disaster recovery rental housing case management program ... · 8/1/2019 · disaster recovery...

COMMUNITY SERVICES DEPARTMENT

HARRIS COUNTY, TX 8410 LANTERN POINT DRIVE, HOUSTON, TX 77054

DISASTER RECOVERY RENTAL HOUSING CASE

MANAGEMENT PROGRAM GUIDELINES

for 2017 Community Development Block Grant – Disaster Recovery (CDBG-DR)

Disaster Recovery Rental Housing Case Management Program Guidelines

Harris County, Texas 2

Table of Contents 1. Overview .................................................................................................................................................... 3

1.1. Background and Purpose ................................................................................................................. 3

1.2. Program Description and Overview .............................................................................................. 6

1.3. Regulations ......................................................................................................................................... 7

2. Program Definitions ................................................................................................................................. 8

2.1. HUD Income Definitions ................................................................................................................ 8

2.2. HUD Homeless Definitions ............................................................................................................ 8

3. DR Rental Housing Case Management ................................................................................................. 9

3.1. Case Loads ......................................................................................................................................... 9

3.2. Participant Eligibility ......................................................................................................................... 9

3.3. Client Assessment ............................................................................................................................. 9

3.4. Client Intake ..................................................................................................................................... 10

3.5. Navigation and Case Management Services ................................................................................ 10

4. Record Keeping ...................................................................................................................................... 13

4.1. Database System .............................................................................................................................. 13

4.2. TIGR ................................................................................................................................................. 13

4.3. HMIS................................................................................................................................................. 13

4.4. Participant Case Notes ................................................................................................................... 14

5. Program Exit ........................................................................................................................................... 14

5.1. Discharge Procedures ..................................................................................................................... 14

6. Complaints and Appeals ........................................................................................................................ 15

6.1. Complaints ....................................................................................................................................... 16

6.2. Appeals ............................................................................................................................................. 16

7. Confidentiality and PII ........................................................................................................................... 17

7.1. Client release of information ......................................................................................................... 17

8. Abuse, Neglect and Exploitation .......................................................................................................... 18

9. Referrals ................................................................................................................................................... 18

10. Staff Training and Competencies ......................................................................................................... 19

11. Contact Information............................................................................................................................... 19

12. Change Log .............................................................................................................................................. 20



Disaster Recovery Rental Housing Case Management Program Guidelines Harris County, Texas

1. Overview

The Harris County Disaster Recovery Rental Housing Case Management Program (DR Rental Housing Case Management Program) is a program under the County’s Community Development Block Grant - Disaster Recovery (CDBG-DR) funding for Affordable Rental Housing. CDBG-DR funding is administered by the Harris County Community Services Department (HCCSD). The DR Rental Housing Case Management Program has been designed to assist households affected by Hurricane Harvey, including homeless populations, seek safe, affordable rental housing and housing stability through case management efforts and housing navigation. Rental assistance will be provided to program participants from community resources administrated by local Housing Authorities.

These guidelines are intended to provide an overview of the DR Rental Housing Case Management Program and information on eligibility, intake, services, partnerships/referrals, client exit, and closeout procedures. CDBG-DR funding for this program is made available by the U.S. Department of Housing and Urban Department (HUD) through the State of Texas General Land Office in response to the presidentially declared Hurricane Harvey disaster event. The primary goal of this program is to preserve and increase affordable housing in Harris County with meeting the requirements set by the CDBG-DR National Objective to benefit low-to-moderate-income persons/households.

1.1. Background and Purpose Hurricane Harvey was the second most costly tropical cyclone impacting the United States. A total of 1 trillion gallons of water fell across Harris County over the 4-day period. Harvey produced the most devastating house flooding ever recorded in Harris County. Based on a house flooding assessment report by the Harris County Flood Control District (HCFCD), about 70 percent of Harris County was flooded by at least 1.5 feet of water, with an estimated 154,180 flooded homes. Of those flooded homes, 64 percent did not have a flood insurance policy in effect.

In the Harris County Disaster Recovery (DR) Service Area that includes the unincorporated county and 33 small cities (outside city of Houston) within the county, 160,695 households registered with FEMA and were determined as valid applicants by FEMA. These registrants had a combined FEMA Verified Loss (FVL) of $566,569,381.64. FEMA paid out $416,901,867.43 in assistance to DR Service area registrants. However, this has left an unmet need of over $2.35 billion for housing.

The U.S. Department of Housing and Urban Development (HUD) has allocated $5.024 billion in Community Development Block Grant Disaster Recovery (CDBG-DR) funds to the state of Texas in response to Hurricane Harvey, DR-4332, through the publication of the Federal



Register, Vol. 83, No. 28, Friday, February 9, 2018. This allocation was made available through the Continuing Appropriations Act, 2018 and Supplemental Appropriations for Disaster Relief Act, 2017 that allocated $7.4 billion in CDBG-DR funds in response to major disasters declared in 2017.

In their Action Plan submitted to HUD on May 8, 2018, the State of Texas, under their program administrator the Texas General Land Office (GLO) and at HUD’s direction, made a direct allocation of $1,115,386,830 in CDBG-DR funding to Harris County. Thus, Harris County developed the Supplemental Action Plan for 2017 CDBG-DR funding which was approved by Harris County Commissioners Court on July 10, 2018. Subsequently, Harris County’s Supplemental Action Plan was incorporated into the State of Texas Action Plan as Amendment #1 and was approved by HUD.

One of the programs listed under the County’s allocation is for affordable rental housing, which includes the building of rental housing units and the provision of case management services to assist county residents to find affordable rental units and achieve housing stabilization post Hurricane Harvey. This guideline discusses the case management services that will be provided by Harris County. Processes for the building of affordable rental units are discussed in a separate set of guidelines.

1.1.1. Organization Information Harris County Community Services Department (HCCSD) is a department under the Harris County governmental structure and is subject to the laws and regulations of a county government under Texas Governance Code. As the administrators of the county’s HUD Entitlement and Disaster Recovery funding, HCCSD is also governed by Federal laws that are associated with HUD funding.

HCCSD’s main office is located at 8410 Lantern Point Drive, Houston, Texas 77054. Office hours are 8am to 5pm Monday to Friday (except for holidays as determined by Commissioners Court).

1.1.2. Organizational History Harris County has provided public assistance since the Great Depression by way of assisting those in need with unemployment relief and financial assistance programs. Due to the demand for assistance, Harris County Commissioner’s Court created the Harris County Department of Welfare in 1957, to specifically address the needs of decent burials, transportation, and distribution of commodities. The Department of Welfare has evolved into the Harris County Community Services Department (HCCSD) with an expanded mission to promote economic growth, revitalize blighted and underdeveloped areas, provide decent housing and living environment for low-to-moderate income individuals, the disabled, and the homeless.

1.1.3. HCCSD Organizational Structure and Services The HCCSD office is focused on addressing the housing, infrastructure and public service needs of the low to moderate income community in Harris County. This is accomplished through a process of securing and managing grants from the U.S. Office of Housing and Urban Development (HUD) and partnerships with other government and non-profit agencies, resulting in a variety of programs, projects and services.



HCCSD has three main program divisions: Programs and Services, Disaster Recovery, and Financial Administration.

The Programs and Services Division The Programs and Services Division includes the Office of Housing & Community Development; Office of Transit Services; and the Office of Social Services. This division provides planning and grant administration for the county HUD Entitlement grants as well as direct services to the public such as transit, human services including homeless services, housing assistance, and community resource connections.

As discussed in the Organizational History section, HCCSD has a long history of providing public assistance and case management services to the residents of Harris County. Today, the HCCSD Office of Social Services administers two programs that provide direct services to strengthen the community through empowerment of the County’s most vulnerable populations: (1) Emergency Utility Assistance and (2) Case Management Services.

Emergency Utility Assistance Emergency utility assistance is available when clients are faced with a utility termination notice. Referrals are made to clients with needs beyond the scope and resources of this office to other service providers who can address additional needs.

Case Management Services The Office of Social Services provides case management to low-income families, disabled adults, and homeless households to aid them in attaining greater self-sufficiency and secure safe affordable housing. The goal is to provide services that afford the highest level of personal independence through effective use of resources. Case Management can also assist Harris County residents who require emergency assistance for vacate/eviction notice.

The Office of Social Services strives to meet its mission: To strengthen the community, protect the vulnerable and empower the able by providing intense comprehensive case management services and direct financial assistance to eligible clients. In addition to providing direct services, Social Services advocates on behalf of clients to ensure that Harris County residents receive a continuum of services which will aid in achieving self-sufficiency and stability.

To meet the needs of those affected by Hurricane Harvey, the principals and staffing model of the Office of Social Services will be utilized in the development of the Disaster Recovery Division’s Rental Housing Case Management Service Program.

The Financial Administration Division The Financial Administration Division is tasked with the financial monitoring and oversight of the HCCSD county funds and grant funds.

Disaster Recovery Division HCCSD created the Harris County Disaster Recovery Division to manage the disaster recovery programs outlined in Harris County’s Action Plan utilizing HUD disaster recovery funding provided after a presidentially declared disaster. The programs to be managed by the Disaster Recovery Division include:

• Residential Buyout Program

• Commercial Buyout Program



• Homeowner Assistance Program

• Homeowner Reimbursement Program

• Affordable Housing Preservation Program

• Single Family New Construction

• Affordable Rental Housing Program o Disaster Recovery Rental Housing Case Management Program (Under Affordable

Rental Housing Program funding)

• Disaster Recovery Infrastructure Improvements

Disaster Recovery Affordable Rental Housing Program As noted in the Overview section, in its local action plan, HCCSD created a program for renter populations. The Affordable Rental Housing Program has been designed to provide funds for acquisition, rehabilitation, reconstruction, and new construction of affordable multi-family housing projects in areas impacted by Hurricane Harvey, as well as a case management services program for Hurricane Harvey affected renter households, including homeless populations. The DR Rental Housing Case Management Program will assist those individuals and households, affected by Hurricane Harvey, to seek safe, affordable rental housing and to aid in their housing stability through quality case management and housing navigation.

1.1.3.3.1. Disaster Recovery Rental Housing Case Management Program The DR Rental Housing Case Management Program will be administered and staffed by HCCSD.

1.1.3.3.1.1. Housing & Community Resource Center The Harris County Housing & Community Resource Center (HCRC) offers a customized online search for the best affordable housing available for those facing homelessness or eviction. Additional community resources such as emergency shelter, employment, health screenings, transportation, food, clothing are also provided. The HCRC is a resource for the DR Rental Housing Case Management Program and its clients for emergency and mainstream community resources and programs.

For those county residents wishing to check out these services themselves, go to https://housingandcommunityresources.net/. For direct, customized support from a qualified Resource Navigator, call (832) 927-4955.

1.2. Program Description and Overview

1.2.1. Partnership with Coalition for the Homeless The Coalition for the Homeless (Coalition) is the lead agency in the region for the Continuum of Care (CoC). During Hurricane Harvey the Coalition was a primary resource for those individuals and household in emergency shelters in the County. The Coalition staff embedded into the shelters and began evaluating survivors of Hurricane Harvey to find housing using their assessment system. This system is still in place evaluating those affected by Hurricane Harvey.

HCCSD will participate in the coordinated access system. The system consists of an electronic assessment system housed in the Homeless Management Information System (HMIS) and a dedicated Project Manager through the Coalition. Coordinated access uses a common housing assessment to ensure that all individuals are referred to the appropriate housing intervention, including the DR Rental Case Management Program.

https://housingandcommunityresources.net/



1.2.2. Partnership with Houston Housing Authority The Houston Housing Authority (HHA) provides affordable homes and services to more than 58,000 low-income Houstonians, including over 17,000 families housed through the Housing Choice Voucher Program and another 5,700 living in 25 public housing and tax credit developments around the city of Houston. HHA also administers the nation's third largest voucher program exclusively serving homeless veterans.

The Houston Housing Authority will utilize and administer the housing coupons for the DR Rental Housing Case Management Program. These housing coupons will be funded through community resources.

HCCSD will coordinate with the Houston Housing Authority in finding affordable rental units for the families needing housing who are referred by The Coalition for the Homeless and Harris County Housing & Community Resource Center (HCRC).

1.3. Regulations

1.3.1. Community Development Block Grant Disaster Recovery (CDBG-DR) Community Development Block Grant Disaster Recovery is a federal grant funding source appropriated by the US Congress to assist those communities impacted by presidentially declared disasters to recover and to rebuild. The underlying program regulations are detailed at 24 CFR §570 and in the federal notices published in the Federal Register addressing specific disaster events. As noted in the Overview section, the federal notice addressing Hurricane Harvey is the Federal Register, Vol. 83, No. 28, Friday February 9, 2018.

The DR Rental Housing Case Management Program for renters is an activity under the Affordable Rental Housing Program. The program will serve low-to-moderate-income individuals and households affected by Hurricane Harvey in need of housing stabilization. HCCSD will partner with the Coalition for the Homeless and Houston Housing Authority to access rental assistance services when needed by the renter. CDBG-DR funding will only be used to provide case management and housing navigation services.

1.3.2. Fair Housing, Equal Access and Non-Discrimination Title VIII of the Civil Rights Act of 1968 (Fair Housing Act), as amended, prohibits discrimination in the sale, rental, and financing of dwellings, and in other housing-related transactions, based on race, color, national origin, religion, sex, familial status (including children under the age of 18 living with parents or legal custodians, pregnant women, and people securing custody of children under the age of 18), and disability.

On February 3, 2012, HUD published a final rule in the Federal Register entitled Equal Access to Housing in HUD Programs regardless of Sexual Orientation or Gender Identity. The rule creates a new regulatory provision that generally prohibits considering a person's marital status, sexual orientation, or gender identity (a person's internal sense of being male or female) in making housing assistance available. Lesbian, gay, bisexual, and transgender people are guaranteed equal access to all housing for all types of housing (affordable, permanent, transitional and emergency) funded through HUD.

In addition to the final rule on Equal Access to Housing, HUD published a final rule in the Federal Register entitled "Equal Access in Accordance with an Individual's Gender Identity in Community Planning and Development Programs". This rule was published on September 21,



2016. HCCSD provides equal access in accordance with the Equal Access to Housing Final Rule which requires housing programs be made available to individuals and families without regard to actual or perceived sexual orientation, gender identity, or marital status.

HCCSD is in compliance with the Fair Housing Laws and the Fair Housing Act. The HCCSD will provide nondiscriminatory measures to ensure the health, safety, security, and privacy of all clients to the best of its ability.

HCCSD programs are fully available to all residents of the community, regardless of race, color, national origin, gender, handicap or familial status including those individuals with Limited English Proficiency.

2. Program Definitions Federal Register (FR) – A daily publication of the US federal government that issues proposed and final administrative regulations of federal agencies.

Household – A household is defined as all persons occupying the same housing unit, regardless

of their relationship to each other. The occupants could consist of a single family, two or more

families living together, or any other group of related or unrelated persons who share living

arrangements. For housing activities, the test of meeting the LMI National Objective is based on

the LMI of the household.

Homeless Management Information System (HMIS) – the information system designated by

the Continuum of Care to comply with the HUD’s data collection, management, and reporting

standards and used to collect client‐level data and data on the provision of housing and services to

homeless individuals and families and persons at‐risk of homelessness.

Housing Quality Standards (HQS) – The HQS establish certain minimum standards, which all

units must meet before assistance can be paid on behalf of a family and at least annually

throughout the term of the assisted tenancy.

2.1. HUD Income Definitions Low to Moderate Income National Objective – Activities which benefit persons of income that does not exceed 80 percent of the area median income:

• Very low: Household’s annual income is up to 30 percent of the area median family income, as determined by HUD, adjusted for family size

• Low: Household’s annual income is between 31 percent and 50 percent of the area median family income, as determined by HUD, adjusted for family size

• Moderate: Household’s annual income is between 51 percent and 80 percent of the area median family income, as determined by HUD, adjusted for family size

2.2. HUD Homeless Definitions Clients who are determined as homeless must meet the HUD criteria for determining homelessness as either literally homeless (Category 1) or fleeing/attempting to flee domestic violence (Category 4). These categories are defined below:



Category 1 - Literally Homeless is an individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning:

• Has a primary nighttime residence that is a public or private place not meant for human habitation

• Is living in a publicly or privately operated shelter designated to provide temporary living arrangements (including congregate shelters, transitional housing, and hotels and motels if paid for by charitable organizations or by federal, state and local government programs)

OR

• Is exiting an institution where (s)he has 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

Category 4 - Fleeing Domestic Violence includes any individual or family who

• Is fleeing, or is attempting to flee, domestic violence

• Has no other residence

• Lacks the resources to support networks to obtain other permanent housing

3. DR Rental Housing Case Management The Case Manager will assist clients in navigating the process of securing housing from the initial referral to lease up and assist with housing stabilization based on the client’s individual needs and housing plan.

3.1. Case Loads It is expected that Case Managers maintain a reasonable case load to be able to provide quality housing case management to each client. Case Managers should maintain a case load of 20 – 30 clients. These ratios ensure that Case Managers are able to give quality housing case management to address the needs of their clients and provide the expected level of service.

Housing Navigators will maintain a reasonable case load to enable them to provide quality housing search and navigation. Navigators should maintain a case load of 35 – 40 clients actively searching for housing.

The Navigation and Case Management Services section will outline the Housing Navigator and Case Managers responsibilities.

3.2. Participant Eligibility Eligible participants of the DR Rental Housing Case Management Program are low-to-moderate-income individuals and households affected by Hurricane Harvey seeking safe, affordable rental housing in Harris County, particularly those households who are homeless or at risk of homelessness. Client referrals will be from the Continuum of Care Coordinated Access System or Harris County Housing and Community Resource Center.

3.3. Client Assessment Prior to being referred to the DR Rental Housing Case Management Program, clients must have an initial eligibility assessment and triage for appropriate housing by a specially trained housing assessor utilizing the Coordinated Access System. The trained assessor will be a staff member



from the referring agency, Coalition of the Homeless or Harris County Housing and Community Resource Center.

• All clients will come through the Coordinated Access System and will be assessed using a housing triage tool in HMIS and will be asked if they were impacted by Hurricane Harvey

• The standard assessment evaluates the length and frequency of homelessness, physical and mental health status and history, criminal history, veteran status, domestic violence experience, substance abuse conditions and employment history

• The housing triage will identify, based on the standard assessment, individuals who are best suited for the DR Rental Housing Case Management Program or other regional homeless assistance programs

3.3.1. Client Referrals through Harris County Housing & Community Resource Center

The Coordinated Access System will prioritize based on the assessment and send referred clients through the HMIS system to the DR Rental Housing Case Management Program staff for intake and enrollment.

3.4. Client Intake DR Rental Housing Case Management Program staff will familiarize and educate participants affected by Hurricane Harvey about the program, including the services available for housing placement and housing stabilization. Intake procedures will include:

Staff will collect and complete the necessary documentation including:

• Participant consent forms allowing for exchange of information to ensure continuum of services between HCCSD and rental assistance provider(s)

• All documentation and data required to initiate services during the screening and engagement phases of the program

Staff will brief the client including:

• Providing a brief explanation of program including its purpose and goals as it relates directly to individual participants

• Familiarizing participants with case management services and the process of accessing said services for optimal benefits

• Familiarizing participants with rental assistance services and the process of accessing said services for optimal benefits

• Familiarizing participants with grievance policies, discharge procedures, appeals policies as well as other program procedures

• Clarifying releases of information to be utilized with overall emphasis on participant legal right to choose if, how or when their personal information is shared

3.5. Navigation and Case Management Services Hurricane Harvey affected many lives especially renters and those marginally housed and at risk of becoming homeless. Lack of affordable housing resources particularly case management has hindered their recovery.

3.5.1. Housing Plan DR Rental Housing Case Management Program will identify unmet needs and barriers to stable housing at the onset through an assessment. These needs and barriers, with additional input of



client resources/skills, will be used in the development of a housing plan to assist clients achieve housing stability.

3.5.2. Housing Navigation Housing Navigators will assist clients and Case Managers to identify available safe, affordable rental units in the County. This specialized position will be dedicated to finding appropriate housing and developing relationships with affordable rental suppliers so that clients have greater housing choice, rather than expecting clients to navigate the system on their own.

Housing Navigation will begin providing housing search and placement services upon receiving the referral from Coordinated Access for homeless clients or Harris County Housing & Community Resource Center for low-to-moderate income households.

The Housing Navigators will assist clients in the process of securing housing from the initial referral to lease up. This process may include, but is not limited to, the following activities: obtaining ID, social security cards, homeless verification documents, a security deposit, and application fees, and by completing the rental assistance provider’s request for tenant approval packet.

3.5.3. Case Management The Case Manager will focus on creating stability in the client’s life as they transition into their new housing accommodations. Case Managers will work to eliminate recidivism among their client base.

HCCSD requires that Case Managers must conduct home visits at least on a monthly basis. Case Managers will document efforts in HMIS, if referred by Coordinated Access, and client project files related to client contact, agency visits, referrals to other agencies, and other services for clients.

Once a client has attained housing stability, the client will have a final assessment completed and will be exited out of the program. As part of the requirement for comprehensive case management for housing stability, all Case Managers are expected to complete, at a minimum, an in-person follow-up with clients 30 days after exiting the program, and then again at 90 days after exiting the program.

3.5.4. Rental Assistance Rental assistance will be provided by a rental assistance provider, such as the Houston Housing Authority.

DR Rental Housing Case Management Program will provide case management services to the client and report to the rental assistance provider the progress of the client towards housing stabilization.

Housing Navigator will complete rental assistance providers’ request for tenant approval packet and submit to the provider for approval of rental assistance.

Case Managers and Housing Navigators will follow the program rules of the rental assistance provider.



Housing Navigator may coordinate housing deposits and application fees on behalf of the client in accordance with the rental assistance provider’s policies and procedures if applicable.

Rent Reasonableness HUD regulation also requires that the rent being charged must be reasonable. Rent Reasonableness means that the total rent charged for a unit must be reasonable in relation to the rents being charged during the same time period for comparable units in the private unassisted market and must also not be in excess of rents being charged by the owner during the same time period for comparable non-luxury unassisted units [HUD NOA 06/08/09 Docket No. FR-5307 N-01, 15]. Units that have been determined unreasonable will be unable to receive assistance. Rental Reasonableness will be conducted and managed by the rental assistance provider and in accordance with the rental assistance provider’s regulations.

Housing Quality Standards (HQS) Inspection Regulation Any unit that receives financial rental assistance must pass a Housing Quality Standards Inspection as outlined by the rental assistance provider. HUD federal regulations require that all units comply with an HQS inspection. If HQS inspection fails, the landlord will get an opportunity to complete corrective actions. Inspection will be conducted and managed by the rental assistance provider and in accordance with the rental assistance provider’s regulations.

3.5.5. Duration, Amount of Assistance, and Client Participation DR Rental Housing Case Management Program will provide support to clients for the time necessary to stabilize that client or until the end of the GLO Agreement and provide for the likelihood of positive housing outcomes after assistance. The maximum time limit for case management services provided to individuals is until September 30, 2023 unless an extension is granted by HUD to expend the CDBG-DR Hurricane Harvey Round One grant. The amount of assistance and duration of assistance can vary substantially among clients. All Case Managers are required to re-assess clients annually. Based on the re-assessment, a decision will be made to continue or exit clients from the program based on the attainment of housing stability.

HCCSD, as part of the Houston/Harris County Continuum of Care (CoC), has adopted housing models and rules to measure community outcomes for all housing interventions. The CoC and HCCSD require the use assessment tools to determine the duration and amount of assistance. The tools do not dictate the amount of assistance that each household receives but guides the Case Manager and client to determine the appropriate amount of assistance for each household.

• All clients are assessed to determine initial need and create a budget to outline planned need for assistance

• Case Managers cannot set organizational maximums or minimums but must rely on the program tools to determine household need

• Through case management, client files are reviewed monthly to ensure that planned expenditures for the month validate financial assistance request

• HCCSD expects that households will receive the minimum amount of assistance necessary to stabilize in housing

• Clients will be re-assessed on an annual basis to affirm the household still meets income eligibility and for rental assistance provider requirements

Funding will be provided under the CDBG-DR Harvey Round One for the DR Rental Housing Case Management Program.



Any rental assistance will be provided by the rental assistance provider in accordance with their rule and regulations.

In accordance with the rental assistance provider’s rules for the provision of rental assistance, participant share will be determined by use of common assessment and budgeting tools approved by the rental assistance provider. These tools will determine the monthly assistance amount and client contribution.

The rental assistance provider will determine the client’s contribution based on monthly income and in accordance with the rental assistance provider’s rules.

Clients will participate in the development of their individual housing plan with a Case Manager based on client goals and shared goals for achieving housing stability.

Clients are expected to contribute a portion of their income based on budgeting to ensure housing stability. Financial assistance is available for households with zero income.

4. Record Keeping The DR Rental Housing Case Management Assistance Program will maintain program files in accordance with the Texas General Land Office file creation and retention policy.

4.1. Database System Case Managers are required to collect all support documents needed to prove client eligibility. Case Managers must document all client information in the Database System. Case Managers must follow all required entries as listed in the Database System training manual. Client information is to be recorded within a timely manner. Case Managers and supporting staff will accurately enter all client information into the Database System.

4.2. TIGR The Texas Integrated Grant Reporting (TIGR) system is the system utilized by The Texas General Land Office (GLO) for Subrecipient grant reporting for Disaster Grants 2015 / 2016 / Hurricane Harvey. The TIGR site allows subrecipients and other participants in the CDR Grants Relief program to self-manage applications, contracts, projects, and cases.

4.3. HMIS Homeless Management Information System (HMIS) is a HUD required computerized data collection tool specifically designed to capture client-level, system-wide information over time on the characteristics and services needs of individuals experiencing homelessness or who are at risk of homelessness. HMIS allows the aggregation of client-level data across homeless service agencies to generate unduplicated counts and service patterns of clients served. HMIS is both a collection method and a way to consolidate, review and analyze data. Data elements include basic demographics, income and benefits, family characteristics, education, employment and housing history, and situational data. Each data element can be generated into a spreadsheet. The confidentiality of HMIS data will be protected per HMIS Privacy Policies and Procedures maintained by the HMIS local administrator, the Coalition of the Homeless of Houston and HCCSD.



It is important to note that prior to entering clients’ information into the database, all clients are required to sign the Homeless Information Management System (HMIS) Consent to Release Information form.

The following documents shall be maintained electronically in HMIS under each participant’s name in the database:

• Individual Eligibility Form

• Release of Information for property manager/landlord (pending client consent)

• Release of Information for emergency contact (pending client consent)

• All other releases of information (as applicable and pending client consent)

• Houston Housing Authority (HHA) Income Re-certification Packet and relevant supporting documentation (as received and completed)

The following shall be maintained electronically in the Homeless Management Information System (HMIS):

• Case notes

• Services provided

• Initial, ongoing and exit assessments

4.4. Participant Case Notes To ensure that participant contacts are recorded accurately in regard to content and timeliness, the following procedure should be adhered to by Case Managers and Housing Navigators:

• Case notes must be completed within 72 business hours of contact with a participant or work on behalf of a participant

• Case notes from homeless households must be entered into the Homeless Management Information System (HMIS) by the end of the work week

• Complete sentences and correct spelling are required

• Use clear, specific and precise wording

• Include only pertinent, objective language

• Avoid use of jargon, slang and abbreviations

• Do not use defamatory language

• Do not reference other participants by name if it is not their file

• All notes are entered in the DAP format, providing Date, Assessment and a Plan. Data and Plan must be consistently entered for each case note; the Assessment section is not required but can be used at the discretion of the staff member entering the note

5. Program Exit DR Rental Housing Case Management Program staff will ensure that exit from services is a smooth and orderly process that adheres to CDBG-DR regulations and ensures a smooth transition out of services.

5.1. Discharge Procedures Discharge is the process that takes place when a participant of the program terminates his/her

participation in the program's services, voluntarily or involuntarily. The circumstances in which a

participant could be discharged from the Program services occurs when the participant:



• No longer wants the program’s services and provides documented refusal of services and assistance

• Fraudulent activity including (but not limited to) providing falsified information regarding income or benefits

• Determined ineligible at annual re-certification

• In the event of participant death

• Successfully completes the program

When participants wish to terminate services, the Case Manager will notify the Program Supervisor and rental assistance provider and coordinate an abbreviated termination process to facilitate a smooth transition and ensure a written statement expressing the participant’s desire to terminate service is filed whenever possible. Program staff will discuss, as permitted by the participant, any services needed or desired by the participant and specific plans for obtaining these services. Staff will collaborate with participants in exploring appropriate outside resources and make verbal and/or written contact on behalf of and with the permission of participants prior to their discharge. Discharge statement (if obtained) will be uploaded to the Data System, TIGR and HMIS into the participant’s electronic file. Any relevant plans will be documented in HMIS via a case note.

Denial of Continued Assistance for Case Management Services will occur when client:

• No longer meets eligibility requirements

• Successfully completes the program

In the event a client meets the following criteria above, Case Managers must complete the termination process and seek supervisory approval prior to denying continued assistance. All closed cases should be documented in the Data System and HMIS. When exiting clients from the program, the appropriate exit reason should be documented in the Data System, TIGR and HMIS.

Termination Procedure:

• The Case Manager will distribute an “Effort to Maintain Services” letter. Clients will have the option to reply within 10-15 business days of the post marked date they received the letter to appeal the case closure. Additional efforts will be made to ensure that the clients’ feedback is received. If there is no response after this time, a closure letter will be generated

• Case Managers will mail a “Case Closure” letter to clients who fail to reply or attempt to resolve their non-compliance status. In addition, client will be informed of written appeal process enclosed with the closure letter

• All closure recommendations will be reviewed with a Supervisor

6. Complaints and Appeals HCCSD is required to have a complaint process for non-applicants, applicants, and participants. HCCSD is also required to have an appeal process so that applicants and participants have recourse when the organization or their contractors makes an adverse determination of eligibility or benefits.



HCCSD is responsible for responding to complaints and appeals within 15 days of the concern. HCCSD will maintain a record of all complaints, appeals, and resolutions, including all communications, for a five (5) year period after the completion of the grant.

6.1. Complaints Complaints alleging violation of fair housing laws will be directed to the U.S. Department of Housing and Urban Development for immediate review. Complaints regarding fraud, waste, or abuse of government funds will be forwarded to the HUD OIG Fraud Hotline (phone: 1–800–347–3735 or email: [email protected]).

For complaints not alleging a violation of fair housing and/or fraud, or waste and abuse, applicants, participants or other organizations/persons can submit any general program complaint in writing, in person at any HCCSD office, or over the phone by contacting HCCSD at 1-832-927-4700.

HCCSD will take verbal complaints and try to resolve the complaint informally. If not able to come to agreeable resolution, HCCSD will request the complainant submit the complaint in writing.

6.2. Appeals HCCSD is required to have a systematic appeal process so that non-applicants, applicants, and/or participants have recourse when they feel HCCSD has made an adverse determination of eligibility or benefits. HCCSD has adopted an appeal process that will apply for all recipients and will not be applied in a manner that discriminates against any individual based on race, color, national origin, religion, sex, sexual orientation, age, familial status, or disability. If, at any time, an individual requires a reasonable accommodation to the established appeals process, HCCSD staff will follow reasonable accommodation protocol.

Filing an Appeal with Harris County Project Recovery Program

The appeals procedure will be a formal process and may include but not be limited to informal hearings, third-party review and director approval.

• The appellant must appeal any issues regarding their award within 45 days of the date on the determination letter

• All appeals must be requested in writing in order to be considered

• After 45 days, the status is considered final and can no longer be reviewed

• HCCSD will research all information related to an application only as it relates to current policies governing program award outcomes

• HCCSD cannot change policies or laws set forth by the County, State of Texas, or the federal government

• The final decision will be mailed to the complainant in an Appeals Decision letter

After the appellant receives their Appeal Decision Letter from HCCSD, the individual has two options:

1. Accept the determination within 30 days of receiving the Appeal Decision Letter

OR



2. Request a review of the determination by the Texas General Land Office (GLO) as described in the Appeal Decision Letter

Filing an Appeal with the Texas General Land Office

The appellant must request a GLO review within 30 days of the date of the Appeal Decision Letter.

If the appellant requests a GLO review, the DR Appeals Coordinator will forward the request to GLO.

The applicant may at their own option, send an appeal’s request directly to GLO.

• The applicant may file an appeal with the Texas General Land Office if the final decision does not address the appeal to their satisfaction. GLO contact information: 1–800–998–4456 or http://www.glo.texas.gov/contact/email-us/index.html

GLO-DR, Texas General Land Office P.O. Box 12873 Austin, Texas, 78711-2873

7. Confidentiality and PII Various funding sources require the collection of specific client data. Therefore, HCCSD maintains the confidentiality of client information by ensuring hard files are kept in locked drawers and by inputting information into secure databases, including County, State/Federal and the local Homeless Management Information System (HMIS) databases. All information is confidential within the agency, but can be viewed upon request by client, grantors of funds, and Harris County and State of Texas General Land Office Program Monitors and Auditors.

All client information must remain confidential including client files and any information related to the client. Employees are prohibited from disclosing or engaging in any conversation or exchange of any documentation outside of obtaining or providing information pertaining to financial assistance. Confidentiality of all program participants must be maintained. Information about a participant may only be shared outside the organization through a formal release signed, dated, and approved by the participant or their legal guardian or by subpoena, court order or legal statute.

A Client who present themselves as a victim of Domestic Violence and/or is in protective custody who reports they prefer to use a pseudonym name must also provide their legal name, date of birth, real address, and social security number. The Pseudonym cases will be handled in such a manner as to protect the client’s real identity. The Supervisor will approve all Pseudonym name cases.

7.1. Client release of information

7.1.1. With Participant’s Authorization: 1. No information may be released about a participant without their express written permission 2. Permission to release information is granted through a signed “Release of Information” 3. The “Release of Information” documents the following information:

http://www.glo.texas.gov/contact/email-us/index.html



• Participant’s name

• Date of authorization

• Original signatures of participant and Housing Advisor/counselor

• Name of INDIVIDUAL and ORGANIZATION to which information will be released

• Indication of what information is to be released

• Duration for which the release is effective 4. A new “Release of Information” will be completed as required for each request 5. Under no circumstances will staff or volunteers acknowledge on the phone, in person or in

writing that an individual is a participant in the program 6. The residence of all participants will be maintained confidential from all persons outside the

organization 7. Landlords will not be privy to any information which may violate a participant’s federally

guaranteed rights and/or safety 8. Unauthorized release of information will result in termination of the staff member/volunteer

and potential prosecution

7.1.2. Without Participant’s Authorization: 1. Information about a participant may be released without their approval or knowledge, with

Supervisor’s and Disaster Recovery Officer’s approval 2. Information may be released only under the following conditions:

● A threat of harm to self or others

● A subpoena, court order or legal statute

8. Abuse, Neglect and Exploitation The DR Rental Housing Case Management Program will ensure that participants are protected from abuse, neglect, and exploitation by reporting an allegation or reasonable suspicion of abuse, neglect, and exploitation immediately to the Supervisor within the DR Rental Housing Case Management Program. The following procedure will be followed:

1. All allegations of abuse, neglect or exploitation shall be reported within 24 hours to the Program Supervisor, Manager, and Director of Programs as appropriate

2. In the case that a report is made to Adult Protective Services, the Case Manager will provide the protective agency with on-going assistance as required

3. The Case Manager, with a Release of Information, may coordinate services with the protective agency, as required

9. Referrals The DR Rental Housing Case Management Program will coordinate with and access mainstream and other targeted homeless resources in order to positively affect housing stabilization. The DR Rental Housing Case Management Program will work closely with the Harris County Housing and Community Resource Center to assist households to seek needed household goods and furniture, tenant legal counseling services, healthcare service providers, and with other unmet needs. The program will also connect clients to mainstream resources, such as Texas Gold Card/food stamps, food pantries, social security or disability benefits, and veteran services as needed. For those clients in need of transportation services, Case Managers can provide



information on the Harris County Transit Services non-medical transportation program and the RIDES programs for the client to contact as needed.

10. Staff Training and Competencies To ensure that all program staff are trained in a manner that optimizes positive participant outcomes, DR Rental Housing Case Management Program Manager and Supervisor will develop a training log for each Case Manager noting annual trainings and skill building. At a minimum, staff will be trained in:

• Motivational Interviewing

• Cultural Competency

• Ethics as applicable to any licensing requirements that staff may have

• HMIS training

• Database System training

11. Contact Information The DR Rental Housing Case Management Program under the Disaster Recovery Office can be contacted through:

Harris Recovery Housing Program at 832-927-4961 or toll free 855-393-2923

Website: www.harrisrecovery.org

Our email address: [email protected]

http://www.harrisrecovery.org/



12. Change Log HCCSD will provide a change log listing all substantial changes to the DR Rental Housing Case Management Program Guidelines

DR RENTAL HOUSING CASE MANAGEMENT PROGRAM GUIDELINE CHANGE LOG

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Section Change Change Date

disaster recovery rental housing case management program ... · 8/1/2019 · disaster recovery...

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