MODULE 2: HPRP PROGRAM TOOLS

Indiana HPRP Training1

HPRP consists of two programs2

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

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

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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%

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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

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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 costsMonths of rental assistance do not have to be

consecutiveAll rents assisted must meet HUD’s rent

reasonableness requirements, not FMR.

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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

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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

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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

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Moving Cost Assistance

Reasonable moving costs Truck rental, moving company

Storage fees for belongings Maximum of 3 months or Until participant is in housing

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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

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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

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Case Management

Use uniform assessment toolArranging, 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

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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.

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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

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Legal Services

Eviction preventionRelated services to keep tenants in their

homesCannot assist in resolving mortgage or

foreclosure issuesNot to be used for general debt concerns

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Credit Repair

No payment of personal financial obligationsSkills training in budgeting and money

managementSupport in resolving credit issues

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Data Collection

Eligible use of HPRP fundsMust use HMIS for data collectionEligible 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

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Administrative Costs

Accounting for use of grant fundsPreparing reports for HUDProgram auditsSimilar costs related to administering grant

post-awardTraining specific to learning about HPRPDo not include:

Costs of issuing financial assistance Providing services Carrying out housing inspections, etc.

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HPRP Program Eligibility

Any individual/family receiving financial assistance must at least have initial consultation with case manager

Household income cannot exceed 50% AMIAll 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 HomelessnessAnd 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

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Two Eligibility Paths21

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

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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

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Homeless Prevention Eligibility

Risk of homelessness must be documentedResponsibility 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

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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

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Changed homeless definition in HEARTH Act

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“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

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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

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Risk of Homelessness in HEARTH Act29

Income below 30% of AMIMove frequently for economic reasonsLive doubled upFace evictionLive in hotel/motelLive in severely overcrowded housingExiting an institution

Ineligible Uses of Funds

Cannot use HPRP to move a household into transitional housing

Cannot support transitional housing programsOperating costs for any program are ineligibleProhibited 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

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Ineligible Activities (Continued)

Development of discharge plans from institutions Can provide assistance to persons being discharged

Cash assistance to program participantsChild careEmployment trainingClothing/groomingFees cannot be charged to program

participants

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Accessing HPRP Assistance – Homeless Participants

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Homeless Participants – Requirements for Housing Unit

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Prior to Receiving Rental Assistance34

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

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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 Reasonableness36

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 Dipping37

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 Assistance38

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 rent39

Use HUD methodologyTenant 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 payment40

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 rent41

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 Includes42

All amounts to all family membersAnticipated over upcoming yearAmounts obtained from assetsRegs: 24 CFR 5.609

Sources of income to include43

Wages and salariesNet income from business/professionInterest and dividendsSocial security, annuities, retirement, pensionsUnemployment, worker’s compWelfare paymentsAlimony & child supportArmed forces pay

Income that is not included by HUD44

Income from employment of children under 18 yearsPayments for foster childrenLump sum additions (inheritances, insurance, capital

gains)Funds for medical expense reimbursement Income of live-in aideStudent financial aid provided to studentHostile fire pay (armed forces)Amounts received under HUD funded training programsTemporary, non-recurring, or sporadic income (incl. gifts)Reparation paymentsEarnings over $480 for full-time student 18 or older

Income not included (Cont.)45

Adoption assistance payments over $480/adopted child

Deferred periodic amounts from SSI/SSDRebates of property taxesPayments on behalf of developmentally disabled

family member living at homeFood stampsDomestic volunteer service payments (VISTA)LIHEAP paymentsEarned income tax creditPayments under Job Training Partnership ActNative American/Alaskan Native claim settlement

Income Deductions46

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 Assets47

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 Verification48

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

contactTips/Self-employment

Tax returns Notarized statement from applicant (tip: have or

locate a notary)

Income Verification – 2 49

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 50

Interest/Dividends Passbook/bank statement Income tax return

Assets Passbook/bank statement Tax assessment or appraisal of real property

Income Verification – 4 51

Child Care expenses Receipts/cancelled checks Statement from child care agency or babysitter Itemized list signed by applicant

Medical expenses Receipts/cancelled checks Statement from physician/hospital

Timeliness in Expending HPRP Funds52

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

Reallocation53

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

Requirements on Termination of Assistance

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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

Confidentiality Requirements55

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

Conflict of Interest56

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

Equal Participation of Religious Organizations

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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

Resources made Available by IHCDA58

IHOPIndiana Housing NowRent Reasonableness Program

GoSection8 Software

On-line resources FMRS Utility allowances

Income/rent calculation worksheets