HPRP FREQUENTLY ASKED QUESTIONS (FAQS)

Transcription

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

22 FAQ ID: 1333 How are federal and state tax refunds treated when determining income? Should federal and state tax refunds be considered when reviewing assets? Federal and state tax refunds must not be counted as additional sources of income when calculating annual income to determine a household's eligibility or need for assistance under HPRP. In addition, if Federal tax refunds received within the previous 12 months make up part of a household's cash assets, that part of the household's cash assets must not be counted among the household's financial resources when determining the household's eligibility or need for assistance under HPRP. See "Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010," Pub. L. No ,? 728, 124 Stat. 3296, For example, if a household applying for HPRP assistance in July 2011 has $2000 in total assets that includes a $500 federal income tax refund received in April 2011, no more than $1500 of the household's total assets may be considered when determining whether the household has the financial resources and support networks needed to obtain immediate housing or remain in its existing housing or when determining the amount or type of assistance that household needs. This exclusion does not apply to Federal tax refunds received prior to the previous 12 months or state tax refunds. If those tax refunds make up part of a household's cash assets, they are treated the same as the other cash assets. In determining HPRP eligibility, the recipient or subrecipient must determine, among other things, whether the applicant lacks the financial resources and support networks needed to obtain immediate housing or remain in its existing housing. However, HUD has not established specific requirements regarding what amount or types of assets should be considered in determining an applicant's financial resources. Instead, each grantee should establish and implement its own policy on the amount and types of assets that should be considered when determining whether a household has the financial resources and support networks needed to obtain immediate housing or remain in its existing housing. For further information, see HPRP Eligibility Determination and Documentation Guidance. Date Published: 7/1/2011 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 1335 Is HPRP assistance treated as income under the SSI program? The Social Security Administration has determined that HPRP assistance must be treated as unearned income for purposes of SSI-- it is not an exclusion. If HPRP funds are used to pay a utility company or rent to a landlord on behalf of an SSI beneficiary, SSI benefits will be reduced. Under SSI regulations, this reduction is capped at onethird of the Federal Benefit Rate which, in 2011, is $674/month for a cap of $244.66/month. For example, if HPRP paid $600 per month in 2011 for an SSI beneficiary's rent, the SSI benefit amount would be reduced by $ per month. HPRP FAQs 21 June 2013

23 For the SSA guidance on this issue, go to: Date Published: 7/1/2011 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 1850 Will the changes in the definition of "homeless" and "at risk of becoming homeless" under the Final Rule of the HEARTH Act carry over to current HPRP activities? No. The changes in the definition of "homeless" and "at risk of becoming homeless" under the Final Rule of the HEARTH Act only apply to the Continuum of Care programs and the Emergency Solutions Grants program. Under HPRP, the terms "homeless" and "at risk of becoming homeless" will continue to be defined as they were when the HPRP Notice was issued in Date Published: 12/8/2011 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility FAQ ID: 720 Can grantees provide utility-only assistance? What is the qualifying hardship? And what type of documentation is required in such instances? Grantees can provide utility-only assistance, but HUD expects that this will be rare. First, there are laws governing public utilities in many states that prevent utility companies from shutting off power to a unit during winter months, and which may also require the utility company to offer payment plans to households that miss payments. Second, staff must confirm that no other utility assistance, such as LIHEAP, is available to prevent the shut-off. If neither of these conditions exist, however, utility-only assistance may be justified under a couple of different scenarios. First, if utilities are shut off during winter months, this can result in a dangerous situation for the occupants. If the household is going to have to abandon the housing due to a lack of utilities and can avoid moving to a shelter by having utilities paid, then HPRP funds may be used for this purpose. Under another scenario, an applicant's lease may include a provision requiring utilities be maintained for the unit by the tenant. As a result, a utility shut-off could constitute a lease violation, thus placing the household at risk for eviction. In both cases, it is the grantee or subgrantee's responsibility to confirm and document in the case file that the utility company will in fact shut-off the utility if the amount due is not paid. If the household is going to have to leave the housing due to a lack of utilities, can avoid literal homelessness by having utilities paid, and meets other HPRP eligibility requirements, then a household may be assisted under the Homelessness Prevention category with utility-only assistance. With regard to documentation, a copy of a utility shut-off notice or arrears statement is not sufficient by itself to document program eligibility. In addition to documenting, via an assessment, that the household has no other HPRP FAQs 22 June 2013

24 financial resources, support networks, or other housing options, grantees/subgrantees must also assess and document that a household with a utility shut-off notice will become literally homeless but for HPRP assistance. In practical terms, this means that HPRP staff must assess whether the household will lose their housing if the utility is shut-off (i.e., it will constitute a lease violation causing lease termination and/or will cause housing to be unfit for human habitation). HPRP staff should attempt to obtain a copy of the participant's lease and highlight the provision related to utility obligations and consequences. If unable to obtain a lease, HPRP staff should assess and record such circumstances in the HPRP participant case file. As with other HPRP eligibility documentation, HPRP staff must first attempt to obtain third-party verification. Participant self-declaration is only acceptable if third-party documentation cannot be obtained. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Eligible Activities/Costs - Financial Assistance FAQ ID: 874 If a client has an eviction notice, no or very low income, and no support networks, financial resources, or subsequent housing options, can an agency provide both rent and utility assistance in cases where the client does not have a utility shut-off notice? Or is a shut-off notice always required to provide utility assistance? An agency can provide both rent and utility assistance since eligibility and need has already been established. HPRP is designed to prevent homelessness, so once an applicant has been determined at imminent risk (because of the eviction notice) and meets all other eligibility criteria (at/below 50% AMI and lacks other resources, support networks, and housing options), it would be appropriate to identify an assistance plan that includes payment of both rent and utilities. However, grantees must be sure to include documentation in the case file (i.e., case notes) why payment of the utilities is necessary - which may be that the household has no resources to pay utilities, and/or any existing income must be used for other household needs - e.g., food. It is reasonable that utilities would be paid even in the absence of a shut-off notice given the other conditions presented (eviction notice, no income, etc.) and that payment of utilities will help achieve the goal of stabilizing the household. Please note that this situation is different from cases where a grantee may be considering utility-only assistance. Providing utility-only assistance requires a different level of documentation, since grantees must establish why the household is at imminent risk of homelessness if they do not receive the assistance. Please see the related FAQ for additional information on providing utility-only assistance. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Eligible Activities/Costs - Financial Assistance FAQ ID: 568 Not all households assessed under HPRP will be eligible for assistance. Is the time spent assessing such households an eligible expense? (REVISED; Originally posted 8/14/2009) HPRP FAQs 23 June 2013

25 Yes. Time spent assessing any household, whether or not the household ultimately turns out to be eligible for assistance, is an eligible expense. Time spent assessing a household may be charged to either Case Management or Outreach and Engagement under Housing Relocation and Stabilization Services. Date Published: 10/11/2011 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 883 Is a person eligible to receive HPRP assistance if he/she currently has a home, but the home was damaged during a hurricane or other nature disaster and will be rehabilitated with Federal funding? During the rehabilitation period, the homeowner will be required to move out of the home, but cannot afford to pay moving or rental expenses. Often, homeowners insurance will cover temporary housing while a home is being repaired/rehabilitated. If the household has no insurance, if the home is not suitable for human habitation, if the household meets all HPRP eligibility criteria (including being at or below 50% AMI and lacking subsequent housing options/financial resources/support networks), AND if HPRP is a last resort to prevent them from becoming homeless, the household could receive assistance to temporarily relocate them to more suitable housing. The HPRP assistance may include financial assistance and housing relocation and stabilization services. The grantee/subgrantee is responsible for ensuring that the household has exhausted all of the other resources available to people in a Federal disaster area, including FEMA or HUD assistance. The grantee must be able to document that the household has applied for benefits available to people in Federally-declared disaster areas. Keep in mind that case managers must assess and document the financial resources, support networks, and other housing options available to the household as they must do for all applicants. See HUD's HPRP Eligibility Determination and Documentation Guidance for more information. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Eligible Activities/Costs - Housing Relocation and Stabilization Services, Eligible Activities/Costs - Financial Assistance, Eligible Participants (Clients) FAQ ID: 397 Who can receive HPRP assistance? There are two populations of persons facing housing instability that are eligible to receive HPRP assistance: 1) individuals and families who are currently housed but are at risk of becoming homeless and need temporary assistance to prevent them from losing their housing or to help them relocate to a more stable housing situation (classified as prevention assistance); and 2) individuals and families who are literally homeless (per HUD's HPRP FAQs 24 June 2013

26 definition, as defined in the HPRP Notice) and need temporary assistance in order to obtain housing (classified as rapid re-housing assistance). With the exception of legal services (see related FAQ on legal services), the type of assistance available under each category is exactly the same. In order to receive HPRP assistance, each household must meet the minimum eligibility requirements as set forth by HUD. Though grantees can impose additional eligibility requirements, there are three Federal eligibility criteria for receipt of HPRP assistance: 1) The household must have at least an initial consultation with a case manager or other authorized representative who can determine the appropriate type of assistance to meet their needs. 2) The household must be at or below 50 percent of Area Median Income (AMI). 3) The household must be either homeless or at risk of losing its housing and meet both of the following circumstances: (a) no appropriate subsequent housing options have been identified; AND (b) the household lacks the financial resources and support networks needed to obtain immediate housing or remain in its existing housing. For additional information on program eligibility requirements, please refer to HUD's HPRP Eligibility Determination and Documentation Guidance. Date Published: 3/20/2009 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Eligible Participants (Clients) FAQ ID: 410 As a grantee, can I establish more strict requirements than HUD has established? Yes. HUD is providing grantees with discretion to establish requirements that further target community needs. Grantees may elect to implement more stringent targeting and/or eligibility requirements as long as all program participants meet the minimum eligibility criteria and the grantees comply with all local and federal requirements. For example, grantees may set limits on the amount of assistance any household may receive, may pay for only a portion of a program participant's rent, may require participants be at 30% or less of Area Median Income (AMI) or may require participants have additional risk factors. Date Published: 3/20/2009 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Eligible Participants (Clients) FAQ ID: 703 How is a household defined for purposes of HPRP? Under the HPRP program, a household is a single individual or group of persons who together apply to an HPRPfunded program for assistance and together meet the conditions outlined in the HPRP Notice for eligible program HPRP FAQs 25 June 2013

27 participants. Note that if two unrelated individuals are joint parties to a lease, a grantee must consider total household income to determine eligibility (i.e., either the whole household is eligible for assistance, or the whole household is not). Date Published: 1/6/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Eligible Participants (Clients) FAQ ID: 706 Can HPRP funds be used to assist illegal aliens? If so, what type of identification documentation is acceptable? In accordance with Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, an alien (a person who is not a U.S. citizen or national) may be eligible for assistance under HPRP only if he or she is a 'qualified alien' (defined in 8 U.S.C. 1641). This means that no entity that receives funds under HPRP may knowingly provide HPRP assistance to an alien who is not a qualified alien. The law requires all state and local governments that directly administer HPRP assistance to first verify that an alien is a qualified alien before using HPRP funds to assist him or her. Nonprofit organizations that administer HPRP assistance are not required, but may, verify that an alien is a qualified alien in order to provide him or her with HPRP assistance. However, if a nonprofit organization pursues verification, it must follow the requirements set forth in the interim guidance published by the Department of Justice. For more information on these requirements (including documentation), see the 'Interim Guidance on Verification of Citizenship, Qualified Alien Status, and Eligibility under Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996,' 63 Federal Register (Nov. 17, 1997), available at (Select 1997 Federal Register and search for page Scroll down through the list provided to find 'Interim Guidance of Verification of Citizenship, Qualified Alien.') Grantees/subgrantees with additional questions are encouraged to contact their local US Citizenship and Immigration Services (USCIS) office. An office locator is available at Date Published: 1/6/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Eligible Participants (Clients) FAQ ID: 869 Is an applicant required to have income to be eligible for HPRP assistance? In the HPRP Notice, HUD emphasizes that HPRP assistance is temporary, and that communities should target the funds to households who are most likely to be able to maintain their housing once HPRP assistance ends. Also, are households with very high barriers appropriate for HPRP assistance? (REVISED; Originally posted 7/20/2010) HPRP FAQs 26 June 2013

28 Providing proof of earned income or the ability to sustain housing when HPRP assistance ends is not an eligibility requirement for HPRP. Although the HPRP Notice does emphasize that HPRP assistance is temporary, it also states that the intent of the assistance is to rapidly transition homeless or nearly homeless program participants to stability, either through their own means or through public assistance. This program is a unique and limited resource for communities to reduce and end homelessness. Communities that are only serving persons who already have a job or can demonstrate that they will be stably housed at the end of the temporary assistance are missing an opportunity to assist homeless households for whom HPRP could be the key to future stability. Grantees and subgrantees may consider how a household's barriers may affect their ability to achieve stable housing (unsubsidized or subsidized) once the assistance ends. However, HUD cautions grantees against creating barriers for persons in need of this assistance, or putting in place criteria that are so strict that they cannot find households to serve. Instead, case managers should be fully assessing each client's situation (housing history, employment history/prospects, financial situation, etc.) and establishing a service plan that will help them become stabilized during the term of assistance. There are many different paths to stability. For example, an individual might obtain employment or financial assistance (such as Unemployment Compensation or Supplemental Security Income) while receiving HPRP assistance. Likewise, experienced Rapid Re-Housing staff report that households with the highest barriers often recognize their vulnerability and can be the most motivated to succeed. With stable housing as a base, people can then turn to other meaningful life goals. While stable housing does not assure success, lack of stable housing often results in escalating crises and greatly increases the odds of failure. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Eligible Participants (Clients) FAQ ID: 870 Is an applicant that has been sanctioned by another Federal housing subsidy or income support program eligible for HPRP assistance? What about an applicant that owes back taxes? As long as the applicant meets all HPRP eligibility requirements, the applicant is eligible to receive HPRP assistance. The HPRP Notice does not prohibit grantees or subgrantees from serving persons who have been sanctioned by another Federal source of income support or that owe back taxes. HPRP cannot be used to pay the back taxes or fees associated with sanctions. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Eligible Participants (Clients) FAQ ID: 881 Is a person living in a hotel eligible for assistance? If so, would they be served under the Prevention or Rapid Re- Housing category? HPRP FAQs 27 June 2013

29 As long as the applicant meets the program eligibility criteria (i.e., at or below 50% AMI, homeless or at risk of losing their housing, and no other housing options, financial resources, or support networks), he/should would be eligible for assistance. The appropriate category of assistance depends on the specific situation. Some communities use motels as overflow emergency shelters, especially in the winter. Thus, if the client has a motel voucher from a homeless services provider, he/she would be considered literally homeless and would be served under the rapid re-housing category (since the client meets the HUD homeless definition). However, if the client was paying for the room on his/her own but was at risk of losing the housing, the client would be classified as at imminent risk and would be served under the prevention category. Note that if a prevention client was being assisted to remain in a hotel or motel, grantees and subgrantees must ensure that there is a rental or occupancy agreement in place, that the unit meets rent reasonableness standards, leadbased paint standards (as applicable), and that the unit is appropriate for permanent housing (i.e., it has a kitchen, adequate living space, etc.). Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Eligible Participants (Clients) FAQ ID: 889 For HPRP assistance, what forms of identification are acceptable? Must each adult member of the household show picture ID? HUD does not require a picture ID to receive HPRP assistance, but remember that HPRP funds may only be used to assist persons deemed eligible by the grantee/sub-grantee. It is the responsibility of the grantee/sub-grantee to conduct due diligence to ensure that persons served are eligible and to establish policies with regard to identification. This is critical in order to prevent fraud or abuse of the program. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Eligible Participants (Clients) FAQ ID: 1243 How does HUD define "high overcrowding"? At what point does overcrowding make a unit uninhabitable? 'High overcrowding' is listed as a risk factor on page 25 HPRP Notice. However, risk factors are not equivalent to eligibility criteria; rather, they are examples of things grantees may want to consider to help better target funds. As always, providers must ask, "Will this applicant become homeless 'but for' (if they do not receive) this assistance?" In some cases, families can stay in an 'overcrowded' situation until they can move into a unit on their own with no HPRP FAQs 28 June 2013

30 assistance. In other cases, staying with a family or friend is unsafe and/or unsustainable and will likely result in one or more of the families being evicted and becoming homeless. In other words, "high overcrowding" is not a hard and fast rule, and as such, no definition standard definition can be provided. However, as explained in a separate FAQ, households receiving HPRP financial assistance and moving into a different unit must be afforded adequate space and security for themselves and their belongings and an acceptable place to sleep (per the habitability requirements). Consequently, "high overcrowding" may be considered situations where the number of persons exceeds health and/or safety standards for the housing unit size. To help determine if a household is at imminent risk of homelessness due to overcrowding, grantees may wish to consider the following questions: 1) Is the situation in violation of state or local occupancy standards? 2) Is the situation causing a lease violation? 3) Are health and/or safety standards compromised? As always, it is up to the judgment of the case manager to assess the applicant's situation and determine the level of risk presented by the situation. As always, case managers should document their decision/rationale in the case file via case notes (and any supporting documentation, as applicable). Date Published: 12/27/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Eligible Participants (Clients) FAQ ID: 694 What is the HPRP Staff Certification of Eligibility and who must sign it? The Staff Certification of Eligibility (previously referred to as the Staff Affidavit) certifies that the HPRP household meets all eligibility criteria for HPRP assistance, certifies that true and complete information was used to determine eligibility, and certifies that no conflict of interest exists related to the provision of the assistance. The Staff Certification must be completed and signed by the person determining eligibility and his or her supervisor for all households determined eligible on or after November 1, A new Staff Certification is only required to be completed if a different staff person re-determines eligibility at a later date. For example, if an intake worker makes the initial determination of eligibility on November 15th, the Staff Certification must be signed by the intake worker and his/her supervisor. If the household's eligibility is then recertified three months later by a case manager (not the same person as the intake worker), a new Staff Certification signed by the case manager and his/her supervisor would be required. However, if the same individual recertifies the household, he/she would not need to complete an additional Staff Certification form. Assuming the grantee is not administering funds directly, the grantee does not need to sign the Staff Certification. However, when grantees conduct periodic monitoring of subgrantees, they should ensure that signed forms appear in approved program participants' case files. Date Published: 10/29/2009 HPRP FAQs 29 June 2013

31 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Grants Management and Monitoring FAQ ID: 695 Why is HUD making HPRP grantees sign the Staff Certification of Eligibility? The HPRP Staff Certification of Eligibility (formerly referred to as the Staff Affidavit) was established in response to a real instance of fraud that occurred early in the implementation of HPRP. It is intended to protect HUD and grantees against fraud and abuse charges. The Staff Certification serves to remind HPRP program staff that they are legally bound to determine and document the eligibility of applicants according to HPRP requirements before providing assistance. Use of the form will be reviewed by HUD as part of the monitoring process. Date Published: 10/29/2009 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Grants Management and Monitoring FAQ ID: 696 Is the Staff Certification of Eligibility required only when financial assistance is being provided? No the Staff Certification of Eligibility (formerly referred to as the Staff Affidavit) must be used regardless of whether the household is receiving financial assistance or housing relocation and stabilization services. Both represent an expenditure of HPRP grant funds for eligible households. Date Published: 10/29/2009 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Grants Management and Monitoring FAQ ID: 717 When completing the Staff Certification of Eligibility, is a case manager required to determine if the applicant has a familial connection to any grantee or subgrantee staff? If an individual seeking assistance is related to a grantee or subgrantee staff member, is he/she automatically disqualified? A familial connection between an applicant and a staff member of the grantee or subgrantee agency does not necessarily mean that there is a conflict of interest, and it would not automatically disqualify him/her from receiving assistance. It does, however, disqualify the related staff member from doing the eligibility determination. The goal of the Staff Certification of Eligibility (previously referred to as the Staff Affidavit) is to affirm that there is no conflict of interest between the HPRP staff member conducting the eligibility determination, his/her supervisor, and the household applying for HPRP assistance, to ensure that the program participant is eligible and there is no fraud occurring. HPRP FAQs 30 June 2013

32 Date Published: 1/6/2010 Topic: HPRP; Subtopic: Determining and Documenting Client Eligibility, Grants Management and Monitoring FAQ ID: 417 What costs are eligible pre-award costs? Must these be pre-approved? Can housing inspections be considered a preaward cost? (REVISED) Grantees may incur eligible pre-award costs, which are limited to administrative costs. These costs must be directly related to preparing the application for submission to HUD, for the period of time between the publication of the Notice on March 19, 2009 through the execution of the grant agreement between HUD and the grantee. This includes, but is not limited to, staff costs for preparing the substantial amendment, other costs related to the public comment process, hiring a consultant for preparation of the Substantial Amendment, and attending HUD-sponsored HPRP meetings and trainings. Note that costs related to the provision of financial assistance, including housing inspections, and housing relocation and stabilization services are not considered administrative costs, and therefore, are not eligible pre-award costs. Date Published: 4/24/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Administrative Costs FAQ ID: 418 Are there any notification requirements to HUD if jurisdictions wish to exercise the option of incurring pre-award administrative expenses? There are no notification requirements. Grantees, however, must make sure that the pre-award costs are eligible and, of course, maintain documentation of all expenses. If a grantee has questions about any costs, it should contact its local HUD field office to verify whether they are eligible. Date Published: 4/3/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Administrative Costs FAQ ID: 456 Is it true that administrative costs may not be used for staff engaged in the general administration of the program (e.g., bookkeeping costs)? (REVISED) HPRP FAQs 31 June 2013

33 HUD's policy for eligible administrative activities limits the costs to the items listed in Section IV.A.4 of the Notice because administrative funds are statutorily limited to 5% of the total grant. Bookkeeping costs may be charged under administration, financial assistance, or housing relocation and stabilization services depending on the type of activity being conducted by the bookkeeper. For example, costs for a bookkeeper to pay for rental assistance, security deposits, etc., are allowable under the category of Financial Assistance because it is directly related to the delivery of financial assistance. The costs for the bookkeeper to pay the for salaries of case managers is a payroll function and, as such, is an administrative cost. Therefore, grantees need to break out the bookkeeper's time based on the activities performed (i.e., the delivery of direct service activities or administrative activities). Date Published: 5/20/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Administrative Costs FAQ ID: 457 In the Notice, HUD states that administrative costs includes training 'case managers who will serve program participants, as long as this training is directly related to learning about HPRP.' Does such training include case management skills to provide services in rapid re-housing programs or training in other skills critical to homelessness prevention, such as the skills necessary to connect HPRP participants to mainstream programs offering employment services? (REVISED) General training for case manager to enhance their ability to provide services, counseling, or linkages with other programs even Recovery Act programs is NOT an eligible cost. These are considered general skills that a case manager would need in order to do their job, regardless of HPRP. HUD's intent is to allow persons providing services or administering the local HPRP program to attend training provided by HUD, the grantee, an authorized HPRP technical assistance provider or other HPRP training held in partnership with HUD in order to learn about HPRP eligible activities, eligible participants, and other requirements, and intent of HPRP. Training on the specific policies and procedures of a grantee's HPRP program may also be an eligible expense, but general training on rapid re-housing or homelessness prevention programs is not. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Administrative Costs FAQ ID: 463 Is the grantee required to share administrative funds with subgrantees? If so, are there guidelines for determining what constitutes a 'reasonable and appropriate amount'? Yes, grantees are required to share administrative funds with their subgrantees. HUD has not defined 'reasonable share,' however, grantees should consider their fixed and variable costs related to conducting the eligible HPRP FAQs 32 June 2013

34 administrative functions when calculating the amount to be retained by the grantee and the amount to be shared with subgrantees. Date Published: 4/24/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Administrative Costs FAQ ID: 499 Can HPRP funds be used as match for SHP? HPRP may be used to match activities under SHP that are also eligible under HPRP. This would include services related to rapid re-housing of homeless persons, for example. It would not include operating costs associated with a transitional housing facility since operating a transitional housing facility is not eligible under HPRP. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Administrative Costs FAQ ID: 506 Can HPRP administrative funds be used to fund general CoC staff positions? HPRP administrative funds may be used for the administration of HPRP grants only. General CoC operations are not eligible costs under HPRP. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Administrative Costs FAQ ID: 1330 Are interest charges on a Line of Credit eligible HPRP costs? Grantees and subgrantees may consider negotiating local "lines of credit" to help address the challenges of managing cash flow. When using lines of credit-- or relying on other local discretionary funds-- to maintain cash flow on HPRP programs, keep in mind that interest payments are NOT an eligible HPRP expense. Date Published: 7/1/2011 Topic: HPRP; Subtopic: Eligible Activities/Costs - Administrative Costs HPRP FAQs 33 June 2013

35 FAQ ID: 405 What are the eligible categories for activities under the HPRP? There are four categories of activities eligible as HPRP expenditures: financial assistance, housing relocation and stabilization services, data collection and evaluation, and administrative costs. Date Published: 3/20/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Administrative Costs, Eligible Activities/Costs - Data Collection and Evaluation, Eligible Activities/Costs - Housing Relocation and Stabilization Services, Eligible Activities/Costs - Financial Assistance FAQ ID: 862 Are an agency's indirect costs eligible under HPRP? HPRP grant funds may be used to pay indirect costs in accordance with OMB Circular A-87 or A-122, as applicable. Indirect costs may be allocated to each eligible HPRP activity, including grant administration, so long as that allocation is consistent with an indirect cost proposal developed in accordance with OMB Circular A-122 (for nonprofit organizations) or OMB Circular A-87 (for local governments). Note that an indirect cost proposal developed by a non-profit organization must be submitted to its cognizant agency for negotiation of an indirect cost rate as required by OMB Circular A-122. Indirect cost proposals developed by a governmental grantee must be retained for audit in accordance with the records retention requirements contained in 24 CFR part 85 and must be submitted to its cognizant agency for negotiation of an indirect cost rate when required by OMB Circular A-87. The total grant administration costs charged to the grant, including both direct and indirect costs, must not exceed 5% of the grantee's total HPRP grant amount. In the event that an organization does not have an approved indirect cost rate, and it is not feasible to establish one, granteees/subgrantees may direct charge a reasonable proportion of their indirect costs to the activity with which the cost is associated. For example, if an HPRP subgrantee employs ten staff, four of which work full time on HPRP case management and service activities, the subgrantee could charge 40% of their monthly office lease/rent costs to the Housing Relocation and Stabilization Services category. As always, the grantee or subgrantee's plan for directcharging indirect costs must be reasonable and supported by documentation. Supporting documentation should show that costs charged were incurred during the effective period of the grantee's agreement with HUD (or subgrantee's agreement with the grantee), the costs were actually paid out (or properly accrued), were expended on allowable items, and had been approved by the responsible official in the organization. This guidance permits the charging of indirect costs incurred since the inception of a grantee's program, if the grantee has not already charged those costs. Grantees that have already charged indirect costs are not required to make changes or modifications to charges previously made, but should make changes moving forward to ensure they are in compliance with the guidance outlined above. HPRP FAQs 34 June 2013

36 HUD expects that many grantees will have budget changes as a result of this indirect cost guidance. HPRP grantees may adjust budgeted amounts for eligible activities by amending their Substantial Amendment. As explained in the HPRP FAQs, the Consolidated Plan regulations require grantees to establish criteria in their Citizen Participation Plan for what constitutes a Substantial Amendment to its Consolidated Plan. Under some plans, any changes over a certain amount Date Published: 7/13/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Administrative Costs, Eligible Activities/Costs - Data Collection and Evaluation, Eligible Activities/Costs - Housing Relocation and Stabilization Services, Eligible Activities/Costs - Financial Assistance, Grants Management an FAQ ID: 1237 Can subgrantees and service providers participating in a grantee's HPRP program charge a 'fee for service' as an alternative to charging indirect costs? It is up to HPRP grantees to determine whether they will allow this alternative. HUD requires only that fee-forservice charges be reasonable, well documented, and in compliance with the OMB Circular A-87 guidance, which states: "Federal agencies should work with States or localities which wish to test alternative mechanisms for paying costs for administering Federal programs. The Office of Management and Budget (OMB) encourages Federal agencies to test fee for service alternatives as a replacement for current cost reimbursement payment methods in response to the National Performance Review's (NPR) recommendation. The NPR recommended the fee for service approach to reduce the burden associated with maintaining systems for charging administrative costs to Federal programs and preparing and approving cost allocation plans. This approach should also increase incentives for administrative efficiencies and improve outcomes." If a grantee elects to use this alternative, it must maintain documentation to support the fee being charged and the costs associated with service delivery. Date Published: 12/17/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Administrative Costs, Eligible Activities/Costs - Data Collection and Evaluation, Eligible Activities/Costs - Housing Relocation and Stabilization Services, Eligible Activities/Costs - Financial Assistance, Grants Management an FAQ ID: 507 Under HPRP, is case management considered an eligible cost under the administrative category? Case management expenses must be charged under the Housing Stabilization and Relocation Services category and are not eligible under the Administrative cost category. HPRP FAQs 35 June 2013

37 Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Administrative Costs, Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 439 It states in the HPRP Notice that for HMIS, funds can be used for Data Collection and Evaluation costs, but is limited to jurisdictions that do not have an HMIS already implemented. How does this address the cost of data entry for existing HMIS users? And, if a new subgrantee receives HPRP funds but does not currently use HMIS, can HPRP funds be used to pay for their training, computer equipment, and other associated costs, including access to DSL? There are five eligible HMIS cost categories for HPRP, which would fall under Data Collection and Evaluation: (1) Equipment. Leasing or purchase of hardware (computers, servers, printers), networking, and security; (2) Software. User licensing for existing HMIS software, purchase of HMIS software (only if CoC does not have an HMIS and with HUD Headquarters approval), support and maintenance, tools that support existing software, and participation fees; (3) Services. Third-party training, technical services, programming (customization, system interface, data conversion), connectivity, disaster and recovery, and data integration support; (4) Personnel. System administrators, trainers, technical staff, and data entry, analysis, and programming support; and (5) HMIS space and operations. Grantees that are the HMIS administering agency and/or will be providing services directly to HPRP participants may use HPRP funds to expand the scope of the HMIS for data collection and reporting for HPRP. Grantees that do not administer the HMIS or will not be providing direct service may provide funds to the HMIS administering agency to allow the HMIS to expand the scope of the HMIS. A subgrantee may use HPRP funds to fund activities necessary for the organization to implement the HPRP data collection and reporting requirements in the CoC's HMIS. Date Published: 4/3/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Data Collection and Evaluation FAQ ID: 729 Can HPRP Data Collection and Evaluation funds be used for travel to attend HUD's national HMIS training conference? Yes, HPRP Data Collection and Evaluation funds can be used for expenses related to attending HUD's national HMIS training conference. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Data Collection and Evaluation HPRP FAQs 36 June 2013

38 FAQ ID: 1334 Will outcomes from the HPRP program affect our Continuum of Care scores? No. Although the Continuum of Care Exhibit 1 application may ask about uses of HPRP in the community, HUD will not take an HPRP grantee's HPRP outcomes-- such as the percentage of persons who exit to permanent housing destinations after HPRP assistance-- into account as a part of CoC scoring. Date Published: 7/1/2011 Topic: HPRP; Subtopic: Eligible Activities/Costs - Data Collection and Evaluation FAQ ID: 472 Can HPRP funds be used to purchase and implement a Housing Search/ Locator System? Would this activity be funded under Data Collection and Evaluation or Housing Relocation and Stabilization? HPRP funds under the Data Collection and Evaluation activity may be used to increase the scope of the HMIS to include a web-based housing search/housing locator module in the CoC's HMIS. This would include purchasing a module available through the CoC's HMIS software product or, when the CoCs HMIS software product does not have a housing search/housing locator module available, purchasing a 'customizable off-the-shelf' (COTS) product. However, if a COTS product is purchased, it must interface with the HMIS. Data Collection and Evaluation funds may not be used to purchase and implement a stand-alone housing locator/housing search product that is not integrated with the HMIS. The costs associated with implementing the housing locator/housing search functionality, including staff time for data entry, user training, and software licensing and support, are also eligible under the Data Collection and Evaluation activity, but the research conducted to identify landlords and/or properties for populating the housing locator is eligible under the Outreach and Engagement activity of Housing Relocation and Stabilization Services. Please note that HPRP Administrative funds may not be used to purchase or implement housing search/housing locator functionality since the use of Administrative funds is limited to costs associated with reporting, audits, and grant management. Date Published: 5/8/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Data Collection and Evaluation, Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 477 How should a grantee calculate the budget for Data Collection and Evaluation costs? Is there a recommended or maximum amount that grantees should budget for Data Collection and Evaluation costs? HPRP FAQs 37 June 2013

39 HPRP grantees are required to collect client-level data through the CoC's Homeless Management Information System (HMIS) or a comparable database to comply with the HPRP monitoring and reporting requirements. HPRP funds may be used to pay reasonable costs associated with data collection, data entry, data analysis, reporting and participation in HUD evaluation for HPRP. While preparing the substantial amendment, grantees should realistically budget for existing and future HMIS costs related to HPRP, remembering that HPRP funds must be expended by September 30, HUD encourages grantees to carefully consider costs for the following items when developing their budgets for Data Collection and Evaluation. - Hardware costs - Software costs (e.g., user licenses, annual support) - Participation fees - HMIS training (e.g., users, system administrator) - Staff costs, recognizing possibility of staff turnover (e.g., data collection/entry/analysis, reporting, system operation) - Data integration with comparable database (e.g., DV providers, legal services, legacy database) - Connectivity - Participation in national or regional HMIS training events (including travel) - Providing data to HUD for the national evaluation HUD has not established minimum or maximum funding amounts for any HPRP activity category, except for administrative funds which are capped at 5% of the HPRP grant. HUD encourages grantees to carefully consider potential costs to be incurred for expanding HMIS for HPRP data collection, reporting and participation in the HUD evaluation of HPRP, and to budget accordingly. Date Published: 5/8/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Data Collection and Evaluation, Substantial Amendment Requirements and Process FAQ ID: 403 Can HPRP funding help me with my mortgage payments? (REVISED) No, HPRP is not a mortgage assistance program. Also, HPRP may not be used to pay for any taxes or fees related to homeownership. Date Published: 6/10/2009 HPRP FAQs 38 June 2013

40 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 406 Does HPRP assistance provide long-term assistance? The maximum amount of rental assistance that may be provided under HPRP is 18 months. The purpose of HPRP short- and medium-term rental assistance is to help eligible program participants to quickly obtain and/or sustain stable housing. It is not intended to provide long-term support for program participants, nor will it be able to address all of the financial and supportive services needs that affect housing stability. In fact, many prevention and rapid re-housing program models include short- or medium-term rental assistance and services for households who have barriers to housing, but who are likely to sustain housing after the subsidy ends. Therefore, organizations providing assistance should use a process to assess, for all potential program participants, their level of service need, other resources available to them, and the appropriateness of their participation in the rapid re-housing assistance portion of HPRP. Program participants who require longer-term housing assistance and services should be directed to programs that can provide the requisite services and financial assistance. Date Published: 3/20/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 407 What are the eligible financial assistance expenses? Financial assistance is limited to the following activities: short-term rental assistance, medium-term rental assistance, security deposits, utility deposits, utility payments, moving cost assistance, and motel and hotel vouchers. Date Published: 3/20/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 408 What is considered short-term rental assistance and what is considered medium-term rental assistance? Short-term rental assistance may not exceed rental costs accrued over a period of 3 months. Medium-term rental assistance may not exceed actual rental costs accrued over a period of 4 to 18 months. Date Published: 3/20/2009 HPRP FAQs 39 June 2013

41 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 411 Can the rental assistance be used to pay unpaid rental debt? (REVISED) Yes, rental assistance may also be used to pay up to 6 months of rental arrears for eligible program participants facing eviction for non-payment of rent if the payment enables the program participant to remain in the housing unit for which the arrears are being paid. In cases where an eviction cannot be prevented, rental arrears can still be paid if it satisfies the grievance with the evicting landlord and thereby allows the participant to obtain different housing. Note that rental arrears can be paid on behalf of a person receiving a subsidy from another public program (e.g., Section 8) because it represents a different time period and cost type than the rental subsidy (ie, the arrears represents a back payment of the client portion, and the current rental assistance is a forward payment). Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 434 Are grantees allowed to charge a program fee (e.g., 30% of a participant's adjusted gross income) and use it to establish a savings account for the participant? Grantees and subgrantees may not charge program fees to participants. However, programs may be designed to require participants to pay a portion of their income for rent and/or into escrow/savings accounts for the purpose of maximizing their housing stability. Date Published: 4/3/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 442 How is HPRP different from the Rapid Re-housing (RRH) demonstration program? UNDER THE RRH PROGRAM: - Eligible Participants: Households with dependent children (families) - Rental Subsidy Period: 3-6 months OR months - Centralized Intake Process: Required HPRP FAQs 40 June 2013

42 - Community-wide Screening Tool: Required UNDER THE HPRP PROGRAM: - Eligible Participants: Individuals or Families (households with dependent children) - Rental Subsidy Period: Any # of months up to 18 months - Centralized Intake Process: Optional (HUD Recommends) - Community-wide Screening Tool: Optional (HUD Recommends) Date Published: 3/20/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 459 The guidance indicates that up to 6 months of utility arrears can be paid under the eligible activities within financial assistance. Is the eligible amount the actual charges accrued during the most recent 6 months, or any timeframe, up to a maximum of 6 months of total expenses? Utility arrears may be paid for any 6 months, as long as the program participant meets all eligibility criteria, and as long as the payment of the arrears allows the program participant to either remain in the housing or obtain new housing. The maximum amount that can be paid is the total arrears accrued during the 6 month period. Date Published: 4/24/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 476 Would the assistance to pay for up to 30 days of motel/hotel stay, a security deposit, or three months of storage count toward the 18 month limitation for rental assistance? For example, if a program participant receives a voucher for a 30-day stay at a motel, and then receives security deposit assistance, would that participant be eligible for 18 months of rental assistance? The only activity that counts towards the 18-month maximum is the payment of rental arrears. Motel/hotel vouchers, security/utility deposits, and moving assistance (including the storage fees) do not count toward the 18- month maximum of rental assistance. Date Published: 5/8/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance HPRP FAQs 41 June 2013

43 FAQ ID: 494 On page 16, the Notice states, 'HPRP funds may be used for reasonable and appropriate motel and hotel vouchers for up to 30 days if no appropriate shelter beds are available and subsequent rental housing has been identified but is not immediately available for move-in by the program participants.' Is this to be taken literally? Can a hotel/motel voucher be used only if a unit has been identified for that participant/household? Yes, as stated in the Notice, a hotel/motel voucher can only be used when a unit has been identified and no shelter beds are available. Because it could take a few weeks to locate suitable rental housing, it would be advisable for grantees to try to identify an alternate source of funding for emergency housing to assist households in-between the time of program entry and the identification of housing if the community's shelters are at capacity. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 497 What types of utility expenses are eligible under HPRP? Assuming that the participant meets all HPRP eligibility requirements, utility assistance related to housing may be provided. Utilities eligible for assistance are: heat, electricity, water, sewer and garbage collection. Telephone and cable services are not eligible. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 503 Could HPRP funds be used to pay continued room and board costs of foster care for youth who would otherwise have to leave foster care at age 18? In other words, could these funds be used to extend the foster care placement beyond age 18 when Title IV-E is no longer available as a funding source? HPRP funds can be used to prevent homelessness for youth aging out of foster care, as long as they meet the minimum requirements defined in section D.2. of the Notice, and as long as the program participant's name is on the lease in the assisted unit. Continued room and board costs in the youth's foster home would not be eligible, but moving the youth to a unit of his/her own would enable him/her to be eligible as long as he/she meets all of the eligibility criteria. As described in section IV.C, persons who are being imminently discharged into homelessness from publicly funded institutions are eligible to receive financial assistance or services through HPRP and is HPRP FAQs 42 June 2013

44 considered prevention assistance. However, developing or updating system discharge plans and policies is not an eligible expense. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 505 Can HPRP funds be used for shelters? Can funds be used to house persons in an emergency shelter on a short term basis? No. HPRP funds may not be used for shelter operations OR to pay to house persons in shelter, even on a temporary basis. However, as stated on page 16 of the Notice, "HPRP funds may be used for reasonable and appropriate motel and hotel vouchers for up to 30 days if no appropriate shelter beds are available and subsequent rental housing has been identified but is not immediately available for move-in by the program participants." This is the only circumstance that HPRP funds can be used to pay for emergency housing costs i.e., when permanent housing has been identified but it not yet available, and when shelter beds in the community are full. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 511 May HPRP funds be used to make buildings more energy efficient? Can they be used for lead-based paint remediation? HPRP funds may not be used for rehabilitation. However, there are many other programs being funded by HUD, DOE, EPA, and other departments/agencies that would fund these types of improvements. Please see for more information. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 564 Can a municipal grantee or subgrantee provide a client with utility assistance in cases where the city owns the utility company? HPRP FAQs 43 June 2013

45 HPRP funds may be used to pay for utility assistance provided by a municipal utility company, provided the program participant meets all eligibility requirements, the assistance will prevent the participant's homelessness, and the municipal department is not treating HPRP participants differently than non-hprp participants (e.g., with regard to fees or disconnections). A waiver is not required. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 571 Can landlords be reimbursed for court costs if it prevents a client's eviction? (REVISED; Originally posted 8/14/2009) Payment of reasonable court costs/attorney fees to make the landlord "whole" can be eligible HPRP expenses under the following circumstances: 1)The landlord's court costs have been applied by judgment of the court as part of the total amount due to prevent eviction; 2)Payment of the court costs are necessary for the landlord to retain the tenant in the property; AND 3)Nonpayment of the judgment will cause the tenant to become homeless. Note that paying court fees alone is not allowable if the household does not meet all other program eligibility criteria, including that they would be homeless 'but for' the assistance. Date Published: 7/1/2011 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 572 Is payment of rented trailer pads/lots on which a mobile home residence rests an eligible expense under HPRP? Rental assistance or arrears to pay for a lot on which a trailer is located can be eligible under financial assistance, although it is up to the grantee to determine whether to use HPRP funds for financial assistance costs associated with manufactured homes/trailer pads. HUD does not prohibit it. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance HPRP FAQs 44 June 2013

46 FAQ ID: 573 When a grantee provides security deposit assistance, must they recover the deposit if/when the household moves? HUD is giving grantees the discretion to determine how to handle security deposits. Assuming the landlord is not retaining the security deposit to pay for costs incurred by the tenant (e.g., damages), the grantee may recover the security deposit, in which case it must be treated as program income. Alternately, the grantee may allow the household to keep the deposit and use it towards their next unit. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 576 Is there any cap on relocation expenses? In other words, can a grantee use HPRP funds to help a client relocate to a different state, or from one end of a state to another? There is no cap on relocation expenses. However, as explained in the Notice, moving cost assistance is limited to truck rental fees, moving company fees, short-term storage, and related expenses. Transportation costs for participants (e.g., bus, train, plane tickets) are not eligible. If a grantee decides to help a client relocate to a different state or another area of a state, the grantee retains responsibility for ensuring that all requirements associated with the program are met, either by the grantee or another grantee. This includes documentation of rent reasonableness, conducting the habitability and lead-based paint inspections, and conducting reassessments every three months. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 690 Can HPRP funds be used to pay for credit reports and/or criminal background checks? (REVISED) Grantees and subgrantees electing to conduct credit and background checks on HPRP participants in an effort to understand the client's credit issues and other barriers to stable housing (i.e., as part of the client assessment) may use HPRP funds to pay the costs associated with the credit and background checks. However, grantees and subgrantees may NOT use HPRP funds to reimburse landlords for their costs associated with conducting background checks. HPRP FAQs 45 June 2013

47 NOTE: If grantees or subgrantees elect to conduct credit and/or background checks on HPRP participants, they must do so universally so as to not violate Fair Housing Law or otherwise discriminate among HPRP participants. The costs associated with the credit and/or background checks can be charged to housing search and placement under Housing Relocation and Stabilization. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 691 Can HPRP funds be used to pay for pet deposits? (REVISED; Originally posted 10/29/2009) Fees for pet deposits are not an eligible HPRP expense. Fees may not be charged for service animals that are required for a member of the household due to a disability. Service animals are not pets and reasonable accommodation law prohibits pet fees to be charged for service/assistance animals. See the regulations at 24 C.F.R. Part , and 24 C.F.R See also Secretary, HUD v. Purkett, HUDALJ Date Published: 4/7/2011 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 692 Can HPRP funds be used to assist with late fees and/or unit damages that are sometimes included with bills for rent arrears? HPRP funds may be used to pay for late fees associated with rent or utility arrears, as long as the payment enables the program participant to remain housed or become rehoused. However, HPRP funds may not be used to pay for damage costs incurred by the tenant. Date Published: 10/29/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 693 Can HPRP program participants receive assistance in tax credit projects? (REVISED) Tax credit projects could be eligible to house HPRP program participants the rental 'subsidy' received from a tax credit property is not considered the same "cost type" (as defined in the HPRP Notice) as direct rental assistance. HPRP FAQs 46 June 2013

48 However, if a grantee or subgrantee has any ownership interest--even 1 percent or less in the project, it does invoke the conflict of interest provisions of the HPRP Notice. In cases where the grantee or the subgrantee has an ownership interest in a project (such as a tax credit project), the grantee may seek a waiver from HUD to allow the use of this housing for HPRP participants. The grantee must submit a letter to the CPD Director requesting a waiver for good cause, including the following information: The use of the housing owned by the grantee/subgrantee/related entity is necessary to provide an adequate supply of appropriate housing options for HPRP participants; The grantee/subgrantee has disclosed the conflict of interest; HPRP participants will not be required or steered to live in the grantee/subgrantee/related entity's housing in order to receive financial or other assistance under HPRP; and Other than a one-time payment of rent in arrears, the grantee will not provide HPRP rental assistance to any tenant who lives in a unit that receives ongoing assistance, or who receives tenant-based rental assistance, under any other program. Date Published: 7/1/2011 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 707 Can HPRP financial assistance be used to cover "excess utilities" for public housing tenants, over and above the amount subsidized in public housing? No. As explained in the Notice, HPRP assistance cannot be provided to eligible individuals or families for the same period of time and for the same cost types that are being provided through another Federal, state, or local subsidy program. If a participant is receiving utility assistance under another program (either a full or partial subsidy), HPRP funds may not be used for utility assistance during that same time period. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 708 If a household is receiving LIHEAP assistance for help with a gas bill, are they eligible for HPRP assistance for other utilities? No. As explained in the Notice, HPRP assistance cannot be provided to eligible individuals or families for the same period of time and for the same cost types that are being provided through another Federal, state, or local subsidy HPRP FAQs 47 June 2013

49 program. If a participant is receiving utility assistance under another program, such as LIHEAP, HPRP funds may not be used for utility assistance during the same time period that LIHEAP assistance is provided. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 709 Can HPRP funds be paid to a collection agency for rental or utility debt? No, HPRP funds may not be paid to collection agencies or other third-party debt collectors. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 710 If a grantee is providing both rent and utility assistance for the same household, can the rental payment include a utility allowance, or must rental assistance and utility assistance be paid and tracked separately? (REVISED) All payments must go to third parties. Generally speaking, rental payments must be paid to landlords, and utility payments to the utility company. In addition, because the 18 months of rental assistance and utility assistance must be tracked and reported separately in the QPR, grantees will have to track the payments separately. However, in the event that utilities are master-metered for the property and the HPRP participant's monthly rent charge is inclusive of utilities, the utilities would be considered an amenity of the property. In such cases, the payment would be considered (and tracked as) a rent payment only; grantees/subgrantees would not need to separate out the utility expenses and cut separate checks to the landlord/property management firm. Note that such units must still comply with rent reasonableness standards, though the fact that the rent is inclusive of utilities should not pose a problem since the rent reasonableness rule requires a grantee to assess the total rent charged for a unit in relation to rents charged during the same time period for comparable units (i.e., those offering the same amenities). Date Published: 7/21/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 711 Can HPRP funds be used to pay rent in a group home, assisted living facility, or board and care setting? HPRP FAQs 48 June 2013

50 As long as each resident of a group home, assisted living facility, or boarding house has an individual lease, and has been assessed and certified to be eligible to receive HPRP assistance, HPRP funds may be used to assist persons residing in these types of housing. However, grantees must remember that in order to be eligible to receive HPRP assistance, the person must be about to become homeless, or homeless "but for" HPRP assistance. Grantees must also remember that HPRP is tenant-based assistance, and HPRP funds cannot be used for assistance in any project-based programs. The assistance cannot be attached to a unit; an eligible HPRP program participant must be able to choose whether to reside in the group housing or in another unit. Further, HPRP is a temporary assistance program with limited services that are provided separate from the housing, and is intended to assist persons who can remain stably housed after the assistance ends. If someone needs more intensive supports, HPRP may not be the most appropriate program for that individual. Finally, grantees must remember that financial assistance for persons in a group home setting is limited to rent, security deposits, utility deposits, and utility payments. Service fees that might be applied at assisted living facilities are not eligible. In addition, if there is another rental subsidy being provided, HPRP cannot be used for rent, and if there is a utility subsidy being provided, HPRP cannot be used for utilities. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 713 May financial assistance funds be used to move an individual or household to live with family in another state? HPRP is not a reunification or relocation program. Therefore, HPRP assistance for moving costs related to reuniting eligible applicants with family members is not eligible unless the participant can live with the family member permanently. If the HPRP program participant has been assessed and determined to meet all HPRP eligibility criteria described in the HPRP Notice, and they have permanent affordable housing identified in another location, HPRP funds may be used to pay for moving costs to another state. However, note that transportation costs (including bus, train, and airplane tickets) for program participants are not eligible. As described in the HPRP Notice, eligible moving costs include truck rental fees, moving company fees, and similar costs. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 714 Are utility reconnect fees an eligible expense? Yes. Late fees and reconnect fees that are sometimes associated with arrears are an HPRP-eligible expense, as long as the assistance is needed to prevent homelessness for the household. HPRP FAQs 49 June 2013

51 Date Published: 1/6/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 715 If HPRP funds are used to assist an eligible client with arrears, does each month of arrears count as one month of HPRP assistance? Yes. Although the payment would be a lump sum payment (and recorded as such in HMIS), each month of arrears would count against the 6 month limit on arrears as well as the 18 month overall limit on rental assistance allowed under HPRP. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 873 Can utility assistance be provided in cases where the utility bill is not in the name of the applicant? Can HPRP be used to pay fees associated with changing a utility bill to the name of the applicant? In situations where a utility bill is not in the name of the applicant or someone else in the applicant household (e.g., a spouse or child), the applicant must be able to demonstrate responsibility for payment of the utility, and likewise, the grantee must obtain documentation that the applicant is responsible for the payment. In such cases, the applicant should be encouraged to transfer the utility payment into his/her name as soon as possible. HPRP cannot be used to pay fees associated with changing a utility bill into the program participant's name. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 877 In some cases, a landlord will require both first and last month's rent to be paid up front. Is the 'last month's rent' an eligible expense? The last month's rent is an eligible expense, but how it is tracked and reported will depend on how it is treated by the landlord. If the last month's rent refers to a security deposit requirement that will be returned to the tenant upon move-out, the expense would be categorized as security deposit assistance and would not count against the 18 month HPRP FAQs 50 June 2013

52 limit on rental assistance. (Note that grantees can pay a security deposit equal to two times the monthly rent payment.) In contrast, if the last month's rent will actually be used to cover the tenant's final rent payment, then the payment would count against the total 18 months of rental assistance that is allowed under HPRP. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 891 Can HPRP funds be used to pay for rental application fees? HPRP funds may be used to pay for reasonable rental application fees if payment is required to obtain housing for the program participant. Grantees/subgrantees are encouraged to assist clients with their housing search (particularly individuals with multiple barriers who may have difficulty passing background checks) to avoid paying rental application fees to landlords/property management firms who are unwilling to work with HPRP clients that might not meet all of the landlord's requirements. Grantees may find some of the resources in HUD's Housing Search Assistance Toolkit to be useful, including the 'Client Telephone Guide: Calling About an Apartment.' Date Published: 7/21/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 1248 Are there any limits on security deposit assistance? How many months' worth of rent can be paid? HUD has not set a specific limit on the number of months' worth of rent that can be paid out as a security deposit; however, it is the responsibility of the grantee or subgrantee to ensure that the amount required is fair and reasonable. The landlord or property manager should have a policy in place so that different security deposit amounts are not arbitrarily collected. If the amount is more than 2 months' worth of rent, the grantee/subgrantee should obtain a copy of that policy for the case file. In many states, it is common for landlords to require "first and last month's rent" to be paid up front. If this refers to a security deposit requirement that will be returned to the grantee upon conclusion of the lease, the assistance would be considered/recorded as security deposit assistance. Note that security deposits do not count toward the 18-month cap on rental assistance. In contrast, if first and last month's rent are charged in addition to a security deposit and actually cover the client's first and last month of rent, the assistance would be considered rental assistance and would count against the 18 months allowed under HPRP. Date Published: 12/27/2010 HPRP FAQs 51 June 2013

53 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 1327 Will HPRP pay for the cost of a moving company to move furniture from a thrift shop or other donation center? As stated in a related HPRP FAQ, moving cost assistance such as truck rental fees, moving company fees, shortterm storage and related expenses are eligible under HPRP. Moving cost assistance to assist an eligible client with transporting donations from a nonprofit center or thrift store to the client's new home are similarly eligible, as long as payment to purchase the furniture itself is not included. Date Published: 7/1/2011 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance FAQ ID: 1918 Can I pay for a program participant s rent in advance, even if it is after the end of the 3-year grant expiration date? An HPRP grantee or subgrantee may pay for one month of a program participant s rent when the rent payment date falls within the 3-year deadline and the end of the month is after the deadline, and may not pay more than one month s rent at that time. For example, if a grantee s 3-year deadline is July 15, and a grantee normally pays rent beginning July 1, a grantee or subgrantee may pay July rent for program participants, because the cost is incurred on the day rent is due (July 1). However, the grantee or subgrantee may not pay for any costs for program participants incurred beyond the 3-year deadline, and therefore they may not pay rent for August, September, or any month after that. Date Published: 6/21/2012 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance, Closeout and Program End FAQ ID: 409 If a program participant initially received short-term rental assistance for 3 months and needs additional assistance, are they eligible to receive more funding through the HPRP? (REVISED) Yes, after 3 months, if program participants receiving short-term rental assistance need additional financial assistance to remain housed, they must be re-evaluated for eligibility and appropriateness of services/assistance (ie, would the participant be homeless 'but for' HPRP assistance). Participants may receive up to 15 additional months of medium-term rental assistance, for a total of 18 months. The 18 months need not be consecutive. As stated in the HPRP FAQs 52 June 2013

54 Notice, HUD is requiring grantees and subgrantees to certify eligibility at least once every 3 months for all program participants receiving medium-term rental assistance. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance, Eligible Participants (Clients) FAQ ID: 566 If a participant is receiving rental assistance through another program, can they also receive HPRP assistance? HPRP assistance cannot be provided to eligible individuals or families for the same period of time and for the same cost types that are being provided through another Federal, state, or local subsidy program. There are six cost types: rental assistance, security deposits, utility deposits, utility assistance, moving cost assistance, and hotel/motel vouchers. If a participant is receiving rental assistance under another program (either a full or partial subsidy), HPRP funds may not be used for rental assistance during that same time period. HUD expects the Public Housing Agency, or the agency administering the other housing subsidy program (e.g., HOME, HOPWA), to recalculate the tenant share of the rent payment when there has been a decrease in household income so that the housing remains affordable for the tenant. While a household receiving an ongoing housing subsidy cannot receive HPRP rental assistance to help with their portion of the payment for the current or future months, HPRP can be used to help the household pay for up to six months of arrears in cases where the household has fallen behind on its portion of the payment. For example, the household may have fallen behind due to a time lag between the household's change in income and the recalculation of the tenant rent contribution, or because of a legitimate unanticipated expense that prevented the household from being able to pay its portion of rent. (Grantees are responsible for assessing the household's budget and documenting that the expense was legitimate/unavoidable.) Note that assistance with arrears is eligible because it represents a different period of time i.e., the arrears represents a back payment for previous months, while the current rental assistance is a payment going forward. Finally, participants receiving rental assistance under another program may be eligible for other types of HPRP assistance, as long as they are not also receiving that 'type' of assistance through another source. For example, a homeless veteran receiving a VASH voucher would not be eligible for HPRP rental assistance, but may receive other types of HPRP assistance, such as security deposit assistance. In contrast, participants that are receiving utility assistance through LIHEAP may be eligible for HPRP rental assistance (as long as they are not receiving another rental subsidy), but would not be eligible for HPRP utility assistance during the same time period they are receiving LIHEAP. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance, Eligible Participants (Clients) HPRP FAQs 53 June 2013

55 FAQ ID: 575 HUD has indicated that grantees may provide rental assistance or services to eligible program participants who are residing or would like to reside outside their jurisdiction. Does this mean that grantees can serve persons in another state? It is up to the grantee to determine if they wish to assist persons in another state. This may be common where a metropolitan community or Continuum of Care crosses state boundaries. However, if they do so, the grantee retains responsibility for ensuring that all requirements associated with the program are met, either by the grantee or another grantee. This includes documentation of rent reasonableness, conducting the habitability and lead-based paint inspections, and conducting reassessments every three months. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance, Eligible Participants (Clients) FAQ ID: 1241 Is it allowable to provide rental assistance to an otherwise eligible applicant that is behind on his payments for a cooperative unit? Cooperative housing developments and/or mutual housing projects are generally recognized by state law as forms of homeownership. Since HPRP funds may NOT be used for payments that are associated with homeownership, payments for charges as part of a cooperative housing development are not an eligible HPRP expense. For a complete list of the assistance that can be provided to homeowners, please review this related FAQ. Date Published: 12/27/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance, Eligible Participants (Clients) FAQ ID: 1240 When a client that has received HPRP-funded security deposit assistance moves, HUD has indicated that the grantee/subgrantee may allow the client to keep the deposit for use at their next unit, or they may recover the deposit, in which case it must be treated as program income. If the deposits are recovered after the end of the program, how is that money treated? If the deposits are sent back to the grantee or subgrantee after the end of the HPRP grant period, the grantee/subgrantee agency may use the funds as they determine appropriate. There are no Federal requirements governing the disposition of program income earned after the end of the HPRP program. See the related FAQ that describes if and when recovered security deposits become program income. HPRP FAQs 54 June 2013

56 Date Published: 12/27/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Financial Assistance, Grants Management and Monitoring, Closeout and Program End FAQ ID: 419 Can HPRP be used to create a regional or state-wide prevention hotline? If yes, under what activity could the costs be incurred? Yes, a regional or state-wide prevention hotline would be eligible as an outreach and engagement activity under Housing Relocation and Stabilization Services. Date Published: 4/3/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 420 Where would assisting clients to access mainstream benefits/entitlements (e.g., SSI/SSDI) fit under HPRP? Would they be considered a case management service and funded as such? Yes, assisting a program participant to access public benefits would be considered case management. As stated in the HPRP Notice, "HPRP case management funds may be used for activities for the arrangement, coordination, monitoring, and delivery of services related to meeting the housing needs of program participants and helping them obtain housing stability." This activity would be considered an arrangement and coordination of public benefits. Date Published: 4/3/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 431 What category does staff time for screening clients for eligibility and processing client applications fall under? (REVISED; Originally posted 4/3/2009) Staff time associated with administering a particular program activity is charged to that program activity. Staff time for screening clients and processing client applications may be charged to either Case Management or Outreach and Engagement under Housing Relocation and Stabilization Services. Date Published: 10/11/2011 HPRP FAQs 55 June 2013

57 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 498 Is assisting homeless or those at risk of becoming homeless to obtain expungements and/or pardons of their criminal records an eligible activity under HPRP? Is re-entry advocacy to help ex-offenders get jobs and/or social services an eligible activity? Assisting homeless or soon-to-be-homeless persons in obtaining expungements and/or pardons of their criminal records is not an eligible activity under HPRP. Furthermore, advocacy is not an eligible expense, nor is helping persons get jobs. All eligible HPRP activities are directly related to housing. Helping eligible program participants to obtain other Recovery Act or mainstream resources is an eligible Housing Relocation and Stabilization Service. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 501 Can grantees provide housing stabilization supports to households that are relocated from shelter to unsubsidized housing, even if HPRP rent assistance is not used in that re-housing activity? Eligible program participants who are rapidly re-housed from shelter to unsubsidized housing may receive Housing Relocation and Stabilization Services without also receiving HPRP rental assistance, as long as they meet all of the eligibility criteria and would be homeless without the HPRP services provided. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 504 What kinds of legal assistance are eligible activities under HPRP? Legal services are limited to the activities described in the HPRP Notice. Eligible legal services may include assisting program participants with legal advice and representation in administrative or court proceedings related to tenant/landlord matters or housing issues. Legal assistance related to mortgages is not eligible. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services HPRP FAQs 56 June 2013

58 FAQ ID: 508 In the HPRP Notice, under Ineligible and Prohibited Activities, it states that transportation and travel costs are ineligible. Does this refer to the transportation/travel expenses of case managers, or does it refer to the client? This prohibition on transportation and travel costs refers to program participants. Case managers may travel if needed to serve eligible HPRP program participants. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 509 Under HPRP, is there a minimum or maximum cost that can be expended on case management/staff? As explained in the HPRP Notice, HUD has not established minimum or maximum funding amounts for any HPRP activity category, except for administrative funds which are capped at 5% of the HPRP grant. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 510 Are there education or qualification requirements for case managers under HPRP? HUD has not set any specific minimum criteria for case management staff that conduct the required initial assessment of program participants. However, HUD strongly encourages grantees to set minimum qualifications or credentials for these staff persons since they are the ones who will determine participant eligibility and therefore the program's compliance with the HPRP Notice. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 514 Is working with a housing counseling agency an eligible activity under HPRP? HPRP FAQs 57 June 2013

59 Housing Counseling agencies largely work with homeowners facing foreclosure. As mortgage assistance is not an eligible activity under HPRP, homeowners seeking this type of service should be referred to the appropriate Housing Counseling programs within your community. A housing counseling agency may be a subgrantee of HPRP funds if the scope of services include HPRP-eligible activities such as rental assistance and housing search and placement for HPRP-eligible participants. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 577 Can HPRP funds be used to help a household purchase furniture? As stated in the Notice, HPRP funds may not be used to help participants purchase furniture. However, there are a number of resources available to help households who need assistance furnishing an apartment. Visit to find a furniture bank in your community. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services, Eligible Activities/Costs - Financial Assistance FAQ ID: 712 According to the Notice, payment of credit arrears (e.g., credit cards, loans) is an ineligible financial assistance activity. At the same time, the Notice indicates that credit repair is an allowable housing relocation and stabilization service. What is the difference? Credit repair is an eligible activity under Housing Relocation and Stabilization Services and refers to such services as helping clients develop a household budget, access credit reports, negotiate with banks, etc. It does not include paying down consumer debt. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services, Eligible Activities/Costs - Financial Assistance HPRP FAQs 58 June 2013

60 FAQ ID: 716 How would the 18-month timeline for the receipt of assistance be calculated for participants receiving different types of assistance? The 18-month limitation applies to services as well as rental and utility assistance. They are each calculated separately, and the months need not be concurrent. The intent of separate clocks is to provide flexibility to grantees, but HUD expects that in most cases, households will need services that are concurrent with financial assistance in order to increase housing stability. Grantees must remember that all households even those receiving services only must be reassessed every three months to verify that they meet all HPRP eligibility criteria and that the assistance is needed to prevent homelessness. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services, Eligible Activities/Costs - Financial Assistance FAQ ID: 1247 The HPRP Notice states that HPRP assistance 'cannot be made on behalf of eligible individuals or families for the same period of time and for the same cost types that are being provided through another Federal, state, or local housing subsidy program.' Does this rule cover charitable donations provided by private organizations and/or individuals? For example, if a client received $200 from their church to help with their rent, could the client receive HPRP rental assistance during that same month? The intent of this rule, known as the 'cost type' rule, is to prevent the use of HPRP funds where other governmental assistance, determined based on client income and need, is provided on a regular basis. One-time assistance from private charitable sources such as a church would not prohibit a grantee/subgrantee from providing HPRP rental assistance to a household. Date Published: 12/27/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services, Eligible Activities/Costs - Financial Assistance, Eligible Participants (Clients) FAQ ID: 1249 If people re-housed with HPRP retain their homeless status and eligibility for CoC-funded programs, it would seem they would also remain eligible for HUD-VASH. Is this true? HPRP FAQs 59 June 2013

61 Yes. In some cases, a veteran who is homeless and determined eligible for HUD-VASH cannot move into that housing immediately. If this individual has been determined to be eligible for HPRP and is assisted with HPRP (they either sign a lease or are placed into a hotel or motel for up to 30 days with HPRP because subsequent housing has been identified), they do maintain their homeless status, and therefore can be assisted with HUD-VASH subsequent to HPRP. Remember that HPRP cannot be used for the same cost type and time period as another type of assistance. Therefore, HPRP funds can be used to pay for moving costs or a security deposit to help someone move into a HUD-VASH funded unit, but HPRP could not pay any portion of the rent as long as another subsidy, such as HUD- VASH, was paying the rent for that unit. Date Published: 1/11/2011 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services, Eligible Activities/Costs - Financial Assistance, Eligible Participants (Clients) FAQ ID: 1239 May HPRP-funded legal services be used to assist Rapid Re-Housing clients, or may they be used to assist only persons at risk of homelessness (homelessness prevention clients)? The HPRP Notice states the following: 'HPRP funds may be used for legal services to help people stay in their homes, such as services or activities provided by a lawyer or other person(s) under the supervision of a lawyer to assist program participants with legal advice and representation in administrative or court proceedings related to tenant/landlord matters or housing issues' (Section IV.A.2.d.). HUD recognizes that persons who are homeless can have extensive and wide-ranging legal issues that prevent them from obtaining housing. However, HPRP is a homeless prevention and rapid re-housing program not a legal aid program. As such, the Notice was intentionally written very narrowly, and HPRP-funded legal assistance is, in fact, limited to helping clients that are facing evictions and resolving other landlord/tenant matters to help them keep their housing. As a result, legal services will most typically be provided to homeless prevention clients. Rapid re-housing clients are not strictly prohibited from receiving legal services, but HUD expects it to be more rare for example, if a program participant that has been recently evicted from housing can recover that housing with the receipt of legal assistance. If grantees/subgrantees need additional information on whether a particular program applicant falls within the scope of this rule, they are encouraged to contact the Help Desk for further guidance. Date Published: 12/27/2010 Topic: HPRP; Subtopic: Eligible Activities/Costs - Housing Relocation and Stabilization Services, Eligible Participants (Clients) FAQ ID: 387 Why was $500,000 chosen as the minimum amount that will be allocated to grantees? HPRP FAQs 60 June 2013

62 HPRP funds were allocated according to the Emergency Shelter Grants (ESG) formula. In the ESG program, the minimum grant amount is 0.05 percent; however, the Recovery Act gave the Secretary discretion to set the minimum grant amount. At $500,000 (approximately percent), more metropolitan cities and urban counties can receive funds directly than in ESG. The intent is to expedite the process of getting the funds to the program participants, who need the assistance quickly. Date Published: 3/20/2009 Topic: HPRP; Subtopic: Eligible Grantees and Subgrantees FAQ ID: 398 Who are eligible grantees for HPRP funding? (REVISED) States, U.S. territories, metropolitan cities, or urban counties are eligible grantees for HPRP funding. Grantees may subgrant to local units of government, which may include metropolitan cities and urban counties that receive HPRP funds directly from HUD, and/or to private nonprofit organizations. For state subgrantees, the local government in the locality in which the organization will operate the program must certify that it approves of the program. Date Published: 4/24/2009 Topic: HPRP; Subtopic: Eligible Grantees and Subgrantees FAQ ID: 450 Are tribal units of government eligible recipients of funds in a subgrantee capacity from the State? No, tribal governments are not eligible subgrantees. State HPRP grantees must subgrant funds to either units of general local government in the state which may include metropolitan cities and urban counties that receive grants amounts directly from HUD or private nonprofit organizations. Date Published: 4/24/2009 Topic: HPRP; Subtopic: Eligible Grantees and Subgrantees FAQ ID: 489 Where can a list of "entitlement communities" or HPRP grantees be found? HPRP FAQs 61 June 2013

63 To find this information, please refer to the HPRP Eligible Grantees with CDBG Contact Information document which is posted on the HUD HRE. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Grantees and Subgrantees FAQ ID: 651 Can a State HPRP grantee subgrant funds to Public Housing Agencies, Housing and Redevelopment Authorities, and other Special Purpose Governmental Organizations? State HPRP grantees may only subgrant to private non-profit organizations and units of general purpose local government. In the vast majority of cases, the State cannot subgrant its HPRP funds to a PHA or HRA because these are not units of general purpose local government. HUD relies on the classifications in the Census of Governments in determining whether an entity is a unit of general purpose local government. For information on these classifications, see 'Structure of Governments' at Please note the following: a.hud cannot waive this requirement because it is statutory. The provisions under which HPRP was authorized in the American Recovery and Reinvestment Act of 2009, Public Law 111-5, specify that funding for HPRP 'be allocated to eligible grantees (as defined and designated in sections 411 and 412 of subtitle B of title IV of the McKinney-Vento Homeless Assistance Act (the 'Act')) pursuant to the formula authorized by section 413 of the 'Act.' Section 413 of the Act states that '[t]he Secretary [of HUD] shall allocate assistance... to... States (for distribution to local governments and private nonprofit organizations in the States).' 42 U.S.C Section 411 of the Act defines the term 'local government' as a 'unit of general purpose local government.' 42 U.S.C It is this parenthetical that sets the requirement, and since it is statutory, it cannot be waived. b.a state subgrantee may not further subgrant state HPRP funds to a PHA, HRA, or other special purpose local government agency that is not a unit of general purpose local government. c.a state subgrantee that adheres to the requirements of 24 CFR may procure the services of any entity, including a PHA, HRA, to carry out the eligible activities under HPRP. However, the procurement rules are based on free and open competition for the grantee/subgrantee to get the best deal for its grant dollars in obtaining goods and services from a qualified organization. The noncompetitive proposal method (procurement through solicitation of a proposal from only one source, or after solicitation of a number sources, competition is determined inadequate) is only permitted by 24 CFR 85.36(d)(4) if other methods of procurement are infeasible and one of the specified circumstances applies. Date Published: 9/11/2009 Topic: HPRP; Subtopic: Eligible Grantees and Subgrantees HPRP FAQs 62 June 2013

64 FAQ ID: 652 Can a Metropolitan City or Urban County HPRP grantee subgrant funds to Public Housing Agencies, Housing and Redevelopment Authorities, and other Special Purpose Governmental Organizations? Metropolitan Cities and Urban Counties may subgrant to private non-profit organizations or other units of general purpose local government. In the vast majority of cases, a city or county PHA, HRA, or other special purpose public agency is not recognized as a unit of general purpose local government. HUD relies on the classifications in the Census of Governments in determining whether an entity is a unit of general purpose local government. For information on these classifications, see 'Structure of Governments' at: The following are four ways that a PHA, HRA, or other special purpose public agency may qualify to conduct HPRP activities: a.if the PHA, HRA, or other entity is a department of a unit of general purpose local government pursuant to state law, then it may carry out HPRP activities for the city or county government and no subgrant is required. In this case, the unit of general local government, not the PHA, would be the grantee (or subgrantee, if using funds subgranted from another local government grantee). The majority of PHAs do not meet this requirement. If the special purpose public entity does meet this qualification, then the HPRP grantee must notify the CPD Director in writing that the PHA or other special purpose entity is a department of the unit of general purpose local government, including the statutory citation and name(s) of the PHA(s) or other special purpose entity. b.if any organization, including a PHA, or HRA, has a status of a 501(c)(3) private non-profit organization, it qualifies as an eligible subgrantee. c.if the grantee submits a request for a waiver of the prohibition on subgranting HPRP funds to a PHA, or HRA or other special purpose entity and HUD approves this waiver request, the metropolitan city or urban county grantee may subgrant to a PHA, HRA, or other special purpose local government for the organization to carry out eligible activities or administer the program. The grantee must submit a letter to the CPD Director requesting a waiver for good cause, including the following information: - Description of how inclusion of the PHA, HRA, or other organization as a subgrantee is in the best interest of HPRP participants, including any benefit(s) to the participants, - Demonstrate the PHA, HRA, or other organization's expertise serving homeless persons, and - Explanation of selection process for HPRP participants. d.a metropolitan city or urban county grantee that adheres to the requirements of 24 CFR may procure the services of any entity, including a PHA or HRA, to carry out the eligible activities under HPRP. However, the procurement rules are based on free and open competition for the grantee/subgrantee to get the best deal for its grant dollars in obtaining goods and services from a qualified organization. The noncompetitive proposal method (procurement through solicitation of a proposal from only one source, or after solicitation of a number sources, competition is determined inadequate) is only permitted by 24 CFR 85.36(d)(4) if other methods of procurement are infeasible and one of the specified circumstances applies. Date Published: 9/11/2009 HPRP FAQs 63 June 2013

65 Topic: HPRP; Subtopic: Eligible Grantees and Subgrantees FAQ ID: 404 Does a program participant need to have a child or children in the household to be eligible to receive assistance? No, a program participant can be an individual or a household with or without children. Date Published: 3/20/2009 Topic: HPRP; Subtopic: Eligible Participants (Clients) FAQ ID: 414 What assistance can be provided to homeowners? (REVISED) While mortgage assistance is not eligible under HPRP, homeowners who become homeless are eligible for all HPRP activities, provided they meet the other eligibility criteria as listed in the Notice. Homeowners who are housed but are at risk of becoming homeless and meet all other eligibility criteria (consultation with a case manager, below 50% of AMI, and at risk of becoming homeless with no housing options and lack financial resources/support network) may be assisted with the following: utility payments (including arrears but excluding deposits) and housing relocation and stabilization services (such as credit repair, case management, and housing search/placement but excluding legal services related to a mortgage). In addition, persons who are foreclosed upon, are going to become homeless, and meet all of the eligibility criteria may be eligible to receive homelessness prevention assistance for example, rental assistance in a rental unit, moving cost assistance, etc. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Participants (Clients) FAQ ID: 415 Will citizens returning to the community following discharge from a state correctional system (who meet all stated eligibility requirements) be eligible for receipt of short-term housing assistance? Yes, persons who are discharged from publicly funded institutions and who meet all HPRP eligibility requirements may receive financial assistance and/or services under HPRP. Date Published: 4/3/2009 Topic: HPRP; Subtopic: Eligible Participants (Clients) HPRP FAQs 64 June 2013

66 FAQ ID: 458 If an individual has severe and persistent physical or mental health issues that would make them a good fit for a permanent supportive housing program (like Shelter Plus Care-funded housing), but there are no available openings in such programs, can the person access HPRP funds while they sit on the waiting list? (REVISED) The intent of the legislation is to assist persons who need temporary assistance to obtain or remain in housing, and hopefully be able to sustain housing, subsidized or unsubsidized, once HPRP ends. That said, persons who are disabled and eligible for permanent supportive housing are eligible to receive tenant-based rental assistance available through HPRP. Therefore, persons on a permanent supportive housing program waiting list may be served with HPRP assistance until a permanent supported housing unit is available, provided the permanent supportive housing unit will be available within 18 months, does not violate conflict of interest leasing requirements, the services provided are limited to the HPRP Housing Relocation and Stabilization services described in the Notice, and the assessment reveals that the person is likely to be able to maintain the HPRP housing until the permanent supportive housing unit is available. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Participants (Clients) FAQ ID: 462 Under HPRP, if homeless families are re-housed and receive short or medium-term rental assistance, will this make them ineligible for a CoC-funded transitional or permanent supportive housing program? In other words, does participation in HPRP eliminate an individual's homeless status? What about their status as a chronically homeless person? (REVISED) HPRP assistance is temporary. Persons who were homeless before receiving HPRP assistance (Rapid Re-housing assistance) do not lose their homeless status and remain eligible for assistance under other CoC-funded programs. HUD recently established a new policy for the status of chronically homeless persons that receive HPRP assistance, similar to the policy for homeless status. The new policy is that if someone was chronically homeless before receiving HPRP assistance, they retain their chronically homeless status, which allows them to exit HPRP to Continuum of Care Samaritan Permanent Housing projects. Date Published: 12/27/2010 Topic: HPRP; Subtopic: Eligible Participants (Clients) FAQ ID: 473 Can HPRP funds be used to assist individuals/families in transitional housing? HPRP FAQs 65 June 2013

67 HPRP funds may not be used to move an individual or family into a transitional housing program, nor may it be used to assist persons residing in a transitional housing program. However, HPRP funds may be used to assist persons that are graduating from or timing out of a transitional housing program to obtain permanent housing. Date Published: 5/8/2009 Topic: HPRP; Subtopic: Eligible Participants (Clients) FAQ ID: 493 The activities funded under the prevention and re-housing categories seem to be the same. How do I know the category under which to draw down funds in IDIS? Is the distinction between participants who are assisted to stay in their existing housing and those that are placed in new housing? All persons assisted with HPRP funds whether it is considered prevention or rapid re-housing assistance may receive assistance from any of the HPRP eligible activities. The distinction is related to the population served. The difference is that persons receiving prevention assistance are housed at the time they begin receiving HPRP assistance, and persons receiving rapid re-housing assistance are homeless (according to the HUD definition) at the time they begin receiving assistance. If the applicant does not meet the HUD homeless definition, the assistance would be classified as prevention. For example, an individual who has been in a hospital, prison, or other institution for less than 180 days and who was sleeping in an emergency shelter or on the streets immediately prior to entry into the institution meets the HUD definition and therefore would be served under the rapid re-housing category. In contrast, a person who has been a resident of an institution for more than 180 days would still be eligible (assuming he/she meets other HPRP eligibility criteria), but in this case, the individual would be served under the prevention category. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Participants (Clients) FAQ ID: 500 Are set-asides allowed for any specific population who may be, at some point, at risk of losing their jobs? No. Grantees may not set aside funds for a specific group of people who are not yet eligible for HPRP funds. HPRP eligibility must be determined on a case-by-case basis, upon the required initial visit with a case manager or other professional who is qualified to determine eligibility for the program. This is why unemployment is not the only criteria that a grantee or subgrantee may look at for participation in HPRP - a program participant must meet all of the eligibility criteria described in section IV.A.2. of the HPRP Notice. There is no way for the grantee to know, without the careful, initial assessment by a case manager, which of the workers that may be laid off would become homeless without HPRP assistance, so a "set-aside" is not allowed. HPRP FAQs 66 June 2013

68 Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Participants (Clients) FAQ ID: 502 Under HPRP, is there an age restriction on persons receiving assistance? No, there are no age restrictions. However, just as with McKinney-Vento programs, HPRP funds may not be used to serve youth who are wards of the state. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Participants (Clients) FAQ ID: 512 Under HPRP, are people living doubled-up with friends or family considered to be at risk of homelessness? Are they eligible to receive HPRP funds? Families or individuals who are precariously housed may be eligible for HPRP prevention assistance if is determined that they would be 'homeless but for this assistance' and they meet all other HPRP eligibly criteria, as specified in the Notice. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Eligible Participants (Clients) FAQ ID: 704 If otherwise eligible for HPRP assistance, can ex-offenders or offenders who are scheduled for release but have no suitable housing options be assisted with HPRP? HPRP regulations do not require grantees to disqualify individuals or families based on criminal history. HUD requires only that all program participants meet the minimum eligibility criteria and that grantees comply with all local and Federal requirements. Grantees are allowed flexibility in designing their programs, which means they have the discretion to establish their own policies regarding ex-offenders. If grantees choose to serve ex-offenders with HPRP funds, it is the role of grantees and subgrantees to work with landlords in developing strategies to reduce barriers to housing for exoffenders. HPRP FAQs 67 June 2013

69 Per the definitions in HPRP Notice, persons who have been incarcerated for less than 180 days and were homeless prior to entering the institution would be assisted under the rapid re-housing category. Persons that have been in the institution for longer than 180 days would be assisted under the prevention category. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Eligible Participants (Clients) FAQ ID: 705 If a client is terminated from HPRP for non-compliance, are they eligible to re-apply for services? Each grantee has the discretion to decide whether to allow participants that have been terminated for noncompliance to re-apply for assistance, and if so, the timeline for re-application. Please note that the HPRP Notice requires grantees to have a formal termination process in place that recognizes the rights of individuals receiving assistance to due process of law. Although the HPRP Notice does not prescribe an appeal process, HUD recommends that grantees and subgrantees develop and make public such a process. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Eligible Participants (Clients) FAQ ID: 1331 Can HPRP continue to provide rental assistance for a unit that is vacant due to incarceration? This response assumes a household comprised of an individual. HPRP assistance cannot be provided if the participant is not residing in the unit for which assistance is being provided due to time in jail or prison. Assistance can be reinstated when the client returns to his/her unit (or, if they lose the housing, assistance can be provided to help him/her locate a new/different unit). Date Published: 7/1/2011 Topic: HPRP; Subtopic: Eligible Participants (Clients) FAQ ID: 1332 Can HPRP continue to provide rental assistance for a unit that is vacant due to hospitalization/treatment? This response assumes a household comprised of an individual, and that the grantee or subgrantee learns of the hospitalization/stay in a treatment facility before the 3-month recertification. At the 3-month recertification, the HPRP FAQs 68 June 2013

70 grantee or subgrantee should determine if the household is still eligible for HPRP assistance based on the regular HPRP eligibility criteria. A grantee may choose to pay rent while the individual is hospitalized or in a treatment facility. If the grantee determines that it will not pay rent during the time a program participant is hospitalized or in treatment, the program participant must be terminated from the program, based on the normal termination process. Recall that the HPRP Notice requires the grantee to provide a formal process when terminating the assistance (see related FAQ on this topic). Grantees should establish a policy about whether and for how long to pay rent if a program participant is hospitalized/in treatment while receiving rental assistance. Important factors that should be addressed in this policy include: 1.Establishing a reasonable time period and reasonable costs for rent payment for a vacant unit due to hospitalization/treatment. 2.Process for evaluating each case and ensuring that paying rent on a vacant unit is a cost effective means for preventing homelessness (e.g., if the program participant is expected to be hospitalized for an extended time period and placing items in storage is more cost effective than paying rent, the grantee should exercise this option). All grantee policies must be applied consistently, and case managers should document all decisions made. Further, the grantee must ensure that the rent paid on behalf of the program participant does not exceed 18 months; and that the program participant remains eligible for HPRP assistance while any assistance is being provided. Date Published: 7/1/2011 Topic: HPRP; Subtopic: Eligible Participants (Clients), Determining and Documenting Client Eligibility FAQ ID: 474 Can HPRP funds awarded to an entitlement city or county be used outside of the city or county's jurisdiction? Grantees may provide rental assistance or services to eligible program participants who are residing or would like to reside outside their jurisdiction. They may also fund subgrantees that serve persons outside of the jurisdiction, subgrantees that are located outside of the jurisdiction, and subgrantees that serve multiple jurisdictions. A grantee may establish more stringent requirements, such as requiring that HPRP funds be spent within the jurisdiction or establishing a residency requirement, but HUD is not setting these requirements. Date Published: 5/8/2009 Topic: HPRP; Subtopic: Eligible Participants (Clients), Eligible Grantees and Subgrantees FAQ ID: 1927 Can I serve HPRP program participants with ESG? HPRP FAQs 69 June 2013

71 For those program participants who, at the last recertification before HPRP ends, are not going to be able to remain stably housed without assistance, ESG funds may be used to help them after HPRP funds are no longer available. If that is the case, they must meet one of the seven criteria listed in category one of the at-risk of homelessness definition at 24 CFR A complete eligibility/intake assessment must be conducted and includes having an income below 30 percent of median family income for the area, as determined by HUD, and lacking the resources and support networks to prevent them from going into an emergency shelter or one of the places listed in paragraph (1) of the Homeless definition at 24 CFR If they are eligible for ESG, you will need to exit them out of HPRP (including exiting them out in HMIS). Since they are already in housing, they would not qualify for rapid re-housing assistance, it would be categorized as homelessness prevention. Date Published: 7/16/2012 Topic: HPRP, Emergency Solutions Grants (ESG) Program; Subtopic: Eligible Participants (Clients), Emergency Solutions Grants (ESG) Program, Closeout and Program End FAQ ID: 750 What types of conflict of interest exist with regard to HPRP? And what information must a grantee submit to request a conflict of interest waiver? (REVISED) There are two situations that are often referred to as a 'conflict of interest.' 1) The first is when HPRP program participants are to be assisted in a property that is owned by the grantee, subgrantee, or the parent/subsidiary/affiliated organization of the subgrantee. In this instance, a grantee must submit a letter to the CPD Director requesting a waiver for good cause. The waiver must demonstrate that: - The use of the housing owned by the grantee/subgrantee/related entity is necessary to provide an adequate supply of appropriate housing options for HPRP participants; - The grantee/subgrantee has disclosed the conflict of interest; - HPRP participants will not be required or steered to live in the grantee/subgrantee/related entity's housing in order to receive financial or other assistance under HPRP; and - Other than a one-time payment of rent in arrears, the grantee will not provide HPRP rental assistance to any tenant who lives in a unit that receives ongoing assistance, or who receives tenant-based rental assistance, under any other program. Without an approved waiver from HUD, HPRP assistance cannot be provided to persons served in housing owned by the grantee, subgrantee, or the parent/subsidiary/affiliated organization of the subgrantee. For questions about a specific situation, please contact your local HUD field office. 2) The second type of conflict of interest that can occur is at the individual level (as opposed to the grantee/subgrantee level). The HPRP Notice states: 'No person who is an employee, agent, consultant, officer, or elected or appointed official of the grantee and who exercises or has exercised any functions or responsibilities with HPRP FAQs 70 June 2013

72 respect to assisted activities, or who is in a position to participate in a decision-making process or gain inside information with regard to such activities, may obtain a personal or financial interest or benefit from the activity, or have an interest in any contract, subcontract, or agreement with respect thereto, or the proceeds thereunder, either for himself or herself or for those with whom he or she has family or business ties, during his or her tenure or for one year thereafter.' Please note that employees of a grantee or subgrantee and their families are not automatically disqualified from receiving HPRP assistance, as long as they meet the qualifications of the above paragraph (i.e., they are not in a position to exercise any responsibilities, make decisions about, gain inside information into, or obtain a personal benefit from HPRP). This situation would be more likely in a large grantee/subgrantee agency than it would in a very small grantee/subgrantee agency. When this type of conflict of interest exists, the grantee may seek an exception by writing to the local HUD Field Office, including the following information: - For states and other governmental entities, a disclosure of the nature of the conflict, accompanied by an assurance that there has been public disclosure of the conflict and a description of how the public disclosure was made; and - For all grantees, an opinion of the grantee's attorney that the interest for which the exception is sought would not violate state or local law. If there is a question or the appearance of a conflict of interest of any type, please contact the local HUD field office to determine if an exception or waiver is needed. Date Published: 7/1/2011 Topic: HPRP; Subtopic: Eligible Participants (Clients), Grants Management and Monitoring, Funds Distribution & Subgrantee Selection, Eligible Grantees and Subgrantees FAQ ID: 399 Can a State award HPRP funds in an area that receives its own HPRP allocation, or is the State restricted to distributing funds in non-entitlement areas? Under HPRP, a state may subgrant with areas that receive a direct allocation from HUD. Date Published: 4/3/2009 Topic: HPRP; Subtopic: Funds Distribution & Subgrantee Selection FAQ ID: 443 Does the grantee have to engage in a competitive process for the selection of sub-grantees? Does this process have to be included in the Consolidated Plan submission? HPRP FAQs 71 June 2013

73 HUD is giving discretion to grantees to develop their own allocation process. The grantee's plan for distribution, administration, and oversight of funds needs to be addressed in the Substantial Amendment that is submitted to HUD to receive HPRP funding. Note that it is the grantee's responsibility to ensure that any agency or organization receiving HPRP funding is in compliance with the requirements outlined in the HUD Notice. Date Published: 4/24/2009 Topic: HPRP; Subtopic: Funds Distribution & Subgrantee Selection FAQ ID: 490 Can a State use a combination process and award HPRP funds directly to units of general local government (for example, counties) and directly to a regional or statewide non-profit? HUD is providing all grantees, including state grantees, with the discretion to subgrant to local nonprofits or local governments to carry out HPRP activities (see section III.C of the HPRP Notice). HUD also provides discretion for grantees to develop a subgrantee selection process, provided it is fair and reasonable. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Funds Distribution & Subgrantee Selection FAQ ID: 491 If a city is not a grantee, must it apply to the State grantee or, if the county in which the city is located is an HPRP grantee, must the city apply to the county? The county, as a grantee, has the discretion to distribute HPRP funds to the cities within its jurisdiction as subgrantees. The city is also eligible to receive funds from the State as a subgrantee, at the discretion of the State grantee. Further, cities and counties may subgrant HPRP funds to other local governments. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Funds Distribution & Subgrantee Selection FAQ ID: 650 What is the September 30th deadline and what are the consequences if we cannot meet it? Can we request a waiver of this deadline? HPRP FAQs 72 June 2013

74 Section V.A.1. of the HPRP Notice requires grantees to 'award or enter into legally binding agreements with all subgrantees by September 30, 2009.' If a grantee issues award letters to subgrantees by the deadline, HUD will consider the grantee to have met the requirement. HPRP is a part of the Recovery Act, and therefore, it is vital that subgrantees have access to the funds so that the assistance can reach those in need as soon as possible. HUD strongly encourages grantees to do everything possible to meet this deadline, and will not grant waiver requests. As with all program requirements, noncompliance with the September 30th deadline will increase the grantee's risk level for monitoring and may result in monitoring findings and/or sanctions. Date Published: 9/11/2009 Topic: HPRP; Subtopic: Funds Distribution & Subgrantee Selection FAQ ID: 444 Can a state grantee sub-grant funds to another state agency, such as a state mental health or foster care agency? A state grantee may not subgrant HPRP funds to another state agency. The American Recovery and Reinvestment Act cites Section 413 of the ESG statute as to how the funds must be allocated, and per Section 413(a), funds are intended for 'distribution to local governments and private nonprofit organizations in the states." So, as under ESG, states cannot directly provide financial assistance or services and they cannot subgrant to another state agency. Date Published: 4/24/2009 Topic: HPRP; Subtopic: Funds Distribution & Subgrantee Selection, Eligible Grantees and Subgrantees FAQ ID: 471 In Section III, Part A, the HPRP Notice indicates that state grantees may subgrant directly to private nonprofit organizations 'if the local government for the locality in which the program is located certifies that is approves of the program.' When does this rule apply, and what does certification entail? (REVISED) The only instance that local certification is required is when state grantee is allocating HPRP funds to non-profit organizations located in an area outside of the state's Consolidated Plan jurisdiction. That is, when a state subgrants HPRP funds to a non-profit organization located in an entitlement area covered by another Consolidated Plans, the local government for the area in which the office of the non-profit organization is physically located must certify that it approves of the program. If funds are being provided to a non-profit organization in an area covered by the state's Consolidated Plan, certification is not required. To obtain certification by the local unit of government, grantees should use a form similar to the one used by state grantees under the Emergency Shelter Grants (ESG) program. View the form here. Date Published: 8/14/2009 HPRP FAQs 73 June 2013

75 Topic: HPRP; Subtopic: Funds Distribution & Subgrantee Selection, Eligible Grantees and Subgrantees FAQ ID: 423 What is the timeframe to spend HPRP funds? (REVISED) The Recovery Act requires grantees to draw down from IDIS 60 percent of HPRP grant funds within two years of the date that HUD signed the grant agreement, and 100 percent of funds within three years of this date. If a grantee receives any reallocated funds, these must all be expended within three years of the grantee's initial grant agreement as well. No expenses may be incurred after the 3-year expenditure deadline, but grantees may draw down funds to be reimbursed for eligible HPRP expenses incurred during the 3-year grant period for up to 90 days after the grant period ends. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Grants Management and Monitoring FAQ ID: 425 Can grantees draw down funds as a cash advance, or do they have to be reimbursed? (REVISED) The preferred method is reimbursement. However, grantees and subgrantees may be paid in advance, pursuant to procedures outlined in 24 CFR for nonprofit organizations and 24 CFR for units of government. All requirements in 24 CFR or 24 CFR 85.21, as applicable, including the standards for financial management systems and limitations on advance payments or working capital advances, apply to HPRP grantees and subgrantees. For additional guidance on advance payment requirements, grantees should contact their local HUD Field Office. Date Published: 4/24/2009 Topic: HPRP; Subtopic: Grants Management and Monitoring FAQ ID: 426 Will there be flexibility to adjust budgets among the four eligible funding areas during the contract period? HPRP grantees may adjust budgeted amounts for the eligible activities just as they do under ESG. The Substantial Amendment to the grantee's 2008 Annual Action Plan, completed by the grantee to receive HPRP funds, is only a planned budget. Actual budgets may vary during implementation. A grantee should consult its citizen participation plan (in the grantee's Consolidated Plan) to determine if the grantee provides a threshold amount for budget changes for which local citizen participation and consultation is required. HPRP FAQs 74 June 2013

76 The HPRP grantee must document changes in IDIS via funds committed to projects and activities. The grantee should use its own internal process to document contract changes with subgrantees. Date Published: 4/3/2009 Topic: HPRP; Subtopic: Grants Management and Monitoring FAQ ID: 427 Is there a cap on any of the funding categories? For example, is there a cap on services or data collection and evaluation? The only limit is on administrative costs, which are limited by statute to 5 percent of the grant amount. Grantees should consider the extent and variety of needs in their communities in order to determine how much to spend on any given type of activity. Date Published: 4/3/2009 Topic: HPRP; Subtopic: Grants Management and Monitoring FAQ ID: 518 Will a Single Audit be acceptable for the HPRP program or will a project audit be required? All grantees and subgrantees must conduct audits as required under the OMB Circulars for the type of organization and the funding streams received by the organization. In general, an HPRP-specific project audit will not be required in addition to a Single Audit (see OMB Circular A-133 for more information). Please note that the Recovery Act states that for fiscal years ending September 30, 2009 and later, all Single Audit reports filed with the Federal Audit Clearinghouse will be made publicly available online. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Grants Management and Monitoring FAQ ID: 578 How will HUD's monitoring for HPRP be conducted? HUD will conduct on-site monitoring using the CPD Monitoring handbook as a guide, as is done with ESG or CDBG and other CPD programs. HUD is currently developing specific monitoring procedures for HPRP. HUD will also conduct desk (off-site) monitoring, and will be examining grantee draws and financial reporting in IDIS to HPRP FAQs 75 June 2013

77 evaluate rates of spending and to ensure that the grantees are drawing HPRP funds for eligible activities. Grantees will be monitored for compliance with applicable lead-based paint requirements in accordance with the CPD Monitoring handbook, chap. 24, Lead-Based Paint. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Grants Management and Monitoring FAQ ID: 875 Are grantees required to draw down funds on a quarterly basis? Yes. Grantees must draw down from IDIS at least quarterly after the first draw, and are urged to draw down from IDIS monthly. If a grantee does not draw funds at least every three months, it will result in a monitoring finding. In addition, HUD will be looking at grantee disbursements, and will be contacting grantees with slow spending rates. If 60 percent of funds are not spent 2 years from the date HUD signed the grant agreement, HUD may recapture the remaining funds. Grantees should use existing IDIS reports to monitor their expenditures. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Grants Management and Monitoring FAQ ID: 879 Are subgrantees required to set up a separate, non-interest-bearing checking account for advances of HPRP funds? No, establishing a separate account is not required. HUD recommends reimbursement as the method of payment. However, when advance payments are used, the funds should be kept in a non-interest-bearing account since any interest earned over $100 would have to be returned to HUD. Per the regulation at 24 CFR 85.21(i), "grantees and subgrantees shall promptly, but at least quarterly, remit interest earned on advances to the Federal agency. The grantee or subgrantee may keep interest amounts up to $100 per year for administrative expenses." Further, per 24 CFR 85.21(b), grantees must "minimize the time elapsed between the transfer of the funds and their disbursement by the grantee or the subgrantee." 24 CFR 84.22(b)(2) states that "the timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the recipient organization for direct program or project costs and the proportionate share of any allowable indirect costs." This should typically be within two weeks at a maximum. It is up to the grantee or subgrantee to determine whether to keep advanced funds in a separate account, but having a separate account (particularly if it is interest-bearing) may facilitate keeping track of interest in excess of $100. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Grants Management and Monitoring HPRP FAQs 76 June 2013

78 FAQ ID: 892 What types of waivers will HUD consider? HUD can consider waivers on issues that are not defined by statute. In other words, HUD is allowed to waive some provisions of the HPRP Notice, but not the Recovery Act itself. Under HPRP, the most common waivers that HUD has approved include waivers of the following Notice provisions: - The prohibition on conflicts of interest, to allow grantees to assist HPRP participants in properties owned by the grantee/subgrantee/related entity; - The requirement that state grantees must subgrant all funds except for administration costs, to allow them to retain funds for data collection and evaluation expenses to run a statewide HMIS; and - The requirement that metropolitan cities and urban counties may only subgrant HPRP funds to private non-profit organizations and units of general purpose local governments, to allow an HPRP grantee to subgrant HPRP funds to a public housing agency. Grantees with additional questions on waivers should contact their local HUD Field Office. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Grants Management and Monitoring FAQ ID: 1244 The Recovery Act requires recipients of ARRA funds to display a 'whistleblower' poster on company/agency grounds. Does this requirement apply to HPRP grantees? In accordance with Section 1553 of the Recovery Act, entitled 'Protecting State and Local Government and Contractor Whistleblowers,' HPRP grantees and certain other recipients are required to display, in their place of employment, the Whistleblower Protection Poster. This poster is a notice of whistleblowers' rights and remedies, and can be obtained using the following link to the Whistleblower Information web page: The requirements do apply to: - All HPRP grantees; - Any other recipient of HPRP funds that is a government of a political subdivision of a state or territory (including any unit of general purpose local government that receives HPRP funds as a subgrantee); and - Any contractor or subcontractor that is procured by and receives HPRP funds from a state, territory, the District of Columbia, or any government of a political subdivision of a state or territory (regardless of whether that government is a grantee or subgrantee). For example, contractors or subcontractors that are procured by cities and HPRP FAQs 77 June 2013

79 counties, whether the city or county is a grantee or subgrantee, even if the contractor or subcontractor is a non-profit organization, would need to display the poster. The requirements under Section 1553 of the Recovery Act do not apply to any private nonprofit organization, unless that organization receives HPRP funds as a contractor or subcontractor of (i.e. was procured by) a State, territory, the District of Columbia, or the government of a political subdivision of a state or territory. If a private nonprofit organization only receives HPRP funds as a subgrantee, it is not subject to the requirements under Section For HPRP, the Whistleblower Protection posters must be displayed at the job sites of the above employers, where they can be seen by the protected employees. Date Published: 12/27/2010 Topic: HPRP; Subtopic: Grants Management and Monitoring FAQ ID: 1246 Do grantees need to submit the SF-425, the Federal Financial Report? The SF-425 replaces the SF-272 and SF-269 for federal financial reporting requirements in 24 CFR parts 84 and 85 (see the interim rule in the Federal Register, Vol. 75, No. 135, published on Thursday, July 15, 2010). However, if the same information is collected electronically by HUD, then grantees do not need to complete the SF-425. For HPRP, IDIS fulfills this requirement, and therefore, grantees do not need to submit the form to the local HUD field offices. Date Published: 12/27/2010 Topic: HPRP; Subtopic: Grants Management and Monitoring FAQ ID: 1280 What is the Catalog of Federal Domestic Assistance (CFDA) number for HPRP? The CFDA number, as stated in the Notice, is This CFDA number is effective until the end of the program on September 30, Date Published: 1/25/2011 Topic: HPRP; Subtopic: Grants Management and Monitoring HPRP FAQs 78 June 2013

80 FAQ ID: 1328 As a grantee, when making payments to subgrantees for HPRP expenditures, what level of source documentation review do we need to conduct? The regulations at 24 CFR 85.20(a) for state grantees and 85.20(b) for other grantees differ slightly; please be sure to review both in detail. For state grantees, their subgrantees and contractors, the requirement is that the fiscal controls and accounting procedures "must be sufficient to... permit the tracing of funds to a level of expenditures adequate to establish that such funds have not been used in violation of the restrictions and prohibitions of applicable statutes." For other grantees and subgrantees, the regulations state that they must "maintain records which adequately identify the source and application of funds provided for financially-assisted activities," and "Accounting records must be supported by such source documentation as cancelled checks, paid bills, payrolls, time and attendance records, contract and subgrant award documents, etc." These regulations also require that costs be eligible, actual, and incurred. While the only way for a grantee to establish that all costs are eligible, actual and incurred would be a 100% review of the documentation, a 100% review is not spelled out as a requirement. Therefore, grantees can develop a practice that gives them assurance that costs drawn were eligible, actual, and incurred. Frequent monitoring, strong oversight, and periodic sampling of supporting documentation for expenses might give one grantee comfort that expenses are eligible, actual, and incurred and enable them to reduce their requirements for supporting documentation from subgrantees. On the other hand, another grantee may consider any practice that falls short of a 100% review as an inadequate risk control measure. However, HUD cannot prescribe what the ideal process for meeting these requirements would be. This process and protocols must be designed by each grantee: some grantees are comfortable with assuming some risk and not reviewing everything; whereas others are not comfortable assuming ANY risk and therefore require a review of all documentation. Date Published: 7/1/2011 Topic: HPRP; Subtopic: Grants Management and Monitoring FAQ ID: 1329 What is the difference between a working capital advance and a cash advance? HUD regulations allow for two types of advances that grantees might utilize to pay for HPRP expenses, as an alternative to the reimbursement method of payment: cash advances and working capital advances. Grantees and subgrantees intending to use a cash advance strategy should be prepared to demonstrate that they have a track record of correctly determining housing status and income eligibility for program participants, that they have established capacity to manage financial reconciliation, and that they are maintaining appropriate documentation of related records. HPRP FAQs 79 June 2013

81 If you are not sure if the method of payment that you are currently using meets the HUD regulations at 24 CFR part or 84.22, please contact your local HUD field office. Key features of each method of advances are summarized below: Cash Advances: Grantees and subgrantees may be paid in advance, provided that they minimize time elapsing between the transfer of the funds and their disbursement by the grantee or subgrantee. If electing this option: -State and local governments must follow the requirements articulated in 24 CFR part 85.21, and -Non-profit organizations must follow the requirements in 24 CFR part Specifically, non-profit organizations are required to maintain financial management systems that meet certain standards (described in the regulation). Also, cash advances to a non-profit organization must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the organization in carrying out the purpose of the approved project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the organization for direct program costs and the proportionate share of any allowable indirect costs. Working Capital Advances: A working capital advance is a mechanism that grantees can use if they cannot meet the criteria for advance payments described in 24 CFR part 84 or 85 (see above), and if HUD has determined that operating on a reimbursement-only basis is not feasible because the grantee or subgrantee lacks sufficient working capital. In most cases, a working capital advance is no longer an option for HPRP grantees because their program is already well underway. Grantees need to contact their local HUD Field Office or HPRP Desk Officer at HUD Headquarters if they would like to consider use of a working capital advance. Under the rules for working capital advances, grantees and, in turn, subgrantees, are permitted to receive a one-time cash advance to cover their estimated disbursement needs for an initial period, generally geared toward the disbursing cycle (often, one month). After that, HUD or the grantee will reimburse the grantee or the subgrantee, respectively, for actual cash disbursements. Note that the working capital advance method of payment must not be used if the reason for using it is the unwillingness or inability of the grantee to provide timely payments to the subgrantee to meet the subgrantee's actual cash disbursements. Grantees who use this mechanism should also be aware that all funds advanced must be expended and accounted for prior to the subsequent drawdown, and in compliance with the federal regulations outlined in 24 CFR for units of local government and in 24 CFR for non-profit organizations. Date Published: 7/1/2011 Topic: HPRP; Subtopic: Grants Management and Monitoring FAQ ID: 475 Grantees and subgrantees have three years from the date the grant agreement is executed to expend all funds. Will there be a grace period so that a client enrolled near the end of the grant agreement period can continue to receive assistance for the entire length of time deemed necessary to stabilize that client? HPRP funds may not be expended after three years from the date of the grant agreement. This means that grantees and subgrantees will need to plan in advance - in order for a program participant to receive a full 18 months of rental HPRP FAQs 80 June 2013

82 assistance, they would need to begin receiving it 18 months before the grant expires. If a participant seeks assistance 4 months before the grant expires, that household would be able to receive a maximum of 4 months of rental assistance. Date Published: 5/8/2009 Topic: HPRP; Subtopic: Grants Management and Monitoring, Closeout and Program End FAQ ID: 880 If and when do recovered security deposits become program income? If a grantee collects program income after the grant has ended, what should the grantee do with these funds? If the grantee or the subgrantee recovers security deposit monies that originally came from the HPRP grant, the result is the generation of program income. HPRP-generated income received by the grantee is subject to Federal regulations governing program income (there are no HPRP-specific program requirements for program income; the Federal rules apply). Please see 24 CFR part for the Federal rules on program income for state and local governments. Likewise, HPRP-generated income received by the subgrantee, which acts on behalf of the grantee, is subject to the same rules governing program income. In both cases, the grantee is responsible for tracking the receipt, use (or re-use), and disposition of all such income. HUD does not impose any requirements on program income received after the end of the award period (after the date of the final financial report), and the grantee is free to use that income in any way it chooses (see related FAQ). Date Published: 7/21/2010 Topic: HPRP; Subtopic: Grants Management and Monitoring, Closeout and Program End FAQ ID: 1929 As HPRP grants come to a close, what expenses are eligible for the remaining funds that have not been allocated? Grantees are accountable for all expenses incurred, and should take great care to verify eligibility of all costs paid with grant funds. Even if a significant portion of the funds remain, grantees may not exhaust funds by purchasing equipment that will not be used to carry out essential HPRP activities before expiration. Any purchase made must pass all three of the following tests: 1)Reasonable costs reflect the prudent decision made in purchasing the items at that price. They are necessary for the completion of HPRP. 2)Allowable costs are permitted as direct costs under the terms of HPRP and local contracts. 3)Allocable costs can be specifically identified with HPRP and are completed in time to benefit program participants. HPRP FAQs 81 June 2013

83 Grantees that have purchased equipment in the third year of HPRP will bear the responsibility for demonstrating how the purchase was absolutely necessary to carry out the remainder of the grant (previously held equipment was irreparably damaged and no longer functional, for instance). Any purchases made in the final months of the grant will be subject to the strictest scrutiny from SNAPS and the Office of the Inspector General. * While the repurposing of HPRP equipment acquired at under $5,000 to other programs may be allowed, no equipment can be purchased with the intent of use in other programs. EXAMPLE A subrecipient purchases a computer to maintain its client records and comply with HMIS requirements (allowable). To be considered an eligible expense, this computer must have been purchased during the service period of the grant (allocable), must have been necessary to complete compulsory HPRP activities (reasonable & allowable), and must have been purchased at a reasonable price (reasonable). Date Published: 7/25/2012 Topic: HPRP; Subtopic: Grants Management and Monitoring, Closeout and Program End, Eligible Activities/Costs - Administrative Costs FAQ ID: 470 What process would an eligible municipality use to allow another eligible entity to carry out HPRP activities cooperatively, combining both jurisdictions' funds? A metropolitan city or urban county that receives a grant allocation directly from HUD may subgrant to another local government. By subgranting their allocation, the grantee maintains responsibility for oversight and all other grantee responsibilities that are required when they subgrant funds to another entity. Please note that this is different from carrying out HPRP activities cooperatively through a "joint agreement" joint agreements are not allowed under HPRP. Therefore, the HPRP grantee must submit a substantial amendment, and then complete a subgrant agreement with the other local government. Date Published: 5/8/2009 Topic: HPRP; Subtopic: Grants Management and Monitoring, Funds Distribution & Subgrantee Selection FAQ ID: 492 Can a grantee or subgrantee procure services from a for-profit organization to implement the local HPRP program? Services could include particular aspects related to program administration (e.g., inspections), technical assistance, etc. Grantees and sub-grantees can procure services from for-profit organizations. Grantees and sub-grantees must follow the applicable federal procurement rules: HPRP FAQs 82 June 2013

84 -24 CFR Part 85, applicable to States and local governments -OMB Circular A-110 as implemented through 24 CFR Part 84, applicable to nonprofits. Additionally, most states and many local governments have laws and regulations regarding procurement. Each grantee and sub-grantee receiving HPRP funds should aware of the state and/or local laws that may affect procurement policies. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Grants Management and Monitoring, Funds Distribution & Subgrantee Selection FAQ ID: 876 Are HPRP subgrantees required to follow a competitive procurement process before awarding HPRP funding to another party? HPRP subgrantees that are nonprofit organizations must follow the applicable Federal procurement rules in OMB Circular A-110 and at 24 CFR Part 84. Small purchase procedures allow subgrantees to acquire goods and services totaling no more than $100,000 without publishing a formal request for proposals or invitation for bids, so a competitive process will not be required in all instances. In addition, if the nonprofit organization already has an existing contract with a vendor, AND the existing contract was originally procured in accordance with 24 CFR parts through 84.48, HPRP funds can be added to an existing contract for services. If the subgrantee intends to modify its existing contracts, it must follow the requirements for contract modifications in 24 CFR part 84. However, if the modification involves substantial changes to the terms of the contract OR if the original procurements were not done in accordance with 24 CFR part 84, the grantee must conduct a new procurement following the requirements of 24 CFR part 84. (A substantial change to the terms of the contract is a fact-specific determination that would need to be made by the HUD Field Office on a case-by-case basis.) Subgrantees should also be aware that most states and many local governments have laws and regulations regarding procurement. Additionally, grantees may have imposed additional restrictions for their programs. Subgrantees should review their grant agreement for any procurement-related clauses and contact their grantee for additional information as needed. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Grants Management and Monitoring, Funds Distribution & Subgrantee Selection FAQ ID: 1238 What are the deadlines for grantees to expend funds? What happens if funds are not expended by the deadlines? HPRP FAQs 83 June 2013

85 Per the HPRP Notice, each grantee must draw down 60 percent of its HPRP grant funds within 2 years of the date that HUD signed the grant agreement, and must expend 100 percent of its funds within 3 years of this date. The HPRP Notice also specified that HUD may recapture unexpended violations of the 2-year expenditure requirement and reallocate such funds to grantees in compliance with that requirement. However, given recent amendments to ARRA by the Wall Street Reform and Consumer Protection Act of 2010, any funds that are recaptured by HUD cannot be reallocated to other grantees. Funds recaptured by HUD will instead be deposited into the General Fund of the Treasury. However, HPRP grantees may recapture funds from their subgrantees and reallocate to other subgrantees (see related FAQ on recapturing and reallocating funds between subgrantees for more information). Date Published: 12/27/2010 Topic: HPRP; Subtopic: Grants Management and Monitoring, Funds Distribution & Subgrantee Selection, Closeout and Program End FAQ ID: 581 At what point must a grantee prepare a substantial amendment? For the Supportive Housing Program, budget amendments are triggered if there is a change in a particular budget category that exceeds 10 percent. (REVISED; Originally posted 8/14/2009) HUD has not set a specific percentage for changes to the HPRP budget submitted in the grantee's substantial amendment. The Consolidated Plan regulations require grantees to establish criteria in their Citizen Participation Plan for what constitutes a substantial amendment to its Consolidated Plan, including the specific threshold as well as how that threshold is calculated (e.g., percentage change between budget categories, percentage change between subgrantees). Therefore, HUD does not determine when a substantial amendment is necessary this is determined by the grantee's Citizen Participation Plan. Grantees should note, however, that when the substantial amendment process is triggered, the public comment period is not abbreviated, as it was under the original substantial amendment submission. If there is a proposed change that necessitates a Substantial Amendment to the Consolidated Plan, the grantee must send a copy of the revised amendment to the local HUD Field Office as well as the grantee's HPRP Desk Officer. This submission should include clear documentation that the jurisdiction has complied with its own Substantial Amendment requirements. In addition, the grantee must report the change in the Grant Allocation table of its subsequent HPRP Quarterly Performance Report (QPR), and make the appropriate changes in IDIS. If there are other changes that do not constitute a substantial change to the Consolidated Plan, the grantee should still send a copy to the HUD Field Office and the HPRP Desk Officer, report any budget changes in the QPR, and make changes in IDIS. To see criteria for amendments, refer to Section of the Consolidated Plan Final Rule 24 CFR Part 91. See this related FAQ: Date Published: 12/27/2010 HPRP FAQs 84 June 2013

86 Topic: HPRP; Subtopic: Grants Management and Monitoring, Funds Distribution & Subgrantee Selection, Substantial Amendment Requirements and Process FAQ ID: 1236 If a subgrantee is not compliant with program requirements, is not performing adequately, or is not spending quickly enough (and will prevent the grantee from meeting the statutory expenditure deadlines for HPRP), can a grantee recapture and reallocate funds between subgrantees or to a new subgrantee? Yes, as allowable according to the contract or subgrant agreements that are in place. Also, the grantee must comply with the Substantial Amendment criteria established in the Citizen Participation Plan portion of its local Consolidated Plan. The Consolidated Plan regulations require grantees to establish criteria in their Citizen Participation Plan for what constitutes a substantial amendment to its Consolidated Plan. Issues of timing, public participation, and threshold requiring a resubmission may be unique for each jurisdiction. If there is a proposed change that necessitates a Substantial Amendment to the Consolidated Plan, the grantee must send a copy of the revised amendment to the local HUD Field Office as well as the grantee's HPRP Desk Officer. This submission should include clear documentation that the jurisdiction has complied with its own Substantial Amendment requirements. In addition, the grantee must report the change in the Grant Allocation table of its subsequent HPRP Quarterly Performance Report (QPR), and make the appropriate changes in IDIS. If there are other changes that do not constitute a substantial change to the Consolidated Plan, the grantee should still send a copy to the HUD Field Office and the HPRP Desk Officer, report any budget changes in the QPR, and make changes in IDIS. Lastly, grantees are cautioned to reallocate funds with sufficient time for the funds to be expended within the statutory deadlines. To see criteria for amendments, refer to Section of the Consolidated Plan Final Rule 24 CFR Part 91. Date Published: 12/17/2010 Topic: HPRP; Subtopic: Grants Management and Monitoring, Funds Distribution & Subgrantee Selection, Substantial Amendment Requirements and Process FAQ ID: 451 What are the on-site habitability inspection requirements, when do they apply, and who can conduct them? (REVISED) The standards for housing unit inspections are the housing habitability standards described in Appendix C of the Notice. These standards apply only when a program participant is receiving security deposit, utility deposit, rental, and/or utility assistance and moving into a new unit. They do not apply to persons receiving moving costs only. Also, they do NOT apply to persons receiving services only. Finally, they do not apply to persons served with HPRP prevention assistance in a unit in which the program participants were already residing. Please see other questions for the lead-based paint assessment requirements, as they differ from the habitability standard inspection requirements. HPRP FAQs 85 June 2013

87 Note that the habitability standards are different from the Housing Quality Standards (HQS) used for other HUD programs. Because the HQS criteria are more stringent than the habitability standards, a grantee could use either standard. Also note that the HPRP Notice does not exempt units from having to be compliant with local housing codes. Therefore, if there are requirements that are in both the local housing code and the HPRP Notice, the grantee must comply with the more stringent of the two. In contrast to HQS inspections, the habitability standards do not require a certified inspector. For example, HPRP project staff or staff from or hired by an agency of the grantee's local government can conduct the inspection. In addition, if a program participant is moving in to a unit and using another subsidy program that requires an inspection, staff from the other program may conduct the inspection, as long as they follow the minimum habitability standards required by HPRP. Inspections must be conducted upon initial occupancy and then on an annual basis for the term of HPRP assistance. Please note that housing that is occupied by families with children under the age of 6 and that was constructed before 1978 whether served with prevention or re-housing assistance - must also comply with Lead Based Paint inspection requirements, per the Lead Based Paint Poisoning Prevention Act. (Please see additional questions on lead-based paint inspection requirements.) Date Published: 8/14/2009 Topic: HPRP; Subtopic: Housing and Lead Inspections FAQ ID: 453 What type of documentation does HUD require related to the housing habitability inspection? (REVISED) Grantees and subgrantees are responsible for documenting that each unit meets the habitability standards as described in Appendix C of the Notice. However, HUD is not requiring a particular form of documentation. A sample form is available on the HRE. Date Published: 10/29/2009 Topic: HPRP; Subtopic: Housing and Lead Inspections FAQ ID: 454 What are the lead-based paint inspection requirements? (REVISED) The Lead-Based Paint requirements are more stringent than the habitability standards. A lead-based paint visual assessment must be completed for all units that meet the three following conditions: - The household living in the unit is being assisted with HPRP financial assistance (rent assistance, utility assistance, utility/security deposits, or arrears). - The unit was constructed prior to HPRP FAQs 86 June 2013

88 - A child under the age of six is or will be living in the unit. Under HPRP, the lead requirements apply regardless of whether a household is remaining in an existing unit or moving to a new unit. The visual assessment must be completed prior to HPRP assistance being provided, and annually thereafter. Detailed guidance on the Lead-Based Paint requirements and sample tools are available on the HRE on the HPRP Tools and TA Resources Page. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Housing and Lead Inspections FAQ ID: 455 Who can conduct the Lead-Based Paint Visual Assessments? (REVISED) Visual assessments must be conducted by a HUD-Certified Visual Assessor. Anyone may become a HUD-Certified Visual Assessor by successfully completing a 20-minute online training on HUD's website at: The training teaches individuals how to identify deteriorated paint and how deteriorated paint must be treated. Note that a HUD-certified Visual Assessor is not equivalent to a Lead Risk Assessor or Certified Clearance Examiner, whose services may be needed if lead hazards are identified during the visual assessment. Detailed guidance on the Lead-Based Paint requirements and sample tools are available on the HRE on the HPRP Tools and TA Resources Page. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Housing and Lead Inspections FAQ ID: 496 Appendix C of the HPRP Notice outlines the habitability standards for HPRP. Must the local housing code be used if it meets a higher standard than the identified requirements in Appendix C? Several sections indicate that grantees may use either standard. The grantee or subgrantee is responsible for ensuring that a housing inspection is conducted, to ensure that units assisted with HPRP funds meet the housing habitability standards described in Appendix C of the Notice. Local housing codes also apply to the units, but the landlord should have a Certificate of Occupancy or other documentation that ensures that the building complies with local requirements. The HPRP Notice does not exempt units from having to be compliant with local housing codes. Therefore, if there are requirements that are in both the local housing code and the HPRP Notice, the grantee must comply with the more stringent of the two. HPRP FAQs 87 June 2013

89 Date Published: 6/10/2009 Topic: HPRP; Subtopic: Housing and Lead Inspections FAQ ID: 724 If a Section 8 or public housing resident is seeking HPRP assistance for a security deposit, utility assistance, or arrears, and the unit has already passed an HQS inspection by the PHA, must the HPRP grantee conduct separate habitability and lead inspections? If a unit has already passed a Housing Quality Standards (HQS) inspection by the PHA with the past 12 months, the HPRP grantee is not required to repeat the inspection. However, it is the HPRP grantee's responsibility to obtain documentation from the PHA for the HPRP case file. HPRP grantees should be aware that some PHAs use a sampling technique with regard to inspections for public housing units, and as such, the grantee must ensure that an inspection was conducted for the actual unit into which the HPRP program participant will be moving. If the PHA did not conduct an HQS inspection for that unit, then the HPRP grantee must conduct a habitability inspection in compliance with Appendix C of the HPRP Notice and a lead-based paint visual assessment (as applicable) before assistance can be approved. Inspections are required annually during the term of assistance, and it remains the HPRP grantee's responsibility to either conduct the follow-up inspections or obtain the needed documentation from the PHA. Documentation should be attained prior to approving the HPRP assistance. Grantees should note that HQS the standards required under the Section 8 program are more stringent than the habitability standards required under HPRP, and as such, adequately satisfy HPRP requirements. If HPRP grantees rely on inspections required under another housing program and conducted by another agency, including an inspection for a local housing code requirement, they must ensure that the standards used are equal to or greater than the habitability standards required under HPRP. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Housing and Lead Inspections FAQ ID: 725 In addition to assessing habitability standards, the guidelines also say that the homes occupied by HPRP recipients must meet all state and local requirements. What documentation is required to satisfy that state and local housing requirements are met? The Notice indicates that housing must be in compliance with state and local housing codes to ensure that grantees understand the habitability standards do not replace state and local codes. Likewise, if a local Certificate of Occupancy or other inspection is required by local code, it cannot be used in place of the HPRP habitability inspection unless the grantee can verify that it meets all of the standards in Appendix C of the HPRP Notice (including the frequency with which the inspection is required). If there are requirements that are covered in both HPRP FAQs 88 June 2013

90 the habitability standards and state/local housing code, grantees must comply with the more stringent of the two. However, compliance with state and local codes is a local matter. Typically, landlords should have a Certificate of Occupancy or other documentation that ensures that the building complies with local requirements. If grantees have questions about their state or local housing code, they are encouraged to contact their state or local housing agency for more information. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Housing and Lead Inspections FAQ ID: 871 If a grantee or subgrantee is assisting a client who owns a mobile home with lot rent, do the housing inspection and lead based paint requirements apply? The habitability inspection requirements apply only when HPRP funds are used to assist a household to move to a new unit. When HPRP funds are used to prevent homelessness by helping a household to stay in their existing unit, a habitability inspection is not required. In contrast, the lead-based paint requirements apply whenever financial assistance is being provided for a pre-1978 structure (owned or rented) that is or will be occupied by a family with children under the age of 6, regardless of whether prevention or rapid re-housing assistance is provided. (Please see the FAQs on lead-based paint inspection requirements.) Therefore, if a grantee or subgrantee is proposing to use HPRP funds to pay for the rent of the lot, the grantee or subgrantee must comply with the lead-based paint inspection requirements if the structure was built prior to 1978 and there are any pregnant women or children under the age of 6 residing in the housing assisted with HPRP funds. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Housing and Lead Inspections FAQ ID: 872 If a property does not pass the lead-based paint visual assessment, and the outside of the structure cannot be repaired due to weather conditions, is it acceptable to issue HPRP assistance based upon the inside of the structure passing inspection with the condition that outside areas of deteriorated paint be repaired and re-inspected when weather permits? The lead-based paint regulation at 24 CFR a.12 states the following: "Performance of an evaluation or leadbased paint hazard reduction or lead-based paint abatement on an exterior painted surface as required under this part may be delayed for a reasonable time during a period when weather conditions are unsuitable for conventional construction activities." HPRP FAQs 89 June 2013

91 HUD recognizes that it is not possible to paint outdoors if temperatures are too low and/or there is precipitation. However, HUD does not interpret the regulation as allowing for a blanket seasonal exemption. At the same time, it is not possible to establish a single rule since what is reasonable in one region may not be reasonable in another. As a result, HUD is providing grantees with the discretion to determine what is considered reasonable on a case-by-case basis. As always, it is important that a grantee's decision be both defensible and documented. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Housing and Lead Inspections FAQ ID: 413 Will the condition of a unit or building impact a household's ultimate eligibility to receive financial assistance? For persons residing in buildings that have been condemned or otherwise not suitable for human habitation, HPRP funds may be used to relocate them to more suitable housing. The HPRP assistance may include financial assistance and housing relocation and stabilization services. The unit into which the program participants move must meet habitability standards as defined Appendix C of the Notice. Grantees and subgrantees are encouraged to consider local and state building and housing codes when providing financial assistance to persons to allow them to remain in their housing. Keep in mind that HPRP funds may not be used for the construction or rehabilitation of a building. Date Published: 3/20/2009 Topic: HPRP; Subtopic: Housing and Lead Inspections, Eligible Activities/Costs - Financial Assistance FAQ ID: 452 Are costs related to conducting the inspections an eligible cost under the category of financial assistance? (REVISED) The costs associated with conducting a habitability inspection are eligible and should be charged under the financial assistance category. The costs should generally be charged to Rental Assistance, unless the agency is providing the household with, for example, security deposit or utility assistance only (in which case the costs should be correlated to the type of assistance provided). Similarly, the cost of conducting a Lead-Based Paint visual assessment is also an eligible financial assistance expense. Note that if peeling/deteriorated paint is detected during the visual assessment, costs associated with testing and repair/cleanup are not eligible under HPRP. However, once the deteriorated paint has been repaired, the cost of one Clearance Exam may be charged against the grant under the financial assistance category. Date Published: 1/6/2010 HPRP FAQs 90 June 2013

92 Topic: HPRP; Subtopic: Housing and Lead Inspections, Eligible Activities/Costs - Financial Assistance FAQ ID: 432 Is completion of "Rent Reasonableness Checklist and Certification" required documentation for payments related to rental arrears, security deposits, utility deposits, or other financial assistance? In the Notice, HUD set a requirement that rents must be in compliance with the HUD standard of "rent reasonableness." This would include rental payments, rental arrears, and security deposits. However, it is up to the grantee to determine exactly which documentation it will require in order to ensure that the rent reasonableness standard is met. Date Published: 4/3/2009 Topic: HPRP; Subtopic: Lease and Rent Requirements FAQ ID: 464 How is rent reasonableness determined? Are grantees required to use the 'Rent Reasonableness Checklist' referenced in the HPRP Notice? (REVISED) Rent reasonableness is determined on a case-by-case basis. Rent reasonableness should be determined by considering the reasonableness of the rent in relation to rents being charged for comparable unassisted units, taking into account the location, quality, size, type, and age of unit, as well as any amenities, housing services, maintenance, and utilities provided by the owner. Comparable rents can be checked by using a market study, by reviewing comparable units advertised for rent, or with a note from the property owner verifying the comparability of charged rents to other units owned (for example, the landlord would document the rents paid in other units). It is up to the grantee to determine exactly what documentation is required in order to ensure that the rent reasonableness standard is met. Grantees are not required to use the rent reasonableness checklist referenced in the HPRP Notice, but it does present one way of documenting rent reasonableness, and HUD recommends that grantees use it or a similar one. For monitoring purposes, HUD will be looking to see that the grantee/subgrantee developed and followed a process to determine and document that the rent was reasonable and that the basis for the conclusion reached is supported by the evidence gathered. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Lease and Rent Requirements FAQ ID: 465 Will HUD be issuing sample Housing Assistance Payment (HAP) contracts to be used for short-term and medium term rental assistance similar to the HOME TBRA forms available on HUD's website? HPRP FAQs 91 June 2013

93 No, HUD is giving grantees the discretion to determine which documents to use under its local HPRP program. However, sample documents used by other communities are available in the HRE's TA Resource Database at Grantees and subgrantees are encouraged to review these documents to determine which they could adapt for their local program. Date Published: 4/24/2009 Topic: HPRP; Subtopic: Lease and Rent Requirements FAQ ID: 513 Under HPRP, may a program participant lease a unit with a legal sublease? (REVISED) HPRP financial assistance funds may only be spent on behalf of program participants where there is a written legal lease or occupancy agreement in place. A sublease is considered a legal lease and is acceptable, however, the grantee must ensure that the relationship between the sublessee and lessee is not in violation of the conflict of interest provisions outlined in the HPRP Notice (particularly in instances where an applicant is subleasing a room and the primary occupant is remaining in the unit). In cases where an applicant is subleasing from friends or a family, it is particularly important to remember the "but for" rule (i.e., if the applicant does not receive the assistance, will he/she literally end up on the street or in a shelter). This is an important consideration given the relationship between the two parties. Date Published: 6/10/2009 Topic: HPRP; Subtopic: Lease and Rent Requirements FAQ ID: 580 When does the rent reasonableness requirement apply? Grantees/subgrantees must determine and document rent reasonableness for all units for which HPRP rental assistance (including arrears) and/or security deposit assistance is being provided. The requirement applies whether homelessness prevention assistance or rapid re-housing assistance is provided (i.e. when participants are moving into units and when there is a current lease in place). If the rent for the unit does not meet the rent reasonableness standard, then HPRP funds may not be used to assist the household in that unit. Further, HPRP funds cannot be used to pay the rent up to the rent reasonable standard, while the tenant pays the remainder. However, an eligible household could receive HPRP assistance to relocate to another unit that does comply with rent reasonableness standards, and is ultimately more affordable to the household. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Lease and Rent Requirements HPRP FAQs 92 June 2013

94 FAQ ID: 726 Can HPRP funds be used to assist a unit that exceeds the Fair Market Rent? Fair Market Rents (FMRs) are not applicable under HPRP. As explained in the HPRP Notice, HPRP rental assistance may only be used to assist eligible households in units that meet rent reasonableness standards. Therefore, assistance may be provided for units that exceed the FMR as long as the rent meets the rent reasonableness standard. However, if the rent for the unit does not meet the rent reasonableness standard, then HPRP funds may not be used to assist the household in that unit (nor can HPRP funds be used to pay the rent up to the rent reasonable standard, while the tenant pays the remainder). However, in such instances, the household could receive assistance to relocate to another unit that does comply with rent reasonableness standards. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Lease and Rent Requirements FAQ ID: 727 Does a rent reasonableness determination have to be conducted for households living in Section 8 units or public housing? Grantees must remember that HPRP assistance cannot be provided to eligible individuals or families for the same period of time and for the same cost types that are being provided through another Federal, state, or local housing subsidy program. As such, HPRP may not be used to pay the tenant's portion of the rent payment when the household is receiving another rental assistance subsidy (even if the other subsidy is a shallow subsidy). However, in cases where HPRP is being used to assist an eligible household living in Section 8 or public housing with other types of assistance (arrears or a security deposit, as applicable), the grantee must document that the unit is in compliance with the rent reasonableness standard. Grantees should also remember that documenting compliance with the FMR is not enough. As explained in a separate FAQ, Fair Market Rents (FMRs) and rent reasonableness are two different concepts; FMRs do not apply under HPRP. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Lease and Rent Requirements FAQ ID: 878 Does the calculation of rent reasonableness need to include a utility allowance? The Rent Reasonableness Checklist and Certification form referenced in the HPRP Notice includes a utility allowance in the calculation for proposed gross rent. HPRP FAQs 93 June 2013

95 The Rent Reasonable Checklist is a sample form that is used across different housing programs, and as such, includes some concepts and terms that are not applicable to HPRP. Utility allowances and payment standards are both examples of concepts that are used under other HUD programs like HOME and Section 8 but are not directly applicable to HPRP. As explained in the Notice, HUD has specified that it is up to the grantee to determine exactly which documentation it will require in order to ensure that the rent reasonableness standard is met. This means that use of this specific checklist is not required. (Note: While utility allowances are not applicable under HPRP, there may be instances where a participant's monthly rent payment is inclusive of utilities. For information on determining rent reasonableness in such situations, please see the related FAQ on this topic.) Date Published: 7/21/2010 Topic: HPRP; Subtopic: Lease and Rent Requirements, Determining and Documenting Client Eligibility FAQ ID: 890 HUD has indicated that a client must have a written lease or occupancy agreement in place in order to receive HPRP assistance. In many cases, the lease has already expired but the applicant's name is on the lease and they have continued to rent the unit. Is it ok to provide assistance in this case? (REVISED) Arrears could be eligible, even though the lease is expired, if the expired lease gives the program participant an enforceable leasehold interest under state law and the agreement and rent owed are sufficiently documented by the owner's financial records, rent ledgers or canceled checks. In order to provide ongoing financial assistance, the expired lease must have a clause addressing the continuance of the agreement to a month to month arrangement unless State law dictates that the lease automatically continues under a month-to-month or annual arrangement until the lease is renewed or is otherwise terminated. If the lease does not contain such a clause and State law does not dictate a continuance, in order to confirm that the automatic renewal is current and still in place, a grantee must request either a current lease or a statement from the landlord confirming that the lease and the automatic renewal remain in force. Date Published: 7/1/2011 Topic: HPRP; Subtopic: Lease and Rent Requirements, Determining and Documenting Client Eligibility FAQ ID: 866 If a single individual is living in a two-bedroom apartment, the rent is reasonable for a two-bedroom unit, and he meets all eligibility criteria, can he be assisted? Or can he only be assisted if he moves to a one-bedroom unit? HUD has not established specific occupancy standards for HPRP, though grantees have the discretion to establish standards as part of their local program design. Assuming it is not prohibited by the grantee, a single individual living in a two-bedroom unit can be assisted. However, given that persons are only eligible for HPRP if they are HPRP FAQs 94 June 2013

96 homeless or at imminent risk of homelessness, the affordability of the unit is an important consideration. Because housing stability is the goal of the program, a case manager should discuss with the client whether the unit is the most appropriate for his needs and whether it will be affordable for him in the long term. If it is determined that the unit is not appropriate, HPRP funds could be used to help the client relocate to a more suitable unit. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Lease and Rent Requirements, Determining and Documenting Client Eligibility, Eligible Participants (Clients) FAQ ID: 433 Does a lease have to be in place in order to pay rental assistance? Is an oral lease acceptable? (REVISED 8/18/11) Each program participant receiving rental assistance must have a written lease for the rental unit, unless the assistance is solely for rental arrears. The program participant must be on the lease. The document must identify the payee (i.e., the individual and/or entity collecting rent), the HPRP program participant as the tenant, and the terms of the agreement (dates of tenancy, monthly amount due, etc.). The agreement must be current, signed by both parties and dated. A verbal/oral agreement is not sufficient for providing ongoing financial assistance. Note, however, that once a written lease/agreement is established, eligible program participants may receive assistance with future payments. Where the assistance is solely for rental arrears, an oral agreement may be accepted in place of a written lease, if the agreement gives the program participant an enforceable leasehold interest under state law and the agreement and rent owed are sufficiently documented by the owner s financial records, rent ledgers or canceled checks. Grantees/subgrantees are encouraged to work with the landlord and program participant to resolve arrears that cannot be documented, using other resources including negotiating a payment plan if possible. For information about providing legal assistance without a written lease, view the related FAQ. Date Published: 8/18/2011 Topic: HPRP; Subtopic: Lease and Rent Requirements, Eligible Activities/Costs - Financial Assistance FAQ ID: 460 Is the amount of rental assistance provided under HPRP based on the HOME TBRA program, where the household must pay 30% of its income for rent, or can their entire rent cost be subsidized? HUD is providing grantees with a great deal of flexibility in determining their local programs and adding any restrictions. The grantee may decide whether to subsidize the full rent of a program participant or only a portion, depending on local priorities and need. Date Published: 4/24/2009 HPRP FAQs 95 June 2013

97 Topic: HPRP; Subtopic: Lease and Rent Requirements, Eligible Activities/Costs - Financial Assistance FAQ ID: 570 Can grantees provide assistance to households in a rent-to-own or lease-in-place situation? Yes, as long as the individual would be homeless 'but for' the assistance and the full amount of the financial assistance is going towards rent or utilities (for example, no HPRP funds may be used for taxes or fees that may be associated with homeownership), a rent-to-own situation is permissible. Please be sure to document that the rent payment is not a mortgage payment as it would be in a lease purchase scenario because HPRP funds may NOT be used for payments that are associated with homeownership. Date Published: 8/14/2009 Topic: HPRP; Subtopic: Lease and Rent Requirements, Eligible Activities/Costs - Financial Assistance, Eligible Participants (Clients) FAQ ID: 1234 Per the FAQs, a written lease or documentation establishing tenancy must be in place to pay rental assistance for a household using HPRP funds. Is a written lease required in order to provide legal services? HPRP funds can be used to provide legal services only to assist an eligible household to remain in their housing. In such cases a written lease is not required but other written evidence of a valid pre-existing tenancy must be in the case files. For example, if there is an oral lease agreement in place, court documents could serve to document the household's tenancy; similarly, a case manager could review a landlord's rent ledger to confirm the amount of rent and terms of the oral lease agreement and make a note in the case file as documentation of tenancy. Please note that the same level of documentation of eligibility to receive HPRP assistance (the income and 'but for' criteria) is required no matter whether financial assistance or housing relocation and stabilization services are provided. Date Published: 12/17/2010 Topic: HPRP; Subtopic: Lease and Rent Requirements, Eligible Activities/Costs - Housing Relocation and Stabilization Services FAQ ID: 567 In a situation where there are two unrelated individuals on a lease - one who is eligible, and one who is not can a grantee assist the eligible individual? (REVISED) HPRP FAQs 96 June 2013

98 If two unrelated individuals are joint parties to a lease, a grantee must consider total household income to determine eligibility (i.e., either the whole household is eligible for assistance, or the whole household is not). In contrast, if two unrelated individuals share a unit and have (or are able to establish) separate lease agreements with the landlord, then the grantee would be able to determine eligibility for and provide assistance to one roommate independently since presumably one person's tenancy and participation in HPRP is not affected by the other. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Lease and Rent Requirements, Eligible Participants (Clients) FAQ ID: 1242 What are the occupancy standards under HPRP? There are no Federal occupancy standards under HPRP, though grantees may establish specific occupancy standards at the local level. Each grantee is responsible for determining (in accordance with local and Federal requirements) the best way to serve those in need with HPRP funds. This includes determining what is reasonable and appropriate with regard to occupancy. Additionally, per the habitability inspection requirements, households receiving HPRP financial assistance and moving into a different unit must be afforded adequate space and security for themselves and their belongings and an acceptable place to sleep. To determine what constitutes adequate space and security and an acceptable place to sleep, HUD defers to the standards establish by state and local law. The HPRP notice also requires the housing to comply with all applicable state and local housing codes, licensing requirements, and any other requirements in the jurisdiction in which the housing is located regarding the condition of the structure and the operation of the housing or services. Program participants receiving financial assistance to remain in an existing unit are not subject to the habitability inspection requirements, though again, the HPRP notice requires that all housing assisted under HPRP comply with applicable state and local housing codes. Date Published: 12/27/2010 Topic: HPRP; Subtopic: Lease and Rent Requirements, Housing and Lead Inspections FAQ ID: 574 Can grantees pay off a client's rental debt owed to a previous landlord if it enables the household to obtain new housing? And do inspection and rent reasonableness requirements apply? (REVISED) Grantees/subgrantees can pay up to six months of rental and utility arrears regardless of when they were incurred, provided that the existence of the arrears prevents the eligible participant from obtaining housing, and it is likely that the participant will be able to maintain the housing. All other arrears--e.g., credit card, car payments, medical HPRP FAQs 97 June 2013

99 expenses, cable, or phone bills--are considered bad debt and are not eligible expenses. The inspection and rent reasonableness requirements do not apply to arrears payments for a previous unit. Date Published: 7/21/2010 Topic: HPRP; Subtopic: Lease and Rent Requirements, Housing and Lead Inspections, Eligible Activities/Costs - Financial Assistance FAQ ID: 438 It appears that the Performance Reports will require grantees to report on "the number of jobs created and retained." What entity is responsible for creating the jobs and who are the potential employees to be hired? One of the requirements of the Recovery Act of 2009 is that jobs that are created and/or retained through the use of these funds be tracked and reported. For HPRP, this could be jobs created or retained at the grantee or subgrantee levels. For example, a subgrantee may need to hire three case managers to operate a new Homelessness Prevention program in a particular County. These three jobs will be reported as "created" through the use of HPRP funds. Date Published: 4/3/2009 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) FAQ ID: 469 Will there be new IDIS reporting requirements, other than the ones needed for ESG? If so, when will these requirements be published? The IDIS reporting requirements for HPRP differ somewhat from the IDIS reporting requirements for the Emergency Shelter Grants (ESG) program. Guidance for HPRP grantees is available on the HRE. Date Published: 4/24/2009 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) FAQ ID: 730 If I have already reported in FederalReporting.gov, must I also report in e-snaps? Yes. FederalReporting.gov is managed by the White House Office of Management and Budget (OMB), whereas e- snaps is managed by HUD. OMB is requiring all Recovery Act grantees to submit data common to all Recovery Act programs in FederalReporting.gov each quarter. In contrast, e-snaps collects HPRP-specific performance and HPRP FAQs 98 June 2013

100 expenditure data for HUD. Grantees MUST file reports with both systems EVERY quarter, until all grant funds are expended. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) FAQ ID: 732 I am a grantee. Can I have my subgrantees submit reports directly into e-snaps on my behalf? No. Grantees must aggregate all data from subgrantees and file only one report in e-snaps. Under no circumstances should subgrantees be submitting reports in e-snaps. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) FAQ ID: 733 I am a grantee, and I accidentally created multiple reports in e-snaps. How can I delete them? Once created, a report cannot be deleted. However, as long as it is not submitted, the system will ignore it and HUD will not receive it. If multiple reports were submitted, either for the grantee or for subgrantees, the grantee must create one correct report that compiles data for all subgrantees and name it such that a reviewer could easily identify it as the correct version. In such instances, grantees can also send a note through the Virtual Help Desk to inform HUD which report is the correct version. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) FAQ ID: 734 As a grantee, I will not receive all reimbursement requests from my subgrantees by the quarterly report deadline. By "expenditures during the reporting period," does HUD mean expenditures that we, as the grantee, have received and reimbursed for that quarter? Or does it mean all expenditures, whether they have been submitted or not? Per QPR instructions, the accounting method for financial reporting is left to grantees to determine. The grantee may base reporting either on their expenses (i.e., what they have paid) or on expenses incurred by the grantee and HPRP FAQs 99 June 2013

101 subgrantees (i.e., accrued expenses, but not yet paid). HUD recommends the latter and suggests that grantees ask subgrantees for expenses to date as of the end of the reporting period, even if subgrantees have yet to seek payment from the grantee. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) FAQ ID: 735 Does HUD expect that quarterly expenditures as reported in the QPR will actually be drawn down from IDIS by the time the report is submitted? In other words, will HUD be comparing draws in IDIS with the information reported in the QPR? The QPR requires grantees to report on the HPRP expenses incurred, whether or not the grantee has been reimbursed by IDIS. Grantees must draw down from IDIS at least quarterly (preferably before the quarterly reports are due), and are urged to draw down from IDIS monthly. HUD will monitor disbursements, but does not expect the draws in IDIS to match exactly what is reported in the QPR. HUD recognizes that due to differences in timing of draws and expenditures, the information in both systems could vary. However, if there are large differences between the amounts reported as drawn and expended between the two systems, HUD may contact the grantee. Grantees can use existing IDIS reports (e.g., the PR02 report) to monitor their commitments and expenditures. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) FAQ ID: 736 For reporting on FederalReporting.gov, what is the difference between a vendor and a subgrantee? The following definitions should be used for the purpose of HPRP reporting: - A grantee for HPRP is the legal entity to which the HPRP grant is awarded and that is accountable for the use of grant funds; grantee and recipient are synonymous. Each grantee is responsible for ensuring that all activities carried out under its grant comply with all requirements of the Notice, regardless of whether those activities are carried out by the grantee's subgrantee(s), vendor(s)/contractor(s), or its own employees. - A subgrantee/subrecipient for HPRP is a private, nonprofit organization or unit of general purpose local government (or a Public Housing Agency or other special purpose local government entity that has received a waiver from HUD to be a subgrantee of a metropolitan city or urban county) that receives funding through the HPRP grantee or subgrantee to carry out any portion of the HPRP program; it does not include an individual that is a beneficiary of the HPRP program. The terms and conditions of the Federal award are carried forward to the subgrantee. It is possible that a subgrantee for one award may also be a primary grantee of another Federal award provided directly from the Federal Government. Subgrantees that receive all or a portion of Recovery funding from HPRP FAQs 100 June 2013

102 a grantee may be delegated the responsibility by the grantee to report information into the reporting system at OMB guidance does not provide for such a delegation to vendors. Note that each subgrantee is responsible for ensuring that all activities carried out under its subgrant comply with the requirements of the Notice, whether those activities are carried out by the employees of the subgrantee or by any vendor(s)/contractor(s) of the subgrantee. - A vendor is defined as a dealer, distributor, merchant, or other seller providing a grantee or subgrantee with generally required goods or services that have been purchased by the grantee/subgrantee for the conduct of the Federal program (i.e., a vendor is a contractor selected by the grantee or subgrantee pursuant to the procurement requirements in 24 CFR part 84 or 85 to provide goods or services for HPRP). Vendors are not subject to the terms and conditions of the HPRP grant agreement, but they are subject to the terms and conditions of the contract between the grantee/subgrantee and vendor. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) FAQ ID: 737 The QPR/IPR asks for expenditures by type of Financial Assistance as well as by type of Housing Relocation and Stabilization Services. However, the 2009 HMIS Data Standards do not include HPRP expenditures. Are grantees required to provide expenditure amounts for HPRP services and assistance? As explained in the QPR/IPR Instructions, grantees may report expenses for HPRP services (Financial Assistance and Housing Relocation and Stabilization Services) based on HMIS data or by other accounting means as determined by the grantee. HMIS data elements were not specifically designed to provide for accounting and reporting of all HPRP expenditures to HUD. Thus, it is up to grantees to determine the most appropriate financial records upon which to generate financial information for the QPR. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) FAQ ID: 738 The QPR requires grantees to submit information both on households served and expenditures. What happens if the expenditure occurs at the end of one quarter, but the assistance is actually for the following quarter? It is possible that an assisted household and the expenditure for that household could appear in two different quarterly reports. For example, the grantee should report a participant as receiving HPRP rental assistance based on the "start date" and 'end date' entered in the participant's Financial Assistance Provided record in HMIS. If the grantee expended funds on December 29 but the household did not move into the unit and their lease did not begin until January 1, the household's start date is January 1 and the participant(s) would be reported in the April QPR (reporting on persons served in January March). Because HUD is allowing grantees to determine the accounting HPRP FAQs 101 June 2013

103 method for reporting HPRP expenses on the QPR, it is possible that the actual rental assistance expense would be reported in the January QPR if the check was issued and accounted for by the grantee on or before December 31. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) FAQ ID: 745 Does a rental arrears payment impact whether a client is reported as having received short-term or medium-term assistance? For example, would payment of 1-3 months be considered short-term assistance and 4-6 months be considered medium-term assistance? The QPR does not require grantees to differentiate between persons/households who receive short-term and medium-term rental assistance. However, grantees must still document the number of months of rental assistance provided, whether for arrears or current rent, to ensure participants receive no more than the maximum 18 months of total rental assistance. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) FAQ ID: 857 I am the only person at our agency with access to our HPRP reports in e-snaps. Can we provide additional staff members access? If so, what is the process? While HUD requires notification for changes to the Authorizing Official or the HPRP contact person identified in the Substantial Amendment, as long as a pre-existing user has access to the grantee's e-snaps applicant profile, grantees have the ability to add new users to their e-snaps profile directly -- without submitting a formal letter to HUD. For step by step instructions, see the Q5 Update beginning on page 4. A word of caution, while there is no limit to the number of users a grantee can have in e-snaps, HUD recommends linking only 2 or 3 users to the HPRP report, as providing more users with access can lead to reporting errors and a decrease in data reliability. Additionally, users added to a profile for the purpose of submitting the QPR/APR will also have access to any other forms that you create under that applicant profile in e-snaps. Date Published: 10/5/2010 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) HPRP FAQs 102 June 2013

104 FAQ ID: 861 I already submitted my final QPR, but I have discovered an error. Can I correct the error? Once a final report has been submitted, a grantee can only make edits if HUD opens the report on the back end and amends it back to the grantee. For this reason, HUD recommends that grantees wait to ensure all of their data is as complete and accurate as possible before submitting it. Grantees needing to have a final report amended back can submit a request to HUD through the Virtual Help Desk. Grantees should note that this can only be done during the data review period (i.e., until the 5th of the month following the preliminary due date). Once the data review period has ended, additional edits to the quarterly report are not possible. However, grantees do have an opportunity to correct errors in previous reports by updating grantto-date figures in subsequent reports. Date Published: 6/30/2010 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) FAQ ID: 697 If a household contains multiple people, but only one person directly received a service, how many persons served should be reported in the QPR? For example, if a household consists of one adult and one child, but only the adult participated in a case management session, how many people should be counted as receiving the service? How should unaccompanied individuals be counted? In the QPR and IPR, a person should be considered as receiving a service if anyone in the household received the service. If, as in the example above, a household consists of one adult and one child, but only the adult participated in a case management session, this would count as two people served and one household served. An unaccompanied individual should be counted as one person and one household. The report is intended to describe the number of people benefiting from the service, regardless of who directly participates in the activity. While only the adult directly participated in the service, the service benefited the entire household. Similarly, all persons in the household should be counted as served by financial assistance. In most cases, only one household member directly interacts with the service provider. If only that person is counted as receiving the service, then the total number of persons would almost always be equivalent to the total number of households, and the 'person' count would not be meaningful for determining the actual number of persons in households served. The count of total number of persons inclusive of all household member can be generated in multiple ways: (1) Grantees and subgrantees can specifically enter a service record for each member of the household enrolled in the program, regardless of whether the person received the service directly. (2) The software can automate the process of adding service records to all household members whenever one member receives the service. (3) When reports HPRP FAQs 103 June 2013

105 are generated, queries can automatically tally all members of a household whenever any household member is associated with a service record. The automated approaches can only be used if the other household members have the same household identification and housing status as the person directly interacting with the service provider, and if those other household members are actually enrolled in the program on the date in which the service was delivered. Date Published: 10/29/2009 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS), Collecting Client-Level Data (HMIS & Comparable Databases) FAQ ID: 746 According to the QPR Instructions, grantees have to report expenditures for each of the Housing Relocation and Stabilization Services subcategories (e.g., outreach and assessment, case management, housing search and placement) as well as by assistance type (prevention versus rapid re-housing). Does HUD expect case managers to track their hours at this level of detail? The housing status of each program participant is a mandatory data element that must be tracked for each participant at program entry. This field is used to classify all activities as either prevention or rapid re-housing assistance for purposes of the HPRP QPR and APR - i.e., clients with a Housing Status of 'literally homeless' at entry would be classified as receiving homeless assistance(rapid re-housing); clients with a Housing Status other than 'literally homeless' would be classified as receiving homelessness prevention assistance. For HPRP Housing Relocation and Stabilization Services, the intention is to record in HMIS whether a given program participant is provided one or more types of services. At a minimum, services provided must be recorded in HMIS once every three months. Grantees and subgrantees may record services provided data at more frequent intervals (e.g., monthly, daily). HUD allows grantees to identify and use an appropriate accounting system to record and report eligible HPRP expenditures. Grantees and subgrantees must follow OMB requirements related to allowable cost accounting as defined in OMB Circulars A-87 and A-122 (2 CFR parts 225 and 230) for eligible HPRP activities. Date Published: 1/6/2010 Topic: HPRP; Subtopic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS), Collecting Client-Level Data (HMIS & Comparable Databases) FAQ ID: 388 Do HPRP funds have a match requirement? No, grantees are not required to match HPRP funds with any other funding. Date Published: 3/20/2009 HPRP FAQs 104 June 2013

106 Topic: HPRP; Subtopic: Substantial Amendment Requirements and Process FAQ ID: 394 Where can I find the latest version of Form SF-424? (REVISED) Use the SF-424 posted online at: Date Published: 4/24/2009 Topic: HPRP; Subtopic: Substantial Amendment Requirements and Process FAQ ID: 396 Is the HPRP part of the Consolidated Plan process? Portions of the Consolidated Plan process related to the application and approval process for receiving HPRP funds do apply, as indicated in the Notice. Grantees must submit an amendment to the Consolidated Plan 2008 Action Plan in order to receive funds, and grantees are required to take public comment on it before finalizing it. However, this public comment period has been reduced to at least 12 days instead of 30 days as is normally required for a substantial amendment. Also, grantees are not required to report on HPRP in their Consolidated Annual Performance and Evaluation Report (CAPER), as the reporting requirements from Congress and OMB take the place of this. Date Published: 3/20/2009 Topic: HPRP; Subtopic: Substantial Amendment Requirements and Process FAQ ID: 445 Form does not have much space on it for narrative. Is the form itself considered the "substantial amendment" or should we write a longer, more narrative amendment and attach it to the form? Grantees are required to use the actual form (HUD-40119) posted on the HRE and on HUD's website. Since this form is in a Word format, grantees may enter as much information as needed to amend their Annual Action Plan appropriately. However, please be mindful of the maximum word guidelines. Date Published: 4/24/2009 Topic: HPRP; Subtopic: Substantial Amendment Requirements and Process HPRP FAQs 105 June 2013

107 FAQ ID: 447 How long does it generally take for subgrantees to be issued a DUNS number? Is there any available guidance to help subgrantees as they register to get a DUNS number? Please seek the following link regarding registration for a DUNS number: Date Published: 4/24/2009 Topic: HPRP; Subtopic: Substantial Amendment Requirements and Process FAQ ID: 448 When preparing our amendment, would we have to spell out how we are going to allocate the entire HPRP grant in that initial amendment? For example, if a grantee is receiving $1,000,000 in HPRP funds and wants to set aside $600,000 for utility deposit assistance and short/medium term rental assistance, but is unsure how they are going to allocate the remaining $400,000, would it be acceptable to state that the remaining funds will be used for other HPRP-eligible projects? The substantial amendment, which must be postmarked no later than May 18, 2009, requires grantees to indicate the estimated amount for each of the four activity types (financial assistance, housing relocation and stabilization services, data collection and evaluation, and administration) within the two program types (homelessness prevention and rapid re-housing). The budget in the substantial amendment does not require grantees to indicate estimated budgets at a more granular level. The total requested must match the total HPRP amount budgeted. Grantees will report their final allocations and subgrantee selections in the Initial Performance Report due in October Date Published: 4/24/2009 Topic: HPRP; Subtopic: Substantial Amendment Requirements and Process FAQ ID: 478 Can HPRP administrative funds be used to pay for technical assistance? Grantees were allowed to hire a contractor to help prepare their substantial amendment, which was an eligible preaward cost. Now that all grant agreements have been executed, grantees may use administrative funds to hire a consultant to assist with aspects of grant administration, including tasks related to the allocation of funds to subgrantees, program design, data collection and reporting, etc. Grantees may also hire consultants to develop and deliver training on policies and procedures that are specific to their local program design and implementation. HPRP FAQs 106 June 2013

108 Grantees may NOT use funds to hire a consultant or technical assistance provider to provide general training on HPRP. HUD hosted a series of regional HPRP workshops during May and June of 2009, webinars on reporting in December 2009, and will be providing additional resources to assist grantees throughout the three-year period of the program. Additionally, consultants and contractors should note that they may not develop and deliver general training on HPRP that has not been approved by HUD Headquarters. Date Published: 5/8/2009 Topic: HPRP; Subtopic: Technical Assistance, Eligible Activities/Costs - Administrative Costs HPRP FAQs 107 June 2013