Transcript Indiana HPRP Training MODULE 2: HPRP PROGRAM TOOLS 1

Indiana HPRP Training
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MODULE 2: HPRP
PROGRAM TOOLS
HPRP consists of two programs
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 Homelessness prevention to assist
households not literally homeless, avoid becoming
homeless
 Rapid Re-housing for those households who have
become homeless to get them back into stable
housing
HPRP Eligible Activities – Same for both
program components
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 Financial Assistance
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Short and medium term rental assistance
Security deposits
Utility deposits
Moving cost assistance
Hotel/motel vouchers
 Housing Relocation and Stabilization
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Case management
Outreach and engagement
Housing search and placement
Legal services
Credit repair
HPRP Eligible Activities (2)
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 Data Collection and Evaluation
 HMIS
 Evaluation
 Administrative costs
 Accounting for grant funds
 Preparing HUD reports
 Program audits
 Staff costs associated with activities
 Staff training
 Not to exceed 5% of HUD grant; IHCDA retained 3%
Financial Assistance
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 Limitations:
 No direct payments to program participants
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Payments must go to 3rd parties: landlords and utilities
Assisted units may not be owned by grantee, subgrantee, or
parent, subsidiary or affiliated organization of subgrantee
Rental Assistance
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 Short term up to 3 months
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Must be evaluated at the end of 3 months prior to receiving
continuing assistance
 Medium term cannot exceed 4-18 months
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(Special procedures in Indiana for rental assistance in excess of 12
months)
Re-evaluated for assistance every 3 months
 Assistance limited to actual rental costs
 Months of rental assistance do not have to be consecutive
 All rents assisted must meet HUD’s rent reasonableness
requirements, not FMR.
Rental Assistance (2)
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 No double dipping: no assistance for same cost types that
are covered by any other federal, state or local housing
subsidy program
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It can pay for deposits or utilities if participant is not receiving
assistance with these cost types from any other program
 Participants are required to pay rent – Indiana program
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Tenant share must be the greater of: 30% of adjusted income or 10%
of gross income
 Up to 6 months of rent arrears may be paid
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Arrearages paid count toward 18 month limit
Can be paid if it allows participant to remain in unit or move to
another unit
Security and Utility Deposits
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 Deposits can cover same period and unit as other
subsidy program
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HUD emphasizes use of deposits to assist veteran-headed
households receiving VASH assistance
 Programs should track deposits and make good faith
effort to secure return
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Notify landlord and/or utility to whom deposit should be
returned
Utility Payments
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 Payments can be made for up to 18 months
 In Indiana, waiver required to receive utility payments for
longer than 12 months
 Can provide up to 6 months of arrearages payments.
No time limit on when arrearage occurred.
 Must have responsibility for debt
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Utility account in name of participant or member of household
Evidence of prior payments such as cancelled checks or
receipts from utility
Moving Cost Assistance
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 Reasonable moving costs
 Truck rental, moving company
 Storage fees for belongings
 Maximum of 3 months or
 Until participant is in housing
Motel and Hotel Vouchers
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 Indiana: only permitted when appropriate housing
is already identified but will not be available for a
period not to exceed 30 days
 Costs must be reasonable and appropriate
Housing Relocation and Stabilization
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 Services can only be provided for up to 18 months for
participants
 Services include:
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Case management
Outreach and engagement
Housing search and placement
Legal services
Credit repair
Case Management
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 Use uniform assessment tool
 Arranging, coordinating, monitoring services all
targeted toward achieving and maintaining housing
stability
 Counseling – related to achieving housing
permanency.
 Working with client to develop and maintain housing
and services plan
Outreach and Engagement
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 Allow people who are homeless or at risk of
homelessness to be aware of HPRP services
 Recognizes that engagement may require multiple
contacts and allows for innovative strategies
 In Indiana, largely the responsibility of each
Continuum of Care.
Housing Search and Placement
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 Outreach and support to landlords to secure
participation
 Tenant counseling – responsibilities, understanding
leases
 Assisting clients locate housing, obtain utilities,
moving arrangements
 Representative payee services for rent and utilities
Legal Services
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 Eviction prevention
 Related services to keep tenants in their homes
 Cannot assist in resolving mortgage or foreclosure
issues
 Not to be used for general debt concerns
Credit Repair
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 No payment of personal financial obligations
 Skills training in budgeting and money management
 Support in resolving credit issues
Data Collection
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 Eligible use of HPRP funds
 Must use HMIS for data collection
 Eligible costs:
 Purchase of HMIS software/user licenses. IHCDA has a 1% fee.
 Leasing/purchasing computers
 Data collection, entry and analysis
 Ineligible
 Planning and developing HMIS systems
 Development of new software systems
 Replacing state/local funding for existing HMIS
Administrative Costs
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 Accounting for use of grant funds
 Preparing reports for HUD
 Program audits
 Similar costs related to administering grant post-
award
 Training specific to learning about HPRP
 Do not include:
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Costs of issuing financial assistance
Providing services
Carrying out housing inspections, etc.
HPRP Program Eligibility
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 Any individual/family receiving financial assistance must at
least have initial consultation with case manager
 Household income cannot exceed 50% AMI
 All participants must be documented to be:
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Homeless
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HUD definition – streets, shelters, places not meant for human habitation
People being imminently discharged from publically funded institutions
(health care, foster/youth care programs, corrections)
Graduating or timing out of transitional housing
Domestic violence victims or
At Risk of Homelessness
 And meet both of following:
 No appropriate subsequent housing options are identified
 Household lacks financial resources and support networks to obtain
immediate housing or remain in its existing housing
Two Eligibility Paths
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Central Intake
Homeless
Assessment of
Ability to
Maintain
Housing
Assistance in
locating
housing
Risk of
Homelessness
Initial 3 month
assistance
Assessment of
ability to
maintain
housing
Quarterly Certification
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 Eligibility must be re-certified quarterly for all
participants receiving financial assistance
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Income eligibility
Continuing need for financial assistance
Likelihood of sustaining housing at end of HPRP assistance
Documentation of Homelessness
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 All participants who are eligible for assistance
because of their homeless status must have
documentation of status:
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Letterhead from shelter, outreach provider, etc.
Documentation from institution that discharge is imminent
Outreach team documentation
 Documentation should indicate that household lacks
resources or support in community to obtain housing
without HPRP support
Homeless Prevention Eligibility
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 Risk of homelessness must be documented
 Responsibility for debt must be established prior to
HPRP payments
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Participant must be legal resident of premises prior to obtaining
short or medium term rental assistance
Participant must be responsible for paying rent or utility bills
Named on lease
 Named on utility account
 Evidence (receipts, etc.) that participant has paid these bills in the
past
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As part of evidence of risk of homelessness, documentation should
exist that required payments have not been made or participant lacks
resources to make necessary payment
Determination of Risk of Homelessness
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 Risk of losing housing
 No housing options identified
 No financial resources and/or support networks to remain in
housing or locate other housing
 Would client become homeless but for this assistance
 Can be used to assist persons graduating or timing
out of transitional program to obtain permanent
housing
Changed homeless definition in HEARTH Act
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 “Homeless” will also include:
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Imminent risk of homelessness
Must leave current housing in the next 14 days
 No place to go
 No support network or resources to obtain housing
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Family or unaccompanied youth is living ‘unstably’
Defined as homeless under other Federal programs (DOE Education
for Homeless Youth and Children)
 Have lived for a long period without living independently in
permanent housing
 Have moved frequently
 Will continue to experience instability because of disability, history of
domestic violence or abuse, or multiple barriers to employment
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Assessment must document risk of homelessness
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 Risk factors include:
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Eviction in 2 weeks from private dwelling
Discharge in 2 weeks from institution
Sudden and significant loss of income
Sudden and significant increase in utility costs
Mental health and substance abuse issues
Severe housing burden
Homeless in last 12 months
Young head of household
Current or past child welfare involvement
Pending foreclosure of rental housing
Extremely low income
High overcrowding
Risk Factors (Cont)
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History of institutional care (corrections, treatment, hospital)
Recent traumatic event to household (illness, death)
Credit problems that preclude access to housing
Significant medically-related debt
Risk of Homelessness in HEARTH Act
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 Income below 30% of AMI
 Move frequently for economic reasons
 Live doubled up
 Face eviction
 Live in hotel/motel
 Live in severely overcrowded housing
 Exiting an institution
Ineligible Uses of Funds
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 Cannot use HPRP to move a household into transitional
housing
 Cannot support transitional housing programs
 Operating costs for any program are ineligible
 Prohibited activities and expenditures
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Construction or rehabilitation
Credit cards, consumer debt,
Car repair or transportation
Food
Medical/dental care and medications
Pet care
Entertainment
Work or education materials
Ineligible Activities (Continued)
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 Development of discharge plans from institutions
 Can provide assistance to persons being discharged
 Cash assistance to program participants
 Child care
 Employment training
 Clothing/grooming
 Fees cannot be charged to program participants
Accessing HPRP Assistance – Homeless
Participants
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Central Intake
Assessment
Develop housing
plan
Housing Search
assistance
Verify
income/household
composition
Homeless Participants – Requirements for
Housing Unit
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Locate Unit
Landlord
signs
agreement
Unit
inspected for
habitability
Visual
assessment
for lead paint
Rent is
‘Reasonable’
Prior to Receiving Rental Assistance
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 Housing must be inspected
 Prior to assisted household occupying unit
 Every 12 months
 Unit must meet HPRP standards or repaired/re-inspected
 If the participant is not moving to a new unit, the current unit does
not need to be inspected prior to receiving rental assistance.
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Must be re-inspected if assistance goes over 12 months
State and local building and housing codes should be considered when
deciding to provide rental assistance
 Any unit that will house a child under 6 years old must be visually
assessed for lead based paint hazards
 Documentation of inspection must be maintained
 A lease must be in place and the program participant must be on the
lease to receive rental assistance
Overview of Lead Based Paint Requirements
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 Exemptions from requirements
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Any unit constructed after January 1, 1978
All 0-BR, Studio units
 For non-exempt units that will be occupied by children 6
and under:
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Visual assessment must be performed by HPRP agency
If deteriorated paint surface is found:
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Paint stabilization must be performed using ‘safe work practices’
 Occupant protection
 Specialized cleaning after hazard reduction activities
If abatement work occurs, unit must be visually assessed again to
verify that hazard has been removed
Must be re-assessed every 12 months and anytime a new household
occupies unit
Rent Reasonableness
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 Rental assistance cannot exceed actual rental cost
 Must comply with rent reasonableness
 Cannot exceed rents charged by owner for comparable units
 Must be reasonable when compared to the costs of comparable
units in the community
Location, quality, size, type and age of unit
 Amenities, services and utilities provided by owner
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 Go Section8 software will allow easy determination
of rent reasonableness.
Double Dipping
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 No rental assistance from HPRP if:
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Payments are being received from another federal, state
or local program for same cost types
Rent
 Security deposits
 Utility deposits
 Utility payments
 Moving cost assistance
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Time Limits on Assistance
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 Housing relocation and stabilization (including case
management) limited to 18 months/program
participant
 Rental Assistance cannot exceed 18 months
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Up to 6 months of rent arrearages in 18 month limit
Indiana: participants may only receive 12 months of rent
assistance unless term is extended
Participants must pay rent
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 Use HUD methodology
 Tenant rent payment can be used to pay utilities (up
to utility allowance)
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If tenant rent exceeds utility allowance, balance must be paid
to landlord
If tenant rent is less than utility allowance, HPRP can pay
balance of utilities (up to allowance) directly to utility
NO PAYMENTS CAN BE MADE DIRECTLY TO
PARTICIPANTS
Tenant rent payment
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 Every person receiving rental assistance (short or
medium term) supported by HPRP must pay as rent
(the higher of):
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30% of adjusted income
10% of gross income
Process of determining tenant rent
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 Step 1: Calculate Annual Income – including and
excluding required amounts
 Step 2: Adjust income for allowable deductions
 Step 3: Determine which approaches produces the
highest tenant payment and calculate subsidy
amount
Annual Income Includes
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 All amounts to all family members
 Anticipated over upcoming year
 Amounts obtained from assets
 Regs: 24 CFR 5.609
Sources of income to include
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 Wages and salaries
 Net income from business/profession
 Interest and dividends
 Social security, annuities, retirement, pensions
 Unemployment, worker’s comp
 Welfare payments
 Alimony & child support
 Armed forces pay
Income that is not included by HUD
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 Income from employment of children under 18 years
 Payments for foster children
 Lump sum additions (inheritances, insurance, capital gains)
 Funds for medical expense reimbursement
 Income of live-in aide
 Student financial aid provided to student
 Hostile fire pay (armed forces)
 Amounts received under HUD funded training programs
 Temporary, non-recurring, or sporadic income (incl. gifts)
 Reparation payments
 Earnings over $480 for full-time student 18 or older
Income not included (Cont.)
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 Adoption assistance payments over $480/adopted child
 Deferred periodic amounts from SSI/SSD
 Rebates of property taxes
 Payments on behalf of developmentally disabled family
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member living at home
Food stamps
Domestic volunteer service payments (VISTA)
LIHEAP payments
Earned income tax credit
Payments under Job Training Partnership Act
Native American/Alaskan Native claim settlement
Income Deductions
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 24CFR5.611
 $480/dependent
 $400/elderly or disabled family member
(1/household only)
 Expenses greater than 3% of annual income for:
Unreimbursed medical expenses
 Unreimbursed attendant and equipment
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 Reasonable child care to permit family member to
work or further education
Treatment of Assets
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 Cash value of all assets must exceed $5000 to be
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considered
Income from assets must be included in annual income –
not assets
Greater of actual income or imputed income from assets
Income should be imputed based on passbook rate applied
to cash value of assets
Cash value = market value minus cost of converting asset to
cash
Income Verification
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 Wages and Salaries:
 Pay stubs, earnings statement, W-2 form
 Signed and dated statement from employer
 Statement from employer based on phone or in-person contact
 Tips/Self-employment
 Tax returns
 Notarized statement from applicant (tip: have or locate a
notary)
Income Verification – 2
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 Assistance benefits (TANF, Workers Comp, SS,
unemployment, etc.)
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Copy of benefit check
Copy of award letter
Verification form from agency
 Child support payments
 Copy of court records
 Copy of payment check
Income Verification – 3
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 Interest/Dividends
 Passbook/bank statement
 Income tax return
 Assets
 Passbook/bank statement
 Tax assessment or appraisal of real property
Income Verification – 4
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 Child Care expenses
 Receipts/cancelled checks
 Statement from child care agency or babysitter
 Itemized list signed by applicant
 Medical expenses
 Receipts/cancelled checks
 Statement from physician/hospital
Timeliness in Expending HPRP Funds
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 All Indiana HPRP funds must be expended by
September 30, 2012 (36 months after grant
agreement)
 Participants must be receiving HPRP rental
assistance by (24 months after grant agreement) in
order to receive 12 months of assistance.
 65% of Indiana HPRP funds ($...) must be expended
within 2 years of grant agreement
Reallocation
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 HUD may reallocate grant funds not expended
within 24 months; all funding will be lost in 36
months
 Indiana subgrantees that fail to expend HPRP
resources on a timely basis may have funds
reallocated to other subgrantees
Requirements on Termination of Assistance
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 Assistance can be terminated to a program
participant who violates program requirements
 Assistance can be resumed to a terminated
participant
 In order to terminate due process must be followed:
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Written notice, providing clear statement of reasons for
termination
A review of the decision in which the terminated person can
present written or oral objections before a person other than
the one making the termination decision
Prompt written notice of final decision
Confidentiality Requirements
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 Grantees and subgrantees must develop and
implement procedures to ensure:
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Confidentiality of records pertaining to any individual
receiving HPRP assistance
The address or location of assisted housing will not be made
public
Conflict of Interest
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 No employee of subgrantee or person who participates in
decision-making for subgrantee may obtain a personal or
financial interest or benefit from HPRP assisted activities
or have any interest in a contract, subcontract or
agreement with respect to HPRP funds for individual or
those that the individual has a family or business tie.
 This covers the period of employment and for one year
post-employment
 HUD may grant an exception to above
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Requires opinion of grantees attorney that the interest for which the
exception is sought would not violate state or local law
Equal Participation of Religious Organizations
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 Religious or faith-based organizations can
participate on an equal footing with any other
organization
 HPRP resources cannot be used for inherently
religious activities (worship, religious instruction or
proselytizing)
 Participating religious organizations may continue to
carry out their missions but cannot discriminate
against participants based on religious belief
Resources made Available by IHCDA
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 IHOP
 Indiana Housing Now
 Rent Reasonableness Program
 GoSection8 Software
 On-line resources
 FMRS
 Utility allowances
 Income/rent calculation worksheets