1 © Copyright 2008 Nan McKay & Associates Managing the FSS Program with Patti Zatarian Menard ©...

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1 © Copyright 2008 Nan McKay & Associates Managing the FSS Program with Patti Zatarian Menard with Patti Zatarian Menard © Copyright 2008 Nan McKay & Associates

Transcript of 1 © Copyright 2008 Nan McKay & Associates Managing the FSS Program with Patti Zatarian Menard ©...

Page 1: 1 © Copyright 2008 Nan McKay & Associates Managing the FSS Program with Patti Zatarian Menard © Copyright 2008 Nan McKay & Associates.

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© Copyright 2008 Nan McKay & Associates

Managing the FSS Program

with Patti Zatarian Menardwith Patti Zatarian Menard

© Copyright 2008 Nan McKay & Associates

Page 2: 1 © Copyright 2008 Nan McKay & Associates Managing the FSS Program with Patti Zatarian Menard © Copyright 2008 Nan McKay & Associates.

Managing the FSS Program

© Copyright 2008 Nan McKay & Associates

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© Copyright 2008 Nan McKay & Associates

Overview Program StepsDevelop PCC

Identify & coordinate needs to resources

Develop Action PlanRevise Action Plan

ACO

Develop program designService systems

Select & service participants

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© Copyright 2008 Nan McKay & Associates

FSS Program DesignPlanning

Outreach

Orienting

Assessing Needs & Setting Goals

Selecting

Contracting

Servicing

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© Copyright 2008 Nan McKay & Associates

Case Managing & Support Services

Escrowing and Porting

Monitoring & Evaluating

Reporting

Program Evaluation Quantitative Qualitative

FSS Program DesignServicing

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Managing the FSS Program

Action Plan Program Coordinating

Committee Escrow Accounts Case Workers

© Copyright 2008 Nan McKay & Associates

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FSS Coordinator Activities Develop program needs assessment Identify realistic program outcomes Design FSS program Develop FSS case management record systems Match FSS program’s needs and goals to

existing services in community Develop new community services Develop and maintain program outcomes

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Case Manager Activities

Develop and manage effective Individual Training & Service Plans by: Conducting orientations and intake interview Assessing skills, abilities, needs & resources Identifying realistic goals, develop tasks to

accomplish goals Monitoring and documenting progress Completing CM relationships of FSS

participants

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Managing the FSS Program Know the Basics Clarify the Basics Identify Common Mistakes Identify Best Practices

© Copyright 2008 Nan McKay & Associates

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Managing the FSS Program

Know the Basics

© Copyright 2008 Nan McKay & Associates

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© Copyright 2008 Nan McKay & Associates

FSS BASICS

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Family Self SufficiencyProgram Goals

Matching Housing Assistance Families

with

Existing Community Services

to

Achieve Economic Self Sufficiency

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Managing the FSS Program

Clarify the Basics Identify Common Mistakes Identify Best Practices

© Copyright 2008 Nan McKay & Associates

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FSS Regulations Clarification

Families can Complete FSS without

reaching economic self sufficiency

Complete with less money than when started

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FSS Best Practice

Identify what PHA is trying to accomplish in FSS program Get people a job any job Move families toward self

sufficiency Decrease HAP dependence

increase rent roll What does your Logic Model

say?

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FSS Common Mistakes Implementing FSS

without considering goal Implementing FSS

without matching goal to PHA goals

Not telling FSS Coordinator goal

Completing Logic Model without staff input

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© Copyright 2008 Nan McKay & Associates

HUD References

24CFR Part 984, SubParts (A)(B)(C)(D) PIH Notice 93-24, Q & A’s PIH Notice 95-5 Modification of Contract FSS Contract of Participation FAQs

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HUD Regulations (M & M’s)

The PHA must… The PHA shall…

The PHA may not… The PHA shall not…

No Choice: Do It!

Prohibited: Can’t Do It !

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HUD Regulations (M & M’s)

PHA may = Choice Choice = Policy Policy =

FSS Action Plan ACOP or Administrative Plan

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PHA Policy

Agency Plan

AnnualPlan

Admin & OCC Plan

Action Plan

Admin Plan

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Action Plan

© Copyright 2008 Nan McKay & Associates

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Action Plan Requirements

Must have a HUD-approved Action Plan to operate an FSS program

Developed with PC and CEO of Gov’t PHA final decision-maker

Must include revisions in Annual Plan

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Minimum Required Contents

24 CFR 984.__ Action Plan must include Demographics Selection Procedures Incentives Activities Termination Procedures Timetable Assurances

Non Interference Coordination

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Managing the FSS Program

Clarify the Basics Identify Common Mistakes Identify Best Practices

© Copyright 2008 Nan McKay & Associates

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FSS Regulations Clarification

FSS Action Plan is the only policy for FSS

All “mays” must be clarified in Action Plan

Any undefined words must be defined in plan

Action Plan must be up to date, approved by Board, followed exactly

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FSS Best Practice Create an Action Plan

“Boiler” to work in by highlighting Every “may” Every word or phrase not

clearly defined in regulation and

Everything regulation says “must” be in policy

Then….

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FSS Best Practice

Make a “Word” document using the bold headings from the regulation

Fill in each one of the policy decisions that needs to be made

Take this list to PCC first for recommendations

Take the list and recommendations to management

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FSS Common Mistakes

Working from an old and insufficient Action Plan

PHA makes all decisions without any vocational expertise

FSS Coordinator makes all decisions without vocational expertise

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PROGRAM COORDINATING COMMITTEE

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PROGRAM COORDINATING COMMITTEE

Must establish a PCC: Can establish own or use existing entity (ex: WIA)

Assists With Program PHA Accountable Must include:

HCV Participant PH resident: resident council or other resident

group PHA Representative

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Other Possible Members

Who else…………?

Childcare

Employ

Legal

Fund-raising

Religious

Political

Financial

Entrepreneurship

Law enforcement

Marketing/Media

Social work

Case management

Homeownership

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Managing the FSS Program

Clarify the Basics Identify Common Mistakes Identify Best Practices

© Copyright 2008 Nan McKay & Associates

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FSS Regulations Clarification

Must have PCC with appropriate members

Nothing else about PCC is regulated

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FSS Best Practice FSS Coordinator makes PCC their #1

concern PCC membership from

Community College Adult Basic Education Workforce Investment Board Career Center Community Based Organizations w/ WIA

Funding Dept Health & Human Services United Way City or County

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© Copyright 2008 Nan McKay & Associates FSS Program Coordinating

Committee

Social Policy

Law

Regulations

DOE DOL DHUD DHHS DOT

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FSS Best Practice

PCC Members are policy makers

PHA rep is policy maker Chair of PCC is leader in

community PCC is a group of experts FSS Coordinator “staffs”

PCC

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FSS Best Practice At first or renewing PCC

meeting Explain the goal of FSS Ask PCC members # of their

clients w/ S8 or PH assistance

Describe S8 and PH families Ask what it would take for

them to get SS wage jobs in 5 years

Brainstorm Plan

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FSS Common Mistakes

No PCC FSS Coordinator chairs meeting

Group doesn’t know they share clients

Group doesn’t see WIFM FSS Coordinator doesn’t network, network, network

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© Copyright 2008 Nan McKay & Associates

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Denial of Participation

May deny FSS participation to: People who are not

motivated Previous participant who was

terminated Families where services are

unavailable Participants and residents

who owe debt to any PHA

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© Copyright 2008 Nan McKay & Associates

FSS CONTRACT OF PARTICIPATION

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FSS CONTRACT

Must execute COP -HUD Form 52650 ITSP must be completed for head Must be signed by family head Initial term 5 Years

Effective 1st day pf month after signing Can be extended up to two years for “good

cause” beyond family control May extend to help family meet the 12

consecutive month welfare-free requirement

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INDIVIDUAL TRAINING AND SERVICE PLAN

Mandatory for Head Optional for other family members if PHA agrees Must Attach to Contract Final Goal: Suitable Employment Interim Goal: All members welfare-free 12

consecutive months prior to expiration Includes Interim Goals and Incentives Any changes included as a written revision

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FSS CONTRACT

Contract May Be Modified:1. ITSP2. Contract Term3. New FSS Head

4. Eliminate termination line

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This is serious business

COMPLIANCE WITH LEASE

FSS Contract requires Compliance with program

lease Compliance with Family

Obligations contract PHA may terminate FSS

Contract for... non-compliance with lease

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SEEK AND MAINTAIN EMPLOYMENT

Requirement for FSS head only PHA must define “seek” PHA determines suitability of employment

No minimum time period the Head needs to be employed

Only head required to obtain employment

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Interim Escrow Disbursements

At sole discretion of PHA If family has completed certain interim

goals, and PHA determines funds consistent with

contract and needed for completing goals (ex: job training, tuition, business start-up)

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Managing the FSS Program

Clarify the Basics Identify Common Mistakes Identify Best Practices

© Copyright 2008 Nan McKay & Associates

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FSS Regulations Clarification

Must define in Action Plan Extensions for good cause Seek and maintain employment Suitable employment Interim disbursements

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FSS Best Practice

Extensions if an extension means more earnings

Seek and maintain definition that allow education or training

Interims that get money needed to meet goals

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FSS Common Mistakes

Making arbitrary escrow and term policies

Using escrow simply as a reward

Setting policies so tight that forfeitures are likely

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You go!!!

COMPLETION OF THE FSS CONTRACT

All obligations complete on or before expiration of FSS contract…or

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Cut the escrow check!

COMPLETION OF THE FSS CONTRACT

30% AMI equals/exceeds FMR, AND

Head certifies family welfare free

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© Copyright 2008 Nan McKay & Associates Consequences of Non-Compliance with FSS

Contract

Withhold supportive services Terminate FSS participation Terminate S8 assistance (unless only

basis is failure to become welfare-free)

PHA never “required” to terminate assistance for FSS non-compliance

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TRANSITIONAL SERVICES

Transitional Services If head is employed

FSS COP may be terminated: Mutual consent Failure to meet obligations Withdrawal

FSS family is entitled to grievance hearing

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Managing the FSS Program

Clarify the Basics Identify Common Mistakes Identify Best Practices

© Copyright 2008 Nan McKay & Associates

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FSS Regulations Clarification

Must have policies that make it clear when a missed goal results in Changed ITSP More case management Withheld services Termination

Policy can not be arbitrary or discriminatory

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FSS Best Practice

Always best to start with case management first

Remember They volunteered Its their dream We need them to work

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FSS Common Mistakes

No policy at all Each case manager

deciding each case Not getting guidance

from PCC

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ESCROW ACCOUNTS

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How the Escrow Account Works

Generally, escrow credit is amount that family’s rent increases as result of increase in earned income

Families continue to pay increased rent Must use HUD formula Amount of escrows depends on income level

(very-low Vs. low) Let’s see…..

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© Copyright 2008 Nan McKay & Associates Income and Rent Calculations

“BASELINE FIGURES”

Annual income, earned income and family rent entered into contract

Taken From Last Recertification..…

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Baseline Figures

Unless…more than 120 days elapsed Then must conduct interim

Escrow is triggered by increases in earned income, not unearned income

Increase in earned income of any adult family member…. Not just FSS head

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Timing of Escrow Calculations

At time of contract, enter baseline figures No escrow until an increase in earnings is

included in annual income After effective date of contract PHA will

calculate credit At every annual and interim reexamination When there is earned income received by an adult

family member When there is a change in earned income

Remember…PHA policy sets effective date

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Effects of Earned Income Disregard (EID)

Earned income that is not included in family’s annual income due to EID will not be counted in calculation of escrow

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Where Does The Escrow Come From In Public

Housing FSS? Rental Income!!!

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In Section 8?

PHA Share to LL (HAP)

Family Share to LL

Escrow

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Crediting the Escrow

Deposit in single account for each FSS program

Track each family on subsidiary ledger Credit, post interest, and report to family

not less than annually Credits are based on actual rent paid No retro credits for families who don’t report

increases

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Forfeiting Escrow Account

Contract terminated Completed but family receiving welfare If head dies and remaining members choose not

to participate Forfeited Funds

Section 8: treated as program receipts for payment of program expenses (HAP payments)

PH: credited to PHA operating reserves and counted as “other income” in next budget year

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Disbursing FSS Account

Final Disbursement…. When

Family fulfills all obligations under contract

or 30% MAI =/> FMR

Subtract from Escrow… dollars owed the PHA and pay out balance

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Managing the FSS Program

Clarify the Basics Identify Common Mistakes Identify Best Practices

© Copyright 2008 Nan McKay & Associates

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FSS Regulations Clarification

Completion is 30% MAI =/> FMR

NOT Zero HAP

Must have interim if more than 120 days

May not issue 1099 on escrow

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FSS Regulations Clarification

Must reduce escrow balance by $ owed under the lease before posting interest

Must reduce escrow by $ owed PHA before final distribution

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FSS Best Practice Do the basics! Work closely with finance Work using the

regulations from both FSS and Finance as well as

Policies and procedures for paying accounts payable

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FSS Common Mistakes

Not working with finance FSS left out of the loop! Incorrect information to

finance

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Managing Case Managers in the FSS

Program

Know the BasicsProgram Design

© Copyright 2008 Nan McKay & Associates

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FSS Coordinator Activities Develop program needs assessment Identify realistic program outcomes Design FSS program Develop FSS case management record systems Match FSS program’s needs and goals to

existing services in community Develop new community services Develop and maintain program outcomes

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Overview Program StepsDevelop PCC

Identify & coordinate needs to resources

Develop Action PlanRevise Action Plan

ACO

Develop program designService systems

Select & service participants

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FSS Program DesignPlanning

Outreach

Orienting

Assessing Needs & Setting Goals

Selecting

Contracting

Servicing

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Case Managing & Support Services

Escrowing and Porting

Monitoring & Evaluating

Reporting

Program Evaluation Quantitative Qualitative

FSS Program DesignServicing

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FSS Support Services

Voc Assessment Ed Assessment Career Exploration Voc/Ed Planning Job Training Education Tutoring

Life Skills Support Groups Community Activities Job Search

Assistance Resources:

Child Care Transportation Medical

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Managing Case Managers in the FSS

Program

Clarify the Basics Identify Common Mistakes Identify Best Practices

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FSS Program Design Clarification

HUD doesn’t regulate FSS program design

Logic Model is PHAs own creation and includes activities in program design

Design is based on PHAs goal for the program

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FSS Program Design Clarification

Outreach, orientation, needs assessment, and goal setting are separate activities

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FSS Common Mistakes

Designing the FSS program without vocational expertise From PCC From expert staff

Designing the FSS program based on myths about the hardest serve GED is a necessary 1st step People who don’t follow

through aren’t motivated

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FSS Best Practice Use PCC as experts in

employment services Develop FSS program

using referrals to already existing employment services

Put emphasis on FSS Coordination rather than on case management

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Managing Case Managers in the FSS

Program

Know the BasicsCase Management Design

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Case Manager Activities

Develop and manage effective Individual Training & Service Plans by: Conducting orientations and intake interview Assessing skills, abilities, needs & resources Identifying realistic goals, develop tasks to

accomplish goals Monitoring and documenting progress Completing CM relationships of FSS

participants

Page 91: 1 © Copyright 2008 Nan McKay & Associates Managing the FSS Program with Patti Zatarian Menard © Copyright 2008 Nan McKay & Associates.

Managing Case Managers in the FSS

Program

Clarify the Basics Identify Common Mistakes Identify Best Practices

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FSS Case Management Clarification

HUD doesn’t require FSS programs to provide any or all of the case management services

HUD doesn’t regulate file documentation

PHAs may partner for any or all of the case management

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Case Manager Activities

Develop and manage effective Individual Training & Service Plans by: Conducting orientations and intake interview Assessing skills, abilities, needs & resources Identifying realistic goals, develop tasks to

accomplish goals Monitoring and documenting progress Completing CM relationships of FSS

participants

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FSS Case Management Clarification

Really two types of monitoring progress in case management Have you completed this

task or interim goal? What can we do to help?

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FSS Common Mistakes

Developing ITSPs from a conversation between the FSS HOH and the case manager

Providing FSS case management services without training and expertise on how to do so….

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FSS Best Practice

Refer for assessment, goal setting, and monitoring when completing a task or goal is a problem

Place emphasis on PCC and referrals rather than direct case management service

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FSS Best Practice Develop clear

procedures for file documentation and tracking services, completion of tasks, challenges, and outcomes

Use this information to inform PCC

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FSS Best Practice Build strong case

management relationships with FSS families and then partner as they use referral sources

Collaborate for services with PCC so families can succeed

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NMA Upcoming Lunch ‘n’ Learns… The HAP Contract, the Lease, the RFTA

November 7, 2008 Managing EIV

November 14, 2008 Community Service

November 21, 2008