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Module 2: HPRP Program toolS

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Title: Indiana HPRP Training Author: Howard Burchman Last modified by: Lenovo User Created Date: 8/31/2009 4:21:31 PM Document presentation format – PowerPoint PPT presentation

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Title: Module 2: HPRP Program toolS


1
Indiana HPRP Training
  • Module 2 HPRP Program toolS

2
HPRP consists of two programs
  • 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

3
HPRP Eligible Activities Same for both program
components
  • Financial Assistance
  • Short and medium term rental assistance
  • Security deposits
  • Utility deposits
  • Moving cost assistance
  • Hotel/motel vouchers
  • Housing Relocation and Stabilization
  • Case management
  • Outreach and engagement
  • Housing search and placement
  • Legal services
  • Credit repair

4
HPRP Eligible Activities (2)
  • 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

5
Financial Assistance
  • Limitations
  • No direct payments to program participants
  • 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

6
Rental Assistance
  • Short term up to 3 months
  • Must be evaluated at the end of 3 months prior to
    receiving continuing assistance
  • Medium term cannot exceed 4-18 months
  • (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 HUDs rent
    reasonableness requirements, not FMR.

7
Rental Assistance (2)
  • No double dipping no assistance for same cost
    types that are covered by any other federal,
    state or local housing subsidy program
  • 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
  • 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
  • Arrearages paid count toward 18 month limit
  • Can be paid if it allows participant to remain in
    unit or move to another unit

8
Security and Utility Deposits
  • Deposits can cover same period and unit as other
    subsidy program
  • 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
  • Notify landlord and/or utility to whom deposit
    should be returned

9
Utility Payments
  • 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
  • Utility account in name of participant or member
    of household
  • Evidence of prior payments such as cancelled
    checks or receipts from utility

10
Moving Cost Assistance
  • Reasonable moving costs
  • Truck rental, moving company
  • Storage fees for belongings
  • Maximum of 3 months or
  • Until participant is in housing

11
Motel and Hotel Vouchers
  • 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

12
Housing Relocation and Stabilization
  • Services can only be provided for up to 18 months
    for participants
  • Services include
  • Case management
  • Outreach and engagement
  • Housing search and placement
  • Legal services
  • Credit repair

13
Case Management
  • 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

14
Outreach and Engagement
  • 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.

15
Housing Search and Placement
  • 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

16
Legal Services
  • 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

17
Credit Repair
  • No payment of personal financial obligations
  • Skills training in budgeting and money management
  • Support in resolving credit issues

18
Data Collection
  • 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

19
Administrative Costs
  • 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
  • Costs of issuing financial assistance
  • Providing services
  • Carrying out housing inspections, etc.

20
HPRP Program Eligibility
  • 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
  • Homeless
  • 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

21
Two Eligibility Paths
22
Quarterly Certification
  • Eligibility must be re-certified quarterly for
    all participants receiving financial assistance
  • Income eligibility
  • Continuing need for financial assistance
  • Likelihood of sustaining housing at end of HPRP
    assistance

23
Documentation of Homelessness
  • All participants who are eligible for assistance
    because of their homeless status must have
    documentation of status
  • 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

24
Homeless Prevention Eligibility
  • Risk of homelessness must be documented
  • Responsibility for debt must be established prior
    to HPRP payments
  • 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
  • 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

25
Determination of Risk of Homelessness
  • 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

26
Changed homeless definition in HEARTH Act
  • Homeless will also include
  • 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
  • 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

27
Assessment must document risk of homelessness
  • Risk factors include
  • 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

28
Risk Factors (Cont)
  • 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

29
Risk of Homelessness in HEARTH Act
  • 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

30
Ineligible Uses of Funds
  • 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
  • Construction or rehabilitation
  • Credit cards, consumer debt,
  • Car repair or transportation
  • Food
  • Medical/dental care and medications
  • Pet care
  • Entertainment
  • Work or education materials

31
Ineligible Activities (Continued)
  • 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

32
Accessing HPRP Assistance Homeless Participants
33
Homeless Participants Requirements for Housing
Unit
34
Prior to Receiving Rental Assistance
  • 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.
  • 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

35
Overview of Lead Based Paint Requirements
  • Exemptions from requirements
  • 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
  • Visual assessment must be performed by HPRP
    agency
  • If deteriorated paint surface is found
  • 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

36
Rent Reasonableness
  • 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
  • Go Section8 software will allow easy
    determination of rent reasonableness.

37
Double Dipping
  • No rental assistance from HPRP if
  • 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

38
Time Limits on Assistance
  • Housing relocation and stabilization (including
    case management) limited to 18 months/program
    participant
  • Rental Assistance cannot exceed 18 months
  • 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

39
Participants must pay rent
  • Use HUD methodology
  • Tenant rent payment can be used to pay utilities
    (up to utility allowance)
  • 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

40
Tenant rent payment
  • Every person receiving rental assistance (short
    or medium term) supported by HPRP must pay as
    rent (the higher of)
  • 30 of adjusted income
  • 10 of gross income

41
Process of determining tenant rent
  • 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

42
Annual Income Includes
  • All amounts to all family members
  • Anticipated over upcoming year
  • Amounts obtained from assets
  • Regs 24 CFR 5.609

43
Sources of income to include
  • Wages and salaries
  • Net income from business/profession
  • Interest and dividends
  • Social security, annuities, retirement, pensions
  • Unemployment, workers comp
  • Welfare payments
  • Alimony child support
  • Armed forces pay

44
Income that is not included by HUD
  • 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

45
Income not included (Cont.)
  • Adoption assistance payments over 480/adopted
    child
  • Deferred periodic amounts from SSI/SSD
  • Rebates of property taxes
  • Payments on behalf of developmentally disabled
    family 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

46
Income Deductions
  • 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
  • Reasonable child care to permit family member to
    work or further education

47
Treatment of Assets
  • Cash value of all assets must exceed 5000 to be
    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

48
Income Verification
  • 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)

49
Income Verification 2
  • Assistance benefits (TANF, Workers Comp, SS,
    unemployment, etc.)
  • Copy of benefit check
  • Copy of award letter
  • Verification form from agency
  • Child support payments
  • Copy of court records
  • Copy of payment check

50
Income Verification 3
  • Interest/Dividends
  • Passbook/bank statement
  • Income tax return
  • Assets
  • Passbook/bank statement
  • Tax assessment or appraisal of real property

51
Income Verification 4
  • 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

52
Timeliness in Expending HPRP Funds
  • 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

53
Reallocation
  • 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

54
Requirements on Termination of Assistance
  • 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
  • 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

55
Confidentiality Requirements
  • Grantees and subgrantees must develop and
    implement procedures to ensure
  • Confidentiality of records pertaining to any
    individual receiving HPRP assistance
  • The address or location of assisted housing will
    not be made public

56
Conflict of Interest
  • 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
  • Requires opinion of grantees attorney that the
    interest for which the exception is sought would
    not violate state or local law

57
Equal Participation of Religious Organizations
  • 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

58
Resources made Available by IHCDA
  • IHOP
  • Indiana Housing Now
  • Rent Reasonableness Program
  • GoSection8 Software
  • On-line resources
  • FMRS
  • Utility allowances
  • Income/rent calculation worksheets
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