Table of Contents. Table of Contents (cont d) Understanding HOPWA. I. Overview (4-14) II. HOPWA Funding (15-24) III. Client Eligibility (25-30)

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1 Understanding HOPWA Funded by the National HOPWA Technical Assistance Program of the U.S. Department of Housing and Urban Development s (HUD) Office of HIV/AIDS Housing (2013) Table of Contents I. Overview (4-14) II. HOPWA Funding (15-24) III. Client Eligibility (25-30) IV. Eligible Activities (31-46) V. Needs Assessment & Housing Plans (47-64) VI. Financial & Grants Management (65-108) 2 Table of Contents (cont d) VII. Monitoring Requirements ( ) VIII. Reporting Requirements ( ) IX. HOPWA & the ConPlan Process ( ) X. Integration with Other Community Planning Efforts ( ) XI. Additional Resources ( ) 3 1

2 Part I: HOPWA Overview Statutory Purpose Homelessness and HIV Program Origin Objectives Current Use of Funds 4 Statutory Purpose To provide states & localities with resources & incentives to devise longterm comprehensive strategies for meeting the housing needs of persons with acquired immunodeficiency syndrome & families of such persons. (42 U.S.C ) 5 6 Homelessness & HIV Up to 70% of all People living with HIV/AIDS (PLWHA) report a lifetime experience of homelessness or housing instability 10% to 16% of all PLWHA in some communities are literally homeless at any time sleeping in shelters, on the street, in a car or other place not meant for human habitation Many more PLWHA are unstably housed or faced with housing problems or the threat of housing loss 2

3 Homelessness & HIV Risk Factors 3% to 14% of all homeless persons are HIV+ (10 times the rate in the general population) Rates of HIV infection are 3 to 16 times higher among those who are homeless or unstably housed, compared to those with stable housing Studies show that among persons at high risk for HIV infection due to injection drug use or risky sex, those without a stable home are more likely than others to become infected 7 Homelessness & HIV Risk Factors Research shows a direct relationship between housing status and risk behaviors among extremely low income HIV+ persons with multiple behavioral issues Homeless women were 2 to 4 times as likely to have multiple sex partners as housed indigent women - in part due to the effects of physical violence 8 Federal Response/Program Origin Established by the AIDS Housing Opportunity Act of 1990 (42 U.S.C ) HOPWA regulations finalized in 1992 (24CFR Part 574) Administered by the HUD Office of Community Planning & Development, Office of HIV/AIDS Housing Monitored by HUD State & Local Field Offices 9 3

4 HUD s Overall Strategic Objectives Meet the Need for Quality Affordable Rental Homes End Homelessness and Substantially Reduce the Number of Families and Individuals with Severe Housing Needs 10 HUD s Overall Strategic Objectives Utilize Housing as a Platform for Improving Quality of Life Improve health outcomes Improve housing stability through supportive services for vulnerable populations including seniors, persons with disabilities, homeless persons and those at risk of being homeless 11 HUD s Overall Strategic Objectives HOPWA strives to align with other national efforts: 1) The National HIV/AIDS Strategy: Establishes three major goals to Reduce HIV infections Increase access to care for persons living with HIV/AIDS Reduce HIV-related disparities and improve health outcomes 12 4

5 HUD s Overall Strategic Objectives 2) Opening Doors: Federal Strategic Plan to prevent and end homelessness through a housing-based approach and build on successful service delivery models No one should experience homelessness No one should be without a safe, stable place to call home 3) National Prevention Strategy - America s Plan for Better Health and Wellness: National Prevention, Health Promotion and Public Health Council plan on the impact of social, economic and environmental disadvantage, and strategies for elimination of health disparities and improving quality of life for all Americans 13 Policy and Practice Implications HIV prevention and care strategies will not succeed without addressing structural barriers such as homelessness & housing instability Housing for persons with HIV/AIDS saves lives and taxpayer dollars, making it is a sound health care investment Housing status is likely the most important characteristic of a person with HIV/AIDS who seeks services and the most significant determinant of their health and risk outcomes 14 Part II: HOPWA Funding Overview Formula Competitive Technical Assistance Obligation & Expenditure Requirements 15 5

6 Funding Overview Annual funding has grown from $42.9 million in 1992 to $332 million in 2013 However, this is a $2 million reduction from 2011 funding Eligible Formula Jurisdictions have grown from 34 in 1992 to 135 in funding served over 61,000 households 98% very low incomes, less than 50% AMI 91% extremely low incomes, less than 30% AMI 16 Formula Funding Distribution 1,500 cumulative AIDS cases Population of 500,000 in metropolitan areas Eligible formula areas cities or states HUDapproved Con Plan 17 Formula Program: $ Allocation 18 90% of annual HOPWA funds allocated to eligible states & metropolitan statistical areas (EMSA) *138 EMSA in % of total formula based on cumulative AIDS cases 25% of the formula awarded as a bonus to EMSAs with higher than average per capita incidence of AIDS, as reported the previous year by the CDC 6

7 Formula Program The largest city in the EMSA is appointed as grant recipient ( Grantee ) Grantee responsible for selecting Project Sponsors & implementing grant activities across EMSA HUD requires submission of an approved Consolidated Plan Competitive Program 10% of annual HOPWA funds awarded through HUD s competitive process 1. Long-term Comprehensive Strategies For states & localities not eligible for formula Nine states do not receive HOPWA formula funds, but all have competitive grants: ME, NH, VT, SD, ND, MT, WY, ID, AK Pacific Insular Territories are the only U.S. funded location without any HOPWA funding 2. Special Projects of National Significance (SPNS) Unique or innovative model projects addressing needs of low-income PWAs Competitive Program Funds awarded on a 3 year cycle Applicants can be state, city, or nonprofits New projects awarded after renewals, based on remaining funds available 2007 Appropriations Act requires priority given to expiring grants with successful permanent supportive housing activities Additional eligible activities are outlined in the HUD Federal Register each NOFA 21 7

8 Administration of Funds Project Sponsors: Nonprofits or governmental housing agencies under contract with Grantee to carry out eligible activities Awards to Project Sponsors based on the needs & priorities outlined in the Consolidated Plan & Annual Action Plan Grantees are responsible for monitoring & oversight of Project Sponsors Grantees are responsible for collecting performance data from project sponsors & reporting to HUD for OMB 22 Technical Assistance (TA) Funding OneCPD represents the result of HUD s 2011 Transformation Initiative HUD s CPD allocates funds for TA to provide assessment, training & technical guidance for the formula programs (CDBG, HOME, ESG, HOPWA) HOPWA TA Goal: To strengthen the management, operation, & capacity of HOPWA Grantees, Project Sponsors, & potential new applicants Grantees can request TA online: Grantees and project sponsors can ask questions: 23 Obligation & Expenditure Obligation Requirements: HUD has 3 years to obligate HOPWA formula funds based on the statute,& 2 years to obligate competitive funds Expenditure Requirements: Formula grantees are given 5 years to fully expend funds, allowing time for extensions if necessary, but encouraged to fully expend in 3 years Competitive & TA grants have 3-year grant agreements. An extension up to 12 months (for cause) may be approved by the Field Office 24 8

9 Part III: Client Eligibility Establishing Income Eligibility HIV/AIDS Status Confidentiality Requirements Termination of Assistance 25 Client Eligibility Client Eligibility Requirements Documented HIV or AIDS Gross incomes at or below 80% of the Area Median Income Health professional Not case manager Jurisdictions may impose more stringent requirements Based on local housing availability Planning decisions HUD approval Client Confidentiality Information on the HIV/AIDS status of a client is subject to confidentiality requirements Mandated by Section 856 of the AIDS Housing Opportunity Act 24 CFR The grantee shall agree, & shall ensure that each Project Sponsor agrees, to ensure the confidentiality of the name of any individual assisted under this part & any other information regarding individuals receiving assistance" 9

10 Client Confidentiality Information on HIV/AIDS status only to be used for purpose of determining eligibility Information accessible only to staff who work directly with client Files must be maintained in locked cabinets, or security software Caution with inadvertent disclosures (e.g., checks, caller ID, fax ID, housing quality inspections, publicity) Confidentiality is a monitoring requirement 28 Confidentiality Protection 1. Subsidiary organization with generic name for housing payments to landlords or IRS documentation sent to landlords 2. Separate bank account with checks using a generic name 3. P.O. Box for receiving mail related to housing assistance & payments to landlords 4. Dedicated phone numbers/lines with generic names for dealing with landlords & public Termination of Assistance 1. Death of the client Surviving family may continue to receive housing &/ or supportive services for a grace period Grantee establishes the grace period EMSA-wide Grace period cannot exceed one year 2. Violation of regulations/program requirements Grantee must have a formal written process which follows due process law Process must include written notice, clear statement of reasons for termination, allowance for review/ rebuttal by client, & prompt written notice of final decision 10

11 Part IV: Eligible Activities 24 CFR (b) A. Direct Housing Assistance B. Supportive Services C. Other Program Activities D. Administrative Expenses 31 A. Direct Housing Assistance 1. Facility-based housing development, acquisition, rehabilitation, conversion, and/or leasing 2. Facility-Based Housing Operations Costs (Including project-based rental assistance PBRA) 3. Tenant-Based Rental Assistance (TBRA) 32 A. Direct Housing Assistance 4. Short-Term Supported Housing (emergency shelter) 5. Short-Term Rent, Mortgage, & Utility (STRMU) Assistance 6. Permanent Housing Placement 33 11

12 A1. Facility-Based Development New construction for community residences & single room occupancy (SRO) units Community residence: A multi-unit residence to provide a lower cost residential alternative to institutional care. (24 CFR (a) SRO: A residential property with single-room units for occupancy by a single individual SRO s must include food preparation & sanitary facilities 10 Yr. minimum use period for new construction 34 A1. Facility Acquisition, Rehabilitation, Conversion, Lease, Repair Acquisition, rehabilitation, conversion, lease or repair of facilities Rehabilitation must bring facility up to HOPWA housing quality standards (see 24 CFR (b)) Minimum use periods: 10 years for acquisition &/or substantial rehabilitation 3 years for non-substantial rehabilitation & repairs 35 Uniform Relocation Assistance Federal law to ensure uniform, fair, & equitable treatment of persons whose real property is acquired, or who are displaced, in connection with federally funded projects Applies to acquisition, rehabilitation, or demolition For more information on URA requirements, see: 49 CFR Part 24 (the government-wide regulation that implements the URA) The Real Estate Acquisition & Relocation Policy & Guidance, HUD Handbook

13 A2. Facility-Based Operations Leasing a building or scattered site units Project-based rental assistance (PBRA) Rental subsidy stays with housing facility/units Maintenance, security, insurance, utilities, furnishings, equipment/supplies Requires blended management approach, integrating housing management with provision of supports HOPWA TBRA & Section 8 regulations apply (tenant rent payment, HQS/habitability standards) 37 A3. Tenant-Based Rental Assistance (TBRA) 38 Subsidy stays with client in housing of their choice - within the HOPWA EMSA (not portable) HOPWA habitability standards apply (see 24 CFR (b)) Subsidy pays the difference between the Fair Market Rent or Housing Choice Voucher Payment Standard) & the tenant s portion Tenant must pay greater of 10% gross monthly income, 30% of monthly adjusted income, or the designated welfare housing amount Annual income recertification & unit inspection required to assure ongoing eligibility Tenants may request interim rental adjustment based on increases or decreases in income A4. Short-Term Supported Housing 39 Housing facilities that provide temporary shelter Assistance is limited to 60 days during a 6-month period * The 60 days do not have to be consecutive Facilities may not provide housing for more than 50 individuals or families at any time May be used to pay for short-term hotel/motel vouchers Must, to the extent possible, provide individuals with the opportunity for placement in permanent housing Must also provide an opportunity to receive case management & supportive services Projects must demonstrate efforts to connect beneficiaries to other housing & support systems 13

14 A4. Hotel/Motel Vouchers Track & report as leased units in the APR or CAPER under Short-term Shelter or Transitional Supportive Housing Facility/Units Categorical exclusion documentation under HUD s environmental review requirements is required, made prior to undertaking the activity All short-term housing efforts must follow HOPWA STRMU guidance in CPD Notice addressing connecting HOPWA beneficiaries to stable housing results with on-going support 40 A5. Short-Term Rent, Mortgage, & Utility Assistance (STRMU) Time-limited, needs-based housing & utility assistance designed to prevent homelessness & increase housing stability Assistance is provided to help homeowners & renters remain in their current place of residence Cannot be used for security deposits, first months rent, or other move-in support Designed as a short-term intervention. Other types of assistance (rental assistance or residency in community facility) should be used for clients with ongoing needs A5. STRMU May provide assistance for up to 21 weeks in any 52- week period (weeks do not have to be consecutive) Amount varies per client depending on funds available, client need, & program guidelines May authorize Project Sponsors to cap/limit payments, but must be applied uniformly Cannot be provided if help also being received from other HOPWA, federal, state, or local subsidy program Habitability/HQS inspection not required Providers should assess, through inquiry, unit condition as part of ongoing assessment of housing needs/stability * Decent, safe, & sanitary condition 14

15 A6. Permanent Housing Placement 43 Provides assistance to households moving into permanent housing Staff time for assessment and coordination of PHP activities as a direct service delivery cost Application fees Credit checks Reasonable security deposits Housing costs can not exceed 2 months of rent value) May be used for subsidized housing B. Supportive Services Promote housing stability, reduce homelessness risk Eligibility Assessment & Housing Resources Case Management/Housing Case Management Drug, Alcohol & Mental Health Treatment & Counseling Day Care Personal Assistance Nutritional Services Intensive Care (when required) Assistance in Other Federal/State/Local Benefits & Services Limited Healthcare Costs (Under HUD Guidance) Limited Transportation Costs 44 C. Other Program Activities Housing Information Services Information & referrals to assist eligible persons with locating, acquiring, financing, & maintaining housing Resource Identification Activities to identify, coordinate, & develop housing assistance resources for eligible persons Technical Assistance (Local) Resources used to assist in establishing/ operating a community residence 45 15

16 D. Administrative Expenses 46 Costs for general management, oversight, coordination, evaluation, & reporting Program staff coordination, management, reporting Contracted services (legal, audit, accounting) Goods & services needed for administration (equipment rental/purchase) Limits 3% for HOPWA Grantees of total HUD award 7% for Project Sponsors of total Grantee award Competitive Grantees who also carry out Project Sponsor activities are limited to 3% Part V: Client Needs Assessment and Housing Service Plans Intake Initial client engagement opportunity Basic HOPWA eligibility Determine if a crisis warrants immediate assistance or referral Explain services and case management role Clarify client rights and responsibilities Secure consent for participation Obtain personal data and contact/emergency information, etc. Ensure corresponding documentation and paperwork is received 16

17 Approaches to Assessment 49 Be clear about your role Be direct but respectful and empathic Use creative engagement: think outside the box! Be consistent with your approch - Avoid manipulation Use motivational Interviewing: A directive, yet non-confrontational style to help people who are ambivalent about change Focus on the value of the process and relationship building. First Interactions can leave lasting impressions with applicants 50 Housing Lens vs. Medical Lens There are similarities and overlap in medical psycho-social, and housing assessment and case management Housing stability is the primary objective The housing lens focuses on: Decrease risk of homelessness Housing needs and preferences Income to obtain and maintain housing Eligibility for housing available housing funding Skills and support needed to maintain housing stability and supporting access to care 51 Housing Service Plans HOPWA regulations 24 CFR require appropriate supportive services to be provided as part of any HOPWA-assisted housing HUD Notice CPD STRMU states: Grantees are required to conduct an ongoing assessment of the housing assistance and supportive services required by participants Individualized Housing Plans are mandated as a means to address HOPWA s outcome goals: Increase housing stability Improve access to care Prevent homelessness 17

18 Benefits to Clients Focuses on a better housing situation more appropriate to needs Reduces disparities & impacts health status through improved housing & access to care Expands possibilities to increase income Develops basic life skills Provides a sense of well-being 52 Stages in Housing Plan Development Engagement & Needs Identification through 1. Intake & Assessment: * Income & HIV eligibility * Income & benefits needs * Emergency needs * Healthcare needs * Life skills * Housing needs/preference * Barriers to housing success * Co-occurring disorders * Family & social networks 53 * Use this opportunity to build trust & rapport 2. Goal Setting & Housing Planning 3. Evaluation & Plan Updating Housing Stability Goals Housing stability is the key goal! Goals must be client driven but mutually developed by both client & case manager for maximum buy-in Address immediate needs first Next, encourage development of future oriented goals Explore housing options with, or closer to family, or where affordable housing options &/ or support exist 54 18

19 Mutually Developed Goals Educate client on all available & realistic housing options Focus on Increased Income Earned income goals Benefits sought Focus on Increased Education/Skills Basic life skills Job training Degree related 55 Mutually Developed Goals Identify assistance needed to accomplish plan: Skills or Resources Budgeting & Income Support Negotiating Health Care or Behavioral Health Working with Landlords Identify skills & support needed to maintain chosen housing options & access to care Specify activities for case manager & client with timelines & consequences (if applicable) Client & case manager sign off on plans & updates to formalize the agreement 56 Role of Case Manager Identify assistance needed to accomplish plan Skills or Resources Budgeting & Income Support Negotiating Health Care or Behavioral Health Working with Landlords Be a Cheerleader! 57 19

20 Plan Update & Reassessment Purpose: Identify changes in circumstances that could impact housing plan Health status Family composition Income/employment Behavioral health needs Assessment (formal or informal) can take place with each client interaction Revisit plan progress with each client encounter 58 Intervals for Updating Plan Whenever significant changes occur in client s status If receiving time limited HOPWA services (STRMU or short-term shelter), at least 30 days prior to change in HOPWA support Otherwise, at least every 3 months/quarterly * HOPWA requires at least annual income & rent re-certification 59 Working With Landlords Engagement: Pro-active outreach (landlord associations, newspapers, knocking on doors) Be patient & persistent Know fair housing law Appeal to their priorities: * Focus on how you can be helpful & respond to their needs * Recognize that they are business owners & that renting housing is their livelihood 60 20

21 61 Working With Landlords Understand landlord priorities: Rent payments Apartment maintenance Peaceful community Keeping units filled Assistance with problem tenants Provide education: Available services Knowledge of tenancy expectations Positive experiences with other landlords Client File Contents Well maintained client files with adequate documentation are critical! Completed intake/assessment forms with client data Health status Family composition Income/employment Behavioral health needs Signed Release of Information (ROI) annually updated Valid HIV/AIDS verification Completed household income verification with supporting documents - annually updated 62 Client File Contents Verification of expenses & supporting documents Signed program service agreement Housing plan/individual service plan with updates Completed gross income eligibility worksheet updated annually or when significant change occurs Completed gross & adjusted income & rent calculation worksheet for TBRA or facilities, updated annually or when significant change occurs 63 21

22 64 Client File Contents Shared housing rent calculation worksheet (if applicable) Current Fair Market Rent (FMR) & utility allowance charts (if applicable) Rent Reasonable comparison sheet Housing Inspection Housing habitability/hqs inspection completed & Lead-based Paint Notification - Annually updated (if applicable) Case notes indicating client interactions & progress in meeting desired goals Part VI: Financial & Grants Management 65 Responsibility for HUD Funds 66 Grantees are responsible for ensuring that grants are administered in accordance with the requirements of this part & other applicable laws. Grantees are responsible for ensuring that their respective project sponsors carry out activities in compliance with all applicable requirements. 24 CFR, Part 574, Section 500(a) 22

23 Why Does it Matter? Serious Consequences Funds recaptured Fines, penalties, & worse Not Documented = Un-allowed Not just fraud & intentional Without document backup, funds can be recaptured Sustain or Destroy Organization Proper procedures & systems are essential to organizational survival 67 Written Policies & Procedures are Critical! How transactions are recorded Classification & tracking according to chart of accounts Who has authority to approve transactions Policies that separate duties Organizational charts show lines of responsibility HUD Regulations: Conflict of Interest 24 CFR & 24 CFR (a) Applicability 1. Procurement of supplies, equipment, construction, & services by recipients & by sub-recipients 2. In all cases not governed by the above other provisions apply from , 204; ; (i) e.g. - Acquisition; rehabilitation; preservation - Improvements of private properties - Disposition of real property - Assistance to individuals & private entities under eligible grant activities 23

24 HUD Regulations: Conflict of Interest (b) Conflicts prohibited The general rule - A conflict occurs with persons who: 1. Exercise or have exercised any functions or responsibilities with respect to HOPWA-assisted activities 2. Are in a position to participate in a decision making process, or gain inside information with regard to such activities 4. Have a financial interest in any contract, subcontract, or agreement with respect to a HOPWA-assisted activity 70 HUD Regulations: Conflict of Interest 5. Obtain a financial interest or benefit from any HOPWA assisted activity or proceeds 6. Applies during tenure or for one year thereafter (c) Persons covered as a Conflict of Interest 71 Employees Consultants Business Associates Designated Public Agencies Elected/Appointed Officials Agents Board of Directors Immediate Family Ties Recipients or Sub-recipients HUD Regulations: Conflict of Interest (d) Exceptions HUD may grant exceptions/waivers an on a case-by-case basis when satisfactory requirements have been met 1. Threshold requirements: HUD will consider an exception only after the recipient has provided the following documentation: (i) Disclosure of nature of the conflict, containing - assurance of public disclosure of the conflict - description of how the public disclosure was made 72 24

25 73 HUD Regulations: Conflict of Interest (ii) An opinion of recipient's attorney that the conflict for which the exception is sought would not violate State or local laws (2) Factors to be considered for exceptions/waivers HUD shall conclude that such exceptions will serve to further the purposes of the Act & the effective, efficient administration of the recipient's program or project, considering the cumulative effect of applicable factors: (i) Whether the exception would provide significant cost benefit or an essential degree of expertise to program or project that would otherwise not be available HUD Regulations: Conflict of Interest 74 (ii) Whether opportunity was provided for open competitive bidding or negotiation (iii) Whether affected person is a member of a group or class of low- or moderate-income persons intended to be beneficiaries of the assisted activity, & (iv) Whether the exception will permit affected person to receive generally same interests or benefits as made available/provided to the group or class; (v) Whether affected person has withdrawn from his or her functions, responsibilities, or decision making process with respect to the specific assisted activity in question HUD Regulations: Conflict of Interest (vi) Whether the interest or benefit was present before affected person was in a position (vii)whether undue hardship will result either to recipient or affected person when weighed against the public interest served by avoiding the prohibited conflict (viii) Any other relevant considerations (e) Ongoing monitoring of exceptions/waivers HUD & HOPWA Grantees must monitor the effects of exceptions into the future 75 25

26 Conflicts of Interest Policy Written Code of Conduct Required Should Contain Administrative & Disciplinary Actions for Violations Ensure that all affected personnel, Board of Directors & vendors are informed Update & re-sign annually by all staff & Board of Directors 76 Program Management Requirements Ensuring grants are administered in accordance with applicable laws, regulations & notices Ensuring Project Sponsors carry out activities in compliance with all federal & local requirements, & conditions of grant agreement Reporting to HUD via the Grantee on proper use of funds & programs accomplishments Ensuring that people living with HIV/AIDS are the fairly served & stably housed 77 Financial Management Requirements Approved applications & budgets Satisfactory audits Written internal policies & agreements Charts of accounts & accounting manual Separation of duties Documentation over records & documents Regular reconciliations 78 26

27 79 Financial Management Requirements Maintenance of vendor invoices, bank statements, timesheets, purchase orders Sufficient personal property controls Timely reimbursements & draw of funds from HUD Hiring polices to ensure qualified staff Oversight by grantees - Risk assessment, training & technical assistance Common Financial Management Problems Staffing or housing assistance expenses not supported by documentation Reported & charged costs do not agree with accounting records Instead of time sheets, staff charged based on estimates or pre-established ratios Lack of internal controls 80 HUD Regulations 24 CFR Part 574 HOPWA Regulations HUD Part 84: Admin Requirements for Grants & Contracts with Universities, Hospitals & Non-Profits HUD Part 85: Administrative Requirements for Grants to States, Local Governments, Indian Tribal Governments 81 27

28 Other Controlling Documents OMB A-87: Cost Principles for State, Local Governments, Indian Tribal Governments OMB A-102: Grants & Cooperative Agreements with State & Local Governments OMB A-110 Cost Principles for Educational Organizations, Hospitals & Non-profits OMB A-122 Cost Principles for Non-profit Organizations OMB A-133: Audits of States, Local Governments & Nonprofit organizations (>$500K in federal funding) 82 Financial Key Components Internal Controls Budgets Cash Management Record Keeping Procurement Property Controls Audits 83 Internal Controls Why have them? Ensure that financial data are accurate & reliable Safeguard assets & records including documents, cash, & property Promote operational efficiency Encourage adherence to established policies 84 28

29 Samples of Internal Controls Requiring 2 signatures on checks Separate responsibilities for receiving cash & checks from depositing Having someone other than bookkeeper reconcile bank statements Board involvement in financial management oversight 85 Basic Principles of Allowable Costs Eligible Reasonable Allocable Documented By HUD regulation & consistent with grant agreement Consistent with what others would pay for the same thing Can be attributed to a specific grant & activity Written documentation to support the expenditure 86 Allowable & Non-Allowable Costs Travel Allowed when directly connected to grant activities Written policies in place for expense reimbursement Entertainment Not allowed includes social activities & directly associated costs Contributions Cannot be paid by federal funds Fines & Penalties Not allowed unless in compliance with provisions of a grant award Political Costs Lobbying, etc. not allowed 87 29

30 Adequate Documentation for Costs Beneficiary is eligible for assistance Personnel costs: documentation of actual staff activity Assistance provided meets program requirements 88 Understanding Direct & Indirect Costs Direct Costs Indirect Costs Directly performing activities related to HOPWA objectives Serves common or joint organizational objectives 89 Exercise: Allocating Rental Assistance Costs Expense Allocate to? Subsidy calculation Housing inspection Admin Rental Assistance Check Audit of rent payments Rental Assistance Program Cost 90 Assistance in lease negotiation Security Deposit Permanent Housing Placement 30

31 Understanding Budgets 91 What do budgets do? Help make decisions about planned activities Provide a way to control planned activities Allow financial implications to be analyzed Link revenue & expenditures to program objectives Create a plan of action expressed in financial terms Budgets Budgets provide framework for analyzing & controlling activities Track progress according to planned activity & outcomes Budgets compared to actual reports allow plans to be assessed or modified, as needed Cash flow can be monitored to assure funds are there to meet expenses & that projects are sustainable Budget Controls Expenditures are posted to accounts that correspond to approved budget Organizations regularly compare actual expenditures with the budget Steps are taken to address discrepancies between budget & actual, e.g., steps taken to adjust activities to get back on track Financial information is analyzed with respect to actual performance & accomplishments 31

32 Program Income Examples Participant rents Return of security deposits Funds repaid due to corrective actions Allowable Uses Add to funds used for eligible program purposes Use to cover non-federal share Deduct income from the total project Restricted Revenue Only used for eligible & approved activities 94 Administrative Costs Definition General management Oversight & coordination Evaluation Reporting Based on Actual Costs Cannot simply bill an = % of each month s expenditures Must have documentation of actual costs Admin Vs. Program Activity Costs of managing rental assistance is a direct cost Supervision of case managers is a direct cost 95 Cash Management Federal funds should be drawn down periodically (generally monthly) Funds need to be disbursed within 3 business days of receipt 96 32

33 Records Keeping & Source Documentation Accounting records must identify the source & use of all funds Accounting records must be supported by source documentation Controls must be in place to assure that costs charged to HUD grant are eligible for funding Financial records maintained for 4 years 97 Budget Changes & Amendments Changes are often necessary during the life of a grant Minor changes from the initial application do not substantially affect implementation of the grant: * A shift of less than 10 percent of from one approved activity to is allowed Minor changes do not require HUD approval, nor amendment to the grant agreement but must be documented Documentation must be available to HUD for onsite or remote monitoring & sent to the HUD Office, if requested 98 Program Changes & Amendments Significant program changes in a Formula HOPWA program require a written request to the grantee Formula grantees must ensure program changes align with their Consolidated Plan activities Any program changes for a Competitive HOPWA program require a written request to local HUD office The local HUD office may request additional items to process the request * Grantees should understand that very limited program changes are allowed under Competitive funding All requests must indicate the nature of the change & circumstances of need for change 99 33

34 Equipment records should include: Procurement Written Procurement Policies Govern activities of employees to avoid real or apparent conflicts of interest Allow for free & open competition to extent practical Avoid purchasing unnecessary items Examine lease vs. purchase options Solicitations issued are clear & accurate 100 Procurement Process Analysis of cost & price for every procurement & documented Efforts to use small, minority-owned & womenowned businesses Anything beyond $100,000 must have * Basis for contractor selection * Justification for lack of competition * Basis of award cost Contract administration & oversight assures conformance with terms & conditions 101 Property Controls Property procured/purchased with grant funds tracked & controlled minimum of annually 102 Equipment description Serial number, model number, &/or other identification numbers Source of equipment including award number Acquisition date & cost Location & condition of equipment & date information reported Unit acquisition cost 34

35 Audits Required by federal government when over $500,000 in federal funds received annually Some states impose lower thresholds on nonprofit organizations Audits address many of the financial management compliance issues that monitoring reviews 103 Audits There are various types of Audits: A-133 Audit General Audit Compilation Review Opinions & Management Letters 104 Results of Audits A-133 Audits must be submitted to HUD annually Deficiencies or material weaknesses found must be addressed Even if the federal requirement for A-133 audit isn t met, organizations should get independent audits

36 Treatment of Salaries & Wages All personnel costs must be supported by after-the-fact activity reports Must document all of employees activity not just a single portion Prepared at least monthly & coincide with one or more pay periods 106 Common Problems with Personnel Billings Billing based on budget projections, not after the fact Staff allocations taken from grant agreements Billing based on occasional time studies Personnel assigned so as to spend down grant 107 Note About Timesheets Time sheets must reflect actual times - not percentages Time sheets must be signed & dated by staff & supervisor If time is split between programs (RW, HOPWA, homeless) time sheets must reflect split Only actual HOPWA incurred costs can be charged to HOPWA

37 Part VII: Monitoring Requirements 109 Program Monitoring & Risk Assessment HUD Grantees Admin Agents & Project Sponsors Sub-recipients Ensure requirements & stated program goals are met Ensure funds are used for eligible purposes Monitor compliance with OMB specified standards Enhance management capacity through TA Identify areas in need of improvement Forge working partnership with funder & Grantee Program Monitors Verify Compliance with regulations Final Rule 24 CFR Parts 84, 85, 574 & OMB Circulars Properly documented medical/income eligibility Properly documented housing quality standards Properly documented rent calculations Adherence to rental assistance timelines Program funding limits Maintenance of client confidentiality 37

38 Program Monitors Verify Sound fiscal management, accounting & administrative practices Compliance with Fair Housing practices Adherence to procurement & disposition requirements Timely & accurate reporting Progress in meeting program goals Staffing capacity, training, & turnover Assurance of good practices for each client Types of Financial Management Oversight 1. Remote oversight: Timely & accurate invoices Adequate documentation to back-up invoices Pace of spending is within expectations Billing matches approved activities Billing matches progress reports Timely & accurate performance & outcome reporting Audit reports received from sponsor & reviewed by grantee Types of Financial Management Oversight 2. On-site monitoring: Management monitoring priorities based on prior & current concerns & audit findings Sponsors have adequate written financial policies & procedures Internal cash controls are in place Sponsors adequately tracks grant & activity-level spending Sponsors properly allocates direct & indirect costs Time record documentation for all personnel 114 costs, including administrative staff 38

39 Grantee Responsibility The Bottom Line: HUD holds the grantee responsible for the operations of its sponsors, including: Sound financial practices Compliance with HUD & other regulations Adequate documentation of all activity KEY: Incorporate financial oversight into regular business operations with sponsors Important Dates & Timeliness Standards U.S. Treasury rules require grantees to repay interest gained on holding grant funds in an interest bearing account U.S. Treasury rules prohibit payment of late charges Grantees are discouraged from using other funds to pay for program activities & later reimbursing themselves after IDIS draw Grantees have 90 calendar days to close accounting books at the end of the grant term Only costs with receipts incurred prior to grant expiration date can be paid Part VIII: Reporting Requirements

40 HUD Reporting Requirements Formula Grantees * CAPER - Consolidated Annual Performance & Evaluation Report * IDIS - Integrated Disbursement & Information System Competitive Grantees *APR - Annual Performance Report *IDIS - Integrated Disbursement & Information System Starting in Program year Provides performance data to HUD, OMB, Congress, General Accountability Office (GAO), & other decision makers Provides grant writing data for additional funds 118 * No outcome data - No $ - No programs! Why is Performance Reporting Important? Provides a Planning tool, self- evaluadon APR & CAPER data Grantee Feedback, resources, program enhancements, guidance HOPWA oversight & advocacy & informadon More $ for HOPWA Transparency Community collaboradon increases clients resources BeHer services to clients 119 APR Competitive Grantees APR Associates HOPWA activities with Con Plan & HUD performance outcomes Project Sponsor information Program accomplishments & challenges Total numbers served Planned goals Household demographics Household income levels Expenditures & outcomes by activity Other funds leveraged Housing stability & access to care outcome Report submitted to HUD within 90 days after close of program year

41 CAPER - Formula Grantees CAPER associates HOPWA activities with Con Plan & HUD performance Project Sponsor Information Program accomplishments & challenges Total numbers served & demographics Planned goals Actual performance, Expenditures & outcomes by activity Other funds leveraged Housing stability & access to care outcome Reports are submitted to HUD within 90 days after close of program year IDIS Integrated Disbursement & Information System Provides data to HUD on HOPWA program activities & expenditures Participation is required for formula awards and 2012 competitive awards in addition to APR and CAPER IDIS is a web-based system accessed via the Internet Also a method for drawing reimbursement funds from HUD to grantee bank accounts Part IX: HOPWA & the Consolidated Planning Process

42 124 Consolidated Planning Community-wide 3-5 year master plan for affordable housing in local communities & states Serves as community s application to HUD for CDBG, HOME, ESG, & HOPWA (formula) funds Annual Action Plans are required by HUD * Describes general priorities for allocating funds * Includes a housing market Analysis that describes Market conditions Supply & demand Condition & cost Access to special needs population Public comment sought HOPWA & Annual Action Plan Must provide data on HIV/AIDS housing needs & priorities Details specific AIDS Housing Plans & studies conducted to gather information Outlines method for selecting project sponsors * Community based * Faith based Specifies annual goals for STRMU, TBRA, PBRA households Includes policy changes, such as instituting caps (STRMU) or limiting eligibility to below 80% AMI Requires consultation with organizations that provide housing & supportive services to those with special needs Involvement in ongoing task forces or committees may be best method for impacting the process 125 Part X: Integration with Other Community Planning Efforts Consolidated Plan Ryan White Continuum of Care

43 Why is Collaboration Important? Simply, because we can t afford not to! The need is greater than available resources Increases understanding of relationships among funding streams Supports appropriate systems-level response Leads to more efficient use of funds & prevents duplication of services Brings beneficial outside perspectives Involves key players to develop recommendations 127 HOPWA: Investing in the Future HOPWA funding is a cornerstone of enhanced HUD partnership with other community efforts on HIV/AIDS HUD is working to: Engage in better community planning by sharing meaningful results and data to inform future plans Improve leveraging of HIV and homeless efforts with other resources to promote increased access to health care and other services Make information technology improvements to reduce burdens in use and reporting, and allow better tracking of results and transparency Ryan White Program Focus: Increase availability of healthcare & support services for those living with HIV/AIDS, whose needs are not met through other public programs or private insurance Source: U.S. Department of Health & Human Services, Health Resources & Services Administration (HRSA) Funds available through Ryan White Parts A-F Requires needs assessment & strategic plan for states & communities that receive formula funding Mandates planning involving a broad range of input * Health care agencies * Housing organizations * Community-based providers * 33% must be people receiving HIV-related services 43

44 Homeless Continuum of Care Focus: A Community/region-wide planning process to identify gaps in local housing & services & coordinate strategies to meet the specific needs of homeless individuals & families Source: McKinney-Vento Act/Hearth Act Funds available through the Department of Housing & Urban Development (HUD) Annual Competition Supports the Supportive Housing Program (SHP), Shelter Plus Care, & Section 8 Moderate Rehab (SRO) programs Funding priority: Expand permanent supportive housing for the homeless 130 Homeless Continuum of Care 131 Collects data on the needs of homeless people Conducts inventory of the availability of existing housing & services Identifies opportunities for linkages with mainstream housing & service programs Develops strategies to address highest priority needs/gaps Mandates planning involving a broad range of input * Community & neighborhood groups * State & local governments * Homeless housing & service providers * Housing developers * Private foundations * Homeless & formerly homeless people 132 HMIS: HUD s Housing Management Information System Web-base data collection & management system Simplifies & improves reporting burden Generates valid data for accountability, evaluation, & policy Improves coordination with other HUD & federal programs Increases collaboration Streamlines intakes & coordination for case managers Simplifies service access for clients Improves benefits screening Enhances service delivery 44

45 HOPWA & HMIS HOPWA projects targeting homeless persons are required to participate in HMIS & integrate with the local Homeless Continuum of Care HOPWA projects assisting homeless persons, but not targeting this sub-population are not required to participate in HMIS Homeless HOPWA projects are encouraged to consider the benefits of HMIS HMIS Data & Technical Standards March Part XI: Additional Resources HOPWA Resources HOPWA Statute (42 U.S.C ) & Regulations (24 CFR 574) HOPWA Consolidated Annual Performance & Evaluation Report (CAPER) HOPWA Frequently Asked Questions (FAQs) Notice CPD 06-07: Standards for HOPWA STRMU HOPWA Grantee Oversight Resource Guide CPD Monitoring Guide (see chapter 10 HOPWA) 45

46 Additional Resources HOPWA Program Administration Toolkit HOPWA Best Practices Training Series OneCPD Resource Exchange Mailing List Ryan White Program Information Office of National AIDS Policy AIDS.gov