An EIV Income Discrepancy Report means EIV's data doesn't match what's on the certification — and unresolved discrepancies are one of the most common MOR findings. Here's the resolution process that survives review.
Step 1: Confirm the discrepancy is real
EIV data lags. First check whether the "discrepancy" is a timing artifact: income that started after the effective date, employment that ended, or amounts already captured on a later interim. Document your analysis either way — a note explaining why no action was needed is the resolution for a false positive.
Step 2: Third-party verify
If the discrepancy appears real, verify the income through acceptable methods for your program — EIV itself is not the source used to calculate rent. Obtain the actual amounts and dates.
Step 3: Meet with the tenant
Notify the tenant of the discrepancy and give them the opportunity to explain and provide documentation. Document the conference (or the tenant's failure to respond) in the file.
Step 4: Correct the certifications
If unreported income affected past certifications, process corrections retroactive to when the income should have been reported, recalculating rent for each affected period.
Step 5: Repayment agreement
Where the tenant owes back rent due to unreported income, execute a repayment agreement consistent with HUD requirements — reasonable monthly amounts, signed, tracked, and retained.
Step 6: File it all
The reviewer's test is simple: discrepancy report + your analysis + verifications + tenant contact + corrections + repayment agreement (if applicable), all in the file, all dated inside required timeframes.
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FAQ
How long do I have to resolve a discrepancy? Work discrepancies promptly upon the report's generation — reviewers look for timely, documented action, not just eventual resolution.
Can I use the EIV amount to calculate rent? No. EIV identifies issues; rent calculations rely on verification obtained through your program's acceptable methods.
What if the tenant refuses to cooperate? Document your attempts and follow your program's enforcement path — up to termination of assistance where the tenant fails to comply with reporting obligations.
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