“Overview and Comments on HUD’s NoFA: Housing Vouchers for Non-Elderly Individuals with Disabilities“ Center for Medicare and Medicaid Services

““Overview and Comments on HUD’s Overview and Comments on HUD’s NoFA: Housing Vouchers for Non-NoFA: Housing Vouchers for Non-

Elderly Elderly

Individuals with Disabilities“Individuals with Disabilities“

Center for Medicare and Medicaid Services Center for Medicare and Medicaid Services

22

BackgroundBackground

Historically, non-elderly persons with Historically, non-elderly persons with disabilities have sought to:disabilities have sought to:

Have access to affordable housing, Have access to affordable housing,

Overcome housing barriers to transition back Overcome housing barriers to transition back to the community, and to the community, and

Have choices about where they decide to Have choices about where they decide to live.live.

33


The Department of Housing and Urban The Department of Housing and Urban Development (HUD) and the Centers for Development (HUD) and the Centers for Medicare & Medicaid Services (CMS) have Medicare & Medicaid Services (CMS) have established a working relationship to expand established a working relationship to expand the availability of funding for accessible and the availability of funding for accessible and affordable housing.affordable housing.

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On June 22, 2009, HUD posted in the Federal On June 22, 2009, HUD posted in the Federal Register, a draft, proposed Notice of Funding Register, a draft, proposed Notice of Funding Availability (NOFA) of $30M for: Availability (NOFA) of $30M for:

4,000 new Housing Choice Vouchers4,000 new Housing Choice Vouchers

1,000 of these vouchers target non-elderly 1,000 of these vouchers target non-elderly persons with disabilities transitioning out of persons with disabilities transitioning out of institutional settings.institutional settings.

55


HUD’s “Proposed Notice of Funding Availability HUD’s “Proposed Notice of Funding Availability (NOFA) for Fiscal Year (FY) 2009 Rental (NOFA) for Fiscal Year (FY) 2009 Rental Assistance for Non-Elderly Persons With Assistance for Non-Elderly Persons With Disabilities; Request for Comments”, is Disabilities; Request for Comments”, is available at:available at:

http://edocket.access.gpo.gov/2009/pdf/E9-http://edocket.access.gpo.gov/2009/pdf/E9-14651.pdf 14651.pdf

Federal Register/Vol 74, No. 118/Monday, June 22, 2009/Notices. All page numbers in Federal Register/Vol 74, No. 118/Monday, June 22, 2009/Notices. All page numbers in

this presentation, unless otherwise specified, refer to this document. this presentation, unless otherwise specified, refer to this document.

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The OpportunityThe Opportunity

HUD’s Proposed NOFA identified two specific HUD’s Proposed NOFA identified two specific target groups for the vouchers:target groups for the vouchers:

1)1) Those with a disability, at risk of Those with a disability, at risk of institutionalization, who are on a waiting institutionalization, who are on a waiting list for subsidized housing, and list for subsidized housing, and

2)2) Those seeking to transition from a nursing Those seeking to transition from a nursing facility or other institutional setting to the facility or other institutional setting to the community.community.

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These Vouchers are described as: These Vouchers are described as:

Category 1 vouchers “…enable non-elderly Category 1 vouchers “…enable non-elderly disabled families on a PHA’s waiting list to access disabled families on a PHA’s waiting list to access affordable housing…”affordable housing…”11 and are targeted towards and are targeted towards households at risk of institutionalization. households at risk of institutionalization.

Category 2 vouchers “…enable non-elderly persons Category 2 vouchers “…enable non-elderly persons with disabilities to transition from nursing homes with disabilities to transition from nursing homes and other health care institutions into the and other health care institutions into the community”.community”.22

Seventy-five percent of the funds, or about 3,000 Seventy-five percent of the funds, or about 3,000 vouchers,vouchers,

support Category 1 recipients.support Category 1 recipients.

1 Federal Register/Vol. 74, No. 118/Monday, June 22, 2009, page 29504.1 Federal Register/Vol. 74, No. 118/Monday, June 22, 2009, page 29504.2 Federal Register/Vol. 74, No. 118/Monday, June 22, 2009, page 29504. 2 Federal Register/Vol. 74, No. 118/Monday, June 22, 2009, page 29504.

88


OpportunityOpportunity to address the housing needs of non-elderly to address the housing needs of non-elderly persons with disabilities,persons with disabilities,

OpportunityOpportunity to increase number of actual transitions in to increase number of actual transitions in your State,your State,

OpportunityOpportunity to further relationships with PHAs, and to further relationships with PHAs, and

OpportunityOpportunity to prevent possible institutionalization of to prevent possible institutionalization of non-elderly individuals with disabilities who are “at risk”non-elderly individuals with disabilities who are “at risk”

OpportunityOpportunity for more vouchers to be issued in the future. for more vouchers to be issued in the future.

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HUD Requests HUD Requests CommentsComments

The proposed NOFA solicits comments on:The proposed NOFA solicits comments on:

Threshold factors Threshold factors Alternative distribution methods (performance Alternative distribution methods (performance

based, for example)based, for example) How…”state institutional transition programs, How…”state institutional transition programs,

such as the Money Follow the Person such as the Money Follow the Person Demonstration, can work effectively with the Demonstration, can work effectively with the PHAs that are awarded vouchers for this PHAs that are awarded vouchers for this purpose.”purpose.”

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HUD Requests HUD Requests CommentsCommentsProposed Proposed ThresholdThreshold factors are: factors are:

Standard threshold factors for PHAs Standard threshold factors for PHAs Written code of conduct in PHA Administrative Written code of conduct in PHA Administrative

PlanPlan Affirmatively Furthering Fair Housing Affirmatively Furthering Fair Housing

requirementsrequirements PHA must be in good standing with HUD and PHA must be in good standing with HUD and

meet specific performance criteria (FR, page meet specific performance criteria (FR, page 29506). 29506).

Experience serving persons with disabilitiesExperience serving persons with disabilities Resources for Supportive ServicesResources for Supportive Services

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Proposed Proposed ThresholdThreshold factors – some details: factors – some details: Standard threshold factors for PHAs (Section III.C. of Standard threshold factors for PHAs (Section III.C. of

PHA General Section Federal Register “will be PHA General Section Federal Register “will be available” at www.grants.gov)available” at www.grants.gov)

Affirmatively Furthering Fair Housing requirements, Affirmatively Furthering Fair Housing requirements, including an addendum outlining actions specific to including an addendum outlining actions specific to this program. Must include informing applicants how this program. Must include informing applicants how to file a fair housing complaint. to file a fair housing complaint.

PHA must be in good standing with HUD and meet PHA must be in good standing with HUD and meet specific performance criteria (FR, page 29506). specific performance criteria (FR, page 29506).

llll

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Proposed Proposed ThresholdThreshold factors – some details: factors – some details: Experience: PHAs must demonstrate experience via the following Experience: PHAs must demonstrate experience via the following

criteria:criteria:– Document that at least 20% of the PHA’s current HCVs are used by “non-Document that at least 20% of the PHA’s current HCVs are used by “non-

elderly disabled families”, elderly disabled families”, oror– Document that the PHA has established a preference for “non-elderly Document that the PHA has established a preference for “non-elderly

disabled families”, disabled families”, oror– Document that the PHA has participated in specific programs: Rental Document that the PHA has participated in specific programs: Rental

Assistance for Non-Elderly Persons with Disabilities in Support of Assistance for Non-Elderly Persons with Disabilities in Support of Designated Housing Plans; Rental Assistance for Non-Elderly Persons Designated Housing Plans; Rental Assistance for Non-Elderly Persons with Disabilities Related to Certain Types of Section 8 Project-Based with Disabilities Related to Certain Types of Section 8 Project-Based Developments; Mainstream Housing Opportunities for Persons with Developments; Mainstream Housing Opportunities for Persons with Disabilities; Project Access Program.Disabilities; Project Access Program.

Page 29507Page 29507

llll

Threshold Criteria Threshold Criteria CommentComment

The Issue:The Issue: PHAs are the only eligible PHAs are the only eligible applicants. applicants.

Description of the Problem: Description of the Problem: - Programs seeking either category 1 and/or - Programs seeking either category 1 and/or

category 2 vouchers are at the mercy of the category 2 vouchers are at the mercy of the PHAs in their area. If a PHA chooses not to PHAs in their area. If a PHA chooses not to participate, there is no remedy. participate, there is no remedy.

Possible Comment:Possible Comment: - Encourage HUD to allow non-PHA applicants - Encourage HUD to allow non-PHA applicants

under certain conditions (when a PHA in a under certain conditions (when a PHA in a jurisdiction is ineligible or will not apply).jurisdiction is ineligible or will not apply).

1414

HUD Requests HUD Requests CommentsCommentsProposed Proposed ThresholdThreshold factors – some details: factors – some details:

Resources for supportive servicesResources for supportive services– For category 1: must “…describe those For category 1: must “…describe those

resources in full detail…”resources in full detail…”– For category 2: must “…identify the partnering For category 2: must “…identify the partnering

resource agency and describe the provision of resource agency and describe the provision of supportive services for a transitioned person.”supportive services for a transitioned person.”

Page 29507Page 29507

llll

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Threshold Criteria Threshold Criteria CommentsComments

The Issue: The Issue: Only PHAs with specific experience Only PHAs with specific experience may may apply. apply.

Description of the Problem: Description of the Problem: - This could eliminate a friendly PHA (perhaps without the - This could eliminate a friendly PHA (perhaps without the specific experience) that might be willing to partner with specific experience) that might be willing to partner with service providers capable of providing sufficient services to service providers capable of providing sufficient services to transition or maintain individuals in the community. transition or maintain individuals in the community.

Possible Comment: Possible Comment: - - Encourage HUD to accept applications from PHAs without Encourage HUD to accept applications from PHAs without the required experience where that PHA can document a the required experience where that PHA can document a working partnership with Medicaid-funded transition working partnership with Medicaid-funded transition programs and/or other community-based programs capable programs and/or other community-based programs capable of providing essential services and supports. of providing essential services and supports.

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Distribution Method Distribution Method CommentsComments

The Issue:The Issue: The PHA voucher request is limited The PHA voucher request is limited to to 10% of its “…authorized 10% of its “…authorized baseline units or baseline units or 200 vouchers, 200 vouchers, whichever is less.” whichever is less.”

Description of the Problem:Description of the Problem: -- For category 2, the guiding factor should be For category 2, the guiding factor should be

the number of vouchers that can be used by the number of vouchers that can be used by the transition agency in the fiscal year. the transition agency in the fiscal year.

Possible Comment:Possible Comment: -- For category 2, allow the provider requestsFor category 2, allow the provider requests

to guide the number of vouchers requested. to guide the number of vouchers requested.

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The Issue – The Issue – HUD’s requests for “alternative HUD’s requests for “alternative methods of distribution”methods of distribution”

Description of the Problem:Description of the Problem: – The overall number of vouchers in The overall number of vouchers in

Category 1 is greater than Category 2, Category 1 is greater than Category 2,

Possible Comment:Possible Comment:- PHA baseline limits the number of vouchers - PHA baseline limits the number of vouchers

that can be requested, and that can be requested, and - Requirement that vouchers are intended - Requirement that vouchers are intended

for people on the PHA waiting list. for people on the PHA waiting list.

1818


The Issue:The Issue: Waiting List Requirement Waiting List Requirement

Description of the Problem:Description of the Problem: - There may be many “at risk” households that are not on a list - There may be many “at risk” households that are not on a list

now.now. - Some PHA lists are closed now and have been closed for long- Some PHA lists are closed now and have been closed for long periods of time. periods of time.

- For Category 2, people in institutions may not have- For Category 2, people in institutions may not have considered transition back to the community as an option, and considered transition back to the community as an option, and

maymay not be on any PHA lists. not be on any PHA lists.

Possible Comment:Possible Comment: - Requiring vouchers to be distributed to people based on their- Requiring vouchers to be distributed to people based on their presence on a waiting list will eliminate large numbers of presence on a waiting list will eliminate large numbers of

otherwise otherwise eligible persons.eligible persons.

TimetableTimetable

Applications will be due 60 days after Applications will be due 60 days after publication ofpublication of

the final NOFA.the final NOFA.

So be ready to…So be ready to…

1919

2020

ACT NOWACT NOW

AApproach the PHAspproach the PHAs

CContact your Resourcesontact your Resources

TTrain your Coordinatorsrain your Coordinators

NNetwork with your Stakeholdersetwork with your Stakeholders

OOpen doors to Communicationpen doors to Communication

WWork to make it happenork to make it happen

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Next StepsNext Steps

State Medicaid agencies and other State Medicaid agencies and other stakeholders representing services and stakeholders representing services and supports for individuals with disabilities can supports for individuals with disabilities can take some immediate next steps to make take some immediate next steps to make this opportunity more beneficial for non-this opportunity more beneficial for non-elderly individuals with disabilities. elderly individuals with disabilities.

2222

Next Steps – Related Next Steps – Related to Proposed NOFAto Proposed NOFA

Organizations seeking category 1 or category 2 Organizations seeking category 1 or category 2 HCVs can ensure they are ready to take HCVs can ensure they are ready to take advantage of these opportunities by: advantage of these opportunities by:

Making sure that people seeking transitions Making sure that people seeking transitions are on the PHA waiting list where possible. are on the PHA waiting list where possible.

Initiating conversations with PHA Partners Initiating conversations with PHA Partners about these opportunities.about these opportunities.

Identifying communities with effective Identifying communities with effective transition coordinators and case managers, transition coordinators and case managers, and matching them with PHAs.and matching them with PHAs.

2323

Next Steps – Next Steps – Preparation StepsPreparation Steps

For those communities, estimate the number For those communities, estimate the number of HCVs that can reasonably be used within of HCVs that can reasonably be used within the next 12 months, where possible.the next 12 months, where possible.– How many people are ready to exit the How many people are ready to exit the

institution and lack ONLY funding for institution and lack ONLY funding for housing? housing?

– How many people plan to transition within How many people plan to transition within the next 90 days, and lack ONLY funding the next 90 days, and lack ONLY funding for housing?for housing?

– These two groups provide a reasonable These two groups provide a reasonable estimate of the number of vouchers that estimate of the number of vouchers that could be used within the time frame. could be used within the time frame.

2424


Review HUD’s Suggested Preference Language for PHAs:Review HUD’s Suggested Preference Language for PHAs:Persons Transitioning from Institutional Settings: Persons Transitioning from Institutional Settings: Under Under the category of local preferences, a PHA may choose to provide the category of local preferences, a PHA may choose to provide a preference to people transitioning from institutional settings a preference to people transitioning from institutional settings into independent, community-based living. Institutional into independent, community-based living. Institutional settings include hospitals, nursing homes, and institutions for settings include hospitals, nursing homes, and institutions for individuals with developmental disabilities. Some people individuals with developmental disabilities. Some people transitioning may reside in one of the 29 States or the District transitioning may reside in one of the 29 States or the District of Columbia that have received specific funding for of Columbia that have received specific funding for transitioning persons from institutions through a demonstration transitioning persons from institutions through a demonstration called Money Follows the Person (MFP). MFP is administered by called Money Follows the Person (MFP). MFP is administered by the Centers for Medicare & Medicaid Servicesthe Centers for Medicare & Medicaid Services

(http://www.cms.hhs.gov/RealChoice/downloads/MFP.pdf). The (http://www.cms.hhs.gov/RealChoice/downloads/MFP.pdf). The demonstration provides the necessary health and social demonstration provides the necessary health and social services that people will require upon transitioning from an services that people will require upon transitioning from an institution and thereafter to live independently in the institution and thereafter to live independently in the community.community.

2525


Describe and document available supportive services:Describe and document available supportive services:– care management, and care management, and – needed health and social services. needed health and social services.

Prepare a general template, applicable to any Prepare a general template, applicable to any community likely to participate. Assess the readiness community likely to participate. Assess the readiness of transition coordinators and case managers to make of transition coordinators and case managers to make successful applications for HCV.successful applications for HCV.– Obtain needed documentation (i.e. award letter, Obtain needed documentation (i.e. award letter,

birth certificates)birth certificates)– Completed applicationCompleted application

Provide training and support where needed. Provide training and support where needed.

2626

Talking Points – Talking Points – Reaching out to PHAsReaching out to PHAs

Why should PHAs participate? Why should PHAs participate?

This activity helps them meet their legal and This activity helps them meet their legal and ethical obligations under Olmstead. ethical obligations under Olmstead.

National Movement towards Home and National Movement towards Home and Community-Based Health Care and Living.Community-Based Health Care and Living.

Compliance with Americans with Disabilities Compliance with Americans with Disabilities Act.Act.

It’s the right thing to do.It’s the right thing to do.

Talking Points – Talking Points – ReachingReaching

out to PHAsout to PHAsWhy should PHAs partner with MFP?Why should PHAs partner with MFP?

Medicaid-funded case managers and Medicaid-funded case managers and transition coordinators will bring qualified transition coordinators will bring qualified customers with well-prepared applications for customers with well-prepared applications for consideration. consideration.

Housing is one of the biggest barriers to Housing is one of the biggest barriers to realizing the Rebalancing of Long-Term Care realizing the Rebalancing of Long-Term Care Services and Programs.Services and Programs.

2727

Talking Points – Talking Points – Reaching Reaching out to out to PHAsPHAsWhy should PHAs partner with MFP?Why should PHAs partner with MFP?

Medicaid waivers and other Medicaid-funded Medicaid waivers and other Medicaid-funded coordinated services can assure funding for coordinated services can assure funding for supports and services.supports and services.

Transition coordinators and other service Transition coordinators and other service providers ensure all necessary supports and providers ensure all necessary supports and services. services.

– PHA staff have no additional burden.PHA staff have no additional burden. 2828

Documents

“Overview and Comments on HUD’s NoFA: Housing Vouchers for Non-Elderly Individuals with Disabilities“ Center for Medicare and Medicaid Services