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American Recovery and Reinvestment Act
      Homelessness Prevention and
       Rapid Re-housing Program


               HPRP
    Frequently Asked Questions

                         Sponsored by:
     Office of Special Needs Assistance Programs (SNAPS)
       U.S. Department of Housing & Urban Development
Purpose
2

    Discuss top 10 most frequently asked
    questions
    – Clarify requirements
    – Explain intent
    – Address misconceptions
1. Eligibility Criteria vs.
       Risk Factors
3


     What is the difference between
     eligibility criteria and
     risk/targeting factors?
Eligibility vs. Risk Factors
    continued
4

     Sample risk/targeting factors from the HUD Notice:
      – Sudden and significant loss of income
      – Sudden and significant increase in utility costs
      – Recent traumatic life event, such as death of a spouse, or
        recent health crisis that prevented the household from
        meeting its financial responsibilities
      – Homeless in last 12 months
      – Young head of household (under 25 with children or
        pregnant)
      – Current or past involvement with child welfare, including
        foster care
      – High overcrowding (the number of persons exceeds health
        and/or safety standards for the housing unit size)
Eligibility vs. Risk Factors
    continued
5

     Participant eligibility:
      – Do participants meet HUD’s minimum requirements?
     Targeting:
      – What target population will program serve?
      – Targeting decisions impact program design and
        program design decisions impact targeting
2. Stability and Eligibility
6


     Is an applicant required to have
     an income to be eligible for HPRP
     assistance?
3. Eligibility under Prevention
    vs. Rapid Re-housing
7

      Homelessness Prevention
       – Persons/households at imminent risk of losing
         current housing and will be literally homeless
         without (“but for”) HPRP assistance
       – BUT FOR = 1) no other housing options AND 2)
         no resources OR support networks to
         maintain/obtain housing
      Rapid Re-housing (Homeless Assistance)
       – Persons/households that are homeless per the
         HUD definition
Eligibility under Prevention vs
    Rapid Re-housing - Example
8


     Is a person living in a hotel eligible
     for assistance? If so, would they be
     served under the Prevention or
     Rapid Re-Housing category?
4. Identification Requirements
9

     For HPRP assistance, what forms of
     identification are acceptable? Must
     each adult member of the household
     show picture ID?

     Are applicants required to provide a
     Social Security Number in order to
     receive HPRP assistance?
5. Lease Requirements
10

      Does a lease have to be in place in
      order to pay rental assistance? Is an
      oral lease acceptable?

      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?
Lease Requirements continued
11

      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?

      Under HPRP, may a program
      participant have a legal sublease?
6. HPRP & Occupancy
     Standards
12

      Can HPRP assist a single individual in a
      two-bedroom apartment if the rent is
      reasonable for a two-bedroom unit and
      the client meets all eligibility criteria?
      Or can he only be assisted in a one-
      bedroom unit?
7. Combining HPRP and Other Types
     of Assistance (Cost Type Rule)
13

      If a participant is receiving rental
      assistance through another program,
      can they also receive HPRP assistance?

       – Can HPRP clients receive assistance in HOME or
         tax credit project?

       – Is assistance from a local charity, foundation, or
         church included in the cost-type rule?
8. Utility-Only Assistance vs Rent
     and Utility Assistance
14

      If a client has an eviction notice and
      meets all eligibility requirements but
      does not have a utility shut-off notice,
      can an agency provide both rent and
      utility assistance? Or is a shut-off
      notice always required to provide
      utility assistance?
9. Recertification
15


      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?
       – What if there is a break in assistance?
Recertification: Documentation
16


      What documentation is
      required at recertification?
      – If served under Prevention Assistance, is
        another eviction notice required?
      – If served under Rapid Re-housing, does
        client have to be literally homeless again?
10. Appeals Process for
     Applicants Denied Assistance
17


      Is there a specific process that
      must be used when an applicant
      is denied service and wants to file
      an appeal?
      – What about termination of assistance
        and/or services to program participants?
11. Indirect Cost
18


      Are indirect costs eligible? If so,
      how does a grantee/subgrantee
      charge those costs to the HPRP
      program?
11. Indirect Cost
19

      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 non-profit organizations) or OMB
      Circular A-87 (for local governments).
      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.
      Indirect costs charged to other 3 eligible activity
      types are not subject to the 5% cap.
11. Indirect Cost
20

      If an organization does not have an approved
      indirect cost rate, granteees/subgrantees may
      allocate a reasonable proportion of their indirect
      costs to the activity.
      Example: An HPRP subgrantee employs ten
      staff, four of which work full time on HPRP case
      management and service activities. They can
      charge 40% of monthly office lease/rent costs to
      the Housing Relocation and Stabilization Services
      category. As always, the grantee or subgrantee's
      plan for direct-charging indirect costs must be
      reasonable and supported by documentation.
11. Indirect Cost
21


      Can apply this policy retroactively, but
      not required to
      Subgrantees work with grantees
      Maintain documentation when
      applying indirect cost rates
      If you have budget changes as a result
      of this policy, submit a revised
      substantial amendment
22




     Common Issues
Rent Reasonableness &
        Moving Cost Assistance
23


     Rent Reasonableness ≠ FMRs
     Rent Reasonableness checks required
     for Prevention and Rapid Re-housing
     assistance
     Moving Costs must be reasonable and
     documented
Documentation,
             Documentation,
24           Documentation!
     Supporting documents for draws
     3-month re-certifications
     – Must meet all eligibility criteria
     – Use 2010 AMI:
       http://www.huduser.org/portal/datasets/il
       /il10/index.html
     Payment of arrears must not exceed 6
     months
Documentation,
             Documentation,
25           Documentation!
     Hotel/motel vouchers – remember, all
     3 criteria must be met
     Habitability standards
     Lead-based paint assessments
     – Must be completed for prevention and
       rapid re-housing assistance
26




     Questions

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6.3 Ask the Experts: HPRP Questions

  • 1. American Recovery and Reinvestment Act Homelessness Prevention and Rapid Re-housing Program HPRP Frequently Asked Questions Sponsored by: Office of Special Needs Assistance Programs (SNAPS) U.S. Department of Housing & Urban Development
  • 2. Purpose 2 Discuss top 10 most frequently asked questions – Clarify requirements – Explain intent – Address misconceptions
  • 3. 1. Eligibility Criteria vs. Risk Factors 3 What is the difference between eligibility criteria and risk/targeting factors?
  • 4. Eligibility vs. Risk Factors continued 4 Sample risk/targeting factors from the HUD Notice: – Sudden and significant loss of income – Sudden and significant increase in utility costs – Recent traumatic life event, such as death of a spouse, or recent health crisis that prevented the household from meeting its financial responsibilities – Homeless in last 12 months – Young head of household (under 25 with children or pregnant) – Current or past involvement with child welfare, including foster care – High overcrowding (the number of persons exceeds health and/or safety standards for the housing unit size)
  • 5. Eligibility vs. Risk Factors continued 5 Participant eligibility: – Do participants meet HUD’s minimum requirements? Targeting: – What target population will program serve? – Targeting decisions impact program design and program design decisions impact targeting
  • 6. 2. Stability and Eligibility 6 Is an applicant required to have an income to be eligible for HPRP assistance?
  • 7. 3. Eligibility under Prevention vs. Rapid Re-housing 7 Homelessness Prevention – Persons/households at imminent risk of losing current housing and will be literally homeless without (“but for”) HPRP assistance – BUT FOR = 1) no other housing options AND 2) no resources OR support networks to maintain/obtain housing Rapid Re-housing (Homeless Assistance) – Persons/households that are homeless per the HUD definition
  • 8. Eligibility under Prevention vs Rapid Re-housing - Example 8 Is a person living in a hotel eligible for assistance? If so, would they be served under the Prevention or Rapid Re-Housing category?
  • 9. 4. Identification Requirements 9 For HPRP assistance, what forms of identification are acceptable? Must each adult member of the household show picture ID? Are applicants required to provide a Social Security Number in order to receive HPRP assistance?
  • 10. 5. Lease Requirements 10 Does a lease have to be in place in order to pay rental assistance? Is an oral lease acceptable? 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?
  • 11. Lease Requirements continued 11 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? Under HPRP, may a program participant have a legal sublease?
  • 12. 6. HPRP & Occupancy Standards 12 Can HPRP assist a single individual in a two-bedroom apartment if the rent is reasonable for a two-bedroom unit and the client meets all eligibility criteria? Or can he only be assisted in a one- bedroom unit?
  • 13. 7. Combining HPRP and Other Types of Assistance (Cost Type Rule) 13 If a participant is receiving rental assistance through another program, can they also receive HPRP assistance? – Can HPRP clients receive assistance in HOME or tax credit project? – Is assistance from a local charity, foundation, or church included in the cost-type rule?
  • 14. 8. Utility-Only Assistance vs Rent and Utility Assistance 14 If a client has an eviction notice and meets all eligibility requirements but does not have a utility shut-off notice, can an agency provide both rent and utility assistance? Or is a shut-off notice always required to provide utility assistance?
  • 15. 9. Recertification 15 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? – What if there is a break in assistance?
  • 16. Recertification: Documentation 16 What documentation is required at recertification? – If served under Prevention Assistance, is another eviction notice required? – If served under Rapid Re-housing, does client have to be literally homeless again?
  • 17. 10. Appeals Process for Applicants Denied Assistance 17 Is there a specific process that must be used when an applicant is denied service and wants to file an appeal? – What about termination of assistance and/or services to program participants?
  • 18. 11. Indirect Cost 18 Are indirect costs eligible? If so, how does a grantee/subgrantee charge those costs to the HPRP program?
  • 19. 11. Indirect Cost 19 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 non-profit organizations) or OMB Circular A-87 (for local governments). 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. Indirect costs charged to other 3 eligible activity types are not subject to the 5% cap.
  • 20. 11. Indirect Cost 20 If an organization does not have an approved indirect cost rate, granteees/subgrantees may allocate a reasonable proportion of their indirect costs to the activity. Example: An HPRP subgrantee employs ten staff, four of which work full time on HPRP case management and service activities. They can charge 40% of monthly office lease/rent costs to the Housing Relocation and Stabilization Services category. As always, the grantee or subgrantee's plan for direct-charging indirect costs must be reasonable and supported by documentation.
  • 21. 11. Indirect Cost 21 Can apply this policy retroactively, but not required to Subgrantees work with grantees Maintain documentation when applying indirect cost rates If you have budget changes as a result of this policy, submit a revised substantial amendment
  • 22. 22 Common Issues
  • 23. Rent Reasonableness & Moving Cost Assistance 23 Rent Reasonableness ≠ FMRs Rent Reasonableness checks required for Prevention and Rapid Re-housing assistance Moving Costs must be reasonable and documented
  • 24. Documentation, Documentation, 24 Documentation! Supporting documents for draws 3-month re-certifications – Must meet all eligibility criteria – Use 2010 AMI: http://www.huduser.org/portal/datasets/il /il10/index.html Payment of arrears must not exceed 6 months
  • 25. Documentation, Documentation, 25 Documentation! Hotel/motel vouchers – remember, all 3 criteria must be met Habitability standards Lead-based paint assessments – Must be completed for prevention and rapid re-housing assistance
  • 26. 26 Questions