2012 Continuum of Care: Focus on the Basics

1. 2012 Continuum of Care:Focus on the Basics Technical Assistance Workshop for the Project Sponsors of Harris County’s Continuum of Care Program May 29, 2013

2. Presented by: • Esmeralda Gonzalez, Public Services Manager • Demetra Davis, Project Monitor • Debra Hayes, Project Monitor

3. Attendees • Project Sponsors with an assigned Housing Agent • Mental Health Mental Retardation Authority of Harris County • SEARCH Homeless Services • Temenos Community Development Corporation • Veterans Affairs • Volunteers of America • Housing Agents • Texas Interfaith Management • City of Houston Housing Authority • Project Sponsors without a Housing Agent • AIDS Foundation Houston • Cloudbreak Houston, LLC and U.S. Vets • HOPWA Housing NorthlineSRO

4. 24 CFR 578.3 Definition of Permanent Housing • Community-based housing without a designated length of stay • For homeless, disabledindividuals and their families • Program participant is tenant on lease • For a term of at least one year • Renewable for terms that are a minimum of one month long • Lease which is terminable for cause • Supportive services promoting independent living must be made available

5. Documentation of Homelessness

6. Inadequate Homelessness Documentation

7. 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.

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

9. 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.

10. Selection of the Unit • Case Manager to assist with locating unit • Suitable Dwelling Size as deemed by household size (2 persons per bedroom/sleeping area) • Rent Reasonableness, Fair Market Rent • Housing Quality Standards, Lead Based Paint

11. Fair Market Rents • The 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 $477 • EFF $636 • 1BR $765 • 2BR $945 • 3BR $1,290 • 4BR $1,595

12. 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.

13. 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?

14. 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 HQS • Requests should be submitted 90 days prior to the expiration date of when the unit previously passed inspection • Problems must be corrected within 30 days from the date of initial inspection • Grantee has no funds to cover costs for periods of non-compliance

15. Lead-Based Paint Requirements • Regulations at 24 CFR Part 35 • HUD Office of Lead Hazard Control homepage: www.hud.gov/offices/lead • EPA Clearinghouse: (800) 424-LEAD • Lead Based Paint Disclosure Form • Pamphlet

16. 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?

17. 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 unit • relationship to the participant • date of birth and gender • Birth Certificates and Social Security Cards must be included for dependent children in household.

18. 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?

19. Resident Rent Calculations24 CFR 582.310 Each resident under SPC must pay the highest of: • 30 percent of monthly adjusted income • 10 percent of monthly gross income

20. Income Certification • Household income cannot exceed Median Family Income limits • Information on the Occupancy Agreement must match the information on the Lease, Rent Calculation Worksheet, Persons Served Worksheet and Household Characteristics Reports • Effective 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.

21. CSD Programmatic Reports (on CD) • Monthly Reports: • Project Status Report • Household Characteristics Report • Household Characteristics Summary • Security Deposit Request (if applicable) • Persons Served Worksheet

22. Most common reporting issues: • Incorrect income calculation • Rent amount on lease agreement does not match approved amount on Rent Reasonableness request • Lease dates incorrect or inconsistent with occupancy agreement • Failure to sign reports as indicated • Late HQS requests • HMIS certification not signed/signed but not done • Inaccuracies in the Persons Served Worksheet

23. Annual Monitoring • To determine compliance with HUD regulations, circulars and statutes • To determine whether activities are implemented as described in the application and APR • To verify that all required documentation is in the file • To determine if all applicable income was used to calculate resident rent

24. 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

25. 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.

26. Termination of Assistance 24 CFR 578.91 • Serious violations of program requirements or conditions of occupancy • Due 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 assistance • Written notice clearly stating reasons for termination • A review of the decision with written/oral objections • Prompt written notice of final decision

27. 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; and • Written statement from the individual detailing their current or formerly homeless situation.

28. Annual Performance Reports • Data 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.

29. Responsibilities Matrix • Only for Subrecipients with Housing Agent