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1. Homeless Services Reform Act (HSRA) Information Session Presented by The Community Partnership
June 14 and 15, 2006
Additional Program Rules
Staff:
Amy McPherson, Chief Financial Officer
Darlene Mathews, Policy Analyst
Tamura Upchurch, Federal Programs Manager
3. Introductions Handouts
-Additional Program Rules Template
-Power Point
-HSRA service level chart
-Shelter & Housing Program Listing by Continuum of Care Category
4. HSRA Decision Making DECISION MAKING
AUTHORITY
Department of
Human Services
IMPLEMENTATION
Program Providers
and
The
Community
Partnership
5. Purpose New DHS requirement for re-submission of “Additional Program Rules”
Goal: to format, standardize and simplify Additional Program Rules
6. History of Homeless Services Reform Act Re-writing of the laws that govern homeless services
Bill passed in summer 2005
Expected to become effective in Jan. 2006
In reality it became effective in Oct. 2005
7. What does the HSRA do? Establishes an Interagency Council made up of government agencies, clients, providers and nonprofits to set the policy objectives for the Continuum
Protects the right to due process for clients
Articulates the rights and responsibilities of clients
Articulates Providers’ standards of service
Redefines service levels in the Continuum of Care
8. Implementing the HSRA Phase I- Development of Universal Program Rules
Phase II- Implementation of Notices
Phase III- Development of Additional Program Rules by each Provider
Phase IV- Training on how to Request a Reasonable Accommodation (Forthcoming)
9. Phase I Complying with the law: Universal Program Rules Universal Program Rules were developed for each
service level in the Continuum
Severe Weather Shelter –Formerly Hypothermia Shelters
Low Barrier Shelter -provides safe, decent overnight shelter in a congregate setting –Formerly Emergency Singles Shelters
Temporary Shelter -provides safe, decent shelter and supportive services for at least 12 hours and up to 24 hours a day. Formerly Emergency Shelter for Families and Transitional Programs for Singles w/ minimum eligibility reqs.
10. Phase I Complying with the law: Universal Program Rules Transitional Shelter/Housing -provides housing and supportive services 24 hours a day to assist homeless individuals and families develop the skills necessary to live in permanent housing.
Permanent Supportive Housing –provides housing with supportive services for an unrestricted amount of time. This type of housing is often offered for homeless people who unable to be self sufficient due to a disability.
11. Phase I: Universal Rules Articulate all of the required services and processes under the law including clients rights, clients responsibilities, clients’ due process under the law
These cannot be changed or altered
These rules MUST be signed and reviewed with all clients during intake.
12. Phase II: Complying with the law:Due Process Notices Any agency receiving public money to provide a service is obligated to provide their client with adequate NOTICE when there is a change to their service. The NOTICES inform a client of a change in service and their opportunity to appeal the change.
-Trainings on how to use these NOTICES were conducted on April 3 & 7
13. Phase II: Due Process Notices DHS developed Notices for the following actions that can be taken against a client:
-Notice of Eligibility
-Notice of Transfer
-Notice of Suspension
-Notice of Termination
-Notice of Emergency Action
THESE NOTICES MAY NOT BE CHANGED
14. Phase II: Complying with Due Process Notice If you take an action against your client such as:
-Deny a person entrance to your program based on eligibility standards
-Suspend
-Terminate
-Transfer
-Emergency Transfer, Suspend or Terminate
You must provide them with the appropriate DOUBLE SIDED notice and have them sign it.
15. Phase III: Complying with the law:Additional Program Rules As required under the law Providers are required to develop Additional Program Rules. These are the rules clients must follow to participate in your program.
Providers have been working hard to turn in their Program Rules, however DHS has redefined the areas that should be covered in these program rules
16. Phase III:Changes to the Program Rules DHS has identified 10 areas that are under HSRA jurisdiction.
Rules should be focused on these areas
If there are additional procedures around implementing these rules they should be placed in an additional “client handbook.”
Areas that are addressed in the Universal Rules i.e. termination, suspension and transfer do not need to be repeated in your Additional Program Rules
17. Phase III: Additional Program Rules Template DHS has developed a template for Additional Program Rules
Additional Program Rules do NOT need to repeat Universal Program Rules
Goal of new format is to make the Additional Program Rules document simple and clear
All clients must have Universal Program Rules and Additional Program Rules explained to them and must sign them upon entry into program
Programs can also have a “client handbook” to provide further details regarding procedures (required for HUD funded programs/optional for other programs)
18. Additional Program Rules Template Rules should define expectations for clients and program
Rules must have a table of contents
Total number of pages must not exceed 7 pages including the table of contents
There is an exception for grievance and appeal processes required by other public funding sources for your program
A decorative cover page may be added without counting towards page limit
Font size of 12 with 1 inch margins around all sides
19. Additional Program Rules Template Table of Contents
Section names must appear exactly as they appear in the sample
May NOT add any other sections
Sections that do not apply to a program must still have the section and state “Does not Apply”
Example: Curfew for scattered site permanent housing programs
Must include program name and address on Table of Contents page
20. Additional Program Rules Overview of Required Sections
#1 Special Eligibility Criteria
#2 Curfew
#3 Visitation
#4 Case Management Requirements
#5 Behavior Requirements
#6 Pets
#7 Alternate Sanctions
#8 Grievance Policy and Procedures
#9 Appeal Procedure
21. #1 Special Eligibility Criteria Eligibility requirements above and beyond the Universal Program Rules
Do not restate eligibility requirements already in Universal program rules
Examples:
Shelter + Care: Eligibility determined by HUD regulations
Programs serving clients with a particular need (ie. Domestic violence, substance abuse, medical condition)
22. #2 Curfew Hours of curfew
Policy regarding exceptions
Policy regarding posting of curfew rules
Policy regarding the programs right to change curfew with notice to clients
Policy for overnight passes
23. #3 Visitation
Hours of visitation
Definition of “Visitor”
Cannot include professional assistance to client (ie. Attorney, mental health professional)
Policy regarding exceptions
Policy regarding posting of visitation rules
Policy regarding the programs right to change visitation with notice to clients
24. #4 Case Management Requirements Client requirements regarding meetings with case mangers
Client requirements regarding adherence to the service plan
Can use sub-sections from the sample rules, but they are not required
25. #5 Behavior Requirements Rules regarding client behaviors
Can use sub-sections from the sample rules, but they are not required
26. #6 Pets Policy regarding pets
If pets are not allowed in your program, we recommend that you include the “exception language” from the sample program rules
“Exceptions to the rule will be made for service animals in accordance with this program’s reasonable accommodation policy and the Americans with Disabilities Act.”
TCP will sponsor training around ADA “reasonable accommodations”
27. #7 Alternative Sanctions Outline steps of progressive discipline
Steps that would lead to client receiving 15 day termination notice.
Do not need to repeat any issues from Universal Program Rules
If program has a policy of providing increased client privileges, this policy can be included in this section
28. #8 Grievance Policy and Procedures Procedures must state:
Who and how complaints should be made
Define timeframe for response to client
Additional levels of internal appeal
For programs with multiple levels of grievance through other agencies, include reference to those procedures as well
Can include grievance policy from other public funding sources in its entirety (does not count towards page limit)
29. #9 Appeal Process Must use the following language:
You may request a fair hearing to appeal any decision by a service provider to transfer, suspend or terminate services, or any alleged violation of your client rights or provider standards which are listed in the Homeless Services Reform Act.
You may request a fair hearing in writing or verbally to the provider, the Department of Human Services, the Office of Administrative Hearings, or the Mayor. Please see the Universal Program Rules or your provider for information on how to request a fair hearing.
Can include appeal process from other public funding sources in its entirety (does not count towards page limit)
30. Client/Staff Acknowledgement Program Rules must have “Acknowledgement Statement”
“I acknowledge that I have received, understand and accept the Additional Program Rules of this program.”
And, if applicable: “I further understand that I must enforce these rules with my entire family.”
Space for client signature and date
Space for staff signature and date
Program should provide a copy to the client
31. Submission Requirements Additional Program Rules following this format are due to The Community Partnership by 5pm Friday, July 7.
Additional Program Rules must be submitted in Word format as an email attachment to
dmathews@community-partnership.org
32. Next Steps
Darlene Mathews at The Community Partnership will review all submissions and communicate any concerns regarding the rules with the provider
Rules will be submitted to DHS for review and approval
Providers will be given a bi-weekly status report of their rules and notified in writing by The Community Partnership when their rules have been approved by DHS
33. Changes to Approved Rules After Additional Program Rules have been approved:
The current Additional Program Rules and any client handbooks will be required to be re-submitted to The Community Partnership as a contract deliverable each year
TCP will forward the Additional Program Rules to DHS each year for re-approval
34. Changes to Approved Rules During the program year, if providers change the approved Additional Program Rules for
Eligibility
Alternative Sanctions
Grievance
The changes must be approved by DHS before the change is implemented following the same process as the initial submission
35. Wrap Up All HSRA information is available at www.community-partnership.org/initiatives/hsra
Additional Program Rules are due to dmathews@community-partnership.org by 5pm July 7
Use Sample format
36. Questions