The Data Liberation Project — Public Housing Tenant Terminations

This request is a collaboration with independent researcher Julia Kieserman.

Public housing authorities have the ability to remove tenants from public housing and voucher programs, and have broad discretion in their policies for taking such actions. Little is known, however, about how often this happens, for what reasons, and how those frequencies or reasons vary by public housing authority.

The Department of Housing and Urban Development (HUD) maintains a database system called the Enterprise Income Verification (EIV) system, whose stated purpose is “to support up-front income verification by providing income information to be used by [public housing authorities] during tenant recertification as well as related tools to be used in identifying possible dual entitlement situations and whether applicants already are receiving HUD rental housing assistance.”

The system also contains a “Debts Owed to PHA’s and Terminations” module, which “allows users to access information concerning former tenants who left owing a debt to a PHA or who had their voucher terminated for cause.” Among the records available for each termination are the following fields:

Date of Initial Entry
Date of Update
PHA Code
Program Type
PHA Name
End of Participation Date
End of Participation Status [also phrased as “Reason for Termination”]
Repayment Agreement
Default on Repayment Agreement
Bankruptcy

Our FOIA request 📄 to HUD seeks database records matching the fields listed above, for all entries in the module. (We explicitly are not requesting personally-identifiable information regarding any former tenant recorded in the module, such as the name, former address, or Social Security Number.)

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Updates

Appeal Partly Granted • On August 8, 2024, HUD responded to our appeal 📄, partly granting it and partly denying it. HUD takes the stance that the aggregated summary data are the only segregable portions of the records, and that providing any additional details would impinge on tenants’ personal privacy. HUD has agreed, however, to check whether the records can be provided in a spreadsheet format rather than as a PDF.
Appeal Filed • On July 12, 2024, after several months of seeking clarification from HUD and improvement of the records provided, the Data Liberation Project filed an appeal 📄 of the agency’s response. The appeal has been assigned tracking number 24-A-HQ-00043.
Initial Determination Provided • On April 19, 2024, HUD provided a determination letter 📄 (dated April 12, 2024) and 19 pages of records 📄 it considered responsive to the request; unfortunately, those records provided only aggregate summary information, rather than the actual records requested.
Request Acknowledged, Placed on “Complex” Track • On April 27, 2023, HUD emailed a letter 📄 acknowledging this request and placing it on the agency’s “complex” processing track.