chapter 13 supportive housing program (shp) · chapter 13 supportive housing program (shp) 13-1 ......

6509.2 REV-5

13-1 09/2005

CHAPTER 13

SUPPORTIVE HOUSING PROGRAM (SHP)

13-1 APPLICABILITY. This Chapter provides guidance for conducting

comprehensive monitoring of the Supportive Housing Program (SHP). The SHP is designed to develop supportive housing and services that will allow homeless persons to live as independently as possible. Eligible applicants are States, units of local government, other governmental entities such as Public Housing Authorities (PHAs), and private nonprofits. (Note: For purposes of this Chapter, term “grantee” means the direct recipient of the HUD award. The term “sponsor” means the organization that is responsible for carrying out the proposed project activities. The terms “participant” and “client” mean the individuals and adults in families who received assistance during the operating year.)

HUD awards funds through a national competition held annually. The competition requires communities to shape a comprehensive and coordinated housing and service delivery system via a Continuum of Care. The Continuum of Care approach helps communities plan for and provide a balance of emergency, transitional, and permanent housing, and service resources to address the needs of homeless persons so they can make the critical transition from the streets to jobs and independent living to the extent possible. As part of a local Continuum of Care strategy, SHP assistance is provided to help homeless persons meet three overall goals: achieve residential stability, increase their skill levels and/or incomes, and obtain greater self-determination (i.e., more influence over decisions that affect their lives). Specific performance measures for each of these three goals must be established by grantees based on the needs and characteristics of the homeless population to be served. Grantees are required to monitor their clients' progress in meeting their performance measures on an ongoing basis. A Continuum of Care system should also include a homeless prevention strategy, even though homeless prevention is not an eligible activity under SHP.

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13-2 PREPARING FOR MONITORING. The specific SHP program areas or requirements to be monitored are determined as part of the risk assessment process (see additional guidance provided in Chapter 2). Before monitoring, the reviewer should be familiar with both the SHP requirements and the design and operation of the grantee’s SHP, particularly those areas that have been identified as high risk or are the focus of the monitoring. Information that will assist in successful SHP monitoring include:

the authorizing legislation, Title IV, Subtitle C, of the McKinney-Vento

Homeless Assistance Act of 1987, as amended (42 U.S.C. Subtitle C, 421-429);

the grant agreement(s) for the project(s) being monitored, including the

attached SHP regulations at 24 CFR Part 583;

the Supportive Housing Program Desk Guide, which describes the SHP grant process from grant award onward, covering both very basic information as well as the intricacies of grant administration. It is a practical guide to help with project implementation issues;

the Supportive Housing Program (SHP) Self-Monitoring Tools, which

provides SHP project sponsors and grantees with "user-friendly" forms to enable staff to assess their project operations against the standards set by HUD rules and regulations. To the extent possible, these forms correspond to the topics addressed in the SHP Desk Guide and have been designed for use in conjunction with the Guide. In using the SHP Desk Guide and the SHP Tools together, local staff can evaluate their projects based on both the general guidelines for the SHP and the particular rules established by the project. In this way, the SHP Tools provide a set of standard instruments to guide a process of regular project monitoring and supplement the information presented in the SHP Desk Guide;

the most recent Annual Progress Report (APR);

Line of Credit Control System (LOCCS) drawdown information; and

the approved application (comprising both the first submission narrative

and the technical submission).

6509.2 REV-5

13-3 09/2005

13-3 FILE SELECTION AND SAMPLING. As described in Chapter 2, the risk analysis process will be used to determine which grantees and areas should be reviewed. Once that process has been completed, where it is indicated that a file review is necessary to answer Exhibit questions, the HUD reviewer should consider the following factors when determining the specific files that will comprise the review sample:

A. Where feasible, initial file selection should be made using a random selection

method. B. The reviewer would consider adding more files to this selection in order to:

i. Include a file or files from each staff person working in the respective program area being monitored;

ii. Expand the sample, if possible, to include additional files with the

same characteristics, if indicated by the severity or nature of any problems(s) noted during the initial selection’s review (for example, same problem category, same staff person, same activities or other characteristics);

This expanded sampling aids in determining whether problems are isolated events or represent a systemic problem.

C. The reviewer may also add files to the selection from any project that the

HUD reviewer has reason to believe may have compliance problems or that is substantially different in terms of size, complexity, or other factors from other projects the SHP grantee has undertaken.

Exhibit 13-1 6509.2 REV-6 Supportive Housing Program (SHP)

13-1 04/2010

Guide for Review of SHP Supportive Services Name of Grantee: Staff Consulted: Name(s) of Reviewer(s)

Date

NOTE: All questions that address requirements contain the citation for the source of the requirement

(statute, regulation, NOFA, or grant agreement). If the requirement is not met, HUD must make a finding of noncompliance. All other questions (questions that do not contain the citation for the requirement) do not address requirements, but are included to assist the reviewer in understanding the grantee's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding."

Instructions: This Exhibit is designed to assess the SHP grantee’s performance in conducting on-going client needs assessments and in providing the supportive services identified in the approved application covering the grant term. Follow the instructions in Section 13-3 of the introduction to this Chapter to select client files to review. The sample of files randomly selected to answer this Exhibit’s questions can also be used to complete Exhibit 13-3, “Guide for Review of SHP Housing,” and Exhibit 13-4, “Guide for Review of SHP Clients,” if part of the same monitoring. Note: It is the option of the reviewer to use this form for each individual client reviewed or as a master response form encompassing information regarding all of the clients reviewed. It is the responsibility of the reviewer to ensure that sufficient evidence is documented to support your conclusions, including any finding(s) and/or concern(s) noted in the final monitoring report. Additionally, this exhibit has been amended to include compliance monitoring questions applicable to SHP projects funded in 2008 under the Rapid Re-Housing for Families (RRH) Demonstration Program. Questions: 1.

Are the supportive services being provided (type and level of service) consistent with those described in the approved application (including the supportive services budget)? [24 CFR 583.410 (a)]

Yes No N/A

Describe Basis for Conclusion:

2. Does the grantee conduct on-going assessments of the participants’ supportive services needs? [24 CFR 583.300(d)]

Yes No N/A


6509.2 REV-6 Exhibit 13-1 Supportive Housing Program (SHP)

04/2010 13-2

3.

Describe the supportive services provided to SHP beneficiaries.


Rapid Re-Housing for Families Demonstration Program (RRH) 4.

Do the records indicate that RRH-supportive services funds are only being used for: housing placement, case management, legal assistance literacy training, job training, mental health services, childcare services and substance abuse services? [2008 NOFA section I.A.4.w.]

Yes No N/A


5. Do the financial documents indicate that the grantee has expended no more than 30 percent of the total eligible activities (award total minus five percent for administrative costs) for RRH-eligible supportive services? [Federal Register, July 10, 2008 – NOFA – Section I. Funding Opportunity Description (A) Program Description (w) Rapid Re-Housing for Families Demonstration Program, pg 39843]

Yes No N/A


6. Do the grantee and subgrantees’ records show evidence that the same single assessment tool is being used for all program participants? [2008 NOFA section I.C.12.c]

Yes No N/A


7. Does the assessment tool used by the grantee and/or subgrantee(s) contain sufficient information to meet the requirements outlined within the 2008 NOFA? [2008 NOFA section I.C.12.b.i-ix.]

Yes No N/A



13-1 04/2010

Guide for Review of SHP Project Progress Name of Grantee: Staff Consulted: Name of Project: Project Grant Term: Name(s) of Reviewer(s)

Date



Instructions: This Exhibit is designed to review SHP projects to ensure that activities are being carried out in a timely manner and that the number of persons served is consistent with the grant application. The grant application includes any amendments that have been executed since the grant agreement. One Exhibit should be completed for each SHP project reviewed. The sampling guidance in Section 13-3 of the introduction to this Chapter is to be used in selecting the projects and activities to monitor. Questions: 1.

Is the number of participants currently being served consistent with the service number in the approved application? [24 CFR 583.410 (a)]

Yes No N/A


2.

Is the Line of Credit Control System (LOCCS) drawdown rate consistent with the projected point-in-time expenditures for the project’s grant term and approved budget? [NOFA timeliness standards]

Yes No N/A


Exhibit 13-3 6509.2 REV6 Supportive Housing Program (SHP)

13-1 04/2010

Guide for Review of SHP Housing Name of Grantee: Staff Consulted: Name(s) of Reviewer(s)

Date



Instructions: This Exhibit is designed to evaluate the SHP grantee’s housing operations, including resident rent calculations, residential supervision, due process for terminations, confidentiality procedures for domestic violence families, habitability standards, Section 3, Affirmative Outreach and the Rapid Re-housing for Families Demonstration Program. Follow the sampling instructions in Section 13-3 of the introduction to this Chapter for selecting project/activity files to review. This same sample can also be used to complete Exhibit 13-1, “Guide for Review of SHP Supportive Services, and Exhibit 13-4, Guide for Review of SHP Clients,” if part of the same monitoring. Note:

1. It is the option of the reviewer to use this form for each individual client reviewed or as a master response form encompassing information regarding all of the clients reviewed. It is the responsibility of the reviewer to ensure that sufficient evidence is documented to support conclusions, including any finding(s) and/or concern(s) noted in the final monitoring report.

2. This exhibit includes additional compliance monitoring questions for SHP projects funded in 2008 under the Rapid Re-Housing (RRH) Demonstration Program. Since the SHP regulations are applicable to the RRH Program projects, reviewers should utilize the full exhibit as a questioning guide.

Questions: 1.

a. For projects using SHP leasing funds, in reviewing records showing the amounts of monthly/yearly rent against documentation showing comparable rents in the area, are the rents charged reasonable and are they documented for each lease? [24 CFR 583.115]

Yes No N/A



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b. If individual housing units are being leased with SHP funds, are the lease amounts within the current Fair Market Rent rates (which includes utilities) for the area? [24 CFR 583.115]

Yes No N/A


c. For projects using leasing funds, are the funds not being used to lease

units or structures owned by the project sponsor, the grantee, or their parent organization? [24 CFR 583.115]

Yes No N/A


2. For projects reviewed which charge participant rent, are the rents charged accurately calculated, including deductions and utility allowances, if applicable? [24 CFR 583.315]

Yes No N/A


3. For projects reviewed which charge participant rent, does the file documentation show the source(s) of income used in preparing the rent calculations?

Yes No N/A


4. For projects reviewed which charge participant rent, do the rent records indicate that participants’ incomes are re-examined at least annually?

Yes No N/A



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5. For the projects reviewed, is there adequate residential supervision, based both upon the regulatory criteria and interviews with grantee staff? [24 CFR 583.300(e)]

Yes No N/A


6. a. Is there a written termination policy and does it provide for a formal process that

recognizes the due process rights of individuals receiving assistance? (If there is no written policy, interview staff regarding the process for handling terminations.)


b. If clients have been terminated, does a review of these clients’ files show

that the minimum due process requirements for termination were followed? [24 CFR 583.300(i)]

Yes No N/A


7. For projects reviewed which serve domestic violence victims, is there evidence to support that the grantee has established written procedures regarding confidentiality of client records and the address/location of any project serving domestic violence victims? [24 CFR 583.300(h)]

Yes No N/A


8. [OS] After making a visual inspection of selected housing facilities, are the habitability standards being met? [24 CFR 583.300(b)]

Yes No N/A



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9. For Transitional Housing (TH) projects only, do the entry-exit dates shown in the participant files indicate that the participants exceed the 24-month limitation of stay? [McKinney-Vento Act, Section 424(b)]

Yes No N/A


10. If there are TH projects where participants stay longer than 24 months, do the files for these clients document the need for extended program participation? [24 CFR 583.300(j)]

Yes No N/A


11. If there are TH projects where participants stay longer than 24 months, is the number of participants less than 50% of the total number served by the projects for the projects reviewed? [24 CFR 583.300(j)]

Yes No N/A


12.

Do the grantee’s records show evidence that the required Section 3 reports are being submitted in a timely manner for projects with new construction and rehab activities? [2008 NOFA section I.C.12.c.]

Yes No N/A


13.

a. Has the recipient reviewed the procedures it intends to use to make known the availability of the supportive housing to determine whether they are unlikely to reach persons of any particular race, color, religion, sex, age, national origin, familial status, or handicap who may qualify for admission to the housing? [24 CFR 583.325(c)]

Yes No N/A



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b. Has the recipient established additional procedures that will ensure that persons in the particular race, color, religion, sex, age, national origin, familial status, or handicap groups identified under “a” above can obtain information concerning the availability of the housing?

[24 CFR 583.325(c)]

Yes No N/A


14.

Is there evidence of the recipient’s adoption and implementation of procedures to make available information on the existence and locations of facilities and services that are accessible to persons with a handicap? [24 CFR 583.325(c)]

Yes No N/A


RAPID RE-HOUSING FOR FAMILIES DEMONSTRATION PROGRAM 15.

Do the project’s records show evidence that leasing is the only Housing expenditure? [2008 NOFA section I.A.4.w.]

Yes No N/A


16. Do the participants’ records indicate that the homeless families received only leasing assistance for a period of 3-6 months or 12-15 months? [2008 NOFA section I.A.4.w.]

Yes No N/A


17. Do the participants’ records show evidence that no more than 18 months of leasing assistance was provided to any participant? [2008 NOFA section I.A.4.w.]

Yes No N/A



13-1 04/2010

Guide for Review of SHP Participants Name of Grantee: Staff Consulted: Name(s) of Reviewer(s)

Date



Instructions: This is a MANDATORY review for all of the Supportive Housing Program (SHP) projects. This Exhibit is designed to review the SHP grantee’s homeless projects to determine that program participant eligibility has been adequately documented in terms of their homelessness upon entry into the program (and for SHP/PH projects, their disability). Following the sampling guidance in Section 13-3 of the introduction to this Chapter, request a listing of project clients (current and former), including their entry dates. Select a random sample from both current and former clients (names, case file numbers, apartment numbers, etc. may be used to identify participants). Review these client files to complete the questions in this Exhibit, supplemented by grantee staff interviews. The file sample selected for this Exhibit can also be used to complete Exhibit 13-1, “Guide for Review of SHP Supportive Services,” and Exhibit 13-3, “Guide for Review of SHP Housing.” Note:

1. It is the option of the reviewer to use this form for each individual client reviewed or as a master response form encompassing information regarding all of the clients reviewed. It is the responsibility of the reviewer to ensure that sufficient evidence is documented to support conclusions, including any finding(s) and/or concern(s) noted in the final monitoring report.

2. This exhibit includes additional compliance monitoring questions for SHP projects funded in 2008 under the Rapid Re-Housing Demonstration Program. Since the SHP regulations are applicable to the Rapid Re-Housing Demonstration Program, reviewers should utilize the full exhibit as a questioning guide.

Questions: 1.

Do the program participant files reviewed document that the individuals or families were homeless prior to entry? [24 CFR 583.5]

Yes No N/A



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2.

If SHP funds are used for Permanent Housing Component projects, do the program participant files reviewed demonstrate disability of the homeless individuals or family members? [24 CFR 583.5]

Yes No N/A


3. Are program participant coming from the target populations (e.g., mentally disabled, domestic violence, veterans) identified to be served in the homeless assistance competition approved application? [24 CFR 583.405]

Yes No N/A


4. For the projects reviewed, was there at least one homeless person or formerly homeless person participating in the policy decision-making process? [24 CFR 583.300(f)]

Yes No N/A


RAPID RE-HOUSING DEMONSTRATION PROGRAM PROJECTS 5.

Do all the case management records document that only homeless families are being accepted into the project? [2008 NOFA section I.C.12.b]

Yes No N/A



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6.

Do all the program participants’ records show evidence that the homeless family came from the street or an emergency shelter where the family had resided for a minimum of seven consecutive days prior to project acceptance? [2008 NOFA section I.C.12.b]

Yes No N/A


7. Do all of the program participants’ records show evidence that the homeless families met at least one of the moderate barriers to housing prior to being accepted into the program? [2008 NOFA section I.C.12.b.i-ix.]

Yes No N/A



13-1 04/2010

Guide for Review of SHP Match Documentation Name of Grantee: Staff Consulted: Name(s) of Reviewer(s)

Date


(statute, regulation, NOFA, or grant agreement). If the requirement is not met, HUD must make a finding of noncompliance. All other questions (questions that do not contain the citation for the requirement) do not address requirements, but are included to assist the reviewer in understanding the participant's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding."

Instructions: This Exhibit is designed to evaluate the SHP grantee’s compliance with the financial documentation required to demonstrate that the grantee has contributed its portion of acquisition, rehabilitation, new construction, operations, and supportive services costs for SHP projects. The Annual Progress Report (APR) provides the grantee’s match information. Questions: 1.

Request financial documents and enter the amount of cash resources that the grantee contributes to the project in columns 2-4 of the match exhibit matrix.

SHP Activity

Application Amount Pledged

APR Amount Shown

Documented Amount On-Site (if applicable)

Acquisition $ $ $

Rehabilitation $ $ $

New construction $ $ $

Supportive Services–Year 1 $ $ $



Operations – Year 1 $ $ $



2.

Are the match contributions at least equal to the statutorily required match? [24 CFR 583.125(c), 24 CFR 583.145, and HUD Appropriations Act]

Yes No N/A



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3.

Do the grantee’s cash match contributions equal at least the amount shown in the homeless assistance competition approved application? [Grant Agreement]

Yes No N/A



13-1 04/2010

Guide for Review of SHP Sponsor Management Name of Grantee: Staff Consulted: Name(s) of Reviewer(s)

Date



Instructions: This Exhibit is designed to assess the SHP grantee’s sponsor management, including oversight of the day-to-day operations of sponsor activities to ensure compliance with applicable Federal requirements and the achievement of performance goals identified in the homeless assistance competition approved application. Follow the sampling instructions in Section 13-3 of the introduction to this Chapter in selecting sponsors to review. Note: This exhibit has been amended to include compliance monitoring questions applicable to SHP projects funded in 2008 under the Rapid Re-Housing for Families Demonstration Program (RRH). Questions: 1.

Does the SHP grantee have a management system for the oversight of its sponsors? (If “yes,” briefly describe below and, if the grantee has a written description of its sponsor management policies or systems, attach a copy). [24 CFR Part 84.5 or 24 CFR 85.5]

Yes No N/A


2. Has the grantee executed written agreements with its sponsors to carry out activities in the homeless assistance competition approved application(s)? [24 CFR 84.5 or 24 CFR 85.5]

Yes No N/A



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3. If the answer to “2” above is “yes,” do the statements of work, for the sponsor agreements reviewed, contain sufficient information regarding the descriptions of the types of supportive services/supportive housing activities that would enable the grantee to effectively monitor the sponsor activities? [24 CFR 583.410 (a), CFR 84.5 or 24 CFR 85.5]

Yes No N/A


4. If the grantee executes written agreements with its sponsors, does it have a system or method for amending these sponsor agreements? [24 CFR 84 or 24 CFR 85]

Yes No N/A


5. Does the grantee have a method for monitoring assigned sponsor deadlines for accomplishing major project milestones? [24 CFR 583.410]

Yes No N/A


6. If the SHP grantee is a State or unit of local government, does it pass on at least 50% of the administrative funds to nonprofit organization(s) that are operating supportive housing and/or supportive services projects? [Notice of Funding Availability and applicable Appropriations Act]

Yes No N/A



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7. Does the grantee review sponsors for evidence of conflicts of interest either between the grantee and the sponsor or between sponsors and their contractors? [24 CFR 583.330 (e)]

Yes No N/A


8. For SHP projects involving new construction or rehab activities, does the grantee have a tracking system to document the subgrantees’ submissions of the Section 3 reporting requirements? [2008 NOFA section I.C.12.c.]

Yes No N/A


RAPID RE-HOUSING FOR FAMILIES DEMONSTRATION PROGRAM (RRH) 9.

Does the grantee review its centralized intake system to ensure that subgrantees are entering program participants’ data across the CoC’s jurisdiction? [2008 NOFA section VI.C.2]

Yes No N/A


10. Does the grantee review subgrantees to ensure that all program participants’ needs are being determined by the use of the same assessment tool? [2008 NOFA section I.C.12.c.]

Yes No N/A


Exhibit 13-7 6509.2 REV-5 CHG-2 Supportive Housing Program (SHP)

13-1 03/2008

Guide for Review of SHP Overall Management Systems Name of Grantee: Staff Consulted: Name(s) of Reviewer(s)

Date



Instructions: This Exhibit is designed to evaluate the SHP grantee’s ability to carry out the administrative responsibilities for its SHP funds. The HUD reviewer is to answer Exhibit questions based on staff interviews and file reviews, following the sampling guidance in Section 13-3 of the introduction to this Chapter. Questions: 1.

a. What is the grantee’s system or procedure for ensuring that SHP funds are used in accordance with all program requirements?


b. Does the grantee have written procedures describing its management of the SHP program? (If so, attach copies, or relevant portions thereof, to this Exhibit.)

Yes No


2.

How are responsibilities for implementing and managing the SHP program assigned and delegated? Describe Basis for Conclusion:

6509.2 REV-5 CHG-2 Exhibit 13-7 Supportive Housing Program (SHP)

03/2008 13-2

3. Are the duties for administrative personnel defined by job descriptions that match those submitted in the approved homeless assistance competition application?

Yes No


4. Does a randomly selected review of administrative personnel costs reveal that staff being paid from SHP funds are working on SHP-funded activities? [24 CFR 583.135 (b)]

Yes No


5. Does a randomly selected review of cost records show that SHP funds have been disbursed for eligible activities (e.g., acquisition, rehabilitation, new construction, leasing, supportive services or operating expenses)? [24 CFR 583.110 through 24 CFR 583.135(b)]

Yes No


6.

Does the grantee review for evidence of conflicts of interest between itself and sponsors or contractors?

Yes No Describe Basis for Conclusion:


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7. a. Has a system been developed to track progress of each SHP-funded project

or activity in the program?


b. If developed, does the tracking system include a timetable with

scheduled completion dates?

Yes No N/A


8. If the grantee charges indirect costs to the SHP program, are such costs supported by an Indirect Cost Rate/Cost Allocation Plan prepared in accordance with OMB Circular A-87, Attachment A, Section F, Attachments C and E (for governmental units) or OMB Circular A-122, Attachment A, Section C (for nonprofit organizations)? [24 CFR 583.330(c)]

Yes No N/A


9. If the grantee charges indirect costs to the SHP program, are the costs current and approved? [24 CFR 583.330(c)]

Yes No N/A



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10. Are the administrative costs charged to the SHP, whether direct or indirect, eligible costs? [24 CFR 583.135]

Yes No


Exhibit 138 6509.2 REV5 CHG2 Supportive Housing Program (SHP)

131 03/2008

Guide for Review of SHP Financial Management Name of Grantee:

Staff Consulted: Name(s) of Reviewer(s)

Date

NOTE: All questions that address requirements contain the citation for the source of the requirement (statute, regulation, NOFA, or grant agreement). If the requirement is not met, HUD must make a finding of noncompliance. All other questions (questions that do not contain the citation for the requirement) do not address requirements, but are included to assist the reviewer in understanding the grantee's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding."

Instructions: This Exhibit is designed to review the SHP grantee’s financial management system and eligibility of SHP grant expenditures. With respect to the applicability of OMB Circulars on cost principles, certain requirements do not apply to the SHP program. Specifically, all expenditures for the SHP program must be based on actual, incurred costs. Costs that do not represent an incurred cost such as depreciation or professional retainer fees are not allowable. Follow the sampling guidance in Section 133 of the introduction to this Chapter.

Questions: 1.

Does the grantee have written procedures for recording financial transactions, and a current accounting manual and a chart of accounts? [24 CFR 583.330(c), 24 CFR 84.21(b)(2) or 24 CFR 85.20(b)(2)]

Yes No


2. Does the grantee maintain a policy manual covering the authority for approving financial transactions? [24 CFR 583.330(c), 24 CFR 84.21(b)(2) or 24 CFR 85.20(b)(2)]

Yes No


6509.2 REV5 CHG2 Exhibit 138 Supportive Housing Program (SHP)

03/2008 132

3. If the grantee has a policy manual, does it provide guidelines for controlling expenditures, such as purchasing requirements and travel authorizations? [24 CFR 583.330(c), 24 CFR 84.21(b)(2) or 24 CFR 85.20(b)(2)] Yes No N/A


4. Does the grantee have written procedures regarding the maintenance of accounting records? [24 CFR 583.330(c), 24 CFR 84.53(b) or 24 CFR 85.42]

Yes No


5. Are the grantee’s fiscal records and valuables secured in a limitedaccess area? [24 CFR 583.330(c), 24 CFR 84.21(b)(3) or 24 CFR 85.20(b)(3)] Yes No


6. If the SHP grantee has an interestbearing account, is there evidence that any interest on grant advances has been returned to HUD? [24 CFR 583.330 (c), 24 CFR 84.22(k) or 24 CFR 85.21(i)] Yes No N/A



133 03/2008

7. Does the grantee identify expenditures in its accounting records according to eligible activities identified in the approved homeless assistance competition application? [24 CFR 583.410 and 24 CFR 583.330(c), 24 CFR 84.21(b)(2) or 24 CFR 85.20(b)(2)]

Yes No


8. Do the fiscal records indicate evidence that the grantee has effective internal control over, and accountability for, all grant funds, property and other assets? [24 CFR 583.330 (c), 24 CFR 84.21(b)(3) or 24 CFR 85.20(b)(3)]

Yes No


9. Does a review of the sample transaction records indicate that SHP expenditures were for eligible costs and supported by adequate source documentation (invoices, contracts, or purchase orders)? [24 CFR 583.100135 and 24 CFR 583.330 (c), 24 CFR 84.21(b)(7) or 24 CFR 85.20(b)(6)]

Yes No


10. If the grantee draws down SHP funds on an advance (and not reimbursement) basis, do the financial records reveal that payments made for project costs occurred within three business days of the deposit of grant funds? [24 CFR 583.330 (c), 24 CFR 84.21(b)(5) or 24 CFR 85.20(b)(7)]

Yes No N/A



03/2008 134

11. Are journal entries for expenditures clearly explained and reviewed by some form of a checks and balance system? [24 CFR 84.21(b)(1) or 24 CFR 85.20(b)(1)]

Yes No


12. Is there evidence that the grantee requires subsidiary records for accounts, etc., to be balanced with control accounts on a regular basis? [24 CFR 583.330(c), 24 CFR 84.21(b)(1) or 24 CFR 85.20(b)(1)]

Yes No


13. a. Are charges to the SHP for salaries and wages, whether treated as direct or

indirect costs, based on payrolls documented in accordance with generally accepted accounting principles and approved by a responsible official(s) of the organization being monitored?

Yes No


b. For employees working solely on SHP, are charges for their salaries and wages supported by periodic certifications that the employees worked solely on that program for the period covered by the certification? [OMB Circular A87, Attachment B, 8(h)(3)]

Yes No N/A



135 03/2008

c. Were the certifications prepared at least semiannually and signed by the employee or a supervisory official having first hand knowledge of the work performed by the employee? [OMB Circular A87, Attachment B, 8(h)(3)]

Yes No


14. Is there evidence that the staff duties are separated so that no one individual has complete authority over an entire financial transaction? [24 CFR 583.330(c), 24 CFR 84.21(b)(1) or 24 CFR 85.20(b)(1)]

Yes No


15. Are payments for employee salaries supported by timesheets indicating actual times, not percentages? [24 CFR 583.330 (c), OMB Circular A87, Attachment B, #8(h) or OMB Circular A122, Attachment B, #8]

Yes No


16. If salaries are being paid from more than one source, do the fiscal records clearly define payments among the funding sources? [24 CFR 583.330 (c), OMB Circular A87, Attachment B, #11(h) or OMB Circular A122, Attachment B, #11(m)]

Yes No N/A



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17. If salaries involve payments from more than one SHP activity line (e.g., supportive services, operating costs), can payments for wages be clearly tracked within the grantee’s fiscal records? [24 CFR 583.330 (c), 24 CFR 84.21(b)(1) or 24 CFR 85.20(b)(1)]

Yes No N/A


18. Is there evidence in the financial records of any cash payments being provided directly to the clients? Yes No


19. Does the Line of Credit Control System (LOCCS) withdrawal information match the information from the SHP grantee’s drawdown voucher requests? [24 CFR 583.330(c)]

Yes No



13-1 03/2008

Guide for Review of SHP Cost Allowability Name of Grantee: Staff Consulted: Name(s) of Reviewer(s)

Date


(statute, regulation, Consolidated Plan/IDIS/CAPER, or grant agreement). If the requirement is not met, HUD must make a finding of noncompliance. All other questions (questions that do not contain the citation for the requirement) do not address requirements, but are included to assist the reviewer in understanding the grantee's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding."

Instructions: This Exhibit is designed to review the SHP grantee's allocation of cost to verify that its procedures comply with OMB Circular A-87, OMB Circular A-122, 24 CFR Part 84 and 24 CFR 85.22, made applicable to the SHP program per 24 CFR 583.300. Follow the sampling guidance in Section 13-3 of the introduction to this Chapter in selecting cost items to review, supplemented by staff interviews. Questions: 1.

Does a sampling of costs reveal that professional service contracts (e.g., legal, account, audit, consulting) costs were necessary and reasonable for proper and efficient administration of the SHP program? [24 CFR Part 84 or 24 CFR Part 85; OMB Circular A-87, Attachment B.32 or OMB Circular A-122, Attachment B.37]

Yes No


2. Does a sampling of costs reveal that travel expenditures were necessary and reasonable for proper and efficient administration of the SHP program? [24 CFR Part 84 or 24 CFR Part 85; OMB Circular A-87, Attachment B.43 or OMB Circular A-122, Attachment B.51 ]

Yes No



03/2008 13-2

3. Are all of the administrative costs reviewed necessary and reasonable for proper and efficient administration of the SHP program? [24 CFR Part 84 or 24 CFR Part 85; OMB Circular A-87, Attachment B or OMB Circular A-122, Attachment B]

Yes No


4. Do all of the SHP expenditures reviewed meet the program and fiscal eligibility requirements? (Examples of ineligible expenditures include, but are not limited to, costs associated with entertainment,contributions and donations, fines and penalties, or general governmental and nonprofit expenditures including salary and expenses of the chief executive officer of the grantee.) [OMB Circular A-87, Attachment B, or OMB Circular A-122, Attachment B]

Yes No


5. Does a review of the SHP expenditures indicate that costs related to lobbying political activities have not been charged to the SHP program? [OMB Circular A-87 or OMB Circular A-122]

Yes No



13-1 09/2005

Guide for Review of SHP Procurement Name of Grantee: Staff Consulted: Name(s) of Reviewer(s)

Date



Instructions: This Exhibit is designed to monitor the SHP grantee’s compliance with procurement requirements. It applies to governmental entities. The appropriate procurement requirements for non-profit organizations can be found at 24 CFR 84.40 – 84.48. The Exhibit is divided into five sections: Sample Selection; Small Purchase; Sealed Bids; Competitive Proposals; and Noncompetitive Proposals. The HUD reviewer should follow the sampling instructions in Section 13-3 of the introduction to this Chapter and randomly select a sample of the grantee’s procurement transactions, pull the procurement files related to the selected transactions and use the files to verify responses to the Exhibit questions. The SHP regulatory citation for the uniform administrative requirements is located at 24 CFR 583.330. Questions:

A. SAMPLE SELECTION 1.

Provide the following information for the selected sample of procurement transactions. (If additional rows are needed, please attach an additional sheet.)

Name of Contractor/Purpose

Date of Purchase

Amount Budgeted

Amount Obligated

Amount Expended

ProcurementMethod*

* Use the following numbers for these methods of procurement [see 24 CFR 85.36(d) : (1) Small Purchase; (2) Sealed Bids; (3) Competitive Proposals; and (4) Noncompetitive Proposals.


09/2005 13-2

B. SMALL PURCHASES 2.

Does the grantee document receipt of an adequate number of price or rate quotations from qualified sources for procurements of $25,000 or less? [24 CFR 85.36(d)(1)]

Yes No


C. SEALED BIDS 3.

Does the grantee receive at least two or more sealed bids for each procurement transaction? [24 CFR 85.36 (d)(2)]

Yes No


4.

Do the procurement transactions reviewed lend themselves to firm, fixed price contracts and can selection of successful bidders be made principally on the bases of price? [24 CFR 85.36]

Yes No



13-3 09/2005

5. Did the grantee publicly advertise the Invitation for Bids (IFBs) and were bids solicited from an adequate number of known suppliers, providing them sufficient time before the date set for opening bids? [24 CFR 85.36(d)(2)(ii)(A)]

Yes No


6.

Did the IFBs, including specifications and pertinent attachments, clearly define the items or services needed in order for the bidders to properly respond? [24 CFR 85.36(d)(2)(ii)(B)]

Yes No


7.

For the transactions reviewed, were all bids opened publicly at the times and places stated in the IFBs? [24 CFR 85.36]

Yes No


8.

Are contracts awarded to the lowest responsive and responsible bidders? [24 CFR 85.36]



09/2005 13-4

D. COMPETITIVE PROPOSALS 9.

Is this procurement method used generally when conditions are not appropriate for sealed bids? [24 CFR 85.36]

Yes No


10.

For the transactions reviewed, do the Requests for Proposals (RFPs) state clearly and accurately the technical requirements for the goods or services to be procured? [24 CFR 85.36]

Yes No


11.

Are proposals solicited from an adequate number of qualified sources, consistent with the nature and requirements of the procurements? [24 CFR 85.36]

Yes No



13-5 09/2005

12.

Does the grantee publicize RFPs and honor reasonable requests by parties to compete to the maximum extent practicable? [24 CFR 85.36]

Yes No


13.

Do the RFPs identify all significant evaluation factors, including price or cost where required and their relative importance? [24 CFR 85.36]

Yes No


14.

Do the records indicate that the grantee conducted technical evaluations of submitted proposals; determined responsible offerors from such evaluations; as necessary and when authorized, conducted negotiations, written or oral, for final contract award; and made awards to the most responsive and responsible offerors whose proposals will be most advantageous to the grantee after price and other factors are considered? [24 CFR 85.36(d)(3)(iii) and (iv) and 24 CFR 85.36(b)(8)]

Yes No



09/2005 13-6

15.

If RFPs involved architectural or engineering professional services, were submissions evaluated with respect to factors other than price (e.g., can the grantee document the bases for negotiations of fair and reasonable compensation)? [24 CFR 85.36]

Yes No N/A


16.

If RFPs involved architectural or engineering professional services, does the grantee maintain a list of qualified bidders who can respond to its RFPs? [24 CFR 85.36]

Yes No N/A


E. NONCOMPETITIVE PROPOSALS 17.

If noncompetitive proposals were used, can the grantee show that other methods of procurement (small purchase, sealed bids or competitive proposals) were infeasible because the items were available from a single source; OR a public exigency or emergency was of such urgency to not permit a delay resulting from competitive solicitation; OR, after solicitation from a number of sources, competition was determined inadequate; OR approval was granted by HUD? [24 CFR 85.36(d) (4)]

Yes No N/A



13-1 03/2008

Guide for Review of SHP Equipment and Equipment Disposition Name of Grantee: Staff Consulted: Name(s) of Reviewer(s)

Date



Instructions: This Exhibit is designed to review the SHP grantee’s equipment management policies for compliance with 24 CFR 85.32 and 24 CFR 84.34. It is divided into three sections: Sample Selection, Equipment Management, and Equipment Disposition. If the grantee’s accounting system includes information on equipment acquired with SHP funds, it can be used as starting point for selecting a representative sample of equipment transactions to review. The HUD reviewer is to follow the sampling guidance in Section 13-3 in the introduction to this Chapter to select records regarding equipment purchases and sales. These records, along with staff interviews, will form the basis for completing the chart below and answering Exhibit questions. The SHP regulatory citation for the uniform administrative requirements is located in 24 CFR 583.330. Questions: A. SAMPLE SELECTION 1.

Complete the table below after selecting equipment transactions for review. (If additional rows are needed, please attach an additional sheet.)

Item

Date

Acquired Acquisition

Cost

Federal Share of

Acquisition Cost

Disposition Date

Disposition Proceeds

Federal Share of

Disposition Proceeds


03/2008 13-2

B. EQUIPMENT MANAGEMENT 2.

Does the grantee maintain equipment records that contain the information required by the applicable regulations? [24 CFR 85.32 or 24 CFR 84.34]

Yes No


3. Has a physical inventory of equipment been taken and the result reconciled with the property records within two years from the date of this monitoring? [24 CFR 85.32 or 24 CFR 84.34]

Yes No


C. EQUIPMENT DISPOSITION 4.

a. Do the grantee’s procedures require efforts to obtain the highest possible return for sale of equipment? [24 CFR 85.32 (d)(5) or 24 CFR 84.34(f)(6)]

Yes No


b. If grant-funded equipment was sold during the period under review, is

there evidence to show that efforts were made to obtain the highest possible return? [24 CFR 85.32 (d)(5) or 24 CFR 84.34(f)(6)]

Yes No N/A



13-1 03/2008

Guide for Review of SHP Other Federal Requirements Name of Grantee: Staff Consulted: Name(s) of Reviewer(s)

Date


(statute, regulation, NOFA, or grant agreement). Note, however, that certain questions in this Exhibit reference reviews conducted using Exhibits elsewhere in this Handbook. If a requirement is not met, HUD must make a finding of noncompliance. Where responses to questions for this Exhibit are based on other Exhibit reviews, the conclusions should be noted here, as applicable. Other questions (questions that do not contain the citation for the requirement) do not address requirements, but are included to assist the reviewer in understanding the participant's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding."

Instructions: This Exhibit is designed to evaluate the SHP grantee’s compliance with other applicable Federal requirements. Note that the provisions of the Davis-Bacon Act do not apply to the SHP program per the regulations at 24 CFR 583.330(g). For certain requirements, a reference is made to other Exhibits or Chapters in this Handbook. If other Exhibits are used to monitor these areas, only the conclusion(s) should be noted here with a cross-reference to the supporting review documentation/Exhibit. Note also that, if other HUD funds have been used to carry out SHP-assisted projects and compliance monitoring for the areas below has been conducted in the past 12 months, it is not necessary to review these areas again unless the last risk analysis results or subsequent information raise questions or concerns. Questions: A. DRUG-FREE WORKPLACE 1.

Does the SHP grantee have a drug-free workplace statement per the requirements of 24 CFR 21.200?

Yes No


2. If the requirements of the Drug-Free Workplace actions were monitored, is the SHP grantee in compliance?

Yes No N/A



03/2008 13-2

B. UNIFORM RELOCATION ASSISTANCE AND REAL PROPERTY ACQUISITION POLICIES ACT OF 1970, as amended

3. If SHP funds have been used to assist projects involving acquisition, demolition, or rehabilitation, has the grantee budgeted or paid for relocation assistance to displaced persons or businesses? [24 CFR 583.310]

Yes No N/A


C. CONFLICT OF INTEREST 4.

Is the SHP grantee in compliance with the conflict of interest requirements or has an exception been granted? [24 CFR 583.330(e)]

Yes No


D. FLOOD INSURANCE 5.

If SHP funds were used for acquisition or construction (including rehabilitation) of real property located within the Special Flood Hazard Area (SFHA), are those assisted properties in compliance with flood insurance purchase and community participation requirements at Sections 102(a) and 202(a) of the Flood Disaster Protection Act of 1973, as amended, and at 24 CFR 583.330(a)? (Complete Exhibit 27-1 of this Handbook, “Guide for Review of Flood Insurance Protection.”) [24 CFR 583.330(a) and 24 CFR 58.6(a)]

Yes No N/A



13-3 03/2008

E. COASTAL BARRIER RESOURCES ACT 6.

If applicable, is there evidence of the SHP grantee’s compliance with the requirements of the Coastal Barrier Resources Act of 1982? [24 CFR 583.330(b)]

Yes No N/A


F. LEAD HAZARD ABATEMENT REQUIREMENTS 7.

If this area was reviewed, was the SHP grantee determined to be in compliance with the applicable requirements? (Use pertinent Exhibits in Chapter 24 and note conclusions below.) [24 CFR 583.330(d)]

Yes No N/A


G. ENVIRONMENTAL REVIEW 8.

Were environmental requirements at Part 58 met? (Use the applicable Exhibits in Chapter 21 to answer this question.) [24 CFR 583.230]

Yes No


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