Best Practices for HUD CoC Grantees

Transcription

1 Best Practices for HUD CoC Grantees Better Together Conference November 8, 2018 Rachel Ganz and Dawn Horgan, CPD Representatives Office of Community Planning and Development Minneapolis Field Office of HUD Slide 1

2 Agenda Topic Areas HEARTH ACT Rent Calculation Written Intake Participant Eligibility and Documentation Rent Reasonableness SAGE and APRs ELOCCS Monitoring Slide 2

3 Resources Packet Contents PowerPoint Presentation CoC Wellness Checklist HUD staff directory and grantee assignments Sample Rent Reasonableness form Sample disability form Rent Calculation CPD Notice Determining Rent Contribution When Participant is Responsible for utilities CPD Notice Monitoring Exhibit 29-1: Guide for Review of Homeless and At-Risk Determination/Recordkeeping Requirements Slide 3

4 Where do I start? Of course at the very beginning Slide 4

5 HEARTH ACT Homeless Emergency Assistance and Rapid Transition to Housing= HEARTH The HEARTH Act amends and reauthorizes the McKinney- Vento Homeless Assistance Act with substantial changes including: A consolidation of HUD competitive grant programs The creation of Rural Housing Stability Assistance Program A change in HUD s definition of homeless and chronic homelessness A simplified match requirement An increase in prevention resources An increase in emphasis on performance

6 Continuum of Care (CoC) Program HUD published the CoC interim rule in the federal register on July 31, 2012, effective August 30, Rule established the requirements for the CoC program Applying for and administering funds CoC responsibilities Consolidated the following homeless assistance programs: Shelter Plus Care Supportive Housing Program (SHP) Section 8 Moderate Rehabilitation Single Room Occupancy Incorporates the Final Homeless Definition The public comment period closed on November 16, 2012 and an updated version of the CoC interim rule was submitted in the Federal Register on April 1, The updated rule addresses the mobility of participants with tenant-based rental assistance to provide protections of domestic violence, dating violence, sexual assault, or stalking Incorporated the Final definition of chronic homeless

7 TAKE AWAY What do your policies and procedures say? 7

8 TOPIC AREA #1: RENT CALCULATION Slide 8

9 Rent Calculation Notice CPD-96-03: Tenant Rent Calculations for Certain HUD McKinney Act Programs This notice: Defines income Specifies items that must be excluded from income Specifies allowable adjustments to income 9

10 Rent Calculation Employment Example 10 10

11 Rent Calculation Employment Example 11 11

12 Rent Calculation Employment Example When calculating use the household s monthly GROSS income $ $375.14=$ monthly income $ x 12 months=$ annual income Pay period #1 Pay period #2 12

13 Rent Calculation Employment Example $9, $0 $9, $960 ($480 x 2) $0 Addition information about the household HOH has a documented disability 2 minor children (dependents) Household is responsible for electricity 13

14 Rent Calculation Employment Example $0 $0 $0 $0 $0 $0 $0 $400 $400 $ $9, $960 (dependent)-$400 (disability)=$ $ $ / 12 x 0.3=$ $80.31 $0 $ /12 x 0.1=$80.31 Select rent amount that is higher-in this example, it is $206.94

15 1 5 Rent Calculation Employment Example $ Utilities paid by the tenant Electricity-$11+$32=$43 $43 $ $ $43=$

16 Rent Calculation Social Security Benefits $9600 ($800 x 12 months) $9600 $0 800 $0 $

17 Rent Calculation Social Security Benefits $0 $0 $0 $0 $0 $0 $0 $400 Addition information about the household Single head of household with a documented disability All utilities are included $400 $9200 $9600-$400=9200 $ $9200/12 x.3 17

18 Rent Calculation Social Security Benefits $ $0 $

19 Rent Calculation TAKE AWAYS At least annually What do your policies and procedures say? Recalculate at time of income decrease or increase? Compliance with other types of rental subsidies (deductions) Section 8, LTH Refer to notice Retain all 3 rd party documentation-attached to worksheet Ask your CPD Rep if you have any questions! Slide 19

20 TOPIC AREA #2: Written Intake Procedures 11/1/

21 Written 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 Order of Priority HUD s preferred order 1. Third Party- written, including already available documents Oral 2. Intake Staff Observations 3. Self-Certification 21

22 Tips for Policies and Procedures: Adopt a checklist that reflects and implements the preferred order of priority for eligibility documentation Have staff check for existing documentation first Example- HMIS records, discharge paperwork Create forms for tracking and documenting due diligence Collaborate with partners 22

23 TOPIC AREA #3: Participant Eligibility and Documentation 11/1/

24 Documentation of homeless eligibility What does HUD staff look for when reviewing eligibility supporting documentation? Is the grantee following their policies and procedures as it pertains to obtaining source documentation? Program start date vs move in date Is supporting documentation Signed? Dated? on agency letterhead? identify the title of staff signing the letter? clear timeframe of period of homelessness? Location not meant for human habitation (i.e. car, tent)? TAKE AWAY- a 3 rd party needs to be able to clearly follow the housing history, including due diligence.

25 Chronic vs Long-term homelessness 25

26 Chronic vs Long-term homelessness This does not meet HUD s chronic definition George Smith 26

27 Disability documentation PSH projects may only accept individuals with a qualifying disability or families where one member of the family has a qualifying disability* Disability documentation must be third-party and must be documented by: A professional licensed by the state to diagnose and treat that condition OR Social Security Administration (SSA) for persons receiving disability benefits SSI/SSDI check *For projects dedicated to serving individuals and families who are chronically homeless, the head of household must have the qualifying disability 27

28 Is the disability Is expected to be long-continuing or of indefinite duration AND Substantially impedes the person s ability to live independently AND Could be improved by more suitable housing 28

29 TOPIC AREA #4: Rent Reasonableness 11/1/

30 Rent Reasonableness Make sure to be looking at like properties Location Size Type Amenities Management The proposed unit Location: Duluth Comparable #1 Number of bedrooms: 1 Unit/Building Type: Apartment Amenities: utilities (tenant pays electric), off-street parking, community room, air conditioning, front desk Reasonable rent MUST not exceed rents currently being charged by the same owner for a comparable unassisted unit. 30

31 Rent Reasonableness Remember: Add this process to your policy and procedure manual

32 TOPIC AREA #5: Initial Lease 11/1/

33 Initial One-year Leases PSH RRH TH Initial lease must be one year renewable Initial lease must be one year renewable Lease term of at least one month and be automatically renewable upon expiration 11/1/

34 TOPIC AREA #6: Suitable Dwelling Size 11/1/

35 Suitable Dwelling Size (c) Suitable dwelling size. The dwelling unit must have at least one bedroom or living/sleeping room for each two persons. (1) Children of opposite sex, other than very young children, may not be required to occupy the same bedroom or living/sleeping room. (2) If household composition changes during the term of assistance, recipients and subrecipients may relocate the household to a more appropriately sized unit. The household must still have access to appropriate supportive services. Examples: Scenario #1: Single adult is looking for housing. A 2 bedroom is available and is below the 1 bedroom FMR. Can they move in to a 2BR? Scenario #2: Family of 3 (2 children of opposite gender) has been living in a 3 bedroom, oldest child turns 18 and leaves. Can the HH stay in the 3BR? 35

36 TOPIC AREA #7: eloccs 11/1/

37 ELOCCS TAKE AWAY DO NOT SHARE YOUR USERNAMES AND PASSWORDS Lengthy/complex process (start early/as soon as you know there is a change to staff) Pay attention to detail Two systems Secure Systems and eloccs Two roles Approving Official and User Call your CPD Rep! They will then refer you to our Financial Analyst, Secure Systems Help Desk, etc. Slide 37

38 TOPIC AREA #8: Budget 11/1/

39 Transfer of funds between budget line items: ASK YOUR REP FOR PERMISSION FIRST TO MOVE FUNDS Include in your request: Amount of funds to be moved What eligible costs the moved funds will pay for If less than 10% of funds are moving from one budget line item to another, an amendment is not required If more than 10% of a budget line item will be moved to another, a formal HUD amendment is required 39

40 When transfer of funds between BLI can not occur: New grants (grant number ending in 00), no changes to new grants To move funds out of rental assistance when rental assistance is based on FMR New grants (grant number ending in 00), no changes to new grants To move funds out of rental assistance when rental assistance is based on FMR Regardless of budget line change, the project still must serve the original number of households/individuals proposed in approved application. 40

41 TOPIC AREA #9: SAGE AND ANNUAL PROGRESS REPORTS Slide 41

42 TOP 5 REASONS AN APR IS SENT BACK FOR AMENDMENT/EDITS Slide 42

43 Number 5 Discrepancy between proposed and actual households served Slide 43

44 Number 4 Low Project Utilization Rate Slide 44

45 Number 3 Client Eligibility Slide 45

46 Number 2 Grantee match does not comply with the 25% requirement in the budget. Slide 46

47 THE NUMBER 1 REASON AN APR IS SENT BACK FOR AMENDMENT IS Slide 47

48 LOCCS does not match APR budget LOCCS disbursement APR budget Slide 48

49 Tips for a Successful APR Submission The end of a project/program year is when the APR will appear in SAGE. For example, program year is from 7/1/18-6/30/19, APR will appear 07/1/19 Budget information is pulled from LOCCS Program staff need to talk to financial staff If you have an issue with data, consult with ICA or submit an AAQ Field Office has different access to SAGE than grantees When in doubt add narrative in the additional comments section Copy of Guidebook can be found on the SAGE dashboard Slide 49

50 Topic Area #10: Tips for Successful Monitoring Visit 50

51 Monitoring visit Your experience will NOT be like this. Slide 51

52 Your experience will be like this! Monitoring Visit Or better yet think of a monitoring visit like. Slide 52

53 Monitoring Visit Winning the lottery Not a Gotcha but see our role as your partner. Opportunity to tell us all the great things happening as well as challenges and themes Allows HUD staff technical assistance on process improvement Slide 53

54 Tips to a Successful Monitoring Visit Read the notification letter Open book test Notify sponsors, partners, other depts and review exhibits Create schedule Collect supporting documentation for voucher Locate and review service and housing files Space for HUD reviewers to close door Availability for client and staff discussion time Gather requested documents prior to visit (i.e. policies/procedures, participant list, staff list, organizational chart) Review documents/tenant files to be reviewedhomeless doc, disability, lease, rent calculation, rent reasonableness Contact clients if chosen for interview

55 Thank you! Rachel Ganz, CPD Representative Dawn Horgan, CPD Representative Slide 55