HUD Sends Follow-Up Guidance to PHAs Regarding Immigration Reverification Directive
May 11, 2026
By Renee Williams, NLIHC Senior Advisor for Public Policy
On May 6, HUD notified public housing agencies (“PHAs”) of several developments regarding its immigration reverification directive that the agency announced earlier this year (see Memo, 2/2). Specifically, HUD directed PHAs to use the EIV-SAVE Tenant Matching Report (“EIV-SAVE Report” or “Report”) to identify possible inconsistencies in tenant records regarding immigration status or citizenship.
In March, HUD sent a message to PHAs with clarifications regarding the directive; HUD also then noted that an FAQ document was forthcoming. These additional developments follow several PHA industry groups expressing concerns with the initial directive (see Memo, 2/23).
The May 2026 HUD email to PHA directors outlines three updates:
- HUD has “refreshed” the EIV-SAVE Report;
HUD informs PHAs that they will be required to attest that they have verified immigration eligibility and immigration status/citizenship of those individuals identified in the Report; and
HUD has published an FAQ document regarding the Report.
Brief Background
On January 23, HUD announced that it was requiring PHAs to review potential inconsistencies in tenant records regarding immigration status/citizenship using the EIV-SAVE Report, and to initiate corrective action within 30 days. The Report cross-references HUD data with U.S. Citizenship and Immigration Services data. Importantly, PHAs already ascertain tenant program eligibility, which includes checking for eligible immigration status.
On February 13, three housing industry groups asked HUD to rescind its 30-day immigration reverification directive to PHAs, outlining a series of concerns, including EIV-SAVE Report accuracy. HUD sent a follow-up message to PHAs in March 2026 with additional information and to announce that FAQs would soon be available. The National Association of Housing and Redevelopment Officials (NAHRO) summarized the March 2026 update here.
May 2026 Updates
HUD’s May 6 email to PHAs included three updates regarding the reverification directive and the EIV-SAVE Report.
First, HUD tells PHAs that the EIV-SAVE Report has been “refreshed” to reflect information from April 2026. HUD notes that due to initial PHA actions, some records have been removed from the EIV-SAVE Report. As noted in the FAQs (discussed below), the Report does not automatically refresh; however, HUD must manually refresh the Report to remove someone’s name. Per the May 6 message, HUD’s recent refresh “includes an update to other records, new admissions, and additions to households since the initial release.” HUD says that PHAs should review the EIV-SAVE Report, verify “that they have accurately reported individuals’ citizenship or immigration status,” and initiate “corrective actions as appropriate.”
Second, HUD states that it will “require PHAs to attest that they have reviewed the citizenship or immigration status of the identified individuals on the EIV-SAVE Tenant Matching Report and have verified their eligibility” consistent with Section 214 of the “Housing and Community Development Act of 1980” and current HUD regulations. HUD says that attestation will be required within 60 days of HUD issuing instructions, and that these instructions will be provided within the two weeks following May 6.
Third, HUD shared FAQs published May 4, 2026, entitled, “EIV-SAVE Tenant Matching Report for Public Housing Agencies.” The following identifies and discusses several points made in the FAQs:
- The document notes that the FAQs reference current HUD requirements. In other words, the FAQ does not reflect HUD’s recently proposed regulatory changes that would displace or separate mixed-status families and impose stricter verification and documentation requirements on HUD-assisted households (including U.S. citizens and eligible noncitizens). Those regulatory changes have not been finalized.
HUD says that it is “requesting PHAs review the results, compare with available household data, review tenant documentation of citizenship and immigration status, and take corrective actions.” Although HUD uses the word “requesting,” HUD is also requiring PHAs attest that they have reviewed the EIV-SAVE Report information and made “all necessary corrections or initiated additional verification, as appropriate, in compliance with applicable HUD regulations and requirements.”
The FAQs state that PHAs must maintain documentation of their review, as HUD may request it.
The EIV-SAVE Report “does not automatically refresh” and the most recent Report reflects April 2026 data. Individuals will not be removed from the EIV-SAVE Report until HUD initiates a “manual refresh.” HUD is planning “regular updates” to Report data.
HUD acknowledges that MTW Expansion PHAs may experience data accuracy issues and is therefore “requesting these PHAs review the results of the report and compare them with available household data.”
HUD identifies a series of SAVE initial verification responses as not being “evidence of ineligibility.”
HUD says that PHAs cannot use the EIV-SAVE Report to determine eligibility for assistance; HUD states that PHAs must themselves verify eligibility of noncitizens via SAVE under current HUD regulations. PHAs must not “delay, deny, reduce, or terminate assistance because of a delay in the process of determining eligible status, unless the family causes the delay.”
Read NAHRO’s summary of the May 6 message and HUD FAQs here.
Read the HUD May 6 message to PHAs here.
Read the HUD FAQs here.