to sign an affidavit declaring their income.

Information Regarding Verification of Specific Income Types

The following is a list of the most common income types, as well as other items that the Housing Authority documents, including details associated with how these items are verified. This is not a comprehensive list, as new income sources and other related items are added frequently. Items presented below are listed in alphabetical order.

Annual contributions / gifts – HUD requires that regular and ongoing contributions and gifts should be counted towards annual income. However, gifts or contributions that occur annually (such as Christmas or birthday gifts) are not considered regular or ongoing because they occur only once during the re-examination reporting period of one year. Therefore, such contributions and gifts are to be excluded if they are less than $1,000 per household.

Assets: For current program participants at annual re-examination only, the Housing Authority will accept tenant self certification of assets on the Personal and Financial Statement if total household assets are reported to be less than $5,000. For applicants in the eligibility process, and for current program participants with $5,000 or more in total household assets, the Housing Authority will collect current tenant provided documents, such as bank statements.

Cash on hand – Occasionally Tenants report their cash on hand (as requested on the Personal and Financial Statement). Cash amounts less than $1,000 per household will not be counted as an asset. However, any amount of cash that is greater than or equal to $1,000 per household will be counted as an asset.

Child Care Expense Deductions: The Housing Authority must first verify that child care expenses are used to enable a family member to work, actively seek employment, or further his/her education. For instance, the childcare must be provided during the hours of work, education, etc. when there is no other activity (such as school) for the child.

Community Service Requirement: For verification of participation in required community service for public housing tenants, a timesheet signed by the agency but provided by the family is acceptable. For verification that a family member is exempt from performing community service, staff must obtain the highest level of thirdparty verification possible in accordance with this procedure, except for those exemptions that are due to permanent reasons such as age or permanent disability which have already been verified and documented.

Disability: If a tenant receives SSI, the verification of the SSI payment is acceptable verification of the disability. If the tenant does not receive SSI, verification of disability, depending on the individual’s circumstances, will be requested from a doctor, other health care professional or a social worker, with medical or professional knowledge of the person’s disability. If such verification is not available, the Authority may consider other forms of verification on a case-by-case basis.

Full Time Student Status: Full time student status must be verified using current tenant documents provided either by the household or by the school. Full time student status will be annually.

Citizenship and Immigration Status: All program participants admitted to the program must sign a statement indicating whether they are a US citizen, a legal resident, or whether they do not contend to have eligible citizenship status (and will therefore receive prorated assistance). US citizens will be asked to provide proof of citizenship, which may include either a birth certificate, passport, or naturalization certificate. Non-citizens who are under the age of 62 years old must provide documentation of eligible immigration status (which is then verified in the E-verify SAVE system).

Medical Expense and Disability Assistance Expense Deduction: The Department of Health and Human Services has developed Federal privacy standards to protect patients’ medical records and other health information provided to health plans, doctors, hospitals, and other health care providers as of April 14, 2003. These standards are part of the Health Insurance Portability and Accountability Act of 1996 (HIPAA). The privacy requirements under HIPAA have a significant impact on how PHAs verify disability status, medical expenses, and disability assistance expenses. HIPAA requires that patients sign a specific authorization before a covered entity can release their medical information to a third party for purposes not related to the patient’s health care.

The Housing Authority appreciates the statement in the Verification Guidance acknowledging that “with increasing privacy law requirements, PHAs may have difficulty in verifying” medical and disability assistance expenses. In light of these considerable difficulties, the Housing Authority has determined that the best way to ensure the validity of medical and disability assistance expense information, while simultaneously protecting the confidentiality of our applicants and participants and complying with HIPAA, is a reliance on applicant / participant self-certification. To receive the medical expense deduction, tenants must complete the medical expense verification forms provided in the medical expense packet. However, if a program participant reports medical expenses in excess of $3,000, Housing Authority staff will attempt to further validate the expenses in a manner that does not violate the confidentiality of the program participant.

Photo Identification: All adult household members will be asked to provide a government issued photo identification at the initial interview, before being added to the household, or at the annual re-examination following an existing household member’s eighteenth birthday. Photo identification may consist of a passport, drivers license, state issued identification card, military identification card or a student identification card. Photo identification must always be presented in person, rather than by mail.

Seasonal Income: If a participant is employed in an occupation that is cyclical (that increases or decreases at the same time each year such as farm workers, teachers and construction workers) all income expected to be received during the year must be annualized. If the Housing Authority determines that past income is the best predictor of future income, historical data may be used to project annual income.

Self Employment: All self employed tenants and applicants will be asked to provide a complete copy of their most recent tax return (including Schedule C and Schedule SE if applicable). Additionally, all self employed tenants and applicants will be asked to complete the self employment certification form, and to sign form IRS 4506-T.

Social Security (SS) / Supplemental Security Income (SSI): The Housing Authority is required to use the HUD EIV system to obtain up-front verification of Social Security and SSI benefits for current program participants. If the amount shown on EIV does not match the amount provided on a current original benefits letter, the amount in the benefits letter will be used. If no current original benefits letter has been provided, but EIV matches the amount the tenant has reported through the Personal and Financial Statement, EIV may be used without collecting tenant documents. However, if the amount reflected on the PFS does not match EIV and the tenant has not supplied an original benefits letter, staff will either obtain an original benefits letter or will contact the tenant by phone to provide the tenant an opportunity to dispute the information in EIV. If the tenant does not dispute the information in EIV, staff will document the phone call and may use the data in EIV. If the tenant does dispute EIV, an original benefits letter must be obtained. Additionally, original benefits letters will be used to verify the Social Security and SSI benefits of applicants and other individuals who are not in the EIV system.

Social Security Numbers: All applicants, regardless of age, must disclose a valid Social Security Number and provide the required documentation at the time of their initial eligibility determination.

Wages: The Housing Authority is required to use the HUD EIV system, along with tenant provided documentation (such as current consecutive paystubs), to obtain verification of wages.