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Homelessness Prevention and Rapid Re-Housing ProgramMasterpiece on the Mississippi TO: The Honorable Mayor and City Council Members FROM: Michael C. Van Milligen, City Manager SUBJECT: Homelessness Prevention and Rapid Re- Housing Program HUD Monitoring DATE: September 13, 2010 ik chael C. Van Milligen Dubuque hittitil AN- Amelcaclty I'll! 2007 Housing and Community Development Department Director David Harris is transmitting the August 24, 2010 monitoring report of the U.S. Department of Housing and Urban Development (HUD) regarding the Homelessness Prevention and Rapid Re- Housing Program, along with the City of Dubuque's proposed corrective action. MCVM:jh Attachment cc: Barry Lindahl, City Attorney Cindy Steinhauser, Assistant City Manager David Harris, Housing and Community Development Department Director Masterpiece on the Mississippi To: Mich e Van Milligen, City Manager From: David arris, Housing and Community Development Subject: Homelessness Prevention and Rapid Re- Housing Program HUD Monitoring Date: September 7, 2010 F: \USERSWTAUKE\HPRP\HUD HPRP monitoring. mvm memo.doc Dubuque 1I-Analaaly f 2007 This memorandum is provided in response to the August review by the U.S. Department of Housing and Urban Development (HUD) regarding the Homelessness Prevention and Rapid Re- Housing Program (HPRP). The City of Dubuque received $502 294 in HPRP funds from HUD through the American Recovery and Reinvestment Act. The City contracted with Project Concern as the primary service delivery provider for the HPRP grant activities in September 2009. All funds must be expended by the HUD required expenditure deadline of July 14, 2012. The HPRP program provides financial and other assistance to prevent individuals and families from becoming homeless and helps those who are experiencing homelessness to be quickly re- housed and stabilized. The funds target individuals and families who would become homeless if not for this assistance and provide for short-term and medium -term rental assistance, and housing relocation and stabilization services. Homelessness prevention assistance is provided to individuals and families who are at risk of becoming homeless and who would be homeless without assistance. Rapid re- housing assistance is provided to individuals and families who are homeless. Attached is the August 24 monitoring report and our proposed corrective action to be submitted to the HUD -Omaha field office. Masterpiece on the Mississippi Patricia McCauley, Director Community Planning and Development U.S. Department of Housing and Urban Development Nebraska State Office Executive Tower Centre 10909 Mill Valley Road Omaha, Nebraska 68154 -3955 Dear Pat: Housing and Community Development 1805 Central Avenue Dubuque Iowa 52001 -3656 (563) 589 -4212 office (563) 589 -4244 fax atauke a(�.citvofdubuque.orq September 8, 2010 This letter is our response to the findings and concerns as stated in your August 24 letter relating to the August 2 -5, 2010 on -site review of the Homelessness Prevention and Rapid Re- Housing Program (HPRP) with the City of Dubuque. The resulting monitoring report is referenced and our proposed corrective action is attached. FINDING NO. 1 Source documentation was incomplete and lacked staff signatures and dates on the forms. Discussion The City of Dubuque contracts with Project Concern (PC) to administer the Homelessness Prevention and Rapid Re- Housing Program. When the HPRP program was implemented, Staff from Project Concern attended the regional HPRP training by HUD. The HPRP Notice No. FR- 5307 -N -01 was provided which defined the eligibility and documentation requirements. Corrective Action City Staff will meet with Project Concern Staff to review the importance of complete and accurate reporting and documentation. City staff has revised the HPRP Policy and Procedures for Project Concern to provide additional written clarification of the HPRP eligibility requirements and the process for determining type, level and duration of assistance, income eligibility and housing status. The procedure clearly defines how documentation will be maintained in all files and how individual plans for housing stability of living conditions for clients will be developed and maintained. City Staff will provide a training session for all PC Staff involved in the HPRP intake and review process within 30 days. The session will train staff on HPRP documentation requirements and adequate client file recordkeeping. City Staff will train all new PC staff as needed. A monthly monitoring visit will be undertaken for a minimum of three months and until it has been determined that HPRP client files are being maintained with all required documentation. City staff will review at least ten percent of the monthly client files to certify accuracy, consistency and completeness. If incomplete, City staff will meet individually with PC staff to further instruct them on reporting requirements and perform additional periodic reviews to insure completeness and accuracy as needed. FINDING NO.2 Files were missing or had improper homeless documentation. Discussion HPRP funds are intended to assist persons who are still housed but at risk of becoming homeless and persons who are already homeless. Persons in need of assistance apply at Project Concern and staff determines eligibility. Staff from Project Concern attended the regional HPRP training by HUD when the program was implemented. The HPRP Notice No. FR- 5307 -N -01 was provided which defined the homeless documentation requirements. Corrective Action Homeless documentation requirements will be included in the proposed training session for all existing and future PC Staff involved in the HPRP process. The revised HPRP Policy and Procedures for Project Concern will provide additional written clarification of the HPRP housing status eligibility and documentation for homeless assistance and homelessness prevention. The revised procedures specify acceptable documentation of homelessness and require evidence that clients at addresses listed were eligible to receive assistance. The session will train staff on completion of homeless verification forms and proper documentation for each client. The `Homeless Certification' and, if needed the `Self - Declaration of Housing Status' form, from the HUDHRE website, will be completed as required. A monthly monitoring visit will be undertaken for a minimum of three months and until it has been determined that HPRP client files are being maintained with all required documentation. A copy of the most recent HPRP monitoring visit will be provided. FINDING NO.3 No income eligibility calculation worksheets were found in client files. Discussion The HPRP client files contained third party verification, anticipated income and budget figures to document eligibility for HPRP assistance. PC Staff used current HUD income limits to calculate eligibility but no income eligibility calculations worksheets were in the files. No HPRP participants were determined ineligible for assistance they received. Corrective Action The revised HPRP Policy and Procedures for Project Concern provides additional written clarification of the HPRP income eligibility requirements. The procedures define how to calculate income for the HPRP eligibility and require the HPRP client files contain the completed HUD `HPRP Income Eligibility Calculation Worksheet' and `Verification of Income' form in the files. The training session will instruct staff on proper completion and documentation of client income. Ongoing monitoring as described above will insure proper documentation. CONCERN #1 Project Concern and the City were using HUD's Fair Market Rents (FMRs) to determine if rents were reasonable. Discussion Guidance had previously been received that the adopted Fair Market Rent could be used in lieu of performing the rent reasonableness evaluation because Fair Market Rent tends to be less than rent reasonable. A directive was received in June 2010 that FMRs could be used to establish a cap on the amount of assistance provided under our HPRP program, but this did not negate the need to determine rent reasonableness for each unit to allow for location, configuration or amenities provided. Corrective Action As you stated in your letter, the City has been preparing all rent reasonable comparables for the units since June 1, 2010 to determine that rental assistance does not exceed actual rental cost and that the actual rental cost(s) is /are in compliance with HUD's standard for rent reasonableness. The City has established a process whereby PC staff forward a Rent Reasonableness form containing the HPRP applicant information to the Housing and Community Department for completion prior to approving client assistance. The completed form is returned to PC staff for inclusion in the client file. The procedure will continue to provide to ensure rent reasonableness determinations will be followed in accordance with HPRP regulations. In order to insure complete and accurate reporting and documentation for HPRP, the revised HPRP Policy and Procedures provide for more interactive participation between City staff and Project Concern staff. A more defined signoff process has been identified to insure completion of HPRP eligibility prior to assistance. We anticipate continued refinement of the process to insure HUD's HPRP requirements are met. We appreciate the comments received on our Homelessness Prevention and Rapid Re- Housing Program. We strive to utilize HPRP funds in compliance with all applicable regulations as these funds provide a means to enhance our community's quality of life. If further information is needed, please contact Aggie Tauke or me at 563- 589 -4239. Si rely, avid Harris Department Director cc: Michael Van Milligen, City Manager F: \USERS ATAUKE \CDBG\HUD\HUD Audit Response.HPRP 2010.doc 011■ENZ 0, S ill Ps W_ : * ;6 * 1111111 e R E IN DEW Honorable Roy Buol City Hall 50 West 13 Street Dubuque, IA 52001 -4864 Dear Mayor Buol: 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 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 Sincerely; 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. 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 tirnefiame 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. Finding #2: Files were missing or had improper homeless documentation. 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 e. Victims of domestic violence. 3 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 Finding #3: No income eligibility' calculation worksheets were found in client files. 4 clients at 1718 ''A White Street, 2459 Jackson Street and 2666 Owen Court #10, were eligible to receive HPRP assistance. 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. 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. 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). .... .r.44 VON:08. tfil • .. .. ........ 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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: [7 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 (pis. 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 Name, Title: Address and Phone: Authorized Payment Source Representative Signature: Date: