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Module 2: HPRP Program toolS

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1 Module 2: HPRP Program toolS
Indiana HPRP Training Module 2: HPRP Program toolS

2 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

3 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

4 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%

5 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

6 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.

7 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

8 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

9 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

10 Moving Cost Assistance
Reasonable moving costs Truck rental, moving company Storage fees for belongings Maximum of 3 months or Until participant is in housing

11 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

12 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

13 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

14 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.

15 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

16 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

17 Credit Repair No payment of personal financial obligations
Skills training in budgeting and money management Support in resolving credit issues

18 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

19 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.

20 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

21 Two Eligibility Paths Central Intake Homeless
Assessment of Ability to Maintain Housing Assistance in locating housing Risk of Homelessness Initial 3 month assistance Assessment of ability to maintain housing

22 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

23 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

24 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

25 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

26 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

27 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

28 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

29 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

30 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

31 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

32 Accessing HPRP Assistance – Homeless Participants
Central Intake Assessment Develop housing plan Housing Search assistance Verify income/household composition

33 Homeless Participants – Requirements for Housing Unit
Locate Unit Landlord signs agreement Unit inspected for habitability Visual assessment for lead paint Rent is ‘Reasonable’

34 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

35 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

36 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.

37 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

38 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

39 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

40 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

41 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

42 Annual Income Includes
All amounts to all family members Anticipated over upcoming year Amounts obtained from assets Regs: 24 CFR 5.609

43 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

44 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

45 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

46 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

47 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

48 Income Verification Wages and Salaries: Tips/Self-employment
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)

49 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

50 Income Verification – 3 Interest/Dividends Assets
Passbook/bank statement Income tax return Assets Tax assessment or appraisal of real property

51 Income Verification – 4 Child Care expenses Medical expenses
Receipts/cancelled checks Statement from child care agency or babysitter Itemized list signed by applicant Medical expenses Statement from physician/hospital

52 Timeliness in Expending HPRP Funds
All Indiana HPRP funds must be expended by September 30, 2012 (36 months after grant agreement) Participants must be receiving HPRP rental assistance by (24 months after grant agreement) in order to receive 12 months of assistance. 65% of Indiana HPRP funds ($...) must be expended within 2 years of grant agreement

53 Reallocation HUD may reallocate grant funds not expended within 24 months; all funding will be lost in 36 months Indiana subgrantees that fail to expend HPRP resources on a timely basis may have funds reallocated to other subgrantees

54 Requirements on Termination of Assistance
Assistance can be terminated to a program participant who violates program requirements Assistance can be resumed to a terminated participant In order to terminate due process must be followed: Written notice, providing clear statement of reasons for termination A review of the decision in which the terminated person can present written or oral objections before a person other than the one making the termination decision Prompt written notice of final decision

55 Confidentiality Requirements
Grantees and subgrantees must develop and implement procedures to ensure: Confidentiality of records pertaining to any individual receiving HPRP assistance The address or location of assisted housing will not be made public

56 Conflict of Interest No employee of subgrantee or person who participates in decision-making for subgrantee may obtain a personal or financial interest or benefit from HPRP assisted activities or have any interest in a contract, subcontract or agreement with respect to HPRP funds for individual or those that the individual has a family or business tie. This covers the period of employment and for one year post-employment HUD may grant an exception to above Requires opinion of grantees attorney that the interest for which the exception is sought would not violate state or local law

57 Equal Participation of Religious Organizations
Religious or faith-based organizations can participate on an equal footing with any other organization HPRP resources cannot be used for inherently religious activities (worship, religious instruction or proselytizing) Participating religious organizations may continue to carry out their missions but cannot discriminate against participants based on religious belief

58 Resources made Available by IHCDA
IHOP Indiana Housing Now Rent Reasonableness Program GoSection8 Software On-line resources FMRS Utility allowances Income/rent calculation worksheets

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