American Recovery and Reinvestment Act American Recovery and Reinvestment Act Homelessness Prevention and Homelessness Prevention and

Rapid ReRapid Re--housing Programhousing Program

HPRP HPRP Frequently Asked Questions Frequently Asked Questions

Sponsored by: Sponsored by: Office of Special Needs Assistance Programs (SNAPS)Office of Special Needs Assistance Programs (SNAPS)

U.S. Department of Housing & Urban DevelopmentU.S. Department of Housing & Urban Development

PurposePurpose

Discuss top 10 most frequently asked Discuss top 10 most frequently asked questionsquestions–– Clarify requirementsClarify requirements–– Explain intentExplain intent–– Address misconceptionsAddress misconceptions

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1. Eligibility Criteria vs. Risk Factors

What is the difference between eligibility criteria and risk/targeting factors?

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Eligibility vs. Risk Factors continued

Sample risk/targeting factors from the HUD Notice:– Sudden and significant loss of income– Sudden and significant increase in utility costs– Recent traumatic life event, such as death of a spouse, or

recent health crisis that prevented the household from meeting its financial responsibilities

– Homeless in last 12 months– Young head of household (under 25 with children or

pregnant)– Current or past involvement with child welfare, including

foster care– High overcrowding (the number of persons exceeds health

and/or safety standards for the housing unit size)

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Eligibility vs. Risk Factors continued

Participant eligibility: Participant eligibility: –– DoDo participants meet HUDparticipants meet HUD’’s minimum requirements?s minimum requirements?

Targeting:Targeting:–– What target population will program serve?What target population will program serve?–– Targeting decisions impact program design and Targeting decisions impact program design and

program design decisions impact targetingprogram design decisions impact targeting

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2. Stability and Eligibility

Is an applicant required to have an income to be eligible for HPRP assistance?

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3. Eligibility under Prevention vs. Rapid Re-housing

Homelessness Prevention– Persons/households at imminent risk of losing

current housing and will be literally homeless without (“but for”) HPRP assistance

– BUT FOR = 1) no other housing options AND 2) no resources OR support networks to maintain/obtain housing

Rapid Re-housing (Homeless Assistance)– Persons/households that are homeless per the

HUD definition

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Eligibility under Prevention vsRapid Re-housing - Example

Is a person living in a hotel eligible for assistance? If so, would they be served under the Prevention or Rapid Re-Housing category?

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4. Identification Requirements

For HPRP assistance, what forms of For HPRP assistance, what forms of identification are acceptable? Must identification are acceptable? Must each adult member of the household each adult member of the household show picture ID?show picture ID?

Are applicants required to provide a Are applicants required to provide a Social Security Number in order to Social Security Number in order to receive HPRP assistance?receive HPRP assistance?

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5. Lease Requirements

Does a lease have to be in place in Does a lease have to be in place in order to pay rental assistance? Is an order to pay rental assistance? Is an oral lease acceptable? oral lease acceptable?

In many cases, the lease has already In many cases, the lease has already expired but the applicant's name is on expired but the applicant's name is on the lease and they have continued to the lease and they have continued to rent the unit. Is it ok to provide rent the unit. Is it ok to provide assistance in this case? assistance in this case?

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Lease Requirements continued

In a situation where there are two In a situation where there are two unrelated individuals on a lease unrelated individuals on a lease -- one one who is eligible, and one who is not who is eligible, and one who is not ––can a grantee assist the eligible can a grantee assist the eligible individual?individual?

Under HPRP, may a program Under HPRP, may a program participant have a legal sublease? participant have a legal sublease?

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6. HPRP & Occupancy Standards

Can HPRP assist a single individual in a two-bedroom apartment if the rent is reasonable for a two-bedroom unit and the client meets all eligibility criteria? Or can he only be assisted in a one-bedroom unit?

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7. Combining HPRP and Other Types of Assistance (Cost Type Rule)

If a participant is receiving rental assistance through another program, can they also receive HPRP assistance?

– Can HPRP clients receive assistance in HOME or tax credit project?

– Is assistance from a local charity, foundation, or church included in the cost-type rule?

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8. Utility-Only Assistance vs Rent and Utility Assistance

If a client has an eviction notice and meets all eligibility requirements but does not have a utility shut-off notice, can an agency provide both rent and utility assistance? Or is a shut-off notice always required to provide utility assistance?

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9. Recertification

HPRP requires grantees to certify eligibility of all program participants every 3 months. Does the 3 month period begin at applicant intake or when the client first receives financial assistance?– What if there is a break in assistance?

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Recertification: Documentation

What documentation is required at recertification? – If served under Prevention Assistance, is

another eviction notice required? – If served under Rapid Re-housing, does

client have to be literally homeless again?

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10. Appeals Process for Applicants Denied Assistance

Is there a specific process that must be used when an applicant is denied service and wants to file an appeal?– What about termination of assistance

and/or services to program participants?

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11. Indirect Cost

Are indirect costs eligible? If so, how does a grantee/subgranteecharge those costs to the HPRP program?

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11. Indirect Cost

Indirect costs may be allocated to each eligible Indirect costs may be allocated to each eligible HPRP activity, including grant administration, so HPRP activity, including grant administration, so long as that allocation is consistent with an indirect long as that allocation is consistent with an indirect cost proposal developed in accordance with OMB cost proposal developed in accordance with OMB Circular ACircular A--122 (for non122 (for non--profit organizations) orprofit organizations) or OMB OMB Circular ACircular A--87 (for local governments).87 (for local governments).The total grant The total grant administrationadministration costs charged to costs charged to the grant, including both direct and indirect costs, the grant, including both direct and indirect costs, must not exceed 5% of the granteemust not exceed 5% of the grantee’’s total HPRP s total HPRP grant amount.grant amount.Indirect costs charged to other 3 eligible activity Indirect costs charged to other 3 eligible activity types are not subject to the 5% cap. types are not subject to the 5% cap.

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11. Indirect Cost

If an organization does not have an approved If an organization does not have an approved indirect cost rate, indirect cost rate, granteees/subgranteesgranteees/subgrantees may may allocate a reasonable proportion of their indirect allocate a reasonable proportion of their indirect costs to the activity.costs to the activity.Example:Example: An HPRPAn HPRP subgranteesubgrantee employsemploys ten ten staff,staff, four of which work full time on HPRP case four of which work full time on HPRP case management and service activities. They can management and service activities. They can charge 40% of monthly office lease/rent costs to charge 40% of monthly office lease/rent costs to the Housing Relocation and Stabilization Services the Housing Relocation and Stabilization Services category.category. As always, the grantee or As always, the grantee or subgrantee'ssubgrantee'splan for directplan for direct--charging indirect costs must be charging indirect costs must be reasonable and supported by documentation.reasonable and supported by documentation.

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11. Indirect Cost

Can apply this policy retroactively, but Can apply this policy retroactively, but not required tonot required toSubgranteesSubgrantees work with granteeswork with granteesMaintain documentation when Maintain documentation when applying indirect cost ratesapplying indirect cost ratesIf you have budget changes as a result If you have budget changes as a result of this policy, submit a revised of this policy, submit a revised substantial amendment substantial amendment

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Common Issues

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Rent Reasonableness & Rent Reasonableness & Moving Cost AssistanceMoving Cost Assistance

Rent Reasonableness Rent Reasonableness ≠≠ FMRsFMRsRent Reasonableness checks required Rent Reasonableness checks required for Prevention for Prevention andand Rapid ReRapid Re--housing housing assistanceassistanceMoving Costs must be reasonable and Moving Costs must be reasonable and documenteddocumented

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Documentation, Documentation, Documentation, Documentation, Documentation!Documentation!

Supporting documents for drawsSupporting documents for draws33--month remonth re--certificationscertifications–– Must meet all eligibility criteriaMust meet all eligibility criteria–– Use 2010 AMI: Use 2010 AMI:

http://www.huduser.org/portal/datasets/ilhttp://www.huduser.org/portal/datasets/il/il10/index.html/il10/index.html

Payment of arrears must not exceed 6 Payment of arrears must not exceed 6 months months

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Documentation, Documentation, Documentation, Documentation, Documentation!Documentation!

Hotel/motel vouchers Hotel/motel vouchers –– remember, all remember, all 3 criteria must be met3 criteria must be metHabitability standardsHabitability standardsLeadLead--based paint assessmentsbased paint assessments–– Must be completed for prevention and Must be completed for prevention and

rapid rerapid re--housing assistancehousing assistance

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