Project Sponsor Meeting May 17, 2012 Weston, WV WV Balance of
State CoC
Slide 2
Purpose of this Meeting is To Review: Statutory and regulatory
requirements of the Supportive Housing Programs (SHP) and Shelter
Plus Care Program (S+C); Client intake and exit procedures, and in
HMIS Termination policies for clients, especially in PSH;
Performance measures to track monthly in HMIS; Entering APR data in
e-snaps from HMIS; Preparing for the APR before operating year
ends.
Slide 3
Cash Match Requirements Each program category (operations,
supportive services, leasing) has a different % of Cash Match
required. Operations requires a 25% match; Supportive services
requires a 20% match; Leasing and Administration require no match;
After HEARTH regs are implemented all cash match will be 25% for
SHP. S+C requires a 100% match (supportive services $ = Housing
$)
Slide 4
What is Cash Match? Ordinarily, it means that the grantee gets
cash from somewhere to pay for the % of the program cost. However,
for supportive services, it could mean that cash match is being
paid for (in cash) by another entity, probably a government or a
private agency, for services that are provided to clients in the
program, not a transfer of actual cash. Cash match requirements are
in Section E of the SHP Desk Guide.
Slide 5
Important to Know: Cash match must be applied to an existing
budget line item for which SHP funds are being used. Example: Case
management, where funds from BHHF are being used for mental health
and/or substance abuse services for clients. Clients are being case
managed, are being assessed by Case Managers according to their
needs for services, being referred for services by the CM, and then
getting those services. All this is part of case management.
Slide 6
Match for Operations This is more difficult to obtain. Grants
may be gotten from a foundation, an agency whose budget allows for
operating costs (such as energy assistance), or from a private
source (such as a church group) to supplement line items like
furnishings and utilities. Some sponsors/grantees use tenant
program fees or rent to cover match for operations. Under a leasing
program the grantee would hold the lease in order to use rent as
match.
Slide 7
Rent or Program fee charged to Clients SHP and S+C regulations
state that clients can pay no more than 30% of adjusted income for
rent (or program fee, unless the program fee, in addition to the
rent, is for a specific, received service for which the agency
charges the normal fee) Even for leased housing, the client pays
30% of adjusted income for rent, which must include all utility
costs.
Slide 8
Difficulties with FMR in some areas In operating your SHP
projects (this is not true for S+C), you are stuck with the Fair
Market Rent budget (the FMR) in existence at the time your proposal
was submitted. So if your project was funded in the 2010 NOFA, you
may still be working with 2009 FMR, and those rent limits are
difficult for your geographic area. This may change when HEARTH is
implemented. The rent, at the FMR, is to INCLUDE utilities, or if
not, then you need to use the utility allowance method to calculate
the amounts what amount will be covered by the grant.
Slide 9
Utility Allowances HUD allows a method established by the local
PHA to be used to calculate reasonable amounts for utilities. This
amount is the utility allowance. If the utilities are in the client
households name, they will pay 30% of their income to cover their
rent and utility allowance amounts. Overages in the utility bills
are a grey area, and it may be difficult for clients to pay
overages. If the utilities are in the grantee organizations name,
the budget may not cover both the cost of the rent and the
utilities.
Slide 10
Client Homelessness and Disability Eligibility Issues: For TH,
PSH and S+C, all clients accepted must be homeless. For PSH and
S+C, all clients (or one adult in the household) must have a
disability. These eligibility rules are covered in the SHP Desk
Guide, Section B.
Slide 11
Current Definition of Homelessness Updated 12/20/11
http://hudhre.info/documents/DeterminingParticipantStatus_1
2.20.11.pdf 1. Literally homeless individuals/families 2.
Individuals/families who will imminently (within 14 days) lose
their primary nighttime residence with no subsequent residence,
resources or support networks 3. Unaccompanied youth or families
with children/youth who meet the homeless definition under another
federal statute and 3 additional criteria 4. Individuals/families
fleeing or attempting to flee domestic violence with no subsequent
residence, resources or support networks
Slide 12
1. Literally Homeless An individual or family who lacks a
fixed, regular, and adequate nighttime residence, meaning: Sleeping
in a place not designed for or ordinarily used as a regular
sleeping accommodation, including A park A car An abandoned
building A bus or train station An airport A camping ground
Slide 13
1. Literally Homeless Cont. Living in a shelter designated to
provide temporary living arrangements, including Congregate
shelters Transitional housing Hotels and motels paid for by
charitable organizations or federal/state/local government programs
Exiting an institution (e.g., jail, hospital) where they resided
for 90 days or less AND were residing in emergency shelter or place
not meant for human habitation immediately before entering
institution.
Slide 14
Individuals/families who will imminently lose their primary
nighttime residence within 14 days AND Has no subsequent residence
identified AND Lack the resources or support networks needed to
obtain other permanent housing 2. Imminently Losing Primary
Nighttime Residence
Slide 15
People with ALL of these characteristics: 1. Unaccompanied
youth (less than 25 years of age) OR family with children and youth
2. Defined as homeless under other federal statutes (i.e. Dept of
Ed) who do not otherwise qualify under HUDs definition 3. Has not
had a lease, ownership, or occupancy agreement in permanent housing
in the 60 days prior to applying for assistance 4. Has moved 2 or
more times in the 60 days prior to applying for assistance 5. Has
one or more defined barriers (i.e. Chronic disabilities, Substance
addition, DV, illiteracy, lack of HS diploma or GED, history of
unstable employment, etc.) 3. Unaccompanied Youth under 25 or
family with Children and youth
Slide 16
Process for using funds for persons who fall under the new
definition CoC must be able to demonstrate to HUD that use funds
for this population is of an equal or greater priority or is
equally or more cost effective in meeting the overall goals and
objectives identified in the FY 2011 Exhibit 1 application in
regards to children and unaccompanied youth. The CoC needs to know
no later than August 1 if any projects plan to begin using renewal
or new grant funds for this population. How many beds? How much
money? CoC must make a formal written to HUD and identify specific
projects requesting to use the funds. Funds set aside for this
population cannot exceed 10% of the total grant funds awarded to
the CoC.
Slide 17
4. Individuals/Families Fleeing or attempting to Flee Domestic
Violence dating violence, sexual assault, stalking, or other
dangerous or life threatening conditions related to violence, who
have no identified subsequent residence; AND lack the resources and
support networks needed to obtain other permanent housing.
Slide 18
Recordkeeping/Documentation Grantees must develop, maintain,
and follow written intake procedures to ensure compliance with the
homeless definition, respectively. The procedures must require
documentation at intake of the evidence relied upon to establish
and verify homeless status.
Slide 19
Homeless Status: Recordkeeping Requirements (*Updated 05/11/12)
http://hudhre.info/documents/HomelessStatus_5.11.12.pdf Policies
and Procedures must require intake staff to document: At
intake/screening for eligibility For ALL persons seeking assistance
Evidence relied upon to establish and verify Homeless status
Policies and Procedures must also be consistent with recordkeeping
requirement and must reflect HUDs preferred order.
Slide 20
HUDs Preferred Order for Homeless Documentation 1. Third Party
Written, including already available documents Oral 2. Intake Staff
Observation 3. Self-Certification
Slide 21
Exceptions to Preferred Order for Documentation of Homelessness
Types of assistance provided: Emergency Shelter Street Outreach
Victim Services To protect the safety of individuals/families
fleeing or attempting to flee Domestic Violence Emergency Shelter
and Street Outreach should be short-term therefore documentation
may be redundant or unnecessary.
Slide 22
HUD Tips for adhering to homeless documentation requirements
Adopt checklists that reflect preferred order Incorporate guidance
and examples of exceptions to preferred order Have staff check
existing documentation first Create forms for tracking and
documenting due diligence Check hudhre.info for updates as well as
with CoC Staff
Slide 23
Form of Documentation: Written Letters/Referrals Official
communication (must be issued on agency letterhead or program
template) Signed and dated by appropriate third party
representative Additional standards depend on criteria/condition of
the Homeless Definition Category being used WE RECOMMEND PRINTING
AND TABBING, or INTERNET BOOKMARKING, THESE ADDITIONAL STANDARDS
FOR EASY REFERRENCE!
Slide 24
Oral Documentation Recorded in Writing By intake staff Of 3 rd
party providing verification Signed and dated by intake staff as
true and complete **Recommend standardized form by program type -
Create clearly labeled sections for including relevant details and
certifications.
Slide 25
Individual/Head of Household Self- Statement Written statements
certified (signed and dated) as true and complete Regulations
specify when oral statements can be used If self-certification must
be verified: Confirmation that certification was verified OR Due
diligence documentation ** Recommend standardized form by program
type
Slide 26
Due Diligence Describe efforts to obtain third party
documentation May include phone logs, email correspondence, copies
of certified letters etc. Outcome of effort, including obstacles
Signed and dated by intake staff as true and complete ** Recommend
standardized form
Slide 27
Eligibility for PSH and S+C: Disability Overview of Disability
Definition: 1. Developmental disability OR 2. HIV/AIDS OR 3. Other
impairment (physical, mental, or emotional). The disability is
expected to be : of long-continuing or of indefinite Duration;
Substantially impedes the individuals ability to live
independently; Could be improved by the provision of more suitable
housing conditions and Is a physical, mental or emotional
impairment, including impairment caused by alcohol or drug abuse,
post-traumatic stress disorder, or brain injury
Slide 28
Documenting Disability Status Documentation requirements
applicable only when status is required for eligibility to program
(PSH and S+C - 100% of units) Written 3rd Party Written
Verification State licensed professional Social Security
Administration Receipt of disability check Veterans
Administration
Slide 29
Documenting Disability Status Cont. Intake staff observations
Applicable only in the absence of written 3 rd party verification.
Must be confirmed and accompanied by written 3 rd party
verification no later than 45 days **Oral-third party and
self-certification is NOT appropriate in ANY case.
Slide 30
Client Terminations This is a difficult issue for some of our
projects. For communal buildings, there are safety issues for the
entire building population that must be considered carefully when
establishing a termination policy. For Transitional Housing,
clients should be terminated under the following circumstances
(generally, according to common sense, not HUD rules): Behavior
that is endangering the health or safety of other residents. This
does not necessarily include substance abuse relapse.
Slide 31
More on terminations For TH housing, the main performance
measure HUD uses is exit to permanent housing. Therefore,
termination should be undertaken only when really necessary,
especially if no permanent housing has been located and secured.
This is a judgment call, and/or an agency policy issue, but HUD
performance measures should be part of the consideration. Failure
to meet individual goals in the action plan, in and of itself, is
not grounds for termination, unless it interferes with long-term
client progress in general and/or contributes to a culture of
non-adherence to program performance as a whole. Normally the
latter does not apply to leased housing since inter-client contact
is sometimes minimal.
Slide 32
Preparing for Operating Year End
Slide 33
Performance Measures HUDs 3 Performance Measures for SHP and
S+C 1. To help program participants obtain and remain in permanent
housing 2. To help participants increase skills and/or income which
will allow the participants to live as independently as possible.
3. To help participants achieve greater self-determination which
will enable the participant to gain needed confidence to make the
transition out of homelessness.
Slide 34
Purpose of the PSH The main purpose of Permanent Supportive
Housing (including S+C) is for clients to remain in permanent
housing. The only reasons for exit are: The client no longer has
the disability that defined them as eligible for PSH They no longer
need the services of the program and other affordable housing is
available to them. The clients disability has become worse
necessitating a higher level of care that the project can not offer
(hospital long term stay, nursing home, etc.)
Slide 35
Reporting in the actual APR Permanent Housing Projects 1. The %
of persons who remained in the permanent housing program as of the
end of the operating year or exited to permanent housing
(subsidized or unsubsidized). 2. The % of persons age 18 and older
who maintained or increased their total income (from all sources)
as of the end of the operating year or program exit. Transitional
Housing Projects 1. The % of persons who exited to permanent
housing (subsidized or un- subsidized) during the operating year.
2. The % of persons age 18 through 61 who increased their earned
income as of the end of the operating year or program exit. 3. The
% of persons age 18 and older who increased their total income
(from all sources) as of the end of the operating year or program
exit. New CoC APR Guidebook published May 1, 2012
http://www.hudhre.info/documents/esnapsCoCAPRGuidebook.pdf
Slide 36
Reporting on your successes (client outcomes/HUD Performance
Measures) HUD assesses the percentage of all clients in all
projects who gained access to mainstream services and who gained
employment. Related to this, HUD asks on the APR for applicants to
calculate: 1. Number of adults who left projects during the
operating year 2. Income (from all sources and employment if
applicable) at program entry of the adults who left projects during
the operating year. 3. Income (from all sources and employment if
applicable) at program exit of the adults who left projects during
the operating year.
Slide 37
Tracking in HMIS Any and all benefits, income must be recorded
in the Income screen of Customer Intake in HMIS
Slide 38
Tracking in HMIS - Employment Track employment information
within the Income Screen of HMIS. Note all changes in employment,
wage amounts. System will track history.
Slide 39
Tracking in HMIS Non-Cash Track Non-Cash benefits in the
Non-Cash benefits section of Income Names to be used: SNAP (Food
Stamps), Medicaid, Medicare, CHIPS, WIC, VA Medical Services, TANF
Child Care, TANF Transportation, Other TANF non-Cash, Section 8,
PH, or other Rental Assistance, Other Temporary Rental Assistance,
Other System will track history. Assign estimated, actual or a $0
value
Slide 40
Prepping for the APR and End of Grant Year 90 days prior to the
end of the grant year Ask CPD Rep in Pittsburgh for Copy of LOCCS
draws and balance status Check this against your records of draws
and balances 1. Not enough money - solutions 2. Too much money
solutions You should be pulling your APR Quarterly from HMIS to
monitor performance measures and data completeness If your project
performance measures are not adequate, plan and take corrective
action.
Slide 41
At the end of the operating year As soon as grant ends Pull APR
and make sure there are no data issues Dont wait until the last
minutes to pull your final APR from HMIS! Request assistance from
WVCEH/BoS CoC anytime!! Check your grant balances again in LOCCS.
You have 30 days after the end of the operating year to draw funds
for expenditures that occurred or were obligated during the
operating year. File correct APR and send copy to WVCEH/BoS
CoC