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American Recovery and Reinvestment Act of 2009 ARRA Homelessness Prevention Rapid Re-Housing Program HPRP

HPRP Purpose. The purpose of HPRP is to provide homelessness prevention assistance to households who would otherwise become homeless ? many due to the economic crisis ? and to provide assistance to rapidly re-house persons who are homeless.HUD strongly encourages targeting assistance to those individuals/families at greatest risk of becoming homeless and who can remain stably housed after this temporary assistance ends..

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American Recovery and Reinvestment Act of 2009 ARRA Homelessness Prevention Rapid Re-Housing Program HPRP

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    1. American Recovery and Reinvestment Act of 2009 (ARRA) Homelessness Prevention & Rapid Re-Housing Program (HPRP) Missouri Department of Social Services Family Support Division August 7, 2009

    2. HPRP Purpose The purpose of HPRP is to provide homelessness prevention assistance to households who would otherwise become homeless – many due to the economic crisis – and to provide assistance to rapidly re-house persons who are homeless. HUD strongly encourages targeting assistance to those individuals/families at greatest risk of becoming homeless and who can remain stably housed after this temporary assistance ends.

    4. HPRP is NOT A mortgage assistance program Intended to serve persons who need long-term and/or intensive supports ESG Program Different eligibility requirements Different eligible activities

    5. Definitions Grantee: County or county designee that applies for and receives an HPRP allocation. The designee must be another unit of local government. Subgrantee: The non-profit, 501(c), agency/organization, and/or other unit of local government, that the grantee subcontracts with to provide services. Unit of Local Government: Any city, county, town, township, parish, village, or other general purpose political subdivision of the state.

    6. Change We Can Believe In and Sustain Consider how prevention and emergency assistance is currently provided in your community. With this large amount of funding, with local control, can you design a system that changes what is broken today, not just for now but for the long term? Do people in your community have to go to multiple emergency assistance centers to gather enough money to pay their rent in a time of crisis? Do people in your community receive supportive services when they need rental assistance? Do people in your community that receive mainstream resource benefits access support if they are in a financial crisis to ensure they really are getting benefits they need?

    7. Guiding Principles Resources should be targeted to households with the highest likelihood of becoming homeless. Programs should provide just enough assistance to prevent or end an episode of homelessness stretching resources as far as possible. Distribution of funds should achieve maximum access for needy Missourians while minimizing administrative costs to the extent possible. Other federal, state, and local funds, including other ARRA funds must be coordinated. HPRP funds should supplement and compliment existing programs and subgrantees should have the infrastructure, capacity, and experience to rapidly get funds to Missourians with housing needs that have been caused by the downturn in the economy.

    8. Planning for HPRP Consider including – those in your community who are currently doing prevention work. Think about who are the emergency assistance providers…who gets your FEMA money for emergency rent/utility assistance? Make sure your CoC leadership is involved! Consider access into the program: Do you have a 211 system that could screen and direct clients most at-risk? Do you have a “common intake into shelter” system that could screen and divert to the program? Who do persons in need currently turn to for assistance with rent or utilities?

    9. Eligible Applicants – County or County Designee Counties may apply for funding or designate another “unit of local government” to apply on their behalf. Non-profits are not “units of local government” nor are Regional Planning Commissions. These agencies may be subgrantees, but not grantees. The grantee is ultimately responsible for funding.

    10. Eligible Applicants – County or County Designee Counties should assess their capacity for monitoring, reporting and accountability. We continue to encourage counties with infrastructure or capacity issues, to pool their allocations with other counties designating a “lead county” to accept their allocations. This allows one contract with DSS for a group of counties and one contract with the non-profit(s) in the area making overall contract management and service delivery less confusing.

    11. Selection of Subgrantees It is critical that every effort should be made to select the best possible subgrantees with the capacity, experience, and infrastructure to distribute HPRP funds in the most efficient, effective and accountable manner. A competitive bid process is not required by DSS when selecting subgrantees (unless the county requires that as part of a local procurement process). However, DSS strongly encourages counties to develop a method to evaluate all possible subgrantees based on the overall needs and resources currently available in the county, experience and expertise, organizational structure and capacity, population served, and future sustainability. DSS also encourages utilizing multiple subgrantees to ensure services are accessible to appropriate populations in all geographic areas.

    12. Funding Available DSS notified each county’s Presiding Commissioner of the allocation available for his/her county. DSS allowed the county to decide: Whether to apply or to designate another unit of local government (city or county) to apply on its behalf, and Whether to provide services directly or subcontract to a 501(c) for direct service provision.

    13. General Requirements HPRP may serve individuals or families. Payment must be made to a third party (e.g. landlord or utility company). Payment cannot be made directly to a participant An assisted property may not be owned by the grantee, subgrantee, or the parent subsidiary or affiliated organization of the subgrantee. Grantees who use funds for ineligible purposes must reimburse DSS.

    14. Eligible Activity Categories Financial Assistance Housing Relocation and Stabilization Services Data Collection Administration “Activities are intentionally focused on housing – either financial assistance to help pay for housing or services designed to keep people in housing or to find housing.”

    15. Focused Activities Services must focus on: Housing stabilization Linking program participants to community resources and mainstream benefits Helping clients develop a plan to prevent future homelessness or housing instability

    16. Eligible Activities: Financial Assistance Rental Assistance – Goal is to maintain someone in housing. Participants may qualify for: Short-term rental assistance – not to exceed 3 months. Medium-term rental assistance – not to exceed 4-18 months. Rental arrears not to exceed 6 months. Rental Assistance is limited to 18 months total per participant (Example: 3 months short-term, plus 10 months medium-term, plus 5 months rental arrears equals 18 months of service).

    17. Eligible Activities: Financial Assistance Rental Assistance (continued) Grantees may choose to provide maximum benefits or more limited benefits. They may also determine whether to provide: Shallow subsidy (payment of a portion of the rent) 100% of rent Graduated/declining subsidy Ineligible: No rental assistance may be provided to persons in subsidized housing (e.g. Section 8, SPA, HA, CoC other than the client portion of any arrears) No mortgage assistance may be provided

    18. Eligible Activities: Financial Assistance Rent reasonableness tests are required. For more information, see HUD’s worksheet on rent reasonableness at: www.hud.gov/offices/cpd/affordablehousing/library/forms/rentreasonablechecklist.doc

    19. Eligible Activities: Financial Assistance Security and utility deposits Utility assistance – Up to 18 months total, including up to 6 months in arrears. Utilities eligible for assistance are heat, electricity, water, sewer, and garbage disposal. Telephone and cable services are not eligible. Unless it can be documented that a family would be homeless but for having the utility bill paid by HPRP, funding sources other than HPRP should be explored to assist with utilities. Simply having a shutoff notice does not mean a participant would become homeless unless, for example, city codes require that tenants have current utilities.

    20. Eligible Activities: Financial Assistance 4. Assistance with reasonable moving costs, such as: Moving truck rental Hiring a moving company Moving cost assistance (includes short-term storage fees - maximum of 3 months or until the participant is in housing)

    21. Eligible Activities: Financial Assistance Hotel/Motel Vouchers Though generally not a Prevention Activity – HPRP funding may be used to provide hotel or motel vouchers. Hotels must be reasonable and appropriate facilities. No voucher may be issued for more than 30 days. Vouchers may only be issued if NO shelter beds are available AND subsequent rental housing has been identified but is not immediately available for move-in by participants.

    22. Eligible Activities: Financial Assistance Staff costs for issuing financial assistance. Examples of costs would be cost for eligibility determination, assessment, cutting a check, and other similar payment processes. Inspections - Costs for inspections for Habitability Standards and Lead-Based Paint requirements. Complete records of inspections and follow-up actions must be maintained in client files.

    23. INELIGIBLE Activities: Financial Assistance Duplicating payments Using HPRP funds and another source for exact same cost type for same time period Mortgage assistance/costs Operations for housing programs Assistance longer than 18 months Direct payments to program participants Payment of credit arrears (credit cards, loans, etc.)

    24. Eligible Activities: Housing Relocation and Stabilization Services Housing Relocation and Stabilization Services may be used for services that assist program participants with housing stability and placement: Case management; Outreach and engagement; Housing search and placement including counseling related to locating, obtaining, and retaining suitable housing; Legal services to help people stay in their homes (Legal services related to mortgages are not eligible); Credit repair; and Staff costs relating to any of the above.

    25. INELIGIBLE Activities: Housing Relocation and Stabilization Services Non-housing services such as: Child Care Employment training Education (i.e. books, fees, tuition, etc.) Transportation (i.e. gas, bus tokens, cabs, etc.) Food, household items, clothing Furniture and appliances Discharge planning at institutions

    26. Data Collection and Evaluation Data collection costs are limited to 2% of total grant award. Data collection will be conducted through the use of a HMIS. Client level data will be collected and managed in the local HMIS. Grantees will use this information to report to DSS in a format yet to be determined. In addition to client level data, grantees will be reporting on additional information required under HPRP and ARRA. Domestic Violence Shelters are exempt from entering information into HMIS, but must utilize a comparable data base. (See special instructions for DVS’ on application.)

    27. Data Collection and Evaluation: Domestic Violence Providers “Domestic violence providers” must collect client-level data in a “comparable database” and report aggregate data to the grantee “Domestic violence providers” are organizations with primary mission to serve victims of domestic violence, dating violence, sexual assault or stalking “Comparable database” means must be consistent with HMIS Data and Technical Standards and meet HPRP reporting requirements

    28. Eligible Activities: Data Collection and Evaluation Reasonable costs for collecting and reporting HPRP data through HMIS Software and hardware costs Connectivity costs HMIS HPRP training (users and system administrators) Participation fees for providers using the HMIS Some funding will be provided to support CoC HMIS operations in certain areas of the state. Grantees should coordinate with their local CoC.

    29. INELIGIBLE Activities: Data Collection and Evaluation Planning or developing alternative data system to HMIS Replacing local or state funding EXCEPT when state/local funding is no longer available Contracting for program evaluation

    30. Administrative Costs Grantee administrative costs are limited to three percent (3%) of the total grant award. Grantees are encouraged to share a portion of their administrative funds with Subgrantees. Subgrantees administrative costs should be identified as program operating cost under each of the other three eligible activity categories whenever possible.

    31. Eligible Activities: Administrative Costs Accounting for the use of grant funds Preparing reports for submission to DSS Obtaining program audits Grantee/Subgrantee staff salaries associated with eligible administrative costs Training for staff that is directly related to learning about HPRP

    32. INELIGIBLE Activities: Administrative Costs Staff costs for issuing financial assistance or providing services General training (i.e. for a case manager to gain credentials) Training or technical assistance from someone other than HUD-approved national TA provider

    33. Ineligible or Prohibited HPRP Activities General Payment of mortgage assistance Operation of emergency shelters or other ongoing program costs Transitional housing Construction/rehabilitation Credit card bills or other consumer debt Car repair or other transportation costs Travel costs Food Medical, dental care, or medicine

    34. Ineligible or Prohibited HPRP Activities General Clothing or grooming Home furnishings Pet care Entertainment Activities Work or education related materials Cash assistance to program participants Any other activity that another Recovery Act Resource may pay for – including child care and employment training

    35. Inspections: Habitability Standards To qualify for funding under HPRP rental units must meet habitability standards (as described in Appendix A of the Funding Application Guidelines) and any federal, state, or local ordinances (specifically excluding environmental reviews and requirements under the National Environmental Policy Act of 1969). Inspections must be conducted at initial occupancy, when a participant moves into a new unit, and annually as long as the participant is receiving HPRP assistance. Grantees may require more stringent standards. Habitability standards do not require a HUD certified inspector.

    36. Inspections: Lead-Based Paint Lead-Based Paint requirements are more stringent than the habitability standards, and apply to all housing in which families assisted with HPRP funds will reside, whether they are assisted with homelessness prevention or rapid re-housing. Lead-Based Paint regulations apply to the unit and to common areas servicing the unit if the unit was constructed before 1978 and a child under age 6 will be residing in the unit.

    37. Inspections: Lead-Based Paint Exemptions from this regulation are defined in 24 CFR Part 35.115 and include: zero-bedroom or SRO-sized units, housing for the elderly and there are no children under age 6, units where an inspection has been conducted in accordance with HUD regulations and found not to have lead paint or had lead paint identified and removed as required by HUD, or any of the other exemptions in this section.

    38. Inspections: Lead-Based Paint An initial visual assessment and periodic inspections are required for as long as HPRP assistance is received. The unit must be inspected again when a new family assisted with HPRP funds moves in, and the clock for periodic inspections is reset. The owner must provide a notice to occupants if an evaluation and hazard reduction activities have taken place, in accordance with 24 CFR part 35.125. Please carefully read the regulations that implement the Lead-Based Paint Poisoning Prevention Act, at 24 CFR part 35, subparts A, B, M, and R.

    39. Inspections: Lead-Based Paint Visual assessment means looking for: Deteriorated paint; Visible surface dust, debris, and residue as part of a risk assessment or clearance examination; or The completion or failure of a hazard reduction measure. Per 24 CFR part 35.115 Visual assessments must be conducted by a HUD-Certified Visual Assessor.

    40. Inspections Who will conduct inspections? What qualifications will be required of habitability inspectors? What forms will they use? For sample Housing Quality Standards (HQS) checklist see: http://www.hud.gov/offices/cpd/affordablehousing/library/forms/hqschecklist.pdf. This checklist may be used at the Grantee’s discretion although these requirements are more stringent than required under HPRP.

    41. Targeting for At Risk of Homelessness Participants (Prevention) “Risk Factors” for grantees to consider: Eviction within 2 weeks Discharge from institution within 2 weeks Residency in condemned housing Sudden loss of income or increase in utility costs Mental health and substance abuse issues Extremely low income Significant medical debt

    42. Targeting for Homeless Participants (Rapid Re-Housing) Individuals and families are homeless if: Sleeping in emergency shelter Sleeping in place not meant for human habitation Staying in hospital or institution for up to 180 days, but literally homeless immediately prior to entry Graduating from/timing out of transitional housing or foster care Victim of domestic violence

    43. Program Design HPRP provides flexibility to grantees to meet the needs in their communities Grantees determine type of subsidy (declining, shallow, etc.) and may set more stringent requirements. How do grantees determine who should receive HPRP assistance? How can grantees use funds most efficiently to serve as many as possible?

    44. Program Design Grantee programs should ensure that there is a clear process for determining the type, level, and duration of assistance for each program participant. Other than the requirement of being “needs based”, Grantees/ Subgrantees have the flexibility to determine: The MINIMUM amount needed to assist a case/participant. A maximum per case limit. Average assistance budgeted per case. A maximum number of times the same case can be assisted.

    45. Application/Reassessment/ Recertification Process All cases assisted must have at least an initial consultation with a case manager, and have eligibility reassessed/recertified a minimum of every three months.

    46. Requirements for Program Participants Household must be at or below 50% of Area Median Income (See: http://www.huduser.org/DATASETS/il.html) Household must be at-risk of losing its housing and meet both the following circumstances: No other housing options. AND No financial resources or support networks to obtain or remain in housing.

    47. At Risk of Becoming Homeless Prevention Activities Counties and subgrantees should take care in establishing and documenting that participants would be homeless “but for” this assistance.

    48. Grantee Responsibilities: General Ensuring appropriate use of funds and accurate and timely reporting and funding draws Monitoring subgrantee(s) Coordinating with Continuums of Care Grantees/Subgrantees responsible for coordinating with local organizations funded by other Recovery Act funds

    49. Grantee Responsibilities: Local Coordination HPRP must be administered in coordination with existing CoC’s and other local homeless planning efforts to: Identify local level gaps and needs for HPRP services Promote collaborative use of Recovery Act funds Align HPRP with CoC strategies for preventing and ending homelessness

    50. Grantee Responsibilities: Leveraging Other Resources Grantees are strongly encouraged to maximize all Recovery Act resources Recovery Act funding for serving homeless and at-risk persons also provided to other federal agencies (i.e. Education, HHS, Labor, etc.) Chart of Recovery Act resources and opportunities for collaboration posted at www.hudhre.info

    51. Grantee Responsibilities: Participant Eligibility Grantees or Subgrantees must: Verify and document each client’s eligibility for the program (homeless or at-risk); Assess each household’s need and appropriateness for HPRP assistance; and Evaluate eligibility for assistance every 3 months.

    52. Additional Certifications Grantees/Subgrantees must certify that they will comply with laws regarding: Conflict of interest; Nondiscrimination and Equal Opportunity Requirements; Fair Housing and Civil Rights Laws; Lead-Based Paint Requirements; Uniform Administrative Requirements; Equal Participation of Religious Organizations; Lobbying and Disclosure; Drug-Free Workplace Requirements; Procurement of Recovered Materials; and Environmental requirements do not apply.

    53. Invoicing/Expenditures Anticipated invoicing process is as follows: Grantees may invoice for up to 25% of total funds immediately. Grantees must submit monthly expenditure reports. Grantees may request an additional 25% of funds when they have expended 80% of their previously invoiced amount.

    54. Key Expenditure Dates 60% of allocation must be spent within 2 years of grant execution, but all funds may be expended in the 1st and/or 2nd year. DSS will consider reallocating any remaining funds for year 3 based on expenditures and performance in the first two years. 100% of allocation must be spent within 3 years of grant execution.

    55. GENERAL INFORMATION No match for these funds is required. Local jurisdictions, private foundations, etc. may add to the funds available.

    56. General Reporting Grantees are required to report to DSS, in a format yet to be determined, based on client level contained in HMIS and additional reporting requirements relating to ARRA and Government Transparency. Quarterly performance reports – due to DSS the 1st day of the month following the reporting calendar quarter – First quarterly report due October 1, 2009. Monthly expenditure reports – due to DSS the 10th of each month following the provision of services Annual performance reports – due to DSS 30 days after the end of the fiscal year

    57. Reporting: American Recovery and Reinvestment Act (ARRA) The total amount of ARRA funds the grantee received from the State of Missouri The dollar amount of ARRA funds that were expended or obligated for each project or activity

    58. Reporting: American Recovery and Reinvestment Act (ARRA) (continued) A detailed list of all projects or activities for which ARRA funds were expended or obligated, including: The name of the project or activity; A description of the project or activity; An evaluation of the completion status of the project/activity; An estimate of number of jobs created and the number of jobs retained by the project or activity including narrative regarding the employment impact on the local economy; and For infrastructure investments, the purpose, total cost, and rationale for funding the infrastructure investment.

    59. Reporting: Government Funding Transparency Act of 2008 (including but not limited to) The name of the grantee and each subgrantee receiving an award; The amount of each award; The transaction type; The Catalog of Federal Domestic Assistance number; The program source;

    60. Reporting: Government Funding Transparency Act of 2008 - including but not limited to (continued) The location of the entity receiving the award, including two data elements for the city and Congressional district; The location of the primary place of performance under the award, including two data elements for the city and Congressional district; A unique identifier of the grantee/subgrantee receiving the award;

    61. Reporting: Government Funding Transparency Act of 2008 - including but not limited to (continued) A unique identifier of the parent entity for the subgrantee, should the subgrantee be owned by another entity; and The names and total compensation of the five highest compensated officers of the company if 80% federally funded AND $25 million in annual gross revenue is from federal funds.

    62. Monitoring DSS, or an agent, will conduct monitoring reviews. Grantees are required to adequately and appropriately monitor subgrantees compliance with ARRA, HPRP, and other federal, state, and local requirements.

    63. Timeline Consolidated Plan Amendment was submitted to HUD May 18, 2009. HUD signed grant agreement on July 22, 2009. Grant applications due back to FSD August 17, 2009. Funds must be obligated by DSS by September 30, 2009. First DSS report to HUD due October 10, 2009. First DSS quarterly report due to HUD January 10, 2010, (quarterly report due from Grantee to DSS by January 1, 2010).

    64. Contact Jeannie Chaffin or Jayme Abbott Family Support Division P. O. Box 2320 Jefferson City, MO 65102-2320 (573) 751-6789 Jeannie.L.Chaffin@dss.mo.gov Jayme.A.Abbott@dss.mo.gov

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