U S Department of Housing and Urban Development_HPRRPMasterpiece on the Mississippi
TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: City of Dubuque Homelessness Prevention and Rapid Re- Housing
Program
DATE: September 2, 2010
The City of Dubuque has received the results of an evaluation by the U.S. Department
of Housing and Urban Development of the City of Dubuque Homelessness Prevention
and Rapid Re- Housing Program that is carried out for the City by Project Concern.
Three areas of improvement were noted and the City will respond within the 30 day time
limit.
Mic ael C. Van Milligen
MCVM:jh
Attachment
cc: Barry Lindahl, City Attorney
Cindy Steinhauser, Assistant City Manager
David Harris, Housing and Community Development Department Director
Dubuque
hltd
AN- AmelcaCity
liulr
2007
Honorable Roy Buol
City Hall
50 West 13 Street
Dubuque, IA 52001 -4864
Dear Mayor Buol:
An evaluation of the City of Dubuque Homelessness Prevention and Rapid Re- Housing
Program (HPRP) was conducted on August 2 — 5, 2010, by Ms. Kim Radice. The purpose of this
review was to examine the city's HPRP activities for compliance with program and project
requirements.
As a result of the review, there were three findings and one concern. They are identified
with appropriate corrective actions in the enclosure.
HUD staff would like to thank the City of Dubuque and Project Concern staff for their
cooperation and assistance during the review. The courtesies extended by Aggie Tauke and
Jenny Manders were appreciated.
Please respond within 30 days of the date of this letter. Your response should be sent to
me at the Omaha Field Office. If further information is necessary regarding this letter, please
contact Ms. Kim Radice at (402) 492 -3190.
cc: David Harris
VI ' 8ftricii a
80410 s: A410
61:110 cz 9nn OL
OEAGCAd
U.S. Department of Housing and Urban Development
Omaha Field Office
Edward Zorinsky Federal Building
1616 Capitol Avenue, Suite 329
Omaha, Nebraska 68102 -4908
August 24, 2010
Sincerely,
,17‘
Patricia M. McCauley
Director, Community Planning &
Development Division
City of Dubuque HPRP
Ms. Radice reviewed 8 client files and Ms. Garner reviewed 2 client files (2 past and 8 current)
at Project Concern for compliance with HPRP rules and regulations. Files were reviewed for;
homelessness and income documentation, income calculations, prior intake determination, rent
reasonableness, housing inspections, period of assistance, and case management. This review
also included the agency's written termination policy and procedures.
Finding #1: Source documentation was incomplete and lacked staff signatures and dates on
forms.
Finding #2: Files were missing or had improper homeless documentation.
2
Condition: HUD staff noted through file reviews that source documentation in client files was
incomplete. Some issues noted were; staff affidavits, Intake and Rapid Re- housing application
documentation forms were missing the Supervisor's signature and dates, City inspection forms
were incomplete, two files were missing the unit inspection form and none of the files had
income calculation worksheets. There were no case notes on determining type, level and
duration of assistance, one file did not have head of household filled out on the form and one
client did not sign the privacy consent form.
Criteria: The HPRP Notice Section IV. A., & V.G. states that grant funds must be used for
eligible activities. There are four categories of eligible activities; financial assistance, housing
relocation and stabilization services, data collection and evaluation and administrative costs.
Assistance should be focused on housing stabilization, linking program participants to
community resources and mainstream benefits, and helping them develop a plan for preventing
future housing instability. Grantee programs should therefore ensure that there is a clear process
for determining type, level, and duration of assistance for each program participant. Each
grantee and subgrantee must keep any records and make any reports (including those pertaining
to race, ethnicity, gender, and disability status data) that HUD may require within the timeframe
required.
Cause: Project Concern (subrecipient) staff was not properly trained in file maintenance for the
Homeless Prevention and Rapid Re- Housing Program and lacked attention to detail in
completing forms.
Effect: Without adequate oversight, the City cannot ensure that the HPRP program requirements
are being carried out as directed under the HPRP Notice dated March 19, 2009.
Corrective Action: Submit a written plan describing how the City will ensure that the
subrecipient is trained on HPRP documentation requirements and adequate client file
recordkeeping.
e. Victims of domestic violence.
3
Condition: One client file did not have proper homelessness documentation. It contained a
letter from Project Concern (the subrecipient) not the homeless shelter where this person was
staying and was not signed by the client. Two client files contained homeless verifications
however; the forms were not completed. One file had the form in the file, however; it was not
completed or dated. Also, there was no evidence of an eviction notice or other documentation
stating this client was homeless or would become homeless without this assistance.
Criteria: The HPRP Notice Section IV D. 1., 2. 3, 4 & V.G. — requires when establishing local
programs, grantees should consider how their programs will identify eligible program
participants and meet their needs as intended by the Recovery Act. Grantees should consider
serving two eligible populations with HPRP funds: persons who are still housed but at risk of
becoming homeless and persons who are already homeless. Grantees are responsible for
verifying and documenting the individuals' risk of homelessness that qualifies them for receiving
rental assistance. Rapid re- housing assistance is available for persons who are homeless
according to HUD's definition. Individuals and families who meet one of the following criteria,
along with the minimum requirements established paragraph 2 of this section, are eligible under
the rapid re- housing portion of HPRP:
a. Sleeping in an emergency shelter;
b. Sleeping in a place not meant for human habitation, such as cars, parks, abandoned
buildings, streets /sidewalks;
c. Staying in a hospital or other institution for up to 180 days but was sleeping in an
emergency shelter or other place not meant for human habitation (cars, parks, streets,
etc.) immediately prior to entry into the hospital or institution;
d. Graduating from, or timing out of a transitional housing program; and
Each grantee and subgrantee must keep any records and make any reports (including those
pertaining to race, ethnicity, gender, and disability status data) that HUD may require within the
timeframe required.
Cause: Project Concern's case managers and Coordinator were not completing homeless
verification forms and did not have proper homeless documentation from some of the clients
prior to receiving HPRP funds.
Effect: Ineligible clients could be receiving assistance from the HPRP without proper
homelessness documentation and the City may be required to reimburse the HPRP program.
Corrective Action: Submit a written plan describing how the City will ensure that required and
proper homeless documentation is received and completed for each client. Please provide a copy
of the City's next HPRP monitoring visit of this subgrantee. Please submit evidence that the
4
clients at 1718 '/2 White Street, 2459 Jackson Street and 2666 Owen Court #10, were eligible to
receive HPRP assistance.
Finding #3: No income eligibility calculation worksheets were found in client files.
Condition: Client files did include; third party verification, anticipated income and budget
figures, however, there were no income eligibility calculations worksheets in any of the files to
show that the client qualified for assistance in accordance with the HPRP notice.
Criteria: The HPRP Notice Section IV, D., 2 & V.G. states, in order to receive financial
assistance or services funded by HPRP, individuals and families — whether homeless or housed -
must at least meet the following minimum criteria:
1) Any individual or family provided with financial assistance through HPRP 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. HUD encourages
communities to have a process in place to refer persons ineligible for HPRP to the
appropriate resources or service provider that can assist them.
2) The household must be at or below 50 percent of Area Median Income (AMI). Income
limits are available on HUD's web site at: http: www .huduser.org /DATASETS /il.html.
Grantees should use HUD's Section 8 income eligibility standards for HPRP.
3) The household must be either homeless or at risk of losing its housing and meet both of
the following circumstances: (1) no appropriate subsequent housing options have been
identified; and (2) the household lacks the financial resources and support networks
needed to obtain immediate housing or remain in its existing housing.
Each grantee and subgrantee must keep any records and make any reports (including those
pertaining to race, ethnicity, gender, and disability status data) that HUD may require within the
timeframe required.
Cause: Project Concern Coordinator stated that case managers do have HUD's income limits at
their desk and referred to them, however; they do not complete an income calculation worksheet
to show that the client was eligible to receive assistance.
Effect: Without the income determination worksheets, the case managers cannot document that
clients were eligible to receive funding from the HPRP program. Without proper calculation
worksheets, ineligible clients could receive funding and the City may be asked to reimburse the
HPRP program.
Corrective Action: Provide a copy of the income calculation worksheet that will be used for
each participate and that they will be place in the client files. We have enclosed an example of
the HPRP Income Eligibility Calculation Worksheet and verification of income form. These
documents and more information can be found at www.HUDHRE.info /HPRP /. Please provide a
Concern #1: Project Concern and the City were using HUD's Fair Market Rents (FMR's) to
determine if rents were reasonable.
Recommendation: The City and its subrecipient must continue to follow procedures to ensure
that reasonableness determinations will be followed in accordance with HPRP Notice, Section
IV.(A)(1)(a)(4).
5
plan describing how the subrecipient will be trained on documentation requirements as stated in
the HPRP Notice.
Condition: Up to June 1, 2010, it was apparent that the City and Project Concern were not
properly documenting "rent reasonableness ". However, when further guidance was received, the
City who now prepares all rent comparables has complied with the correct procedure. It was
apparent in the files that were reviewed that none of the client were paying over rent
reasonableness limits or FMR's.
Cause: The City of Dubuque and Project Concern was under the assumption that HUD's FMR's
were considered a market study and was not aware they were not in compliance.
Effect: The City was out of compliance with HPRP requirements. Applicants may have
received assistance that they would not have otherwise qualified for if the correct procedure was
in place.
flPRP I ncorrteEIigitrilitv:Caicula.tion Wor " : '
: `:'.:::..
tJ5 :t e. worksheet below tR deteri:4.i.* d:dacument whether ari applltdnt lv- usehold HPRP: income' eflgiL#Iti#ij:recjuirement ::A y tif:this: sf:Fo#10 be kept in the>.
}(PRP s rt lflP2ri& ease file. TO br effl gtb . for yPRP i ou5eho ?d5 mUStbe os or b %of:rhoA Mssifon I iloini (AMtJAP/O meet 0Th r. HHFRP 0i0¢i}1ty:reglAvi/Cnrs fo i'. dcldttionak
Informatiolt ori;,)**li$Riilitg requirements and.dscumentaf(on standards see "HPRP Etfgibllity Peeerrnination and:Oocumenta ;ion Guidance" at
' , • , . • httrawww.Jtudhre. info / document& S/ HPRUigibilltyAn dpocumentationuidance,Pdt::
HouseEioldN[ einFier
:...:: Number .- -. ::.:
'..Household Member:fianie :'_ : ' i _
::`:a': . ..:. .. _ - .,..
, i Age afHousehoidMember •
..
1
Jane Smith
50
2
Bob Smith
16
3
Joe Smith
19
4
5
6
7
8
9
10
11
Total Household Members (Household size)
3
50% of Area Median Income (AMI) for Household Size
$ 31,950
MduseholdMentl#er:..;
Mumbertflame
; , . Sourtes.of Household Irt .carne
:: gro..ss.Druurnented
c.9.00 Income AltlOtint
FrequentyOf
In(om4:
M
PbYments pen
1':
Anntialgioss panne fgross. -
lneorne entount ) 4 of paytont
Per Year)
1 /Jane Smith
Earned Income (for ADULT household members only)
$ 325
Weekly
52
$ 16,900
3 /Joe Smith
Earned Income (for ADULT household members only)
$ 400
Bi- Weekly
26
$ 10,400
Earned Income (for ADULT household members only)
$ -
$ -
Self- employment /business income
$ -
$ -
Self - employment/business income
$ -
$ -
Interest & Dividend Income
$ -
$
Interest & Dividend Income
$ -
$ -
Pension /Retirement Income
$ -
$ -
Pension /Retirement Income
$ -
$ -
Unemployment & Disability Income
$ -
$ -
Unemployment & Disability Income
$ -
$
TANF /Public Assistance
S -
$ -
TANF /Public Assistance
$ -
$ -
1 /Jane Smith
Alimony, Child Support and Foster Care Income
$ 250
Monthly
12
$ 3,000
Alimony, Child Support and Foster Care Income
$ -
$ -
Armed Forces Income
$ -
$ -
Armed Forces Income
$ -
$ -
Other (specify):
$ -
$ -
Other (specify).
$ -
$ -
Total Annual Gross Income from all Sources
$ 30,300
50% of Area Median Income for Household Size:
$ 31,950
Variance (If Tess than AMI, then household is income eligible)
$ (1,650)
Is the household at or below 50% Area Median Income?
YES Income Eligible
Homeless Prevention and Rapid Re- Housing Program (HPRP)
VERIFICATION OF INCOME
HPRP Applicant Name:
Instructions for Employer /Payment Source Representative: This is to certify the income received by the above named
individual for purposes of participating in the HPRP program. This information will be used only to determine the
eligibility status and level of benefit of the household. Complete only the selected section below that includes an
authorization to release information.
Please return this form to:
Name & Title: Phone:
Address: Fax:
Email:
Employment Income
HPRP Applicant Release: I hereby authorize the release of the following employment information.
HPRP Applicant Signature: Date:
Employer representative to complete this section:
The person named above is employed by since . He /she
is paid $ on a basis and is currently working an average of hours per
Additional compensation please specify (if any):
Probability of continued employment:
Authorized Employer Representative Signature: Date:
Name, Title:
Address and Phone:
Payments and /or Benefit Income (complete one form for each distinct source of income for person named above)
CIRCLE ONE: Social Security /SSI Pension /Retirement TANF
Public Assistance Unemployment Compensation Workers Compensation
Alimony Payments Foster Care Payments Child Support Payments
Armed Forces Income
Other (pls. specify):
HPRP Applicant Release: I hereby authorize the release of the following payment and /or benefit information.
HPRP Applicant Signature: Date:
Payment source representative to complete this section:
Payments or benefits in the amount of $ are paid on a
expected duration of the payments or benefits is
basis. The
Authorized Payment Source Representative Signature: Date:
Name, Title:
Address and Phone: