Balance of State Continuum of Care Written Standards Training

1. Balance of State Continuum of Care Written Standards Training • February 4, 2019 Tina Moore, CoC Program Coordinator

2. Goal of Written Standards • Make policy or recommendations for projects to serve people who are homeless with as few barriers as possible; • Projects have made much progress in this area, and the Written Standards are designed to: • continue that progress • be cognizant of the variance of the way projects are set up and what works locally across 152 counties • focus on client needs (rather than limited project design)

3. What are Written Standards? • Continuum of Care (CoC)-Specific Requirements (578.7(a)(9)): • The CoC must establish and follow written standards for recipients and subrecipients providing assistance with CoC Program funds. They must be developed in consultation with the ESG recipient(s) also funding projects within the CoC’s geographic area. • Policies and procedures for: • Evaluating individuals’ and families’ eligibility for assistance through the CoCProgram • Determining and prioritizing eligible individuals and families for Transitional Housing, Rapid Re-Housing, and Permanent Supportive Housing assistance • Determining the percentage and amount of rent program participants must pay while receiving rapid re-housing assistance • BoSCoC Governance Charter requires that we receive provider input and develop these standards for all project types

4. How do Written Standards relate to ESG? • In addition to CoC-funded recipients, Emergency Solutions Grants (ESG) recipients are required to develop similar policies and procedures for subrecipients to use when providing ESG assistance with ESG Program funds (see 24 CFR 576.400(d)). • Ideally, CoC and ESG recipient(s) collaborate to coordinate and/or align to ensure all populations eligible for assistance within the geographic area are assessed and prioritized for available assistance as consistently as possible.

5. ESG Written Standards • The written standards for providing ESG assistance must include policies and procedures that address the following: • Evaluating eligibility for ESG assistance; • Targeting and providing essential services related to street outreach activities; • Admission to, diversion from, referral to, and discharge from emergency shelters; • Assessing, prioritizing, and re-assessing the need for essential services related to street outreach; • Coordination among other emergency shelter, essential service, homelessness prevention, and rapid re-housing providers as well as with other mainstream housing and service providers; • Determining and prioritizing individuals and families for homelessness prevention and rapid re-housing assistance; • Determining the percentage and amount of rental assistance and utilities each program participant must pay while receiving homelessness prevention or rapid re-housing assistance; • Determining the amount and duration of rental assistance, including how the amount will be adjusted over time, as appropriate; and • Determining the type, amount, and duration of housing stabilization and/or relocation services.

6. Which Projects do these CoC Written Standards Impact? • Balance of State CoC-funded projects MUST follow the Balance of State CoC Written Standards • State ESG-funded projects/sub-recipients in the Balance of State MUST follow these Written Standards • For providers in areas where DCA ESG funds are used in conjunction with non-BoSCoC entitlement ESG funds and where written standards may conflict with DCA’s, the DCA minimum standards will take precedence. If the local standards are more stringent, they can be followed • The CoCSTRONGLY ENCOURAGES other projects that do not receive CoC funds to adhere to them as well.

7. Preparation of Written Standards • DCA staff worked with HUD TA Providers to assess alignment with federal requirements and priorities. • DCA staff reviewed the draft written standards with GA Balance of State CoC ESG Entitlements (Clayton County, Gwinnett County, Macon-Bibb County, and the State of Georgia). • In addition to consultation, we’ve worked with the State of Georgia, Clayton County, and Gwinnett County ESG program staff to incorporate HUD’s requirements of ESG recipients into the draft.  • DCA staff reviewed with a sub-committee of the Standards, Rating & Project Selection Committee. • DCA staff reviewed draft with a select group of providers to obtain provider input.

8. CoC Written Standards Approved • May 15, 2017 – Approved by Standards, Rating & Project Selection Committee (moved to Board) • May 24, 2017 – Approved by BoSCoC Board • To be updated annually or as data available (Approved as Updated on 5-23-18) • These standards tie into CE Written Standards • Next Steps: • Went into effect in 2017 (projects should have already updated policies & procedures for projects)

9. General Standards The written standards for providing assistance include policies and procedures that address the following: 1. HMIS Participation 2. Coordinated Entry Process (a/k/a Coordinated Assessment System) 3. Removal of Barriers 4. Termination of Assistance 5. Faith-based Activities 6. Fair Housing and Equal Opportunity 7. Language Access Plan 8. Allowable Family Limitations and Prohibition against Involuntary Family Separation 9. Equal Access Requirements 10. Violence Against Women Act (VAWA) Requirements

10. Street Outreach Projects

11. Street Outreach • Project Definition • HUD Eligibility Requirements (Category 1) • CoC Recommendations (policy on safety standards, engagement during times where reasonable expectation homeless w/no housing options) • Required Documentation of Homelessness • Assessment/Prioritization: • Assessment where they are/will be offered services of engagement, case management, emergency health and mental health, and transportation services (where not available in mainstream), • Must assess, prioritize, and re-assess need for services, and continuously engage even if services declined). • When appropriate based on individual’s needs and wishes, referral to permanent supportive housing or rapid re-housing as a priority over shelter. • Required to utilize Coordinated Entry Prosess as outlined on Coordinated Entry Written Standards.

12. Emergency Shelters

13. Emergency Shelters • Project Definition • HUD Eligibility Requirements (Categories 1, 2, & 4) • CoC Recommendations (expedited admission policies, no initial ID requirement, no fees) • Required Documentation of Homelessness • Assessment/Prioritization (Coordinated Entry, priority for those with no or extremely low income (<30% AMI)

14. Transitional Housing Projects

15. Transitional Housing (TH) • Project Definition • HUD Eligibility Requirements (Categories 1 & 4) • CoC Requirements (priority for those with no or extremely low income (30% AMI), removal of barriers, Entitlement jurisdictions may further restrict funding of TH projects to serve high barrier households and/or special needs populations as they determine) • CoC Recommendations: • Reserve for youth, safety for persons fleeing DV, and recovery projects • Individuals and families entering are not expected to be able to qualify for permanent housing. • Further, enrollment of a chronically homeless person into TH causes them to loose their chronically homeless determination making them ineligible for many programs • Coordination with PH. • Using TH beds as bridge housing where shelter isn’t available if PSH identified (NO enrollment in TH) • Required Documentation of Homelessness • Assessment/Prioritization (Coordinated Entry, priority for those with no or extremely low income (<30% AMI))

16. Rapid Re-Housing Projects (RRH)

17. Rapid Re-Housing Projects (RRH) • Project Definition • HUD Eligibility Requirements (Categories 1 & 4, ESG requires at or <50% AMI)) • CoCRequirements (removal of barriers, accept those with no income, case management and related services to be offered but not required for all receiving rental assistance and to those not receiving rental assistance at agency discretion) • CoC Recommendations (general limitations on time and amount of rental subsidy and documentation requirements) • RRH Client Contribution Policy as Required by HUD-declining subsidy goal • Rent Determination Procedures (Monthly subsidy amount evaluations, agency discretion on what client can contribute) • Required Documentation of Homelessness (and Income for ESG RRH) • Assessment/Prioritization (Coordinated Entry, priority for those with extremely low income (<30% AMI) and those with longer lengths of stay) • ESG RRH Requirements (monthly utility assistance determinations, agency discretion in determining what a family can contribute and what housing stabilization and/or relocation services financial assistance can be offered)

18. Homeless Prevention Projects

19. Homeless Prevention • Project Definition • HUD Eligibility Requirements (Categories 2 & 4 or meet “at risk” definition, income <30% AMI), no other resources or support network to prevent moving to shelter) • CoCRequirements (removal of barriers to project entry and barriers to remain in project) • CoC Recommendations (participants should receive case management plan, best practice agencies with ability to negotiate with landlords as first step and plan for participants to increase income, length of stay based on needs, goal of 100% subsidy no longer than 6 months, total assistance goal to be no longer than 12 months), with extensions up to 18 months for households with no income or special circumstances with evaluation of circumstances documented in file) • Prevention Client Contribution Policy (policy to provide declining rental assistance with reasonable percentage of contribution based on household’s income

20. Homeless Prevention (cont’d.) • Rent Determination Procedures (households will receive declining subsidy based on their ability to pay rent, subsidy determinations evaluated no less than monthly in case management meetings, flexibility in determining percentage and how subsidy will be reduced based on income, needs of household, and best interest of the household’s housing stability) • Required Documentation (lease in participant’s name, documentation of pending loss of housing can include eviction notice (or equivalent as allowed by law), a Notice to Quit, or Notice to Terminate issued under state law) • Assessment/Prioritization (Utilize Coordinated Entry Process as outlined in Coordinated Entry Written Standards) • ESG RRH Requirements (Monthly Utility assistance determinations, agency discretion in determining what a family can contribute and what Housing Stabilization and/or Relocation Services financial assistance can be offered)

21. Supportive Services Only Projects

22. Supportive Services Only • Project Definition • HUD Eligibility Requirements (Categories 1 & 4) • CoC Requirements (removal of barriers) • CoC Recommendations (expectation of projects to connect participants to permanent housing) • Required Documentation of Homelessness • Assessment/Prioritization (utilize Coordinated Entry Process as outlined on Coordinated Entry Written Standards)

23. Permanent Supportive Housing Projects (PSH)

24. Permanent Supportive Housing (PSH) • Project Definition • HUD Eligibility Requirements (Categories 1 & 4, limited to individuals and families where one adult or child has a disibility) • DedicatedPLUS Eligibility • 100% bed dedication • Chronic, literally homeless for a year but not on four separate occasions, or in a VA TH program who meets one of the listed criteria at ignition intake into VA program) • CoC Requirements (removal of barriers) • CoC Recommendations (Service Provision Criteria, 85% of CoC-funded non-dedicated PSH beds available through turnover prioritized for chronically homeless, terminations of assistance must follow formal process that recognized due process of law and assistance of participants should be terminated only in most severe cases) • Required Documentation of Homelessness AND Disability (and Length of Time for Chronic) • Assessment/Prioritization (Coordinated Entry Process as outlined in the Coordinated Entry Written Standards Policies and Procedures, follow target population allowed in contract) • Additional documentation required for evidence there are no households meeting higher order of priority when applicable

25. Permanent Supportive Housing (PSH) • CoC Recommendations • Service Provision Criteria: • In providing or arranging for housing, the project considers the needs of the individual or family experiencing homelessness. • The project provides assistance in accessing suitable housing. • The project may provide assistance with moving costs. • The project signs occupancy agreements or leases (or subleases) with all project participants residing in housing. • The project enters into an occupancy agreement or lease agreement (or sublease) with project participant for a term of at least once year, which is terminable for cause. The lease must be automatically renewable upon expiration for a minimum term of one month. Assistance may be extended as stated in 24 CFR 578.79. • For projects where regulations require individuals and families residing in permanent supportive housing to pay occupancy charges or rent, occupancy charges and rent may not exceed those specified in 24 CFR 578.77. • At least 85 percent of the CoC Program-funded permanent supportive housing beds that become available through turnover must be prioritized for chronically homeless individuals and families. However, CoC-funded PSH projects that commit above this amount in a competition, are held to the higher amount.

26. Permanent Supportive Housing (PSH) • Termination of Services • In terminating assistance to a program participant, the interim rule provides that a recipient or subrecipient must provide a formal process that recognizes the due process of law. • Recipients or subrecipients that are providing permanent supportive housing for hard-to-house populations of homeless persons must exercise judgment and examine all circumstances in determining whether termination is appropriate. • Under the Continuum of Care Interim Rule, it was determined that a participant‘s assistance should be terminated only in the most severe cases.

27. Permanent Supportive Housing (PSH) • Required Documentation • As defined in the HEARTH Act, eligibility for Permanent Supportive Housing is limited to categories 1 and 4 (Fleeing/Attempting to Flee DV) if they also meet the definition in Category 1. Participants must also: • Enter from the street or shelter, or a transitional housing project to which they originally entered from the street or shelter (NOTE: if the project is designated for chronically homeless, they may only enter from the street or shelter. Individuals may lose their chronically homeless designation after they are enrolled into a transitional housing project); and • The head of household, or at least one member of the household, must have a disability of long duration, verified either by Social Security or a licensed professional that meets the state criteria for diagnosing and treating that condition*. *HUD’s Sample Chronic Homelessness Documentation – 2016 guidance, which includes a list of acceptable documentation to verify disability status, can be found at: https://www.hudexchange.info/resources/documents/Sample-Chronic-Homelessness-Documentation-Form-2016.docx.

28. Permanent Supportive Housing (PSH) • Required Documentation • Documentation must be included in the case file, and/or scanned into the HMIS client record that demonstrates eligibility as follows: • Literally Homeless (in order of preference) • Third party verification (HMIS print-out, or written referral/certification by another housing or service provider); or • Written observation by an outreach or intake worker; or • Certification by the individual or head of household seeking assistance stating that (s)he was living on the streets or in shelter; • For individuals exiting an institution – one of the forms of evidence above and; • Discharge paperwork or written/oral referral, or • Written record of intake worker’s due diligence to obtain above evidence and certification by individual that they exited institution • If the provider is using anything other than a Third Party Verification, the case file must include documentation of due diligence to obtain third party verification.

29. Permanent Supportive Housing (PSH) • Assessment/Prioritization Tool Factors In the Following: • Order of Priority in PSH Beds Dedicated to Persons Experiencing Chronic Homelessness • First Priority - Chronically Homeless Individuals/Families with the Longest History of Homelessness and with the Most Severe Service Needs • Second Priority - Chronically Homeless Individuals/Families with the Longest History of Homelessness • Third Priority - Chronically Homeless Individuals/Families with the Most Severe Service Needs • Fourth Priority - All Other Chronically Homeless Individuals/Families • Order of Priority in PSH Beds Not Dedicated or Prioritized for Persons Experiencing Chronic Homelessness • First Priority - Homeless Individuals/Families with a Disability with Long Periods of Episodic Homelessness and Severe Service Needs • Second Priority - Homeless Individuals/Families with a Disability with Severe Service Needs • Third Priority - Homeless Individuals/Families with a Disability Coming from Places Not Meant for Human Habitation, Safe Havens, or Emergency Shelters Without Severe Service Needs • Fourth Priority - Homeless Individuals/Families with a Disability Coming from Transitional Housing

30. Next Steps and Resources

31. Next Steps • Programs should have already adopted the written standards and included them in their policies and procedures. • DCA to request policies and procedures from BoSCoC-funded providers • DCA will monitor to determine alignment (ESG and CoC) • The VAWA Policies and procedures, including the Emergency Transfer plan, were due to have been adopted by November 30, 2017 (CoC-funded providers).

32. Resources • DCA’s Continuum webpage https://www.dca.ga.gov/safe-affordable-housing/homeless-special-needs-housing/georgia-balance-state-continuum-care • HUD’s Continuum of Care Interim Rule & Ammendmenthttps://www.hudexchange.info/resource/2035/coc-program-interim-rule-formatted-version/ • HUD’s Continuum of Care webpage – https://www.hudexchange.info/programs/coc/

33. Thank you so much for your participation! • Questions? • Mike Thomas – (404) 679-0571 Michael.Thomas@dca.ga.gov • Tina Moore – (404) 327-6870 tina.moore@dca.ga.gov • April Woods – (404) 679-0651 April.Woods@dca.ga.gov