HEARTH Act & The Definition of Homeless Division of Housing, 2013 Agenda History & Background Test your knowledge! HUD regulation: Definition of Homeless Documentation Requirements Answers & Scenarios Lunch Maggie & Jennifer Kate & Adam ETH Grant Application 1:1 with Tanya
History & Background 1983: First Federal task force on homeless was created. Purpose was to provide information to localities on how to obtain surplus federal property. 1986: Congress passed only a few components of the proposed Homeless Persons Survival Act. The Homeless Eligibility Clarification Act removed permanent address requirements and other barriers to existing programs like SSI, AFDC, Veteran, Food Stamps, Medicare. The Homeless Housing Act created Emergency Shelter Grant program and transitional housing demo program.
1987: Urgent Relief for the Homeless Act was introduced. Signed into law on July 22, 1987 by President Reagan. Renamed McKinney-Vento Homeless Assistance Act (in 2000). McKinney-Vento Homeless Assistance Act (1987) The first major federal legislative response to homelessness. Consisted of 15 programs providing a range of services. Such as: Interagency Council of the Homeless Emergency Food & Shelter Program
ESG, SHP, Section 8 Mod. Rehab. SRO Community Mental Health Services block grant Educational programs for homeless youth Amended 4 times 1988: Minor changes focusing on distribution of funds 1990: Created Shelter Plus Care program Community Mental Health Service amended and renamed Projects for Assistance in Transition from Homelessness (PATH) 1992:
Creation of Safe Havens Creation of Rural Homeless Housing Assistance 1994: Amended the Education of the Homeless Children and Youth program and Surplus Property Program 2009 Because far too many Americans go homeless on any given night, this bill provides comprehensive new resources for homeless Americans. Division A -President Obama, May 20, 2009- Helping Families Save Their Homes Act
President Obama signed into law on May 20, 2009 Became Public Law 111-22 Division B HEARTH Act Homeless Emergency Assistance and Rapid Transition to Housing Reauthorizing and amending already existing legislation, McKinney-Vento Homeless Assistance Act Purpose of the HEARTH Act To codify in Federal law the Continuum of Care planning process as a required and integral local function necessary to generate the local strategies for ending homelessness
To establish a Federal goal of ensuring that individuals and families who become homeless return to permanent housing within 30 days To provide clarification on the following terms: homeless, homeless individual, homeless person, and homeless individual with a disability CoC Program: Overview of the Interim Rule and FY 2012 Competition Webinar, July 2012 HUD & the Federal Strategic Plan According to Ann Oliva (Director, HUD Office of Special Needs Assistance Programs): It is important to note that HUD is a key partner in
the implementation of Opening Doors, the Federal strategic plan to prevent and end homelessness. The goals set forth in the plan help to guide the policies that are reflected in the regulation itself That is, when we look at where we want to spend our money we look to the federal strategic plan to understand how funds should be targeted at the national and local level. CoC Program: Overview of the Interim Rule and FY 2012 Competition Webinar, July 2012 Opening Doors: Federal Strategic Plan to Preventing and Ending Homelessness Opening Doors four major goals: End chronic homelessness by 2015 End veteran homelessness by 2015 End family & youth homelessness by 2020 Set a path to ending all homelessness
The U.S. Interagency Council on Homelessness (ICH) is tracking the progress through HUDs annual point-in-time (PIT) data. To inform budgeting & planning, HUD has 3 internal measures designed to track Rapid Re-housing, Permanent Supportive Housing, and Affordable Housing performance. The Federal Strategic Plan is also the policy driver for the NOFA. The underlying assumption in meeting the goals for the Federal Strategic Plan is that we are placing people into the right housing and services in order to meet their needs. Website: http://www.usich.gov/opening_doors/ Funding of HEARTH
To fully implement the HEARTH legislation, it would cost over $4 billion. In FY2012, HUD requested approximately $2.3 billion to implement most aspects. Congress scaled back the request even further As a result, in FY2013, HUD intends to: Tailor specific, existing programs; Implement innovative strategies for engagement; Expect that homeless individuals & families will utilize mainstream resources and benefits more often. HUDs Homeless Assistance Overview of FY 2012 Funding and HEARTH Update Webinar, July 2012 The Paradigm Shift
Congress changing perspective on the types of projects being renewed and the need for strategic thinking Recent House Appropriations Report: It is not the committees intention to maintain an entitlement program for ailing and inflexible service providers. The Committee reminds providers in the Continuum of Care that these funds are intended to assist and house the homeless as effectively and efficiently as possible. HUDs Homeless Assistance Overview of FY 2012 Funding and Update Webinar, July 2012 HEARTH
Then and Now ESG It was originally called The Emergency Shelter Grant. Now, it is called The Emergency Solutions Grant. CoC It was originally comprised of 3 different homeless assistance programs: Supportive Housing Program (SHP), Shelter Plus Care, and Section 8 Mod. Rehab. SRO. Now, the 3 have been consolidated into, The Continuum of Care Program. Together These regulations were intentionally designed to allow and require
ESG recipients and HUD CoC-funded programs to coordinate planning and service delivery across the HUD CoCs geographic area. HUD & the Implementation of HEARTH Once HEARTH was signed into law, HUD developed these 6 sets of regulations to implement the legislation. Emergency Solutions Grant (ESG) Program Published on December 5, 2011 Renamed, broadened, and added activities Continuum of Care Program Consolidated 3 programs Supportive Housing, Shelter Plus Care, and Section 8 Mod. Rehab - into 1program Conforming Amendments to the Consolidated Plan Published on December 5, 2011
Homeless Management Information Systems (HMIS) Proposed on December 9, 2011 Rural Housing Stability Program Replace the Rural Homelessness Grant program And . . . The Homeless Definition Homeless Definition 4 Categories Category 1 Literally homeless individuals and families Category 2
Individuals and families who will imminently (within 14 days) lose their primary nighttime residence with no subsequent residence, resources, or support networks Category 3 Unaccompanied youth or families with children and youth who meet the homeless definition under another federal statute and 3 additional criteria Category 4 Individuals and families fleeing or attempting to flee domestic violence with no subsequent residence, resources, or support networks Test Your Knowledge!
Homeless Definition 4 Categories Category 1 Literally homeless individuals and families Category 2 Individuals and families who will imminently (within 14 days) lose their primary nighttime residence with no subsequent residence, resources, or support networks Category 3 Unaccompanied youth or families with children and youth who meet the homeless definition under another federal statute and 3 additional criteria
Category 4 Individuals and families fleeing or attempting to flee domestic violence with no subsequent residence, resources, or support networks Category #1: Literally Homeless All 3 circumstances include an individual or family who lacks a fixed, regular, adequate nighttime residence. CIRCUMSTANCES: Unsheltered
Sheltered Exiting an Institution Category #1 Circumstance #1: Unsheltered Persons sleeping in a place not designed for or ordinarily used as a regular sleeping accommodation Examples include: car, park, abandoned building, bus or train station, airport, camping ground Category #1 Circumstance #1: Unsheltered DOCUMENTATION: Only one form of documentation is required. They are listed in in order of preference. Third Party written examples:
HMIS street outreach service record Homeless Certification/written referral from local law enforcement or emergency medical service agencies Street outreach worker observation, documented Observation and certification of the outreach worker. Self-Certification of Homelessness (if Third Party documentation not obtainable) Category #1 Circumstance #2: Sheltered Persons living in a supervised shelter designated to provide temporary living arrangements. Shelters* can be publicly or privately operated. Includes:
Emergency/ Congregate Shelters Hotel/Motel Vouchers *HEARTH Statutes define the emergency shelter as follows: Any facility, the primary purpose of which is to provide a temporary shelter for the homeless in general or for specific populations of the homeless and which does not require occupants to sign leases or occupancy agreements. Category #1 Circumstance #2: Sheltered Homeless DOCUMENTATION Only one form of documentation is required. They are listed in in order of preference. Third Party written examples: HMIS shelter stay record Referral/Certification from another shelter Shelter sign-in
Self-Certification of Homelessness (only if third party documentation not obtainable) Category #1 Circumstance #3: Exiting an Institution Persons who are exiting an institution, such as jail or hospital, if the following two conditions are true: CONDITIONS: 1. Length of stay is 90 days or less, and 2. Unsheltered or in emergency shelter prior to entry Category #1 Circumstance #3: Exiting an
Institution CONDITION #1: Length of Stay DOCUMENTATION Only one form of documentation is required. They are listed in in order of preference. 3rd party written Discharge Paperwork Written Referral 3rd party oral statement from institution, certified by case worker or intake staff. Documentation must indicate less than 90 days by either specifying entry/exit dates or the specific duration of stay. Category #1 Circumstance #3: Exiting an Institution CONDITION #2: Homelessness Status Prior to Entry DOCUMENTATION
Only one form of documentation is required. They are listed in in order of preference. 3rd Party written records available may include: HMIS shelter stay/street or outreach service record Homeless certification or written referral from another agency Self-Certification of Homelessness (only if third Party documentation not obtainable) Category #2: Imminent Risk of Homelessness DEFINITION
The primary nighttime residence may be housing they own, rent, live in without paying rent or sharing with others, or it can be a room in a hotel/motel that is not paid for by federal/state/local program or by charitable organizations. Category #2: Imminent Risk of Homelessness CIRCUMSTANCES Client/ family is the tenant or lease-holder. Client/ family staying in a hotel or motel paid for by self and they lack of financial resources to maintain tenancy.
Client/ family staying with friends or family and they are being kicked out: Category #2: Imminent Risk of Homelessness CONDITIONS 1. They will imminently lose their primary nighttime residence within 14 days. some evidence that they are no longer allowed to stay where they are staying 2. There is no other place they can go without help. 3.
They lack resources or support networks needed to obtain other permanent housing. Category #2: Imminent Risk of Homelessness CONDITION #1: They will imminently lose their primary nighttime residence within 14 days. DOCUMENTATION: If client/ family is tenant or lease-holder (must be 3rd Party) Court Order to leave clearly indicating 14 days or less; or A legal Quit or Cure Notice If staying in a hotel or motel paid for by self and lack of financial resources to maintain:
Self-certification, supported by other documentation when practical or appropriate If staying with friends or family and are being kicked out: A letter from owner or renter with whom the individual or family may be staying stating that the individual is no longer allowed to stay and why & Certification from the intake staff that reasonable effort was made to keep the individual in the unit Category #2: Imminent Risk of Homelessness CONDITION #2: There is no other place they can go without help. CONDITION #3: They lack resources or support networks needed to obtain other permanent housing.
DOCUMENTATION: Self-certification, supported by other documentation when available Category #3: Homeless by Other Federal Statutes DEFINITION Unaccompanied youth under 25 or families with children and youth who do not otherwise qualify as homeless, but who do qualify in other federal statutes. Category #3: Homeless by Other Federal Statutes CONDITIONS:
1. Meet homeless definition under another federal statute 2. No lease, ownership interest, occupancy agreement in permanent housing during preceding 60 days 3. Persistent instability two or more moves in preceding 60 days 4. Expected to continue instability for an extended period of time because of special needs or barriers Category #3: Homeless by Other Federal Statutes SPECIAL NEEDS: Chronic physical health or mental health conditions
Substance addiction Histories of domestic violence or childhood abuse (including neglect) Presence of a child or youth with a disability BARRIERS TO EMPLOYMENT Lack of a high school degree or GED Illiteracy History of incarceration History of unstable employment Category #3: Homeless by Other Federal Statutes CONDITION #1: Meet homeless definition under another federal statute DOCUMENTATION
Must have 3rd Party verification written only Must be from agency administering the applicable federal program May be in the form of homeless certification or letter from provider Category #3: Homeless by Other Federal Statutes CONDITION #2: No lease or any ownership interest or occupancy agreement at any time during the last 60 days. DOCUMENTATION Certification by the individual or head of household, and any available supporting documentation of no permanent housing in last 60 days. CONDITION #3: Experienced two or more moves during the preceding 60 days. DOCUMENTATION Certification by the individual or head of household, and any available
supporting documentation, that (s)he has moved two or more times in the past 60 days. Category #3: Homeless by Other Federal Statutes CONDITION #4: Homelessness is expected to continue because of special needs or two barriers to employment DOCUMENTATION Special Needs Written diagnosis from professional licensed by State to diagnose and treat condition NOTE: If documentation of disability is not immediately available, and intake observation confirmed by written diagnosis from licensed professional within 45 days is acceptable . Barriers to Employment Employment records, Department of Correction records, Literacy,
English proficiency tests, Other reasonable documentation Category #4: Fleeing or Attempting to Flee Domestic Violence DEFINITION Persons fleeing or attempting to flee domestic violence, dating violence, sexual assault, stalking, or other dangerous or life threatening condition. Category #4: Fleeing or Attempting to Flee Domestic Violence CONDITIONS 1. Violence occurred either: o in the persons primary nighttime residence; or o makes the person afraid to return to their primary
nighttime residence. 2. Person has no identified subsequent residence. 3. Person lacks the resources & support networks needed to obtain other permanent housing. Category #4: Fleeing or Attempting to Flee Domestic Violence CIRCUMSTANCES 1. A victim services provider
2. An agency that is not a victim services agency and where the clients safety may be jeopardized 3. An agency that is not a victim services agency and where the clients safety is not in jeopardy In NO case should one put someones safety in jeopardy in an attempt to get 3rd Party documentation. Category #4: Fleeing or Attempting to Flee Domestic Violence CIRCUMSTANCE #1: a victim services provider DOCUMENTATION
An oral statement by the individual or head of household seeking assistance which states: they are fleeing; they have no subsequent residence; and they lack resources. That the oral statement was given must then be documented by a signed self-certification or a signed certification by the intake worker. Category #4: Fleeing or Attempting to Flee Domestic Violence CIRCUMSTANCE #2: an agency that is not a victim services agency and where the clients safety may be jeopardized DOCUMENTATION
An oral statement by the individual or head of household seeking assistance which states: they are fleeing; they have no subsequent residence; and they lack resources. That the oral statement was given must then be documented by a signed self-certification or a signed certification by the intake worker. Category #4: Fleeing or Attempting to Flee Domestic Violence CIRCUMSTANCE #3: an agency that is not a victim services agency and where the clients safety is not in jeopardy DOCUMENTATION 3rd Party documentation or certification by the individual or head
of household seeking assistance that they are fleeing violence; & Certification by the individual or head of household that no subsequent residence has been identified; & Self-certification or other written documentation, that the individual or family lacks the financial resources and support networks to obtain other permanent housing Eligibility by Component (Emergency Solutions Grant) Street Emerg Outreac . h Shelte
r Category #1 Literally Homeless X (a) X Rapid Rehousing Homeles s Preventi on X (b) Category #2 Imminent Risk of
Homeless X X (b) Category #3 Under other Federal Statute X X (b) (a) Must serve persons sleeping in a place not designed forXor ordinarilyXused
Category #4 X X (b) (b) as a regular sleeping accommodation Flee or attempt to flee DV (b) Must only serve participants with annual income at or below 30% of CMI. Eligibility by Component (Continuum of Care Program) Supporti ve Service Only (SSO)
Safe Transition Haven al Housing Category #1 Literally Homeless X Category #2 Imminent Risk of Homeless X X X (a) X (a)
Category #3 Under other Federal Statute X (b) X Category #4 X X (a) Must receive prior HUD approval to serve
this category Flee or attempt to flee DV (b) Additional limitations on eligibility within Category 1 (see Continuum of Care Program Interim Rule) Permane nt Supporti ve Housing X (b) X The Basics of Documentation Overview
According to Ann Oliva (Director, HUD Office of Special Needs Assistance Programs): The HEARTH Act didnt actually require that the Homeless definition rule be published with a set of documentation requirements. However, we [HUD] felt it was important to include them in the rulefor a couple of reasons. The first is, the law is somewhat complex in that there is an overlap between the definition of at-risk of homelessness and the definition of homelessness. We have never had that kind of overlap before . . .The second issue that many of you may or may not know is [that] documentation of eligibility is really the number one finding that we [HUD] have across the board when we do monitoring. That is, it is the number one reason that we ask people to repay grant money. Determining Homeless and At-Risk Status, Income, and Disability Webinar (December 20, 2011) HUD & Documentation Requirements
According to Ann Oliva (Director, HUD SNAPS Office): These programs can really only serve those that are defined as homeless because we have more people who experience homelessness at any given point in time during the year than we actually have beds. So we want to first ensure that all of our programs are being used for the purpose that was intended by Congress which is to serve people who are homeless. And we want to make sure our resources are used in the most efficient and effective way possible. So that we are getting at our overall goal of preventing and ending homelessness. HUD has never really written down the specific kinds of details that we were expecting to see in your files. We urge you to document your efforts to get the documentation, understand how people are presenting in the case files, so that when we come to monitor we can understand what you tried to do. Homeless Status: Recordkeeping Requirements Webinar, May 2012 HUD Suggested Tips & Recommendations
Adopt checklists that reflect preferred order Incorporate guidance and examples Have staff check for existing documentation e.g. HMIS records or discharge paperwork Create forms for tracking and documenting due diligence In various places HUD states its recommendation for the use of standardized forms Creating clearly labeled sections, fill-in-the-blank, for including relevant details and certifications HUD will not be creating these standardized forms.
Instead, HUD expects this to occur on the local level. When developing policies & procedures . . . The written policies and procedures must: Require intake staff to document: Evidence gathered as part of the intake/screening process for ALL persons seeking assistance Not just those deemed eligible for assistance If a person is determined ineligible, the documentation in their case file must reflect reasons related to eligibility Evidence relied upon to establish and verify Homeless status Be consistent with recordkeeping requirements & reflect HUDs preferred order
HUDS Preferences 1. 3rd Party (written) includes already available documents 2. 3rd Party (oral) Statements recorded by intake staff from the 3rd party 3. Intake Observation 4. Self-certification Affidavit or statement provided by the potential
program participant 2 Exceptions The lack of 3rd Party documentation should not prevent access to and assistance with: Emergency Shelter Street outreach services Victim Services The regulations make specific provisions related to documenting housing status of individuals/families fleeing or attempting to flee domestic violence. 3rd Party documentation is only required if the agency providing the services is not a victim service provider. Additionally, providers should not attempt to obtain 3 rd Party documentation if the safety of the family or the
individual is jeopardized in any way. 3rd Party Documentation Written letters/Referrals from 3rd parties Official communication (issues on agency stationary or program template) Signed and dated by appropriate 3rd party representative Additional standards depend on category and circumstance of the Homeless Definition category being used Recorded Oral Statements Statements made by 3rd party to intake staff and intake staff records into the case file Clear as to who made the statement, when the statement was made, and what the 3rd party is saying
Certify Sign and date as true and complete by intake staff Intake Observation Recorded intake staff observations Intake staff documents their own observations and assessments Certify Sign and date as true and complete by intake staff Self-certification Individual or Head of Household Statement Written statements certified (signed and dated) as true and complete by the potential program participant
Regulations specify when oral statements can be used Used only as the last resort & only after efforts are made to obtain 3rd party documentation Exceptions include: Those fleeing or attempting to flee violence Those in need of emergency shelter Due Diligence Recorded Intake Staff Efforts Describe efforts to obtain 3rd party documentation in the case file May include phone logs, fax transmittals, email correspondence, copies of certified letters, etc. Describe circumstances so that an outside 3rd
party [HUD] would understand why 3rd party documentation was unable to be obtained Outcome of effort, including obstacles encountered Certified by intake staff as true and complete Signed and dated Answers & Scenarios Resources Determining Homeless and At-Risk Status, Income, and Disability Webinar (December 20, 2011) https://www.onecpd.info/resource/1953/determining-homeless-and-at-risk-status-income-and-disabilitywebinar/ Homeless Definition Final Rule https://www.onecpd.info/resources/documents/HEARTH_HomelessDefinition_FinalRule.pdf Homeless Status: Recordkeeping Requirements Webinar (May 2012) https://www.onecpd.info/resource/2016/homeless-status-recordkeeping-requirements-webinar/
The Homelessness Definition and Eligibility for SHP, SPC, and ESG (May 2012) https://www.onecpd.info/resources/documents/HomelessDefEligibility%20_SHP_SPC_ESG.pdf Desk Guide and Program Requirements for 2012-13 ETH http://doa.wi.gov/docview.asp?docid=9992&locid=173 Checklist Checklist Checklist Checklist Homelessness Prevention http://doa.wi.gov/docview.asp?docid=9892&locid=173 Rapid Re-Housing http://doa.wi.gov/docview.asp?docid=9893&locid=173 Shelter http://doa.wi.gov/docview.asp?docid=9895&locid=173 Street Outreach http://doa.wi.gov/docview.asp?docid=9894&locid=173
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