OMB Approval Number: 2506-0180 (Expiration Date: 9/30/2009) Tulsa County CDBG Urban County Substantial Amendment to the Consolidated Plan 2008 Action Plan for the Homelessness Prevention and Rapid Re-Housing Program (HPRP) Public Comment Period: May 6-18, 2009 Submission to HUD: May 18, 2009 1 HUD-40119
Grantees eligible to receive funds under the Homelessness Prevention and Rapid Re- Housing Program (HPRP) are required to complete a substantial amendment to their Consolidated Plan 2008 Action Plan. This form sets forth the required format for this substantial amendment. A completed form is due to HUD within 60 days of the publication of the HUD HPRP notice. To aid grantees in meeting this submission deadline, the HPRP Notice reduces the requirement for a 30-day public comment period to no less than 12 calendar days for this substantial amendment. With this exception, HPRP grantees are required to follow their Consolidated Plan s citizen participation process, including consultation with the Continuum of Care (CoC) in the appropriate jurisdiction(s). Grantees are also required to coordinate HPRP activities with the CoC s strategies for homeless prevention and ending homelessness. To maximize transparency, HUD strongly recommends that each grantee post its substantial amendment materials on the grantee s official website as the materials are developed. A complete submission contains the following three documents: 1) A signed and dated SF-424, 2) A completed form HUD-40119 (this form), and 3) Signed and dated General Consolidated Plan and HPRP certifications. For additional information regarding the HPRP program, visit the HUD Homelessness Resource Exchange (www.hudhre.info). This site will be regularly updated to include HPRP resources developed by HUD and its technical assistance providers. The information collection requirements contained in this application have been submitted to the Office of Management and Budget (OMB) for review under the Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520). This agency may not collect this information, and you are not required to complete this form, unless it displays a currently valid OMB control number. Information is submitted in accordance with the regulatory authority contained in each program rule. The information will be used to rate applications, determine eligibility, and establish grant amounts. Public reporting burden for this collection of information is estimated to be 16 hours, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. This information is required to obtain benefits. To the extent that any information collected is of a confidential nature, there will be compliance with Privacy Act requirements. However, the substantial amendment to the Consolidated Plan 2008 Action Plan does not request the submission of such information. Warning: HUD will prosecute false claims and statements. Conviction may result in criminal and/or civil penalties. (18 U.S.C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802) 2 HUD-40119
A. General Information Grantee Name Name of Entity or Department Administering Funds HPRP Contact Person (person to answer questions about this amendment and HPRP) Title Address Line 1 Tulsa County INCOG Claudia Brierre Principal Community Development Planner INCOG Address Line 2 201 West 5th., Suite 600 City, State, Zip Code Tulsa, OK 74103 Telephone 918-579-9431 Fax 918-579-9531 Email Address Authorized Official (if different from Contact Person) Title Address Line 1 Address Line 2 cbrierre@incog.org John Smaligo Chair, Tulsa County Board of Commissioners 500 S. Denver Avenue City, State, Zip Code Tulsa, OK 74103 Telephone 918-596-5000 Fax 918-596-4746 Email Address Web Address where this Form is Posted jsmaligo@tulsacounty.org www.tulsacounty.org Amount Grantee is Eligible to Receive* $521,635 Amount Grantee is Requesting $521,635 *Amounts are available at http://www.hud.gov/recovery/homelesspreventrecov.xls 3 HUD-40119
B. Citizen Participation and Public Comment 1. Briefly describe how the grantee followed its citizen participation plan regarding this proposed substantial amendment (limit 250 words). Response: In preparing this draft substantial amendment to its 2008 Consolidated Plan, Tulsa County used its existing Consolidated Plan citizen participation process with abbreviated timeframe for public comment as required by HUD. Activities included: Notice of the Special Public Hearing regarding a Substantial Amendment to the Consolidated Plan published 14 days prior to the public hearing in a newspaper of regional circulation, the Tulsa World; Special Public Hearing notice posted in the city and county offices of the 11 Urban County jurisdictions, INCOG office; and at www.tulsacounty.org Special Public Hearing notice provided to public and Indian housing authorities in the Urban County jurisdiction (Tulsa Housing Authority); Special Public Hearing notice provided to members of the Continuum of Care and Homeless Services Network; Special Public Hearing held on Monday, May 11, 2009 at 9:30 a.m. at the Tulsa County Board of Commissioners meeting. In addition, Tulsa County grant administration staff (INCOG) hosted two community partners meetings in late April and early May to solicit input from key members of Homeless Services Network on HPRP priorities and uses. 2. Provide the appropriate response regarding this substantial amendment by checking one of the following options: Pending Public Hearing and Comment Period Grantee did not receive public comments. Grantee received and accepted all public comments. Grantee received public comments and did not accept one or more of the comments. 3. Provide a summary of the public comments regarding this substantial amendment. Include a summary of any comments or views not accepted and the reasons for non-acceptance. Response: Pending Public Hearing and Comment Period C. Distribution and Administration of Funds Reminder: The HPRP grant will be made by means of a grant agreement executed by HUD and the grantee. The three-year deadline to expend funds begins when HUD signs the grant 4 HUD-40119
agreement. Grantees should ensure that sufficient planning is in place to begin to expend funds shortly after grant agreement. 1. Check the process(es) that the grantee plans to use to select subgrantees. Note that a subgrantee is defined as the organization to which the grantee provides HPRP funds. Competitive Process Formula Allocation X Other (Specify: Sole Source provider organizations) 2. Briefly describe the process(es) indicated in question 1 above (limit 250 words). Response: In April and May, program administration staff convened meetings of key leaders of the Tulsa County Continuum of Care and Homeless Services Network to discuss possible program design for the HPRP funds. Discussion resulted in a selection of a project(s) identified as a priority in the CoC s 10 year plan. The project identifies four specific homeless providers to accomplish the closure of a building-code deficient homeless facility and the transition of the clients to other appropriate housing. Tulsa County has identified these four agencies as the best resources to accomplish the proposed project, based on agency capacity, experience, knowledge of the proposed project, and on the feasibility and appropriateness of their proposal and demonstration of ability to meet federal and local mandates. 3. Briefly describe the process the grantee plans to use, once HUD signs the grant agreement, to allocate funds available to subgrantees by September 30, 2009, as required by the HPRP Notice (limit 250 words). Response: A timetable will be developed to assure that HUD timelines for obligating funding can be met. Following submission of the Substantial Amendment to HUD for review, grant administration staff will meet with project agencies to develop the detailed project scope, establishing target outcomes and performance objectives. Subgrantee contracts will be drafted which set forth respective roles and responsibilities. Draft contracts will be completed by the beginning of August and sent to the Tulsa County District Attorney s office for review and approval. Contracts for HPRP programs will be ready for execution by subgrantees by September 1 to assure approval by the Tulsa County Board of Commissioners no later than September 30. 4. Describe the grantee s plan for ensuring the effective and timely use of HPRP grant funds on eligible activities, as outlined in the HPRP Notice. Include a description 5 HUD-40119
of how the grantee plans to oversee and monitor the administration and use of its own HPRP funds, as well as those used by its subgrantees (limit 500 words). Response: Tulsa County s HPRP grant funds will be targeted to a population who are at-risk of homelessness through the loss of their current stable, long-term affordable housing location. HPRP funds will be used to assist in housing relocation and stabilization services to these clients through the funding of case management, housing search and placement services, and rental assistance. The project has well-defined beginning and end dates which align well with HPRP timelines and produce measurable outcomes. The current housing lived in by the targeted clientele will close permanently by December 31, 2009. Transition of clients to community housing options will begin by November 1, 2009 and be complete by December 31 st. Rental assistance for a period of 18 months will bridge the gap between previous rents and increased rental amounts. After 18 months, the majority of clients will be more stably self-sufficient or be eligible for Section 8 assistance. Tulsa County has a well-established process for managing HUD formula grants through contracting of administration of these programs to INCOG. The County has contracted with INCOG over an extended number of years for administration of its HOME Consortium and CDBG Urban County grants, and will contract with INCOG for administration of HPRP funds. INCOG staff is well versed in HUD s programmatic requirements, assuring that all HPRP requirements for eligible participants, activities and reporting will be met. Grant programs implemented through third-party subgrantees and subrecipients are actively monitored for HUD compliance by INCOG administrative staff and County employees within their area of expertise. INCOG administrative staff will be responsible for conducting systematic reviews across programmatic areas to ensure consistency with contract compliance and to assure that HUD requirements are being met. INCOG staff will be responsible for coordinating and reviewing quarterly HPRP reports and their submittal to HUD; setting up and monitoring IDIS activities; reviewing monthly HMIS reports from the subgrantees; and entering HMIS data into IDIS. A written Monitoring Plan will be developed which details on-site monitoring visits to subgrantees. Each subgrantee will receive no less than one annual on-site visit, with quarterly desk review. Tulsa County will follow monitoring standards outlined in its Consolidated Plan and per HPRP requirements. To ensure compliance, monitoring efforts will include: Evaluation of program performance and compliance reports; Review of monthly expense and data reports to ensure expenditures are allowable budgetary and program requirements; Conducting on-site programmatic and financial monitoring. 6 HUD-40119
County financial staff will be responsible for receiving original source documentation supporting requests for payment from subgrantees and for maintenance of financial records in sufficient detail to satisfy the Office of State Auditor and Inspector, as required by law. D. Collaboration 1. Briefly describe how the grantee plans to collaborate with the local agencies that can serve similar target populations, which received funds under the American Recovery and Reinvestment Act of 2009 from other Federal agencies, including the U.S. Departments of Education, Health and Human Services, Homeland Security, and Labor (limit 250 words). Response: Tulsa County and grant administration staff will ensure the subgrantees selected either already have established relationships and collaborative efforts or will coordinate with various local and Federal agencies to include the U.S. Departments of Education, Health and Human Services, Homeland Security, and Labor. Tulsa County departments which are expected to receive funds under the American Recovery and Reinvestment Act of 2009 from other Federal agencies, such as the Sheriff s Department and Tulsa County Social Services, will be contacted to determine appropriateness of collaboration with HPRP funds. 2. Briefly describe how the grantee plans to collaborate with appropriate Continuum(s) of Care and mainstream resources regarding HPRP activities (limit 250 words). Response: The County will seek to continue to support the Homeless Services Network, a network of non-profits who have been delivering homelessness prevention and housing stabilization services for 15 years, and Continuum of Care strategies through work building upon existing collaborations. The collaboration efforts for HPRP funds began in April with stakeholder meetings. Collaboration will continue through HPRP project planning and initiation, implementation and reporting. Regular reporting of on-going HPRP activities will be presented to the CoC and HSN at their monthly meetings to gage progress toward project goals. Members of both groups will have the opportunity to provide input as to any deficiencies they may be experiencing regarding client needs and HPRP activity funds. 3. Briefly describe how HPRP grant funds for financial assistance and housing relocation/stabilization services will be used in a manner that is consistent with the grantee s Consolidated Plan (limit 250 words). Response: Tulsa County is a first-time grantee for homelessness funding under the Recovery Act special allocation of HPRP. Before the allocation of HPRP funds, Tulsa County did not receive federal funding for homeless services and programs, 7 HUD-40119
and therefore did not set extensive goals for homeless services in the Consolidated Plan. A priority need identified in the Tulsa County Consolidated Plan is to address the housing cost burden of extremely low income households, preventing the risk of homelessness. A stated goal is to support efforts to secure additional tenant-based rental assistance for extremely low income renters to provide options for households to secure decent, safe, and sanitary housing within their income range, and to support homeownership assistance for low income households. Tulsa County s HPRP grant funds will be targeted to a population who are at-risk of homelessness through the loss of their current stable, long-term affordable housing location. Financial assistance through medium-term rental assistance, security deposits, utility deposits, utility payments, and moving cost assistance will be provided to this targeted population as they seek alternate affordable housing, supporting the Consolidated Plan goal of providing options for households to secure decent, safe, and sanitary housing within their income range. Housing relocation and stabilization services will be provided to these clients through the funding of case management and housing search and placement services. 8 HUD-40119
E. Estimated Budget Summary HUD requires the grantee to complete the following table so that participants in the citizen participation process may see the grantee s preliminary estimated amounts for various HPRP activities. Enter the estimated budget amounts for each activity in the appropriate column and row. The grantee will be required to report actual amounts in subsequent reporting. HPRP Estimated Budget Summary Homelessness Prevention Rapid Rehousing Financial Assistance 1 $342,603 $ $ Housing Relocation and $142,950 $ $ Stabilization Services 2 Subtotal (add previous two rows) $ $ $ Total Amount Budgeted Data Collection and Evaluation 3 $ 10,000 Administration (up to 5% of allocation) $ 26,082 Total HPRP Amount Budgeted 4 $521,635 1 Financial assistance includes the following activities as detailed in the HPRP Notice: short-term rental assistance, medium-term rental assistance, security deposits, utility deposits, utility payments, moving cost assistance, and motel or hotel vouchers. 2 Housing relocation and stabilization services include the following activities as detailed in the HPRP Notice: case management, outreach, housing search and placement, legal services, mediation, and credit repair. 3 Data collection and evaluation includes costs associated with operating HUD-approved homeless management information systems for purposes of collecting unduplicated counts of homeless persons and analyzing patterns of use of HPRP funds. 4 This amount must match the amount entered in the cell on the table in Section A titled Amount Grantee is Requesting. 9 HUD-40119
F. Authorized Signature By signing this application, I certify (1) to the statements contained in the list of certifications and (2) that the statements herein are true, complete, and accurate to the best of my knowledge. I also provide the required assurances and agree to comply with any resulting terms if I accept an award. I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties. (U.S. Code, Title 218, Section 1001) Signature/Authorized Official Date Chair, Tulsa County Board of Commissioners Title 10 HUD-40119