Best Practices for HUD CoC GranteesBetter Together Conference

November 8, 2018

Slide 1

Rachel Ganz and Dawn Horgan, CPD RepresentativesOffice of Community Planning and DevelopmentMinneapolis Field Office of HUD

Topic Areas

– HEARTH ACT

– Rent Calculation

– Written Intake

– Participant Eligibility and Documentation

– Rent Reasonableness

– SAGE and APRs

– ELOCCS

– Monitoring

Agenda

Slide 2

• Packet Contents– PowerPoint Presentation

– CoC Wellness Checklist

– HUD staff directory and grantee assignments

– Sample Rent Reasonableness form

– Sample disability form

– Rent Calculation CPD Notice 96-03

– Determining Rent Contribution When Participant is Responsible for utilities CPD Notice 17-11

– Monitoring Exhibit 29-1: Guide for Review of Homeless and At-Risk Determination/Recordkeeping Requirements

Resources

Slide 3

Where do I start?

Slide 4

Of course at the very beginning

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

Continuum of Care (CoC) Program

➢ HUD published the CoC interim rule in the federal register on July 31, 2012, effective August 30, 2012.

➢ 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, 2017.

➢ 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

What do your policies and procedures say?

7

TAKE AWAY

TOPIC AREA #1: RENT CALCULATION

Slide 8

Rent Calculation

Notice CPD-96-03: Tenant Rent Calculations for Certain HUD McKinney Act Programs

9

This notice:• Defines income• Specifies items that must be

excluded from income• Specifies allowable adjustments to

income

Rent CalculationEmployment Example

1010

Rent CalculationEmployment Example

1111

When calculating use the household’s monthly GROSS income

Rent CalculationEmployment Example

12

Pay period #1

Pay period #2

$427.99+$375.14=$803.13 monthly income

$803.13 x 12 months=$9637.56 annual income

Rent CalculationEmployment Example

13

$9,637.56

$0

$9,637.56Addition information about the household• HOH has a documented

disability• 2 minor children

(dependents)• Household is responsible

for electricity

2

$960 ($480 x 2)

$0

Rent CalculationEmployment Example

14

$9,637.56-$960 (dependent)-$400 (disability)=$8277.56

$0$0$0

$0

$0

$0

$0

$400

$400

$8277.56

$206.94 $8277.56 / 12 x 0.3=$206.94

$80.31

Select rent amount that is higher-in this example, it is $206.94

$0

$9637.56/12 x 0.1=$80.31

Rent CalculationEmployment Example

1

5

15

$206.94

Utilities paid by the tenant

Electricity-$11+$32=$43

$43

$163.94

$206.94-$43=$163.94

Rent CalculationSocial Security Benefits

16

800

800

800

$9600 ($800 x 12

months)

$9600

$0

$0

$0

Rent CalculationSocial Security Benefits

17

Addition information about the household• Single head of household

with a documented disability

• All utilities are included

$400

$400

$9200 $9600-$400=9200

$229.99 $9200/12 x .3

$0$0$0

$0

$0

$0

$0

Rent CalculationSocial Security Benefits

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$229.99

$0

$229.99

• 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 96-03

• Retain all 3rd party documentation-attached to worksheet

• Ask your CPD Rep if you have any questions!

Rent Calculation

Slide 19

TAKE AWAYS

TOPIC AREA #2: Written Intake Procedures

11/1/2018 20

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

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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

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TOPIC AREA #3:Participant Eligibility and Documentation

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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 3rd party needs to be able to clearly follow the housing history, including due diligence.

Chronic vs Long-term homelessness

25

Chronic vs Long-term homelessness

26

George Smith

This does not meet HUD’s

chronic definition

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

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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

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TOPIC AREA #4: Rent Reasonableness

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Rent Reasonableness

Make sure to be looking at ‘like’ properties

• Location

• Size

• Type

• Amenities

• Management

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The p

rop

osed

unit

Reasonable rent MUST not exceed rents currently being charged by the same owner for a comparable unassisted unit.

Comparable #1Location: Duluth

Number of bedrooms: 1

Unit/Building Type: Apartment

Amenities: utilities (tenant pays electric), off-street parking, community room, air conditioning, front desk

Rent Reasonableness

Remember: Add this process to your policy and procedure manual

TOPIC AREA #5: Initial Lease

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Initial One-year Leases

11/1/2018 33

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

TOPIC AREA #6: Suitable Dwelling Size

11/1/2018 34

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?

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TOPIC AREA #7: eLOCCS

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ELOCCS

• 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.

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TAKE AWAY

TOPIC AREA #8: Budget

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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

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When transfer of funds between BLI can not occur:

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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.

TOPIC AREA #9: SAGE AND ANNUAL PROGRESS REPORTS

Slide 41

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

Slide 42

Discrepancy between proposed and

actual households served

Number 5

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Low Project Utilization Rate

Number 4

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Client Eligibility

Number 3

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Grantee match does not comply with

the 25% requirement in the budget.

Number 2

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THE NUMBER 1 REASON AN APR IS SENT BACK FOR AMENDMENT IS…

Slide 47

LOCCS does not match APR budget

Slide 48

APR budget

LOCCS disbursement

❑ 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

Tips for a Successful APR Submission

Slide 49

Topic Area #10:Tips for Successful Monitoring Visit

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Monitoring visit

Your experience will NOT be like this….

Slide 51

Monitoring Visit

Your experience will be like this!

Or better yet think of a monitoring visit like….

Slide 52

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

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 reviewed-homeless doc, disability, lease, rent calculation, rent reasonableness

➢ Contact clients if chosen for interview

Thank you!

Slide 55

Rachel Ganz, CPD Representative Dawn Horgan, CPD Representative

rachel.s.ganz@hud.gov dawn.m.Horgan@hud.gov

612-843-6451 612-370-3058