Shelter Plus Care Policy and Procedures Feb 5

Shelter Plus Care Policy and Procedures Feb. 5, 2019 Melodie Garrett, Compliance Officer

HUD Rules and Regulations HUD PART 582. 300…General operation: (d) Records and reports: (1) Each recipient must keep any records and, within the time frame required, make any reports (including those pertaining to race, ethnicity, gender, and disability status data) that HUD may require. (3) Each recipient must develop, and make available to the public upon request, its procedures for managing the rental housing assistance funds provided by HUD. At a minimum, such procedures must describe how units will be identified and selected; how the responsibility for inspections will be handled; the process for deciding which unit a participant will occupy; how participants will be placed in, or assisted in finding appropriate housing; how rent calculations will be made and the amount of rental assistance payments determined; and what safeguards will be used to prevent the misuse of funds.

GHFA/DCA Rules and Regulations DCA Contractual Reference: (DCA & GHFA-SPC Program Management Guide, page 9) POLICIES & PROCEDURES REQUIRED OF SPONSORS: The following policies and procedures are required to be in writing and will be monitored by the DCA monitoring team: Occupancy Agreements Homeless determination and documentation Disability determination and documentation Housing Quality Standards Outreach Activities Matching Requirements Client Rent Termination of Assistance

Continued: Policy and Procedures Nondiscrimination and Equal Opportunity Requirements Records and Reports Tenant Selection Criteria and Scope of Services Provided Housing First Coordinated Assessment Violence Against Women Act Limited English Proficiency Memorandum of Understand with housing and supportive service providers Confidentiality Fair Housing Conflict of Interest

Managing your grant- Our responsibilities For S+C, the grant agreement is between HUD and GHFA (recipient). HUD holds GHFA responsible for the overall administration of the program. Under the grant agreement, GHFA must agree to operate the program in accordance with the provisions of Part 582 and other applicable HUD regulations. GHFA will hold the Sponsor (sub-recipient) to the same standards. This concept is called “flow down” or “flow through”.

Managing your grant- Your responsibilities S+C Sponsor responsibilities fall under four categories: n Legal- These responsibilities are not negotiable by HUD or GHFA n Regulatory- These responsibilities come from negotiation with the public in the normal regulatory process. Regulations that apply to this grant include HUD Chapter V PART 582 --SHELTER PLUS CARE, CARE OMB Circular A-133, and all regulations referred to in these guidelines. n Contractual- These requirements come from the contract you signed when you accepted the award. The contract also refers to your obligation to meet legal and regulatory responsibilities. Reference. Exhibit B-Contract Provisions n Policies and procedures- These requirements come

Occupancy Agreement Develop a written procedure to address that a participant must enter into an occupancy agreement for a term of at least one month. The occupancy agreement must be automatically renewable upon expiration, except on prior notice by either party. Agreement should outline the rights and responsibilities of the participant while in the program to include rental share, explanation and expectations of the program, termination and appeals process, signature and date

Homeless Determination and Documentation Develop a written procedure of how an individual is determined to be Homeless per HUD’s Homeless Definition. This policy should outline the process of obtaining documentation: Homeless verification forms, 3 rd Party verification letters, Self Certification.

Disability Determination and Documentation Develop a written procedures on the basis of determining disability according to HUD’s definition and the documentation process. Disability form must be complete, signed by a Certified Professional, include Professional’s title, License number and date signed.

Housing Quality Standards Develop written procedures regarding the process for selecting housing units for the program. Determine that each housing unit used in the program meets HUD’s rent reasonableness requirements. Keep documents on file for monitoring review. Conduct a “rent reasonableness survey” of the rental market for each unit. Complete the “Certification for Rent Reasonableness” form and a “Rent Reasonableness Checklist” for each unit. Ensure that all units being considered for use in the program meets HUD “Housing Quality Standards” and lead-based paint requirements by: requesting initial inspection by DCA staff; coordinate with DCA staff for annual re-inspection; and if the unit fails either inspection, follow the guidelines for repair, or move the participant to appropriate housing.

Outreach Activities Develop a written procedures of how the agency will provide or arrange for supportive services for each individual participating in the program based on individualized need by making available information on the existence and locations of facilities and services.

Matching Requirements Develop a written procedure of the process for documenting and reporting match at an amount not less than 25% of "Funds Available" over the term of the grant or the amount listed in the original application for funding.

Client Rent Develop a written procedure on determining and documenting the participant’s/household’s income – at entry – does not exceed 50% of the median income (very low income limits) for the locality; review and document the participant/household income on an annual basis to determine rental share only. (Visit www. huduser. org/datasets/il. html for a listing of HUD income limits). Calculate the participant’s contribution toward the rent (30% of adjusted gross income, or 10% of the gross income, whichever is higher).

Termination of Assistance Develop a written procedure of the guidelines for termination of assistance to a participant following the HUD regulation 582. 320. (a) Termination of Assistance, (b) Due Process.

Nondiscrimination and Equal Opportunity Requirements Develop a written procedure outlining the nondiscrimination and equal opportunity requirements set forth in 24 CFR 583. 330 (a) are applicable.

Records and Reports Develop a written procedure to establish and maintain standard operating procedures for ensuring that program funds are used in accordance with the requirements of this part and must establish and maintain sufficient records according to HUD guidelines.

Tenant selection criteria and scope of services to be provided Develop a written procedure on the criteria for selecting a tenant for the program and the scope of services provided for participants in the program.

Housing First Develop a written procedure to incorporate practices that prevent lease violations and evictions among tenants. Housing First is a model of housing assistance that involves reducing barriers to entry into the program.

Coordinated Assessment Develop a written procedure on the centralized or coordinated assessment that provides an initial, comprehensive assessment of the needs of individuals and families for housing and services. Follow the Coordinated Entry guidelines. Required if agency is located in one of the current implementation sites.

Violence Against Women Act (VAWA) Develop a written procedure on the process of providing a written notification to applicants, participants, and property owners and managers, concerning the rights and obligations created under VAWA relating to confidentiality, denial of assistance and, termination of tenancy or assistance.

Limited English Proficiency Develop a written procedure on the training for staff regarding LEP requirements and a method to track LEP services provided to LEP persons.

Memorandum of Understanding Develop a written procedure on the process of establishing an official partnership with housing and supportive services providers.

Confidentiality In addition to meeting the specific confidentiality and security requirements for HMIS data, develop and implement written procedures to ensure: (1) All records containing protected identifying information of any individual or family who applies for and/or receives Continuum of Care assistance will be kept secure and confidential; (2) The address or location of any family violence project assisted with Continuum of Care funds will not be made public, except with written authorization of the person responsible for the operation of the project; and (3) The address or location of any housing of a program participant will not be made public, except as provided under a preexisting privacy policy of the recipient or subrecipient and consistent with State and local laws regarding privacy and obligations of confidentiality;

Fair Housing Develop a written procedure to follow the guideline of the HUD regulation 578. 93 (b) Housing for specific subpopulations. (c) Affirmatively furthering fair housing.

Conflict of Interest Develop a procedure to follow the guidelines of HUD regulation 578. 95: § (a) Procurement § (c) Organizational conflict § (d) Other conflicts

Financial Policies and Procedures Internal Controls Disbursements Purchasing and Acquisition Cash Receipts Accounting Record Retention

QUESTIONS? Reference: • DCA Shelter Plus Care Program Guidelines • HUD-CFR Part 582 -Shelter Plus Care • GA Bo. S Co. C Written Standards

Contact Information Melodie Garrett Compliance Officer, Shelter Plus Care Georgia Department of Community Affairs 404 -851 -7088 melodie. garrett@dca. gov