On 27 May 2022, the Department of Housing and Urban Development (HUD), the Government Accountability Office (GAO) and the Department of the Treasury came to an agreement that Haploos Virtual Card rebates will be considered “new revenue” and any rebate captured as a result of using Haploos Virtual Card to deliver payments will be categorized as UNRESTRICTED funds.
Haploos’ Virtual Card rebates are “new revenue” for PHAs and therefor, funds captured by PHAs while making HAP payments using Haploos’ VC are categorized as UNRESTRICTED funds.
PHAs may use the unrestricted funds in furtherance of their mission.
Haploos Virtual card is a new service to the government. No specific regulations or restrictions exists. PHAs and HUD are free to use Haploos Virtual Card and keep any rebates as unrestricted funds.
Haploos Virtual Card is in compliance with Treasury regulations and is appropriate for use by PHAs making HAP payments.
No active steps are taken to defraud the government. This makes recapturing payments extremely difficult for PHAs and HUD. No strong legal options.
A PHA is paying rent for a voucher holder that is not actually receiving housing. For example the voucher holder moved out, passed away, or never moved in.
HUD estimated passive and active fraud could be as high as 7-10% in 2019.
Passive fraud is most commonly occurring on the landlord side.
Active steps are taken to defraud the government, making it easier to prosecute when found.
Fake vendors, fake landlords and unqualified voucher holders are all examples of active fraud.
Active Fraud is difficult to find, but it is everywhere. Haploos VirtualCard is designed to hunt and kill active fraud.
Haploos is the payment. Everyone else is on the outside looking in, we are the inside.