dvhtac peer support call: covid-19 spending bill & safe ......dvhtac peer support call: covid-19...

Domestic Violence and Housing Technical Assistance Consortium

wwwsafehousingpartnershipsorg

DVHTAC Peer Support Call COVID-19 Spending Bill amp Safe Housing Options for Survivors

April 10 2020

PresentersSarah Saadian National Low Income Housing CoalitionSteve Berg National Alliance to End HomelessnessLisa Coffman HUDs Office of Special Needs and Assistance ProgramsB Aaron Weaver HUDs Office of Community Planning and DevelopmentJasmine Hayes US Interagency Council on Homelessness

HostsDebbie Fox National Network to End Domestic ViolenceJill Robertson Collaborative Solutions



Overview

bull Introduce the federal Domestic Violence and Housing Technical Assistance Consortium and our COVID-19 Response

bull Highlight of partnerships across sectors during the pandemic

bull Overview of recent COVID3 Care housing investments and expansions

bull Explore federal innovative responses to address the safe housing needs of survivors



DV amp Housing TA Consortium (DVHTAC)

Federal Partnersbull Family Violence Prevention amp Services ProgramHHS

bull Office on Violence Against WomenDOJ

bull Office for Victims of CrimeDOJ

bull Office of Special Needs Assistance ProgramsHUD

bull US Interagency Council on Homelessness

Technical Assistance Providers

bull National Alliance for Safe Housing (NASH)

bull Collaborative Solutions Inc (CSI)

bull National Network to End Domestic Violence (NNEDV)

bull National Resource Center on Domestic Violence (NRCDV)

bull National Sexual Violence Resource Center (NSVRC)

bull Corporation for Supportive Housing (CSH)

DVHTAC Peer Support CallCOVID-19 Funding

Jasmine Hayes Deputy Director

April 10 2020

bullPlan

bullCommunity Planning and Preparedness

bullAct

bullSite-Specific Emergency Operations

bullClient Support and Care

bullFunding Flexibilities and Waivers

bullOther Considerations

bullFollow-up

5

Responding to COVID-19

Resources

bullCDC Guidance Supporting People Experiencing Homelessness

bullUSICH COVID-19 resources

bullContact your USICH Regional Coordinator using our State Data and Contacts Map (click on your state to find your RC)

bullSign-up for our newsletter

6

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

Office of Special Needs Assistance Programs

7

Prioritize Your COVID-19 Response

bull SNAPS understands your 1 priority right now is responding to COVID-19

bull HUD will take into account the need for COVID response when considering performance metrics subrecipient monitoring governance and future HUD monitoring and CoC Competitions

bull CoCs are encouraged to be as flexible as possible when thinking through their local competition metrics

Resources for CoCs and Homeless Assistance Providers on the HUD ExchangeInfectious Disease Prevention amp Response page on HUD Exchange

bull Submit a question on the HUD Exchange Ask-A-Question (AAQ) Portal

Check back regularly for new posts

Key Websites with Available Resources

HUD httpswwwhudexchangeinfohomelessness-assistancediseasesinfectious-disease-prevention-response

CDC httpswwwcdcgovcoronavirus2019-ncovcommunityhomeless-sheltersindexhtml

NHCHC httpsnhchcorgclinical-practicediseases-and-conditionsinfluenza

USICH httpswwwusichgovtools-for-actioncoronavirus-covid-19-resources

VA httpswwwpublichealthvagovn-coronavirusindexasp

HRSA httpsbphchrsagovemergency-responsecoronavirus-frequently-asked-questionshtml

CARES Act amp COVID-19 Waivers

Lisa Coffman and Aaron Weaver

US Department of Housing and Urban Development

CARES Act Funding Breakdown

bull $4B for Emergency Solutions Grants

bull $1B Announced on April 2 2020

bull $65M for Housing Opportunities for Persons With AIDS

bull $537M for Formula Grants

bull $10M for Competitive Grants

bull $5B for Community Development Block Grant


COVID-19 Waivers

Regulatory Waivers for CPD Grant Programs and Consolidated Plan Requirements

Background

bull On April 1 2020 HUD issued a memorandum providing regulatory waivers for certain requirements associated with

bull Continuum of Care (CoC) Program

bull Emergency Solutions Grant (ESG) Program

bull Housing Opportunities for Persons with AIDS (HOPWA) Program

bull Consolidated Plan Requirements

bull Effective date is March 31 2020

bull The waivers are intended to help prevent the spread of COVID-19 and to provide additional supports to individuals and families eligible for assistance who are economically impacted by COVID-19

Submitting and Documenting Waivers

bull Recipients wishing to utilize any of the waivers provided should notify their local CPD Director by email of their intent to utilize a specific waiver two days before they anticipate using the flexibility

bull Grantees are strongly encouraged to establish a set of emergency policies and procedures for use during the COVID situation This should outline the waivers they are utilizing and describe the records they will maintain to support those waivers

Step 1 Notify CPD

FO Director

Step 2 Waiting

Period of 2 Calendar

Days

Step 3a

Utilize Waiver

Step 3b Document Conditions (Recpient)

Step 4 Document

Use (Client)

Resources

bull Waiver Memorandum Description of available waivers and the notification procedure

bull Waiver-Specific CPD Director Contact Information Specific email addresses that must be utilized to notify CPD Directors of the intent to utilize available waivers

bull Attachment 1 to the Memorandum Information regarding the procedure for utilizing available waivers including the information that must be included in the notification to CPD Directors

Continuum of Care (CoC) Program

CoC Program Waivers

The following waivers are available for the CoC Program

1

6

4

2

3

5

7

Fair Market Rent for Individual Units and Leasing Costs 24 CFR 57848(b)(2)

Disability Documentation for Permanent Supportive Housing (PSH)24 CFR 578103(a) and 578103(a)(4)(i)(B)

Limit on Eligible Housing Search and Counseling Services 24 CFR 57853(d) and 57853(e)(8)(ii)(B)

Permanent Housing-Rapid Re-housing Monthly Case Management24 CFR 57837(a)(1)(ii)(F)

Housing Quality Standards (HQS) ndash Initial Physical Inspection of Unit24 CFR 57875(b)(1)

HQS ndash Re-Inspection of Units24 CFR 57875(b)(2)

One Year Lease Requirement Definition of Permanent Housing24 CFR 5783 and 57851(i)(1)

Fair Market Rent for Individual Units and Leasing Costs

Requirement Applicability Other Provisions

Rent payments for

individual units with leasing

dollars may not exceed Fair

Market Rent (FMR)

For the 6-month period

beginning on the date of

the waiver memorandum

(3312020) the FMR

restriction is waived for any

lease executed by a

recipient or subrecipient to

provide transitional or

permanent supportive

housing

The affected recipient or

subrecipient must still

ensure that rent paid for

individual units that are

leased with CoC Program

leasing dollars meet the

rent reasonableness

standard in 24 CFR

57849(b)(2)

Disability Documentation for Permanent Supportive Housing


A recipient providing PSH

must document a qualifying

disability of one of the

household members When

documentation of disability is

the intake workerrsquos

observation the regulation

requires the recipient to

obtain additional confirming

evidence within 45 days




(3312020) the requirement

to have third party

documentation of disability

that intake staff-recorded

observation of disability be

confirmed and accompanied

by other evidence no later

than 45 days from the

application for assistance

documentation requirement is

waived for any program

participants admitted into

PSH funded by the CoC

Program

For the purposes of individuals

and families housed in PSH

from the date of this

memorandum until public

health officials determine no

additional special measures

are necessary to prevent the

spread of COVID-19 a written

certification by the individual

seeking assistance that they

have a qualifying disability is

considered acceptable

documentation approved by

HUD under 24 CFR

578103(a)(4)(i)(B)(5)

Limit on Eligible Housing Search and Counseling Services


With respect to program

participantrsquos debts 24 CFR

57853(ed)(8)(ii)(B)

only allows the costs of

credit counseling

accessing a free personal

credit report and resolving

personal credit issues 24

CFR 57853(d) limits the

use of CoC Program funds

for providing services to

only those costs listed in

the interim rule

For the 1-year period



(3312020) the limitation on

eligible housing search and

counseling activities is

waived so that CoC Program

funds may be used for up to 6

months of a program

participantrsquos utility arrears

and up to 6 months of

program participantrsquos rent

arrears when those arrears

make it difficult to obtain

housing

Only applies when those

arrears make it difficult to

obtain housing

Permanent Housing-Rapid Re-housing Monthly Case Management

Requirement Applicability

Recipients must require program

participants of permanent housing ndash rapid

re-housing projects to meet with a case

manager at least monthly

For 2-month period beginning on the

date of the waiver memorandum

(3312020) the requirement in 24 CFR

57837(a)(1)(ii)(F) that requires program

participants to meet with case mangers not

less than once per month is waived for all

permanent housing- rapid re-housing

projects

Housing Quality Standards (HQS) ndashInitial Physical Inspection of Unit


Recipients are required

to physically inspect any

unit supported with

leasing or rental

assistance funds to

assure that the unit

meets housing quality

standards (HQS) before

any assistance will be

provided on behalf of a

program participant




(3312020) this waiver of

the requirement in 24 CFR

57875(b)(1) that the

recipient or subrecipient

physically inspect each unit

to assure that the unit

meets HQS before

providing assistance on

behalf of a program

participant is in effect

Recipients and subrecipients

must meet both the following

criteria

bull The recipient is able to

visually inspect the unit

using technology such as

video streaming to ensure

the unit meets HQS before

assistance is provided and

bull The recipient or subrecipient

has written policies to

physically reinspect the unit

within 3 months after the

health officials determine

special measures to

prevent the spread of

COVID-19 are no longer

necessary

HQS ndash Re-Inspection of Units


Recipients or subrecipients must

inspect all units for which leasing or

rental assistance funds are used at

least annually to ensure they continue

to meet HQS

For the 1-year period beginning on

the date of the waiver

memorandum (3312020) this

requirement in 24 CFR 578(b)(2) is

waived

One-Year Lease Requirement Definition of Permanent Housing


Program participants

residing in PSH must be the

tenant on a lease for a term

of at least one year that is

renewable and terminable

for cause




(3312020) the one-year

lease requirement is waived

The initial lease term of all

leases must be for more

than one month

Emergency Solutions Grant (ESG) Program

ESG Program Waivers

The following waivers are available for the ESG Program

10

13

11

12

HMIS Lead Activities24 CFR 576107(a)(2)

Re-Evaluations for Homelessness Prevention Assistance24 CFR 576401(b)

Housing Stability Case Management24 CFR 576401(e)

Restriction of Rental Assistance to Units with Rent at or Below FMR24 CFR 576106(d)(1)

HMIS Lead Activities


ESG funds may be used to pay the costs

of managing and operating the HMIS

provided that the ESG recipient is the

HMIS Lead

For the 6-month period beginning on

the date of the waiver memorandum

(3312020) the condition that the recipient

must be the HMIS Lead to pay costs under

24 CFR 576102(a)(2) is waived to the

extent necessary to allow any recipient to

use ESG funds to pay costs of upgrading

or enhancing its local HMIS to incorporate

data on ESG Program participants and

ESG activities related to COVID-19

Re-Evaluations for Homelessness Prevention Assistance


Homelessness prevention

assistance is subject to re-

evaluation of each program

participantrsquos eligibility need

for assistance not less than

once every 3 months

For up to the 2-year

period beginning on the

date of the waiver

memorandum (3312020)

the required frequency of

re-evaluations for

homelessness prevention

assistance under section

576401(b) is waived

The recipient or

subrecipient must conduct

the required re-evaluations

not less than once every

6 months

Housing Stability Case Management


Program participants receiving

homelessness prevention or rapid re-

housing assistance must meet with a case

manager not less than once per month

unless certain statutory prohibitions apply



(3312020) this waiver is in effect

Restriction of Rental Assistance to Units At or Below FMR


Under 24 CFR

576106(d)(1) rental

assistance cannot be

provided unless the total

rent is equal to or less than

the FMR established by

HUD as provided under 24

CFR Part 888 and

complies with HUDrsquos

standard of rent

reasonableness as

established under 24 CFR

982507




(3312020) the FMR


individual or family

receiving Rapid Re-housing

or Homelessness

Prevention assistance who

executes a lease for a unit

The ESG recipient or


ensure that the units in

which ESG assistance is

provided to these

individuals and families

meet the rent

reasonableness standard

Housing Opportunities for Persons with AIDS (HOPWA) Program

HOPWA Program Waivers

The following waivers are available for the HOPWA Program

14

17

15

16

Self-Certification of Income and Credible Information on HIV Status24 CFR 574530

FMR Rent Standard24 CFR 574320(a)(2)

Property Standards for TBRA24 CFR 574310(b)

Space and Security24 CFR 574310(b)(2)(iii)

Self-Certification of Income and Credible Information on HIV Status


Each grantee must maintain

records to document

compliance with HOPWA

requirements which includes

determining the eligibility of a

family to receive HOPWA

assistance

This waiver is in effect for

recipients who require written

certification of the household

seeking assistance of their HIV

status and income and agree

to obtain source documentation

of HIV status and income

eligibility within 3 months of

public health officials

determining no additional

special measures are

necessary to prevent the

spread of COVID-19

Eligibility is restricted to a low-

income person who is living

with HIVAIDS and the family of

such person

FMR Rent Standard


Grantees must establish rent standards for

their tenant-based rental assistance

programs based on FMR (Fair Market

Rent) or the HUD approved community-

wide exception rent for unit size Generally

the TBRA payment may not exceed the

difference between the rent standard and

30 percent of the familys adjusted income

Such rent standards may be used for up

to one year beginning on the date of the


Property Standards for TBRA


This section of the HOPWA

regulations provides that

units occupied by recipients

of HOPWA TBRA meet the

Housing Quality Standards

(HQS) established in this

section




(3312020) this waiver is

in effect

Recipients and project sponsors

that must meet the following

criteria

bull The recipient or project

sponsor is able to visually

inspect the unit using

technology such as video

streaming to ensure the unit

meets HQS before any




physically re-inspect the unit

after the health officials

determine special measures

to prevent the spread of


necessary

Space and Security


This section of the HOPWA regulations

provide that each resident must be

afforded adequate space and security for

themselves and their belongings

Waived for grantees addressing

appropriate quarantine space for affected

eligible households during the allotted

quarantined timeframe recommended

by local health care professionals

Consolidated Plan Requirements

Consolidated Plan Waivers

The following waivers are available for Consolidated Plan requirements

8

9

Citizen Participation Public Comment Period for Consolidated Plan Amendment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401

Citizen Participation Reasonable Notice and Opportunity to Comment24 CFR 91105(c)(2) and (k) 24 CFR 91115(c)(2) and (i) 24 CFR 91401

Citizen Participation Public Comment Period for Consolidated Plan Amendment


A CPD grantee may amend

an approved consolidated

plan in accordance with 24

CFR 91505 Substantial

amendments to the

consolidated plan are

subject to the citizen

participation process in the

granteersquos citizen

participation plan The

citizen participation plan

must provide citizens with

30 days to comment on

substantial amendments

Through the end of the

recipientrsquos 2020 program

year the 30-day minimum

for the required public

comment period is waived

for substantial amendments

Grantees must provide no

less than 5 days for public

comments on each

substantial amendment

Any recipient wishing to

undertake further

amendments to prior year

plans following the 2020

program year can do so

during the development of

its FY 2021 Annual Action

Plan

Citizen Participation Reasonable Notice and Opportunity to Comment


As noted above the regulations at 24 CFR

91105 (for local governments) and 91115

(for States) set forth the citizen

participation plan requirements for

recipients For substantial amendments to

the consolidated plan the regulations

require the recipient to follow its citizen

participation plan to provide citizens with

reasonable notice and opportunity to

comment The citizen participation plan

must state how reasonable notice and

opportunity to comment will be given

HUD waives 24 CFR 91105(c)(2) and (k)

24 CFR 91115(c)(2) and (i) and 24 CFR

91401 to allow these grantees to

determine what constitutes reasonable

notice and opportunity to comment given

their circumstances



Sarah Saadian

CARES Act HUD Homeless Funding

Domestic Violence

Steve Berg

National Alliance to End Homelessness

CARES Act ESG funding

Emergency Solutions Grants

bull Larger cities and counties and ldquobalance of

staterdquo are recipients

bull Regular ESG is about $280 million

bull Mostly subcontracted to nonprofits

bull Outreach shelter rapid rehousing

construction and operating costs

CARES Act ESG

Changes from usual ESG - money

bull Lots more money $4 billion

bull ldquoUp tordquo $2 billion under the usual formula

bull The rest under a new formula meant to

target need as a result of coronavirus

bull HUD has already announced $1 billion in

allocations more ldquosoonrdquo

CARES Act ESG

Changes from usual ESG - flexibility

bull No matching requirement

bull No ldquoshelter caprdquo

bull Anybody whose income is under 50 of

area median income is eligible for help

bull No treatment or performance requirement

may be imposed

CARES Act ESG

Best uses

bull Shelter expansion and deconcentration

(CDC guidelines)

bull Non-congregate shelter

bull Connection with permanent housing

bull Landlord outreach

bull Rental assistance up to 2 years

Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0



Safe Housing for Survivors Now More than Ever Flexible programming and financial assistance

Advocacy framed by safety planning and awareness of potential for abuser sabotage

Survivor driven trauma informed culturally and linguistically responsive voluntary services

Broad eligibility minimal program requirements

Flexible duration for survivors who need longer term support

Support for reconnecting with community





National Landscape for VSPsbull Family Violence Prevention Services Act (FVPSA) Victims

of Crime Act (VOCA) and the Violence Against Women Act (VAWA) have been successful in addressing domestic violencemdashworking to expand those funding streamsw COVID4

bull $45 Million FVPSA-

--FVPSA include basic needs

--FVPSA covers rental assistance hotel motel utilities

bull Shelter in FVPSA Regs (45 CFR sect13702) includes the provision of

temporary refuge in conjunction with supportive services in compliance with

applicable State or Tribal law or regulations



Need Technical Assistance or Training

Go to SafeHousingPartnerhipsorg and use the TECHNICAL ASSISTANCE tab in the top toolbar

Lisa Coffman HUDs Office of Special Needs and Assistance ProgramslisaRCoffmanhudgov

B Aaron Weaver HUDs Office of Community Planning and DevelopmentBradleyAWeaverhudgov

Jasmine Hayes US Interagency Council on Homelessness

jasminehayesusichgov

Sarah Saadian National Low IncomeHousing Coalitionssaadiannlihcorg

Steve Berg National Alliance to End Homelessnesssbergnaehorg



Tell us what you are doing

bull How are you enhancing safety housing stability health and well-being for domestic violence and sexual assault victims and

their children during COVID-19

bull What is working in your community and how can we increase supports for survivors during COVID-19



Questions and Discussion



SAFE HOUSING PARTNERSHIPSThe website for the Domestic Violence and Housing Technical

Assistance Consortium

bull Data infographics literature reviews and reports that describe the intersections between

domestic violence sexual assault homelessness and housing

bull Strategies for building effective and sustainable partnerships across systems and case

studies of successful collaborations

bull In-depth resource collections organized around four key approaches to addressing and

preventing housing instability among survivors

bull Access to relevant federal laws regulations and polices

Have questions Need TA Want training

Contact the Consortium directly through the site



Overview

bull Introduce the federal Domestic Violence and Housing Technical Assistance Consortium and our COVID-19 Response

bull Highlight of partnerships across sectors during the pandemic

bull Overview of recent COVID3 Care housing investments and expansions

bull Explore federal innovative responses to address the safe housing needs of survivors


















April 10 2020

bullPlan


bullAct





bullFollow-up

5


Resources





6



7


























COVID-19 Waivers


Background











Step 1 Notify CPD

FO Director

Step 2 Waiting


Days

Step 3a

Utilize Waiver


Step 4 Document

Use (Client)

Resources





CoC Program Waivers


1

6

4

2

3

5

7










Rent payments for



Market Rent (FMR)




(3312020) the FMR


lease executed by a




housing







rent reasonableness

standard in 24 CFR

57849(b)(2)

















to have third party












Program














HUD under 24 CFR

578103(a)(4)(i)(B)(5)





57853(ed)(8)(ii)(B)


credit counseling








the interim rule









months of a program






housing



obtain housing














projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0






































































April 10 2020

bullPlan


bullAct





bullFollow-up

5


Resources





6



7


























COVID-19 Waivers


Background











Step 1 Notify CPD

FO Director

Step 2 Waiting


Days

Step 3a

Utilize Waiver


Step 4 Document

Use (Client)

Resources





CoC Program Waivers


1

6

4

2

3

5

7










Rent payments for



Market Rent (FMR)




(3312020) the FMR


lease executed by a




housing







rent reasonableness

standard in 24 CFR

57849(b)(2)

















to have third party












Program














HUD under 24 CFR

578103(a)(4)(i)(B)(5)





57853(ed)(8)(ii)(B)


credit counseling








the interim rule









months of a program






housing



obtain housing














projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0





















































bullPlan


bullAct





bullFollow-up

5


Resources





6



7


























COVID-19 Waivers


Background











Step 1 Notify CPD

FO Director

Step 2 Waiting


Days

Step 3a

Utilize Waiver


Step 4 Document

Use (Client)

Resources





CoC Program Waivers


1

6

4

2

3

5

7










Rent payments for



Market Rent (FMR)




(3312020) the FMR


lease executed by a




housing







rent reasonableness

standard in 24 CFR

57849(b)(2)

















to have third party












Program














HUD under 24 CFR

578103(a)(4)(i)(B)(5)





57853(ed)(8)(ii)(B)


credit counseling








the interim rule









months of a program






housing



obtain housing














projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0





















































Resources





6



7


























COVID-19 Waivers


Background











Step 1 Notify CPD

FO Director

Step 2 Waiting


Days

Step 3a

Utilize Waiver


Step 4 Document

Use (Client)

Resources





CoC Program Waivers


1

6

4

2

3

5

7










Rent payments for



Market Rent (FMR)




(3312020) the FMR


lease executed by a




housing







rent reasonableness

standard in 24 CFR

57849(b)(2)

















to have third party












Program














HUD under 24 CFR

578103(a)(4)(i)(B)(5)





57853(ed)(8)(ii)(B)


credit counseling








the interim rule









months of a program






housing



obtain housing














projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0























































7


























COVID-19 Waivers


Background











Step 1 Notify CPD

FO Director

Step 2 Waiting


Days

Step 3a

Utilize Waiver


Step 4 Document

Use (Client)

Resources





CoC Program Waivers


1

6

4

2

3

5

7










Rent payments for



Market Rent (FMR)




(3312020) the FMR


lease executed by a




housing







rent reasonableness

standard in 24 CFR

57849(b)(2)

















to have third party












Program














HUD under 24 CFR

578103(a)(4)(i)(B)(5)





57853(ed)(8)(ii)(B)


credit counseling








the interim rule









months of a program






housing



obtain housing














projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0














































































COVID-19 Waivers


Background











Step 1 Notify CPD

FO Director

Step 2 Waiting


Days

Step 3a

Utilize Waiver


Step 4 Document

Use (Client)

Resources





CoC Program Waivers


1

6

4

2

3

5

7










Rent payments for



Market Rent (FMR)




(3312020) the FMR


lease executed by a




housing







rent reasonableness

standard in 24 CFR

57849(b)(2)

















to have third party












Program














HUD under 24 CFR

578103(a)(4)(i)(B)(5)





57853(ed)(8)(ii)(B)


credit counseling








the interim rule









months of a program






housing



obtain housing














projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0





















































Background











Step 1 Notify CPD

FO Director

Step 2 Waiting


Days

Step 3a

Utilize Waiver


Step 4 Document

Use (Client)

Resources





CoC Program Waivers


1

6

4

2

3

5

7










Rent payments for



Market Rent (FMR)




(3312020) the FMR


lease executed by a




housing







rent reasonableness

standard in 24 CFR

57849(b)(2)

















to have third party












Program














HUD under 24 CFR

578103(a)(4)(i)(B)(5)





57853(ed)(8)(ii)(B)


credit counseling








the interim rule









months of a program






housing



obtain housing














projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0
























































Step 1 Notify CPD

FO Director

Step 2 Waiting


Days

Step 3a

Utilize Waiver


Step 4 Document

Use (Client)

Resources





CoC Program Waivers


1

6

4

2

3

5

7










Rent payments for



Market Rent (FMR)




(3312020) the FMR


lease executed by a




housing







rent reasonableness

standard in 24 CFR

57849(b)(2)

















to have third party












Program














HUD under 24 CFR

578103(a)(4)(i)(B)(5)





57853(ed)(8)(ii)(B)


credit counseling








the interim rule









months of a program






housing



obtain housing














projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0





















































Resources





CoC Program Waivers


1

6

4

2

3

5

7










Rent payments for



Market Rent (FMR)




(3312020) the FMR


lease executed by a




housing







rent reasonableness

standard in 24 CFR

57849(b)(2)

















to have third party












Program














HUD under 24 CFR

578103(a)(4)(i)(B)(5)





57853(ed)(8)(ii)(B)


credit counseling








the interim rule









months of a program






housing



obtain housing














projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0






















































CoC Program Waivers


1

6

4

2

3

5

7










Rent payments for



Market Rent (FMR)




(3312020) the FMR


lease executed by a




housing







rent reasonableness

standard in 24 CFR

57849(b)(2)

















to have third party












Program














HUD under 24 CFR

578103(a)(4)(i)(B)(5)





57853(ed)(8)(ii)(B)


credit counseling








the interim rule









months of a program






housing



obtain housing














projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0























































Rent payments for



Market Rent (FMR)




(3312020) the FMR


lease executed by a




housing







rent reasonableness

standard in 24 CFR

57849(b)(2)

















to have third party












Program














HUD under 24 CFR

578103(a)(4)(i)(B)(5)





57853(ed)(8)(ii)(B)


credit counseling








the interim rule









months of a program






housing



obtain housing














projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0





































































to have third party












Program














HUD under 24 CFR

578103(a)(4)(i)(B)(5)





57853(ed)(8)(ii)(B)


credit counseling








the interim rule









months of a program






housing



obtain housing














projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0

























































57853(ed)(8)(ii)(B)


credit counseling








the interim rule









months of a program






housing



obtain housing














projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0


































































projects





unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0

























































unit supported with

leasing or rental

assistance funds to






program participant










meets HQS before


behalf of a program




criteria












special measures to



necessary







to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0



























































to meet HQS





waived








for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0




























































for cause








than one month


ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0






















































ESG Program Waivers


10

13

11

12










HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0


























































HMIS Lead


















once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0




























































once every 3 months



date of the waiver



re-evaluations for



576401(b) is waived

The recipient or




6 months













Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0

































































Under 24 CFR

576106(d)(1) rental






CFR Part 888 and


standard of rent

reasonableness as


982507




(3312020) the FMR




or Homelessness







provided to these


meet the rent





14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0
























































14

17

15

16








records to document





assistance













spread of COVID-19




such person

FMR Rent Standard





















section





in effect



criteria















necessary

Space and Security














8

9









amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




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Sarah Saadian


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Steve Berg










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Sarah Saadian


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Steve Berg










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Steve Berg


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24 CFR 91115(c)(2) and (i) and 24 CFR




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Steve Berg










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Steve Berg


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24 CFR 91115(c)(2) and (i) and 24 CFR




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Sarah Saadian


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Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0



























































amendments to the


















comments on each



undertake further






Plan
















24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0




































































24 CFR 91115(c)(2) and (i) and 24 CFR




their circumstances



Sarah Saadian


Domestic Violence

Steve Berg










CARES Act ESG








CARES Act ESG







may be imposed

CARES Act ESG

Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0























































Sarah Saadian


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Steve Berg










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CARES Act ESG







may be imposed

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Best uses


(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0






















































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Steve Berg










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may be imposed

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Steve Berg


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Twitter sberg0





























































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(CDC guidelines)





Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0





















































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Steve Berg


sbergnaehorg

Twitter sberg0





















































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Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0





















































Homelessness

Steve Berg


sbergnaehorg

Twitter sberg0





















































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