Technical Assistance Workshop for the Project Sponsors of Harris County’s Continuum of Care Program

May 29, 2013

2012 Continuum of Care:Focus on the Basics

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Presented by:

Esmeralda Gonzalez, Public Services ManagerDemetra Davis, Project MonitorDebra Hayes, Project Monitor

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AttendeesProject Sponsors with an assigned Housing Agent

Mental Health Mental Retardation Authority of Harris County SEARCH Homeless Services Temenos Community Development CorporationVeterans Affairs Volunteers of America

Housing AgentsTexas Interfaith Management City of Houston Housing Authority

Project Sponsors without a Housing AgentAIDS Foundation HoustonCloudbreak Houston, LLC and U.S. Vets HOPWA Housing Northline SRO

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24 CFR 578.3 Definition of Permanent Housing

Community-based housing without a designated length of stayFor homeless, disabled individuals and their families Program participant is tenant on lease

For a term of at least one yearRenewable for terms that are a minimum of one month longLease which is terminable for cause

Supportive services promoting independent living must be made available

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Refer to Documentation of Homelessness Checklist

Living Situation Documentation Required (attach to this checklist)

Literally Homeless Individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning: (i) Has a primary nighttime residence that is a public or private place not meant for human habitation; (ii) Is living in a publicly or privately operated shelter designated to provide temporary living arrangements (including congregate shelters, transitional housing, and hotels and motels paid for by charitable organizations or by federal, state and local government programs); or (iii) Is exiting an institution where (s)he has resided for 90 days or less and who resided in an emergency shelter or place not meant for human habitation immediately before entering that institution

Written observation by the outreach worker; or Written referral by another housing or service

provider; or Certification by the individual or head of household

seeking assistance stating that (s)he was living on the streets or in a shelter;

For individuals exiting an institution – one of the forms of evidence above and:

Discharge paperwork or written/oral referral, or

Written record of intake worker’s due diligence to obtain above evidence and certification by individual that they exited institution

Fleeing/Attempting to Flee Domestic Violence Any individual or family who: (i) Is fleeing, or is attempting to flee, domestic violence; (ii) Has no other residence; and (iii) Lacks the resources or support networks to obtain other permanent housing

Oral statement by the individual or head of household seeking assistance that they are fleeing. This statement is documented by self-certification or by the caseworker. Where the safety of the individual or family is not jeopardized, the oral statement must be verified; and

Certification by the individual or head of household that no subsequent residence has been identified; and

Self-certification, or other written documentation, that the individual or family lacks the financial resources and support networks to obtain other permanent housing.

Documentation of Homelessness

Inadequate Homelessness DocumentationInadequate How to fix

Letter from referral source states: “Client has completed treatment and is ready

for permanent housing.”

Need documentation of client’s homelessness before treatment, and that length of treatment will not exceed 90 days.

Letter from referral states: “This letter is not to verify

homelessness.”Need documentation with details of where client has been residing.

Letter from shelter states:“He was homeless before entering our

shelter.”

Need more details: “He was homeless, sleeping at

Herman Park for 2 weeks before entering our shelter.”

Letter from shelter that client stayed there from May 1st – 15th submitted to CSD on May 22nd

Need documentation of where client slept between May 16th – May 22nd

What’s wrong with this scenario?

The Homeless Status Checklist indicates Mr. Brown was living on the streets. A mobile outreach team provided documentation that Mr. Brown was living under the bridge at I-10/Blalock. The physician’s note states that Mr. Brown is looking forward to getting permanent housing so he can stop staying at his daughters’ house.

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Documentation of Disability

Use Harris County’s “Verification of Disability” Form signed by the diagnosing professional including credentials.

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Rental Assistance 24 CFR 578.51 (a)Grant funds may be used for rental assistance and security deposits.

Maintain projections and monitor your awarded funds to cover rents and security deposits for the operating year.

Vacancies - assistance for the unit may continue for a maximum of 30 days from the end of the month in which the unit was vacated.

Case managers must keep tabs on clients; if they vacate and landlord expects rent, it will be your agency’s responsibility to resolve the matter.

In the event of a participant’s death, long term incarceration or institutionalization, surviving household members may retain the assistance until the expiration of the effective lease.

Selection of the Unit

Case Manager to assist with locating unitSuitable Dwelling Size as deemed by household size (2 persons per bedroom/sleeping area)Rent Reasonableness, Fair Market Rent Housing Quality Standards, Lead Based Paint

Fair Market RentsThe gross rent (amount of contract rent on the lease plus the amount of utility allowance) cannot exceed the Fair Market Rent for the unit.FY2013 FMR’s effective November 1, 2012 for Harris County are:

SRO $477EFF $6361BR $7652BR $9453BR $1,2904BR $1,595

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Rent Reasonableness 24 CFR 578.51 (g)The amount of monthly rent charged must be

certified as reasonable• in relation to rents being charged for comparable unassisted

units with similar features and amenities• and not more than rents currently being charged by the same

owner for comparable unassisted units

A Rent Reasonableness Request form must be submitted to CSD for approval

• before a participant moves into a unit• before lease renewals• an “all bills paid unit” begins requiring tenant to pay utilities.

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What’s wrong with this scenario?

On 5/27/13, a Rent Reasonableness Request for Ms. White was submitted indicating that the contract rent would be $450.00 effective 6/1/13. CSD certified this amount as reasonable on 5/28/13. The lease submitted with the June 2013 reports reflects $460.00 as the contract rent amount for the lease period.How can this be remedied?

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Housing Quality Standards: 24 CFR 578.75 (b)

Before any rental assistance will be provided, each unit must be physically inspected to ensure that the unit meets HQSRequests should be submitted 90 days prior to the expiration date of when the unit previously passed inspectionProblems must be corrected within 30 days from the date of initial inspectionGrantee has no funds to cover costs for periods of non-compliance

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Lead-Based Paint Requirements Regulations at 24 CFR Part 35

HUD Office of Lead Hazard Control homepage: www.hud.gov/offices/leadEPA Clearinghouse: (800) 424-LEAD

Lead Based Paint Disclosure FormPamphlet

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What’s wrong with this scenario?

The last HQS inspection passed on 5/6/12 for Ms. Smith. In preparing the reports for June 2013 rents, Sponsor Agency staff noticed that the annual inspection is past due. Ms. Smith continues to live in the same unit, so a new HQS request is submitted and the unit passed on 5/23/13. What is the solution?

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Occupancy Agreements

Information on the Occupancy Agreement must match the information on the Lease, Rent Calculation Worksheet, Persons Served Worksheet and Household Characteristics Reports

Names of all persons living in the unitrelationship to the participantdate of birth and gender

Birth Certificates and Social Security Cards must be included for dependent children in household.

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What’s wrong with this scenario?

An occupancy agreement dated 12/1/12 for Ms. Sandy and two (2) dependents was submitted. As of 5/22/13, the participant has married and has one (1) additional dependent. The annual certification is not due until 12/1/13. What needs to happen and when?

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Resident Rent Calculations24 CFR 582.310

Each resident under SPC must pay the highest of:30 percent of monthly adjusted income10 percent of monthly gross income

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Income Certification

Household income cannot exceed Median Family Income limitsInformation on the Occupancy Agreement must match the information on the Lease, Rent Calculation Worksheet, Persons Served Worksheet and Household Characteristics ReportsEffective date of the income certification should coincide with the effective date of the lease and Occupancy Agreement.If participant claims no income, Sponsor Agency obtains non-income affidavit along with a Texas Workforce Solutions wage print-out.In the event of household income loss, an Interim certification may be completed. Sponsor agency provides a non-income affidavit along with documentation of the income loss.

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CSD Programmatic Reports (on CD)Monthly Reports:

Project Status ReportHousehold Characteristics ReportHousehold Characteristics Summary Security Deposit Request (if applicable)Persons Served Worksheet

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Most common reporting issues:Incorrect income calculationRent amount on lease agreement does not match approved amount on Rent Reasonableness requestLease dates incorrect or inconsistent with occupancy agreementFailure to sign reports as indicatedLate HQS requestsHMIS certification not signed/signed but not doneInaccuracies in the Persons Served Worksheet

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Annual Monitoring

To determine compliance with HUD regulations, circulars and statutesTo determine whether activities are implemented as described in the application and APRTo verify that all required documentation is in the fileTo determine if all applicable income was used to calculate resident rent

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Monitoring Areas

Participant Eligibility

Housing

Project Progress and Overall Management

Program policies and procedures-include CSD reporting forms, application process and determining eligibility for permanent housing, case management/supportive services procedures with time frames of performance

Match Documentation

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Program Participant Records 24 CFR 578.103 (7)

Homeless and disability eligibility, records of services and assistance provided including annual assessment of services and adjustments to the service package accordingly, as well as case management services and compliance with termination of assistance, where applicable.

When you receive the notice of an upcoming monitoring visit, review the enclosed Monitoring Checklist for areas which will be reviewed.If your agency keeps electronic records, print out assessments and service plans for monitoring purposes.Closed participant files will also be reviewed for discharge summaries.Be careful when “thinning out” large files that all required documentation is available for review.

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Termination of Assistance 24 CFR 578.91Serious violations of program requirements or conditions of occupancyDue Process: formal process that recognizes the participant’s rights to the due process of law

Provide a written copy of the program rules and termination process before participant begins receiving assistanceWritten notice clearly stating reasons for terminationA review of the decision with written/oral objectionsPrompt written notice of final decision

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Participation of Homeless Individuals 24 CFR 578.75 (g)

The agency board of directors or other equivalent policy-making entity, must include at least one homeless or formerly homeless individual in decision making regarding the project.

Documentation, such as Board approval, of formal participation, listing the duties and responsibilities of how the person assists the Board with homelessness issues; andWritten statement from the individual detailing their current or formerly homeless situation.

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Annual Performance ReportsData collection requirements

The Full Annual Performance Report relies on data collected and entered into HMIS. The data must be accurate and current information.Print the APR for the operating period from HMIS and submit to Harris County along with a current Persons Served Worksheet within 30 days of the end of the operating period.“missing” or “unknown” data must be minimal.

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Responsibilities Matrix

Only for Subrecipients with Housing Agent