COC PROGRAM ELIGIBILITY DOCUMENTATION

Transcription

1 COC PROGRAM ELIGIBILITY DOCUMENTATION HomeBase December 5, 2014

2 Agenda for Today Overview Section 1: Four Categories of Homelessness Definitions Eligibility Documentation Requirements Section 2: Chronic Homelessness Definitions Eligibility Documentation Requirements Section 3: Tips and Tricks Wrap Up

3 Upcoming Trainings Wednesday, December 10 - Match and Leverage Friday, December 12 - Recordkeeping and HMIS Wednesday, December 17 - To be announced Friday, December 19 - To be announced

4 Overview

5 Background The HEARTH Act (enacted in 2009) changed the HUD definitions of homeless, at risk of homelessness, and chronically homeless. In November 2011, HUD issued final rules on the definition of homeless and associated documentation requirements. In July 2012, HUD issued interim rules on the definition of chronic homelessness and associated documentation requirements.

6 General Overview There are four (4) main categories under which individuals and families are considered homeless. There are specific documentation rules for each of these categories. When available, third-party documentation is the preferred documentation of homeless status.

7 Notes The definition of at risk of homelessness DOES NOT apply to grants awarded through the CoC Program Competition. At risk of homelessness does apply to recipients of Emergency Solutions Grants (ESG) funds.

8 Section 1: Four Categories of Homelessness

9 Four Categories There are four categories of homelessness, including: Category 1: Literally Homeless Category 2: Imminent Risk of Homelessness Category 3: Homelessness Under Other Federal Statutes- DOES NOT APPLY IN SANTA CLARA COC Category 4: Fleeing/Attempting to Flee Domestic Violence

10 Category 1: Literally Homeless

11 Category 1: Literally Homeless Definition An individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning: Has a primary nighttime residence that is a public or private place not meant for human habitation; Is living in a publicly or privately operated shelter designated to provide temporary living arrangements (including congregate shelters, transitional housing, and hotels and motels paid for by charitable organizations or by federal, state, and local government programs); or Is exiting an institution where (s)he has resided for 90 days or less and who resided in an emergency shelter or place not meant for human habitation immediately before entering that institution.

12 Subcategory A: Place Not Meant for Human Habitation Definition An individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning: Has a primary nighttime residence that is a public or private place not meant for human habitation. Note: This includes people sleeping on the streets or in cars, abandoned buildings, bus/train stations, airports, etc.

13 Subcategory B: Temporary Living Arrangements Definition An individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning: Is living in a publicly or privately operated shelter designated to provide temporary living arrangements (including congregate shelters, transitional housing, and hotels and motels paid for by charitable organizations or by federal, state, and local government programs). Note: This includes people staying at emergency shelters, transitional housing programs, or using hotel/motel vouchers.

14 Subcategory C: Institutions Definition An individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning: Is exiting an institution where (s)he has resided for 90 days or less and who resided in an emergency shelter or place not meant for human habitation immediately before entering that institution. Note: This does NOT include persons who lived in transitional housing prior to entry into an institution.

15 Category 1: Literally Homeless Eligibility The following programs can serve Category 1 persons: Permanent Housing (for PSH, also need to be disabled) Safe Haven (with other characteristics) Transitional Housing SSO

16 Category 1: Literally Homeless Eligibility (Samaritan Bonus and Chronic Homeless Projects) Under Category 1, Samaritan Bonus and Chronic Homeless projects can serve persons who meet the definition of chronic homelessness and are: Living in places not meant for human habitation (cars, parks, sidewalks, and abandoned buildings); Living in emergency shelter or government/charity-funded motel (emergency voucher); Living in a Safe Haven; or, Living in one of the above places but temporarily for no more than 90 days residing in an institution.

17 Category 1: Literally Homeless Documentation Requirements Each of the 3 subcategories has its own special documentation rules. Please keep in mind that persons can fit into any one of the 3 subcategories. Thus, client files for an individual or family that is literally homeless only need one of the following types of documentation.

18 Subcategory A: Place Not Meant for Human Habitation Documentation Requirements Subcategory A An individual or family who has a primary nighttime residence that is a public or private place not meant for human habitation. You Need One (1) Document for the File ONE of the following: Written observation by an outreach worker of the conditions where the individual or family was living; Written referral by another housing or service provider; or, Certification by the individual or head of household seeking assistance.

19 Subcategory B: Temporary Living Arrangements Documentation Requirements Subcategory B An individual or family who Is living in a publicly or privately operated shelter designated to provide temporary living arrangements (including congregate shelters, transitional housing, and hotels and motels paid for by charitable organizations or by federal, state, and local government programs). You Need One (1) Document for the File ONE of the following: Written observation by an outreach worker of the conditions where the individual or family was living; Written referral by another housing or service provider; or, Certification by the individual or head of household seeking assistance.

20 Subcategory C: Institutions Documentation Requirements Subcategory C An individual or family who is exiting an institution where (s)he has resided for 90 days or less and who resided in an emergency shelter or place not meant for human habitation immediately before entering that institution You Need Two (2) Documents for the File ONE of the following: Written observation by an outreach worker of the conditions where the individual or family was living; Written referral by another housing or service provider; or, Certification by the individual or head of household seeking assistance. PLUS ONE of the following: Discharge paperwork or a written or oral referral from a social worker, case manager, or other appropriate official of the institution stating the beginning and end dates of residency. All oral statements must be recorded by the intake worker; or, If evidence described above isn t obtainable, a written record of the intake worker s due diligence in attempting to obtain that evidence PLUS a certification by the individual seeking assistance that states (s)he is exiting or has just exited an institution where (s)he has resided for 90 days or less.

21 Consider Anna Banana presents at your permanent supportive housing project for intake. She tells you she s lived by the creeks for the past 18 months, but just left a short stay in the hospital of 3 weeks. - Is Anna homeless under Category 1? - How will you attempt to document her homelessness? - Would you do anything different if you worked at a transitional housing project?

22 Category 2: Imminent Risk of Homelessness

23 Category 2: Imminent Risk of Homelessness Definition An individual or family who will imminently lose their primary nighttime residence, provided that: Residence will be lost within 14 days of the date of application for homeless assistance; No subsequent residence has been identified; and The individual or family lacks the resources or support networks needed to obtain other permanent housing. Note: Support networks include family, friends, faithbased or other social networks.

24 Category 2: Imminent Risk of Homelessness Eligibility Transitional Housing and Supportive Services Only projects can serve persons homeless under Category 2

25 Category 2: Imminent Risk of Homelessness NON- Eligible These programs cannot serve individuals or families that are homeless under Category 2. - Permanent Housing - Safe Haven - Samaritan Bonus and Chronic Homeless

26 Category 2: Imminent Risk of Homelessness Documentation Requirements Each of the 3 definition components of persons at imminent risk of 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 at imminent risk of homelessness need all of the following types of documentation.

27 Component A: Residence Lost Within 14 Days Documentation Requirements Component A Residence will be lost within 14 days of the date of application for homeless assistance. You Need One (1) Document for the File ONE of the following: A court order resulting from an eviction action that requires the individual or family to leave their residence within 14 days after the date of their application for homeless assistance; or the equivalent notice under applicable state law, a Notice to Quit, or a Notice to Terminate issued under state law; For individuals and families whose primary nighttime residence is a hotel or motel room not paid for by charitable organizations or federal, state, or local government programs for low-income individuals, evidence that the individual or family lacks the resources necessary to reside there for more than 14 days after the date of application for homeless assistance; or, An oral statement by the individual or head of household that the owner or renter of the housing in which they currently reside will not allow them to stay for more than 14 days after the date of application for homeless assistance. The intake worker must record the statement and certify that it was found credible. To be found credible, the oral statement must either: Be verified by the owner or renter of the housing in which the individual or family resides at the time of application for homeless assistance and documented by a written certification by the owner or renter or by the intake worker s recording of the owner or renter s oral statement; or, If the intake worker is unable to contact the owner or renter, be documented by a written certification by the intake worker of his or her due diligence in attempting to obtain owner or renter s verification and the written certification by the individual or head of household seeking assistance that his or her statement was true and complete.

28 Component B: No Subsequent Residence Documentation Requirements Component B No subsequent residence has been identified. You Need One (1) Document for the File Certification by the individual or head of household that no subsequent residence has been identified.

29 Component C: No Subsequent Residence Documentation Requirements Component C The individual or family lacks the resources or support networks needed to obtain other permanent housing You Need One (1) Document for the File Certification or other written documentation that the individual or family lacks the resources and support networks to obtain other permanent housing.

30 Consider Carmen Diego presents at your transitional housing project for intake. She tells you her brother is kicking her out of his apartment. - Is Carmen homeless under Category 2? What do you need to know? - If homeless, how would you document her homelessness?

31 Category 3: Homeless Under Other Federal Statutes

32 Not Applicable in Santa Clara CoC Only CoCs approved by HUD may use this definition, and then only for up to 10% of their funds Santa Clara CoC has not requested such a waiver

33 Category 3: Homeless Under Other Federal Statutes Definition Unaccompanied youth under 25 years of age, or families with children and youth, who do not otherwise qualify as homeless under this definition, but who: Are defined as homeless under the other listed federal statutes; Have not had a lease, ownership interest, or occupancy agreement in permanent housing during the 60 days prior to the homeless assistance application; Have experienced persistent instability as measured by two moves or more during the preceding 60 days; and Can be expected to continue in such status for an extended period of time due to special needs or barriers. Note: Any project wishing to serve individuals homeless under Category 3 must have permission from both the CoC and HUD. To date, HUD has not granted permission to any grantees.

34 Category 3: Homeless Under Other Federal Statutes Eligibility If the CoC and project are approved to serve Category 3, the following types could serve this populations: Transitional Housing Supportive Services Only

35 Category 3: Homeless Under Other Federal Statutes NON-Eligible Even if approved the following project types cannot serve Category 3 Permanent Housing Safe Haven Samaritan Bonus and Chronic Homeless projects

36 Category 3: Homeless Under Other Federal Statutes Documentation Requirements Each of the 4 definition components of persons homeless under other Federal statutes 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.

37 Component A: Defined as Homeless Under Other Federal Statute Documentation Requirements Component A Unaccompanied youth under 25 years of age, or families with children and youth, who do not otherwise qualify as homeless under this definition, but who are defined as homeless under the other listed federal statutes. You Need One (1) Document for the File Certification of homeless status by the local private nonprofit organization or state or local government entity responsible for administering assistance under the specified federal statutes. Note: Other federal statutes include examples such as the Head Start Act, the Violence Against Women Act, and the Department of Education s definition of homelessness.

38 Component B: No Lease, Ownership, or Occupancy Agreement in Past 60 Days Documentation Requirements Component B Unaccompanied youth under 25 years of age, or families with children and youth, who do not otherwise qualify as homeless under this definition, but who have not had a lease, ownership interest, or occupancy agreement in permanent housing during the 60 days prior to the homeless assistance application. You Need One (1) Document for the File ONE of the following: Referral by a housing or service provider; Written observation by an outreach worker; or, Certification by the homeless individual or head of household seeking assistance.

39 Component C: Persistent Housing Instability Documentation Requirements Component C Unaccompanied youth under 25 years of age, or families with children and youth, who do not otherwise qualify as homeless under this definition, but who have experienced persistent instability as measured by two moves or more during the preceding 60 days. You Need One (1) Document for the File Certification by the individual or head of household and any available supporting documentation that the individual or family moved two or more times during the 60-day period immediately preceding the date of application for homeless assistance, including: Recorded statements or records obtained from each owner or renter of housing, provider of shelter or housing or social worker, case worker, or other appropriate official of a hospital or institution in which the individual or family resided; or, Where these statements or records are unobtainable, a written record of the intake worker s due diligence in attempting to obtain them. Where a move was due to the individual or family fleeing domestic violence, dating violence, sexual assault, or stalking, then the intake worker may alternatively obtain a written certification from the individual or head of household seeking assistance that they were fleeing that situation and that they resided at that address.

40 Component D: Expectation of Continued Housing Instability Documentation Requirements Component D Unaccompanied youth under 25 years of age, or families with children and youth, who do not otherwise qualify as homeless under this definition, but who can be expected to continue in such status for an extended period of time due to special needs or barriers. You Need One (1) Document for the File ONE of the following: Written diagnosis from a professional who is licensed by the state to diagnose and treat that condition; Intake staff-recorded observation of disability within 45 days of the date of application for homeless assistance that is confirmed by a professional who is licensed by the state to diagnose and treat that condition; Employment records; Department of Corrections records; Literacy or English-proficiency tests; or, Other reasonable documentation of the specified condition.

41 Consider No CoC has received permission to serve Category 3 homeless people. - Why do you think no one has asked? - How might CoCs be serving people in this category?

42 Category 4: Fleeing/Attempting to Flee Domestic Violence

43 Category 4: Fleeing/Attempting to Flee Domestic Violence Definition Any individual or family who: Is fleeing, or is attempting to flee, domestic violence; Has no other residence; and Lacks the resources or support networks to obtain other permanent housing. Note: Domestic violence includes dating violence, sexual assault, stalking, and other life-threatening situations that make them afraid to return to their primary nighttime residence. Note: Support networks include family, friends, faith-based or other social networks.

44 Category 4: Fleeing/Attempting to Flee Domestic Violence Eligibility The following project types can serve Category 4: Permanent housing Transitional housing Supportive services only Safe havens and Samaritan Bonus/Chronically homeless projects can serve Category 4, but the individual must come from streets or shelter (so in most cases would also be Category 1 homeless and would be documented as stated there).

45 Category 4: Fleeing/Attempting to Flee Domestic Violence Documentation Requirements Generally, the person s oral statement plus one other document is all that is required for the client file. However, programs may want to consider documenting oral statements for recordkeeping purposes.

46 Category 4: Fleeing/Attempting to Flee Domestic Violence Documentation Requirements Category 4 Any individual or family who is fleeing, or is attempting to flee, domestic violence, who has no other residence, and who lacks the resources or support networks to obtain other permanent housing. You Need Two (2) Document for the File An oral statement by the individual or head of household seeking assistance that they are fleeing that situation, that no subsequent residence has been identified, and that they lack the resources or support networks (e.g., family, friends, faith-based or other social networks) needed to obtain other housing. PLUS ONE of the following: If the individual or family is receiving shelter or services provided by a victim service provider, the oral statement must be documented by either a certification by the individual or head of household; or a certification by the intake worker; or, Otherwise, the oral statement must be documented by a certification by the individual or head of household that the statement is true and complete, and, where the safety of the individual or family would not be jeopardized, the domestic violence, dating violence, sexual assault, stalking, or other dangerous or life- threatening condition must be verified by a written observation by the intake worker or a written referral by a housing or service provider, social worker, legal assistance provider, health-care provider, law enforcement agency, legal assistance provider, pastoral counselor, or any other organization from whom the individual or head of household has sought assistance for domestic violence, dating violence, sexual assault, or stalking. The written referral or observation need only include the minimum amount of information necessary to document that the individual or family is fleeing, or attempting to flee domestic violence, dating violence, sexual assault, and stalking.

47 Consider Ella Figaro presents at your permanent housing project for intake. She tells you that she s had instable housing for a while due to an abusive, stalking exboyfriend. - What do you need to know to determine if she s eligible for your program? - How would you document Ella s homelessness?

48 Section 2: Other Definitions and Documentation Requirements

49 Other Definitions and Documentation Requirements Other definitions and documentation requirements include: Persons with Disabilities Chronic Homelessness

50 Section 2A: Persons with Disabilities

51 Persons with Disabilities Definition A household composed of one or more persons at least one of whom has a disability.

52 Disability Definition 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.

53 Other Disabilities Definition 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, Except in the case of the SRO Component: n Two or more persons with disabilities living together; n One or more such persons living with another person who is determined to be important to their care or well-being; and, n The surviving member or members of any disabled household who were living, in a unit assisted with CoC funds, with the deceased member of the household at the time of his or her death. (Note: The right to rental assistance will terminate at the end of the grant period in which the deceased member was a participant.)

54 Developmental Disability Definition 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. An individual from birth to age 9, inclusive, who has a substantial developmental delay or specific congenital or acquired condition, may be considered to have a developmental disability without meeting three or more of the criteria above if the individual, without services and supports, has a high probability of meeting those criteria later in life.

55 Persons with Disabilities Eligibility The following project types must serve persons who are disabled: Permanent Supportive Housing Safe Havens Samaritan Bonus or Chronic Homeless projects

56 Persons with Disabilities Eligibility The following project types MAY serve people with disabilities: Rapid rehousing Transitional housing Supportive services only

57 Persons with Disabilities Documentation Requirements Disability Required documentation of disability. You Need One (1) Document for the File ONE of the following: Written verification of the disability from a professional licensed by the state to diagnose and treat the disability and his or her certification that: The person has a disability (according to the previously provided definition); The disability is expected to be long-continuing or of an indefinite duration; and, The disability substantially impedes the individual s ability to live independently; OR, Written verification from the Social Security Administration; The receipt of a disability check (e.g., Social Security Disability Insurance or Veteran Disability Compensation); Intake staff-recorded observation of disability that, no later than 45 days of the application for homeless assistance, is confirmed and accompanied by the evidence described above; or, Other documentation approved by HUD.

58 Consider Wilma Flintstone presents at your permanent supportive housing project. She tells you she has been living in her car for almost a year and that she is a regular heroin user. - What type of documentation do you need to determine whether she is eligible for your program? - How will you attempt to document her homelessness? - May you serve Wilma if she presented at your rapid rehousing project?

59 Section 2B: Chronic Homelessness

60 Chronic Homelessness Definition 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; 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.

61 Chronic Homelessness Definition of an Episode of Homeless An episode of homelessness is a separate, distinct, and sustained stay on the streets and/or in an emergency homeless shelter. The current applicable statutes, regulations, and NOFA Competitions do not define sustained, and so you should use the common definition of the word (i.e., continued ) read in context with separate and distinct.

62 Chronic Homelessness Eligibility All project types may serve chronically homeless individuals and families, but some MUST serve chronically homeless people if stated in their grant agreement.

63 Chronic Homelessness Documentation Requirements 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: n Evidence that the homeless occasion was continuous for at least one year [Component B(1)]; or, n 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.

64 Component A(1): Homeless Status (Place Not Meant for Human Habitation) Documentation Requirements Subcategory A(1) An individual who is homeless and lives in a place not meant for human habitation. You Need One (1) Document for the File ONE of the following: Written observation by an outreach worker of the conditions where the individual or family was living; Written referral by another housing or service provider; or, Certification by the individual or head of household seeking assistance.

65 Component A(2): Homeless Status (Institutions) Documentation Requirements Component A(2) An individual who is exiting an institution where (s)he has resided for 90 days or less and who resided in an emergency shelter or place not meant for human habitation immediately before entering that institution You Need Three (3) Documents for the File ONE of the following: Written observation by an outreach worker of the conditions where the individual or family was living; Written referral by another housing or service provider; or, Certification by the individual or head of household seeking assistance. PLUS ONE of the following: Discharge paperwork or a written or oral referral from a social worker, case manager, or other appropriate official of the institution stating the beginning and end dates of residency. All oral statements must be recorded by the intake worker; or, If evidence described above isn t obtainable, a written record of the intake worker s due diligence in attempting to obtain that evidence PLUS a certification by the individual seeking assistance that states (s)he is exiting or has just exited an institution where (s)he has resided for 90 days or less. PLUS evidence that the individual was homeless and living in a place not meant for human habitation, a safe haven, or in an emergency shelter, and met the criteria of chronic homelessness immediately prior to entry into the institutional care facility.

66 Component B(1): Duration (Continuous for One Year) Documentation Requirements Component B(1) An individual who 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. You Need Two (2) Documents for the File ONE of the following providing evidence that the homeless occasion was continuous, for a year period, without a break (i.e., seven or more continuous nights in place meant for human habitation) in living or residing in a place not meant for human habitation, a safe haven, or in an emergency shelter: Written observation by an outreach worker of the conditions where the individual or family was living; Written referral by another housing or service provider; or, Certification by the individual or head of household seeking assistance. PLUS at least nine (9) months of the 1-year period must be documented by ONE of the following: HMIS data; A written referral; or, A written observation by an outreach worker. In RARE AND EXTREME CIRCUMSTANCES, HUD would allow a certification from the individual or head of household seeking assistance in place of third-party documentation for up to the entire period of homelessness. Where third-party documentation could not be obtained, the intake worker must obtain a certification from the individual or head of household seeking assistance, and evidence of the efforts made to obtain third-party evidence as well as documentation of the severity of the situation in which the individual or head of household has been living.

67 Component B(2): Duration (Four Occasions in Three Years) Documentation Requirements Component B(2) An individual who 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 on at least four separate occasions in the last 3 years. You Need Two (2) Documents for the File ONE of the following providing evidence that the head of household experienced at least four separate occasions of homelessness in the past three years: Written observation by an outreach worker of the conditions where the individual or family was living; Written referral by another housing or service provider; or, Certification by the individual or head of household seeking assistance. PLUS at least three occasions must be documented by ONE of the following (any other occasion may be documented by a self-certification with no other supporting documentation): HMIS data; A written referral; or, A written observation by an outreach worker. In RARE AND EXTREME CIRCUMSTANCES, HUD will allow a certification from the individual or head of household seeking assistance in place of third-party documentation for the three occasions above. Where third-party documentation could not be obtained, the intake worker must obtain a certification from the individual or head of household seeking assistance, and evidence of the efforts made to obtain third-party evidence as well as documentation of the severity of the situation in which the individual or head of household has been living.

68 Component C: Disability Documentation Requirements Component C An individual who 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. You Need One (1) Document for the File ONE of the following: Written verification of the disability from a professional licensed by the state to diagnose and treat the disability and his or her certification that: The person has a disability (according to the previously provided definition); The disability is expected to be long-continuing or of an indefinite duration; and, The disability substantially impedes the individual s ability to live independently; OR, Written verification from the Social Security Administration; The receipt of a disability check (e.g., Social Security Disability Insurance or Veteran Disability Compensation); Intake staff-recorded observation of disability that, no later than 45 days of the application for homeless assistance, is confirmed and accompanied by the evidence described above; or, Other documentation approved by HUD.

69 Consider Barney Rubble presents at your Samaritan bonus permanent 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. Barney 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?

70 Section 3: Tips and Tricks

71 Tips and Tricks for Eligibility Documentation Tips and tricks for eligibility documentation include: Common Mistake: Persons Who Are Not Homeless Timing is Everything Be Detailed and Organized Relative Strength of Documentation What if Documentation is Not Compliant? What if a Current Client is Ineligible?

72 Common Mistakes: People Who Are Not Homeless People in the following situations are not homeless according to the HUD definition and CANNOT be served by programs utilizing CoC funding: People who are in housing, even if: They are paying an excessive amount for that housing; The housing is substandard and in need of repair; or, The housing is crowded; People who are currently incarcerated; People who are currently living with family or friends; People who are living in a Board and Care, an Adult Congregate Living Facility, or similar place; People who are being discharged from an institution after a stay of 90 consecutive days or more; or, People utilizing Housing Choice Vouchers, except Katrina evacuees that received Katrina Disaster Housing Assistance Program (KDHAP) Housing Choice Vouchers.

73 Timing is Everything Document where a client was living at all times including shelter stays and the time in between. Focus especially on where a client stayed the night before entry into the program. If your program requires that persons served have a disability, remember that the client must be disabled at the time (s)he enters your program.

74 Be Detailed and Organized Include as much detail as possible regarding all aspects of documentation. Rely on self-certification only as a last resort; where that s necessary, be sure to generate as much background information as possible, including documentation of the efforts made by intake workers to verify the contents of the self-certification with third parties. Eliminate all gaps in content/timeline between case management assessment and move-in. Organize client files in a thorough and simple manner so that any reviewer has an easy time understanding what is and is not contained in the files.

75 Relative Strength of Documentation You should document homelessness and disability in the following manner, utilizing lower strength documentation only where necessary: Third-party written certification (strongest documentation) Third-party oral certification Observations by program staff Self-certification (weakest documentation)

76 What if Documentation is Not Compliant? If you discover compliance issues in your eligibility documentation: Develop a plan to bring the program into compliance. Backfill documentation regarding homelessness and disability (if necessary) for as many active clients as possible. With careful planning, admit the mistake to HUD and present them with the plan you have developed, the corrective actions you have taken, and your future processes to prevent a reoccurrence of these issues.

77 What if a Current Client is Ineligible? If you discover that a client that is currently being served is ineligible to receive homeless assistance utilizing CoC funding: Work with the individual to come up with an alternate plan to transition the client out of the program. Clean up documentation to the extent possible (will probably require interviewing clients). With careful planning, admit the mistake to HUD and present them with the plan you have developed in conjunction with the client to transition that person out of the program.

78 Wrap Up

79 See you soon!