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HOME Investment Partnership Webinar Going Beyond Mainstream Category 2 and Other Housing Choice Vouchers March 10, 2011 3:00 - 4:30 pm ET.
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HOME Investment Partnership Webinar Going Beyond Mainstream Category 2 and Other Housing Choice Vouchers March 10, 2011 3:00 - 4:30 pm ET
Thousands of people with disabilities are institutionalized in nursing homes across the country and are interested in transitioning back to the community. One of the primary barriers they face to transition is a lack of affordable, accessible housing. Now that the Category 2 Mainstream vouchers have been announced, this webinar will help States find other housing funds to transition people who want to reside in the community. There are federal housing funds available in each State, but they are not being used to transition people out of nursing homes. State Medical Assistance officials need to understand how these funds can be accessed and most importantly to develop a State strategy to show your Governor/State housing department how your State can save State general revenue dollars and comply with ADA. Describe elements of a possible advocacy process: This is a 2 to 3 year process. Provide state-by-state data and contact information (Appendices). Purposes of Webinar 2
Appendix A: Cumulative HOME Budget by Statewide Participating Jurisdiction. Appendix B: Percent Uncommitted Cumulative Statewide Participating Jurisdiction Funds. Appendix C: Cumulative Tenant Based Rental Assistance (TBRA) Expenditures by Statewide Participating Jurisdiction. Appendix D: Annual Home Allocations by Statewide Participating Jurisdiction for 2008-2010. Appendix E: Federal Medical Assistance Percentages (FMAP). Appendix F: Medicaid 1915(c) Home & Community Based Services (HCSB) Waivers Average Expenditures Per Person Served, by State. Appendix G: Nursing Home Medicaid Per Diem (Daily) Reimbursement Rates by State [from industry’s report]. Appendix H: Agencies designated as state Participating Jurisdictions with telephone numbers. State by State Information 3
HUD’s HOME Investment Partnership Most Medicaid advocates have focused, understandably, on local Public Housing Authorities. PHAs do receive and administer the Housing Choice Vouchers – Section 8 and other voucher programs. Many PHAs applied for the vouchers issued under the FY 2009 Rental Assistance for Non-elderly Persons with Disabilities – both Category 1 and 2 vouchers, but unfortunately were not grantees. Purpose of today’s webinar to consider one alternative source of housing opportunities: HUD’s HOME program. 4
How Does the HOME Program Work? HOME is a “block grant” funded annually by Congress (FY 10, $1.825 billion). The amount your State received is based on a formula based on relative poverty rate, poor families in rental housing, age of housing, housing condition, etc. State “Participating Jurisdiction” [PJs] receive 40% of the HOME appropriation (some receive much more and others less than 40%), and local PJs get about 60%. Each State has a “statewide” PJ and has “local” PJs, based on size of city, county, or consortium of counties. (Appendix A lists the cumulative HOME funds received only by Statewide PJs). 5
Federal “match” While technically there is a 75-25% match of federal versus non-federal, many Participating Jurisdictions “match” their share with bond financing proceeds, labor, property – not necessarily $$ appropriations. In other words, the Participating Jurisdiction can be creative in matching the federal dollars, using other resources instead of state general funds 6
Participating Jurisdictions’ Discretion HOME Investment Partnership funds can be allocated by the state or local Participating Jurisdiction for: Homebuyer Assistance – e.g., mortgage subsidy. Homeowner Rehabilitation – e.g., the entire unit must be brought up to applicable rehabilitation standards. Rental Development – building or rehabilitating rental units, new construction. Tenant-Based Rental Assistance (TBRA) – operating similar to housing vouchers. 7
Who is Eligible for Tenant-Based Rental Assistance (TBRA)? Only “very low and low-income families” eligible. 90% of TBRA families’ incomes cannot exceed 60% of median family income for area at time of occupancy. In practice, about 80% of TBRA recipients are less than 30% of median income and almost all below 60%. 8
Tenant-Based Rental Assistance (TBRA) Requirements Eligible TBRA costs are for rental assistance [i.e., monthly “voucher” payments], security deposits [maximum of two months rent], and utility deposits. “Preferences” for persons with disabilities. HUD’s regulations state that “generally” TBRA isfor “all persons with special needs.” Sometimes, HUD programs are not allowed to show preferences for specific populations. But TBRA “Preferences” to transition people with disabilities from institutions to the community are allowed. 24 C.F.R. 92.209 (c )(2)(i) and (ii). TBRA are issued for two years but are renewable, and therefore the initial two year issuance is not a barrier to permanent placement in the community. 9
Annual HOME Allocation Each year HUD allocates HOME funds. In Appendix D, we list the annual amounts allocated to the statewide Participating Jurisdictions for FY 2008, 2009, 2010. 10
Which PJ to Focus Advocacy Efforts? Even though all PJs could use their HOME funds to provide TBRA to assist people to move out of institutions, there are two PJs that have a real financial interest in doing so: Statewide PJs. Those local PJs that have a county or public nursing home in their jurisdiction that receives local funds for the public NH’s operation. The financial interest is in saving state or local general revenues used to support residents in nursing homes In Appendix H, find a list of agencies designated as state Participating Jurisdictions with telephone numbers. 11
HUD Dashboards To assist you, we will use the Virginia statewide Participating Jurisdiction to explain how this works. Every quarter, HUD publishes a Dashboard for every Participating Jurisdiction in your State. Obviously, each State’s PJ operates differently but the principles are the same. You will find the most recent Dashboard for your statewide and local Participating Jurisdictions on HUD’s website: http://www.hud.gov/offices/cpd/affordablehousing/reports/dash.cfm 12
How to Understand the Dashboard In the above slide, there are three boxes. The upper box/pie chart represents the status of funding, and is cumulative for the years that the Participating Jurisdiction has been operational. The percent of Uncommitted Funds is shown in this box/pie chart. See Appendix B for the percent of Uncommitted Funds in each state (as of 9/30/10) 14
Understanding the Dashboard (cont.) The second row of boxes/pie charts shows the allocation among the HOME activities. Under the second set of boxes is a line reporting “Tenant Based Rental Assistance.” The box/line on the left shows the latest quarter; the box/line on the right shows cumulative allocation to date. Under the box/line to the right is the cumulative number of TBRA “vouchers” that have been allocated (as of 9/30/10). See Appendix C for the number of TBRA allocated by statewide Participating Jurisdictions. 15
Virginia Dashboard Data The top line shows “Virginia” as the PJ, rather than any one of its local PJs (e.g. “Norfolk” or “Fairfax County”). Header shows that data is current as of 9/30/10. Virginia has been a Participating Jurisdiction since 1992. The Virginia statewide Participating Jurisdiction’s Dashboard tells us that it has been allocated $231,573,778 cumulatively since 1992. This total does not include the HOME funds that have been allocated to all the local PJs. Generally, the Statewide PJ receives about 40% of the total HOME funds that are allocated to the entire state. For Virginia, this means that the total including the statewide and local PJs would be about $575 million. 17
Virginia Dashboard Data (cont.) As of 9/30/2010, 2% or $4.6 million was “uncommitted” [top box]. That is, Virginia’s statewide Participating Jurisdiction had not decided how to use $4.6 million. Since 1992, the Virginia PJ had completed 9,960 units [2nd row of boxes on right side]. 32% went for Rental Developments. 40% for Homebuyer assistance. 28% for Homeowner Rehabilitation. SINCE 1992, seven (7) HOUSEHOLDS RECEIVED TBRA. 18
$4.6 MILLION FOR TBRA? Virginia’s statewide PJ could allocate its uncommitted HOME funds for Tenant Based Rental Assistance to transition individuals out of nursing homes. Virginia’s statewide PJ could allocate a percentage of its annual HOME block grant for TBRA. 19
Why should Your State Use Some of Its HOME Funds for TBRA? To save Medical Assistance matching funds from its State general revenues. 20
Advocacy Focus: Governor Why focus on your Governor? Because s/he is the person to whom BOTH your Medicaid Office and your HOME Statewide Participating Jurisdiction reports! One huge problem is that neither the Medicaid agency nor HOME Statewide PJ may have an institutional interest in working together. They may not even know how they could assist the State by working together. Your Governor’s office does. If your Governor can save state general revenue Medical Assistance funds by using federal HOME funds to assist people to transition into the community, then there will be an interest. 21
Steps To Convince Your Governor Know the math: person in nursing home whose income is SSI = $676 a month. Under HOME, person in the community must spend only 30% a month on rent/housing = $203 if SSI is only income. Let’s assume for our discussion today that a 1-bedroom apartment rents for $800 a month. $800 - $203 = $597 a month or $7,164 a year. That’s what person needs in a housing “voucher” to leave the nursing home and reside in community. Obviously, the amount changes depending on the rent. 22
Medical Assistance Waiver “Cost Neutrality” Each Waiver must demonstrate “cost neutrality,” i.e., waiver services in the community are less than what the state would spend for nursing home care. The difference is what the state saves by transitioning to the community. To make the argument persuasively, it is necessary to compare what the State’s general revenue expenditures are in both the nursing home and in the community via the Waiver. Focus on the listing of cost savings in the “Difference” column in the CMS Medical Assistance Waiver Application’s Appendix J-1 23
Example Calculation of Savings Let’s look at Virginia’s Home & Community Based Waiver. VA nursing home MA per diem = $142 (see Appendix G) Annually ($142 x 365 days) = $51,830 VA’s average per person Waiver expenditure = $28,030 (see Appendix F) The specific per person amount varies by type of Waiver, so this amount will vary accordingly VA saves per person in the community: $51,830 - $28,030 = $23,800 Because VA’s Federal Medical Assistance Payment (FMAP) match is 50%, ($23,800 x .5 =) $11,900 is saved from VA’s general revenue for each Medicaid-supported nursing home resident who moves into the community (see Appendix E) 24
Let’s Go Back to Virginia’s HOME Funds We estimated that a person on SSI needs a supplement of $7,164 a year for a 1-bedroom apartment to meet his/her housing needs (see Slide 22 above). Assuming $800 rent per month for that 1-bedroom apartment, the SSI recipient would need Tenant Based Rental Assistance of $597 a month ($800-203) or $7,164 a year. 25
TWO SOURCES OF HOME FUNDS 1. “Uncommitted” HOME funds. 2. Annual Allocation of HOME funds.
How Many People Could VA Transition Out With the Uncommitted Funds? Assuming only half the uncommitted Virginia statewide Participating Jurisdiction’s funds are used for TBRA, Virginia could potentially transition 321 people: Half of Virginia’s 2% ($4.6 million) Uncommitted Funds = $2.3 million. Divide $2.3 million by $7,164 per person = 321 persons. State fund savings by using Uncommitted Funds = 321 persons x state general fund savings of $11,900 per person (see Slide 24) = $3.8 million. 27
Using the Annual HOME Allocation What about after the Uncommitted Funds are used up OR there are $0 Uncommitted Funds in your state? Remember, each year HUD allocates HOME funds (see Appendix D). It is necessary to convince your Governor to allocate a percentage of the annual federal HOME funds to transition people out of nursing homes AND THEREFORE SAVE STATE GENERAL REVENUE FUNDS IN THE MEDICAL ASSISTANCE PROGRAM. 28
Example: Virginia Annual HOME Allocation In FY 2010, the HOME allocation for all of Virginia was $35.6 million; the Virginia statewide Participating Jurisdiction received about $14.2 million (40%). If 10% or $1.4 million of Virginia’s statewide PJ’s HOME funds were allocated to transitioning people out of nursing homes, the savings in state funds would be: $1.4 million divided by $7,164 (per person rental assistance, see Slide 22) = about 195 people who could be transitioned. 195 people x $11,900 (per person savings, see Slide 24) = $2.3 million in state general revenue savings. 29
Annual Savings If your Governor wanted to annualize the state’s general revenue savings, s/he could take a percentage of the annual HOME funds and establish a Tenant Based Rental Assistance set-aside for people transitioning out of nursing homes. If your Governor wanted to be creative, s/he could bring together all of the PJs (and Housing Agencies) in your State. Bring also the State’s Housing Finance Agency to sweeten the pot with Low-Income Housing Tax Credits (LIHTC). There are many ways to combine LIHTC, HOME’s TBRA, and Housing Assistance. 30
Amend the Consolidated Plan In order for your statewide Participating Jurisdiction to use HOME funds for Tenant Based Rental Assistance, many states will have to amend their Consolidated Plans. Check out your State’s current Consolidated Plan to determine if it has any provisions for using its HOME funds for TBRA and if they are targeted to people with disabilities to transition out of nursing homes. See Appendix H for a list of Statewide PJs and contact info Work with stakeholders and other advocates to participate in Consolidated Plan development State and local housing agencies have procedures for public input in planning process 31
Additional Questions/Information • For reference materials and additional information: MFP Technical Assistance Website http://mfp-tac.com • E-Mail: mfp-ta@neweditions.net • CMS-Housing Capacity Building Initiative for Community Living Website for Housing Resources:http://www.hhs-hud-housing-collaboration.net/ • Steve Gold’s Website:http://www.stevegoldada.com/ • Email: SteveGoldADA@cs.com or call 215-627-7100