HUD Sends New Immigration Status Guidance to PHAs on SAVE Status Discrepancies

By: Tushar Gurjal, Senior Policy Manager

January 26, 2026 — On January 22, HUD sent an email to PHA Executive Directors with additional immigration status guidance to PHAs on Systematic Alien Verification for Entitlements (SAVE) discrepancies. The guidance notes that HUD has developed a new report in the Enterprise Income Verification (EIV) system to help PHAs in determining when additional verification of immigration status may be necessary. The new report, named the EIV-SAVE Tenant Matching Report, cross references Inventory Management System/PIH Information Center (IMS-PIC) data with U.S. citizenship and immigration services (USCIS) SAVE data.

The EIV-SAVE Tenant Matching Report includes “. . . a list of individuals whose citizenship or eligible immigration status need to be confirmed by HUD.” The report may include “. . . individuals whose citizenship or eligible immigration status needs to be confirmed by the PHA . . .” because of discrepancies between their status on the HUD-50058 and what appears in SAVE (e.g., a person is classified in the 50058 as an “eligible noncitizen” when the SAVE status shows a classification that would not correspond to “eligible noncitizen”). If a PHA has already determined that an individual is an ineligible noncitizen, they are not included in this report (i.e., as NAHRO understands this guidance, those in mixed-status families that do not contend their immigration status should not be impacted by this guidance).

The letter highlights the fact that inclusion in this report does not automatically mean that the individual is ineligible for HUD assistance. Instead, additional information may be required to classify the individual’s immigration status (e.g., additional documentation may be required). Housing agencies should already have any additional documentation needed to classify the individual as an eligible noncitizen, if the SAVE classification could not verify that status previously as the additional documentation would have been required to show that the individual was an eligible noncitizen.

The guidance requires PHAs to take certain steps in the 30 days after the document was sent. The PHA should confirm, as necessary, the following (bullet points below taken verbatim from the letter sent to PHAs):

• “The PHA has sought additional verification from SAVE to verify eligible immigration status.
• The PHA has retained documentation in the tenant file that confirms the individual’s citizenship or eligible immigration status (e.g., documentation and SAVE verification).
• The PHA has correctly coded the individual on the HUD-50058.”

The guidance directs PHAs to take corrective action for any individual whose citizenship or immigration status is incorrectly reported on the HUD-50058. Then the PHA must take the appropriate corrective action, which includes submitting a corrected HUD-50058 to IMS/PIC. If the person is ineligible for HUD assistance, then the PHA may be required to initiate a termination of assistance, depending on the makeup of the household.

Housing agencies that do not use the EIV reports may be subject to sanctions. Sanctions include (but are not limited to) corrective action orders; reimbursement from non-HUD sources; withholding or reducing funding; or any other available corrective action or sanction as HUD deems necessary.

NAHRO will continue to analyze this latest guidance and provide additional updates as necessary.

Instructions on how to access the report may be found here.

The letter sent to PHAs can be found here.