NAHRO, PHADA, and the MTW Collaborative Send Letter to HUD Articulating Concerns with New EIV-SAVE Report and Guidance
By: Tushar Gurjal, Senior Policy Manager
February 17, 2026 – On February 13, NAHRO, along with the Public Housing Authorities Directors Association (PHADA) and the MTW Collaborative, sent a letter to HUD articulating concerns about a new Enterprise Income Verification – Systemic Alien Verification for Entitlements (EIV-SAVE) report and an accompanying guidance letter which was sent by HUD to housing agency executive directors in January, 2026. The guidance letter discussed the EIV-SAVE report and set a timeline for housing agencies to request additional eligibility documentation in many instances for people listed in the report. The industry group letter requests that HUD rescind the guidance letter and engage in a dialogue with industry groups on how HUD can feasibly achieve its policy goals on this issue.
The industry group letter notes several concerns regarding the guidance letter sent by HUD. First, the industry groups note that many housing agencies will be unable to complete the review of program participant files within the 30-day period and that it is an unrealistic timeline. This is because the review will encompass many time-consuming activities like reviewing the files, updating expired verification consent forms, granting time extensions for people in the process of retrieving documentation, or certain other reasons. The letter also notes that the EIV-SAVE report is frequently changing (i.e., the list of people on it changes) and it appears to be filled with inaccurate data (i.e., people who have all of their documentation in order appear to be on the list frequently). There are also concerns that the statuses in the EIV-SAVE report are unclear (i.e., it is not clear what actions housing agencies should take for individuals with certain statuses if a review of the file indicates all documentation is in place), certain Moving to Work agencies have especially inaccurate EIV-SAVE reports because of how they report family data to HUD, and the timeline for completion of the review of files is unclear.
The industry group letter also notes concerns that some of the requested actions may contradict HUD’s regulations in some instances. For example, HUD’s regulations state that “[f]or each family member, the family is required to submit evidence of eligible status only one time during continuously assisted occupancy under any Section 214 covered program.” To the extent that the guidance letter asks housing agencies to request additional information beyond that required in the initial eligibility determination, this requirement could contradict regulations in some instances. Another example is that HUD’s regulations state that eligible noncitizens over the age of 62 only required “. . . a signed declaration or eligible immigration status . . . and . . .[a] proof of age document.” To the extent that the new HUD guidance letter asks for additional documentation beyond this, the requirement could contradict HUD’s regulations.
The industry group letter also expressed certain other concerns.
The industry groups look forward to working with HUD collaboratively to address these issues.
The full letter can be found here.