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 • .. ..
........
T o.e *
ft /8 ifor: „.:A, d
• A i0t-.0
tia(r.601tAtkii5:G13
...........
.. .
- 10 .
1 : : • Jane Smith
•
Bob Smith
Joe Smith
Total Household Members; (Household ;size) • . ..
• 50% of A! ea -M edia n Jrictime:(A801) for:Ho usehdl 3ize •.::,' • il• • •
. .....
... . ..... 0;0. kW
1/Jane:5Mith:: .. . : . Eirned:Inco m e !for ADULT hOuSehOld:melnbe:onM* ..... • • •
3jJoe:Sthith Ear'ned:IritOme (for:ADULT
. ... :
..• . . . : • • ' Earnedilncpme (fon AlDIJ.LT
Salfnemployment/bUsIneSs
. . . . • Self•emOloymerNbutiness
. •: . . .
. : . . interest-&- Dividend incrith .....
• • •••• . . :: Armed ilrces
• • :
.. .............. •
. .... interest k bividend Incom.e. • • • • • •-• • • • "
hefidehOld'uferribees:iiiilY) . ... .$,
filaneSdilth • AlimohY, ancifiigencegjTkei .
. .
•.: . . . . AlimOny; thlidSiip nod a rid foMetaireinco me
...... . . :::.•.•: :•:. . .. .
honSahold.MeMbersionlyl.. :$ .
Income
PthiStontftetireMent 'male .. . ............
. , Beniiiin/Benrement income .
..... . . ' .... :•'• •
Uh employment
IAN FJRI.IPiIIC
............ • - • • •
• • • • ..... •
• kmedroreiS fficome ..
....... ... . ...........................
. .
. •.-- ... ::.•:.••:::
. . .............
50% iffArM ed n co m
...
•
. • • • • • • •
. : ,$ . ..
irone .
i$
$ ..
$1. : .........
$ .... .
* •-• • UnemplOVerne 8 .... . . '$
. .• . . . .
.... .................
. ............ • . ; TANF/1 is tarice• • .....
$ : . . .. . . . : . : . : . :". •
• . : . : . : . : '
.......... • • • •
. • • -
..... ..... • •
•-• ..... .......... ..... . . .•:: ....
• ' • .. : . : . • . . .... . . ............ .....
. . : ...
37_5
250:
•
•
itieO f:?•i*:*
W ..... ..
: . .. .... . •
• . • • . : : . •
. : ........ : .... .
........
..........
.. ..... .... : •
.................
: : . : ... .. ... .
.........
................
....... ................
.....
............
Variance less .thin Aiillillien:hOusehold Is Indorne . ..... : : : . ....
••• -•
•i : . .
• . . . • 1. . . . • • . .3
.....
.. : • :
• .: . • • : : . : ••• • :31,950
..... • • .
• • ........
.. ......... .....
: . . : • • . : • .
16
:19
:.•
:5 . •
$:: ........ ..... ...
• r: : ... .. : : :
: . : . . : .. . • . : . : .. :
. : ......... . : . ........ : : .
. . •
• • . . , .......
. . • • • • • • .........
..... .....................
.... : . . : .......
:
$ . ... ........... .. ............ . ........
3,
..
$ ... " . • . : . : .
4 ........ • ..... .
YI;P!!!!:f!Pn? ... .. ; . ........ :.::::. .......... . . ...... ... .... ` 3 • 0 !‘ 3911
.. . ........ ..... .
• : . : •
• . . : .. " • "
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:
[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: