HPRP FREQUENTLY ASKED QUESTIONS (FAQS)

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1 HPRP FREQUENTLY ASKED QUESTIONS (FAQS) June 2013 Description: This document contains all current HPRP FAQs posted on the Homelessness Resource Exchange (HRE) as of June 2013.

2 FAQ ID: 435 When will the HMIS technical standards be published, and what are the HMIS requirements under HPRP? The HMIS Data Standards Final Notice is currently available on the HRE. This guidance outlines the HMIS requirements under HPRP. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases) FAQ ID: 437 Participation in HMIS is mandated by this program. Is HUD taking the lead to make sure that grantees funded directly through entitled jurisdictions comply? Often, a CoC has little influence over another jurisdiction within the CoC to mandate participation. The HPRP Operating Instructions for Field Offices and the HPRP Grant Agreement will include HMIS participation requirements. HUD will monitor HPRP grantees for compliance with the requirements. Date Published: 4/3/2009 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases) FAQ ID: 563 Is there specific reporting guidance available for domestic violence providers? Yes. On July 7, 2009 HUD released additional reporting guidance for victim service providers funded by the Homelessness Prevention and Rapid Re-Housing Program (HPRP). This guidance document will assist HPRP grantees, subgrantees and HMIS administering agencies to understand and comply with data collection requirements for domestic violence providers. Date Published: 7/7/2009 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases) HPRP FAQs 1 June 2013

3 FAQ ID: 569 Creating a homeless prevention hotline or 211 call center is an eligible activity under HPRP. What are the HMIS reporting requirements for such activities? An agency administering a homeless prevention hotline or 211 call center is not subject to the HMIS data collection and reporting requirements due to the limited nature of the client contact. Instead, it is the programs receiving the referrals from the call centers and actually assisting clients with HPRP funds that are subject to the data collection and reporting requirements. If the agency operating the hotline provides additional HPRP-funded services beyond intake and referral, they would be required to report client-level data per the HMIS Data Standards. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases) FAQ ID: 740 Can an arrears payment for multiple months be made in one lump sum and recorded in HMIS as financial assistance for one month, and then the actual months paid be notated in the case file? If the actual months must be entered into HMIS, should it be back-dated or dated forward from the program entry date? Financial assistance for arrears should be noted in HMIS as a single lump sum payment, with start and end dates being the same and entered as the date the financial assistance is approved (i.e., not back-dated). The actual number of months covered by the arrears payment can be noted in the case file or case management notes. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases) FAQ ID: 742 At what point is it appropriate to "exit" a client household from HMIS - upon the provision of final assistance or at a later date? Does HUD require the grantee to track the housing stability of households following the receipt of HPRP assistance? Grantees and subgrantees should exit a program participant and record a Program Exit Date that coincides with the date the participant is no longer considered a program participant. The exit date may represent the last day a service was provided or the last date of a period of ongoing assistance. Programs should have a clear and consistent procedure for determining when a client who is receiving supportive services is no longer considered a program participant. For example, if a person has been receiving weekly case management as part of a rapid re-housing program and either formally terminates his or her involvement or fails to keep appointments such that the program HPRP FAQs 2 June 2013

4 no longer considers the individual to be a program participant, then the last date of service and exit date may be the date of the last case management session. For HPRP programs, the Program Exit Date may be the same as the Program Entry Date if participation begins and ends on the same day (e.g., in the case of a one-time payment for arrears, a security deposit, or one month of rental assistance). For a program participant receiving ongoing assistance for two or more consecutive months, the Program Exit Date should be equivalent to the last day of the last month for which the rental assistance payment applies. HUD does not require follow-up reporting on housing stability. The housing status identified at program exit should be the agency's best assessment of the household's near-term stability as of the time of exit. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases) FAQ ID: 743 Within HMIS, "Income & Sources" and "Non-Cash Benefits" information is collected more than once. Does any of the historic information need to be retained? Or should those elements just reflect the latest response? Historical data must be retained in the HMIS. The APRs for HPRP, SHP, and S+C programs require that grantees report income and non-cash benefits at program entry, exit, and the most recent annual reassessment if the period between program entry and exit exceeds one year. The difference in income from entry to exit or annual reassessment is an important indicator that assesses increases in client self-sufficiency, self-reliance, and ability to obtain/maintain housing. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases) FAQ ID: 744 Since all HPRP programs must collect the HMIS universal data elements and the HPRP program-specific data elements from each participant, is there a template available that incorporates these data fields? Yes, sample data collection templates are available on the HRE on the HPRP Data Collection and Reporting Page. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases) HPRP FAQs 3 June 2013

5 FAQ ID: 747 If an individual is homeless and applies for HPRP assistance, should this individual's housing status be changed from 'homeless assistance' to 'prevention' once housing is secured? If so, is the person exited out of homeless assistance and re-entered as a new prevention client? Data on a program participant's Housing Status must be collected and recorded separately both at program entry and program exit. Housing Status at program entry and program exit must be based on the response categories defined in HUD's HMIS Data Standards. The type of assistance (homelessness prevention or homeless assistance/rapid rehousing) is based on the Housing Status recorded at program entry. Specifically, program participants with a Housing Status of 'literally homeless' at entry would be classified as receiving homeless assistance (rapid rehousing); clients with a Housing Status other than 'literally homeless' would be classified as receiving homelessness prevention assistance. Once recorded in HMIS (or a comparable database), the Housing Status at program entry field should not be changed as it represents Housing Status at a point-in-time (i.e. at program entry). If a participant is subsequently housed or their Housing Status otherwise changes, then their Housing Status at program exit would be different than the Housing Status at program entry. Thus, if an individual is literally homeless at the time of application, the type of HPRP assistance for the whole period is considered to be homeless assistance (rapidrehousing) even if the program participant is re-housed after program entry. The participant's Housing Status at program exit would be something other than 'literally homeless'. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases) FAQ ID: 749 The HUD QPR instructions ask for a report of persons served by persons and households. Does this mean that each child should be entered as an individual client and be assigned a separate Personal Identification Number? Every client receiving services must be assigned a Personal Identification Number (PIN). The PIN is permanent and unique to each person and is automatically generated by the HMIS. The PIN is used to obtain unduplicated counts of persons served within individual programs and throughout the entire CoC. All clients served by a program, including dependent children, are considered program participants and must be entered into the HMIS so that they can receive a PIN. All individuals in the same household should receive the same Household Identification Number. A household is defined as a single individual or a group of persons who together apply to an HPRP funded program for assistance. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases) HPRP FAQs 4 June 2013

6 FAQ ID: 751 The 2009 HMIS Data Standards state that 'for each Financial Assistance Provided record, the start date must correspond to the first day of the month for which rental assistance applies and the end date must correspond to the last day of the last month for which rental assistance applies.' Does this mean that Service Transactions for these records aren't necessarily the dates that the assistance is actually provided? For one-time payments of rental assistance for a current month or first month and for one-time or multiple payments of rental assistance for consecutive months, the start date in the Financial Assistance Provided record must correspond to the first day of the month for which rental assistance applies and the end date must correspond to the last day of the last month for which rental assistance applies. A new Financial Assistance Provided record must be entered if there is a break in rental assistance for one or more months during a period of program participation (as determined by program entry and exit date). For example, if the rental assistance applies toward payment of the current month's rent, then the start data for that service transaction should be the first day of the current month for which rental assistance applies. If the rental assistance is provided on the 28th of the month but actually applies to the entire current month rent obligation, the start date for that service transaction would still be the first day of that month. If the client's rent payment is based on a lease schedule that does not correspond to the first of the month (e.g., client moves in on the 5th and the lease begins on the 5th), then the start date for rental assistance should correspond to the start date of the rental period (the 5th day of the month). For one-time payment of rental arrears (excluding current month), last months rent, utility payments (including payment for arrears), security deposit, utility deposit, and moving cost assistance, the start date in the Financial Assistance Provided record must correspond to the day the Financial Assistance was approved. The end date should be identical to the start date. Date Published: 1/29/2010 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases) FAQ ID: 741 If an applicant is assessed for program eligibility, and the applicant ultimately does not meet program requirements, should the client be entered into HMIS? If so, how should ineligible clients be reported for HPRP? (REVISED; Originally posted 1/6/2010) HUD encourages grantees to utilize their HMIS to gather data on all clients engaged in their CoC, so we recognize that data on ineligible clients will be entered into HMIS and that is preferred. Although assessing households is an eligible expense, only HPRP program participants that actually receive financial assistance and/or housing relocation and stabilization services should be reported in the Total Served lines in HPRP s APR and QPR reports. HUD recognizes that many grantees are using HPRP funds for staff time to assess potential clients and that not all these clients will be deemed eligible. This staff time can either be charged to HPRP FAQs 5 June 2013

7 Outreach and Engagement or Case Management and clients who are assessed as part of Outreach and Engagement or Case Management should be reported in the appropriate line in both the QPR and the APR. Grantees need to be sure NOT to report those ultimately deemed ineligible in the Total Served lines. Date Published: 10/11/2011 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases), Determining and Documenting Client Eligibility FAQ ID: 748 If a client refuses to sign a Release of Information for HMIS to share non-confidential client level data with other agencies, can they be denied services? An individual or family can refuse to participate in HMIS, and the provider must still provide services to that household, just as with HUD's Continuum of Care programs. However, persons applying for HPRP assistance must provide enough information for the staff person doing the assessment to verify and document that they meet all of the eligibility criteria for HPRP. While it is not HUD's intention that clients be denied service if they refuse or are unable to supply information for HMIS data collection purposes, some information may be required by the program to determine eligibility, assess needed services, or to fulfill reporting requirements. Please note that HUD's baseline consent protocols allow for inferred consent to collect and enter client data into HMIS. It is not required that providers obtain informed consent or even written consent, unless these more stringent consent protocols are required locally (in which case, a grantee would have to develop the form locally). Date Published: 1/6/2010 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases), Determining and Documenting Client Eligibility FAQ ID: 888 Are applicants required to provide a Social Security Number in order to receive HPRP assistance? HPRP grantees and subgrantees are required to collect certain data from program participants as indicated in the HMIS Data Standards. Social Security Number (SSN) is one of the "Universal Data Elements" that HPRP programs are required to collect from all HPRP participants upon program entry or as soon as possible thereafter. Most data elements, such as SSN, include a "Don't Know" or "Refused" response category. These are considered valid responses if the HPRP participant does not know or refuses to respond to the question. It is not HUD's intention that persons be denied service if they refuse or are unable to supply the information. Please note that the "Don't Know" or "Refused" responses should not be used to indicate that the HPRP staff person does not know the client's response because they failed to ask for the data. Date Published: 7/21/2010 HPRP FAQs 6 June 2013

8 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases), Determining and Documenting Client Eligibility, Eligible Participants (Clients) FAQ ID: 466 Under data collection and evaluation, the notice says that reporting must be done through HMIS or a 'comparable client-level database'. Could you please explain what type of comparable client-level database would be acceptable? And who makes that determination? (REVISED) In order to be considered a comparable client-level database, it must comply with the HMIS Data and Technical Standards. The use of a comparable database is allowable under the following circumstances: (1) The grantee's jurisdiction is not located within a CoC; (2) The CoC does not have an HMIS; (3) The grantee and/or subgrantee has a long-standing, client-level legacy data collection system that meets requirements established in the HMIS Data and Technical Standards and will integrate data with HMIS data periodically; or (4) The subgrantee is a domestic violence provider (e.g. organization's primary mission is serving victims of domestic violence/sexual assault/date rape/stalking) or a legal services provider and requires client-level information to remain confidential, and will establish a comparable client-level database internally to its organization (e.g. no identifying data shared with the HMIS or the grantee) and will provide only aggregate data to the grantee as required. The HMIS administering agency, as an agent of the CoC, determines if an alternative database meets the standards for a comparable clientlevel database, including compliance with the HMIS Data and Technical Standards. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases), Eligible Activities/Costs - Data Collection and Evaluation FAQ ID: 588 Are grantees required to contract for HPRP HMIS with the current HMIS lead agency, or may they contract with a new lead agency specifically for administration (of the same system-software) for HPRP? A CoC may have only one HMIS lead agency to administer the HMIS on behalf of the CoC. Since HPRP data collection and reporting is part of the HMIS, the CoC's HMIS lead agency is responsible for HMIS-related activities for HPRP. Therefore, an HPRP grantee may not select and fund another agency to administer HMIS data collection and reporting for HPRP. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases), Eligible Activities/Costs - Data Collection and Evaluation HPRP FAQs 7 June 2013

9 FAQ ID: 698 Can an HPRP grantee require that a subgrantee use a grantee-identified HMIS instead of, or in addition to, the CoC's established HMIS? HPRP grantees have the right to establish data collection requirements as a condition for awarding HPRP funds to subgrantees. However, where a grantee wishes to establish additional data collection requirements, those requirements cannot compel subgrantees to complete direct entry of client level data into a second database. HUD has established the CoC's HMIS as the point of collection for client level data by subgrantees, except when the CoC has not implemented an HMIS, the subgrantee is not located in a CoC, or an agency-specific comparable database is appropriate (e.g., victim service provider). Additionally, HUD requires subgrantees to report unduplicated aggregate data to grantees and does not require identified data be provided to grantees. If a subgrantee does not want to enter data in two databases to accommodate the grantee's data collection requirements, then the subgrantee, or HMIS administering agency as appropriate, must extract the necessary data from the HMIS and provide it to the grantee. The costs associated with this activity are the responsibility of the subgrantee unless other arrangements are agreed to by all parties. If the grantee does not want to import the exported data directly into the grantee database, especially when that database is an HMIS that covers other CoCs, the grantee may establish another database for analytical purposes and import the data from other data systems into this analytical database. The costs associated with importing data and establishing an analytical database are the responsibility of the grantee unless other arrangements are agreed to by all parties. Date Published: 10/29/2009 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases), Eligible Activities/Costs - Data Collection and Evaluation FAQ ID: 589 HUD guidance requires that all grantees report client-level data in an HMIS or comparable system. In states where there are numerous CoCs, many agencies within these various CoCs are likely to be state subgrantees for HPRP. These CoCs may use different HMIS systems that are not set up to communicate with each other. Can the state require that subgrantees report HMIS data directly to HUD as opposed to the State administering agency? All reports must be submitted to HUD by the grantee. The grantee cannot require that subgrantees report directly to HUD. However, it is possible to use HPRP "Data Collection and Evaluation" funds to develop a data warehouse for use in aggregating the data that will come to the state grantee from multiple systems for the purposes of reporting to HUD. This would be considered an eligible cost. Under this scenario, the state could charge each subgrantee a data warehousing/hmis fee (paid out of the Data Collection and Evaluation line item at the subgrantee level) to cover the costs of developing and maintaining the data warehouse for HPRP reporting purposes. Date Published: 8/14/2009 HPRP FAQs 8 June 2013

10 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases), Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 1245 Can the records for HPRP be retained in an electronic format (e.g., using HMIS) or must hard copy records be retained? Grantees/subgrantees may keep files electronically, but grantees/subgrantees must be able to print them out upon request, or allow them to be viewed as part of an on-site or remote monitoring or audits by the HUD Office of Inspector General. Additionally, if the grantee/subgrantee uses an electronic system, they must provide an adequate back-up system for the files, and ensure privacy protections that adhere to other federal privacy regulations, such as HIPAA (Health Insurance Portability & Accountability Act). Date Published: 12/27/2010 Topic: HPRP; Subtopic: Collecting Client-Level Data (HMIS & Comparable Databases), Grants Management and Monitoring FAQ ID: 428 What guidance is available on calculating household income? (REVISED) Requirements related to calculating household income for HPRP applicants is available in the HUD publication 'Eligibility Determination and Documentation Guidance'. HUD is requiring that grantees use this method for applicants assessed on or after November 1, Sample income verification templates are also available on the HRE on the HPRP Tools and TA Resources Page, though grantees/subgrantees are not required to use these specific forms. Grantees and subgrantees may modify these templates or use locally-developed forms as part of the documentation process as long as such documentation contains the required income information. Date Published: 10/29/2009 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 429 Is there guidance available on documenting a participant's 'risk of homelessness'? (REVISED) Yes, guidance on determining and documenting an HPRP applicant's eligibility, including housing status, is available on the HRE. View the Eligibility Determination and Documentation Guidance. HPRP FAQs 9 June 2013

11 Date Published: 10/29/2009 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 430 With regard to verifying and documenting an individual's risk of homelessness, is an actual eviction notice required? HUD has issued documentation requirements for HPRP grantees. Please see "HPRP Housing Status Eligibility Determination and Documentation Requirements"on the HPRP HUD-Issued Guidance Page. Per these requirements, to be eligible for HPRP-funded prevention assistance, grantees and subgrantees must assess and document that an applicant household would become homeless but for the HPRP assistance. In other words, without HPRP assistance, the household would require emergency shelter or would otherwise become literally homeless. Persons who are at-risk of losing their present housing may be eligible if it can be documented that their loss of housing is imminent without HPRP assistance, including verification/documentation that the household has no other financial resources and support networks to assist with their housing need and they have no other subsequent housing options. While the HUD guidance states that an eviction notice (typed or handwritten) is an acceptable form of documentation, HUD's publication does not prescribe various types of eviction notices. In other words, it could be a letter/notice from the owner/landlord or an official legal document. The document must minimally: oidentify the HPRP applicant and unit where HPRP applicant is the leaseholder; oindicate that applicant must leave their housing; and obe signed and dated by owner/landlord or court Ultimately, the most important thing to be mindful of and train staff on is the 'but for' rule. Case files should include clear documentation and assessment notes that demonstrate an assisted household would have become literally homeless if not for the HPRP assistance. A helpful way for grantees to consider this issue is as follows: if HUD, OIG, or another entity were to conduct a monitoring visit, would they be able to clearly see that an assisted household was eligible based on case file documentation/notes? Periodic review of case files by program supervisors to assure adequate and clear documentation should be strongly encouraged among all sub-grantees. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 495 As stated on page 14 of the Notice, HUD is requiring grantees and subgrantees to reassess household and certify eligibility at least once every 3 months. What happens if a household is determined to be at 51 percent Area Median Income (AMI) at the point of recertification? Is there a grace period? HPRP FAQs 10 June 2013

12 Unfortunately, there is no grace period under HPRP. If a household is at 51 percent of AMI at the time it is reassessed, that household is no longer eligible for HPRP assistance. This underscores the importance of providing ongoing case management for program participants receiving rental assistance in order to transition them to independence. Where possible, grantees may wish to identify an alternate (more flexible) funding source to provide continued support to households that have increased their income but remain precariously housed. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 515 Can the last month of a participant's income be used as a qualifying factor versus the last year of income? Could a person who has just recently lost his/her job and is on the verge of becoming homeless, whose previous annual income was above 50% of AMI, qualify for assistance? (REVISED) Yes, the 50% AMI limit is not based on the household's previous income, but on its income at the time of application to the program. If an individual recently lost his/her job, and household income at the time of application is at or below 50% of AMI, the household is eligible to receive HPRP assistance (assuming it meets all the other eligibility criteria). HUD requirements on determining and documenting eligibility for HPRP applicants, including income requirements, are available in the Eligibility Determination and Documentation Guidance. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 516 Page 22 of the Notice states that 'HUD requires grantees and/or subgrantees to evaluate and certify the eligibility of program participants at least once every 3 months for all persons receiving medium-term rental assistance.' Does the reassessment/recertification requirement apply only to those households receiving financial assistance? No, the reassessment/recertification requirement applies to all households served under HPRP, whether they are receiving financial assistance and services or just services. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility HPRP FAQs 11 June 2013

13 FAQ ID: 517 Does the recertification of program participants who relocate to another jurisdiction have to be conducted face to face? If so, which party (subgrantee or program participant) is expected to travel to complete the recertification? HUD recommends that the recertification process be conducted in person if possible. The costs associated with grantee and subgrantee staff traveling to meet the participants are eligible under either Financial Assistance or Housing Relocation and Stabilization Services. No HPRP funds for travel may be paid for or on behalf of the participants. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 583 Is there a specific process HPRP grantees must use in cases where a potential client is denied service by a grantee/subgrantee and wants to file an appeal? What process is required if a client is determined to be ineligible during the 3-month reassessment? (REVISED) Grantees may establish an appeals process for applicants deemed ineligible, but are not required to do so. However, HUD recommends that grantees develop and make public a process where they document the reasons for denial and inform applicants in writing of the denial. Regarding terminations (e.g., when a client is terminated for breaking program rules or determined to be ineligible at a 3-month reassessment), the HPRP Notice states the following: 'A grantee may terminate assistance to a program participant who violates program requirements. Grantees may resume assistance to a program participant whose assistance was previously terminated. In terminating assistance to a program participant, the grantee must provide a formal process that recognizes the rights of individuals receiving assistance to due process of law. This process, at a minimum, must consist of: (1) Written notice to the program participant containing a clear statement of the reasons for termination; (2) A review of the decision, in which the program participant is given the opportunity to present written or oral objections before a person other than the person (or a subordinate of that person) who made or approved the termination decision; and (3) Prompt written notice of the final decision to the program participant.' In other words, grantees (and subgrantees, if appropriate) must establish the termination process that they will follow when terminating clients from the program. When HUD monitors grantees, they will look for this written policy. Grantees have the discretion to determine the specifics of their appeals process, as long as it meets the minimum standards identified above. However, the formal process is only required after a participant has received assistance and is then terminated from receiving continued assistance. HPRP FAQs 12 June 2013

14 Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 584 The HPRP Notice indicates that HUD is requiring grantees and subgrantees to certify eligibility at least once every 3 months for all program participants receiving medium-term rental assistance. Can these assessments be conducted by telephone? The reassessments can be conducted by telephone in cases where distance prohibits a face-to-face assessment, though HUD encourages face-to-face assessments whenever possible. Local travel for program employees (e.g., mileage) is an eligible case management expense. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 585 Can HMIS be used as third-party documentation of an applicant's homeless status? HMIS may be used to document homelessness in three ways: 1. Data on the program participant's residence in an emergency shelter or transitional housing program for homeless persons was collected in the HMIS; 2. A street outreach program entered data about a program participant living on the streets, park, etc. in the HMIS; 3. The HMIS has "homeless status documentation/certification" functionality so that when one agency in a community documents a person's homeless status, that information/certification is available to other providers in the community. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 718 HUD's HPRP Income Determination and Documentation Requirements publication indicates that the definition of income under HPRP reflects household's income at the time of application, and as such, documents and information collected to verify income must be 'recent.' What is considered recent for public assistance benefits? As explained in the guidance, documentation dated within 30 days of application is acceptable. However, for public assistance benefits (e.g., SSI), a benefits statement received anytime within the past year reflecting current benefits HPRP FAQs 13 June 2013

15 approved for and received by an applicant household and/or a copy of a recent bank deposit slip showing receipt of benefits is acceptable. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 719 What should grantees do if they determine an individual applying for assistance has knowingly provided false information? Grantees must terminate assistance to any program participant who violates program requirements established by HUD (and/or any more restrictive requirements established by the grantee). As described in Section V.E. of the HPRP Notice, the grantee must have a formal process in place and ensure that it is followed for terminations. Additionally, if a grantee believes than an individual has falsified information in order to receive Federal assistance, the grantee should contact the police and proceed with criminal charges. The grantee should also notify its local HUD Field Office and the HUD Office of Inspector General (OIG). HUD OIG has a hotline for such situations: Date Published: 1/6/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 721 Do applicants for HPRP assistance have to deplete all of their liquid assets in order to be eligible for HPRP funds? Similarly, must a household's retirement and educational savings accounts be tapped prior to becoming eligible for HPRP assistance? As described in HUD's publication 'HPRP Housing Status Eligibility Determination and Documentation Requirements,' part of determining eligibility is assessing the household's situation to determine if the household has any other financial resources, support networks, or subsequent housing options. A review of the household's assets would certainly be a relevant part of this analysis. However, HUD has not established requirements concerning how assets are to be treated and whether or what amount of assets held by an applicant household must be spent in order to qualify for HPRP assistance. In other words, whether an eligible household is required to spend down all of its assets or is allowed to retain a reasonable amount of assets is a local determination. Grantees may establish a separate policy for each local Continuum of Care (CoC) where one or more subgrantees operate. In all cases, policy related to treatment of assets must be uniform across all subgrantees within a local CoC and determinations must be applied consistently to all applicant households within the CoC. Date Published: 1/6/2010 HPRP FAQs 14 June 2013

16 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 722 Where do I find the AMI table that is used to determine income eligibility for HPRP assistance? The 2012 income limit dataset is available at HUD updates the dataset each year. Grantees must use the most recent dataset until the new dataset becomes available (at which point grantees must use the new income limits). These 2012 AMI limits are effective as of December 1, HPRP grantees and subgrantees must be using the updated AMI limits for all new screening and eligibility assessments and for the 3-month re-certifications. HPRP grantees and subgrantees DO NOT need to reassess clients currently in the program against updated AMIs until their 3-month re-certifications. FY 2012 estimates are calculated for 535 metropolitan and 2,037 nonmetropolitan areas in the U.S. and its territories, using the Fair Market Rent area definitions applied in the Section 8 Housing Choice Voucher program. The FY 2012 Median Family Income (MFI) estimates are based on American Community Survey data from , and updated Consumer Price Index (CPI) information from Links to the current income limits, area definitions, and other useful information are available from HUD USER. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 723 Does HPRP financial assistance count as income for participants for the purpose of determining eligibility under other state and Federal benefit programs? Financial assistance received under HPRP may be required to be declared under other Federal or state tax laws, or in calculating benefits under other programs. The client is ultimately responsible for providing information required under Federal and state tax laws, and as such, HUD encourages grantees to assist HPRP program participants in understanding these requirements. It is important to remember that HPRP prohibits direct payments to HPRP participants. Payments must only be made to a third party for an eligible type of HPRP financial assistance (e.g., rental assistance, utility assistance). These program design features may or may not have an impact on the calculations required by other Federal or state programs, so grantees may want to highlight these features when gathering information on requirements associated with other programs. Finally, grantees should note that HPRP assistance does not count as income for HPRP income eligibility purposes (i.e., if a program is reassessing eligibility for a household receiving rental assistance, they would not count the HPRP assistance already provided as household income). HPRP FAQs 15 June 2013

17 Date Published: 1/6/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 863 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? Recertification must take place before a grantee approves or provides a fourth month of assistance. A grantee may choose to recertify the client 3 months from the date of applicant intake, 3 months from the date when the client begins to receive financial assistance, or at some point in between those dates as long as the client is recertified prior to receiving a 4th month of HPRP assistance (or 7th, or 10th, etc.). Grantees should begin the recertification process early enough so that they have time to gather needed documentation to confirm continued eligibility without a break in assistance. In situations where there is a break in assistance (e.g., the client receives two months of assistance, is exited from the program, and later re-applies for assistance), the household must be re-evaluated as if they were going through an initial consultation regardless of how many months of assistance were initially provided since a change in income, family composition, or need may have taken place during the interim. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 864 What documentation is required at recertification? The reassessment process will vary just slightly from the original assessment process since grantees/subgrantees are evaluating the participant's current status against the barriers identified during the original consultation. Rapid Re- Housing participants who were documented as meeting HUD's homeless definition at initial assessment do not have to become literally homeless again to continue participating in the rapid re-housing program. Similarly, homelessness prevention participants do not need another eviction and/or shut-off notice to continue receiving HPRP assistance. However, all three assessment areas (income, housing status, and housing options/resources) still apply and must be reviewed and documented during the recertification. REASSESSMENT 1. Income Eligibility: The applicant must still be at or below 50% AMI. Grantees/subgrantees must recalculate and document household income as they did during the original assessment, since circumstances may have changed in the intervening months. As explained in a separate FAQ, there is no a grace period. If a household is over 50 percent of AMI at the time it is reassessed, that household is no longer eligible for HPRP assistance. HPRP FAQs 16 June 2013

18 2. Housing Status Eligibility: HUD's expectation is that HPRP staff will evaluate a participant's progress at the initial consultation as well as at the recertifications every 3 months, to determine and document whether the household is still homeless or is at risk of returning to homelessness (for Rapid Re-Housing programs) OR remains at-risk of homelessness (for Prevention programs). Grantees/subgrantees should evaluate the presence of ongoing barriers to stable housing and risk factors that indicate a household continues to need HPRP assistance to prevent or end homelessness. 3. Other Resources/Support Networks ('But For') Eligibility: The documentation standards outlined in HUD's Eligibility Determination and Documentation Guidance are applicable. Case managers must again assess and document that household lacks the financial resources and support networks needed to obtain housing or remain in their housing. ADJUSTING ASSISTANCE AT REASSESSMENT As explained in the Notice, the appropriate level of financial assistance and/or housing relocation and stabilization services should be based on a participant's specific needs. While a household may have been approved for a full or deep subsidy during the original assessment, it is important for case managers to consider during each reassessment if circumstances have changed and how much assistance a household actually needs to be stabilized at that point. Assistance levels can be then be adjusted to be more or less than the original plan. (For more information on different types of subsidies, see 'Designing and Delivering HPRP Financial Assistance', available on the HRE at: Finally, if a different staff person is conducting the reassessment, a new Staff Certification of Eligibility must be completed. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 865 How does a grantee determine the household size when one member of the household is pregnant? In accordance with other Federal programs, a review of the household's income considers all adults and children existing in the family at the time of application. If the household consists of a father, pregnant mother, and 2 children, the household size is 4. When the child is born, the child can then be included in the calculation of household size. With regard to the unit size/suitability relative to household size, grantees should remember that there are no Federal occupancy standards under HPRP. As such, grantees may take into consideration the overall household configuration and general need to identify the most suitable unit for the applicant. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility HPRP FAQs 17 June 2013

19 FAQ ID: 867 If a household has a child in college, should the student be considered a part of the household? As long as the child is a dependent and the residence is their permanent residence (i.e., they are expected to come home for holidays and summers), they may be considered in the calculation of household size. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 868 Per the HPRP Eligibility Determination and Documentation Guidance, persons living in condemned housing may be eligible for prevention assistance. However, some areas either do not have a housing code or they do not enforce it. Is a formal condemnation notice required? Or are caseworkers allowed to use their discretion in determining what constitutes "uninhabitable"? The grantee is responsible for determining (in accordance with local and Federal requirements as applicable) the best way to serve those in need with HPRP funds. Because jurisdictions vary in regards to the housing code and housing code enforcement, the grantee should determine what's appropriate for their program. While a formal condemnation notice is not required, policies should be reasonable, defensible, and documented. Further, although a habitability inspection is not required to provide prevention assistance, the grantee may decide to conduct one, and this would be an eligible HPRP expense. This can then serve as the basis to help someone move to housing that is more appropriate, safe, and sanitary. For persons residing in buildings that have been condemned or are otherwise not suitable for human habitation, HPRP funds may be used to relocate them to more suitable housing. As with any eligible client, the HPRP assistance may include financial assistance and housing relocation and stabilization services. The unit into which the program participant moves must meet habitability standards as defined Appendix C of the Notice. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 882 Are Domestic Violence providers required to complete the Staff Certification of Eligibility? HPRP FAQs 18 June 2013

20 The Staff Certification of Eligibility (formerly referred to as the Staff Affidavit) serves to remind grantees and subgrantees that they are legally bound to determine and document eligibility of applicants before providing assistance and to avoid providing assistance where a conflict of interest exists. In the case of eligible participants who are fleeing domestic violence, the form must still be completed by the staff person determining the eligibility of the participant. However, the grantee/subgrantee may use client identifiers in place of client names. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 884 As stated in the Appendix to the HPRP Eligibility Determination and Documentation Guidance, unemployment and disability income is included, but income of children is excluded. How is Supplemental Security Income (SSI) received on behalf of a minor treated for purposes of calculating household income? Similar to the income inclusions/exclusions used for other Federal programs, unearned income attributable to a minor (e.g., TANF payments, SSI payments, child support) is included in the income calculation. However, the earned income of minors, including earned income of foster children ages 18 and under, is excluded from the calculation. In addition, for each full time student 18 years or older (excluding the head of household), annual income does not include earnings in excess of $480 (per 24 CFR 5.609). Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 885 According to the HPRP Eligibility Determination and Documentation Guidance, child support is included in the household income calculation. If an applicant has a court order to receive child support but does not actually receive the payments, should the amount be included? As explained in the guidance, eligibility for HPRP assistance is based on 'current income' Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility HPRP FAQs 19 June 2013

21 FAQ ID: 886 Why does the HPRP Eligibility Determination and Documentation Guidance list disability income in both the income inclusion and exclusion tables? The distinction is whether the payments are regular versus temporary/nonrecurring. Recurring disability income received on a monthly basis in lieu of earnings (such as disability compensation, SSI, SSDI, and worker's compensation) is listed as an inclusion and must be counted when calculating gross income for the purpose of determining HPRP eligibility. In contrast, deferred SSI and Social Security payments that are received in a lump sum amount are listed as exclusions and should not be counted when calculating gross income. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 887 Are Food Stamps included or excluded in the household income calculation when determining HPRP eligibility? As noted in Appendix A to the HPRP Eligibility Determination and Documentation Guidance, monthly income from government agencies is included, with the exception of amounts designated for shelter, utilities, WIC, food stamps, and childcare. (See page 30.) In other words, Food Stamps received are not included in the income calculation. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 893 Are agencies administering HPRP required to provide a reason for denial of assistance to a client and/or to a case manager who has referred the client to the HPRP agency (with release of information on file)? It is good practice for grantees and subgrantees conducting intake assessments to maintain a file containing the documentation and reasons for denial of assistance to all applicants, in case of challenges to denials. The grantee may establish an appeals process for applicants deemed ineligible, but is not required to do so. In contrast, a grantee is required to establish a written appeals process for termination of program participants who are receiving assistance, including those determined ineligible at a 3-month reassessment. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility HPRP FAQs 20 June 2013

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