Income Verification Approaches
Homeowners at risk of displacement face a number of challenges to remain housed. Pilot HAF Programs demonstrated the importance of simplified application processes to efficiently administer the programs and quickly provide crucial support to homeowners.
Income eligibility and identity verification are two core elements of every HAF application review process. However, some homeowners may have difficulty providing documents to certify their income, identity, loss of income, or coronavirus-related financial hardship for a variety of reasons, including lack of internet access and concerns about privacy.[1]
Taking a human-centered design approach to applications and processes can help eliminate application barriers, build trust with applicants who are in financial crisis, and expedite providing much needed funds to eligible households. Selecting the least burdensome approach to verify an applicant’s eligibility creates a more equitable and efficient program that will benefit families and their communities.
HAF programs can simplify the application process and utilize the strategies below to verify an applicant’s income. These strategies can help efficiently deliver assistance to eligible homeowners and meet the objectives of HAF. As provided in Treasury’s HAF Guidance:
Two approaches for income verification are permissible:
(1) the household may provide a written attestation as to household income together with supporting documentation such as paystubs, W2s or other wage statements, IRS Form 1099s, tax filings, depository institution statements demonstrating regular income, or an attestation from an employer; or
(2) the household may provide a written attestation as to household income and the HAF participant may use a reasonable fact-specific proxy for household income, such as reliance on data regarding average incomes in the household’s geographic area.
Grantees may make reasonable determinations as to what constitutes a household for the purposes of the required household income determination.
| Approach 1 | Approach 2 | |
|---|---|---|
| Self-Attestation | Applicant’s Written Narrative on Household Income | Applicant’s Written Narrative on Household Income |
| Documentation | Homeowner provides supporting documentation such as:
| HAF Participant uses a Reasonable Fact-Specific Proxy for household income such as:
|
| Optional Waivers | HAF Participant provides waivers or exceptions to documentation to accommodate extenuating circ*mstances (disabilities, practical challenges related to the pandemic, or lack of technological access by homeowners). | HAF Participant provides waivers or exceptions to documentation to accommodate extenuating circ*mstances (disabilities, practical challenges related to the pandemic, or lack of technological access by homeowners). |
Written Self-Attestation of Financial Hardship and Income
HAF Programs must require applicants to self-attest or provide a written statement indicating the nature of their financial hardship and income. Doing so can help expedite a household receiving support, alleviate unnecessary stress for the homeowner, and reduce administrative burden for the program.
Key Considerations for Self-Attestation of Income
- Consider using a “COVID-19 Pandemic Impact Questionnaire” to help homeowners quickly identify their eligibility qualifications as well as help triage support from HAF Programs and their partners. An easy-to-read questionnaire can help reduce cognitive burden on the homeowners and ease administrative burden on frontline staff processing applications.
- Develop a form to obtain a written statement from the household of financial hardship associated with the coronavirus pandemic.
- Consider and meet the needs of those with disabilities of any kind by providing information in large print or Braille formats as well as screen reading software to read aloud information provided on the internet, paper copies for those who may require assistance offline, and support available over the phone. Community partners can be a critical resource to help programs reach persons with disabilities and assist them in applying.
- For homeowners with limited English proficiency, provide this form in multiple languages and enable the applicant to respond in their preferred language. For more information, check out www.LEP.gov.
Supporting Documents
Some HAF Programs request applicants verify their income by providing, along with written self-attestation, certain documents such as:
- Paystubs
- W2s or other wage statements
- IRS Form 1099s
- Tax filings
- Bank statements demonstrating regular income
- Attestation from a current or former employer
Easing Applicant Burden
- Present alternative methods for applicants to provide their income documentation such as through a secure web platform or through community partners who can assist with completing applications in person and collect the applications to be shared with the HAF program.
- Housing counseling agencies can be an essential partner in providing assistance to homeowners who are interested in applying to HAF but may need additional support. A housing counselor can clarify a homeowner’s questions about eligibility and required documents as well as help them complete the application accurately with the correct documentation.
Key Considerations for Supporting Documents:
- Many homeowners face barriers to documentation due to language barriers, access to a printer or internet or a situation outside of their control.
- The cognitive load or mental weariness of potential home displacement can make the application process that much more overwhelming for homeowners, especially when combined with barriers to access.
- HAF Programs looking to build trust with households can explore using alternative methods of documenting eligibility.
- Avoid collecting or storing information about the applicant beyond the data required by Treasury for HAF reporting purposes. It is best practice to establish data privacy and security requirements for the information collected from all households, including minimizing collection of unnecessary personally identifiable information (PII), protection of household PII, and providing confidentiality protections, as necessary.
- Comply with Title VI of the Civil Rights Act and improve access for those with limited English proficiency (LEP) with this guide: www.LEP.gov. [2]
HAF Program Waivers
HAF Programs may provide certain homeowners with waivers or exceptions to documentation requirements for a variety of reasons including:
- Disability (Review the Americans with Disabilities Act toolkit on website accessibility.)
- Practical challenges related to the pandemic
- Technology challenges
- Other extenuating circ*mstances related to the pandemic
In these cases, the HAF Program is still responsible for making the required determination regarding the applicant’s household income and documenting that determination. Treasury encourages participants to partner with state unemployment departments or entities that administer federal benefits with income requirements to assist with the verification process, consistent with applicable law.
[1] Programs should ensure that they are complying with the Privacy Act of 1974, for example, by offering alternative identity verification methods for applicants.
[2]Languages spoken by an individual are considered a characteristic of their national origin and under Title VI of the Civil Rights Act, grantees must address the language needs of the limited English proficient (LEP) people they serve. The Department of the Treasury "Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons (LEP Guidance)" provides information and a structure through which a program can be consistently evaluated to ensure meaningful access.
"Improving Access to Public Websites and Digital Services for Limited English Proficient (LEP) Persons" www.LEP.gov is a resource created by the LEP Committee of the Federal Title VI Interagency Working Group housed at the Department of Justice. This guide provides best practices for developing multilingual websites and digital services, effective design strategies to improve language access to websites for LEP persons, and how to handle translation and usability testing.
