ELIGIBLE Program Costs

CoC Grant Implementation Answers to Your Questions April 19, 2016 Presented by: Diana T. Myers and Associates, Inc. (DMA) - For the PA Eastern & Western Balance of State Continuums of Care - Under contract with the PA Department of Community and Economic Development (DCED) Overview This Webinar is based on questions submitted via: pa_coc@hotmail.com Webinar feedback surveys Questions unanswered during previous webinars It will also include several additional CoC Program implementation under HEARTH 2 Overview CoC Implementation Topics: Eligible Program Costs and Match and Leveraging Additional Brief Topics: APR Deadlines Fiscal Management Participation by Homeless Individuals ELIGIBLE Program Costs (under CoC program) 3 4 Eligible Costs For NEW Projects Only: Acquisition Rehabilitation/Construction For NEW and RENEWAL Projects: Operating Costs Supportive Services Project Administration Operating Costs CoC funds may be used to pay the costs of the day-to-day operation of transitional and permanent housing in a single structure or individual housing units. It is the cost of operating real estate not the agency s operating costs. 5 6 1

Operating Costs Eligible Operating Costs: The maintenance and repair of housing Property taxes and insurance Scheduled payments to a reserve for replacement of major systems of the housing (provided that the payments must be based on the useful life of the system and expected replacement cost) Building security for a structure where more than 50 percent of the units or area is paid for with grant funds Electricity, gas, and water Furniture Equipment Supportive Services Grant funds may be used to pay the eligible costs of supportive services that address the special needs of the program participants. Services should be focused on assisting program participants to obtain and retain Permanent Housing 7 8 Supportive Services Eligible Supportive Services costs: Annual Assessment of Service Needs with moving costs Case management Child care Education services Employment assistance and job training Food Housing search and counseling services Legal services Life skills training Mental health services Outpatient health services Outreach services Substance abuse treatment services Transportation Utility deposits Direct provision of services Project Administration Project administrative funding covers costs related to the planning and execution of Continuum of Care activities. It is typically the cost of doing business with HUD 9 10 Eligible Administrative costs: Project Administration 1) General management, oversight, and coordination costs, including: Salaries, wages, and related costs of the recipient s staff, the staff of subrecipients, or other staff engaged in program administration. Activities would include: Preparing program budgets and schedules, and amendments to those budgets and schedules; Developing systems for assuring compliance with program ; Developing agreements with subrecipients and contractors to carry out program activities; Monitoring program activities for progress and compliance with program ; Preparing reports and other documents directly related to the program for submission to HUD; Coordinating the resolution of audit and monitoring findings; Project Administration ( Eligible Costs Continued) Evaluating program results against stated objectives; and Managing or supervising persons whose primary responsibilities are the above Travel costs incurred for monitoring of subrecipients; Administrative services performed under third-party contracts or agreements, including general legal services, accounting services, and audit services; and Other costs for goods and services required for administration of the program, including rental or purchase of equipment, insurance, utilities, office supplies, and rental and maintenance (but not purchase) of office space. 11 12 2

Project Administration (Eligible Costs Continued) 2) Training on Continuum of Care : Costs of providing training on Continuum of Care and attending HUD-sponsored Continuum of Care trainings. 3) Environmental review: Costs of carrying out the environmental review responsibilities under 578.31. LEASING and RENTAL ASSISTANCE 13 14 Definitions of and : of property, or portions of property, not owned by the grant recipient or project sponsor, for use in providing transitional or permanent supportive housing, or providing supportive services. : Provision of rental assistance to eligible persons for transitional or permanent housing. Buildings and/or units are leased by the grant recipient and sub-leased to program participants through an Occupancy Agreement. TH: The agreement must be for a term of at least 1 month and automatically renewable for up to 24 months PH: The agreement must be for a term of at least 1 year and be automatically renewable upon expiration Examples of Leases and Occupancy Agreements are posted on HUDExchange: https://www.hudexchange.info/resource/2894/cocprogram-leasing-rental-assistance-examples-oflease-agreements/ 15 16 Occupancy Charges: Recipients are not required to charge program participants an occupancy charge There is no match requirement for the portion of a CoC budget. If occupancy charges are imposed, they may not exceed: 30% of the family s month adjusted income (adjustment factors include allowances and deductions for disabled household members, medical expenses, child care expenses, etc.); 10% of the family s gross monthly income; or Portion of welfare payments specifically designated by the public welfare agency to meet the family s housing costs. A worksheet for calculating occupancy charges can be obtained from the Section 8 Office of your PHA 17 18 3

No additional program fees may be imposed besides the allowable occupancy charges. Occupancy charges collected are considered to be program income. Program Income may not be used as either match or leveraging Program Income may be used on any CoC Program eligible expense even if it is not part of the project s grant agreement. Rent Limits: Up to 100% of Fair Market Rent (FMR) so long as the rents are determined to be reasonable when compared with similar units in the community Rent paid through grant funds cannot exceed FMR, however, the grantee can pay for housing costs that exceed FMR with non- CoC funds 19 20 Utilities: If the rent includes utilities: funds may be used to pay the entire rent, up to FMR If utilities are not included and participants are expected to pay for utilities: a utility allowance must be be applied to the occupancy charge calculation A worksheet for calculating allowances can be obtained from the Section 8 Office of your PHA Other Eligible Costs: Up to 3 months rent at move-in : Security Deposits 1 st month s rent Last month s rent May use leasing funds to pay rent on vacant units until a new program participant moves in To fulfill the terms of the lease funds CANNOT be used for property damage 21 22 Length of : assistance provides funding to pay part of the rent for a unit in which a homeless person will reside. There must be a lease between the landlord and the program participant. is included in the 25% match requirement Short-term: Up to 3 months of Transitional Housing (TH) or Rapid Rehousing (RRH) Medium-term: 4 to 24 months of TH or RRH Long-term: More than 24 months of Permanent Supportive Housing (PSH) 23 24 4

Types of : Tenant Based (TBRA): The participant locates a housing unit of their choice and enters into a lease with the owner. If they move, they can take the with them. Sponsor Based (SBRA): The grant recipient contracts with a project sponsor who locates and leases housing and subleases to participants. If the participant moves out, the sponsor can lease the unit to another eligible household or support the participant in a different unit the funding stays with the sponsor. Project Based (PBRA): The grant recipient contracts with a building owner who agrees to lease the units to program participants. If the participant moves out, the unit is rented to another eligible participant the rental assistance remains with the unit. Program participants are REQUIRED to pay rent equal to the highest of: 30% of the family s month adjusted income (adjustment factors include allowances and deductions for disabled household members, medical expenses, child care expenses, etc.); 10% of the family s gross monthly income; or Portion of welfare payments specifically designated by the public welfare agency to meet the family s housing costs. No program fees may be imposed on program participants other than their portion of the rent. 25 26 Rent Limits: Unit rents can exceed Fair Market Rents but they must NOT exceed Rent Reasonableness Grants are awarded based on FMR, but the amount that can be paid is based on Rent Reasonableness, even if it is higher than FMR If some units in a project are leased beyond FMR, the grantee must carefully track costs to ensure that there are sufficient funds to serve the contracted number of participants. Rent Payment: The program participant is responsible for their portion of the rent and makes their payment directly to the landlord The grant recipient makes their portion of the payment directly to landlord 27 28 Other Eligible Costs Under : Utilities: If the participant is required to pay for utilities, then a utility allowance must be factored into the rent calculation determination. Up to 3 months rent at move-in : Security Deposits 1 st month s rent Last month s rent Property damages up to 1 month s rent Vacancy payment for up to 30 days if a unit is vacated prior to the end of the lease 29 30 5

Additional Information for Both and Things to Consider When Determining Rent Reasonableness: Location, quality, size, unit type and age of the unit Amenities, housing services, maintenance, and utilities the owner must provide Additional Information for Both and Costs of Administering (including costs of Administering Funds) Processing rental payments to landlords Examining Participant income and family composition Providing housing information and assistance Inspecting units for compliance with housing quality standards Receiving new participants into the program The cost of conducting these activities is payable under the or budget Line Item Note: In the Interim Rule, it states that non-profits cannot administer. This was temporarily fixed to allow non-profits to administer RA and is expected to be permanently fixed through pending legislation. 31 32 Additional Information for Both and Environmental Review: Projects funded for and are required to conduct a Limited Scope Environmental Review prior to expenditure of grant funds. Project Administration Funds can be used for the cost of completing the Environmental Review. The form is available on HUD Exchange: https://www.hudexchange.info/resource/3800/li mited-scope-environmental-review-coc/ MATCH AND LEVERAGING 33 34 What is Match? Match is the cash or in-kind resources contributed to a grant. Cash Match: Actual cash contributed to the program. In-Kind Match: The value of any real property, goods or services contributed to the program that would have been eligible costs under the CoC Program. All match must be for activities that are eligible under the CoC Program, even if those activities are not funded under the grant. Eligible Match Examples of Eligible Match: Cash contributed to the program for eligible activities such as Case management Life Skills Instruction Mental Health Services SOAR Examples of Ineligible Match: Program income such as occupancy charges Tax preparation services for program participants 35 36 6

What is the Required Amount of Match? All CoC grant funds (with the exception of ) must be matched by at least 25% with cash or in-kind resources. Example A: (site based program) Operations: $25,000 Supportive Services: $30,000 Admin: $ 3,850 Total Grant: $58,850 MATCH REQUIREMENT: $14,712 (25% of Total Grant) What is the Required Amount of Match? (continued) Example B: (Scattered site with leasing) : $20,000 Supportive Services: $15,000 Admin: $ 2,450 Total: $37,450 MATCH REQUIREMENT: $ 4,362 (25% of Supportive Services and Admin) 37 38 What are allowable sources of cash match? Grantees may use funds from any source, unless the source is statutorily prohibited from being used as a match. Federal (excluding other CoC Programs) State Local Private What are allowable sources of in-kind match? Grantees may use any public or private source that is not statutorily prohibited from being used as match: Value of real property, equipment or goods Value of services Participant mainstream benefits are NOT considered match Benefits are committed to the individual not the project. 39 40 documentation for CASH Match? Written documentation on the source agency s letterhead, signed and dated by an authorized representative. At a minimum it should include: Amount of cash to be provided Specific date the cash will be available Grant name and fiscal year to which the cash match will be contributed Time period during which funding will be available Allowable activities to be funded by the cash match Documentation must be dated no earlier than 60 days before application due date as established in the NOFA. Documentation must be provided to HUD prior to execution of grant agreement. documentation for IN-KIND Goods and Equipment Documentation for In-Kind Goods and Equipment: Must be on the donating agency s letterhead, signed and dated by an authorized representative. At a minimum, it must include: Value of donated goods Specific date the goods will be made available Allowable activities to be provided by the donation Value of commitments of land, buildings and equipment are one time only and cannot be claimed by more than one project or by the same project for another year. 41 42 7

documentation for IN-KIND Services Documentation for In-Kind Services: The grantee must: Enter into a formal memorandum of understanding (MOU) with the agency providing the in-kind service Establish a system to document the actual value of services provided during the grant term Prior to grant agreement, the grantee may use a letter from the partner agency to document the commitment. Upon notification of the HUD award, an executed MOU is required. for an MOU for IN-KIND Services? The MOU must be executed between the grantee and a third party provider and include at a minimum: 1. Agency Information: Grantee identifying information and point of contact Service provider s identifying information and point of contact 2. Unconditional commitment of the Third Party Provider to provide the service 3. Description of the services to be provided 43 44 for an MOU for IN-KIND Services? (continued) 4. Scope of Services to be Provided and by Whom: Specific contract to be matched Length of time services provided/term of contract Point in time number of clients receiving service Total clients receiving service over grant term Qualifications of persons providing service Estimated value of services provided (such as hourly rate) for an MOU for IN-KIND Services? (continued) 5. Documentation of Services Match Documentation and responsibilities of service provider and grantee Maintaining records of actual hours of service to program participants Timeliness standards of service provider and grantee for providing services to individuals 45 46 What is Leveraging? Leveraging is additional cash or in-kind resources committed to make a CoC project fully operational. Includes all CoC eligible resources in excess of the required 25% match Other resources that are used on costs that are ineligible in the CoC Program Example: Gift cards for program participants What is the Required Amount of Leveraging? There is no required amount of leveraging under the HEARTH Act However, the annual NOFA provides leveraging targets that impact the scoring of the CoC in the national competition 47 48 8

Leveraging Target Amounts Target amounts in the past 2 NOFA s: 2013/2014: 5 Points out of 150. Maximum points if: 100% of projects show committed leveraging in their application Leveraging equals at least 150% of the overall CoC grant request 2015: 1 Point out of 200 for overall 150% leveraging for which grantees attached commitment letters. What Sources of Leveraging have been historically reported? Government: BH/ID HAP County Human Services Private: Churches Medical Centers Colleges Local homeless provider agencies Medical Substance use services Philanthropy 49 50 What are some other potential sources of leveraging? Volunteers Professional services at their usual rate Other volunteers at $10/hour Businesses Subsidized transportation Food pantry donations Furniture and/or clothes from a local consignment shop Documentation of Leveraging The documentation for Leveraging are not spelled out in the CoC Interim Rule Clarification from HUD indicated that it is the same as for Match This is expected to be formally clarified in the CoC Final Rule 51 52 Importance of timely and accurate APR Reporting: Other Topics: APR Deadlines The CoC Annual Performance Report (APR) must be submitted on esnaps within 90 days of the end of your operating year. The program performance data should be drawn from the HMIS. HMIS data must therefore be current and accurate The HUD Guidebook for completing the APR is available on HUD Exchange: https://www.hudexchange.info/resources/documents/e- snaps-coc-apr-guidebook-for-coc-grant-funded- Programs.pdf Other Topics: APR Deadlines (Continued) Many of the factors used for project ranking are taken from the APR HUD will close a project out of eloccs if the APR is late HUD and the CoCs regard timely APR submission as a measure of project capacity and performance In the 2015 CoC Project Renewal Application, HUD requested information about timely submission in the future this may impact the CoC Score and eligibility for project renewal 53 54 9

Fiscal Management Under the CoC Interim Rule, HUD requires grantees to make draw downs from eloccs at least once per quarter As with timely filing of APRs: HUD and the CoCs regard timely draws as a measure of project capacity and performance In the 2015 CoC Project Renewal Application, HUD requested information about timely draws in the future this may impact the CoC Score and eligibility for project renewal Fiscal Management (continued) Grantees are expected to fully expend their grant. Expenditure should be accurately reported on the APR HUD and the CoCs regard full expenditure as a measure of project capacity and performance In the 2015 CoC Project Renewal Application, HUD requested information about the recapture of funds in the future this may impact the CoC Score and eligibility for project renewal The CoCs look at recapture by HUD in the renewal ranking and reallocation process 55 56 Per the CoC Interim Rule: Participation by Homeless and Formerly Homeless Individuals (1) Each recipient and subrecipient must provide for the participation of not less than one homeless individual or formerly homeless individual on the board of directors or other equivalent policymaking entity to the extent that such entity considers and makes policies and decisions regarding any project, supportive services, or assistance provided under this part. This requirement is waived if a recipient or subrecipient is unable to meet such requirement and obtains HUD approval for a plan to otherwise consult with homeless or formerly homeless persons when considering and making policies and decisions Participation by Homeless and Formerly Homeless Individuals (2) Each recipient and subrecipient of assistance under this part must, to the maximum extent practicable, involve homeless individuals and families through employment; volunteer services; or otherwise in constructing, rehabilitating, maintaining, and operating the project, and in providing supportive services for the project. 57 58 QUESTIONS??? Input from Webinar Participants If you would like to suggest topics for future Webinars, please let us know. Reminder: You will receive an evaluation survey shortly after the webinar. 59 60 10

Next Webinar Date: Tuesday May 17 1:30 to 3:00 Topic: Discussion of Low Barriers Policies and Implementation 61 11