Policy #: CE CA602 16 005 Orange County Continuum of Care Policy: Policy on Accepting Clients into Permanent Supportive Housing from Bridge Housing Situations Date Approved by the Commission to End Homelessness: Effective Date: Date Reviewed/Revised: Background The United States Department of Housing and Urban Development (HUD) understands that once a chronically homeless household has been determined eligible and accepted into a [Continuum of Care] CoC Program-funded permanent supportive housing (PSH) program, a unit is not always immediately available. During this time, unless they have other options such as living temporarily with friends or family, the household will generally continue to reside in an emergency shelter or on the streets, prolonging their period of homelessness. Communities should continuously work to improve the system to decrease the amount of time it takes to secure a unit for program participants once accepted into a PSH program. Because these types of changes and improvements can take time, HUD has determined that after an individual or family has been accepted into a program but before an appropriate unit has been identified, a household may stay with a friend or family or in a hotel or motel without losing their eligibility for the permanent supportive housing program in which they have already been accepted. HUD would also allow a CoC to temporarily house the participant in an available transitional housing bed while a permanent housing unit is identified. This allowance is only permitted in the circumstances described here and does not apply to persons enrolled in transitional housing that were considered chronically homeless prior to entry into the program and the following requirements apply: 1. Since the program participant has been accepted into a permanent supportive housing project, the transitional housing provider cannot place any requirements on the program participant, including requiring a program participant to participate in additional services as a condition of occupancy or requiring the program participant to meet sobriety requirements. Commented [ZP1]: Comment received: In the Policy, in the background portion it states that an individual or family can go into bridge housing once they are accepted into a program (RRH/PSH) but under the point of eligibility on the 3rd page, it states they are only eligible once they are actually matched to a PSH unit. What does being accepted into the program versus unit mean and which one would make them eligible for bridge housing? Or maybe the better question is "what is considered a unit"? Commented [ZP2R1]: The background section of the policy is language provided by HUD. In page 3 of the policy that is language based on the current process we have implemented. The question we are posing is more evident in the process workflow, the two yellow boxes. In the current process, a client is matched to a housing provider. The housing provider accepts the clients based on the initial review of housing unit requirements and individuals barriers to housing. The individual at this point is enrolled into the program, however they are not marked as housed until they move into housing. However the client still has to pass the landlord qualifications, which means that if they do not pass, the client is returned to the Prioritization list. Commented [ZP3]: Comment received: If a provider offered TH/ Bridge housing, since the clients can't be charged fees, would there be potential for CoC funding to help cover the costs of damage to property, furnishings and such? Commented [ZP4R3]: In implementation Group #3 we have talked about creating a funding pool that allows for programs to cover costs not covered by grants and contracts. The group is working on doing some research to look at design and other communities practices. We can definitely continue that discussion and explore options to assist with the costs.
2. The permanent supportive housing provider must be actively assisting the program participant to identify a unit as quickly as possible and must be able to document attempts at locating a unit in the case file. Under no circumstances, should the placement in transitional housing slow down placement into permanent housing. This means that placing a program participant into a permanent housing unit should not take any longer than the time it would normally take to place someone in permanent housing who is residing on the streets or in an emergency shelter. 3. There cannot be duplication in billing for the program participant. For example, both programs cannot provide and then seek reimbursement from HUD for housing search or other services. The permanent supportive housing provider and the transitional housing provider must coordinate to ensure that appropriate services are provided and the same services are not being paid for out of both grants. In addition to working to decrease the length of time it takes to locate and house a program participant in a permanent supportive housing unit, HUD expects CoCs to routinely review their portfolio of homeless assistance housing options to ensure the supply reflects the need. This means that if a CoC recognizes it has many homeless persons eligible for permanent supportive housing, for example, but they have more transitional housing available, then they should seriously consider developing a reallocation strategy that would allow them to reduce the number of transitional housing options in favor of creating more permanent supportive housing. HUD recognizes this takes time and is offering CoCs this flexibility, when the criteria above has been met, so chronically homeless persons have an alternative to sleeping on the streets when waiting for housing placement. HUD encourages CoCs and recipients to follow a Housing First approach and establish policies and procedures that reduce barriers to obtaining a unit and reduce the amount of time households wait for units. This could include strategies such as identifying landlords who are willing to work with the recipient, inspecting units for Housing Quality Standards in advance of a household being shown the unit, and identifying landlords who are willing to rent units already in compliance with HUD s standards of Fair Market Rent and rent reasonableness. FAQ Link: https://www.hudexchange.info/faqs/1913/if-a-person-is-accepted-into-apermanent-housing-program-but-the-project/ Housing Program Eligibility To be served in HUD s Homeless Assistance Programs, projects funded under the Continuum of Care (CoC) and/or Emergency Solutions Grants (ESG) Programs, a household must meet the eligibility criteria under the specific project and applicable component type. Staff must document a client s chronically homeless status at intake into the project and should follow HUD s stated preferred order for documentation as described in CPD-14-012 Notice on Prioritizing Persons Experiencing Chronic Homelessness and Other Vulnerable Homeless Persons
in Permanent Supportive Housing and Record Keeping Requirements for Documenting Chronic Homeless Status, and Defining Chronically Homeless Final Rule. If the individual or family is on a waiting list only and they are waiting for a vacancy within the project, their eligibility must be determined at the point in which there is an actual opening in the project which they have been offered and accepted and as defined by section of this policy entitled Point of Eligibility. The Orange County Coordinated Entry System refers to the aforementioned waiting list as the Prioritization List, herein after. Point of Eligibility Permanent Supportive Housing All individuals entering into new and turnover PSH units will be identified and referred to by the Orange County Coordinated Entry System. The point of eligibility into the PSH project is the date in which the individual was matched to the agency, herein after referred to as the match date. Record of the match date is kept on file by the operators of the Coordinated Entry System. After an individual or family has been matched for placement in an identified PSH unit, the individual or family may access eligible forms of bridge housing until the unit is available for move in without jeopardizing their eligibility status. Eligible forms of bridge housing include staying with a friend or family member, in a motel, or in a transitional shelter, if and only if the transitional shelter adheres to the aforementioned guidance by HUD. Individuals and families who have completed an assessment and/or are on the Coordinated Entry System Prioritization List but have not officially been matched to a vacant PSH unit are not eligible for such bridge housing allowances; if bridge housing is used the individual or household may be deemed ineligible for the PSH project as their point of entry is no longer a place not meant for human habitation, emergency shelter, or safe haven. Is it transferrable to Rapid Rehousing? Procedure for Documenting Bridge Housing Stays Documentation of an individual s stay in eligible forms of bridge housing prior to move in to permanent housing must be included in the individual s case file. Acceptable documentation includes the following for each housing type: 1) Stay with friend or family member letter from the friend or family member specifying the dates in which the client stayed with them and a statement from the friend or family member indicating that the stay is temporary and not permanent (Appendix A Template for Friend or Family Member Providing Bridge Housing). Commented [ED5]: Matched needs to be clearly defined. Is this the point when the client completes an intake for the project? Matched should be whenever the agency takes responsibility for housing the household (see comment below). Commented [ZP6R5]: Comment Received: Matched should be defined as point when client gets matched to an agency for a housing opportunity. At that point the agency takes responsibility for housing the household. Commented [ED7]: If the household is matched and then enters bridge housing, the agency becomes responsible for housing that household because if the household returns to the waiting list, they can lose their CH eligibility. If there is a possibility that the agency will return the client to the Prioritization list (client is unable to meet landlord requirements, etc), then the client should not be utilizing bridge housing. Commented [ZP8R7]: Comment Received: The client should be able to enter bridge housing following a match to an agency. The agency should commit and be responsible for finding housing for that client no matter what. Otherwise se risk being blamed for creaming and will not be serving the most vulnerable populations. Clients should not return to the Prioritization List after having been matched to a housing provider. Commented [ZP9R7]: Comment received: is there a reason why these two models have to be mutually exclusive? Answer: There is a possibility that the two models can be mutually exclusive for each housing project type. For example Permanent Supportive Housing may follow Bridge Housing at Landlord Accepted model while Rapid Rehousing projects follow Bridge Housing at Client Accepted model. I do not believe that both models can be utilized for the one housing project type, because someone in this process would have to decide what clients the housing agency are committing to work with until housed, and which individuals they will be returning to the Prioritization List. If that decision is made after an individual has been in bridge housing for longer than 7 days, then that individual s chronic homeless status could change based on the definition. Commented [ZP10]: Comment Received: Yes, the Bridge Housing policy should be the same for both PSH and RRH opportunities.
2) Stay in a motel a receipt designating the dates and number of days in which the client stayed at the motel. In cases in which the motel was provided by a third party, a letter of verification that includes dates and number of days of motel assistance provided (Appendix B Template for Motel Stay as Bridge Housing). 3) Stay in a transitional shelter letter from the transitional housing program operator that includes the dates in which the client stayed, certification that they intention of the stay was temporary and not of long term duration and as an interim or bridge housing support, and certification that the client was not required to participate in additional services as a condition of occupancy or requiring the program participant to meet sobriety requirements (Appendix C Template for Transitional Housing Program Operator Providing Bridge Housing). In all cases, a Case Manager or Program Supervisor from the PSH program must verify that the dates of stay included on the documentation transpired on or after the match date.
Appendix A Template for Friend or Family Member Providing Bridge Housing [DATE] To whom it may concern; [CLIENT NAME], my [STATE RELATION TO CLIENT], has been living with me since [DATE]. The intention of his/her stay is temporary, not permanent, as he/she has been matched to a housing opportunity for which they are eligible and interested in. His/her stay is intended to support him/her while the permanent housing unit is secured and ready for move in. I assert that the above statement is true and accurate. Should you have any questions you may contact me at [EMAIL and/or TELEPHONE NUMBER]. Sincerely, [SIGNATURE]
Appendix B Template for Motel Stay as Bridge Housing [DATE] To whom it may concern; [CLIENT NAME] has been utilizing [MOTEL NAME - ADDRESS] as bridge housing from [START DATE] to [END DATE], for a total of [#] nights. See attached receipt. The intention of his/her motel stay is to provider him/her with a temporary shelter while the permeant housing unit is secured and ready for move in. This bridge housing is allowing for him/her to maintain regular contact with [PSH PROVIDER S] case manager and providing stability. If applicable, complete section below. [THIRD PARTY] provided [#] nights of motel assistance to [CLIENT NAME] from [START DATE] to [END DATE]. For additional information on the assistance provided by [THIRD PARTY] please contact [THIRD PARTY CONTACT] at [EMAIL and/or TELEPHONE NUMBER]. Sincerely, [SIGNATURE]
Appendix C Template for Transitional Housing Program Operator Providing Bridge Housing [AGENCY LETTERHEAD] [DATE] To whom it may concern: [CLIENT NAME] has been utilizing [SHELTER NAME] as bridge housing since [DATE], as he/she has been matched to a housing opportunity for which they are eligible and interested in, with [PROVIDER NAME] on [DATE]. The intention of his/her stay is to provider him/her with a temporary shelter while the permeant housing unit is secured and ready for move in. This bridge housing is allowing for him/her to maintain regular contact with [PSH PROVIDER S] case manager and providing stability. I assert that he/she was not a participant of the [SHELTER NAME] prior to being matched to Permanent Supportive Housing through the Coordinated Entry System. I assert that he/she met the definition of chronic homeless prior to utilizing [SHELTER NAME] as bridge housing. I further assert that no program requirements have been placed on the client during their bridge housing stay with us. Sincerely, [SIGNATURE]