Homeless Services Reform Act (HSRA)

Information Session

Presented by The Community PartnershipJune 14 and 15, 2006Additional Program Rules

Staff:Amy McPherson, Chief Financial Officer

Darlene Mathews, Policy AnalystTamura Upchurch, Federal Programs Manager

AGENDA

Introductions– Amy McPherson

HSRA History and Background– Darlene Mathews

Additional Program Rules Template– Tamura Upchurch

Wrap up and Questions

Introductions

Handouts

-Additional Program Rules Template

-Power Point

-HSRA service level chart

-Shelter & Housing Program Listing by Continuum of Care Category

HSRA Decision Making

DECISION MAKING

AUTHORITY

Department of

Human Services

IMPLEMENTATION

Program Providers

and

The

Community

Partnership

Purpose

New DHS requirement for re-submission of “Additional Program Rules”

Goal: to format, standardize and simplify Additional Program Rules

History of Homeless Services Reform Act

Re-writing of the laws that govern homeless services

Bill passed in summer 2005 Expected to become effective in Jan. 2006 In reality it became effective in Oct. 2005

What does the HSRA do?

Establishes an Interagency Council made up of government agencies, clients, providers and nonprofits to set the policy objectives for the Continuum

Protects the right to due process for clients Articulates the rights and responsibilities of clients Articulates Providers’ standards of service Redefines service levels in the Continuum of Care

Implementing the HSRA

Phase I- Development of Universal Program Rules

Phase II- Implementation of Notices

Phase III- Development of Additional Program Rules by each Provider

Phase IV- Training on how to Request a Reasonable Accommodation (Forthcoming)

Phase I Complying with the law: Universal Program Rules

Universal Program Rules were developed for each

service level in the Continuum Severe Weather Shelter –Formerly Hypothermia

Shelters Low Barrier Shelter -provides safe, decent overnight

shelter in a congregate setting –Formerly Emergency Singles Shelters

Temporary Shelter -provides safe, decent shelter and supportive services for at least 12 hours and up to 24 hours a day. Formerly Emergency Shelter for Families and Transitional Programs for Singles w/ minimum eligibility reqs.

Phase I Complying with the law: Universal Program Rules

Transitional Shelter/Housing -provides housing and supportive services 24 hours a day to assist homeless individuals and families develop the skills necessary to live in permanent housing.

Permanent Supportive Housing –provides housing with supportive services for an unrestricted amount of time. This type of housing is often offered for homeless people who unable to be self sufficient due to a disability.

Phase I: Universal Rules

Articulate all of the required services and processes under the law including clients rights, clients responsibilities, clients’ due process under the law

These cannot be changed or altered These rules MUST be signed and reviewed

with all clients during intake.

Phase II: Complying with the law:Due Process Notices

Any agency receiving public money to provide a service is obligated to provide their client with adequate NOTICE when there is a change to their service. The NOTICES inform a client of a change in service and their opportunity to appeal the change.

-Trainings on how to use these NOTICES were conducted on April 3 & 7

Phase II: Due Process Notices

DHS developed Notices for the following actions that can be taken against a client:

-Notice of Eligibility-Notice of Transfer-Notice of Suspension-Notice of Termination-Notice of Emergency Action

THESE NOTICES MAY NOT BE CHANGED

Phase II: Complying with Due Process Notice

If you take an action against your client such as:

-Deny a person entrance to your program based on eligibility standards

-Suspend

-Terminate

-Transfer

-Emergency Transfer, Suspend or Terminate

You must provide them with the appropriate DOUBLE SIDED notice and have them sign it.

Phase III: Complying with the law:Additional Program Rules

As required under the law Providers are required to develop Additional Program Rules. These are the rules clients must follow to participate in your program.

Providers have been working hard to turn in their Program Rules, however DHS has redefined the areas that should be covered in these program rules

Phase III:Changes to the Program Rules

DHS has identified 10 areas that are under HSRA jurisdiction.

Rules should be focused on these areas If there are additional procedures around

implementing these rules they should be placed in an additional “client handbook.”

Areas that are addressed in the Universal Rules i.e. termination, suspension and transfer do not need to be repeated in your Additional Program Rules

Phase III: Additional Program Rules Template

DHS has developed a template for Additional Program Rules Additional Program Rules do NOT need to repeat Universal

Program Rules Goal of new format is to make the Additional Program Rules

document simple and clear All clients must have Universal Program Rules and Additional

Program Rules explained to them and must sign them upon entry into program

Programs can also have a “client handbook” to provide further details regarding procedures (required for HUD funded programs/optional for other programs)

Additional Program Rules Template

Rules should define expectations for clients and program

Rules must have a table of contents Total number of pages must not exceed 7 pages

including the table of contents– There is an exception for grievance and appeal processes

required by other public funding sources for your program A decorative cover page may be added without

counting towards page limit Font size of 12 with 1 inch margins around all sides

Additional Program Rules Template

Table of Contents– Section names must appear exactly as they appear in

the sample– May NOT add any other sections– Sections that do not apply to a program must still

have the section and state “Does not Apply” Example: Curfew for scattered site permanent housing

programs

– Must include program name and address on Table of Contents page

Additional Program Rules

Overview of Required Sections– #1 Special Eligibility Criteria– #2 Curfew– #3 Visitation– #4 Case Management Requirements– #5 Behavior Requirements– #6 Pets– #7 Alternate Sanctions– #8 Grievance Policy and Procedures– #9 Appeal Procedure

#1 Special Eligibility Criteria

Eligibility requirements above and beyond the Universal Program Rules

– Do not restate eligibility requirements already in Universal program rules

Examples:– Shelter + Care: Eligibility determined by HUD regulations– Programs serving clients with a particular need (ie.

Domestic violence, substance abuse, medical condition)

#2 Curfew

Hours of curfew Policy regarding exceptions Policy regarding posting of curfew rules Policy regarding the programs right to

change curfew with notice to clients Policy for overnight passes

#3 Visitation

Hours of visitation Definition of “Visitor”

– Cannot include professional assistance to client (ie. Attorney, mental health professional)

Policy regarding exceptions Policy regarding posting of visitation rules Policy regarding the programs right to change visitation

with notice to clients

#4 Case Management Requirements

Client requirements regarding meetings with case mangers

Client requirements regarding adherence to the service plan

Can use sub-sections from the sample rules, but they are not required

#5 Behavior Requirements

Rules regarding client behaviors Can use sub-sections from the sample rules,

but they are not required

#6 Pets

Policy regarding pets If pets are not allowed in your program, we

recommend that you include the “exception language” from the sample program rules

“Exceptions to the rule will be made for service animals in accordance with this program’s reasonable accommodation policy and the Americans with Disabilities Act.”

TCP will sponsor training around ADA “reasonable accommodations”

#7 Alternative Sanctions

Outline steps of progressive discipline Steps that would lead to client receiving 15

day termination notice. Do not need to repeat any issues from

Universal Program Rules If program has a policy of providing

increased client privileges, this policy can be included in this section

#8 Grievance Policy and Procedures

Procedures must state:– Who and how complaints should be made– Define timeframe for response to client– Additional levels of internal appeal

For programs with multiple levels of grievance through other agencies, include reference to those procedures as well

Can include grievance policy from other public funding sources in its entirety (does not count towards page limit)

#9 Appeal Process

Must use the following language:

You may request a fair hearing to appeal any decision by a service provider to transfer, suspend or terminate services, or any alleged violation of your client rights or provider standards which are listed in the Homeless Services Reform Act.

You may request a fair hearing in writing or verbally to the provider, the Department of Human Services, the Office of Administrative Hearings, or the Mayor. Please see the Universal Program Rules or your provider for information on how to request a fair hearing.

Can include appeal process from other public funding sources in its entirety (does not count towards page limit)

Client/Staff Acknowledgement

Program Rules must have “Acknowledgement Statement”

– “I acknowledge that I have received, understand and accept the Additional Program Rules of this program.”

– And, if applicable: “I further understand that I must enforce these rules with my entire family.”

Space for client signature and date Space for staff signature and date Program should provide a copy to the client

Submission Requirements

Additional Program Rules following this format are due to The Community Partnership by 5pm Friday, July 7.

Additional Program Rules must be submitted in Word format as an email attachment to

dmathews@community-partnership.org

Next Steps

Darlene Mathews at The Community Partnership will review all submissions and communicate any concerns regarding the rules with the provider

Rules will be submitted to DHS for review and approval Providers will be given a bi-weekly status report of their

rules and notified in writing by The Community Partnership when their rules have been approved by DHS

Changes to Approved Rules

After Additional Program Rules have been approved:– The current Additional Program Rules and any

client handbooks will be required to be re-submitted to The Community Partnership as a contract deliverable each year

– TCP will forward the Additional Program Rules to DHS each year for re-approval

Changes to Approved Rules

– During the program year, if providers change the approved Additional Program Rules for

Eligibility Alternative Sanctions Grievance

– The changes must be approved by DHS before the change is implemented following the same process as the initial submission

Wrap Up

All HSRA information is available at www.community-partnership.org/initiatives/hsra

Additional Program Rules are due to dmathews@community-partnership.org by 5pm July 7

Use Sample format

Questions