Identity Theft Process

These procedures apply to all of DOH’s housing programs, unless otherwise noted.

Step One: Possible Identity Theft is Discovered

1. During an annual or interim action, the Residential Coordinator notices an income discrepancy between income listed on the EIV Report and income listed on documents submitted by the tenant.
2. The Residential Coordinator will contact the tenant to discuss the income discrepancy during a tenant conference.
3. During the tenant conference, one of the following may occur:
   1. The Tenant admits that the information is correct and provides Residential Coordinator with verification of income.
   2. The Tenant disagrees with the income information on the EIV stating that there is an error or identity theft.

Step Two: Identity Theft Documentation

1. Residential Coordinator will mail a letter to the tenant that informs them of their requirement of the following:
   1. Tenant must indicate in writing the reason for the dispute and provide the Residential Coordinator with supporting documentation.
      1. Supporting Documentation for identity theft can be:
         1. Copy of Police Report (not a police report number); or
         2. Notice from credit bureau regarding fraud alert placed on credit report or copy of credit report with fraud alert notice; or
         3. Copy of identity theft report filing with the Federal Trade Commission; and
         4. Copy of tenant’s letter sent to the income source to dispute information and request for correction; and
         5. Any correspondence the tenant received from the income source
   2. The tenant will be given 10 days to provide all supporting documentation. If the tenant requires more time, he/she may submit a Request for Reasonable Accommodation explaining their need for more time.

Step Three: Documentation Review and File Completion

1. Residential Coordinator will do one of the following:
   1. If required documentation is received within the 10 days (or within the time frame approved by the Reasonable Accommodation):
      1. Review all documents submitted to ensure everything has been provided
      2. File supporting documentation in file under Correspondence
      3. If an annual reexamination is due, process the annual, and exclude the income in question. Place a note in Elite advising of the identity theft.
      4. No repayment agreement will be necessary
   2. If the required documentation is not received within 10 days (or within the time frame approved by the Reasonable Accommodation):
      1. If an annual reexamination is due, process the annual and include all income.
      2. If no annual reexamination is due, process an interim with all the income.
      3. Document this in the file, and place a note in Elite stating that the tenant reported identity theft, but did not provide supporting documentation.
         1. A repayment agreement may be necessary.