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Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
DVHTAC Peer Support Call COVID-19 Spending Bill amp Safe Housing Options for Survivors
April 10 2020
PresentersSarah Saadian National Low Income Housing CoalitionSteve Berg National Alliance to End HomelessnessLisa Coffman HUDs Office of Special Needs and Assistance ProgramsB Aaron Weaver HUDs Office of Community Planning and DevelopmentJasmine Hayes US Interagency Council on Homelessness
HostsDebbie Fox National Network to End Domestic ViolenceJill Robertson Collaborative Solutions
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Overview
bull Introduce the federal Domestic Violence and Housing Technical Assistance Consortium and our COVID-19 Response
bull Highlight of partnerships across sectors during the pandemic
bull Overview of recent COVID3 Care housing investments and expansions
bull Explore federal innovative responses to address the safe housing needs of survivors
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
DV amp Housing TA Consortium (DVHTAC)
Federal Partnersbull Family Violence Prevention amp Services ProgramHHS
bull Office on Violence Against WomenDOJ
bull Office for Victims of CrimeDOJ
bull Office of Special Needs Assistance ProgramsHUD
bull US Interagency Council on Homelessness
Technical Assistance Providers
bull National Alliance for Safe Housing (NASH)
bull Collaborative Solutions Inc (CSI)
bull National Network to End Domestic Violence (NNEDV)
bull National Resource Center on Domestic Violence (NRCDV)
bull National Sexual Violence Resource Center (NSVRC)
bull Corporation for Supportive Housing (CSH)
DVHTAC Peer Support CallCOVID-19 Funding
Jasmine Hayes Deputy Director
April 10 2020
bullPlan
bullCommunity Planning and Preparedness
bullAct
bullSite-Specific Emergency Operations
bullClient Support and Care
bullFunding Flexibilities and Waivers
bullOther Considerations
bullFollow-up
5
Responding to COVID-19
Resources
bullCDC Guidance Supporting People Experiencing Homelessness
bullUSICH COVID-19 resources
bullContact your USICH Regional Coordinator using our State Data and Contacts Map (click on your state to find your RC)
bullSign-up for our newsletter
6
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Office of Special Needs Assistance Programs
7
Prioritize Your COVID-19 Response
bull SNAPS understands your 1 priority right now is responding to COVID-19
bull HUD will take into account the need for COVID response when considering performance metrics subrecipient monitoring governance and future HUD monitoring and CoC Competitions
bull CoCs are encouraged to be as flexible as possible when thinking through their local competition metrics
Resources for CoCs and Homeless Assistance Providers on the HUD ExchangeInfectious Disease Prevention amp Response page on HUD Exchange
bull Submit a question on the HUD Exchange Ask-A-Question (AAQ) Portal
Check back regularly for new posts
Key Websites with Available Resources
HUD httpswwwhudexchangeinfohomelessness-assistancediseasesinfectious-disease-prevention-response
CDC httpswwwcdcgovcoronavirus2019-ncovcommunityhomeless-sheltersindexhtml
NHCHC httpsnhchcorgclinical-practicediseases-and-conditionsinfluenza
USICH httpswwwusichgovtools-for-actioncoronavirus-covid-19-resources
VA httpswwwpublichealthvagovn-coronavirusindexasp
HRSA httpsbphchrsagovemergency-responsecoronavirus-frequently-asked-questionshtml
CARES Act amp COVID-19 Waivers
Lisa Coffman and Aaron Weaver
US Department of Housing and Urban Development
CARES Act Funding Breakdown
bull $4B for Emergency Solutions Grants
bull $1B Announced on April 2 2020
bull $65M for Housing Opportunities for Persons With AIDS
bull $537M for Formula Grants
bull $10M for Competitive Grants
bull $5B for Community Development Block Grant
bull $2B Announced on April 2 2020
COVID-19 Waivers
Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Overview
bull Introduce the federal Domestic Violence and Housing Technical Assistance Consortium and our COVID-19 Response
bull Highlight of partnerships across sectors during the pandemic
bull Overview of recent COVID3 Care housing investments and expansions
bull Explore federal innovative responses to address the safe housing needs of survivors
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
DV amp Housing TA Consortium (DVHTAC)
Federal Partnersbull Family Violence Prevention amp Services ProgramHHS
bull Office on Violence Against WomenDOJ
bull Office for Victims of CrimeDOJ
bull Office of Special Needs Assistance ProgramsHUD
bull US Interagency Council on Homelessness
Technical Assistance Providers
bull National Alliance for Safe Housing (NASH)
bull Collaborative Solutions Inc (CSI)
bull National Network to End Domestic Violence (NNEDV)
bull National Resource Center on Domestic Violence (NRCDV)
bull National Sexual Violence Resource Center (NSVRC)
bull Corporation for Supportive Housing (CSH)
DVHTAC Peer Support CallCOVID-19 Funding
Jasmine Hayes Deputy Director
April 10 2020
bullPlan
bullCommunity Planning and Preparedness
bullAct
bullSite-Specific Emergency Operations
bullClient Support and Care
bullFunding Flexibilities and Waivers
bullOther Considerations
bullFollow-up
5
Responding to COVID-19
Resources
bullCDC Guidance Supporting People Experiencing Homelessness
bullUSICH COVID-19 resources
bullContact your USICH Regional Coordinator using our State Data and Contacts Map (click on your state to find your RC)
bullSign-up for our newsletter
6
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Office of Special Needs Assistance Programs
7
Prioritize Your COVID-19 Response
bull SNAPS understands your 1 priority right now is responding to COVID-19
bull HUD will take into account the need for COVID response when considering performance metrics subrecipient monitoring governance and future HUD monitoring and CoC Competitions
bull CoCs are encouraged to be as flexible as possible when thinking through their local competition metrics
Resources for CoCs and Homeless Assistance Providers on the HUD ExchangeInfectious Disease Prevention amp Response page on HUD Exchange
bull Submit a question on the HUD Exchange Ask-A-Question (AAQ) Portal
Check back regularly for new posts
Key Websites with Available Resources
HUD httpswwwhudexchangeinfohomelessness-assistancediseasesinfectious-disease-prevention-response
CDC httpswwwcdcgovcoronavirus2019-ncovcommunityhomeless-sheltersindexhtml
NHCHC httpsnhchcorgclinical-practicediseases-and-conditionsinfluenza
USICH httpswwwusichgovtools-for-actioncoronavirus-covid-19-resources
VA httpswwwpublichealthvagovn-coronavirusindexasp
HRSA httpsbphchrsagovemergency-responsecoronavirus-frequently-asked-questionshtml
CARES Act amp COVID-19 Waivers
Lisa Coffman and Aaron Weaver
US Department of Housing and Urban Development
CARES Act Funding Breakdown
bull $4B for Emergency Solutions Grants
bull $1B Announced on April 2 2020
bull $65M for Housing Opportunities for Persons With AIDS
bull $537M for Formula Grants
bull $10M for Competitive Grants
bull $5B for Community Development Block Grant
bull $2B Announced on April 2 2020
COVID-19 Waivers
Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
DV amp Housing TA Consortium (DVHTAC)
Federal Partnersbull Family Violence Prevention amp Services ProgramHHS
bull Office on Violence Against WomenDOJ
bull Office for Victims of CrimeDOJ
bull Office of Special Needs Assistance ProgramsHUD
bull US Interagency Council on Homelessness
Technical Assistance Providers
bull National Alliance for Safe Housing (NASH)
bull Collaborative Solutions Inc (CSI)
bull National Network to End Domestic Violence (NNEDV)
bull National Resource Center on Domestic Violence (NRCDV)
bull National Sexual Violence Resource Center (NSVRC)
bull Corporation for Supportive Housing (CSH)
DVHTAC Peer Support CallCOVID-19 Funding
Jasmine Hayes Deputy Director
April 10 2020
bullPlan
bullCommunity Planning and Preparedness
bullAct
bullSite-Specific Emergency Operations
bullClient Support and Care
bullFunding Flexibilities and Waivers
bullOther Considerations
bullFollow-up
5
Responding to COVID-19
Resources
bullCDC Guidance Supporting People Experiencing Homelessness
bullUSICH COVID-19 resources
bullContact your USICH Regional Coordinator using our State Data and Contacts Map (click on your state to find your RC)
bullSign-up for our newsletter
6
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Office of Special Needs Assistance Programs
7
Prioritize Your COVID-19 Response
bull SNAPS understands your 1 priority right now is responding to COVID-19
bull HUD will take into account the need for COVID response when considering performance metrics subrecipient monitoring governance and future HUD monitoring and CoC Competitions
bull CoCs are encouraged to be as flexible as possible when thinking through their local competition metrics
Resources for CoCs and Homeless Assistance Providers on the HUD ExchangeInfectious Disease Prevention amp Response page on HUD Exchange
bull Submit a question on the HUD Exchange Ask-A-Question (AAQ) Portal
Check back regularly for new posts
Key Websites with Available Resources
HUD httpswwwhudexchangeinfohomelessness-assistancediseasesinfectious-disease-prevention-response
CDC httpswwwcdcgovcoronavirus2019-ncovcommunityhomeless-sheltersindexhtml
NHCHC httpsnhchcorgclinical-practicediseases-and-conditionsinfluenza
USICH httpswwwusichgovtools-for-actioncoronavirus-covid-19-resources
VA httpswwwpublichealthvagovn-coronavirusindexasp
HRSA httpsbphchrsagovemergency-responsecoronavirus-frequently-asked-questionshtml
CARES Act amp COVID-19 Waivers
Lisa Coffman and Aaron Weaver
US Department of Housing and Urban Development
CARES Act Funding Breakdown
bull $4B for Emergency Solutions Grants
bull $1B Announced on April 2 2020
bull $65M for Housing Opportunities for Persons With AIDS
bull $537M for Formula Grants
bull $10M for Competitive Grants
bull $5B for Community Development Block Grant
bull $2B Announced on April 2 2020
COVID-19 Waivers
Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
DVHTAC Peer Support CallCOVID-19 Funding
Jasmine Hayes Deputy Director
April 10 2020
bullPlan
bullCommunity Planning and Preparedness
bullAct
bullSite-Specific Emergency Operations
bullClient Support and Care
bullFunding Flexibilities and Waivers
bullOther Considerations
bullFollow-up
5
Responding to COVID-19
Resources
bullCDC Guidance Supporting People Experiencing Homelessness
bullUSICH COVID-19 resources
bullContact your USICH Regional Coordinator using our State Data and Contacts Map (click on your state to find your RC)
bullSign-up for our newsletter
6
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Office of Special Needs Assistance Programs
7
Prioritize Your COVID-19 Response
bull SNAPS understands your 1 priority right now is responding to COVID-19
bull HUD will take into account the need for COVID response when considering performance metrics subrecipient monitoring governance and future HUD monitoring and CoC Competitions
bull CoCs are encouraged to be as flexible as possible when thinking through their local competition metrics
Resources for CoCs and Homeless Assistance Providers on the HUD ExchangeInfectious Disease Prevention amp Response page on HUD Exchange
bull Submit a question on the HUD Exchange Ask-A-Question (AAQ) Portal
Check back regularly for new posts
Key Websites with Available Resources
HUD httpswwwhudexchangeinfohomelessness-assistancediseasesinfectious-disease-prevention-response
CDC httpswwwcdcgovcoronavirus2019-ncovcommunityhomeless-sheltersindexhtml
NHCHC httpsnhchcorgclinical-practicediseases-and-conditionsinfluenza
USICH httpswwwusichgovtools-for-actioncoronavirus-covid-19-resources
VA httpswwwpublichealthvagovn-coronavirusindexasp
HRSA httpsbphchrsagovemergency-responsecoronavirus-frequently-asked-questionshtml
CARES Act amp COVID-19 Waivers
Lisa Coffman and Aaron Weaver
US Department of Housing and Urban Development
CARES Act Funding Breakdown
bull $4B for Emergency Solutions Grants
bull $1B Announced on April 2 2020
bull $65M for Housing Opportunities for Persons With AIDS
bull $537M for Formula Grants
bull $10M for Competitive Grants
bull $5B for Community Development Block Grant
bull $2B Announced on April 2 2020
COVID-19 Waivers
Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
bullPlan
bullCommunity Planning and Preparedness
bullAct
bullSite-Specific Emergency Operations
bullClient Support and Care
bullFunding Flexibilities and Waivers
bullOther Considerations
bullFollow-up
5
Responding to COVID-19
Resources
bullCDC Guidance Supporting People Experiencing Homelessness
bullUSICH COVID-19 resources
bullContact your USICH Regional Coordinator using our State Data and Contacts Map (click on your state to find your RC)
bullSign-up for our newsletter
6
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Office of Special Needs Assistance Programs
7
Prioritize Your COVID-19 Response
bull SNAPS understands your 1 priority right now is responding to COVID-19
bull HUD will take into account the need for COVID response when considering performance metrics subrecipient monitoring governance and future HUD monitoring and CoC Competitions
bull CoCs are encouraged to be as flexible as possible when thinking through their local competition metrics
Resources for CoCs and Homeless Assistance Providers on the HUD ExchangeInfectious Disease Prevention amp Response page on HUD Exchange
bull Submit a question on the HUD Exchange Ask-A-Question (AAQ) Portal
Check back regularly for new posts
Key Websites with Available Resources
HUD httpswwwhudexchangeinfohomelessness-assistancediseasesinfectious-disease-prevention-response
CDC httpswwwcdcgovcoronavirus2019-ncovcommunityhomeless-sheltersindexhtml
NHCHC httpsnhchcorgclinical-practicediseases-and-conditionsinfluenza
USICH httpswwwusichgovtools-for-actioncoronavirus-covid-19-resources
VA httpswwwpublichealthvagovn-coronavirusindexasp
HRSA httpsbphchrsagovemergency-responsecoronavirus-frequently-asked-questionshtml
CARES Act amp COVID-19 Waivers
Lisa Coffman and Aaron Weaver
US Department of Housing and Urban Development
CARES Act Funding Breakdown
bull $4B for Emergency Solutions Grants
bull $1B Announced on April 2 2020
bull $65M for Housing Opportunities for Persons With AIDS
bull $537M for Formula Grants
bull $10M for Competitive Grants
bull $5B for Community Development Block Grant
bull $2B Announced on April 2 2020
COVID-19 Waivers
Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Resources
bullCDC Guidance Supporting People Experiencing Homelessness
bullUSICH COVID-19 resources
bullContact your USICH Regional Coordinator using our State Data and Contacts Map (click on your state to find your RC)
bullSign-up for our newsletter
6
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Office of Special Needs Assistance Programs
7
Prioritize Your COVID-19 Response
bull SNAPS understands your 1 priority right now is responding to COVID-19
bull HUD will take into account the need for COVID response when considering performance metrics subrecipient monitoring governance and future HUD monitoring and CoC Competitions
bull CoCs are encouraged to be as flexible as possible when thinking through their local competition metrics
Resources for CoCs and Homeless Assistance Providers on the HUD ExchangeInfectious Disease Prevention amp Response page on HUD Exchange
bull Submit a question on the HUD Exchange Ask-A-Question (AAQ) Portal
Check back regularly for new posts
Key Websites with Available Resources
HUD httpswwwhudexchangeinfohomelessness-assistancediseasesinfectious-disease-prevention-response
CDC httpswwwcdcgovcoronavirus2019-ncovcommunityhomeless-sheltersindexhtml
NHCHC httpsnhchcorgclinical-practicediseases-and-conditionsinfluenza
USICH httpswwwusichgovtools-for-actioncoronavirus-covid-19-resources
VA httpswwwpublichealthvagovn-coronavirusindexasp
HRSA httpsbphchrsagovemergency-responsecoronavirus-frequently-asked-questionshtml
CARES Act amp COVID-19 Waivers
Lisa Coffman and Aaron Weaver
US Department of Housing and Urban Development
CARES Act Funding Breakdown
bull $4B for Emergency Solutions Grants
bull $1B Announced on April 2 2020
bull $65M for Housing Opportunities for Persons With AIDS
bull $537M for Formula Grants
bull $10M for Competitive Grants
bull $5B for Community Development Block Grant
bull $2B Announced on April 2 2020
COVID-19 Waivers
Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Office of Special Needs Assistance Programs
7
Prioritize Your COVID-19 Response
bull SNAPS understands your 1 priority right now is responding to COVID-19
bull HUD will take into account the need for COVID response when considering performance metrics subrecipient monitoring governance and future HUD monitoring and CoC Competitions
bull CoCs are encouraged to be as flexible as possible when thinking through their local competition metrics
Resources for CoCs and Homeless Assistance Providers on the HUD ExchangeInfectious Disease Prevention amp Response page on HUD Exchange
bull Submit a question on the HUD Exchange Ask-A-Question (AAQ) Portal
Check back regularly for new posts
Key Websites with Available Resources
HUD httpswwwhudexchangeinfohomelessness-assistancediseasesinfectious-disease-prevention-response
CDC httpswwwcdcgovcoronavirus2019-ncovcommunityhomeless-sheltersindexhtml
NHCHC httpsnhchcorgclinical-practicediseases-and-conditionsinfluenza
USICH httpswwwusichgovtools-for-actioncoronavirus-covid-19-resources
VA httpswwwpublichealthvagovn-coronavirusindexasp
HRSA httpsbphchrsagovemergency-responsecoronavirus-frequently-asked-questionshtml
CARES Act amp COVID-19 Waivers
Lisa Coffman and Aaron Weaver
US Department of Housing and Urban Development
CARES Act Funding Breakdown
bull $4B for Emergency Solutions Grants
bull $1B Announced on April 2 2020
bull $65M for Housing Opportunities for Persons With AIDS
bull $537M for Formula Grants
bull $10M for Competitive Grants
bull $5B for Community Development Block Grant
bull $2B Announced on April 2 2020
COVID-19 Waivers
Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Prioritize Your COVID-19 Response
bull SNAPS understands your 1 priority right now is responding to COVID-19
bull HUD will take into account the need for COVID response when considering performance metrics subrecipient monitoring governance and future HUD monitoring and CoC Competitions
bull CoCs are encouraged to be as flexible as possible when thinking through their local competition metrics
Resources for CoCs and Homeless Assistance Providers on the HUD ExchangeInfectious Disease Prevention amp Response page on HUD Exchange
bull Submit a question on the HUD Exchange Ask-A-Question (AAQ) Portal
Check back regularly for new posts
Key Websites with Available Resources
HUD httpswwwhudexchangeinfohomelessness-assistancediseasesinfectious-disease-prevention-response
CDC httpswwwcdcgovcoronavirus2019-ncovcommunityhomeless-sheltersindexhtml
NHCHC httpsnhchcorgclinical-practicediseases-and-conditionsinfluenza
USICH httpswwwusichgovtools-for-actioncoronavirus-covid-19-resources
VA httpswwwpublichealthvagovn-coronavirusindexasp
HRSA httpsbphchrsagovemergency-responsecoronavirus-frequently-asked-questionshtml
CARES Act amp COVID-19 Waivers
Lisa Coffman and Aaron Weaver
US Department of Housing and Urban Development
CARES Act Funding Breakdown
bull $4B for Emergency Solutions Grants
bull $1B Announced on April 2 2020
bull $65M for Housing Opportunities for Persons With AIDS
bull $537M for Formula Grants
bull $10M for Competitive Grants
bull $5B for Community Development Block Grant
bull $2B Announced on April 2 2020
COVID-19 Waivers
Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Resources for CoCs and Homeless Assistance Providers on the HUD ExchangeInfectious Disease Prevention amp Response page on HUD Exchange
bull Submit a question on the HUD Exchange Ask-A-Question (AAQ) Portal
Check back regularly for new posts
Key Websites with Available Resources
HUD httpswwwhudexchangeinfohomelessness-assistancediseasesinfectious-disease-prevention-response
CDC httpswwwcdcgovcoronavirus2019-ncovcommunityhomeless-sheltersindexhtml
NHCHC httpsnhchcorgclinical-practicediseases-and-conditionsinfluenza
USICH httpswwwusichgovtools-for-actioncoronavirus-covid-19-resources
VA httpswwwpublichealthvagovn-coronavirusindexasp
HRSA httpsbphchrsagovemergency-responsecoronavirus-frequently-asked-questionshtml
CARES Act amp COVID-19 Waivers
Lisa Coffman and Aaron Weaver
US Department of Housing and Urban Development
CARES Act Funding Breakdown
bull $4B for Emergency Solutions Grants
bull $1B Announced on April 2 2020
bull $65M for Housing Opportunities for Persons With AIDS
bull $537M for Formula Grants
bull $10M for Competitive Grants
bull $5B for Community Development Block Grant
bull $2B Announced on April 2 2020
COVID-19 Waivers
Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Key Websites with Available Resources
HUD httpswwwhudexchangeinfohomelessness-assistancediseasesinfectious-disease-prevention-response
CDC httpswwwcdcgovcoronavirus2019-ncovcommunityhomeless-sheltersindexhtml
NHCHC httpsnhchcorgclinical-practicediseases-and-conditionsinfluenza
USICH httpswwwusichgovtools-for-actioncoronavirus-covid-19-resources
VA httpswwwpublichealthvagovn-coronavirusindexasp
HRSA httpsbphchrsagovemergency-responsecoronavirus-frequently-asked-questionshtml
CARES Act amp COVID-19 Waivers
Lisa Coffman and Aaron Weaver
US Department of Housing and Urban Development
CARES Act Funding Breakdown
bull $4B for Emergency Solutions Grants
bull $1B Announced on April 2 2020
bull $65M for Housing Opportunities for Persons With AIDS
bull $537M for Formula Grants
bull $10M for Competitive Grants
bull $5B for Community Development Block Grant
bull $2B Announced on April 2 2020
COVID-19 Waivers
Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
CARES Act amp COVID-19 Waivers
Lisa Coffman and Aaron Weaver
US Department of Housing and Urban Development
CARES Act Funding Breakdown
bull $4B for Emergency Solutions Grants
bull $1B Announced on April 2 2020
bull $65M for Housing Opportunities for Persons With AIDS
bull $537M for Formula Grants
bull $10M for Competitive Grants
bull $5B for Community Development Block Grant
bull $2B Announced on April 2 2020
COVID-19 Waivers
Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
CARES Act Funding Breakdown
bull $4B for Emergency Solutions Grants
bull $1B Announced on April 2 2020
bull $65M for Housing Opportunities for Persons With AIDS
bull $537M for Formula Grants
bull $10M for Competitive Grants
bull $5B for Community Development Block Grant
bull $2B Announced on April 2 2020
COVID-19 Waivers
Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
COVID-19 Waivers
Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Background
bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with
bull Continuum of Care (CoC) Program
bull Emergency Solutions Grant (ESG) Program
bull Housing Opportunities for Persons with AIDS (HOPWA) Program
bull Consolidated Plan Requirements
bull Effective date is March 31 2020
bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Submitting and Documenting Waivers
bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility
bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers
Step 1 Notify CPD
FO Director
Step 2 Waiting
Period of 2 Calendar
Days
Step 3a
Utilize Waiver
Step 3b Document Conditions (Recpient)
Step 4 Document
Use (Client)
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Resources
bull Waiver Memorandum Description of available waivers and the notification procedure
bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers
bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Continuum of Care (CoC) Program
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
CoC Program Waivers
The following waivers are available for the CoC Program
1
6
4
2
3
5
7
Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)
Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)
Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)
Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)
Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)
HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)
One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Fair Market Rent for Individual Units and Leasing Costs
Requirement Applicability Other Provisions
Rent payments for
individual units with leasing
dollars may not exceed Fair
Market Rent (FMR)
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
lease executed by a
recipient or subrecipient to
provide transitional or
permanent supportive
housing
The affected recipient or
subrecipient must still
ensure that rent paid for
individual units that are
leased with CoC Program
leasing dollars meet the
rent reasonableness
standard in 24 CFR
57849(b)(2)
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Disability Documentation for Permanent Supportive Housing
Requirement Applicability Other Provisions
A recipient providing PSH
must document a qualifying
disability of one of the
household members When
documentation of disability is
the intake workerrsquos
observation the regulation
requires the recipient to
obtain additional confirming
evidence within 45 days
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the requirement
to have third party
documentation of disability
that intake staff-recorded
observation of disability be
confirmed and accompanied
by other evidence no later
than 45 days from the
application for assistance
documentation requirement is
waived for any program
participants admitted into
PSH funded by the CoC
Program
For the purposes of individuals
and families housed in PSH
from the date of this
memorandum until public
health officials determine no
additional special measures
are necessary to prevent the
spread of COVID-19 a written
certification by the individual
seeking assistance that they
have a qualifying disability is
considered acceptable
documentation approved by
HUD under 24 CFR
578103(a)(4)(i)(B)(5)
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Limit on Eligible Housing Search and Counseling Services
Requirement Applicability Other Provisions
With respect to program
participantrsquos debts 24 CFR
57853(ed)(8)(ii)(B)
only allows the costs of
credit counseling
accessing a free personal
credit report and resolving
personal credit issues 24
CFR 57853(d) limits the
use of CoC Program funds
for providing services to
only those costs listed in
the interim rule
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) the limitation on
eligible housing search and
counseling activities is
waived so that CoC Program
funds may be used for up to 6
months of a program
participantrsquos utility arrears
and up to 6 months of
program participantrsquos rent
arrears when those arrears
make it difficult to obtain
housing
Only applies when those
arrears make it difficult to
obtain housing
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Permanent Housing-Rapid Re-housing Monthly Case Management
Requirement Applicability
Recipients must require program
participants of permanent housing ndash rapid
re-housing projects to meet with a case
manager at least monthly
For 2-month period beginning on the
date of the waiver memorandum
(3312020) the requirement in 24 CFR
57837(a)(1)(ii)(F) that requires program
participants to meet with case mangers not
less than once per month is waived for all
permanent housing- rapid re-housing
projects
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit
Requirement Applicability Other Provisions
Recipients are required
to physically inspect any
unit supported with
leasing or rental
assistance funds to
assure that the unit
meets housing quality
standards (HQS) before
any assistance will be
provided on behalf of a
program participant
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) this waiver of
the requirement in 24 CFR
57875(b)(1) that the
recipient or subrecipient
physically inspect each unit
to assure that the unit
meets HQS before
providing assistance on
behalf of a program
participant is in effect
Recipients and subrecipients
must meet both the following
criteria
bull The recipient is able to
visually inspect the unit
using technology such as
video streaming to ensure
the unit meets HQS before
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically reinspect the unit
within 3 months after the
health officials determine
special measures to
prevent the spread of
COVID-19 are no longer
necessary
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
HQS ndash Re-Inspection of Units
Requirement Applicability
Recipients or subrecipients must
inspect all units for which leasing or
rental assistance funds are used at
least annually to ensure they continue
to meet HQS
For the 1-year period beginning on
the date of the waiver
memorandum (3312020) this
requirement in 24 CFR 578(b)(2) is
waived
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
One-Year Lease Requirement Definition of Permanent Housing
Requirement Applicability Other Provisions
Program participants
residing in PSH must be the
tenant on a lease for a term
of at least one year that is
renewable and terminable
for cause
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the one-year
lease requirement is waived
The initial lease term of all
leases must be for more
than one month
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Emergency Solutions Grant (ESG) Program
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
ESG Program Waivers
The following waivers are available for the ESG Program
10
13
11
12
HMIS Lead Activities24 CFR 576107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)
Housing Stability Case Management24 CFR 576401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
HMIS Lead Activities
Requirement Applicability
ESG funds may be used to pay the costs
of managing and operating the HMIS
provided that the ESG recipient is the
HMIS Lead
For the 6-month period beginning on
the date of the waiver memorandum
(3312020) the condition that the recipient
must be the HMIS Lead to pay costs under
24 CFR 576102(a)(2) is waived to the
extent necessary to allow any recipient to
use ESG funds to pay costs of upgrading
or enhancing its local HMIS to incorporate
data on ESG Program participants and
ESG activities related to COVID-19
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention
assistance is subject to re-
evaluation of each program
participantrsquos eligibility need
for assistance not less than
once every 3 months
For up to the 2-year
period beginning on the
date of the waiver
memorandum (3312020)
the required frequency of
re-evaluations for
homelessness prevention
assistance under section
576401(b) is waived
The recipient or
subrecipient must conduct
the required re-evaluations
not less than once every
6 months
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Housing Stability Case Management
Requirement Applicability
Program participants receiving
homelessness prevention or rapid re-
housing assistance must meet with a case
manager not less than once per month
unless certain statutory prohibitions apply
For the 2-month period beginning on
the date of the waiver memorandum
(3312020) this waiver is in effect
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR
576106(d)(1) rental
assistance cannot be
provided unless the total
rent is equal to or less than
the FMR established by
HUD as provided under 24
CFR Part 888 and
complies with HUDrsquos
standard of rent
reasonableness as
established under 24 CFR
982507
For the 6-month period
beginning on the date of
the waiver memorandum
(3312020) the FMR
restriction is waived for any
individual or family
receiving Rapid Re-housing
or Homelessness
Prevention assistance who
executes a lease for a unit
The ESG recipient or
subrecipient must still
ensure that the units in
which ESG assistance is
provided to these
individuals and families
meet the rent
reasonableness standard
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Housing Opportunities for Persons with AIDS (HOPWA) Program
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
HOPWA Program Waivers
The following waivers are available for the HOPWA Program
14
17
15
16
Self-Certification of Income and Credible Information on HIV Status24 CFR 574530
FMR Rent Standard24 CFR 574320(a)(2)
Property Standards for TBRA24 CFR 574310(b)
Space and Security24 CFR 574310(b)(2)(iii)
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Self-Certification of Income and Credible Information on HIV Status
Requirement Applicability Other Provisions
Each grantee must maintain
records to document
compliance with HOPWA
requirements which includes
determining the eligibility of a
family to receive HOPWA
assistance
This waiver is in effect for
recipients who require written
certification of the household
seeking assistance of their HIV
status and income and agree
to obtain source documentation
of HIV status and income
eligibility within 3 months of
public health officials
determining no additional
special measures are
necessary to prevent the
spread of COVID-19
Eligibility is restricted to a low-
income person who is living
with HIVAIDS and the family of
such person
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
FMR Rent Standard
Requirement Applicability
Grantees must establish rent standards for
their tenant-based rental assistance
programs based on FMR (Fair Market
Rent) or the HUD approved community-
wide exception rent for unit size Generally
the TBRA payment may not exceed the
difference between the rent standard and
30 percent of the familys adjusted income
Such rent standards may be used for up
to one year beginning on the date of the
memorandum (3312020)
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Property Standards for TBRA
Requirement Applicability Other Provisions
This section of the HOPWA
regulations provides that
units occupied by recipients
of HOPWA TBRA meet the
Housing Quality Standards
(HQS) established in this
section
For the 1-year period
beginning on the date of
the waiver memorandum
(3312020) this waiver is
in effect
Recipients and project sponsors
that must meet the following
criteria
bull The recipient or project
sponsor is able to visually
inspect the unit using
technology such as video
streaming to ensure the unit
meets HQS before any
assistance is provided and
bull The recipient or subrecipient
has written policies to
physically re-inspect the unit
after the health officials
determine special measures
to prevent the spread of
COVID-19 are no longer
necessary
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Space and Security
Requirement Applicability
This section of the HOPWA regulations
provide that each resident must be
afforded adequate space and security for
themselves and their belongings
Waived for grantees addressing
appropriate quarantine space for affected
eligible households during the allotted
quarantined timeframe recommended
by local health care professionals
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Consolidated Plan Requirements
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Consolidated Plan Waivers
The following waivers are available for Consolidated Plan requirements
8
9
Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Citizen Participation Public Comment Period for Consolidated Plan Amendment
Requirement Applicability Other Provisions
A CPD grantee may amend
an approved consolidated
plan in accordance with 24
CFR 91505 Substantial
amendments to the
consolidated plan are
subject to the citizen
participation process in the
granteersquos citizen
participation plan The
citizen participation plan
must provide citizens with
30 days to comment on
substantial amendments
Through the end of the
recipientrsquos 2020 program
year the 30-day minimum
for the required public
comment period is waived
for substantial amendments
Grantees must provide no
less than 5 days for public
comments on each
substantial amendment
Any recipient wishing to
undertake further
amendments to prior year
plans following the 2020
program year can do so
during the development of
its FY 2021 Annual Action
Plan
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Citizen Participation Reasonable Notice and Opportunity to Comment
Requirement Applicability
As noted above the regulations at 24 CFR
91105 (for local governments) and 91115
(for States) set forth the citizen
participation plan requirements for
recipients For substantial amendments to
the consolidated plan the regulations
require the recipient to follow its citizen
participation plan to provide citizens with
reasonable notice and opportunity to
comment The citizen participation plan
must state how reasonable notice and
opportunity to comment will be given
HUD waives 24 CFR 91105(c)(2) and (k)
24 CFR 91115(c)(2) and (i) and 24 CFR
91401 to allow these grantees to
determine what constitutes reasonable
notice and opportunity to comment given
their circumstances
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Sarah Saadian
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
CARES Act HUD Homeless Funding
Domestic Violence
Steve Berg
National Alliance to End Homelessness
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
CARES Act ESG funding
Emergency Solutions Grants
bull Larger cities and counties and ldquobalance of
staterdquo are recipients
bull Regular ESG is about $280 million
bull Mostly subcontracted to nonprofits
bull Outreach shelter rapid rehousing
construction and operating costs
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
CARES Act ESG
Changes from usual ESG - money
bull Lots more money $4 billion
bull ldquoUp tordquo $2 billion under the usual formula
bull The rest under a new formula meant to
target need as a result of coronavirus
bull HUD has already announced $1 billion in
allocations more ldquosoonrdquo
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
CARES Act ESG
Changes from usual ESG - flexibility
bull No matching requirement
bull No ldquoshelter caprdquo
bull Anybody whose income is under 50 of
area median income is eligible for help
bull No treatment or performance requirement
may be imposed
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
CARES Act ESG
Best uses
bull Shelter expansion and deconcentration
(CDC guidelines)
bull Non-congregate shelter
bull Connection with permanent housing
bull Landlord outreach
bull Rental assistance up to 2 years
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Homelessness
Steve Berg
National Alliance to End Homelessness
sbergnaehorg
Twitter sberg0
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance
Advocacy framed by safety planning and awareness of potential for abuser sabotage
Survivor driven trauma informed culturally and linguistically responsive voluntary services
Broad eligibility minimal program requirements
Flexible duration for survivors who need longer term support
Support for reconnecting with community
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims
of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4
bull $45 Million FVPSA-
--FVPSA include basic needs
--FVPSA covers rental assistance hotel motel utilities
bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of
temporary refuge in conjunction with supportive services in compliance with
applicable State or Tribal law or regulations
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Need Technical Assistance or Training
Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar
Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov
B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov
Jasmine Hayes US Interagency Council on Homelessness
jasminehayesusichgov
Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg
Steve Berg National Alliance to End Homelessnesssbergnaehorg
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Tell us what you are doing
bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and
their children during COVID-19
bull What is working in your community and how can we increase supports for survivors during COVID-19
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
Questions and Discussion
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site
Domestic Violence and Housing Technical Assistance Consortium
wwwsafehousingpartnershipsorg
SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical
Assistance Consortium
bull Data infographics literature reviews and reports that describe the intersections between
domestic violence sexual assault homelessness and housing
bull Strategies for building effective and sustainable partnerships across systems and case
studies of successful collaborations
bull In-depth resource collections organized around four key approaches to addressing and
preventing housing instability among survivors
bull Access to relevant federal laws regulations and polices
Have questions Need TA Want training
Contact the Consortium directly through the site