continuum of care administrative plan
TRANSCRIPT
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HOUSING AUTHORITY of the County of Salt Lake
Continuum of Care
Administrative Plan
November 2015
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Table of Contents
I. GENERAL INFORMATION
1. Purpose of this Manual
2. Continuum of Care Summary
a. Overview
b. Program Goals and Objectives
3. Administrative Structure
a. Overview
b. Continuum of Care Components
II. APPLYING FOR ADMISSION
4. Eligibility Criteria
a. Homelessness
b. Chronic Homelessness
c. Disability
d. Income
e. Eligible Households
f. Denial of Assistance
g. Record Keeping
5. Outreach
a. Outreach Policy
b. Outreach Procedure
6. Referral
7. Waiting List
a. Waiting List Opening
b. Waiting List Order
c. Waiting List Maintenance
8. Application, Screening, and Eligibility Determination Process
a. Application Packet
b. Eligibility Determination
c. Orientation/Coupon Issuance Meeting
d. Fair Housing
III. SECURING A HOUSING UNIT
9. Occupancy Standards
10. Housing Search/Placement
For TRA Programs
a. Housing Certificate
b. Housing Search Process
c. Request for Lease Approval
For SRA/PRA/SRO Programs
d. Unit Selection Policy
11. Housing Unit Inspection
12. Allowable Rents
13. Rent Calculation
14. Hardship Waiver
15. Leasing Process
16. Security Deposits
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IV. ONGOING PROGRAM PARTICIPATION
17. Participant Obligations
18. Support Services
a. Service Participation Requirements
b. Services Provided
c. Responsibilities of Service Provider Agencies
d. Service Match
19. Annual Recertification’s
a. Tracking Recertification Dates
b. Documents Required from Participants and Case Manager
c. Inspection and Rent Adjustment
20. Interim Changes
a. Interim Changes
b. Changes in Household Composition
21. Transfers
a. Transfer Policy
b. Transfer Procedures
c. Transferring Between Grants
22. Vacancies
V. ENDING PROGRAM PARTICIPATION
23. Termination of Housing Assistance/Eviction
a. Termination by Participant
b. Termination by CoC Program
c. Termination of Tenancy by Landlord
24. Participant Appeals/Grievance Procedures
a. Informal Grievance Process
b. Informal Hearing
c. Formal Hearing
VI. ADMINISTRATION
25. Data Management
a. Participant Files
b. HMIS
c. Service Match Documentation
d. Participant File Quality Control
26. Reporting
27. Financial Management
a. Roles and Responsibilities
b. Rental Assistance Payments
c. Administrative Expenses
d. HUD Draws
e. Financial Reports
28. Grant Administration
a. Tracking Grant Income and Expenditures
b. Analyzing and Responding to Grant Utilization Data
c. Grant Extensions and Renewals
d. Grant Amendments
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I. GENERAL INFORMATION
1. Purpose of This Manual
The purpose of this manual is to describe the policies and procedures of the Housing Authority
of the County of Salt Lake (HACSL) for operating the Continuum of Care (CoC) program. The
aim is to provide standard concepts, definitions and procedures to enable staff to understand and
effectively administer the program. This manual is designed to be used as a tool to train new staff
and also as a reference and resource for existing staff. It is also a public document and will be
made available upon request to partner agencies, funders, participants, and others who wish to
read the policies and procedures relating to the program.
To the extent an issue is not otherwise explained in this manual, HACSL will follow the
appropriate provisions of the HEARTH Act and the policies and procedures contained in
HACSL’s Section 8 Administrative Plan.
This manual will be updated on a regular basis to reflect both changes in HACSL’s policies and
procedures as well as new HUD regulations, notices and other guidance.
2. CoC Program Summary
A. Overview
Continuum of Care (CoC) is a U.S. Department of Housing and Urban Development (HUD)
program funded through the McKinney-Vento Act and administered by the Housing Authority of
the County of Salt Lake. The Funding is allocated through the Salt Lake Continuum of Care and
distributed to the various member agencies in the valley.
The CoC Program assists homeless people with disabilities to gain entry to housing and to
achieve residential, economic, and emotional stability. This goal is accomplished by providing
safe, secure permanent housing and a broad range of supportive services. Program participants
pay 30% of household income or a $50.00 minimum rent. The CoC subsidy covers the balance
of the rent payable to the landlord.
HACSL currently has nine CoC grants:
CoC Renewal 88-unit tenant-based rental assistance (TRA)
CoC New Chronic 26-unit tenant-based rental assistance (TRA)
CoC Grace Mary Manor 30-unit project-based rental assistance (PRA)
CoC Kelly Benson 9 -unit project-based rental assistance (PRA)
CoC Sponsor Based with TRH 5-unit sponsor-based rental assistance (SRA)
CoC Bud Bailey Youth 10-unit project-based rental assistance (PRA)
CoC Bud Bailey Families 6-unit project-based rental assistance (PRA)
CoC Leasing 15-unit project based leasing (PRA)
COC PSH TRA Chronic 2014 16-unit tenant-based rental assistance (TRA)
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B. Program Goals and Objectives
The CoC program is primarily designed for people who have lived in places not ordinarily meant
for human habitation or in emergency shelters. The program’s goals and specific outcome
objectives are designed to assist these participants in achieving:
Increased Housing Stability
90% Average Occupancy Rate
85% Length of stay 7 months or longer on the program
10% or less exit to shelter, streets or unknown
Increased Income/Skills
25% Employment at Program exit.
85% Income Amounts Maintained or Increased at Program Exit
Greater Self Sufficiency
30% Health Insurance at Program Exit (Includes Medicaid, SAGA, Veterans Health
Care, Private Insurance, etc)
50% Food Stamps at Program exit
75% Non-Cash Financial Resources
Additional program goals include:
HUD Compliance
Drawdown of Funds within 30 days
No findings addressed in Corrective Action Plan (CAP) submitted to HUD
Meet Universal Data Element Requirements
3. Administrative Structure
A. Overview
HACSL is a tax-exempt, non-profit, municipal corporation, governed by a Board of
Commissioners nominated by the Salt Lake County Mayor and confirmed by the County
Commission.
In accordance with 24 CFR 582(300)(a), HACSL has a former homeless resident of a HACSL
property on the Board of Commissioners that contributes to decisions and policies. The Board of
Commissioners is also assisted by the Resident Advisory Board that makes recommendations
based on the position of the participants.
All policies and procedures developed for the Continuum of Care Programs must be reviewed
and approved by the Board of Commissioners.
B. Continuum of Care Components
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Continuum of Care has four major components or types of assistance: Tenant-based Rental
Assistance (TRA), Project-based Rental Assistance (PRA), Sponsor-based Rental Assistance
(SRA), and SRO Based Assistance (SRO). HACSL administers 3 of the 4 components: TRA,
PRA, and SRA.
Tenant-Based Program (TRA):
Under the TRA component, an applicant (HACSL) requests funds to provide rental assistance on
behalf of program participants who choose their own housing units. If a participant decides to
move, he or she may take their rental assistance to the new housing unit.
The Housing Authority of the County of Salt Lake (HACSL) is the grantee for the TRA CoC
funds and is responsible for the overall management of the CoC Program. Specifically, HACSL
is responsible for: (1) developing and implementing CoC policies and procedures in accordance
with HUD’s regulations and guidance; (2) managing all aspects of the participants’ housing
assistance, including conducting eligibility determinations, annual recertification’s, inspections;
calculating tenant rent and HAP payments; and paying landlords; (3) managing CoC grant funds,
(4) maintaining relevant data on program participants and compiling HUD’s Annual Progress
Report (APR) for each grant; and (5) coordinating with service provider agencies that provide
services to CoC participants.
The HACSL partners with a network of service provider agencies. These agencies are
responsible for: (1) referring potential participants to the program; and (2) providing ongoing
supportive services to participants who are accepted into the program.
Sponsor-Based Program (SRA)
The SRA component of HUD’s CoC program provides grants for rental assistance through
contracts between the grant recipient and sponsor organizations. A sponsor may be a private,
nonprofit organization or a community mental health agency established as a public nonprofit
organization. Participants reside in housing that is owned or leased by the sponsor.
There are two main entities involved with the administration of the HACSL CoC/SRA Program.
This entity and its primary responsibilities are summarized below.
Housing Authority of the County of Salt Lake (HACSL). HACSL is the grant recipient for
the CoC/SRA grant and is responsible for overall grant management. These responsibilities
include: (1) developing and implementing CoC policies and procedures in accordance with
HUD’s regulations and guidance; (2) managing CoC grant funds; (3) compiling the HUD
Annual Progress Report (APR) for the grant; and (4) coordinating with the sponsor and lead
service provider to ensure that all HUD regulations and requirements relating to the grants
are being met.
The Road Home (TRH) is the sponsor for this grant. TRH owns and leases five units of
scattered site supportive housing throughout Salt Lake County. As the sponsor for the grant,
TRH is responsible for ensuring that there are at least five units available for CoC/SRA
Program clients. TRH operates the largest homeless shelter in Utah and has access to the
population served by this grant for referrals. TRH is also the lead service provider for CoC
SRA clients. HACSL has a Memorandum of Understanding with TRH to provide case
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management to eligible clients residing in properties owned by TRH. TRH is responsible for
providing services to CoC SRA clients, including outreach, access to substance abuse
treatment, mental health assessment, treatment and other supportive services. Services will
provide an in-kind match to rental assistance as required by HUD. TRH is also responsible
for documenting all services received by participants and submitting it to HACSL.
Project-Based Programs (PRA)
Under the PRA component, an applicant (HACSL) may request grant funds to provide rental
assistance through a contract with a building owner(s). An applicant must enter into a
contract with the building owner(s) for the full five- or ten-year period of assistance. The
building owner must agree to accept eligible CoC participants for this time period.
Participants must live in an assisted unit in a particular property.
HACSL is also the grantee for CoC/PRA funds and is responsible for the overall
management of the CoC Program. Specifically, HACSL is responsible for: 1) Contracting
with a building owner who agrees to accept eligible CoC participants for a particular length
of time: (2) developing and implementing CoC policies and procedures in accordance with
HUD’s regulations and guidance; (3) managing all aspects of the participants’ housing
assistance, including conducting eligibility determinations, annual recertification’s,
inspections; calculating tenant rent and HAP payments; and paying landlords; (4) managing
CoC grant funds, (5) maintaining relevant data on program participants and compiling
HUD’s Annual Progress Report (APR) for each grant; and (6) coordinating with service
provider agencies that provide services to CoC participants.
HACSL has developed 3 Supportive Housing Apartment complexes that house participants
of the Continuum of Care program as well as other subsidized programs. Each complex has
contracted a certain number units for Continuum of Care as follows: Grace Mary Manor
Apartments (30 units), Kelly Benson Apartments (9 units) and Bud Bailey Apartments (16
units). Each of these locations also has on site case management that is responsible for
service match requirement.
II. APPLYING FOR ADMISSION
4. Eligibility Criteria
The Housing Authority of the County of Salt Lake is responsible for ensuring that every
individual and family admitted to the Continuum of Care program meets all program eligibility
requirements.
To be eligible for the HACSL CoC Programs, applicants must be homeless and disabled as
defined below and meet the following eligibility criteria:
A. Homelessness [24 CFR 91.5]
The applicant must meet the HUD definition of homelessness. There are four categories under
which an individual or family may be defined as homeless. Two of these categories are allowed
under the Permanent Supportive Housing component and are as follows:
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(1) Literally Homeless: An individual or family who lacks a fixed, regular, and adequate
nighttime residence, meaning:
(i) An individual or family with a primary nighttime residence that is a public or
private place not designed for or ordinarily used as a regular sleeping
accommodation for human beings, including a car, park, abandoned building, bus or
train station, airport, or camping ground;
(ii) An individual or family living in a supervised publicly or privately operated
shelter designated to provide temporary living arrangements (including congregate
shelters, transitional housing, and hotels and motels paid for by charitable
organizations or by federal, state, or local government programs for low-income
individuals); or
(iii) An individual who is exiting an institution where he or she resided for 90 days
or less and who resided in an emergency shelter or place not meant for human
habitation immediately before entering that institution;
(2) Fleeing/Attempting to flee DV: Any individual or family who:
(i) Is fleeing, or is attempting to flee, domestic violence, dating violence, sexual
assault, stalking, or other dangerous or life-threatening conditions that relate to
violence against the individual or a family member, including a child, that has either
taken place within the individual's or family's primary nighttime residence or has
made the individual or family afraid to return to their primary nighttime residence;
(ii) Has no other residence; and
(iii) Lacks the resources or support networks, e.g., family, friends, faith-based or
other social networks, to obtain other permanent housing.
B. Chronically Homelessness [24 CFR 91.5]
In addition to the above mentioned criteria several of HACSL’s CoC grants require that
applicants be chronically homeless defined as:
(1) An individual who:
(i) Is homeless and lives in a place not meant for human habitation, a safe haven, or
in an emergency shelter; and
(ii) Has been homeless and living or residing in a place not meant for human
habitation, a safe haven, or in an emergency shelter continuously for at least one
year or on at least four separate occasions in the last 3 years, where each homeless
occasion was at least 15 days; and
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(iii) Can be diagnosed with one or more of the following conditions: substance use
disorder, serious mental illness, developmental disability (as defined in section 102
of the Developmental Disabilities Assistance Bill of Rights Act of 2000 (42 U.S.C.
15002)), post-traumatic stress disorder, cognitive impairments resulting from brain
injury, or chronic physical illness or disability;
(2) An individual who has been residing in an institutional care facility, including a jail,
substance abuse or mental health treatment facility, hospital, or other similar facility, for
that facility; or
(3) A family with an adult head of household (or if there is no adult in the family, a minor
head of household) who meets all of the criteria in paragraph (1) of this definition,
including a family whose composition has fluctuated while the head of household has
been homeless.
Those transitioning from HPRP (Rapid Re-housing Assistance) can also qualify as homeless and
chronically homeless as stated below:
“HPRP assistance is temporary. Persons who were homeless before receiving HPRP assistance
(Rapid Re-housing assistance) do not lose their homeless status and remain eligible for
assistance under other CoC-funded programs.
HUD recently established a new policy for the status of chronically homeless persons that
receive HPRP assistance, similar to the policy for homeless status. The new policy is that if
someone was chronically homeless before receiving HPRP assistance, they retain their
chronically homeless status, which allows them to exit HPRP to Continuum of Care Samaritan
Permanent Housing projects.” http://www.hudhre.info/index.cfm?do=viewFaqById&faqID=462
C. Disability [The McKinney-Vento Homeless Assistance Act As amended by HEARTH
Act of 2009]:
An applicant must have one or more of the following three targeted disabilities:
a. Serious Mental Illness
b. Chronic alcohol and/or drug abuse;
c. AIDS or related diseases
Additionally, the applicant must be disabled according to the following HUD definition [The
McKinney-Vento Homeless Assistance Act As amended by HEARTH Act of 2009]:
(i) (I) is expected to be long-continuing or of indefinite duration;
(II) substantially impedes the individual's ability to live independently;
(III) could be improved by the provision of more suitable housing conditions; and
(IV) is a physical, mental, or emotional impairment, including an impairment
caused by alcohol or drug abuse, post-traumatic stress disorder, or brain injury;
(ii) is a developmental disability, as defined in section 102 of the Developmental
Disabilities Assistance and Bill of Rights Act of 2000 (42 U.S.C. 15002); or
(iii) is the disease of acquired immunodeficiency syndrome or any condition
arising from the etiologic agency for acquired immunodeficiency syndrome.
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In the case of a homeless household with more than one member, at least one adult member of
the households must meet the disability criteria.
In accordance with HUD Regulation 24 CFR 582.330(a) HACSL will not exclude other eligible
disabled persons (i.e. those who do not have mental illness, substance abuse or HIV/AIDS).
However, individuals with other disabilities will not be considered for admission to the program
when there is sufficient demand by the three identified target populations and the other disabled
homeless persons would not benefit from the services provided.
D. Income [24 CFR 582.5]
To be eligible for assistance, persons must be Very Low Income. Very Low-Income means an
annual income not in excess of 50 percent of the median income for the area, as determined by
HUD.
E. Eligible Households [24 CFR 5.105, 5.403]
The following households are eligible to participate in the HACSL CoC Program:
1) Family Households: Family includes, but is not limited to, the following, regardless of actual
or perceived sexual orientation, gender identity, or marital status:
(1) A single person, who may be an elderly person, displaced person, disabled person, near-
elderly person, or any other single person; or
(2) A group of persons residing together, and such group includes, but is not limited to:
(i) A family with or without children (a child who is temporarily away from the home
because of placement in foster care is considered a member of the family);
(ii) An elderly family;
(iii) A near-elderly family;
(iv) A disabled family;
(v) A displaced family; and
(vi) The remaining member of a tenant family.
2) Households with a live in Aid [24 CFR 5.403]: Live-in aide means a person who resides with
one or more elderly persons, or near-elderly persons, or persons with disabilities, and who:
(1) Is determined to be essential to the care and well-being of the persons;
(2) Is not obligated for the support of the persons; and
(3) Would not be living in the unit except to provide the necessary supportive
services.
Verification must be provided by a doctor certifying that the participant requires an attendant
to live with them in order to safely manage their medical and healthcare needs.
Applicants who have Conventional Housing or Section 8 vouchers may not receive
Continuum of Care housing assistance.
Applicants who have previously been terminated by the Continuum of Care Program may
reapply for the program. An applicant’s past history with the program will be taken into
consideration in making an eligibility determination, but will not be the sole determining
factor for acceptance.
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Relationship with Service Provider. HACSL’s Continuum of Care programs require that
applicants already be a client of a social service agency that has committed to providing
ongoing case management to the applicant once they are housed. Current participating
agencies are:
The Road Home (TRH)
Volunteers of America (VOA)
Valley Mental Health (VMH)
Wasatch Homeless Health Care
First Step House(FSH)
Family Promise Salt Lake (FPSL)
Transfer of Subsidy
In the case where a Head of Household (HOH) becomes deceased; the housing subsidy
coupon may be transferred to another person in the household as long as that person meets
the eligibility requirements for the housing program. If that individual does not meet the
eligibility requirements, housing subsidy will be provided until the end of the lease (or until
termination results for non-compliance to the program). (Homelessness 101 – Managing
a HUD Continuum of Care Homelessness Assistance Grant)
In the case the Head of Household is incarcerated for less than 90 days, the Head of
Household may remain on the program. If the Head of Household is incarcerated for more
than 90 days and the household consists of no other members, the housing subsidy will be
terminated. If the Head of Household is incarcerated for more than 90 days and the
household consist of other members, HACSL will allow for housing subsidy for the
remaining family members until the lease ends.
F. Denial of Assistance
A family that does not meet the eligibility criteria discussed in this section must be denied
assistance.
In addition, HUD requires the Housing Authority of the County of Salt Lake to deny
assistance based on certain types of current or past behaviors of family members. Behaviors that
may constitute a denial are and not limited to:
Any household member has ever been convicted of drug-related criminal activity for the
production or manufacturing of methamphetamine.
Any household member is subject to a lifetime registration requirement under a state sex
offender registration program.
In addition, HUD permits the Housing Authority of the County of Salt Lake to deny
assistance based on certain types of current or past behaviors of family members. Behaviors that
may constitute a denial are and not limited to:
Criminal activity that may threaten the health, safety, or right to peaceful enjoyment of
the premises by other residents or persons residing in the immediate vicinity; or Criminal
activity that may threaten the health or safety of property owners and management staff,
and persons performing contract administration functions or other responsibilities on
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behalf of the PHA (including a PHA employee or a PHA contractor, subcontractor, or
agent).
Any past history of repeated offences and/or convictions in relation to illegal drug
activity within the past 6 months./
o The PHA will also consider evidence from treatment providers or community-
based organizations providing services to household members. Due to this policy
the PHA will send out an intent to deny letter to the applicant and will give them
15 days to respond with any documentation that is listed above. If documentation
shows that the participant is cooperating with services the denial can be reversed.
The written notice of denial must contain a statement that the participant has a right to an
Informal Hearing for a review of the decision, in which the participant is given the opportunity to
present written or oral objections and may be represented by a third party advocate. To request
an Informal Hearing, the participant must do so in writing within ten (10) days of the date of the
denial letter. A participant who fails to request an informal hearing waives this right, and the
decision to deny them from the program becomes final.
G. Record Keeping [CFR 582.301]
HACSL must maintain sufficient records to ensure that HUD eligibility requirements are being
met. Acceptable evidence of eligibility criteria are as follows:
1. Homeless Status:
- Third-party documentation
- Intake worker observations
- Certification from the person seeking assistance.
The priority for obtaining the above mentioned evidence is third-party
documentation is first, intake worker observations second, and certification from
the person seeking assistance third. Any certification that is accepted on behalf
from the person seeking assistance may only be used document 1/3 of the time
homeless.
Records contained in an HMIS or comparable database used by victim service or
legal service providers are acceptable evidence of third-party documentation and
intake worker observations.
Literally Homeless
(1) If the individual or family qualifies as Literally Homeless, acceptable
evidence includes a written observation by an outreach worker of the
conditions where the individual or family was living, a written referral by
another housing or service provider, or a certification by the individual or
head of household seeking assistance.
(2) If the individual qualifies as homeless and is exiting an institution where he or
she resided for 90 days or less, acceptable evidence includes one of the
following:
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(i) Discharge paperwork or a written or oral referral from a social
worker, case manager, or other appropriate official of the institution,
stating the beginning and end dates of the time residing in the
institution. All oral statements must be recorded by the intake worker;
or
(ii) Where the evidence is not obtainable, a written record of the intake
worker's due diligence in attempting to obtain the evidence and a
certification by the individual seeking assistance that states he or she is
exiting or has just exited an institution where he or she resided for 90
days or less.
Fleeing/Attempting to Flee DV:
(1) Acceptable evidence includes an oral statement by the individual or head of
household seeking assistance that they are fleeing that situation, that no
subsequent residence has been identified, and that they lack the resources or
support networks, e.g., family, friends, faith-based or other social networks,
needed to obtain other housing.
2. Disability:
(1) Written verification of the disability from a professional licensed by the state
to diagnose and treat the disability and his or her certification that the
disability is expected to be long-continuing or of indefinite duration and
substantially impedes the individual's ability to live independently;
(2) Written verification from the Social Security Administration;
(3) The receipt of a disability check (e.g., Social Security Disability Insurance
check or Veteran Disability Compensation);
(4) Intake staff-recorded observation of disability that, no later than 45 days of the
application for assistance, is confirmed and accompanied by evidence in
paragraph (c)(1), (2), (3), or (4) of this section; or
(5) Other documentation approved by HUD.
5. Outreach
A. Outreach Policy
HACSL will make its best effort to ensure that eligible hard-to-reach homeless persons are
served by the CoC Program. Focus should be directed toward eligible persons who have a
nighttime residence that is an emergency shelter or a space that is not typically designed as a
regular sleeping accommodation for humans (e.g. persons living in cars, streets, and parks) [24
CFR 582.325]. Ongoing outreach and engagement procedures have been established through
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partner agencies for the purpose of engaging with eligible persons so that they may be brought
into the program.
Per 24 CFR 582.330(c), if HACSL procedures that make known the availability of the program
has a difficult time reaching any persons of a particular race, color, religion, sex, age, national
origin, familial status, or handicap, HACSL will establish additional procedures that will ensure
interested persons can obtain information concerning assistance.
B. Outreach Procedures
HACSL will work with partnering agencies to provide outreach to perspective participants
and to those least likely to apply without regard to race, color, national origin, sex, religion,
familial status and disability.
HACSL staff will make presentations about the CoC Program at relevant venues (e.g.
Continuum of Care meetings) and upon request.
HACSL Staff will provide regular informational trainings about CoC eligibility criteria and
application process to partner agency outreach workers and mobile outreach teams.
6. Referral
Service provider agencies that have been recognized as a referring agency and have signed a
Service Provider MOU with HACSL may refer potential participants to the CoC Program.
“Self” referrals are not permitted
.
Current participating agencies include:
The Road Home (TRH)/ Salt Lake County Triage Group
Volunteers of America (VOA)
Valley Mental Health (VMH)
Wasatch Homeless Health Care
First Step House
Family Promise Salt Lake
The referring agency must agree to provide supportive services to the potential participant and
execute a Service Provider Agreement with each participant for whom they are serving as the
case management agency. Referring agencies must be willing and able to meet the HUD cost
match and leverage requirements.
Referrals are accepted at any time that the CoC waiting list is open.
When referrals are being accepted, providers may refer a potential participant to the program by
completing and submitting the following documents to HACSL:
Online Application Submission
Referral Form
o Supportive Housing Referral Form
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o Copy of identification for all adults
o Copy of Social Security Numbers for all households members
o Income Verification (copy of benefit letter, check stubs, employer verification,
etc.)
o Homeless Verification Form
o Disability Verification Form
o Case Management commitment letter or Case Manager and Participant
Agreement Forms
o Criminal Background Check Consent Form
o Release of information
CoC Program Application
o Certification Form
o HUD Authorization for Release of Information
o HMIS Informed Consent
o Interagency Release of Information
o Sex Offender Verification
o Employment Verification
o Income Inquiry or Zero Income
o Asset Questionnaire
o Declaration of U.S. Citizenship
o Program Responsibilities
o Termination of Assistance
o Screening Policy/Termination Form (Attention Applicants)
7. Waiting List
A. Waiting List Opening
A Supportive Housing Specialist maintains a separate waiting list for each of the CoC Programs.
An applicant may be placed on one or more waitlists depending on eligibility criteria. Due to the
relatively slow turn-over of CoC subsidies, the waiting lists can become fairly large.
B. Waiting List Order
HACSL staff will screen all applications to make a preliminary determination of eligibility.
Waiting list order is determined on a first come, first serve basis. However, for all programs
HACSL may determine priority for those whose need is greater .The Kelly Benson and Grace
Mary Manor programs are designed to serve those with the most severe and persistent mental,
physical, and substance abuse-related disorders who are in the highest need. HACSL has
discretion to make these individuals a priority. Through consultation with the referring agencies
and their case managers, considerations such as length of homelessness, vulnerability, and other
factors are taken into account to make a priority determination.
When an applicant comes to the top of the waiting list, his or her case manager will be contacted
and sent an application packet. It is the responsibility of the referring agency to contact the client,
verify that the client is still available for housing and ensure that the packet is completed and
turned in.
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All CoC applicants who come on the CoC program will also be placed on the Section 8 and
Public Housing waiting lists as availability permits. This allows additional spots to open up for
CoC applicants when clients transition to Section 8 and Public Housing programs.
When a Continuum of Care participant is offered a Section 8 or Public Housing Voucher, a
determination will be made as to whether or not the client is prepared to move to a voucher
without case management. This decision will be made through a collaborative process involving
the case manager and HACSL staff but will ultimately be decided by the client.
C. Waiting List Maintenance
An annual wait list update will take place wherein HACSL staff will attempt to contact
applicants and case managers to determine their continued interest in and eligibility for the CoC
Program. Applicants will be removed from the list if:
HACSL fails to contact the applicant after three attempts to reach the applicant directly or
through a contact organization (e.g. emergency shelter provider, case manager, etc.).
The applicant or case manager indicates he or she is no longer interested in or available for
the program.
The applicant indicates that he or she now has permanent housing or is otherwise ineligible
for the program.
Because of the nature of homelessness and lack of permanent address, HACSL may choose to
suspend an applicant’s removal from the wait list. Based on recommendation of the referring
agency, a person may maintain a place on the wait list if it is expected that they may be contacted
in the future. In such a case, vouchers will be awarded to the next eligible applicant.
HACSL staff will send letters or emails to partners with every client correspondence.
Documentation of these correspondences will be placed in the file or tracked in system notes.
8. Application Process and Verification of Eligibility
A. Application Packet
Once an applicant comes to the top of the waiting list, the HACSL’s Housing or Eligibility
Specialist will contact the applicant and his or her case manager to gather the information needed
to make a final determination of eligibility. The Eligibility Specialist will mail the applicant and
case manager a packet containing the following documents:
o Certification Form
o HUD Authorization for Release of Information
o HMIS Informed Consent
o Interagency Release of Information
o Sex Offender Verification
o Employment Verification
o Income Inquiry or Zero Income
o Asset Questionnaire
o Declaration of U.S. Citizenship
o Program Responsibilities
o Termination of Assistance
o Screening Policy/Termination Form (Attention Applicants)
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The participant and case manager will have 14 days to complete and return all the documents
along with:
Third-Party Verification of Income:
For government assistance: a printout or letter from government assistance program (e.g.
GA, SSI, unemployment, etc.) less than 60 days old
For earned income: two pay stubs or a letter from the employer specifying hourly wage
and monthly earnings
For zero income: a signed “affidavit of zero income.”
If there are additional adults in the household (over age 18), they must provide:
CoC Application Supplement for Adults
Criminal Background Check Consent Form
Release of Information
Verification of Income
Picture ID
Social Security Card
Copy of birth certificate
If there are children in the household (under 18), they must provide:
CoC Application Supplement for Children
Copy of Birth Certificate or Medicaid card
Social Security Card
B. Eligibility Determination
Additional eligibility determination information can be found in section II including definitions
of homelessness and disability.
Once all the documents have been returned, the Eligibility Specialist will review the packet for
completeness and make a determination of eligibility based on the following factors:
Signed Verification of Homelessness/Disability Form plus supporting information:
For persons living on the streets: signed statement from outreach worker, other
organization, or participant attesting to applicant’s homeless status
For persons living in emergency shelters: signed statement from shelter provider attesting
that applicant is residing there
For persons exiting transitional housing: signed statement from transitional housing
provider attesting that applicant is residing there and was homeless upon entry
For persons leaving an institution following short-term stay (90 days or less): signed
statement from institution verifying residence of less than 90 days and attesting that
applicant was homeless at time of entry.
For chronically homeless persons: one of the above documents to verify current status
and duration of homelessness, plus, if applicable, a signed statement from the applicant
attesting to past homeless episodes.
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Verification of Disability Form signed by a qualified health care professional trained to make
such a determination. Case managers are not qualified to sign the verification unless they are
a qualified health care professional.
Verification of income eligibility. Applicant’s annual income as documented by government
assistance program printouts and/or pay stubs must not exceed 50% of AMI.
Signed Service Provider Agreement between participant and eligible service provider or
Case Management and Participant agreements.
Based on the review of the application packet, the Eligibility Specialist will make one of the
following determinations:
1. File is complete and applicant is eligible. The Eligibility Specialist will schedule an
application meeting (see below).
2. File is incomplete. If eligibility cannot be determined or there is missing information, the
Eligibility Specialist will notify the applicant and case manager that additional information is
needed. If the requested information is not supplied within 14 days, the applicant will be
determined ineligible.
3. Applicant is ineligible. The application will be denied and the reasons given in writing to the
applicant and case manager. The applicant may appeal the denial of eligibility by the process
described in Section 23.
C. Orientation/Coupon Issuance Meeting
Once an applicant has been determined eligible for the CoC Program, a Eligibility Specialist will
schedule an orientation meeting and will send a confirmation letter to the applicant’s case
management agency informing them of the appointment date and time. The Housing or
Eligibility Specialist will also verbally notify the applicant’s case management agency regarding
the appointment date and time.
At the application meeting, a Housing or Eligibility Specialist will:
Review the CoC policies and program requirements, including participant obligations
Review the CoC program goals
Explain the process for securing a housing unit
Review and have the applicant sign:
CoC Housing Coupon/Voucher
Hand out and review the
Tenant/Landlord Packet
Landlord Packet
Payment Standard/Fair Market Rate Sheet
Participating Landlord List
D. Fair Housing and Reasonable Accommodation [24 CFR 582.330]
Nondiscrimination and equal opportunity requirements.
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(a) General. Recipients may establish a preference as part of their admissions procedures for one
or more of the statutorily targeted populations ( i.e., seriously mentally ill, alcohol or substance
abusers, or persons with AIDS and related diseases). However, other eligible disabled homeless
persons must be considered for housing designed for the target population unless the recipient
can demonstrate that there is sufficient demand by the target population for the units, and other
eligible disabled homeless persons would not benefit from the primary supportive services
provided.
(b) Compliance with requirements. (1) In addition to the nondiscrimination and equal
opportunity requirements set forth in 24 CFR part 5, recipients serving a designated population
of homeless persons must, within the designated population, comply with the prohibitions
against discrimination against handicapped individuals under section 503 of the Rehabilitation
Act of 1973 (29 U.S.C. 794) and implementing regulations at 41 CFR chapter 60–741.
(2) The nondiscrimination and equal opportunity requirements set forth at part 5 of this title are
modified as follows:
(i) The Indian Civil Rights Act (25 U.S.C. 1301 et seq. ) applies to tribes when they exercise
their powers of self-government, and to IHAs when established by the exercise of such powers.
When an IHA is established under State law, the applicability of the Indian Civil Rights Act will
be determined on a case-by-case basis. Projects subject to the Indian Civil Rights Act must be
developed and operated in compliance with its provisions and all implementing HUD
requirements, instead of title VI and the Fair Housing Act and their implementing regulations.
(ii) [Reserved]
(c) Affirmative outreach. (1) If the procedures that the recipient intends to use to make known the
availability of the program are unlikely to reach persons of any particular race, color, religion,
sex, age, national origin, familial status, or handicap who may qualify for assistance, the
recipient must establish additional procedures that will ensure that interested persons can obtain
information concerning the assistance.
(2) The recipient must adopt procedures to make available information on the existence and
locations of facilities and services that are accessible to persons with a handicap and maintain
evidence of implementation of the procedures.
(d) The accessibility requirements, reasonable modification, and accommodation requirements of
the Fair Housing Act and of section 504 of the Rehabilitation Act of 1973, as amended.
A. Fair Housing Policy
It is HACSL policy to comply fully with all Federal, State and local nondiscrimination laws and
with the rules and regulations governing Fair Housing and Equal Opportunity in housing and
employment.
HACSL shall not deny any family or individual the opportunity to apply for or receive assistance
under the Continuum of Care program on the basis of race, color, sex, religion, creed, national or
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ethnic origin, age, familial or marital status, handicap or disability.
B. Reasonable Accommodation Policy
It is the HACSL’s policy to provide “reasonable accommodation” for CoC participants who are
individuals with a disability, where reasonable accommodation is necessary to provide
participants with an equal opportunity to use and enjoy the Departments’ programs and facilities.
This policy is in furtherance of the Department’s goal of providing rental assistance to low
income persons regardless of disability and said policy is in compliance with applicable federal,
state, and local law. A “reasonable accommodation” is a modification or change HACSL can
make to its procedures and rules which would assist an otherwise eligible person with a disability
to benefit from the Department’s programs, provided that the change does not pose an undue
financial and administrative burden to the Department or result in a fundamental alteration of its
program.
The availability of reasonable accommodations will be made known by including notices on
HACSL forms and letters to all participants. These notices shall explain the process whereby a
participant may request an accommodation. All requests will be verified so that the HACSL can
properly accommodate the need presented by the disability.
HACSL is also committed to assuring that all of its programs, services, and activities are
accessible to all persons with disabilities, as well as the facility locations where the programs are
housed, and to remove any barriers that would prohibit participation.
III. SECURING A HOUSING UNIT
9. Occupancy Standards
The PHA must establish subsidy standards that determine the number of bedrooms needed for
families of different sizes and compositions. This part presents the policies that will be used to
determine the family unit size (also known as the voucher size) a particular family should receive,
and the policies that govern making exceptions to those standards. The PHA also must establish
policies related to the issuance of the coupon/voucher, to the voucher term, and to any extensions or
suspensions of that term.
For each family, the HACSL determines the appropriate number of bedrooms under the HACSL
subsidy standards and enters the family unit size on the coupon/voucher that is issued to the family.
The family unit size does not dictate the size of unit the family must actually lease, nor does it
determine who within a household will share a bedroom/sleeping room.
The following requirements apply when the Housing Authority of the County of Salt Lake
determines family unit size:
• The subsidy standards must provide for the smallest number of bedrooms needed to house a
family without overcrowding.
• The subsidy standards must be consistent with space requirements under the housing quality
standards.
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• The subsidy standards must be applied consistently for all, families of like size and
composition.
• A child who is temporarily away from the home because of placement in foster care is
considered a member of the family in determining the family unit size.
• A family that consists of a pregnant woman (with no other persons) must be treated as a
two- person family.
• Any live-in aide must be counted in determining the family unit size;
• Unless a live-in-aide resides with a family, the family unit size for any family consisting of
a single person must be either a zero- or one-bedroom unit, as determined under the subsidy
standards.
The Housing Authority of the County of Salt Lake will assign one bedroom for each two persons
within the household, except in the following circumstances:
Persons of the opposite sex (other than spouses, and children under age 5 will be
allocated separate bedrooms.
Live-in aides will be allocated a separate bedroom. No additional bedrooms will
be provided for the live-in aide’s family.
Single person families will be allocated a zero or one bedroom.
Foster children will be included in determining unit size.
Two children of the same sex will be allocated one room regardless of age.
Current CoC Housing Participants
Children of the opposite sex, both under the age of five (5), will share a
bedroom. Family will be eligible for a larger bedroom voucher, at the next
annual re-certification following older child’s fifth birthday.
Single pregnant women are eligible for a one bedroom voucher.
A single parent expecting an additional child will be eligible for a larger
voucher at the next annual re-certification, following the child’s second
birthday if:
- family size exceeds two children per bedroom, or
- if there are no additional children under the age of ten that the
child can share a room with, regardless of sex
A couple expecting a child is eligible for a two bedroom voucher at the next
annual re-certification
Live in Aid Live-in aide means a person who resides with one or more elderly persons, or
near-elderly persons, or persons with disabilities, and who: (1) is determined
to be essential to the care and well-being of the persons, (2) is not obligated
for the support of the persons, and (3) would not be living in the unit except
to provide the necessary supportive services [24 CFR 5.403].
The Housing Authority of the County of Salt Lake must approve a live-in
aide if needed as a reasonable accommodation in accordance with 24 CFR 8,
to make the program accessible to and usable by the family member with
disabilities.
A live-in aide is a member of the household, not the family, and the income
of the aide is not considered in income calculations [24 CFR 5.609(b)].
Relatives may be approved as live-in aides if they meet all of the criteria
defining a live-in aide. However, a relative who serves as a live-in aide is not
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considered a family member and would not be considered a remaining
member of a tenant family.
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A family’s request for a live-in aide must be made in writing. Written
verification will be required from a reliable, knowledgeable professional,
such as a doctor, social worker, or case worker, that the live-in aide is
essential for the care and well-being of the elderly, near-elderly, or disabled
family member.
In addition, the family and live-in aide will be required to submit a
certification stating that the live-in aide is (1) not obligated for the support of
the person(s) needing the care, and (2) would not be living in the unit except
to provide the necessary supportive services.
The Housing Authority of the County of Salt Lake will not approve a
particular person as a live-
in aide, and may withdraw such approval if [24 CFR 982.3 16(b)]:
The person commits fraud, bribery or any other corrupt or criminal act in
connection with any federal housing program;
The person commits drug-related criminal activity or violent criminal
activity; or
The person currently owes rent or other amounts to the Housing Authority of
the County of Salt Lake or to another PHA in connection with Section 8 or
public housing assistance under the 1937 Act.
Within 10 business days of receiving a request for a live-in aide, including all
required documentation related to the request, the Housing Authority of the
County of Salt Lake will notify the family of its decision in writing.
10. Housing Search/Housing Placement
TRA Program
A. Housing Coupon/Voucher
HACSL will issue each participating household a Housing Coupon/Voucher that is valid for 60
days from the date it is issued (usually the date of the Application Meeting). Participants must
locate a suitable unit within the 60-day term of the Certificate. If an applicant does not locate a
unit within the 60-day term, the applicant may request up to 2 additional 30-day extensions. The
second extension must be approved by the Supportive Housing Manager.
B. Housing Search Process
Participants may search for a unit anywhere in Salt Lake County unless Housing Specialists
determine that a participant shall move in a specific structure or specific area in order to facilitate
the coordination of supportive services [24CFR 582.100(a)].
All applicants receive a copy of a current “Landlord List” at the Orientation Meeting. This list is
merely a compilation of landlords HACSL is aware of that participate in our programs and is not
comprehensive. It is the responsibility of the Case Management Agency to assist the participant
in locating housing. If an applicant is having difficulty finding a housing unit, the Housing
Specialists are available to assess their housing search strategy and make any suggestions or
provide assistance with available units.
Landlords are legally obligated to screen CoC applicants in the same way as non-CoC applicants.
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C. Request for (Tenant)Unit Approval
Once an applicant locates a suitable unit, he or she will work with the landlord to complete the
Request for Tenant/Unit Approval (RFTA). The RFTA must be turned in to the CoC Program
before the applicant’s Coupon/Voucher expires.
A Housing Specialist will review the RFTA for completeness and accuracy. If the form is not
complete, the Housing Specialist will contact the applicant and/or the case manager to obtain the
needed information.
SRA and PRA Programs
D. Unit Selection Policy
HACSL and its partnering agencies have units available at various housing sites for certain SRA
and PRA Grants. When more than one appropriately-sized unit is available, the participant may
choose from among available units. The participant does not, however, have the option of
rejecting all available units and returning to the waiting list until another unit becomes available.
The participant must choose one of the available units or be terminated from the program.
If only one appropriately-sized unit is available at the time the participant is admitted into the
CoC program, he or she must take that unit or be terminated from the program.
11. Housing Unit Inspection
All housing units are inspected by a HACSL Certified Housing Inspector. The inspection must
take place before the applicant moves into the unit and must meet HUD’s Housing Quality
Standards (HQS) prior to move in [24CFR 582.305(a)]. The HACSL Housing Inspector will
complete a Housing Inspection Worksheet at the time of the inspection. The Housing Inspection
Worksheet is based upon the Housing Quality Standards.
At the time of the inspection, the utilities must be turned on so that they can be verified. The
utilities do not need to be established under the participant’s name until the unit passes
inspection.
If the Housing Inspector determines that a unit does not meet HQS, the landlord will have the
option to resolve the deficiencies within 10 business days. The Housing Specialist will provide
the landlord with a written list of items to be repaired or improved. The Housing Specialist will
deny the Request for Unit Approval if:
the deficiencies are not resolved within 10 business days
the landlord chooses not to resolve the deficiencies
the participant chooses not to rent the unit
If a unit fails the HQS inspection, the participant may continue the housing search for the time
remaining in the 60 day search period.
12. Allowable Rents
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In accordance with 24 CFR 582.305(b), HUD will only provide assistance for a unit for which
the rent is reasonable. HACSL will determine whether a rent is reasonable by comparing the
rent being charged for the unit receiving rental assistance to rents being charged for comparable,
unassisted units. The comparison also takes into account the location, size, type, quality,
amenities, facilities and management and maintenance of each unit, as well as not in excess of
rents currently being charged by the same owner for comparable unassisted units. This
comparison is documented using the Rent Reasonableness Form.
13. Rent Calculations
Upon completion of the inspection and receipt of the completed Land Lord/Tenant packets, the
Housing Specialist will determine the tenant’s portion of the rent and the utility allowance using
the Participant Rent Calculation spreadsheet.
Participant rent shall be the highest of:
$50 minimum rent
30 percent of monthly adjusted income
10 percent of monthly gross income; or
If receiving payments for welfare assistance from a public agency and a part of such
payments, adjusted in accordance with actual housing costs, is specifically designated by
such agency to meet housing costs, the portion of such payments which is so designated.
The income of a HACSL-approved Live-In Aide shall not be included for the purpose of
calculating the participant’s rent.
The Housing Specialist will then complete the Rent Calculation Worksheet, which documents
the contract rent for the unit, the tenant’s portion and the CoC subsidy.
14. Hardship Waiver [24 CFR 5.630]
HACSL must grant an exemption from the minimum rent if a family is unable to pay the
minimum rent because of financial hardship. The financial hardship exemption applies only to
families required to pay the minimum rent. If a family’s TTP is higher than the minimum rent,
the family is not eligible for a hardship exemption. If HACSL determines that a hardship exists,
the family share is the highest of the remaining components of the family’s calculated TTP.
The following qualify for a Hardship Waiver
1: When the family has lost eligibility for or is awaiting an eligibility determination for a
Federal, State, or local assistance program, including a family that includes a member
who is a noncitizen lawfully admitted for permanent residence under the Immigration and
Nationality Act who would be entitled to public benefits but for title IV of the Personal
Responsibility and Work Opportunity Act of 1996;
2: When the family would be evicted because it is unable to pay the minimum rent;
3: When the income of the family has decreased because of changed circumstances,
including loss of employment;
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4: When a death has occurred in the family; and
5: Other circumstances determined by the responsible entity or HUD.
A) If a family requests a financial hardship exemption, HACSL must suspend the minimum rent
requirement beginning the month following the family's request for a hardship exemption, and
continuing until the PHA determines whether there is a qualifying financial hardship and
whether it is temporary or long term.
(B) HACSL must promptly determine whether a qualifying hardship exists and whether it is
temporary or long term.
(C) HACSL may not evict the family for nonpayment of minimum rent during the 30-day period
beginning the month following the family's request for a hardship exemption.
Verifications for hardship include but are not limited to:
- A letter from Social Security indicating the client is in the application process
- A letter from Social Security indicating that the client has been denied assistance and
is in the appeal process.
- If none of the above verifications are available: a letter from the client and/or
referring or partner agency case manager detailing the hardship
15. Leasing Process
Participants must enter into a lease agreement of at least one month and it must be automatically
renewable upon expiration, except on prior notice by either party [24CFR582.315(a)].
Occupancy agreements may include a provision requiring the participant to take part in
supportive services provided through the program as a condition of continued occupancy
[24CFR582.315(b)].
Both the lease and contract must be executed and on file before any check may be issued to the
landlord. Once the Lease and HAP contact have been completed and signed by all parties, and
the inspection has been completed, the Housing Specialist will add the participant to the HACSL
tracking systems Elite and HMIS Client Track. Rental assistance checks or direct deposits will
be processed according to HACSL procedures.
If the tenant moves into the unit in the middle of the month, the landlord will receive a rent
payment beginning the date of occupancy not the beginning of the month.
16. Security Deposits [24 CFR 578.49].
Program Uses CoC Funds for Security Deposits
The landlord has the right to require any security deposit. However, HACSL may use CoC funds
to cover security deposits not to exceed two month’s contract rent. This deposit assistance will be
available only for initial move-in. Participants who transfer to a new unit will be required to pay
27
the entire security deposit (unless they have not previously received deposit assistance from
HACSL or if they are forced to move due to reasons beyond their control).
To recieve this assistance, the requested security deposit must be listed in the lease. HACSL will
pay the deposit directly to the landlord along with the initial rental assistance payment.
IV. ONGOING PROGRAM PARTICIPATION
17. Participant Obligations
By signing the CoC Program Agreement, the participant agrees to comply with the following
obligations:
The participant shall:
1. Supply such certification, release of information, and documentation as HACSL or HUD
determine to be necessary, including submissions required for an annual or interim
reexamination of Family income and composition.
2. Allow HACSL or referring/partner agency staff to inspect the dwelling unit at renewal
and as deemed necessary with reasonable notice.
3. Use the dwelling unit solely for residence by the participant’s family, and as the family’s
principal place of residence; and not assign the Lease or transfer the unit.
4. Keep the unit clean inside and out.
5. Pay the participant’s portion of rent on or before the day of the month established in the
lease.
The participant shall not:
6. Move from the unit within the initial lease term, or without landlord approval.
7. Own or have any interest in the dwelling unit. If the Owner is a cooperative, the
participant may be a member.
8. Commit any fraud in connection with the CoC Program.
9. Receive assistance under the CoC Program while occupying, or receiving assistance for
occupancy of, any other unit assisted under any Federal Housing assistance program.
The participant must:
10. Continue to use case management services as needed.
11. Immediately submit verification for all changes in income or family status within 10 days
to the CoC program.
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13. Not allow any additional family members to move into the CoC subsidized unit without
prior approval from the case manager and CoC staff.
14. Be responsible for any damage to the unit during the participant’s residency.
15. Notify HACSL in writing no less than 30 days before moving from a CoC subsidized
unit.
16. Not use the CoC subsidized unit for any illegal drug-related activities. The participant
and any members of the participant’s family or guests will not engage in drug-related
criminal activity or any criminal activity. Drug -related activities include the felonious
manufacture, sale, or distribution or the possession with intent to manufacture, sell or
distribute a controlled substance.
18. Support Services
A. Service Participation Requirements
Per 24 CFR 582.110, recipients of grants for rental assistance must provide or ensure the
provision of supportive services. This includes funding these services itself if these services do
not become available for any reason. The supportive services may be newly created or already
in operation and they may be provided or funded by federal, state, local, and private programs.
Only services provided after the execution of the grant agreement may be counted towards the
match.
Services Are Not Mandatory
As a condition of referring a household for housing assistance, the referring agency must:
Provide an identified case manager from a participating service provider agency
Participate in case management services by meeting at least once per month with their
current clients
Work with the client to develop an individualized case plan designed to assist the participant
to gain housing stability, increase skills and/or income, and increase self-determination; and
B. Services Provided
HACSL must assure that adequate supportive services are available to participants in the
program [24 CFR 582.300(c)]. All CoC participants will have access to the supportive services
they need to assist them to remain housed, increase their skills and/or income; and increase their
self-sufficiency. HACSL must conduct an ongoing assessment of the housing assistance and
supportive services required by participants, and make adjustments as appropriate [24
CFR582.300(b)].
These services may include:
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Case management
Life skills or independent living skills training
Mental health services
Alcohol and/or drug services
Primary health services
HIV/AIDS-related services
Education
Employment and training
Child care
Transportation assistance
Legal assistance
Benefits advocacy
Housing search assistance
Other services as needed
C. Responsibilities of Service Provider Agencies
Each CoC participant must have a case manager from a participating CoC Provider Agency.
Participating service providers must sign the CoC Service Provider Memorandum of
Understanding (MOU) and must be approved by HUD. Under the terms of this agreement, the
provider must:
1. Assist clients to complete the referral and initial application process, as well as the annual
recertification requirements.
2. Assist clients in their housing search to find a unit where they can use their CoC certificate.
3. Provide the property manager of the client’s unit with contact information so that the case
manager can be informed in the event that concerns or problems arise.
4. Provide ongoing case management and service coordination, including regular home visits
(at least once monthly) for as long as the client is receiving rental assistance through the CoC
Program.
5. Develop an individualized service plan that includes the CoC goals contained in the Case
Manager and Participant agreement forms.
6. Intervene in the event that a client’s behavior is jeopardizing their housing, or if critical
concerns arise regarding their health or safety.
7. Notify the CoC Program if there are changes in staffing such that the client’s case manager
changes.
8. Notify the CoC Program in a timely manner when a client is at risk of being discharged from
the provider’s services due to non-participation or program violations. Whenever possible,
prior to discharging the client from services, the Provider will follow due process, including
informing the client that discharge from services may result in the termination of their CoC
rental subsidy, and offering the client the opportunity to appeal the discharge in accordance
with the Provider’s policies.
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9. If the Provider determines that a client no longer requires intensive services and plans to
discharge the client, the Provider will develop a discharge plan in consultation with the CoC
program to assure that the client remains connected with adequate supportive services while
continuing to receive a CoC subsidy.
10. Identify a staff member to act as liaison with the Continuum of Care Program, who can assist
in coordination with the CoC Program and attend quarterly meetings with the program.
11. Maintain up-to-date client files in HMIS Client Track documenting client contact and
provision of services, and all related documents and records to assure proper accounting of
services and performance.
13. Submit service match reports to the CoC Program on a yearly basis, documenting service
utilization and value of services provided as necessary for the CoC Program to continue to
qualify for HUD funding.
D. Service Match
HUD requires that HACSL obtain a 25% service match of total CoC award amount provided by
the grant. Additionally, leverage dollars must equal 150% of the CoC total award amount. The
Supportive Housing Manager shall obtain documentation of service match and leverage from
participating providers at least annually.
19. Annual Recertifications
A. Tracking Recertification Dates
In accordance with HUD requirements, on an annual basis the Housing Specialist will reexamine
the income and household composition of all participants, work with HACSL inspectors to
ensure the participant’s housing unit passes an HQS inspection, and make necessary adjustments
to the tenant rent [24 CFR 582.310(b)(2)].
The Housing Specialist will use the monthly re-certification report from the Elite System to keep
track of the renewal dates for each participant. 90 days prior to the re-certification due date, the
Housing Specialist will contact the participant, and the participant’s case manager to inform
them of the upcoming renewal and housing inspection. In the event that the participant does not
complete the re-certification within 60 days of notification, the landlord will be notified that rent
may be placed on hold until completion of the re-certification.
B. Documents Required from Participant and Case Manager
The Housing Specialist will send the participant and case manager a notice of the required
annual re-certification along with forms to be completed. The partner agency case manager is
responsible to work with the participant to complete this packet and return it to the Program
Specialist within the specified time frame. The forms include:
Certification Form
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HUD Authorization for Release of Information
HACSL Authorization for Release of Information
HMIS Informed Consent
Interagency Release of Information
Notification for Lead Based Paint
Sex Offender Verification
Employment Verification
Income Inquiry or Zero Income
Asset Questionnaire
Program Responsibilities
Termination of Assistance
Screening Policy/Termination Form (Attention Applicants)
If the participant or case manager does not respond within 30 days, the Housing Specialist will
send another letter and packet of forms, requiring a response within 10 business days and notify
the case manager. If the participant does not respond within the stated period of time, HACSL
will send out another letter and packet of forms, requiring response within 10 business days. If
no response if made within that stated period of time, HACSL will initiate probationary action.
In accordance with 24 CFR 582.310(b)(3), as a condition of participation in the program, each
participant must agree to supply the information or documentation necessary to verify the
participant’s income. Also, participants must provide the recipient information at any time their
income or circumstances changes that may result in changes to the participant’s rental payment.
C. Inspection and Rent Adjustment
While the Housing Specialist works on obtaining all the necessary documents from the
participant, HACSL inspectors will schedule a home inspection. The participant’s landlord will
receive a letter, and a copy of the Housing Inspection Checklist. The annual housing inspection
will be conducted in accordance with the procedure described in Section 11. The inspection will
follow the same guidelines (Housing Quality Standards) that were used prior to move in.
If the landlord requests a rent increase, the Housing Specialist will complete a Rent
Reasonableness Form to determine whether the new rent is reasonable and if it falls within the
FMR payment standard. If the participant reports a change in income, the Housing Specialist
will perform a revised rent calculation.
If there is a change in contract rent and/or tenant income, the Housing Specialist will notify the
participant and landlord in writing. If the landlord’s rent increase is denied because it is not
reasonable, or does not fit within the FMR payment standard, the letter will also explain the basis
for the denial.
If the landlord or participant wishes to enter into another lease, a new lease and contract will be
generated and signed. If the landlord does not require the participant to hold a lease, the
participant’s housing shall revert to a “month –to-month” basis and no new lease shall be signed.
The landlord may choose to sign a new lease and contract, but it is not required.
20. INTERIM CHANGES
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A. Income Changes
HUD regulations require that a participant’s portion of the rent be adjusted any time there is a
change in income. Per 24 CFR 582.310(b)(2), HACSL must examine a participant’s income
initially, and at least annually thereafter, to determine the participant’s portion of rent.
Adjustments to participant’s rental payment must be made as necessary.
Participants are required to notify the Housing Specialist when there is a change in income and
participants must supply the information or documentation necessary to verify their income
within 10 business days of the change [24 CFR 582.310(b)(3)]. When an income change is
reported, the Housing Specialist will recalculate the tenant’s portion of the rent and will notify
both the participant and landlord. The adjusted rent will be effective 30 days beyond the end of
the month that it was reported.
B. Changes in Family Composition
Participants are required to notify HACSL of any proposed change in household composition.
The Housing Specialist will review all requests and notify the participant in writing of the
determination. The following policies will apply:
No family members will be approved to be added to the family composition within the
first 12 month of participation, with exceptions made only for birth of a child or
reunification with a child in foster care.
After the initial 12 month period, only family members or live-in aides may be added to
the household. The definition of family may be found in Section 4.
21. TRANSFERS
A. Transfer Policy
CoC participants may move with continued assistance to another unit within Salt Lake County.
The CoC program does not allow for moves with continued assistance outside of Salt Lake
County.
Restrictions on moves:
Participants may not break a lease in order to move. If the participant wishes to break
a lease he or she must obtain permission from their landlord.
Participants may not move if they are not complying with CoC program obligations.
B. Transfer Process
A participant must contact their assigned Housing Specialist to request approval to move. If the
move is approved, the participant will then give the landlord written 30-day notice of their move
out date or longer notice if the participant’s lease requires. The landlord must sign the 30 day
notice to indicate that the tenant is in good standing.
When the participant locates a new unit, he or she must submit a new Request for Tenant/Unit
Approval. The RFTA and will be processed and the lease-up managed in accordance with the
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policies and procedures set forth in Section 11 through 15.
C. Transferring Between Grants
During the course of their participation in the CoC program, the source of a participant’s housing
assistance may change. This transfer from one funding source to another may or may not be
associated with a physical move. The policies governing grant transfers and intra-program
transfers are detailed below.
1. Transfers at the Request of Support Service Provider
A transfer from TRA to a PRA or SRA may be requested in situations where:
A participant is experiencing difficulty in complying with the terms of the lease and;
The case manager or other support service provider believes the participant would be
more successful in a project based or sponsor-based unit where a non-profit
organization is the landlord.
A transfer from PRA or SRA to TRA may be requested in situations where:
A participant has had a stable tenancy in an SRA or PRA unit and wishes to increase
his or her self-sufficiency by moving to a unit owned by a private landlord; and
The case manager or other support service provider supports the participant’s move to
a TRA unit.
The case manager must make the request for transfer in writing, stating the reasons for the
request. HACSL will grant the request on the condition a subsidy of the type requested is
available and that the change is warranted.
2. Transfers by the HACSL
HACSL may elect to transfer participants from one grant component type to another if HACSL
determines such transfer is necessary for grants management reasons, (e.g. to increase or
decrease spending rates in a given grant.) HACSL will notify the participant and case manager
in writing of the change in grant assignment. Such transfers do not involve a physical move by
the participant.
HACSL shall document the date of the transfer and the reason for the transfer in the participant’s
file.
22. Vacancies
Per 24 CRF 582.105(d), the CoC program may not pay rent on a vacant unit for longer than 30
days, unless the participant has entered an in-treatment program. If a participant vacates the unit
for a period of less than 30 days for any reason other than to enter residential treatment, the CoC
Program will continue to pay the rent. At the end of the 30 days, if the participant has not
returned, the CoC Program Specialist will send written notice to the landlord to terminate the
rental subsidy for the unit.
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The assistance for the unit may continue for a maximum of 30 days from the end of the month in
which the unit was vacated, unless occupied by another eligible person. No additional assistance
will be paid until the unit is occupied by another eligible person.
If a participant being housed through CoC enters a residential treatment program or other forms
of inpatient care, they have the option to retain their unit for up to 90 days while they complete
the program. HACSL will pay the rent for the 90 day period that the unit is vacant.
If the participant will be in residential treatment for longer than 90 days (or if they enter a 90-day
program, but prefer to give up their unit), he or she must give a 30 day notice to the landlord, and
the rental subsidy will be terminated. The participant can then qualify for another CoC
certificate upon completion of the program.
V. ENDING PROGRAM PARTICIPATION
23. Termination of Housing Assistance/Eviction [24 CFR 582.320]
(a) Termination of assistance. The recipient may terminate assistance to a participant who
violates program requirements or conditions of occupancy. Recipients must exercise judgment
and examine all extenuating circumstances in determining when violations are serious enough to
warrant termination, so that a participant's assistance is terminated only in the most severe cases.
Recipients are not prohibited from resuming assistance to a participant whose assistance has
been terminated.
(b) Due process. In terminating assistance to a participant, the recipient must provide a formal
process that recognizes the rights of individuals receiving assistance to due process of law. This
process, at a minimum, must consist of:
(1) Written notice to the participant containing a clear statement of the reasons for termination;
(2) A review of the decision, in which the participant is given the opportunity to present written
or oral objections before a person other than the person (or a subordinate of that person) who
made or approved the termination decision; and
(3) Prompt written notice of the final decision to the participant.
Partner case managers must be included in all correspondence that deals with terminations.
A. Termination by Participant
The participant may elect to leave the CoC Program at any time and may do so by informing
their case manager, who will then inform HACSL and the landlord. Participants who are
currently receiving rental assistance must provide their landlord with a 30 day notice (or longer
according to their lease) prior to vacating a unit.
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If the tenant provides the required notice, HACSL will pay the rent up to end of the 30 day
period, unless the landlord rents the unit to another tenant during that period. If the participant
vacates the unit without notice, the CoC Program will pay the rent for a maximum of 30 days
following the day the participant left the unit.
B. Termination by CoC Program (HACSL)
The Continuum of Care Program is designed to serve disabled people who are homeless and
have had poor access to housing and support services. In order to reach this disadvantaged and
hard-to-reach homeless population, sensitivity, flexibility, and respect for the participant’s past
experiences is critical. Behavior that might be grounds for dismissal in more traditional
programs may not be appropriate grounds for dismissal from Continuum of Care.
1. Grounds for Termination
a. Assistance may be terminated or a participant may be put on probation if the participant
violates program requirements or conditions of occupancy [24 CFR 582.320(a)]. Examples
of program violations are:
1. Repeated complaints from the landlord due to violations of the lease agreement, such as
disturbing the quiet enjoyment of the neighbors, allowing unauthorized persons to visit or
live in the unit, property damage, repeated failure of HQS inspections, or non-payment of
rent
2. Violent or threatening behavior, or other behavior that seriously threatens the health and
safety of the community
3. Illegal activities, including illicit drug-related activities
4. Vacating the unit without notice for more than 30 consecutive days.
b. The CoC Program shall exercise judgment in determining when violations are serious enough
to warrant probation or termination. The program will do as much as possible to ensure the
adequacy of support services so that a participant’s assistance is terminated only in the most
severe cases [24 CFR 582.320(a)]. Whenever possible the program will give participants
written warning prior to termination so that they have an opportunity to take appropriate
action to resolve the problems and thus continue their participation in the program.
c. HACSL will not terminate a participant’s assistance simply because the landlord or service
provider feels the participant is “difficult.” In requesting that HACSL initiate termination
procedures, the landlord must demonstrate that the participant has committed repeated and
serious violations of the lease. The service provider may request that a participant be
terminated due to lack of participation in services, but only if the service provider can
demonstrate that the refusal to participate is the underlying cause of repeated and serious
lease violations.
d. Extremely serious program violations (including violent behavior, drug sales, or other
criminal behavior) will result in proceeding immediately to termination proceedings. In all
other cases, the participant will first be placed on probation. (See below)
2. Roles and Responsibilities of Parties in Termination Process
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There are four parties that have roles and responsibilities relating to a participant’s participation
in the CoC program and any decisions regarding termination of the participant’s CoC assistance:
HACSL: As grantee for the CoC funds, HACSL is ultimately responsible for determining
whether a participant continues to receive CoC assistance and for termination of assistance in
cases where it is warranted. HACSL will, in all cases, consult extensively with the other
parties (i.e. the referring partner case manager) prior to terminating a participant from the
program. In the event that agreement cannot be reached with all parties, the HACSL’s
decision will prevail.
Landlord: as sponsor for the program and landlord for the assisted units, the landlord will
advise HACSL as to whether a participant should be placed on probation or terminated from
the program for repeated, serious lease violations. In the event that HACSL elects not to
terminate program participation and/or the participant refuses to leave the unit following
termination of assistance, the landlord may terminate tenancy by undertaking an eviction
procedure in accordance with state and local law (see Section C, below). In the event that the
participant is evicted but HACSL chooses not to terminate participation in CoC, HACSL
may assist the participant in locating a new unit.
Service Provider: the service provider will advise the HACSL as to whether a participant
should be placed on probation or terminated from the program for failure to participate in
needed services. In the event that HACSL elects not to terminate CoC program participation,
the service provider may terminate the participant from support services by following their
established termination process. HACSL may assist the participant in locating a new service
provider.
Participant: throughout the probation and termination process, the participant has a right to be
treated respectfully, fairly and to be afforded due process under the law.
3. Termination Process
Termination is a formal process that recognizes the rights of individuals receiving assistance to
due process of law. The termination process is as follows:
Step One: Informal Resolution. The Housing Specialist and/or the partner case manager
will meet informally with the participant to address the problem. Both the Housing
Specialist and the partner case manager should document in the client file these efforts to
resolve the problem informally. In the case of serious criminal or violent acts HACSL may
proceed to termination procedures of the client.
Step Two: Written Warning. If the behavior cannot be corrected informally, the Housing
Specialist will send the participant written notice specifying the reasons his or her
participation in the program may be in jeopardy, and that if the issues are not resolved, the
next step may be terminate their housing assistance. Copies of the letter will be sent to the
partner case manager.
If the participant disagrees with the warning notice, s/he may request an informal conference
with the CoC Program Manager, and the Housing Specialist to review the matter.
Step 3: Written Notice of Termination. If the participant does not fulfill the terms of the
written warning, the CoC Program Manager shall either proceed with a termination, or
postpone the termination for up to 30 days if the participant has demonstrated a willingness
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to address the problems and has partially corrected the issue. If the matter proceeds to
termination, the CoC Program Manager shall notify the participant in writing that he or she is
being terminated from the program. The notice must contain a clear statement of the
reason(s) for termination.
The written notice of termination must also contain a statement that the participant has a right
to an Informal Hearing for a review of the decision, in which the participant is given the
opportunity to present written or oral objections and may be represented by a third party
advocate. To request an Informal Hearing, the participant must do so in writing within ten
(10) days of the date of the termination letter. A participant who fails to request an informal
hearing waives this right, and the decision to terminate them from the program becomes
final.
Once the participant receives a Notice of Termination, HACSL will send the landlord a 30-
day Notice of Termination and will place a hold on the account, effective the last day of the
30 day period.
If the participant requests a hearing within the allotted time period, HACSL will remove the
hold on the account and will pay for the unit for the month throughout the hearing process.
Procedures for the Informal Hearing are described in Section 24.
Step 4: Informal Hearing. If the participant requests an informal hearing, the hearing
committee must schedule an Informal Hearing within ten (10) working days of receipt of the
request. The Informal Hearing shall be a meeting between the participant, the Housing
Specialist, and the Hearing Committee. Additional groups of people may also attend as
deemed necessary by the participant including legal representation, family supports, relevant
witnesses or character references, and/or the partner agency case manager.
The Hearing Committee is comprised of 2 or more HACSL employees who are unrelated to
the decision for termination and can assess the situation objectively. The Hearing Committee
will make its decision based on the Continuum of Care HUD regulations as well as HACSL’s
own policies and procedures.
The hearing committee shall issue prompt written notification of the decision to the
participant within 10 business days, including a clear statement of the reason(s) for the
decision. The finding of the Hearing Committee is final and may not be further appealed.
HACSL will also be responsible to pay it’s potion of rent to the Landlord for the month the
hearing proceedings take place.
Step 5: Termination. Once the decision to terminate the participant from the program
becomes final, the Housing Specialist shall terminate the CoC assistance by issuing a 30-day
Notice to Terminate to the participant and to the landlord, with a copy to the case manager.
The case manager shall assist the landlord in obtaining the participant's voluntary agreement
to move out of the unit. If the tenant has not moved out at the end of the 30-day notice
period, the landlord may evict the tenant through the legal eviction process. HACSL will
continue to pay rent during the thirty day notice period, unless another tenant moves into the
unit prior to the end of the 30 days.
4. Returning to the CoC Program Following Termination
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After termination, the participant may be given the opportunity to continue with the support
services provided through his or her existing service provider or another agency. By showing
responsibility, motivation, and readiness the participant may become eligible for reinstatement
into the program .In order to qualify for reinstatement, at a minimum the participant must have
continued to participate in services at the partner agency, and resolved any outstanding financial
liabilities associated with the program. If HACSL and the service provider determine that the
participant qualifies for reinstatement, she or he will be placed at the bottom of the CoC waiting
list. Once the participant reaches the top of the waiting list, his or her eligibility for the program
must be verified prior to re-admission.
C. Termination of Tenancy by Landlord
All CoC program participants have the same tenancy rights as any tenant in the State of Utah. If
the landlord decides to evict a tenant in a CoC subsidized unit, they must follow the legal
requirements governing the eviction of tenants under Utah law, as well as any applicable local
laws governing the landlord-tenant relationship.
As noted above, a decision by the landlord to evict the participant from his or her unit does not
necessarily mean that the participant will be terminated from the CoC program. Depending on
the circumstances, HACSL may elect to continue CoC program participation and offer the
participant alternative housing and/or services.
24. Participant Appeals/Grievance Procedures
A. Informal Grievance Process
Participants who have a complaint or problem relating to their participation in the CoC Program
may communicate their grievance to the CoC Program by completing a Grievance Form and
submitting it to the Supportive Housing Manager. The Manager will meet with the participant
and any other relevant parties to discuss the issue and will gather any relevant information
needed to make a decision. The Manager’s decision will be communicated in writing to the
participant and cannot be appealed.
The informal grievance process is not applicable for participants who are being terminated from
the program. Participants who have received a termination notice may request an Informal
Hearing (see above).
Participants may not submit a grievance request for the following types of actions or decisions:
General policy issues
Actions by HACSL which are required under CoC regulations (e.g. limiting security deposit
amounts to a maximum of one month’s rent).
Supportive Services as participation is mandatory.
B. Informal Hearing
As discussed in Section 21, participants who have received a written termination notice may
request an informal hearing within 10 working days of receiving the termination letter. The
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informal hearing will be a meeting between the participant, the Housing Specialist, the Hearing
Committee and any other relevant parties (e.g. the landlord).
1. Hearing Notification
The hearing shall be scheduled within 10 calendar days. The notification of hearing will contain:
The date and time of the hearing
The location where the hearing will be held
An explanation of the participant’s rights at the hearing
2. Rights of the Parties
Prior to the hearing, the participant has the right to:
View any documents or evidence in the possession of the CoC Program on which HACSL
bases the action and to obtain a copy of such documents prior to the hearing.
Copy any relevant documents at their expense;
Request that CoC staff or staff from other organizations be available or present at the hearing
to answer question pertinent to the case
At the hearing, the participant has the right to:
Be represented by legal counsel, advocate, or other designated representative at his or her
own expense.
Present written or oral objections to HACSL’s determination.
Present any information or witnesses pertinent to the issue of the hearing;
Prior to the hearing, HACSL has the right to:
View and obtain copies of documents or evidence which the participant intends to present at
the hearing.
If the participant request copies of documents relevant to the hearing, CoC staff will make copies
and assess a charge of $.25 per copy. The participant will not be allowed to remove the file from
the CoC office.
At the hearing, the participant may be represented by a third party advocate. The hearing allows
the participant and/or the advocate:
The opportunity to hear the reasons for the termination and to review any supporting
documentation or other evidence
The opportunity to make a written or oral presentation of the participant’s reasons why he or
she should not be terminated
The opportunity to rebut any information presented by HACSL or other parties
3. Rescheduling Hearings
After a hearing date is agreed upon, the participant may request to reschedule only upon showing
“good cause,” which is defined as an unavoidable conflict which seriously affects the health,
safety or welfare of the participant. A maximum of one re-scheduling request will be allowed.
If the tenant does not attend the second re-scheduled hearing, a finding will be made in favor of
HACSL.
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If the participant does not appear at a scheduled hearing and had not rescheduled the hearing in
advance, the participant must contact the CoC Program within 48 hours, excluding weekends and
holidays. HACSL will reschedule the hearing only if the participant can show good cause for the
failure to appear. As noted above, only one re-scheduling request is allowed.
4. Hearing Procedures
The Administrative Hearing shall be conducted by the Hearing Officers appointed by HACSL
who is neither the person who made or approved the decision. The CoC program utilizes
HACSL hearing officers.
The hearing shall concern only the issues for which the participant has received the opportunity
for hearing. Evidence presented at the hearing may be considered without regard to admissibility
under the rules of evidence applicable to judicial proceedings.
No documents may be presented which have not been provided to the other party before the
hearing if requested by the other party. “Documents” includes records and regulations.
The Hearing Officer will determine whether the action, inaction or decision of HACSL is legal in
accordance with HUD regulations and HACSL’s own policies and procedures based upon the
evidence and testimony provided at the hearing. Factual determinations relating to the individual
circumstances of the participant will be based on a preponderance of the evidence presented at
the hearing.
The finding of the Hearing Committee is final and may not be further appealed.
HACSL is not bound by hearing decisions:
Which conflict with or contradict HUD regulations or requirements;
Which conflict with or contradict Federal, State, or local laws; or
Which exceeds the authority of the person conducting the hearing.
5. Notice of Hearing Finding
A notice of Hearing Finding shall be provided in writing to CoC staff and the participant within
10 business days and shall include:
A clear summary of the decision and reasons for the decision;
If the decision involves money owed, the amount owed; and
Further instructions as needed
All requests for a hearing, supporting documentation, and a copy of the final decision will be
retained in the participant’s file.
At the hearing, the participant may be represented by a third party advocate. The hearing allows
the participant and/or the advocate:
The opportunity to hear the reasons for the termination and to review any supporting
documentation or other evidence
The opportunity to make a written or oral presentation of the participant’s reasons why he or
41
she should not be terminated
The opportunity to rebut any information presented by HACSL or other parties
The Hearing Committee shall have 10 business days following the hearing to submit a response
in writing to the participant, partner case manager, and CoC staff, clearly stating the reasons for
the decision. The finding of the Hearing Committee is final and may not be further appealed.
VI. ADMINISTRATION
25. Data Management
582.110(c) Calculating the value of supportive services. In calculating the amount of the
matching supportive services, applicants may count:
(1) Salaries paid to staff of the recipient to provide supportive services to CoC participants;
(2) The value of supportive services provided by other persons or organizations to CoC
participants;
(3) The value of time and services contributed by volunteers at the rate of $10.00 an hour, except
for donated professional services which may be counted at the customary charge for the service
provided (professional services are services ordinarily performed by donors for payment, such as
the services of health professionals, that are equivalent to the services they provide in their
occupations);
(4) The value of any lease on a building used for the provision of supportive services, provided
the value included in the match is no more than the prorated share used for the program; and
(5) The cost of outreach activities, as described in §582.325(a).
Per 24 CFR 300(d), HACSL must keep any records and make any reports that HUD requires.
HACSL must develop and make available a description of the procedures used to select sponsors
under the SRA component and buildings under the SRA, and PRA components. HACSL must
also develop, and make available to the public upon request, its procedures for managing the
rental housing assistance funds provided by HUD.
A. Participant Files
1. Applicant Files
HACSL’s Eligibility Specialist is responsible for setting up and maintaining a file for each CoC
applicant. The file shall be created at the time HACSL receives a Referral Form from a
participating support service agency and shall be updated throughout the application and
eligibility verification process.
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Each file shall contain:
Supportive Housing Eligibility Checklist
All Referral Forms listed in Section 6
All documents relating to the eligibility determination (e.g. homeless/disability verification
form, income verification etc.)
Complete applicant files will be handled as follows:
For applicants who are determined to be ineligible, a notice will be sent to the referring
agency case manager and the file will be placed in an archived files box.
For applicants who are determined to be eligible, the contents of the file shall be placed in a
pending file cabinet.
2. Participant Files
The Housing Specialist is responsible for maintaining and storing a file for each CoC participant
once the eligibility process is completed and the coupon/voucher has been issued.
Each file shall contain:
Checklist/Audit Form
Applicable Application Forms listed in Section 6
Each file shall be organized as follows:
Left Side: Eligibility Checklist, Eligibility Documentation and Identifications
Ride Side: Audit Form, income verifications, rental adjustment statements, application forms,
landlord and unit information, leases, coupons, annual recertification and interim information
and any correspondence on the right side.
Files are audited by another Housing Specialist and the Supportive Housing Manager before
activation into the program to verify that correct procedures have been implemented and
followed.
The file shall be continuously updated throughout the participant’s tenure in the CoC Program.
When a participant leaves the program, the folder shall be placed in an archived files box with
the exit date listed on the file.
B. HMIS System
The Homeless Management Information System (HMIS), is a computerized data collection
application that facilitates the collection of information on homeless individuals and families
using residential or other homeless assistance service agencies, and stores that data in a
centralized database for analysis. HACSL is one of many organizations that participate in the
HMIS.
HACLS will comply with all HMIS Requirements.
The Supportive Housing Manager will work with the UHMIS Technical Assistance Department
to gain access to and remove access from the HMIS system. Access will be requested only for
Housing Specialists and Case Managers who provide direct services to participating clients, the
43
appropriate department managers, and the grant writer. New employees will attend the required
HMIS training and sign the End User Agreement before they are given access to the HMIS
System. Employees will also be required to attend HMIS meetings and training as needed.
Revocation to HMIS access will be immediately requested for terminated employees.
HACSL and all employees with access to the system will be held to the policies and procedures
established by UHMIS as follows:
HMIS PARTICIPATION
Must have an Agency Partner Agreement (Appendix) and End-User Agreements
(Appendix ) signed before an agency can receive training to ultimately participate in
UHMIS.
CLIENT INFORMED CONSENT AND PRIVACY RIGHTS
• Participating Agencies will need to display the Privacy Posting in clear sight of clients
that are being served.
• If an agency is collecting more than the Universal Data Elements for one or more of
their programs then they will need to have the client sign an Informed Consent Release
Form and have it in the client’s file.
• Agencies will be required to provide a client with a Grievance Filing Form if the client
feels that the security or integrity of their information has been violated by the end-user
or agency itself.
DATA POLICIES AND PROCEDURES
Agencies that wish to share client information with other agencies to better facilitate
program management must have a Data Sharing MOU (Appendix) in place before the
UHMIS team will grant access to information outside of the originating agency.
HACSL privacy policies signed by all employees will also apply.
Data on CoC participants is entered into the HMIS system at the following times:
When a participant first enters the program
When a participants moves with continued assistance
When a participant has a re-examination
When a participant reports changes in household or income
When a participant exits the program
Assessments:
All entry, follow-up and exit assessments must be completed by HACSL staff. Partner agencies
should not enter any entry, follow-up or exit assessments.
C. Service Match Documentation
Under HUD regulations, HACSL is required to match each dollar of housing assistance with a
dollar of in-kind support services [24CFR582.110(c)]. A list of matching supportive services
applicants may count may be found in 24CFR582.110(c).
Service match is documented using the following forms of documentation:
44
Service match log. On a yearly basis, every service provider agency that works with CoC
clients is required to submit a tracking log documenting the total of all services provided on a
year-to-date basis for all clients on that program.
Mental health and health services computer printout. Services provided by Volunteers of
America (VOA), The Road Home (TRH), Valley Mental Health (VMH), Wasatch Homeless
Healthcare, First Step House and Family Promise of Salt Lake are documented using a
printout from those agencies’ databases. Printouts must include a total listing of all services
received and the value of those services. Inpatient acute hospital care is not eligible to count
as support service match. The CoC Program Manager will review the printout to ensure that
none of the services listed are inpatient acute hospital care. If any such services are listed, the
CoC Program Manager will manually delete them from the printout (by crossing out the
information) and remove the value of those services from the total value of services
provided.
D. Participant File Quality Control
The Supportive Housing Manager is responsible for ensuring quality control of all data in the
participant files.
The Supportive Housing Manager will conduct random file audits ensure:
All required documents have been completed and signed
The eligibility requirements have been met and have been properly documented
That all required HMIS data entry forms have been completed and entered into the HMIS
system.
Additional financial quality control procedures are described in Section 27.
26. Reporting
HUD requires HACSL to submit an Annual Progress Report for the CoC program on an annual
basis. The report is due 90 days after the end of the program operating year.
The CoC Housing Specialist is responsible for compiling the APR using data from the following
sources:
HMIS system (for data on participant demographics, income changes, and services received)
Service match documentation (for calculation of service match)
Participant case records (for tracking of participant outcomes)
The Supportive Housing Manager shall review the APR (including relevant backup
documentation) on a quarterly basis and prior to submitting the report to HUD, to ensure its
accuracy.
27. FINANCIAL MANAGEMENT
§ 582.105 Rental assistance amounts and payments.
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Rental payments may be used in the following situations:
Vacancies – If a participant vacates the unit before the expiration of the occupancy
agreement, assistance may continue for a maximum of 30 days from the end of the month
in which the unit was vacated unless the unit is occupied by another eligible person. This
does not include participants who are in brief periods of inpatient care, which is not to
exceed 90 days for each occurrence.
Administrative costs – [24 CFR 578.59]
HACSL may use up to 10 percent of any grant awarded for Administrative Costs
Eligible administrative costs include:
Eligible administrative activities include processing rental payments to landlords,
examining participant income and family composition, providing housing information
and assistance, inspecting units for compliance with housing quality standards, and
receiving into the program new participants. This administrative allowance does not
include the cost of administering supportive services or the grant ( e.g., costs of preparing
the application, reports or audits required by HUD), which are not eligible activities
under a CoC grant.
A. Roles and Responsibilities
As grantee for the CoC funds, HACSL is responsible for financial management. This
responsibility is divided between two groups: the CoC Program staff (Supportive Housing
Manager and CoC Housing Specialists) and the Accounting Department (Accounting Manager
and Accounting Clerks). The roles of each group in relation to financial management are:
CoC Program Staff:
Collect and verify information on applicant’s income, document contract rent for applicant’s
housing unit
Calculate and document participant’s rental portion and CoC subsidy amount.
Accounting Department
Review CoC subsidy calculations performed by CoC program staff
Issue rental assistance checks to landlords
Track and document grant administration expenses
Draw down CoC funds from HUD
Produce monthly financial reports documenting actual versus budgeted income and expenses.
B. Rental Assistance Payments
HACSL’s Accounting Department is responsible for issuing rental assistance payments to
landlords (including payments for security deposits)
C. Administrative Costs
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HACSL’s Accounting Manager will record in the general ledger all eligible actual administrative
expenses for the CoC Program based on information from staff time sheets, plus any non-
personnel related administrative expenses (e.g. cost of vehicles).
In accordance with HUD regulations, the following activities are eligible as administrative costs:
Receiving new participants into the program;
Providing housing information and search assistance;
Determining participant income and rent contributions;
Inspecting units for compliance with Housing Quality Standards and
Processing rental payments to landlords.
These activities are ineligible as administrative costs:
Administering the grant;
Preparing reports to HUD; and
Costs associated with conducting audits of the grant.
The Accounting Clerk will use the monthly financial report (see below) to track the
administrative costs and to ensure that they do not exceed 10% of the total grant.
D. HUD Draws
On a monthly basis the Accounting Clerk will use HUD’s eLOCCS system to draw down CoC
funds to reimburse HACSL for its eligible expenditures. The following procedure will be
followed:
The Accounting Clerk will generate a General Ledger report documenting all expenditures
for the period, including both administrative costs and rent payments.
The Accounting Clerk will check the General Ledger report against the CoC Rental
Assistance Report and Participant Log to ensure it is accurate
The Accounting Clerk will complete a LOCCS voucher, attaching a copy of the General
Ledger Report, CoC Rental Assistance Report, Participant Log and Rental Assistance
Worksheets.
The Accounting Manager and Director of Housing will review and sign the voucher (HUD
regulations require two signatures)
The Accounting Manager will call in the voucher using HUD’s electronic LOCCS system.
E. Financial Reports
On a monthly basis the Accounting Clerk will run a CoC Financial Report using the general
ledger module of the accounting system. This report will document actual income and expenses
for the current month, prior months, and “year to date” totals for the term of the grant. This
report will also show the total number of units under lease at the end of each month of the grant
term. The Accounting Clerk will distribute this report to the CoC Program Manager.
28. GRANT ADMINISTRATION
A. Tracking Grant Income and Expenditures
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As noted above, the Accounting Clerk will provide the Supportive Housing Manager
with a monthly CoC Financial Report showing a month-by-month breakdown of
expenses and number of units assisted in each month. The purpose of this report is to
provide a tool that the Director and Program Manager can use to monitor grant
expenditures and make the adjustments necessary to ensure that the maximum
number of clients are served without going over budget.
B. Analyzing and Responding to Grant Utilization Data
The Supportive Housing Manager is responsible for monitoring grant utilization and making
needed program adjustments. On a monthly basis, the Manager reviews the CoC Financial
Report prepared by the Accounting Manager, assesses the lease-up rate, and projects whether the
grant will be overspent or underspent at the end of the grant term. If there is a possibility of
under spending, the CoC Program Manager will inform the service provider agencies that
referrals are being accepted for new clients. If the summary report indicates that there is a
possibility of overspending the grant, the Manager will recommend that no new clients are
admitted into the program until the spending rate is reduced to the desired level.
C. Grant Extensions and Renewals
The Grant Writer in connection with the Supportive Housing Manager is responsible for
submitting an annual request for renewal of the CoC grant as part of the Salt Lake Continuum of
Care process by completing the required applications and processes. Since CoC grants with one-
year renewal terms may not be extended, HACSL will make its best effort to expend all grant
funds before the end of the 12-month grant term. As per HUD requirements, the deadline for
drawing down grant funds is 90 days from the end of the grant term (for expenses incurred
during the grant term). Unexpended funds will be returned to HUD.
D. Grant Amendments
Any significant grant changes require written HUD approval [24 CFR 582.405]. HACSL will
submit a written request to HUD and obtain a written grant amendment for any major changes,
such as changing the target population for the grant. As per HUD regulations, HACSL is not
permitted to change units from one CoC program component to another (e.g. changing TRA
units to SRA units).
E. Obligation and De-Obligation of Funds
When HUD and the applicant execute a grant agreement, HUD will obligate the funds to cover
the approved grant. The recipient is expected to carry out the proposed activities in the
application. However, if the recipient does not carry out the proposed activities or if the grant
amount is not used in a timely manner, HUD may de-obligate all or a portion of the funds.
Appendix:
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DISCLOSURE OF CONFLICT OF INTEREST
HOUSING AUTHORITY OF THE COUNTY OF SALT LAKE
The Employee Handbook of the Housing Authority states that an employee or board member having a financial interest in any property or project of the agency must disclose this information to the agency Director/Board and be given the opportunity to disclose all material facts. (See Employee Handbook, Part Four, Section 11, Conflict of Interest.) The purpose of this policy is to protect the interests of the Housing Authority, to deal forthrightly and quickly with conflicts of interest, and to assure our employees that we are complying with the highest standards of behavior in regard to the financial and programmatic activities of the agency. This statement must be filed with the Human Resources department
a) at a new employee’s orientation; b) annually by all employees and members of the Board of Commissioners; c) prior to any transaction between the Housing Authority and the private business or
person; or, d) in any meeting of the Housing Authority where the transaction is discussed.
If you have any questions about this policy, or about potential conflicts of interest please contact Human Resources Describe below the nature of the assistance you are providing to the private business or person or describing the nature of the economic interest you hold in the private business. Also, describe the relationship with or transaction between the business and the Housing Authority. (Use back or attach a separate sheet if necessary.) I have no private business or economic interests that have a relationship or transactions
with the Housing Authority of the County of Salt Lake. Please print name Employee Signature Date
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CONFIDENTIALITY ACKNOWLEDGMENT
I shall respect the privacy concerns of the people we serve, and the employees of the Housing
Authority. I shall hold in confidence all information obtained in the course of professional
service, whether the information is obtained through written records or daily interaction with the
person. Therefore, I will not disclose an individual’s confidences to anyone, except (1) as
mandated by law, (2) to prevent a clear and immediate danger to a person or persons, (3) where I
am compelled to do so by a court or pursuant to the rules of a court.
I shall store or dispose of professional records in ways that maintain confidentiality.
I shall possess a professional attitude and behavior that upholds confidentiality toward the people
we serve, applicants, employees, and any sensitive situations arising within the Housing
Authority.
I, upon my termination, shall maintain client and employee confidentiality and I shall hold
confidential any information about sensitive situations within the Housing Authority.
I understand that violation of this confidentiality statement is grounds for immediate dismissal.
Employee Signature:
Date:
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CODE OF CONDUCT
We aspire to the highest standard of conduct. The Housing Authority of the County of Salt Lake expects the following from volunteers, Board of Commissioners and Staff: honesty, respect for individuals, and a commitment to professional and compassionate service. To this end, I pledge to do my best to achieve the following: I will be conscious of the fact that everything I do, directly or indirectly, has the potential to reflect on HACSL as a whole. I will conduct myself at all times with openness, forthrightness, and honesty in dealing with people and organizations, both internally and externally. I will hold myself to the highest possible standards of conduct reflective of the work that I do, striving always to avoid even the appearance of impropriety. I will treat everyone with dignity, worth, respect, concern, courtesy and fairness. I will respect and comply with all applicable laws, regulations and procedures. I will strive to do my best at all times. I will seek education and training when needed. I will exercise prudent stewardship of all HACSL resources. I will avoid all conflict of interest in relationships with board members, staff, vendors, clients and other organizations with whom I deal, unless disclosed and approved. I will not act in my official capacity in any matter in which I have a personal interest that would impair my judgment. I will accept no gifts or favors, which might influence the performance of my responsibilities. I will make statements critical of other staff or agencies only as they are verifiable and constructive of purpose. I will maintain the integrity of private information, I will not seek personal data beyond what is needed to perform work responsibilities, nor reveal information to anyone who does not have the proper professional use for that information. I will maintain professional conduct at all times. This is not a comprehensive list of behaviors, but examples of professional conduct. A high standard of conduct is expected and any violation of the above standards will be subject to disciplinary action up to and including termination of employment /volunteer activities. I have received and read a copy of the above statement.
___________________________ ____________________ Print Name Date
___________________________ Signature
UHMIS END-USER AGREEMENT
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Printed Name Agency
Job Title E-mail/Phone
Identified User Group Program________
SECTION I PURPOSE OF POLICIES & PROCEDURES FOR DATA IN THE UTAH HOMELESS MANAGEMENT
INFORMATION SYSTEM (UHMIS)
The purpose of this agreement is to: 1) ensure that information collected as part of UHMIS will affirm the basic right of clients to have the confidentiality of their information protected; 2) establish directions for the release of confidential information; 3) cite ethical/legal exception to the right of confidentiality; and 4) create procedures to ensure client confidentiality while providing for the exchange of information necessary for continuity of care.
SECTION II USER POLICY, RESPONSIBILITY STATEMENT, & CODE OF ETHICS
User Policy At the discretion of the UHMIS Partner Agency, information for provision of services to homeless persons may be shared through the networked infrastructure that establishes electronic communication among the Partner Agencies.
Partner Agencies shall at all times have rights to the data pertaining to their clients that was created or entered by them in UHMIS. Partner Agencies shall be bound by all restrictions imposed by clients pertaining to the use of personal data. The UHMIS Informed Consent Release Form must be signed in order for identifying information to be shared with Partner Agencies. Partner Agencies bound by HIPAA or 42 CFR Part 2 are expected to develop and administer appropriate consent and Notice of Privacy Practices documentation in compliance with all appropriate State and Federal regulations.
Minimum data entry on each Client shall consist of the Universal Data Elements as defined in the March 2010 HUD Data Standards. This standard is subject to modification by State and Federal policymakers. Data necessary for the development of aggregate reports of homeless services, including services needed, services provided, referrals and Client goals and outcomes should be entered to the greatest extent possible.
The UHMIS is a tool to assist agencies in focusing services and locating alternative resources to help homeless persons. Therefore, agency staff shall only use the Client information in UHMIS to target services to the Client’s needs.
User Responsibility The user ID and password is given to access to the UHMIS statewide. Users will have to initial each item below to indicate they understand and accept the proper use of your User ID and password. Failure to uphold the confidentiality standards set forth below may result in a breach of client confidentiality. By initialing below and by signing this form UHMIS you are agreeing to uphold all confidentiality standards. _______User ID and password are for the user’s use only and must not be shared with anyone.
_______Users take all reasonable means to keep their password physically secure.
_______Users must understand that the only individuals who can view information in UHMIS are authorized users and the clients to whom the information pertains.
_______Users can only view, obtain, disclose, or use the database information that is necessary to perform their job, and which complies with clients’ signed permission to release information.
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_______If a user is logged into the UHMIS and must leave the work area where the computer is located, they must log-off of the software before leaving the work area. Users will not leave a computer unattended that has the HMIS software “open and running”.
_______Users or the agency will keep hard copies of appropriate UHMIS information/documentation in a secure place. All client information will be kept secure by ensuring that all hard copies of client forms are locked and secure when unattended. When hard copies of the UHMIS information are no longer needed they will be archived for up to seven years. Beyond that, hard copies of the records must be properly destroyed to maintain confidentiality.
_______If a user notices or suspects a security breach; they must immediately notify the Agency Administrator for UHMIS or the System Administrator.
_______Users will not knowingly enter false or misleading client information into HMIS under any circumstances.
_______Users will ensure that they are making the best effort to collect any and all necessary back up documentation for client level information.
User Code of Ethics A. UHMIS Users must treat partner agencies with respect, fairness and good faith.
B. Each UHMIS User should maintain high standards of professional conduct in the capacity as a UHMIS User.
C. The UHMIS User has primary responsibility for his/her client(s).
D. UHMIS Users have the responsibility to relate to the clients of other partner agencies with full professional consideration.
I understand and agree to comply with all the statements listed above. UHMIS User Signature Date Agency Director Date
Version 3-3.2011
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UHMIS Informed Consent Release Form
PLEASE READ THE FOLLOWING STATEMENTS. MAKE SURE YOU HAVE HAD THE CHANCE TO HAVE YOUR QUESTIONS ANSWERED.
__________________________ is part of the Utah Homeless Management Information System (UHMIS).
(Agency Name)
UHMIS is a system that uses computers to collect information about homelessness. The reason for UHMIS is to track funding for homeless programs given by many funders. The goal is to simplify service delivery to people in need.
UHMIS operates over the internet and uses many security protections to keep your information safe. Many service providers across Utah use UHMIS, so your information will be shared with other service providers that provide similar services. Information collected is housed in a secure server located at Data System International (DSI), in Sandy, Utah. DSI employees have access to this server and the data housed there, but only for network support and maintenance purposes. UHMIS staff and approved Utah State Community Services Office (SCSO) staff collect and use only information that is needed for reports on homelessness to help inform policy decisions. Every person with access to this information must sign and comply with all confidentiality agreements.
To better provide services to you in the best way possible is asking your (Agency Name)
permission to share your information with the other approved UHMIS participating agencies in Utah. This will include sharing the following information about you and any dependant minor children with you:
Name, gender, partial SSN, birth date
By signing this form you are letting us share your information, and the information of your dependent children under the age of 18 with other UHMIS participating agencies. This information will be accessible for seven years from the last date of service.
You may cancel this consent at any given time by written request to this agency. The cancellation will not be applied to records already collected from you. If you choose to not give consent, it does not make you ineligible to receive services unless you are applying for the Homeless Prevention and Rapid Re-housing Funding (HPRP or TANF).
Your Rights You have the right to get non-UHMIS, services even if you choose NOT to participate in the
UHMIS.
You have the right to ask who has seen your information.
You have the right to see your information and to change it if it’s not correct. But you must show documentation.
A list of participating agencies is available from your case manager or online at http://hmis.utah.gov. If you don’t want your information shared with a specific agency, please let your case manager or intake worker know. He/she can then take the proper action to honor your request.
SIGNATURE OF CLIENT (AND/OR GUARDIAN) DATE
PRINTED NAME OF CLIENT DOB OF CLIENT
SIGNATURE OF INTAKE WORKER/CASE MANAGER
Version 7.01.2011