Introduction to HOPWA

1
Housing Opportunities for Persons with
AIDS(HOPWA)

• Introduction to HOPWA

2
Program Description

• A federally administrated grant program for state
  and local governments to develop a range of
  housing assistance and supportive services for
  low-income people living with HIV/AIDS and their
  families
• Created through the National Affordable Housing
  Act of 1990
• Authorized by the AIDS Housing Opportunity Act of
  1992
• Administered by the Office of HIV/AIDS Housing
  (OHH) at HUD headquarters
• 3.5 Billion in HUD HOPWA appropriations 1992-2007

3
Allocation of HOPWA Funds
4
HOPWA Outcome

• Assisted households will
• Have been enabled to establish or better maintain
  a stable living environment in housing that is
  decent, safe and sanitary
• Reduce risk of homelessness
• Improve access to health care and supportive
  services reduce disparities

5
Benefits to Clients

• A better housing situation more appropriate to
  needs
• Positive impact on health status through improved
  housing and access to care
• Reduce disparities in access to care

6
HOPWA Performance Goal

• By 2008 over 80 of HOPWA program clients will be
  in stable housing
• For competitive grantees, HUD expects at least
  half of beneficiaries will have stable housing
  during operating year

7
Stable Housing Outcomes

• Continuing with HOPWA assistance (TBRA or
  facility based assistance)
• Private housing
• Other subsidized housing
• Long term care/institution

8
Non-Stable Housing Outcomes

• Disconnected
• Jail/Prison
• Homeless (street/shelter)

9
Temporary Housing

• Preventing/avoiding homelessness
• Receiving STRMU and expected to need this
  assistance again in future to maintain housing
• Housing and services coordinated through Housing
  Services Plan

10
Access to Care and Services Outcomes

• Housing services plan
• Contact with case manager
• Contact with primary care provider
• Obtained health insurance/coverage
• Obtained employment

11
Client Eligibility Requirements

• Low income and living with HIV/AIDS
• People with documented HIV or AIDS
• Individuals or families with incomes at or
  below 80 of the Area Median Income

12
HIV Documentation

• Made by health professional competent to make
  determination
• Documentation from HIV tests conducted by
  physician, HIV counseling center, or community
  health center
• Case manager statement is not sufficient

13
Income eligibility requirements

• Income no greater than 80 of area median income
• Annual re-determination
• Household composition income of all family
  members over 18 counted
• Earned income disregard

14
People with Disabilities

• According to HUDs definition of disabling
  conditions, an HIV/AIDS diagnosis is considered
  a disabling condition
• Section 504 of the Rehabilitation Act of 1973
  prohibits discrimination on basis of disability
  in HUD programs
• Reasonable accommodations are required to be made
  to allow people with disabilities to participate
  in HUD programs
• Cannot provide different or separate housing, aid
  or benefits to individuals or to any class of
  individuals with handicaps

15
Reasonable Accommodations

• Person with disabilities can receive support when
  housed with family member who owns the home
• Family income does not count toward assisted
  disabled persons income
• Housing payments must be reasonable for type and
  nature of housing
• Must be determined by physician that living with
  family member is important to clients overall
  health and well being case by case determination

16
How HOPWA Fits in HUD
17
Consolidated Planning Process

• Programs covered by Consolidated Plan
• CDBG
• Home
• ESG
• HOPWA
• Process
• 5 Year Consolidated Plan
• Annual Action Plan
• Establishes targets for annual HOPWA outcomes

18
HOPWA requirements in Annual Action Plan

• Annual goals specified for
• Households to receive assistance through
• STRMU
• TBRA
• FBRA
• Method for selecting project sponsors
• Community based
• Faith based
• Changes such as instituting caps (STRMU) or
  limiting eligibility must be stated as part of
  Annual Action Plan

19
Citizen Participation Process

• Consolidated Plan requires consultation with
• Organizations that provide housing and supportive
  services to those with special needs
• Organizations serving the chronically homeless
• Citizen Participation
• Local and regional institutions, developers,
  community organizations, faith based involved in
  plan development
• Comments included and adequately addressed
• HOPWA Grantees and Project Sponsors strongly
  encouraged to participate in Consolidated Plan
  process

20
HOPWA Funds Allocation

• Formula Funds
• Competitive Grants
• Technical Assistance

21
HOPWA Formula Funds

• 90 of total HOPWA funding is available through
  formula grants to states and eligible
  metropolitan statistical areas (EMSAs)
• FY 2007 formula funding is 256,162,000
• 25 of formula is awarded as a bonus to EMSAs
  that have a higher than the average per capita
  incidence of AIDS reported in the prior year
• AIDS incidence data derived from CDC reports

22
HOPWA Formula Funds

• Eligible formula areas must have
• At least 1,500 cumulative cases of AIDS reported
  as of March 31st of the previous year
• Population of at least 500,000 in metropolitan
  areas
• HUD-Approved Consolidated Plan

23
Competitive Grants

• 10 of funds are available through competitive
  grants to states, local governments, and
  non-profit organizations
• 2007 Competitive funding is 28.5 million
• Announcement / application for funding available
  through HUDs annual Super NOFA process

24
Competitive Grants

• There are 2 types of competitive grants available
  to communities
• Special Projects of National Significance
  (SPNS) Housing and supportive services projects
  which are unique or innovative and likely to
  serve as effective models in addressing the
  housing and related needs of low-income persons
  living with HIV/AIDS grants to states, local
  government, or nonprofit
• Long-term Comprehensive Strategies Funding to
  states and localities for areas that are not
  eligible for formula grants (government only)

25
National Technical Assistance

• 1-2 of total competitive funding is set aside
  for the delivery of technical assistance,
  training and monitoring activities, including
  assistance in
• Sound management of HUD Grants
• Performance measurement and data collection
• Establishing or operating housing subsidy
  programs and community residences
• Needs assessment and planning activities
• 2007 funding is 1.5 million

26
Grants Management

• Formula 121 Grants including 81 cities, 1 county
  and 39 states
• Competitive 85 Active grants
• Technical Assistance 7 TA partners providing
  local training and other support on meeting
  program objectives
• Project sponsors approximately 500 non-profits
  and a few housing agencies

27
Housing Outputs

• Households served 2004-2005 Program Year
• 21,846 rental assistance (50 expenditures)
• 39,068 short term assistance (24)
• 6,098 housing facilities (20)
• 400 new units (5)

28
Housing Assistance 04-05, Clients Served by
Housing Type
29
Housing Expenditures

• Annual Per Unit Costs (04-05 Program year)
• 3,750 Rental Assistance
• 811 Short-term payments
• 9,056 Operating costs in facilities
• 18,282 Development of new housing

30
Austin Formula Allocations
31
San Antonio Formula Allocations
32
State of Texas Formula Allocations
33
HOPWA Regulations

• Code of Federal Regulations HUD
• 24 CFR Part 574 HOPWA
• 24 CFR Part 9 Consolidated Plan

34
Definitions

• AIDS
• Disease of AIDS
• Any conditions resulting from the etiologic agent
  for AIDS
• HIV Infection

35
Definitions

• Eligible person a person with AIDS or a related
  disease who is a low income person and the
  persons family
• Family 2 or more people who are related or
  important to care and well being and surviving
  members of an eligible persons family

36
Definitions (Continued)

• Low Income below 80 of median
• Project Sponsor -- non-profit or local
  government agency that receives funds through
  contracts with a grantee
• Grantee state or local government receiving
  funds from HUD

37
HOPWA Regulations

• 574.3 Definitions
• 574.300 Eligible Activities
• 574.310c Religious organizations
• Can receive support on equal footing
• 574.310 General Standards
• Payments for health services not permitted if
  payment can reasonably be expected to be made by
  insurance or state compensation or health
  benefits program or on a pre-paid basis
• Health services only for PLWH/A
• Only permitted on case by case individualized
  basis
• See 1998 Notice on Use of Funds for Healthcare
  Costs

38
HOPWA Regulations

• 574-310 General Standards (Cont)
• All housing assisted must meet housing quality
  standards (special requirements for STRMU)
• Minimum use periods
• 10 years for any property involving acquisition,
  new construction or substantial rehabilitation
• 3 years for property with less than substantial
  rehab
• Recipients must pay rent (30 adjusted gross
  income or 10 of gross income)

39
HOPWA Regulations

• 574.310 General Standards (Cont)
• Termination of assistance
• Grace period of up to 1 year for surviving family
  members
• Violations of program requirements or conditions
  of occupancy
• Pursuant to formal process that affords due
  process

40
HOPWA Regulations

• 574.320 Additional Standards for Rental
  Assistance
• Maximum subsidy is lesser of
• Rent standard or
• Reasonable rent
• Rent is pro-rated in shared housing situations

41
HOPWA Regulations

• 574.330 Additional Standards for Short Term
  Supported Housing
• Short term facility can provide residence for not
  more than 60 days in a 6 month period
• STRMU is limited to 21 weeks in any 52 week
  period
• Short term facilities can house no more than 50
  people

42
HOPWA Regulations

• 574.340 Additional Standards for Community
  Residences
• Multi-unit facility as a residential alternative
  to institutional care
• Adequate services must be provided
• Funding must be adequate
• Providers must be qualified
• Qualifies for new construction s
• Can be assisted through local TA

43
HOPWA Regulations

• 574.400 Special responsibilities
• 574.430 Fee Prohibition
• No fees other than rent charged to eligible
  persons
• 574.440 Confidentiality
• The name of any person receiving assistance shall
  be kept confidential by grantee and project
  sponsors

44
HOPWA Regulations

• 574.500 Grant Administration
• Environmental review for acquisition, new
  construction, rehabilitation or leasing of
  structures to provide housing
• Annual reports required
• Records maintained for 4 years
• Deobligation of funds if not expended in timely
  manner generally within 3 years

45
Confidentiality

• HOPWA regulations require that grantees and
  project sponsors ensure the confidentiality of
  both the name of any individual assisted by HOPWA
  and any other information regarding individuals
  receiving assistance.
• 24 CFR 574.440 Confidentiality. The grantee
  shall agree, and shall ensure that each project
  sponsor agrees, to ensure the confidentiality of
  the name of any individual assisted under this
  part and any other information regarding
  individuals receiving assistance.

46
Confidentiality Procedures

• Information related to HIV only to be used for
  limited purpose of determining eligibility
• Only accessible to staff who determine
  eligibility or provide support
• Paper files maintained in locked cabinets
  security software required for electronic files

47
Confidentiality Requirements

• Written procedures and training to maintain
  confidentiality
• Periodic monitoring of procedures and conduct
  appropriate training
• Failure to follow confidentiality procedures is
  default of grant responsibilities and could lead
  to loss of grant funds or other sanctions

48
Confidentiality

• Avoid inadvertent disclosures
• Checks
• Caller IDs
• Fax IDs
• Housing quality inspections
• Publicity for project-based developments
• Other government reporting

49
Other Federal Requirements

• 574.600 Other Federal Requirements
• Non-discrimination and equal opportunity
• OMB Circulars A-87, A-102, A-110 and A-122
• Conflict of Interest
• Displacement/relocation
• Lead based paint
• Flood insurance protection
• Audits

50
Lead Based Paint

• Housing built before 1978
• Occupants include pregnant woman or a child lt6
• OBR units are exempt
• Applies to STRMU or TBRA
• Visual assessment must be done deteriorated
  paint must be repaired using lead-safe work
  practices repaired area must be tested and
  cleared HUD one hour on line course
  prerequisite to do visual assessment

51
Uses of Grant Funds

• Housing facilities
• Client assistance
• Housing subsidies
• Administration

52
Housing Facilities

• Facility based rental assistance
• Acquisition/rehabilitation
• New construction (special limitations)
• Operating costs
• Leasing

53
Housing Facilities

• Includes facilities that provide housing
• May or may not provide services onsite
• Facilities receiving capital support must provide
  housing to eligible PWAs for at least 10 years
• Includes independent apartments or shared
  residences
• Rehabilitation must bring facility up to current
  ADA standards
• Includes lease of existing facility
• FBRA or operating expenses

54
Housing Facilities Operating Costs

• Property Maintenance and Upkeep
• Security Measures
• Insurance
• Utility Costs for Facility
• Furnishings, Equipment, and Supplies
• Other Incidental Expenses

55
Housing Facilities New Construction

• Special Limitations
• Single Room Occupancy (SRO)
• Community Residences
• Including multi-unit family dwellings that
  provide a high-level, service-enriched
  environment

56
Housing Facilities Short-Term Supported Housing

• Facilities to provide temporary shelter
• May be hotel, motel, or shelter facility
• May provide residence to any individual for 60
  days during any 6-month period
• The 60 days do not have to be consecutive
• HOPWA cannot provide hotel/motel vouchers
• Not STRMU

57
Client Assistance Supportive Services

• Provided onsite or for clients in housing
  programs
• Housing service plan
• Assessment for Case Management and Housing Needs
• Health Services limited to PLWA and no other
  source of payment
• Mental Health Care/Drug and Alcohol Abuse
  treatment and counseling
• Child Daycare/Adult Daycare
• Personal Assistance (intensive if required)

58
Client Assistance Supportive Services, Cont.

• Nutritional Services
• Permanent Housing Placement
• Assistance Securing Other Mainstream Benefits
• Transportation
• Translation Services

59
Client Assistance Housing Information Services

• Housing Information and Referral
• Housing Search and Assistance
• Housing Counseling
• Fair Housing Information
• Assistance in Completing Housing Applications
• Can support development of Housing Service Plans

60
Client Assistance Housing Services Plans

• Determine housing needs and preferences
• Develop strategy to achieve or maintain housing
  stability
• Identify eligibility for other housing assistance
• Link to supportive services needed to maintain
  housing stability
• Eligibility for mainstream assistance
• Client sets goals for housing and independence
• Periodically revised and updated
• Housing case management or housing information
  services for funding under HOPWA

61
Client Assistance Resource Identification

• Community based needs assessments
• Comprehensive HIV/AIDS housing plans
• Coordinate housing and supportive services
• HOPWA advisory boards
• Feasibility studies of housing projects
• Project start-up costs
• Financial and program accountability

62
Client Assistance Permanent Housing Placement

• Supportive Service reported separately
• Help establish new residency where on-going
  occupancy is expected to continue
• Can cover
• Costs associated with locating housing
• Housing referral (to decent, safe and sanitary
  housing)
• Tenant counseling/Understanding leases/mediation
• Secure utilities
• Placement costs
• Application fees/credit checks
• Reasonable security deposits (NTE 2 months rent)
• Deposits need to be tracked and returned to
  program

63
Client Assistance Permanent Housing Placement

• Costs/activities not allowed
• Housing supplies
• Smoke alarms
• Standard furnishings
• Minor repairs
• Moving costs

64
Client Assistance Resource Identification

• Unique tool for HOPWA
• Outreach and coordination with supportive housing
  projects and private landlords
• Housing information provided through brochures
  and web resources
• Staff time to locate and identify affordable
  housing vacancies

65
Housing Subsidies

• Tenant based rental assistance
• Short term rent, mortgage, and utility assistance
  (STRMU)

66
Housing Subsidies Tenant Based Rental Assistance

• Section 8 like assistance program
• Subsidizes difference between rent standard or
  reasonable rent (whichever is less) and tenant
  rental contribution
• Units must meet housing quality standards
• Rents plus utilities must not exceed rent
  standards (Fair Market Rents)
• Tenants may request interim rental adjustment
  based on increases or decreases in income

67
Housing Subsidies Rent Reasonableness

• Subsidized rent is lesser of rent standard or
  reasonable rent
• Assisted unit rent should not be greater than
  rent charged for equivalent unit on private
  market
• Obtain and maintain in file documentation from
  brokers or advertisements on rents charged for
  comparable units

68
Housing Subsidies TBRA Requirements

• Housing quality inspection
• Rent standard inclusive of utilities
• Cannot be combined with other HOPWA or HUD
  housing assistance
• Annual recertifications

69
Housing Subsidies Short Term Rent Mortgage and
Utility Assistance (STRMU)

• Prevents homelessness by keeping households in
  current dwelling
• Provides rent, mortgage, and/or utility support
  for no more than 21 weeks in a 52 week period
• Assistance may be subject to further limitation
  by grantees

70
Housing Subsidies STRMU

• Cannot be used for first months rent or security
  deposit cannot assist homeless people
• Assistance must be paid to third party (i.e.
  mortgage, landlord, utility company) No cash
  payments
• Amount of assistance may vary depending on funds
  available, tenant needs, and program guidelines.
  (Caps may be applied)
• Annual reporting counts households assisted not
  payments

71
Housing Subsidies STRMU and HOPWA Outcome

• Temporary solution
• Housing Services Plan key to achieving stability
• Maintain connections to key health and supportive
  services

72
Housing Subsidies STRMU Tenancy Requirements

• Must already be housed to be eligible
• Must be named tenant or provide other evidence
  that they are legal resident
• Account in their name with utility or proof of
  responsibility to make payments (cancelled
  checks/money orders)
• Owner of mortgaged property
• Deed
• Title insurance policy
• Mortgage holder
• Default/late payment notice is not required

73
Housing Subsidies STRMU Needs Based Program

• Needs must be documented through verifiable
  documents client should have no other means for
  payment and support will prevent homelessness
• If they are able, clients should pay portion of
  their housing costs under STRMU
• Portion of rent paid by tenant does not count
  against the 21 week STRMU benefit ceiling
• STRMU cannot be provided if assistance is also
  being received from any other HOPWA, federal,
  state or local housing subsidy program

74
Housing Subsidies STRMU Documentation of
Housing Need

• Inability to make monthly payment
• Record of monthly housing costs vs. income
• Limited available financial resources (savings,
  bank accounts, etc.)
• HIV/AIDS health conditions and impacts on
  resources

75
Housing Subsidies STRMU Capped Payments

• Grantees may allow project sponsors to cap STRMU
  assistance
• Caps must reflect FMRs and/or rent reasonableness
  so that support is sufficient to prevent
  continuing housing crisis
• Caps must be applied in uniform, consistent and
  non-discriminatory manner
• If household receives max amount under cap, it
  will be considered a full 21 weeks of assistance

76
Housing Subsidies STRMU Capped Payments and Con
Plans

• Cap limit must be specified in Annual Action
  Plans
• Must be assessed by Grantee and monitored for
  consistency
• Assessment must be included in Annual Report to
  HUD

77
Housing Subsidies Suitable Housing Units STRMU

• Required to assess whether unit is decent, safe
  and sanitary
• HQS not required initially if needed to prevent
  homelessness and unit is decent and safe
• Continued occupancy should require meeting of HQS
• Any deficiencies in unit should be addressed in
  housing service plan

78
Housing Subsidies STRMU Calculating 21 Week
Period

• Statute limits assistance to 21 weeks in any 52
  week period
• Count calendar days of assistance with max being
  147 (21 x 7)
• Can equate one month with 4 weeks of assistance
  yielding a maximum total of 5 months and 1 week
  of assistance
• Can precisely measure number of weeks in month
  (e.g., 4.3 weeks for 30 day month)
• Methodology must be consistent

79
Housing Subsidies STRMU Calculating Annual
Eligible Period

• All project sponsors must use same method to
  determine annual eligible period
• Standard annual period
• Grantees operating year
• Calendar year
• Separate period of eligibility for each client
• Year starts when client first receives STRMU
  assistance

80
Housing Subsidies STRMU Rent and Utilities in 21
Weeks

• Housing costs are generally monthly utility
  billing periods often include parts of 2 calendar
  months
• Provided that utilities and rent expenses are
  reasonably coincidental (at least 14 days of
  overlap), the monthly housing cost period can be
  used to determine the 21 week period

81
Housing Subsides Expenses Not Covered by STRMU

• Personal items (grooming, clothing, home and
  personal furnishings, care for pets)
• Vehicle maintenance and repairs
• Financial assistance/consumer credit or
  entertainment activities
• Phone services (basic phone service and long
  distance in rural areas may be covered as
  supportive service when needed to access
  necessary services)

82
Housing Subsidies STRMU Support for Mobile
Homes, Trailers

• Can be assisted under STRMU in limited
  circumstances
• Basis for assistance must be rent, mortgage or
  utility bill
• Mobile homes/trailers with wheels and capable of
  relocating are personal property and not eligible
• Must be attached to earth, connected to permanent
  utilities, compliant with local guidelines for
  mobile homes

83
Administrative Fees

• Grantees no more than 3 for
• Administering grant amounts
• Allocating amounts to project sponsors.
• Sponsors no more than 7
• Administrative costs associated with carrying
  out eligible activities
• Fees over entire term of grant
• No 7 - 7

84
Administration Uses of Administration Funds

• General Management
• Oversight
• Coordination
• Evaluation
• Reporting

85
Administrative Expenses Include

• Staff for program coordination, management and
  evaluation
• Travel for official business
• Contracted services (legal, audit, accounting)
• Goods and services needed for admin
• Equipment rental and purchase
• Insurance and utilities

86
Ineligible Expenses for Administrative Costs

• Development of staff professional credentials
• General govt. expenses (e.g. building costs)
• Substitution for general funds.
• Tasks duplicated by grantee and project sponsor.

87
Administration Other Funds for Planning,
Reporting, Evaluation

• Resource Identification
• Technical Assistance
• Housing Information Services

88
Technical Assistance Local

• Assistance in establishing and operating a
  community residence (statutory)
• Training, orientation and capacity development
• Planning and pre-development activities
• Community outreach to neighbors of residence

89
Resources

• HUD Website
• Updated STRMU Notice CPD 06-07
• FAQ on STRMU
• Users Guides to
• New Annual Progress Report (APR)
• New CAPER
• IDIS Version 10
• Logic Model

90
Monitoring and Evaluation

• Purpose and Types of Monitoring
• What do program monitors look for?
• Tools

91
Introduction

• Public Trust Responsibilities
• Federal and Grantee Partnership
• Consolidated Plan
• Technical Assistance

92
Monitoring Issues

• How are grantees selected for monitoring?
• How does HUD prepare for monitoring?
• What is expected to be seen on-site? Document,
  Document, Document
• How are Findings and Concerns handled?

93
Overview

• Monitoring is a shared responsibility between
  HUD, grantees, sponsors.
• 3 types HUD monitors grantees, grantees monitor
  sponsors lead agencies monitor sub-grantees
• To make sure that program requirements are
  followed as intended by the law
• To strengthen administrative capabilities to
  better serve clients

94
Risk AnalysisCPD Notice 04-12

• Who poses the greatest risk?
• Financial
• Physical
• Management
• Satisfaction and
• Services.

95
Risk Analysis 1. Financial

• a. Size of Grant
• b. Timeliness
• c. Timely Submission of OMB A133 Audits
• d. Financial Compliance
• e. Expenditure Provisions

96
RISK ANALYSIS Continued
97
RISK ANALYSIS Continued

• 4. SATISFACTION
• a. Citizen Complaints
• b. Grantee Responsiveness

• 5.SERVICES
• a. Meeting Program Objectives
• b.Carrying Out Program Activities
• c. Program Progress

98
Preparing for Monitoring

• The Consolidated Plan Goals
• Action Plan Activities
• Competitive application budget
• The CAPER or APR
• IDIS Reports
• Previous Monitoring Issues?
• Citizen Complaints?

99
Consolidated Plan

• 91.205. Housing and Homeless Needs Assessment.
• Must include persons with HIV/AIDS and their
  families.
• The Con Plan/Action Plan must estimate the number
  of type of families in need of housing including
  those with HIV/AIDS
• The size and characteristics of the population
  with HIV/AIDS and their families must be described

100
Consolidated Plan Contd

• 91.210. Housing Market Analysis
• The plan must describe the significant
  characteristics of the jurisdictions housing
  market, including the the supply, demand, and
  condition and cost of housing and the housing
  stock available to persons with HIV/AIDS.

101
Consolidated Plan Contd

• 91.215. Strategic Plan
• The plan must describe the general priorities for
  allocating investment geographically within the
  EMSA for the HOPWA program.
• The Con Plan must describe the priority housing
  and supportive service needs of persons with
  HIV/AIDS and their families

102
Action Plan (91.220)

• Includes a description of activities to be
  undertaken during the next year that will address
  the jurisdictions priority needs.
• The activities must describe the number and types
  of families that will benefit, the local
  objectives, and priority needs.
• Specify intended outcomes to be achieved
• Certification HOPWA-funded housing activities
  are consistent with the strategic plan.

103
Client Eligibility

• Selection process waiting lists?
• Documentation of HIV/AIDS Status
• Documentation of 80 of median income, Section 8
  definition, including third party verification,
  assets, unusual medical expenses etc.
• Confidentiality how is it maintained?
• At risk or homeless status how is it
  documented?

104
Housing

• HQS Inspections
• Correct rent calculations
• Income verified at least annually
• Policy Guide on Terminations
• Housing provided consistent with Con Plan
• Client Confidentiality
• Adequacy of Residential Supervision
• Adequacy of Supportive Services

105
Reporting

• CAPER, APR, IDIS, Logic Model, and LOCCS
• Are the number of participants served consistent
  with the Con Plan/Action Plan, the application
  and the numbers reported in the CAPER or APR?
• Are the Reports submitted in a timely manner and
  are they complete and accurate?
• How many people are on waiting lists?
• Are funds being spent in a timely manner?
• Are projected outcomes being achieved?

106
Reporting

• Annual set up of IDIS activities
• Close out of these activities, within 90 days of
  the end of the operating year on their Con Plan
  cycle.
• Consistency in IDIS data and CAPER summary
  information.
• Data included beneficiary information
  (raceethnicity/age etc), expenditure data and
  housing outputs outcome data reported
• Data is accurate, complete, avoids excessive use
  of other or mixed by showing specific costs
  by budget line item, and type of service

107
Grant Administration

• Client files must document grantees are
  conducting on-going assessments of the housing
  assistance and supportive services required by
  participants (574.500(b)(2))
• Files should show adequate provision of services,
  e.g. by accessing mainstream programs, qualifying
  clients for benefits, ensuring payer of last
  resort
• Lease agreements between tenant/landlord or
  agency/landlord kept on file

108
Grant Administration

• Housing efforts should connect to long-term
  solutions, such as movement to permanent housing
  or independence, where possible.
• On STRMU, files must show this short-term
  assistance is limited, not more than 21 weeks in
  any 52 week period or 60 days in any 6 month
  period in an short-term supported facility.
• Grantees must provide oversight on sponsors, e.g.
  on client documentation, rent determinations,
  rent reasonableness timeliness in use of funds,
  and reporting.

109
Property Standards

• Continued Use Requirements being followed?
• 10 years for new construction, substantial rehab
  or acquisition of a building
• Three years for properties involving
  non-substantial rehab.

110
Community Residences

• Is the required certification on file that the
  grantee has entered into a written agreement with
  providers for services?
• Is the funding appropriate for these services and
  providers capable?
• Are any physical improvements to the residences
  in compliance with applicable State and local
  housing codes?

111
Limits on Health Care

• HOPWA emphasizes housing
• Verify that HOPWA funds are not used for medical
  expenses individuals can receive under other
  programs
• Need to document the eligibility of these
  payments on an individual basis
• See the HUD Guidance dated January 21, 1998 in
  contracts on these limitations, requiring HUDs
  pre-approvals

112
Financial Management

• OMB Circulars A-87/A-122
• Part 84/85
• Approved application budget
• Vendor invoices, bank statements, time sheets,
  purchase orders
• Audit Open Findings?
• Personal Property Controls (in excess of 5,000).

113
Financial Management Contd

• Grantee and sponsor employee time sheets should
  reflect actual times, not percentages.
• Time sheets should be signed and dated by the
  staff and then the supervisor.
• If employees split their time between programs
  (e.g. Ryan White) the time sheets should reflect
  this split.

114
Financial Management Contd

• Only actual incurred costs can be charged to
  HOPWA.
• For example. Dont charge HOPWA for a
  counselors time spent with ineligible clients.

115
Financial Management Contd

• Draw funds down on a reimbursement basis from
  IDIS or LOCCS or
• Draw down funds only when they are needed to pay
  for incurred costs
• Rule of thumb three days before paying a bill.

116
Other Federal Requirements

• Environmental Part 58 applies
• Lead Based Paint Applies if children under the
  age of seven will reside in the housing or
  facility.
• Relocation URA applies
• Drug-Free Workplace There should be a Drug-free
  Workplace Statement and it should be consistent
  with the programs certification.

117
Findings and Concerns

• Monitoring letter
• A Finding results from non-compliance with
  regulatory or statutory requirements.
• A Concern results from the need for improvement
  in certain areas that could become a future
  finding.
• Findings and Concerns are entered into HUDs
  Grants Management Process and controlled until
  they are satisfactorily addressed
• Range of sanctions

118
Resources available on CD

• HOPWA Program
• Environment review requirements
• Formula grant operating instructions
• Current and planned APR and CAPER
• IDIS HOPWA Handbook
• HOPWA Regs
• STRMU Notice
• Notice on Health Care Costs

119
CD Resources

• OMB Circulars
• A-87, Cost Principles for State and Local Govt
• A-110, Uniform Admin Requirements for grants and
  agreements for non profits
• A-122, Cost Principles for non profit
  organizations
• A-133 Audits of States, Local Govt and Non
  Profit Organizations