Transcript Document
Understanding Shelter Plus Care From Development, to Implementation, to Best Practices Jonda Clemings - COHHIO Training Overview • • • • • S+C benefits & components Documentation Eligibility Meeting HUD S+C milestones Best practices Training Objective • Leave with two best practices to: – Prepare for development of S+C program or – Improve implementation of S+C program S+C Purpose The purpose of the program is to provide permanent housing in connection with supportive services to homeless people with disabilities and their families. S+C Program Goals • Increase housing stability • Increase skills and/or income • Obtain greater selfsufficiency Getting Your Program Together • • • • • • Recruit participants Assess participants needs; ISP Locate housing Administer rental assistance Coordinate supportive services Report on Progress Starting Your S+C Project • Clarify and coordinate roles of grant administer and service providers; • Obtain housing for S+C participants; • Identify and engage eligible participants: and • Address landlord and community concerns about project. From NIMBY to Acceptance • Emphasize benefit to the community – Provides income to support local landlord – In soft markets, the housing is being used that might otherwise have been vacant – Under SRO or PRA programs - can rehabilitate a unit and improve the neighborhood – Highlight the involvement of case managers in participant’s recovery plans S+C Program Components • • • • Tenant-based rental assistance Sponsor-based rental assistance Project-based rental assistance Mod Rehab for Single Room Occupancy Tenant-Based Rental Assistance Applicant States, units of government, or PHA Entity administering RA Applicant or other contracted entity Type of housing Scattered-site Living Requirements May specify particular structure for first year Term of Assistance 5 years for new grant; 1 year renewals Sponsor-Based Rental Assistance Applicant Entity administering RA States, units of government, or PHA Applicant or other contracted entity Type of housing Variety of housing types - owned by applicant or sponsor Living Requirements Must live in the specified property Term of Assistance 5 years for new grant; 1 year renewals Project-Based Rental Assistance Applicant Entity administering RA States, units of government, or PHA Applicant or other contracted entity Type of housing Variety of housing types Living Requirements Must live in specific property named in application Term of Assistance 5 years for new grant; 1 year renewals Difference Between SRA & PRA SRA PRA Must live in property owned by applicant/ sponsor Portability of S+C may be possible if SRA is scattered-site model Must live in site-based housing identified in grant Portability is not possible Mod Rehab for SRO Applicant Entity administering RA States, units of government, or PHA PHA Type of housing SRO dwelling units Living Requirements Must live in the SRO structure identified in grant Term of Assistance 10 years for new grant; 1 year renewals Grant Funding Basis • Easy math – Fair Market Rate (FMR) x # of units by bedroom size x 60 months = grant fund – SRO mod rehab - x 120 months – Renewal - x 12 months Grantee • Direct recipient of HUD award – Legal entity accountable for grant – Responsible for communication with HUD – Must process funding requests timely • • • • Monitored by HUD May carry out project itself or with sponsor Monitors sponsor Maintains records Sponsor • Provides the supportive services • Works with grantee – Makes requests for program changes – Assists with APR Service Provider • Sometimes the same as sponsor • Provides some or all of services • Must keep documentation on participants HUD • • • • • Program oversight Funder Reviews application Monitors project Technical assistance HUD Access to Files Grantee, Sponsor, and Participants must allow HUD access to all case files related to housing, assessment of services needed and matching supportive services. Memorandum of Understanding • Outlines responsibilities of each partner • Should start at application and be formalized at award • References to everything required by law, HUD, OMB Memorandum of Understanding • • • • • • Scope of work Time of performance Compensation & method of payment Program income Tenant selection criteria Reporting & HMIS participation Memorandum of Understanding • • • • • Record keeping & documentation Termination Include budget criteria Include performance criteria Should be updated annually Benefits of S+C • • • • Do what you do best Quick turn around time Flexible models Capitalize on services & resources Benefits of S+C for CoC • Housing activity - more points in the competitive application • Tailored to the maximum amount of funding (pro rata or special projects) • Easier to implement than SHP • Renewals funded outside of CoC Supportive Services • Documentation is required to show that supportive services are provided • On-going assessments are required • Case/service/housing plans required Housing First • Housing is a choice, not a placement. • Housing is a person’s home, not a residential treatment facility. • All people have a right to safe and affordable housing. • All tenants hold property leases and have the full rights and obligations of tenancy. Housing First • Participation in services is voluntary and not a condition of tenancy. • Staff work to build relationships with tenants, particularly those who need assistance maintaining permanent housing. • Supportive services should be user-friendly and driven by tenants needs and individual goals. Housing First Approach A housing first approach rests on two central premises: • Re-housing should be the central goal of the work with people experiencing homelessness, and • By providing housing assistance and follow-up case management services after one is housed, we can significantly increase the time that someone maintains housing and decrease the risks of further homeless episodes. Harm Reduction • People deserve safe and affordable housing regardless of their special needs. • Services aim to help people reduce the harm caused by their special needs, e.g., substance abuse, mental illness, health-related complications. Harm Reduction • Services focus on helping tenants stay housed by assisting with the management of the problems that interfere with their ability to meet the obligations of tenancy. • Tenants are encouraged to explore obstacles toward their goals in an open and non-judgmental atmosphere where they can contemplate costs and benefits of receiving treatment for their special needs. S+C is NOT Section 8!!!!! • • • • • • No criminal background restrictions required No credit check/rental history required Chemical addiction can be the only disability No set HAP payment for all clients No minimum rent paid by participants Tenant cannot pay >30% of adjusted income S+C is NOT Section 8!!!!! Continued • • • • Admin costs must be earned Reasonable rent only a standard No portability beyond service area No penalty in rent for those sanctioned under TANF • May only terminate for significant problems Document Everything • • • • • • • • Homeless & disability status Housing inspection Assessment of needs; services provided Third party verification of income Rent calculation; rent to owner Damages & deposits Admin costs Basis for fund draws from LOCCS Participant Eligibility • HOMELESS - lack resources to obtain housing • Severely disabled adults • Low-income households S+C Homeless Status • Streets - places not meant for human habitation • Emergency shelter • Transitional housing - must trace back to streets/emergency shelter ** this was changed in 2005 Who is NOT HOMELESS • • • • • • Paying > 30% of income Living in overcrowded conditions In substandard housing Living with roommates or relatives S+C to keep people in their existing home In program/institution in which a discharge plan that must address housing Who is NOT HOMELESS Continued • • • • • Leaving directly from prison Wards of the state or those in foster care Individuals in state psychiatric hospitals Evicted or foreclosed upon persons TH participants that did not come from streets or emergency shelter first Documentation • All documentation should be: – Signed – Dated – Maintained in client files Documenting Street Homelessness • Signed and dated letter from staff working with person on the streets OR • Self-certification statement and notes about your agency’s effort to confirm Documenting Emergency Shelter Homelessness • Signed and dated letter from shelter on letterhead – Date of entry into shelter and – Residing in shelter for homeless Documenting Transitional Housing Homelessness • Signed and dated letter from TH agency on letterhead – Date of entry into TH for the homeless – Homelessness prior to TH was ES or streets Documenting Hotel/Motel Homelessness Must be in hotel/motel in lieu of shelter • Signed/dated letter on letterhead from agency paying for hotel/motel – Staying in hotel/motel paid by agency – Date of entry into hotel/motel – Homeless prior to placement (details of prior living situation) Chronically Homeless • HOMELESS – 1 continuous year or – 4 episodes of homelessness in past 3 years • Unaccompanied adult • Disabled • Must come from streets or emergency shelter Documenting Chronic Homelessness • Documentation of homelessness • Documentation of disability • Documentation of being unaccompanied • Documentation of length of homelessness – Signed/dated letter describing time(s) in shelter – Signed/dated letter describing time(s) on street S+C Disability or Diagnosis • • • • • • • Serious mental illness; and/or Chronic problems with alcohol, drugs or both; and/or HIV+ or related diseases Developmentally disabled Physical disability Traumatic brain injury (TBI) Dual or multiple diagnosed Documenting Disability • Target population documentation – Disability verification form • • • • • Statement of disability Type of disability Disability must be of indefinite duration; Disability impedes ability to live independently; Disability would be improved by housing & supports; OR • Developmentally disabled Documenting Disability • Physician/psychiatrist’s – Name – License number – Signature/date Who is Disabled • For families, the person with a disability must be an adult Who is Not Disabled • Short-term illness/injury • Impairment does not impede independent living • Ability to live independently wouldn’t be improved with housing/services Project Performance Goals • 6 months or more in permanent housing – Milestone is 77% • Employment at exit – Milestone is 20% Other Potential Performance Measures • • • • • Exiting with Mainstream Resources Capacity Eligible prior living situations Reasons for leaving/destination Meeting match/leverage funds proposed Outreach and Retention Strategies • Anticipate high turnover rates • Understand that outreach may take time • Case managers need to assist with the application process • Supportive services are key - identify goals; engage in services Tracking Services and Outcomes • Document the value of services – Billing reports • Document client progress – Case notes S+C Match & Leverage • 1:1 match/leverage • You must document match/leverage in your files – Match/leverage should be consistent with new/renewal application – Match/leverage should be consistent with APR S+C Match & Leverage • Supportive services can be delivered by grantee, sponsor or other provider • Include all household members • Include all supportive services tenant receive to help maintain their independence – – – – Medical Substance Abuse Education Housing Placement - Mental Health - Child Care - Employment Search - Other S+C Match & Leverage • Services must match S+C funds over course of grant – Not tenant by tenant – Over 5/10 years for new grant – Year to year for renewals • Service amounts may vary • Service amounts may taper off S+C Match & Leverage • Document services received in files – In tenant files, case manager notes, charts – Worksheet for documenting service hours • Services documented on worksheet must match notes in files – Document financial value of services • Personnel costs (salary & benefits) - calculated at hourly rate x hours of service to tenant = financial value S+C Match & Leverage • Documenting Value of Other Services – Medicaid valuation – Veteran’s health care valuation – Medicare valuation – Fees or tuition charged Final Funding End Dates for 5 Year Grants • FY04 cannot go beyond 9/30/11 - latest renewal year 2010 • FY05 - 9/30/12 - latest renewal year 2011 • FY06 - 9/30/13 - latest renewal year 2012 • FY07 - 9/30/14 - latest renewal year 2013 • FY08 - 9/30/15 - latest renewal year 2014 HEARTH Act likely to come into play in 2011 Calculating Rent - Definitions • Gross Rent: total rent being charged by landlord • Fair Market Rate: HUD calculated gross rent estimates for each community Calculating Rent Higher of: • 30% of monthly adjusted income OR • 10% of monthly gross income • Include: – Wages, overtime,salaries, bonuses, tips, etc. – Entitlement (welfare assistance) – Payments in lieu of earnings • Unemployment, disability, worker’s comp, severance, etc. – Periodic payments • Retirement, pension, disability/death benefits, etc. Calculating Rent • Income inclusions • Income exclusions • Income adjustments Income Inclusions • Wages, salaries, military pay • Payments from Social Security, retirement, disability, pension • Unemployment, Worker’s Comp • Entitlement/welfare assistance • Alimony/child support Income Inclusions • Net income from business/profession • Interest, dividends, & net income from real and personal property • Armed Forces pay/allowances Income Exclusions • Don’t include: – < 18 year old employment income – Payments for foster children care – Lump-sum additions (inheritance, insurance payment, settlements) – Resident service stipend – Educational-related income (scholarships, grants) – Temporary, non-recurring, or sporadic income – Amounts received under government funded training programs Income Exclusions • Don’t include: – – – – Medical expense reimbursements Income of full-time students over 18 Food stamp/WIC income Matching funds from Individual Development Accounts (IDA’s) ** Check other income exclusions Income Adjustments • Dependent Allowance – $480 must be deducted from annual income for each dependent. Dependents include household members who are under 18, handicapped, disabled, or full-time students, but not any of the following: family head, spouse, or foster children. Income Adjustments • Child Care Allowance - can be deducted in the following conditions: – Child(ren) are 12 years old or under; – Participant is employed or enrolled in school while dependent is receiving care; – Amount deducted as child care expense is necessary for work or school – Participant is not reimbursed for this expense Income Adjustments • Disabled Assistance – Reasonable expenses for attendant care, auxiliary equipment that allows disabled household member or another adult to work – Amount of expenses exceeds 3% of annual gross income Income Adjustments • Medical Expenses – Can only be deducted if HOH or spouse is at least 62 years of age, handicapped or disabled – Non-reimbursed medical expenses that exceed 3% of annual gross income Income Adjustments • Elderly/Disabled Family – $400 per elderly/disabled family member who is at least 62 years old, handicapped, or disabled Income Adjustments • Utility Allowance – If tenant pays utilities, you must calculate a utility allowance for unit based on HUD’s utility allowance - can secure that information from local PHA – If utility allowance exceeds adjusted resident rent, the tenant should receive a reimbursement of the difference (can pay utility company) – If utility allowance is less than the resident rent, the allowance is subtracted from the monthly rent Calculating Rent • Utility Allowance – If utilities (gas, electric, trash, water, sewer) are not included in rent, include utility allowance when calculating tenant rent contribution. – Local PHAs have utility allowance schedules. Recertifications • Income and tenant rent must be calculated annually • Tenants may request re-calculation if there is a change in family composition or decrease in income • Grantee can determine in which circumstances other re-calculations are deemed necessary • Tenant must agree to supply documentation • Self-declaration can be used if no other options Documentation of Tenant Rent • Document amount of tenant rent collected and how it was calculated • Maintain rent calculation worksheet in file • Maintain documentation of tenant’s income sources in file Rent Reasonableness • S+C grantees must ensure that they are paying rents that are reasonable in relation to comparable units. Comparability should consider location, size, type, quality, amenities, facilities, and management services. • Reasonable rents for comparable units • Landlord does charge more for comparable unit Intake & Assessment • HMIS data elements at minimum • Release of information • Documentation of disability & homelessness • Housing case plan May include: • Self-sufficiency matrix • Housing history • Psycho-social assessment Survey the Housing Stock • Assess the available housing that could meet the needs of your target population. • If planning to target those that have been resistant to services - may need a more supervised setting; or housing near one another so that case managers can check frequently. • Foster relationship with landlords and property managers. Landlord Engagement • Certainty of payment • Assurance of supportive services • Support from the sponsor if any problems arise • Educate on the value to the community of expanded housing opportunities for people with disabilities Resident Occupancy • Initial occupancy agreement must be for 1 month, automatically renewable upon expiration, except with prior notice. • Grantee may require supportive services as a condition of participation. • Rental assistance may continue for up to 90 days while participant is receiving inpatient care. Resident Occupancy • If unit is vacated before end of occupancy agreement, S+C may assist with the remainder of the month plus up to 30 additional days. Quic kTime™ and a TIFF ( Unc ompres s ed) dec ompr ess or are needed to s ee this pic ture. Outreach Methods and sources of finding new participants Regulations (24 CFR 582.325) requires grant recipients and partners to focus outreach on those living on the streets or in shelters Accessing Mainstream Resources • Assessment of needs • Comprehensive process for referrals • Eliminate barriers • Achieve outcomes Landlord 101 • Meet with realtor/landlord associations – Provide trainings for them • • • • Discuss participant selection criteria Explain services to be provided Create fund for repairs/damages Pay S+C share of rent on time Termination • • • • • Termination is last resort Due process Program rules Occupancy agreement - 1 month minimum Role of grantee and sponsor (MOU) Termination vs. Eviction • Termination - cease participation in program – Grantee • Eviction - court ordered – Landlord Line of Credit Control System - LOCCS • HUDs accounting & grantee reimbursement system • Line of credit established for new programs • Allows grantee to be paid directly from Federal Reserve LOCCS • • • • • Draw down fund regularly Should draw down every month Track expenditures Determine number of households served Delays in draw downs may call into question your grants management Client Files • • • • • • Application Lease Initial assessment Rent calculation worksheet Housing plan Re-assessments Client Files • • • • • Income verification HQS inspection Homeless documentation Disability documentation Exit documentation Grant Files • • • • • • • • Exhibit 2 Notification letter Technical submission Executed grant agreement Approved grant amendments Operating instructions APR Correspondence with HUD Financial File • • • • Audited financial statement Draw requests Proof of payments Budgets Keep on Target! • • • • Know the # of units contracted by BR size Know the population to be served Know the whereabouts of participants Know and keep current assessment of participant’s needs • Know services provided to participants • Know grant term and end dates Staying on Target • • • • Know reporting dates Know S+C resource materials Know current occupancy Knox activities/responsibilities of grantee, sponsor, and HUD • Know what the grant application, MOU, and grant agreement states • Know when to renew grant Keep Track of the Funds • Spreadsheet of funds by month/quarter • Budget for admin and rental assistance by month • Calculate demand for funds (1, 5, 10 Y) • Keep funds for future rent increases • May add units if funding allows Spend Funds in a Timely Manner • • • • • Keep project full For 5 Y grant - draw 1-2%/M or 4-6%/Q For 1 Y grant - draw 8-9%/M Complete monthly draws Lack of progress may result in loss of funds at grant close and cause monitoring issues Program Procedures File • • • • • • Program guidelines Conflict of interest HUD directives Confidentiality procedures Equal Employment Opportunity (EEO) Grievance procedures Housing Quality Inspections • Unit must pass HQS inspection prior to tenant moving in • Complete a HQS form such as HUD52580 and maintain in file Lead •Visual lead inspection is required on every unit and the sign off is included in the HUD HQS form •An online visual assessment course is available at: http://www.hud.gov/offices/lead/training/visualassessment/h00101.htm Federal Requirements • • • • • • Davis-Bacon Uniform Relocation Assistance Environmental Review ADA and Section 504 Lead-based Paint Fair Housing Davis-Bacon Wage Requirements • Applies to SRO with 9 or more units • Prevailing wage • Documentation maintained on contractors and subcontractors Uniform Relocation Assistance and Real Property Acquisition • • • • Federal relocation requirement Minimize displacement Timely notice Must be provided comparable unit Environmental Review • Complete environmental required for: – Acquisition – Rehabilitation – New construction • Limited environmental required for: – Leasing only projects • TRA projects are excluded ADA & Section 504 • Protects against disability discrimination • Cannot deny opportunity to participate • Reasonable accommodation Lead-Based Paint • All federal laws and regs apply • Provide lead handbook www.epa.gov/lead/pubs/leadpdfe.pdf Monitoring • • • • CPD Monitoring Guide Assess performance overtime Internal management control Review of funds expended Outcome Monitoring • Checking compliance is not enough • Failure to meet commitments of Technical Submission can result in: – HUD taking funds back – Renewal not being approved Monitoring - Risk Analysis • • • • • • New grantee and/or sponsor Staff turnover Local capacity Previous monitoring findings Poor performance Program complexity Monitoring - Methods • Types – On site – Off site (desk review) • Varieties – HUD monitors grantee and/or sponsor – Grantee monitors sponsor – Grantee monitors self – Sponsor monitors self Monitor What • • • • Program goals Client files Entire project Entire sponsor Off Site Review • • • • • • • • • Application Technical submission Grant agreement APR HMIS reports Draw requests Audits & other fiscal issues Policies and procedures Records On Site Review • Review files – Random sample • • • • • Interview staff Interview participants View subsidized units Sample time & activity sheets Rent reasonableness checklist Steps for Onsite Monitoring • • • • • • Conduct pre-monitoring analysis Send notification letter Convene entrance conference Acquire & analyze data Hold exit conference Issue monitoring follow-up letter Monitoring Documentation • Keep a written record – Steps followed – Information reviewed – Monitoring follow-up letter – Plan of correction Recapture Funds • Noncompliance with grant agreement • Slow expenditure of funds • Actual costs are lower than anticipated costs • Unspent funds remain • Ineligible, unallowable, or undocumented costs Grant Amendment • Significant changes to program • Substantial effect on implementation • Adding new services or changing overall goals • Change of grantee or sponsor • NOT an automatic Grant Extension • NOT an automatic • Must be able to carry out project • May affect ability to apply for/renew grants Uses of S+C Funds • Payment to property owner; utility company; and/or tenant • Damage deposits (equivalent 1 M rent) • Damage payments (equivalent 1 M rent) • Admin fee (up to 8% of funds) Administrative Costs • Receiving new participants • Providing housing information & search • Determining participants income & rental contributions • HQS inspections • Processing rental payment to landlords Administrative Costs • Up to 8% of the grant - ONLY if there is enough funds to cover rental costs for all planned participants for the full term • Eligible admin costs include only those related to the administration of the housing, NOT costs associated with the admin of grant or supportive services Merged S+C Grants • Can merge 2+ grants as long as the same component • Both must be at renewal status • Request extension to be completed to obtain same start date • Consolidation happens at contract completion • Contact CPD Rep before taking action S+C Best Practices Coordinating committee – City/County representatives – Grantee representatives – HUD field office representative – Sponsor(s) representative(s) – Property management representative – Supportive service representatives S+C Best Practices Regional Coalition • Share information about project experiences and resource needs • Discuss ways to recruit landlords • Educate on impending legislation S+C Best Practices Case Management Teams • Teams meet regularly to discuss progress and coordinate services • Share experiences and information • Discuss different approaches to care • Clients benefit from plans that reflect input from multiple professionals. Remember You are serving a population that needs reasonable accommodation and a frail population with special needs. Think of the S+C participants and their unique and special needs. Moving Beyond S+C • As participants become more stable, they may choose alternative housing. • Self-sufficiency - no longer need subsidy • Subsidized housing - linkage with PHA; Section 811 program • Movement to other housing - opens up S+C to new participants Enhancing S+C Operations 1. 2. 3. 4. 5. 6. 7. 8. Introduction Getting Your Project Off the Ground Property Acquisition and Financing Participant Outreach and Retention Strategies Tracking Supportive Services Grant Administration Moving Beyond S+C Conclusion S+C Resource Manual Please note that Manual is out-dated • Provides information on: – – – – – – – Goals, components, roles Eligible participants, use of funds Leasing, rent calculation, LOCCS Supportive services match Record keeping Renewal & extension Requirements Title IV of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11403-11476) • S+C - 24 CFR Part 582 Certifications Continued • • • • Maintenance of effort Provide services specified in application Non-profit board members are not paid No participant, board member, or contractors are debarred • Applicant/grantee is qualified to participate 15 Minutes of Fame Use public money wisely, in a way that makes sense, complies with the requirement of the program, your approved application, grant agreement and the intent of Congress…. When in doubt - do you want to explain your actions to HUD or the 6 p.m. news? Practices to Avoid • Do not make people homeless to serve them • Do not serve grantee/sponsor agency staff’s friends and relatives (if needed seek waiver from HUD) • Do not serve people in housing they already occupy • Avoid recruiting clients from facilities in which a discharge plan needs to be in place • Do not use units owned by participant’s relatives Complete and submit your APR on time. Have a Board Member who is homeless or formerly homeless. Ensure that all units pass Housing Quality Standards and make sure all inspections are on file. Complete timely assessments of client needs and have documentation of adequate supportive services. Ensure that tenant rents are calculated correctly - including deductions for disabilities, day care, out of pocket medical expenses, etc. Utilize OMB approved accounting standards. Make certain that you keep documentation for costs billed to grant - invoices, leases, timesheets, etc. Guarantee that homeless and disability eligibility documentation are in the file. Keep your project full and spend your funds on time. Communicate & Ask Questions * Partners * CoC Lead * TA Provider * HUD Information for this Training Came From • http://www.hud.gov/local/mn/working/cp d/annualshelter.cfm • http://www.hud.gov/offices/cpd/homeles s/programs/index.cfm • Shelter Plus Care Resource Manual • Enhancing S+C Guide • CPD Monitoring Handbook Questions Coalition on Homelessness and Housing in Ohio Jonda Clemings, MSEd, LSW 175 S. Third St. - Suite 250 Columbus, Ohio 43215 Phone 614-280-1984 Fax 614-463-1060 www.cohhio.org [email protected]