HUD Frequently Asked Questions

topics
Chronic Homeless
Housing First  
Reallocation
Leverage
programs
COC Funded RRH
COC Funded TH
program components
Leasing/Security Deposits
Supportive Services
reporting documentation
APR
Documentation of Disability

topics

Chronic Homeless
1.  Question Text:

(1) What if a homeless person who was chronically homeless for one full year and has
the documentation to substantiate it, moves into a transitional housing program? Do they keep their CH status when they enter TH?

(2) Now, the same person is applying for a PH program with dedicated to CH beds. Is that person from #1 eligible?

(3) What if an individual was qualified as chronically homeless and entered directly into a COC-funded permanent housing program? Can that person hold onto that chronically homeless status while in the program?

Response:

No, individuals and families residing in transitional housing do not maintain their chronically homeless status for purposes of eligibility into other CoC Program funded projects.

For an individual to be considered chronically homeless, he/she must meet the following criteria:

(i) Is homeless and lives in a place not meant for human habitation, a safe haven, or in an emergency shelter; and

(ii) Has been homeless and living or residing in a place not meant for human habitation, a safe haven, or in an emergency shelter continuously for at least one year or on at least four separate occasions in the last 3 years; and

(iii) Can be diagnosed with one or more of the following conditions: substance use disorder, serious mental illness, developmental disability (as defined in section 102 of the Developmental Disabilities Assistance Bill of Rights Act of 2000 (42 U.S.C. 15002)), post-traumatic stress disorder, cognitive impairments resulting from brain injury, or chronic physical illness or disability.

For a family to be defined as chronically homeless, the family must have an adult head of household (or if there is no adult in the family, a minor head of household)who meets all of the above criteria, including a family whose composition has fluctuated while the head of household has been homeless.

In addition, program participants do not retain their homeless status once placed in permanent supportive housing.

However, under the Continuum of Care (CoC) Program, permanent supportive housing projects may serve individuals and families from other permanent housing projects who originally met the eligibility requirements for permanent supportive housing so long as the program participants were eligible for the original permanent housing (Section 423(f) of the McKinney-Vento Act, as amended by the HEARTH Act). This means that an individual or family may transfer from one permanent supportive housing program to another under the CoC Program, including a transfer to a PSH project dedicated to serving the chronically homeless if the household was originally chronically homeless. This could occur if there were another permanent supportive housing program that better met the service needs of the program participant.

Be aware, recipients or subrecipients accepting program participants from other permanent housing projects must keep records on file demonstrating that the individual or family is (1) transferring from another permanent housing project; (2) the reason for the transfer; and (3) met the eligibility requirements for permanent housing prior to entering the original permanent housing project. 
1.  Question Text:

I understand that to be housing first a program can not screen out applicants who have no income and there can be no requirements of sobriety. Are there any barriers to housing that a program can screen out and still be considered housing first? We have some programs who screen for sex offenders and complete a criminal background check. Can they be considered housing first? 

Response:

Housing First is an approach to quickly and successfully connect individuals and families experiencing homelessness to permanent housing without preconditions and barriers to entry, such as sobriety, treatment or service participation requirements. Supportive services are offered to maximize housing stability and prevent returns to homelessness as opposed to addressing predetermined treatment goals prior to permanent housing entry.  This approach removes unnecessary barriers and assumes that supportive services are more effective in addressing needs when the individual or family is housed – when the daily stress of being homeless is taken out of the equation. Key components of this model include a simple application process, a harm reduction approach, and no conditions of tenancy beyond those included in the lease. This approach is highlighted in Opening Doors as a core strategy for ending homelessness. 

Although Housing First is not defined specifically in the CoC Program interim rule, many communities have embraced the Housing First model, and in the FY 2013-FY 2014 CoC Program Competition, CoCs were scored to the extent in which they have adopted this approach in their permanent supportive housing projects.  The core components of Housing First include:

  • Few to no programmatic prerequisites to permanent housing entry – People experiencing homelessness are offered permanent housing with no programmatic preconditions such as demonstration of sobriety, completion of alcohol or drug treatment, or agreeing to comply with a treatment regimen upon entry into program. People are also not required to first enter a transitional housing program in order to enter permanent housing
  • Low barrier admission policies – Permanent supportive housing’s admissions policies are designed to “screen-in” rather than screen-out applicants with the greatest barriers to housing, such as having no or very low income, poor rental history and past evictions, or criminal histories.  Housing programs may have tenant selection policies that prioritize people who have been homeless the longest or who have the highest service needs as evidenced by vulnerability assessments or the high utilization of crisis services.
  • Rapid and streamlined entry into housing – Many people experiencing chronic homelessness may experience anxiety and uncertainty during a lengthy housing application and approval process.  In order to ameliorate this, Housing First permanent supportive housing models make efforts to help people experiencing homelessness move into permanent housing as quickly as possible, streamlining application and approval processes, and reducing wait times.
  • Supportive services are voluntary, but can and should be used to persistently engage tenants to ensure housing stability - Supportive services are proactively offered to help tenants achieve and maintain housing stability, but tenants are not required to participate in services as a condition of tenancy.  Techniques such as harm reduction and motivational interviewing may be useful.  Harm reduction techniques can confront and mitigate the harms of drug and alcohol use through non-judgmental communication while motivational interviewing may be useful in helping households acquire and utilize new skills and information.   
  • Tenants have full rights, responsibilities, and legal protections – The ultimate goal of the Housing First approach is to help people experiencing homelessness achieve long-term housing stability in permanent housing.  Permanent housing is defined as housing where tenants have leases that confer the full rights, responsibilities, and legal protections under Federal, state, and local housing laws.  Tenants are educated about their lease terms, given access to legal assistance, and encouraged to exercise their full legal rights and responsibilities. Landlords and providers in Housing First models abide by their legally defined roles and obligations. For instance, landlords and providers do not enter tenants’ apartments without tenants’ knowledge and permission except under legally-defined emergency circumstances.   Many Housing First programs in permanent supportive housing programs also have a tenant association or council to review program policies and provide feedback, and formal processes for tenants to submit suggestions or grievances. 
  • Practices and policies to prevent lease violations and evictions ­–Housing First supportive housing programs should incorporate practices and policies that prevent lease violations and evictions among tenants. For instance, program policies consistent with a Housing First approach do not consider alcohol or drug use in and of itself to be lease violations, unless such use results in disturbances to neighbors or is associated with illegal activity (e.g. selling illegal substances.)  Housing First models may also have policies that give tenants some flexibility and recourse in the rent payment, which in many subsidized housing programs is 30% of the participant’s income. For example, rather than moving towards eviction proceedings due to missed rent payments, programs may allow tenants to enter into payment installment plans for rent arrearages, or offer money management assistance to tenants.
  • Applicable in a variety of housing models – The Housing First approach can be implemented in different types of permanent supportive housing settings, including: scattered-site models in private market apartments, where rental assistance is provided, and tenants have access mobile and site-based supportive services; single-site models in which permanent supportive housing buildings are newly constructed or rehabilitated  and tenants have access to voluntary on-site services; and set-asides, where supportive services are offered to participants in designated units within affordable housing developments.
As for your specific question, in general, a project that is following a housing first approach may request information related to a potential program participant's sex offender status or other criminal background history, but should use the information identified in the screening to determine the most appropriate housing placement and not to screen out an otherwise eligible individual or family.  The only exception to this policy is for site-based projects.  In these instances, it is possible that an individual or family may be screened out of the site-based project based on a background check (e.g., if an individual is a registered sex offender and cannot live near children and the site has a household with children residing in it); however, HUD encourages the recipient or subrecipient of that project to work with the individual or family presenting for assistance to identify another appropriate housing placement.
Reallocation
Question Text:

If you have a household with children in Transitional Housing (scattered site) and they were literally homeless going into Transitional Housing (coming from a shelter or the street) and they were CMI 0-30%, can they transition into Rapid RE-housing from Transitional Housing?

In other words if you have eligible participants in TH and you switch to RRH, can those clients switch into the new program?

Response:

Thank you for your question. In the case you described in AAQ 31658, where a Transitional Housing grant has been re-allocated to create a new Rapid Re-Housing project, no residents of the original Transitional Housing program would be eligible for entry into the new Rapid Re-Housing program, although they would be permitted to remain in their existing units. This is because PH: RRH funds awarded through the FY 2013 - FY 2014 CoC Program Competition are limited to serving households with children that are coming from the places not meant for human habitation or emergency shelters.

HUD would not expect recipients to exit program participants of transitional housing who are still residing in the units at the expiration of the current transitional housing grant. HUD would permit (and expect) the recipient to continue providing housing and services to those program participants with other non-CoC Program resources until these program participants complete the project. The new project could enroll program participants incrementally, as the expiring project ramps down.

If the recipient does not have other HUD funding, then HUD would expect the project to work with program participants to identify alternate placements or to work on housing stability and exit plans that will help program participants prepare to exit by the end of the current grant period. Even if there has been under-spending in the grant, it is not possible to extend the period of performance of the grant that has been reallocated.
Leverage
Question Text:

We have a lot of misinformation floating around about match/leverage.  I am trying to clarifying for the members of my COC. 

Question #1 - this is our interpretation of the difference between match/leverage.  Is this correct?
Match and leverage are two different categories of program funds – they both must be acquired from other eligible sources & not associated with the grant request.  The only thing that makes match & leverage any different is what you use them for.  Match has to be on program eligible costs and leverage can be used on any program related costs.  But at the end of the day, they source of match & leverage both have to be acceptable sources per HUD.

Question #2 - Sources - are these acceptable as leverage:

Rent payment and occupancy charges collected from program participant?

Amount of food stamps, WIC, and/or TANF that the client receives because of the assistance of a case manager (referral, follow through, documentation, etc)?

Amount of Social Security the client receives because of the assistance of a case manager?

Amount of funds that have been waived by a clinic or therapist (fee for service) because of the advocacy done by the case manager?

Amount of Medical Assistance, State Children's Health Insurance Program - premiums because of the assistance of a case manager?

Response:

Under the FY 2013-FY 2014 CoC Program Competition, match must equal 25% of all amounts requested from HUD, except for leasing funds. Match in the CoC Program is defined as the minimum required cash or in-kind contributions for a project. Match in the CoC Program is restricted to the costs identified in Subpart D of the CoC Program interim rule and the applicable OMB Circulars.

Match and leverage are separate and distinct. Leverage is over and above match; in other words, an amount that is listed as leverage in the project application may not also be listed as match on the project budget.  

Match must equal 25% of all amounts requested from HUD, except for leasing funds. So if your project is requesting $100,000 from HUD (without leasing), the required match for the projects equals $100,000 X.25 = $25,000. Match in the CoC Program is defined as the minimum required cash or in-kind contributions for a project. Match in the CoC Program is restricted to the costs identified in Subpart D of the CoC Program interim rule and the applicable OMB Circulars.

The CoC Program interim rule states at 578.73(c) Matching Requirements/In-kind Contributions that "The recipient or subrecipient may use the value of any real property, equipment, goods, or services contributed to the project as match, provided that if the recipient or subrecipient had to pay for them with grant funds, the costs would have been eligible under Subpart D."

Information on leveraging can be found in Section II.C.2.b.(4) on page 16 of the FY 2014 CoC Funding Notice.  It states:

Applicants may receive up to 5 points based on the extent to which the project will leverage additional resources to develop a comprehensive project that meets the needs of the chronically homeless and ensure successful program outcomes. To receive full points, applicants must demonstrate, with a written commitment, that the cash or in-kind value of leveraged commitments is at least 200 percent of the total request to HUD. Leveraging commitment letters must be attached in e-snaps to the project application.

You can find a copy of the Notice at https://www.hudexchange.info/resource/4032/nofa-for-fy2014-funds-in-the-fy2013-fy2013-coc-program-competition/.

Leverage in the CoC Program is cash and in-kind contributions in excess of the minimum required match contributions for a project. A recipient/subrecipient may use leveraged funds for other aspects of a project even if the costs are not allowable in the CoC Program.

Any financial assistance that comes from public or private resources can be counted as cash leverage. Services (counseling, legal advocacy, etc.) and physical goods (food, furniture, clothing, etc.) can be counted as in-kind leverage. The funds, goods, or services would need to come directly from the source to your organization. In other words, items provided to and for individuals/program participants are not eligible as leverage.

Programs                 

COC Funded RRH
1.  Question Text:

If a COC-funded TH program wants to reallocate their grant and creates a new RRH program through the next COC Competition cycle . . . what happens to the clients that are currently in the TH program? Is there a waiver process to allow them to finish out their program?

Response:

Thank you for your question.

For program participants of transitional housing that are residing in the units upon expiration of the transitional housing grant, HUD would not expect recipients to exit the program participants from the units, but would instead permit the recipient to continue providing housing and services to those program participants until the end of their participation in the program. However, the recipient cannot use grant funds from the PH: RRH grant to pay for the housing or services and recipients would have to use funds other than the PH: RRH grant funds to pay for the continued housing and services. This is because PH: RRH funds awarded through the FY 2013 - FY 2014 CoC Program Competition are limited to serving households with children that are coming from the places not meant for human habitation or emergency shelters.  If the recipient does not have other HUD funding, then HUD would expect the project to work with program participants on housing stability plans and exit plans that will help program participants prepare for project exit and transitioning into permanent housing.

2.  Question Text:

We have several projects reallocating to RRH for families.  To clarify:

(1) When can agencies begin using the money for an eligible family?  In leasing it isn't until they move into a unit, so how does that work for RRH?

(2) When are they "enrollled" for the purposes of RRH - is it when they are deemed eligible even if they are still in shelter or is it once they have secured a unit?  

(3) If you can enroll a client while they are still in shelter or in their car, is there a time limit for using case/care management funds without a family actually obtaining housing?   How long can you use supportive services on a client without rental assistance in the beginning?

(4) Do those clients then still count on the APR as being in the program? 

Response:

Thank you for your inquiry. We regret the delay in responding to your question.

(1) When can agencies begin using the money for an eligible family? In leasing it isn't until they move into a unit, so how does that work for RRH?

When you can begin using your project's rapid rehousing funds depends on the budget line items in your grant.  Eligible costs of the Permanent Housing: Rapid Rehousing (PH-RRH) component are outlined at Section 578.37(a)(1)(ii) of the CoC Program interim rule. It states that recipients and subrecipients can provide supportive services as set forth in 578.53 and/or short-term (up to 3 months) and/or medium-term (4-24 months) tenant-based rental assistance for a unit to help homeless individuals and families to move quickly into permanent housing and achieve stability in that housing. The rental assistance provided to a program participant cannot exceed 24 months. Additionally, supportive services may be provided for no longer than 6 months after the rental assistance stops. In order to receive PH-RRH assistance, all program participants must be the tenant on a lease that has an initial term of at least one year, is renewable, and is terminable only for cause.

Costs associated with staff assisting clients before and during their move to permanent housing may be eligible if they are eligible supportive services costs of the CoC Program and the purpose of the services is to move or stabilize the household into permanent housing. Eligible Supportive Services are outlined at 578.53 of the CoC Program interim rule. Staff time spent on activities directly related to carrying out supportive services (such as housing search and counseling services, per 578.53(e)(8)) or managing the staff who carry out these tasks would be allocated to the supportive services line item.

In addition, staff costs associated with assessing, verifying, and documenting program participant eligibility are an eligible case management cost under the CoC Program interim rule at 578.53(e)(3), whether or not the household ultimately turns out to be eligible for assistance. These costs would be eligible as a direct supportive service program activity. However, once a household has been found ineligible for the program, no additional costs may be incurred on their behalf.

Outreach services, as defined in Section 578.53 (e) (13) of the CoC Program interim rule are to be used to engage participants who are not connected to services and/or housing and include:  "The costs of activities to engage persons for the purpose of providing immediate support and intervention, as well as identifying potential program participants, are eligible.
(i) Eligible costs include the outreach worker‘s transportation costs and a cell phone to be used by the individual performing the outreach.
(ii) Component activities and services consist of: initial assessment; crisis counseling; addressing urgent physical needs, such as providing meals, blankets, clothes, or toiletries; actively connecting and providing people with information and referrals to homeless and mainstream programs; and publicizing the availability of the housing and/or services provided within the geographic area covered by the Continuum of Care."

Also of important note, the costs of administering rental assistance are considered service delivery costs of rental assistance and are therefore eligible under rental assistance costs in the CoC Program. Until HUD publishes the CoC Program final rule that lists the eligible rental assistance costs for administering rental assistance, recipients and subrecipients may use 24 CFR 582.105(e)(2), to identify eligible rental assistance administration activities, which include:

a. Processing rental payments to landlords;
b. Examining participant income and family composition;
c. Providing housing information and assistance;
d. Inspecting units for compliance with housing quality standards; and
e. Receiving into the program new participants.

(2) When are they "enrollled" for the purposes of RRH - is it when they are deemed eligible even if they are still in shelter or is it once they have secured a unit?

Once the participant is determined eligible and meets the definition of homeless as set forth in section 578.3 of the, the CoC Program interim rule as well as any additional eligibility criteria set forth in the CoC Program NOFA under which the project was funded, the person is "enrolled."

For purposes of HMIS data entry: If the HMIS uses a single project to document RRH clients then the date the client was determined eligible would be the project entry date. The project would then use the new data element 4.17 “Residential Move-In Date” to indicate when the client moves into permanent housing, if/when the client moves in.  If the HMIS uses two projects in the HMIS then the pre-entry project entry date would be the date the client was determined eligible and the RRH residential project entry date would be the date of move in to housing.

(3) If you can enroll a client while they are still in shelter or in their car, is there a time limit for using case/care management funds without a family actually obtaining housing? How long can you use supportive services on a client without rental assistance in the beginning?

There is no time limit for using case management funds for eligible families prior to the family obtaining housing.

While rapid re-housing is a model of housing assistance that is designed to assist the homeless (with or without disabilities) move as quickly as possible into permanent housing and achieve stability in that housing, HUD understands that once a household has been determined eligible and enrolled in a CoC Program-funded permanent housing program (including both rapid re-housing and permanent supportive housing), a unit is not always immediately available—sometimes because the waiting lists are too long or because of the things that must be accomplished to secure a unit (e.g., HQS review or application processing). Communities should be continuously working to improve the system to decrease the amount of time that it takes to secure permanent housing, however, HUD acknowledges that these types of improvements take time.

(4) Do those clients then still count on the APR as being in the program?

Yes, those clients will still appear on the APR.  Any clients served by the project is included in the APR.
COC Funded TH
1.  Question Text:

If you have a client who is currently in an agency-owned TH unit (paid for with other, non-COC funds), can that client transfer to a scattered site TH program funded through COC dollars?


Response:

Please note that people residing in transitional housing or emergency shelters (which includes many transitional shelters) are considered homeless under Category 1 of the Homeless Definition. Therefore, there is no restriction on CoC-funded transitional housing programs from accepting individuals coming from transitional shelters or on transferring a client from a privately funded transitional housing program to a CoC-funded transitional housing program, given that they meet all eligibility requirements.

However, while it is technically allowable, HUD cautions against moving clients from one transitional housing placement to another. Transitional housing providers are expected to have program designs that successfully exit people to permanent housing and should not include transferring clients to another TH project as a regular part the program design. Therefore, HUD recommends that this be done on a case-by-case basis, so that it is not a common practice or core aspect of your program design, but is provided only when necessary to prevent the program participant from going back to the streets or emergency shelter

Program Components

Leasing/Security Deposit
1.  Question Text:

We had a client in our scattered site transitional housing program that abandoned her unit and the costs related to cleaning and repair are more than the security deposit.  I read through the CoC Interim Rule for guidance under Eligible Costs for Leasing (which is what we do) and Rental Assistance. I’m not sure what that means for how much we can pay for damages. It looks to me that at the beginning of the program, we can pay a double security deposit (so two times the cost of a month’s rent). But does that mean we can pay up to two month’s rent costs toward damages? Or more, since there is no limit stated like there is under Rental Assistance?

(4) Security deposits and first and last month’s rent. Recipients and sub-recipients may use grant funds to pay security deposits, in an amount not to exceed 2 months of actual rent. An advance payment of the last month’s rent may be provided to the landlord in addition to the security deposit and payment of the first month’s rent.

Under Eligible Costs for Rental Assistance (the way we used to do things) it says this:

(j) Property damage. Recipients and sub-recipients may use grant funds in an amount not to exceed one month’s rent to pay for any damage to housing due to the action of a program participant. This shall be a one-time cost per participant, incurred at the time a participant exits a housing unit.

Response:

Thank you for your inquiry. The CoC Program interim rule does not explicitly provide guidance on recovering damages from a tenant who has caused property damage.

Property damage can, however, be paid for with grant funds in the following instances:

  • If you receive funds for leasing, section 578.49 of the CoC Program interim rule provides that leasing funds may be used for security deposits, therefore damages that would come out of the security deposit could be covered as an eligible cost.
  • If you receive funds for operating, and the cost of repairing or maintaining the housing is not included in the lease, then you may use operating funds to repair the housing.  If these costs are included in the lease, then they are not eligible operating costs (see section 578.55 of the CoC Program interim rule for more information).
Please note, HUD strongly encourages proactive outreach and use of case management with the program participant to help program participants maintain the unit without causing damages beyond the normal wear and tear of residing in a unit for a period of time. 

2.  Question Text:

Can COC leasing funds be used for security deposits for TH programs - in which the agency is the tenant and the unit is sub-let to the client?

Can  COC leasing funds be used for security deposits for PSH programs?

Response:

For recipients of leasing funds under the CoC Program, section 578.49(b)(4) states that recipients and subrecipients with leasing funds may use grant funds to pay security deposits, in an amount not to exceed 2 months of actual rent. This applies to both transitional and permanent supportive housing projects.

Therefore, as the recipient of leasing funds, you would be able to pay a security deposit to the landowner with CoC Program leasing funds. However, keep in mind you would not be able to charge program participants a security deposit.
Supportive Services
1.  Question Text:

There is disagreement within our COC as to what can be included in which of the supportive service line items.  Specifically:

(1) Cell phone for case managers when they go to home visits

(2) mileage reimbursement for case managers using their own vehicles to go to home visits

Do they go in #3 under case management?

or do they go in #13 - outreach OR #17 - operating (for the phone) and

#15 - transportation (for the mileage)?

Response:

As indicated in Section 578.59(a) of the CoC Program interim rule, staff and overhead costs directly related to carrying out activities eligible under Sections 578.43 through 578.57 are eligible costs as part of those activities. Only items that are specifically included in the CoC Program interim rule are eligible costs. Grant funds may only be used for eligible costs in the budget line items that were approved as part of the grant agreement.

Section 578.53 of the CoC Program outlines eligible supportive service costs.

The costs of the cell phone should be included on the budget line item for the activity being performed.

  • The cost of cell phones for case managers is an eligible case management service cost as long as the cell phones are being used for assessing, arranging, coordinating and monitoring the delivery of individualized services to meet the needs of program participant(s).
  • Outreach services, as defined in Section 578.53 (e) (13) of the CoC Program interim rule are to be used to engage participants who are not connected to services and/or housing and include: "The costs of activities to engage persons for the purpose of providing immediate support and intervention, as well as identifying potential program participants, are eligible. (i) Eligible costs include the outreach worker‘s transportation costs and a cell phone to be used by the individual performing the outreach."
  • If the cell phone is being used for more than one activity, the cost of the phone should be prorated among the appropriate budget line items.
With regard to the mileage and transportation costs, please review the CoC Program interim rule for information on the eligible costs under Supportive Services. The decision to record this cost as case management, outreach, or transportation cost depends on the use of the vehicle and your CoC Program grant agreement and approved budget line items. Remember, you may need to prorate the costs.

Note that line #17 operating costs in the supportive services budget is for SSO projects only.

A copy of a formatted version of the CoC Interim rule is available at https://www.hudexchange.info/resource/2035/coc-program-interim-rule-formatted-version/

For detailed instructions on completing the budget section of the project application, please refer to the following resource:  https://www.hudexchange.info/resource/2912/coc-project-application-budget-information/

2.  Question Text:

Can you use supportive service funds to buy gas cards and give them to clients?  

Response:

The CoC Program interim rule at Section 578.53(e)(15) sets forth eligible transportation costs. It includes the costs of program participant's travel in a vehicle provided by the recipient or subrecipient to and from medical care, employment, child care or other eligible supportive services under the CoC Program. Specifically, in Section 578.53(e)(15)(iv) it also includes the cost of the vehicle's gas, insurance, taxes, and maintenance.  Costs incurred by a program participant's vehicle are not an eligible cost.

Gift cards (as gas cards are) are considered to be a form of cash, and under OMB Circular A-87 and OMB Circular A-122, cash payments to program participants are never allowed. Specifically, Section 578.99(5) of the interim rule states that all recipients and subrecipients of CoC Program funds are subject to these circulars that require that for costs to be allowable and allocable they must be "adequately documented." The burden of adequate documentation makes reimbursement of gift cards a potentially unallowable and unallocable expense.

Agencies that received Supportive Housing Program (SHP) funds were also subject to OMB Circular A-87 and OMB Circular A-122. If you have any questions concerning regulations under previous programs, please submit that question to the Legacy AAQ desk.

Reporting Documentation

Annual Performance Review (APR)
Question Text:

We have a renewal TH project that has a DV component and a non-DV component.  As a result, the agency completes two APRs (DV and non-DV) for the same grant.  There appears to be a disconnect between the instructions in ESNAPS as it pertains to what questions include all participants and which questions include only the DV vs. only the non-DV.  

Reviewing the HUD APR guidance (April 2014), it appears that all DV data goes on the DV APR (including number of beds/units and participants just for DV) and all the non-DV data goes on the non-DV APR (including number of beds/units and participants just for non-DV).  That way when added together, the two different APRs equal one project.  

Please confirm that this is the case or provide clarification if there is another interpretation that is more accurate.

Response:

Thank you for your question.  Based on the information that you have provided to us, the recipient completing the APR needs to select "At least one VAWA provider and at least one non-VAWA provider" in question 3.  Once they do that, e-snaps will generate two APRs for the recipient to complete. 

For their first APR, the recipient needs to enter data on questions 4 through 29a2 for the non-VAWA providers with the data coming from their HMIS.  Next, the recipient needs to enter the financial information and the performance measurement questions for the entire grant (i.e. both the non-DV and DV providers), and press Submit. 

 
Lastly, the recipient returns to the Submissions List and completes the "CoC Full APR-DV" with the data on the VAWA provider(s).  This last step means that in the second APR, called CoC Full APR-DV, data on questions 4-29a2 will be entered for the VAWA providers, just as it was for the non-VAWA providers in the first APR. 

Please continue to reference the CoC APR Guidebook if you have any questions about how to complete your APR: https://www.hudexchange.info/resource/1850/e-snaps-coc-apr-guidebook-for-coc-grant-funded-programs/.
Documentation of Disability
Question Text:

In terms of verification of disability, the HUD recognized COC has developed a verification of disability to be used to confirm eligibility for COC funds (not social security).  The document explains what COC TH and PSH funds are for, what the HUD disabiliy definitions are, and a spot for the licensed to diagnose/treat professional to sign off.  Is this sufficient?  It is standardized for the entire HUD recognized COC.

There has been a discrepancy between local HUD staff as to whether this verificaiton is sufficent or whether it has  to be a letter from a doctor on letterhead (which is almost impossible to get).  

Response:

where disability is an eligibility requirement for the project, the recipient must also document the program participant's disability. As found in the HEARTH: Defining "Homeless" Final Rule, the following documentation of disability is accepted:

  1. Written verification of the disability from a professional licensed by the state to diagnose and treat the disability and his or her certification that the disability is expected to be long-continuing or of indefinite duration and substantially impedes the individual's ability to live independently; OR
  2. Written verification from the Social Security Administration; OR
  3. The receipt of a disability check; OR
  4. Intake staff-recorded observation of a disability that, no later than 45 days of the application for assistance, is confirmed and accompanied by evidence in this; OR
  5. Other documentation approved by HUD.
Where the documentation of disability is from a professional licensed by the state to diagnose and treat the disability, HUD would expect that the licensed professional would follow professional, state, and local licensing guidelines.

This help desk cannot determine if the Disability Verification Form you described is sufficient or appropriate for documenting a disability. Please review the disability documentation requirements that apply to your projects to determine if the form meets the requirements. Please note that the requirements do not specify that the "written verification of the disability from a professional licensed by the state to diagnose and treat the disability" be in the form of a letter from a doctor on letterhead.