| ID | Status | Date | Public/Private | Industry | AHACPA Contact |
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| #13670 | Closed | public | Multifamily | _General Support |
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I sent this ticket a little ago and wanted to make sure you have received. Just want to know if there is any HUD update on tenant testing for Section 8 entities and EIV information being sent electronically due to Covid 19. Or what do you suggest on this , since travelling and accessing the files personally is so hard with travel restrictions. thanks!! Hi Les, Hope you are doing well. have you heard or are you expecting any changes on tenant testing requirements for Section 8 audits? We have several 06/30 year end Section 8 clients , and we typically travel to the properties to get the tenant testing done, since there is not much sensitive information not allowed to be sent electronically. Due to Covid -19 travel is not as easy, and senior housing properties may have restrictions? Thank you so much in advance! |
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Clara, I have been trying to get an answer to this question for some time. As you know, chapter 9 of Handbook 4350.3 prohibits CPAs from accessing EIV data from any place except the client’s premises. HOwever, Housing Notice 2020-4
B. Access.
1. Industry professionals will access documents as required by the function of those documents. (For example, maintenance staff will not have access to tenant certification records. Real Estate Assessment Center (REAC) inspectors will not have access to tenant files.) 2. Access to electronic information must comply with the same HUD program requirements that apply to paper files. Industry partners must ensure the security of important electronic records and documents. Access to e-storage systems must be restricted to certain users based on specific HUD program guidance. 3. Industry partners must adhere to special rules surrounding EIV or other documents, such as documents disclosing a tenant’s/applicant’s status as a victim of domestic violence, dating violence, sexual assault, or stalking. 4. Industry partners will use the stored information only for its intended purpose and must not share any electronic or paper files for purposes other than those strictly related to an appropriate request. Proprietary information must not be shared with another like entity. (For example, a CA would not share rent comparability studies submitted by one O/A with another O/A.) 5. This Notice permits Independent Public Auditors (IPA), while conducting HUD financial audits, to have access to O/A electronic records. Now this is not all that clear. I have requested specific clarification that this also includes EIV data. However, after several months I have given up any hope of getting an answer. I really believe that the intent is to give us access, however, there is nothing more than this to rely on.
Les
Les Sparks
AHACPA
(801) 547-0809
—– Original Message —– From: AHACPA Support <support@ahacpa.org> To: les@ahacpa.org Sent: Wed, 16 Sep 2020 18:00:54 -0600 (MDT) Subject: Tenant testing and EIV information for Section 8 audits – Covid 19 |