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Indiana HPRP Training. Module 2: HPRP Program toolS. HPRP consists of two programs. Homelessness prevention to assist households not literally homeless, avoid becoming homeless Rapid Re-housing for those households who have become homeless to get them back into stable housing .
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Indiana HPRP Training Module 2: HPRP Program toolS
HPRP consists of two programs • Homelessness preventionto assist households not literally homeless, avoid becoming homeless • Rapid Re-housingfor those households who have become homeless to get them back into stable housing
HPRP Eligible Activities – Same for both program components • Financial Assistance • Short and medium term rental assistance • Security deposits • Utility deposits • Moving cost assistance • Hotel/motel vouchers • Housing Relocation and Stabilization • Case management • Outreach and engagement • Housing search and placement • Legal services • Credit repair
HPRP Eligible Activities (2) • Data Collection and Evaluation • HMIS • Evaluation • Administrative costs • Accounting for grant funds • Preparing HUD reports • Program audits • Staff costs associated with activities • Staff training • Not to exceed 5% of HUD grant; IHCDA retained 3%
Financial Assistance • Limitations: • No direct payments to program participants • Payments must go to 3rd parties: landlords and utilities • Assisted units may not be owned by grantee, subgrantee, or parent, subsidiary or affiliated organization of subgrantee
Rental Assistance • Short term up to 3 months • Must be evaluated at the end of 3 months prior to receiving continuing assistance • Medium term cannot exceed 4-18 months • (Special procedures in Indiana for rental assistance in excess of 12 months) • Re-evaluated for assistance every 3 months • Assistance limited to actual rental costs • Months of rental assistance do not have to be consecutive • All rents assisted must meet HUD’s rent reasonableness requirements, not FMR.
Rental Assistance (2) • No double dipping: no assistance for same cost types that are covered by any other federal, state or local housing subsidy program • It can pay for deposits or utilities if participant is not receiving assistance with these cost types from any other program • Participants are required to pay rent – Indiana program • Tenant share must be the greater of: 30% of adjusted income or 10% of gross income • Up to 6 months of rent arrears may be paid • Arrearages paid count toward 18 month limit • Can be paid if it allows participant to remain in unit or move to another unit
Security and Utility Deposits • Deposits can cover same period and unit as other subsidy program • HUD emphasizes use of deposits to assist veteran-headed households receiving VASH assistance • Programs should track deposits and make good faith effort to secure return • Notify landlord and/or utility to whom deposit should be returned
Utility Payments • Payments can be made for up to 18 months • In Indiana, waiver required to receive utility payments for longer than 12 months • Can provide up to 6 months of arrearages payments. No time limit on when arrearage occurred. • Must have responsibility for debt • Utility account in name of participant or member of household • Evidence of prior payments such as cancelled checks or receipts from utility
Moving Cost Assistance • Reasonable moving costs • Truck rental, moving company • Storage fees for belongings • Maximum of 3 months or • Until participant is in housing
Motel and Hotel Vouchers • Indiana: only permitted when appropriate housing is already identified but will not be available for a period not to exceed 30 days • Costs must be reasonable and appropriate
Housing Relocation and Stabilization • Services can only be provided for up to 18 months for participants • Services include: • Case management • Outreach and engagement • Housing search and placement • Legal services • Credit repair
Case Management • Use uniform assessment tool • Arranging, coordinating, monitoring services all targeted toward achieving and maintaining housing stability • Counseling – related to achieving housing permanency. • Working with client to develop and maintain housing and services plan
Outreach and Engagement • Allow people who are homeless or at risk of homelessness to be aware of HPRP services • Recognizes that engagement may require multiple contacts and allows for innovative strategies • In Indiana, largely the responsibility of each Continuum of Care.
Housing Search and Placement • Outreach and support to landlords to secure participation • Tenant counseling – responsibilities, understanding leases • Assisting clients locate housing, obtain utilities, moving arrangements • Representative payee services for rent and utilities
Legal Services • Eviction prevention • Related services to keep tenants in their homes • Cannot assist in resolving mortgage or foreclosure issues • Not to be used for general debt concerns
Credit Repair • No payment of personal financial obligations • Skills training in budgeting and money management • Support in resolving credit issues
Data Collection • Eligible use of HPRP funds • Must use HMIS for data collection • Eligible costs: • Purchase of HMIS software/user licenses. IHCDA has a 1% fee. • Leasing/purchasing computers • Data collection, entry and analysis • Ineligible • Planning and developing HMIS systems • Development of new software systems • Replacing state/local funding for existing HMIS
Administrative Costs • Accounting for use of grant funds • Preparing reports for HUD • Program audits • Similar costs related to administering grant post-award • Training specific to learning about HPRP • Do not include: • Costs of issuing financial assistance • Providing services • Carrying out housing inspections, etc.
HPRP Program Eligibility • Any individual/family receiving financial assistance must at least have initial consultation with case manager • Household income cannot exceed 50% AMI • All participants must be documented to be: • Homeless • HUD definition – streets, shelters, places not meant for human habitation • People being imminently discharged from publically funded institutions (health care, foster/youth care programs, corrections) • Graduating or timing out of transitional housing • Domestic violence victims or • At Risk of Homelessness • And meet both of following: • No appropriate subsequent housing options are identified • Household lacks financial resources and support networks to obtain immediate housing or remain in its existing housing
Quarterly Certification • Eligibility must be re-certified quarterly for all participants receiving financial assistance • Income eligibility • Continuing need for financial assistance • Likelihood of sustaining housing at end of HPRP assistance
Documentation of Homelessness • All participants who are eligible for assistance because of their homeless status must have documentation of status: • Letterhead from shelter, outreach provider, etc. • Documentation from institution that discharge is imminent • Outreach team documentation • Documentation should indicate that household lacks resources or support in community to obtain housing without HPRP support
Homeless Prevention Eligibility • Risk of homelessness must be documented • Responsibility for debt must be established prior to HPRP payments • Participant must be legal resident of premises prior to obtaining short or medium term rental assistance • Participant must be responsible for paying rent or utility bills • Named on lease • Named on utility account • Evidence (receipts, etc.) that participant has paid these bills in the past • As part of evidence of risk of homelessness, documentation should exist that required payments have not been made or participant lacks resources to make necessary payment
Determination of Risk of Homelessness • Risk of losing housing • No housing options identified • No financial resources and/or support networks to remain in housing or locate other housing • Would client become homeless but for this assistance • Can be used to assist persons graduating or timing out of transitional program to obtain permanent housing
Changed homeless definition in HEARTH Act • “Homeless” will also include: • Imminent risk of homelessness • Must leave current housing in the next 14 days • No place to go • No support network or resources to obtain housing • Family or unaccompanied youth is living ‘unstably’ • Defined as homeless under other Federal programs (DOE Education for Homeless Youth and Children) • Have lived for a long period without living independently in permanent housing • Have moved frequently • Will continue to experience instability because of disability, history of domestic violence or abuse, or multiple barriers to employment
Assessment must document risk of homelessness • Risk factors include: • Eviction in 2 weeks from private dwelling • Discharge in 2 weeks from institution • Sudden and significant loss of income • Sudden and significant increase in utility costs • Mental health and substance abuse issues • Severe housing burden • Homeless in last 12 months • Young head of household • Current or past child welfare involvement • Pending foreclosure of rental housing • Extremely low income • High overcrowding
Risk Factors (Cont) • History of institutional care (corrections, treatment, hospital) • Recent traumatic event to household (illness, death) • Credit problems that preclude access to housing • Significant medically-related debt
Risk of Homelessness in HEARTH Act • Income below 30% of AMI • Move frequently for economic reasons • Live doubled up • Face eviction • Live in hotel/motel • Live in severely overcrowded housing • Exiting an institution
Ineligible Uses of Funds • Cannot use HPRP to move a household into transitional housing • Cannot support transitional housing programs • Operating costs for any program are ineligible • Prohibited activities and expenditures • Construction or rehabilitation • Credit cards, consumer debt, • Car repair or transportation • Food • Medical/dental care and medications • Pet care • Entertainment • Work or education materials
Ineligible Activities (Continued) • Development of discharge plans from institutions • Can provide assistance to persons being discharged • Cash assistance to program participants • Child care • Employment training • Clothing/grooming • Fees cannot be charged to program participants
Prior to Receiving Rental Assistance • Housing must be inspected • Prior to assisted household occupying unit • Every 12 months • Unit must meet HPRP standards or repaired/re-inspected • If the participant is not moving to a new unit, the current unit does not need to be inspected prior to receiving rental assistance. • Must be re-inspected if assistance goes over 12 months • State and local building and housing codes should be considered when deciding to provide rental assistance • Any unit that will house a child under 6 years old must be visually assessed for lead based paint hazards • Documentation of inspection must be maintained • A lease must be in place and the program participant must be on the lease to receive rental assistance
Overview of Lead Based Paint Requirements • Exemptions from requirements • Any unit constructed after January 1, 1978 • All 0-BR, Studio units • For non-exempt units that will be occupied by children 6 and under: • Visual assessment must be performed by HPRP agency • If deteriorated paint surface is found: • Paint stabilization must be performed using ‘safe work practices’ • Occupant protection • Specialized cleaning after hazard reduction activities • If abatement work occurs, unit must be visually assessed again to verify that hazard has been removed • Must be re-assessed every 12 months and anytime a new household occupies unit
Rent Reasonableness • Rental assistance cannot exceed actual rental cost • Must comply with rent reasonableness • Cannot exceed rents charged by owner for comparable units • Must be reasonable when compared to the costs of comparable units in the community • Location, quality, size, type and age of unit • Amenities, services and utilities provided by owner • Go Section8 software will allow easy determination of rent reasonableness.
Double Dipping • No rental assistance from HPRP if: • Payments are being received from another federal, state or local program for same cost types • Rent • Security deposits • Utility deposits • Utility payments • Moving cost assistance
Time Limits on Assistance • Housing relocation and stabilization (including case management) limited to 18 months/program participant • Rental Assistance cannot exceed 18 months • Up to 6 months of rent arrearages in 18 month limit • Indiana: participants may only receive 12 months of rent assistance unless term is extended
Participants must pay rent • Use HUD methodology • Tenant rent payment can be used to pay utilities (up to utility allowance) • If tenant rent exceeds utility allowance, balance must be paid to landlord • If tenant rent is less than utility allowance, HPRP can pay balance of utilities (up to allowance) directly to utility • NO PAYMENTS CAN BE MADE DIRECTLY TO PARTICIPANTS
Tenant rent payment • Every person receiving rental assistance (short or medium term) supported by HPRP must pay as rent (the higher of): • 30% of adjusted income • 10% of gross income
Process of determining tenant rent • Step 1: Calculate Annual Income – including and excluding required amounts • Step 2: Adjust income for allowable deductions • Step 3: Determine which approaches produces the highest tenant payment and calculate subsidy amount
Annual Income Includes • All amounts to all family members • Anticipated over upcoming year • Amounts obtained from assets • Regs: 24 CFR 5.609
Sources of income to include • Wages and salaries • Net income from business/profession • Interest and dividends • Social security, annuities, retirement, pensions • Unemployment, worker’s comp • Welfare payments • Alimony & child support • Armed forces pay
Income that is not included by HUD • Income from employment of children under 18 years • Payments for foster children • Lump sum additions (inheritances, insurance, capital gains) • Funds for medical expense reimbursement • Income of live-in aide • Student financial aid provided to student • Hostile fire pay (armed forces) • Amounts received under HUD funded training programs • Temporary, non-recurring, or sporadic income (incl. gifts) • Reparation payments • Earnings over $480 for full-time student 18 or older
Income not included (Cont.) • Adoption assistance payments over $480/adopted child • Deferred periodic amounts from SSI/SSD • Rebates of property taxes • Payments on behalf of developmentally disabled family member living at home • Food stamps • Domestic volunteer service payments (VISTA) • LIHEAP payments • Earned income tax credit • Payments under Job Training Partnership Act • Native American/Alaskan Native claim settlement
Income Deductions • 24CFR5.611 • $480/dependent • $400/elderly or disabled family member (1/household only) • Expenses greater than 3% of annual income for: • Unreimbursed medical expenses • Unreimbursed attendant and equipment • Reasonable child care to permit family member to work or further education
Treatment of Assets • Cash value of all assets must exceed $5000 to be considered • Income from assets must be included in annual income – not assets • Greater of actual income or imputed income from assets • Income should be imputed based on passbook rate applied to cash value of assets • Cash value = market value minus cost of converting asset to cash
Income Verification • Wages and Salaries: • Pay stubs, earnings statement, W-2 form • Signed and dated statement from employer • Statement from employer based on phone or in-person contact • Tips/Self-employment • Tax returns • Notarized statement from applicant (tip: have or locate a notary)
Income Verification – 2 • Assistance benefits (TANF, Workers Comp, SS, unemployment, etc.) • Copy of benefit check • Copy of award letter • Verification form from agency • Child support payments • Copy of court records • Copy of payment check
Income Verification – 3 • Interest/Dividends • Passbook/bank statement • Income tax return • Assets • Passbook/bank statement • Tax assessment or appraisal of real property