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Under the HCV program, PHAs are only required to keep tenant files for a period of three years (24 CFR 982.158(e)). What if an EID participant leaves the HCV program and then returns 3 ½ years later, after the PHA has already purged his or her previous record?

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Under the HCV program, PHAs are only required to keep tenant files for a period of three years (24 CFR 982.158(e)). What if an EID participant leaves the HCV program and then returns 3 ½ years later, after the PHA has already purged his or her previous record?

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In order for the PHA to be aware of the individual’s prior receipt of EID and the number of months he or she received the exclusion, the individual would have had to report the information, or the PHA would have had to retain a record of the individual’s participation for longer than the HUD required three-year period. Because HUD regulations limit a participant’s exclusionary period to 48-months in a lifetime, the Department strongly recommends all PHAs carefully track and retain the records of EID participants for as long as necessary. HUD also recommends PHAs (1) adopt policies that require relevant documents to be provided by former participants claiming they received EID in years’ prior; (2) improve the interviewing skills of their staffs; (3) develop comprehensive data collection tools; (4) and make the maximum use of up-front income verification (UIV) tools to prevent and detect false statements. That being said, if after being re-admitted into the HCV program, or into public ho

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