WV Balance of State CoC

1. WV Balance of State CoC Project Sponsor Meeting May 17, 2012 Weston, WV

2. Purpose of this Meeting is To Review: Statutory and regulatory requirements of the Supportive Housing Programs (SHP) and Shelter Plus Care Program (S+C); Client intake and exit procedures, and in HMIS Termination policies for clients, especially in PSH; Performance measures to track monthly in HMIS; Entering APR data in e-snaps from HMIS; Preparing for the APR before operating year ends.

3. Cash Match Requirements Each program category (operations, supportive services, leasing) has a different % of Cash Match required. Operations requires a 25% match; Supportive services requires a 20% match; Leasing and Administration require no match; After HEARTH regs are implemented all cash match will be 25% for SHP. S+C requires a 100% match (supportive services $ = Housing $)

4. What is Cash Match? Ordinarily, it means that the grantee gets cash from somewhere to pay for the % of the program cost. However, for supportive services, it could mean that cash match is being paid for (in cash) by another entity, probably a government or a private agency, for services that are provided to clients in the program, not a transfer of actual cash. Cash match requirements are in Section E of the SHP Desk Guide.

5. Important to Know: Cash match must be applied to an existing budget line item for which SHP funds are being used. Example: Case management, where funds from BHHF are being used for mental health and/or substance abuse services for clients. Clients are being case managed, are being assessed by Case Managers according to their needs for services, being referred for services by the CM, and then getting those services. All this is part of case management.

6. Match for Operations This is more difficult to obtain. Grants may be gotten from a foundation, an agency whose budget allows for operating costs (such as energy assistance), or from a private source (such as a church group) to supplement line items like furnishings and utilities. Some sponsors/grantees use tenant program fees or rent to cover match for operations. Under a leasing program the grantee would hold the lease in order to use rent as match.

7. Rent or Program fee charged to Clients SHP and S+C regulations state that clients can pay no more than 30% of adjusted income for rent (or program fee, unless the program fee, in addition to the rent, is for a specific, received service for which the agency charges the normal fee) Even for leased housing, the client pays 30% of adjusted income for rent, which must include all utility costs.

8. Difficulties with FMR in some areas In operating your SHP projects (this is not true for S+C), you are “stuck” with the Fair Market Rent budget (the FMR) in existence at the time your proposal was submitted. So if your project was funded in the 2010 NOFA, you may still be working with 2009 FMR, and those rent limits are difficult for your geographic area. This may change when HEARTH is implemented. The rent, at the FMR, is to INCLUDE utilities, or if not, then you need to use the utility allowance method to calculate the amounts what amount will be covered by the grant.

9. Utility Allowances HUD allows a method established by the local PHA to be used to calculate “reasonable” amounts for utilities. This amount is the utility allowance. If the utilities are in the client households name, they will pay 30% of their income to cover their rent and utility allowance amounts. Overages in the utility bills are a “grey area”, and it may be difficult for clients to pay overages. If the utilities are in the grantee organization’s name, the budget may not cover both the cost of the rent and the utilities.

10. Client Homelessness and Disability Eligibility Issues: For TH, PSH and S+C, all clients accepted must be homeless. For PSH and S+C, all clients (or one adult in the household) must have a disability. These eligibility rules are covered in the SHP Desk Guide, Section B.

11. Current Definition of HomelessnessUpdated 12/20/11 http://hudhre.info/documents/DeterminingParticipantStatus_12.20.11.pdf Literally homeless individuals/families Individuals/families who will imminently (within 14 days) lose their primary nighttime residence with no subsequent residence, resources or support networks Unaccompanied youth or families with children/youth who meet the homeless definition under another federal statute and 3 additional criteria Individuals/families fleeing or attempting to flee domestic violence with no subsequent residence, resources or support networks

12. 1. Literally Homeless An individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning: Sleeping in a place not designed for or ordinarily used as a regular sleeping accommodation, including A park A car An abandoned building A bus or train station An airport A camping ground

13. 1. Literally Homeless Cont. Living in a shelter designated to provide temporary living arrangements, including Congregate shelters Transitional housing Hotels and motels paid for by charitable organizations or federal/state/local government programs Exiting an institution (e.g., jail, hospital) where they resided for 90 days or less AND were residing in emergency shelter or place not meant for human habitation immediately before entering institution.

14. 2. Imminently Losing Primary Nighttime Residence Individuals/families who will imminently lose their primary nighttime residence within 14 days AND Has no subsequent residence identified AND Lack the resources or support networks needed to obtain other permanent housing

15. 3. Unaccompanied Youth under 25 or family with Children and youth People with ALL of these characteristics: Unaccompanied youth (less than 25 years of age) OR family with children and youth Defined as homeless under other federal statutes (i.e. Dept of Ed) who do not otherwise qualify under HUD’s definition Has not had a lease, ownership, or occupancy agreement in permanent housing in the 60 days prior to applying for assistance Has moved 2 or more times in the 60 days prior to applying for assistance Has one or more defined barriers (i.e. Chronic disabilities, Substance addition, DV, illiteracy, lack of HS diploma or GED, history of unstable employment, etc.)

16. Process for using funds for persons who fall under the new definition CoC must be able to demonstrate to HUD that use funds for this population is of an equal or greater priority or is equally or more cost effective in meeting the overall goals and objectives identified in the FY 2011 Exhibit 1 application in regards to children and unaccompanied youth. The CoC needs to know no later than August 1 if any projects plan to begin using renewal or new grant funds for this population. How many beds? How much money? CoC must make a formal written to HUD and identify specific projects requesting to use the funds. Funds set aside for this population cannot exceed 10% of the total grant funds awarded to the CoC.

17. 4. Individuals/Families Fleeing or attempting to Flee Domestic Violence… dating violence, sexual assault, stalking, or other dangerous or life threatening conditions related to violence, who have no identified subsequent residence; AND lack the resources and support networks needed to obtain other permanent housing.

18. Recordkeeping/Documentation Grantees must develop, maintain, and follow written intake procedures to ensure compliance with the homeless definition, respectively. The procedures must require documentation at intake of the evidence relied upon to establish and verify homeless status.

19. Homeless Status: Recordkeeping Requirements (*Updated 05/11/12) http://hudhre.info/documents/HomelessStatus_5.11.12.pdf Policies and Procedures must require intake staff to document: At intake/screening for eligibility For ALL persons seeking assistance Evidence relied upon to establish and verify Homeless status Policies and Procedures must also be consistent with recordkeeping requirement and must reflect HUD’s preferred order.

20. HUD’s Preferred Order for Homeless Documentation Third Party Written, including already available documents Oral Intake Staff Observation Self-Certification

21. Exceptions to Preferred Order for Documentation of Homelessness Types of assistance provided: Emergency Shelter Street Outreach Victim Services To protect the safety of individuals/families fleeing or attempting to flee Domestic Violence Emergency Shelter and Street Outreach should be short-term therefore documentation may be redundant or unnecessary.

22. HUD Tips for adhering to homeless documentation requirements Adopt checklists that reflect preferred order Incorporate guidance and examples of exceptions to preferred order Have staff check existing documentation first Create forms for tracking and documenting due diligence Check hudhre.info for updates as well as with CoC Staff

23. Form of Documentation: Written Letters/Referrals Official communication (must be issued on agency letterhead or program template) Signed and dated by appropriate third party representative Additional standards depend on criteria/condition of the Homeless Definition Category being used WE RECOMMEND PRINTING AND TABBING, or INTERNET BOOKMARKING, THESE ADDITIONAL STANDARDS FOR EASY REFERRENCE!

24. Oral Documentation Recorded in Writing By intake staff Of 3rd party providing verification Signed and dated by intake staff as true and complete **Recommend standardized form by program type - Create clearly labeled sections for including relevant details and certifications.

25. Individual/Head of Household Self-Statement Written statements certified (signed and dated) as true and complete Regulations specify when oral statements can be used If self-certification must be verified: Confirmation that certification was verified OR Due diligence documentation ** Recommend standardized form by program type

26. Due Diligence Describe efforts to obtain third party documentation May include phone logs, email correspondence, copies of certified letters etc. Outcome of effort, including obstacles Signed and dated by intake staff as true and complete ** Recommend standardized form

27. Eligibility for PSH and S+C: Disability Overview of Disability Definition: Developmental disability OR HIV/AIDS OR Other impairment (physical, mental, or emotional). The disability is expected to be: of long-continuing or of indefinite Duration; Substantially impedes the individual’s ability to live independently; Could be improved by the provision of more suitable housing conditions and Is a physical, mental or emotional impairment, including impairment caused by alcohol or drug abuse, post-traumatic stress disorder, or brain injury

28. Documenting Disability Status Documentation requirements applicable only when status is required for eligibility to program (PSH and S+C - 100% of units) Written 3rd Party Written Verification State licensed professional Social Security Administration Receipt of disability check Veterans Administration

29. Documenting Disability Status Cont. Intake staff observations Applicable only in the absence of written 3rdparty verification. Must be confirmed and accompanied by written 3rdparty verification no later than 45 days **Oral-third party and self-certification is NOT appropriate in ANY case.

30. Client Terminations This is a difficult issue for some of our projects. For communal buildings, there are safety issues for the entire building population that must be considered carefully when establishing a termination policy. For Transitional Housing, clients should be terminated under the following circumstances (generally, according to common sense, not HUD rules): Behavior that is endangering the health or safety of other residents. This does not necessarily include substance abuse relapse.

31. More on terminations For TH housing, the main performance measure HUD uses is exit to permanent housing. Therefore, termination should be undertaken only when really necessary, especially if no permanent housing has been located and secured. This is a judgment call, and/or an agency policy issue, but HUD performance measures should be part of the consideration. Failure to meet individual goals in the action plan, in and of itself, is not grounds for termination, unless it interferes with long-term client progress in general and/or contributes to a “culture” of non-adherence to program performance as a whole. Normally the latter does not apply to leased housing since inter-client contact is sometimes minimal.

32. Preparing for Operating Year End

33. Performance Measures HUD’s 3 Performance Measures for SHP and S+C To help program participants obtain and remain in permanent housing To help participants increase skills and/or income which will allow the participants to live as independently as possible. To help participants achieve greater self-determination which will enable the participant to gain needed confidence to make the transition out of homelessness.

34. Purpose of the PSH The main purpose of Permanent Supportive Housing (including S+C) is for clients to remain in permanent housing. The only reasons for exit are: The client no longer has the disability that defined them as eligible for PSH They no longer need the services of the program and other affordable housing is available to them. The client’s disability has become worse necessitating a higher level of care that the project can not offer (hospital – long term stay, nursing home, etc.)

35. Reporting in the actual APR • Permanent Housing Projects • The % of persons who remained in the permanent housing program as of the end of the operating year or exited to permanent housing (subsidized or unsubsidized). • The % of persons age 18 and older who maintained or increased their total income (from all sources) as of the end of the operating year or program exit. • Transitional Housing Projects • The % of persons who exited to permanent housing (subsidized or un-subsidized) during the operating year. • The % of persons age 18 through 61 who increased their earned income as of the end of the operating year or program exit. • The % of persons age 18 and older who increased their total income (from all sources) as of the end of the operating year or program exit. New CoC APR Guidebook published May 1, 2012 http://www.hudhre.info/documents/esnapsCoCAPRGuidebook.pdf

36. Reporting on your successes (client outcomes/HUD Performance Measures) HUD assesses the percentage of all clients in all projects who gained access to mainstream services and who gained employment. Related to this, HUD asks on the APR for applicants to calculate: Number of adults who left projects during the operating year Income (from all sources and employment if applicable) at program entry of the adults who left projects during the operating year. Income (from all sources and employment if applicable) at program exit of the adults who left projects during the operating year.

37. Tracking in HMIS • Any and all benefits, income must be recorded in the Income screen of Customer Intake in HMIS

38. Tracking in HMIS - Employment • Track employment information within the Income Screen of HMIS. • Note all changes in employment, wage amounts. • System will track history.

39. Tracking in HMIS – Non-Cash • Track Non-Cash benefits in the “Non-Cash benefits” section of Income • Names to be used: • SNAP (Food Stamps), Medicaid, Medicare, CHIPS, WIC, VA Medical Services, TANF Child Care, TANF Transportation, Other TANF non-Cash, Section 8, PH, or other Rental Assistance, Other • Temporary Rental Assistance, Other • System will track history. • Assign estimated, actual or a $0 value

40. Prepping for the APR and End of Grant Year 90 days prior to the end of the grant year Ask CPD Rep in Pittsburgh for Copy of LOCCS draws and balance status Check this against your records of draws and balances Not enough money - solutions Too much money – solutions You should be pulling your APR Quarterly from HMIS to monitor performance measures and data completeness If your project performance measures are not adequate, plan and take corrective action.

41. At the end of the operating year As soon as grant ends – Pull APR and make sure there are no data issues Don’t wait until the last minutes to pull your final APR from HMIS! Request assistance from WVCEH/BoSCoC anytime!! Check your grant balances again in LOCCS. You have 30 days after the end of the operating year to draw funds for expenditures that occurred or were obligated during the operating year. File correct APR and send copy to WVCEH/BoSCoC

42. Thank you for your attendance!