Rental Integrity Monitoring (RIM)

Purpose

In 2002, HUD Headquarters commissioned Field Offices to conduct onsite monitoring of PHAs—RIM reviews—to:

• Detect and reduce errors in income and rent calculations at targeted PHAs
• Reduce rent underpayments and overpayments by residents
• Maximize HUD's limited housing resources

In FY 2003, PIH completed over 700 RIM reviews covering PHAs administering 80 percent of PIH's rental assistance funding.

Selection of PHAs for RIM Reviews

The Field Offices use the existing PIH risk model, particularly those PHAs who are SEMAP and PHAS-troubled, to assist in determining the PHAs most likely to have serious rent and income errors. This model is supplemented by:

• SEMAP indicators #3, #9, and #10
• Information from the PD&R QC study on income errors
• REAC large-scale match data
• Financial exposure
  

What is a RIM Review?

RIM reviews are but one strategy in a larger, HUD-wide effort to reduce income and rent errors and improper payments in the administration of both public housing and Section 8 housing choice voucher (HCV) programs. This includes gathering PHA income and rent information, identifying income and rent errors, and assessing PHA policies and procedures. The reviewer analyzes this information to establish root causes of income and rent errors and recommend necessary corrective actions for PHA improved performance.

RIM Review Process

Pre-review Preparation

• Select and identify targeted PHAs and pull sample of tenant files for review
• Review key resources (e.g., PHA annual plan, PHA policies, prior reviews and audits) available in the HUD office
• Identify monitoring topics (e.g., admissions and occupancy policies, payment standards, reexaminations, and HUD-Form 50058 and PIC)

Onsite Monitoring

• Review sample of tenant files
• Identify PHA income and rent errors, findings, and concerns or observations
• Record specific tenant file errors on the Tenant File Error Report (MS-Excel) and any findings on the PHA Review Summary Report (MS-Excel)
• Discuss preliminary conclusions and findings with PHA staff

Post-review Activities

HUD Field Offices will:

• Issue a written report of findings to the PHA that clearly describe the condition, criteria or citation, cause, consequence, and timeframe (generally 45 days) for completing the PHA corrective action plan
• Review and consider the PHA's response to report issues
• Prepare and report findings to Headquarters via the Tenant File Error Report and the PHA Review Summary Report (i.e., Error Tracking Reports)

Re-reviews or Follow-up Reviews

During a re-review, if a PHA does not appear to be resolving the income and rent findings and making the necessary adjustments, the Field Office will determine the reasons for the PHA's failure to address deficiencies and take appropriate actions, including the imposition of sanctions and recovery of disallowed costs (See Notice PIH 2003-34, RIM Disallowed Costs and Sanctions under RHIIP). The Field Office may also provide additional technical assistance or adopt new strategies for ensuring that the PHA receives the assistance it needs (e.g., partnering with other PHAs, contracting out for needed training, etc.) to address review findings.