1 Defining & Recording Chronic Homelessness Technical Assistance Training Series March 27 th, 2015
2 INTRODUCTIONS Presenters: Lisa Mayse-Lillig, Vice President of Programming Dave Thomas, Director of Programming You: Name Agency & what types of projects you have What you hope to learn from this training.
3 HOUSEKEEPING Training will be from 9:30am-11:30 Breaks Access to bathroom/keys Please be mindful of noise when entering/exiting room (close door) Questions
4 TRAINING OBJECTIVES Participants will review and understand. Define Chronically Homeless (CH) Understand HUD s documentation requirements Clarify beds dedicated vs. beds prioritized
5 BACKGROUND The McKinney-Vento Homeless Assistance Act was signed into law by President Ronald Reagan in In 2009, President Obama signed the Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act. The HEARTH Act amends and reauthorizes the McKinney-Vento Homeless Assistance Act with substantial changes, including: A consolidation of HUD's competitive grant programs; The creation of a Rural Housing Stability Assistance Program; A change in HUD's definition of homelessness and chronic homelessness; A simplified match requirement; An increase in prevention resources; and, An increase in the emphasis on performance In 2011, HUD issued final rules on the definition of homeless and associated documentation requirements. In 2012, HUD issued interim rules on the definition of chronic homelessness and associated documentation requirements.
6 Section 1: Four Categories of Homelessness
7 OVERVIEW OF HOMELESS DEFINITION Homeless definition has 4 categories: Literally homeless individuals/families Individuals/families who will imminently (within 14 days) lose their primary nighttime residence with no subsequent residence, resources or support networks Unaccompanied youth or families with children/youth who meet the homeless definition under another federal statute and 3 additional criteria Individuals/families fleeing or attempting to flee domestic violence with no subsequent residence, resources or support networks
8 HOMELESS CATEGORY 1 An individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning: Sleeping in a place not designed for or ordinarily used as a regular sleeping accommodation. Living in a shelter designated to provide temporary living arrangements. Exiting an institution (e.g., jail, hospital) - where they resided for 90 days or less AND were residing in emergency shelter or place not meant for human habitation immediately before entering institution.
9 HOMELESS CATEGORY 2 Individuals/families who will imminently lose their primary nighttime residence within 14 days AND: have no subsequent residence identified AND lack the resources or support networks needed to obtain other permanent housing
10 HOMELESS CATEGORY 3 Unaccompanied youth under 25 or families with children and youth who do not otherwise qualify as homeless, but who meet homeless definition under another federal statute; AND have not had lease, ownership interest, or occupancy agreement in permanent housing at any time during last 60 days; AND have experienced two or more moves during last 60 days; AND Can be expected to continue in such status for an extended period of time because of: chronic disabilities; OR chronic physical health or mental health conditions; OR substance addiction; OR histories of domestic violence or childhood abuse (including neglect); OR presence of a child or youth with a disability; OR two or more barriers to employment
11 HOMELESS CATEGORY 4 Individuals/families fleeing or attempting to flee domestic violence, dating violence, sexual assault, stalking, or other dangerous or lifethreatening conditions related to violence, who have no identified subsequent residence; AND lack the resources and support networks needed to obtain other permanent housing.
12 SCENARIO # 1 True or False: John will be discharged from jail after 4 months. He has no housing options/resources. He meets the criteria for Category 1.
13 SCENARIO # 2 Sarah is fleeing dating violence and has no resources/support networks identified. Sarah is homeless under which category? A.Category 1 B.Category 2 C.Category 3 D.Category 4
14 Section 2: Defining & Recording Disability
15 DISABILITY A person shall be considered to have a disability if (s)he has a condition that: Is expected to be long-continuing or of indefinite duration; Substantially impedes the individual s ability to live independently; Could be improved by the provision of more suitable housing conditions; and, Is a physical, mental, or emotional impairment including an impairment caused by alcohol or drug abuse, posttraumatic stress disorder, or brain injury.
16 OTHER DISABILITIES A person shall be considered to have a disability if: (S)he has a developmental disability; (S)he has Acquired Immunodeficiency Syndrome (AIDS) or Human Immunodeficiency Virus (HIV); or, * Any member of the household can have the disability as defined, not just the head of household.
17 DEVELOPMENTAL DISABILITIES A severe, chronic disability of an individual that is: Attributable to a mental or physical impairment or combination of mental and physical impairments; Is manifested before the individual attains age 22; Is likely to continue indefinitely; Results in substantial functional limitations in three or more of the following areas of major life activity: self-care, receptive and expressive language, learning, mobility, self-direction, capacity for independent living, or economic self-sufficiency; and, Reflects the individual s need for a combination and sequence of special, interdisciplinary, or generic services, individualized supports, or other forms of assistance that are of lifelong or extended duration and are individually planned and coordinated.
18 DOCUMENTING DISABILITIES
19 SCENARIO # 3 Joan presents at your permanent supportive housing project. She tells you she has been living in her car for almost a year and that she has taken medication for bipolar disorder but has been off her meds for the last few days. - What type of documentation do you need to determine whether she is eligible for your program? - How will you attempt to document her homelessness?
21 CHRONICALLY HOMELESS An individual who: Is homeless and lives in a place not meant for human habitation; Has been homeless and living or residing in a place not meant for human habitation, a safe haven, or in an emergency shelter continuously for at least one year or on at least four separate occasions in the last 3 years; and Can be diagnosed with one or more of the following conditions: substance use disorder, serious mental illness, developmental disability, post-traumatic stress disorder, cognitive impairments resulting from brain injury, or chronic physical illness or disability;
22 CHRONICALLY HOMELESS An individual who has been residing in an institutional care facility, including a jail, substance abuse or mental health treatment facility, hospital, or other similar facility, for fewer than 90 days and met all the criteria above before entering that facility; A family with an adult head of household (or if there is no adult in the family, a minor head of household) who meets all of the criteria above, including a family whose composition has fluctuated while the head of the household has been homeless.
23 DOCUMENTING CHRONIC HOMELESS CoC-funded projects serving chronically homeless individuals and families must keep records regarding: Evidence of homeless status [Components A(1) or A(2)]; Evidence of the duration of homelessness, either: Evidence that the homeless occasion was continuous for at least one year [Component B(1)]; or, Evidence that the household experienced at least four separate homeless occasions over three years [Component B(2)]; AND, Evidence of diagnosis with a disability (Component C). Each of the 3 definition components of chronic homelessness has its own special documentation rules. Please keep in mind that each component must be separately documented. Thus, client files for an individual or family that is homeless under other Federal statutes need all of the following types of documentation.
24 RANGE OF DOCUMENTATON TYPES In order of preference: third-party documentation first intake worker observations second certification from the person seeking assistance third Already available documentation Discharge paperwork HMIS service transactions
25 DOCUMENTING CH COMPONENT A (1) Component A(1): Homeless Status (Place Not Meant for Human Habitation)
26 DOCUMENTING CH COMPONENT A (2) Component A(2): Homeless Status (Institutions)
27 DOCUMENTING CH COMPONENT B (1) Component B(1): Duration (Continuous for One Year)
28 DOCUMENTING CH COMPONENT B (2) Component B(2): Duration (Four Occasions in Three Years)
29 DOCUMENTING CH COMPONENT C Component C: Disability
30 SCENARIO # 4 Josh presents at your supportive housing project. He tells you that in the past three years he had been living in his car, then in an emergency shelter, and is now living near the creek. Josh also tells you that he was once diagnosed with schizophrenia. What type of documentation do you need to determine whether he is eligible for your program? - How will you attempt to document his homelessness?
31 Dedicated CH Beds Dedicated CH Beds: Must be filled by a CH person Upon turnover (when a participant exits the program) Hold vacant until CH referral received Unless there are no CH persons within the geographic area
32 Non-Dedicated CH Beds Non-Dedicated CH Beds PSH are strongly encouraged to prioritize non-dedicated beds to CH persons Upon turnover (as they become available)
33 Non-Dedicated CH Beds With Prioritization Prioritization means implementing an admissions preference for chronically homeless persons for CoC Program-funded PSH beds. CoCs were scored on the extent to which they were willing to commit to prioritizing chronically homeless persons in a percentage of their non-dedicated PSH beds with the highest points going to CoCs that committed to prioritize the chronically homeless. Further, project applicants for CoC Program-funded PSH had to indicate the number of non-dedicated beds that would be prioritized for use by persons experiencing chronic homelessness. These projects are now required to prioritize chronically homeless persons in their non-dedicated CoC Program-funded PSH beds for FY 2013 and FY 2014, as the project application is incorporated into the grant agreement. Essentially the same guidelines as Dedicated Chronically Homeless Beds
34 TRANSITIONAL HOUSING Transitional Housing Breaks CH eligibility!!! Persons coming from TH are NOT considered Chronically Homeless EXAMPLE: Phil met CH criteria (i.e. documented stay in emergency shelter for 1 year and doctor diagnosed disability). Then Phil moves into TH Program and is applying for PSH. Phil is no longer considered Chronically Homeless.
35 SCENARIO # 5 Your program has 1 bed available, and receives three referrals that are all eligible for your program. Of those referrals, one person is chronically homeless and the other two people are not. -Which client would you take?
36 Section 5: Things To Remember
37 HUD TIPS & RECOMENDATIONS Adopt checklists that reflect preferred order Incorporate guidance and examples Have staff check for existing documentation Create forms for tracking and documenting due diligence Review template forms from HUD
38 3 rd PARTY CERTIFICATION LETTER On Letterhead Paper Include: Client s full name Start & Completion dates of homelessness Signature & Titles of staff member Local printout of history Things To Remember: Staff members of the housing program for CH CANNOT qualify persons themselves based on internal knowledge and information gathering. The supporting documentation must be provided by an appropriate 3rd party. However, if the housing organization is also the provider of a homeless service (such as emergency shelter or street outreach), then an authorized staff member from the emergency component of the same organization CAN, in fact, be considered a 3rd party and may provide a signed letter.
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