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Frequently Asked Questions (FAQs): HPRP
Find answers to commonly asked questions about:
- HUD homeless assistance programs and policies, including questions regarding the most recent (2009) CoC NOFA application. (Note: If your grant award is from a previous year, please refer to NOFA FAQs from Previous Grant Years to find the NOFA FAQs that correspond to that grant award.);
- HOPWA Short-term Rent, Mortgage, and Utility Assistance (STRMU) Payments; and
- Homelessness Prevention and Rapid Re-Housing Program (HPRP);
For information regarding the HRE, visit About the HRE. For HPRP questions not addressed in this section, please visit the HPRP Virtual Help Desk.
If you have a question on a topic other than HPRP that is not addressed in this section, please visit the Contact Us page to obtain contact information for your local HUD Field Office.
You may search the FAQs by program/system, topic, keyword, and date, or browse the FAQs by program/system.
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HPRP
- Eligible Grantees and Subgrantees
- Substantial Amendment Requirements and Process
- Funds Distribution & Subgrantee Selection
- Grants Management and Monitoring
- Eligible Participants (Clients)
- Eligible Activities/Costs - Financial Assistance
- Eligible Activities/Costs - Housing Relocation and Stabilization Services
- Eligible Activities/Costs - Data Collection and Evaluation
- Eligible Activities/Costs - Administrative Costs
- Determining and Documenting Client Eligibility
- Housing and Lead Inspections
- Lease and Rent Requirements
- Collecting Client-Level Data (HMIS & Comparable Databases)
- Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS)
- Technical Assistance
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| Topic: Eligible Grantees and Subgrantees | |||
|---|---|---|---|
| Date | Program/ System |
Question | Answer |
| 1/6/10 | HPRP | What information must the grantee submit to request a conflict of interest waiver? | There are two situations that are often referred to as a “conflict of interest.” 1) The first is when HPRP program participants are to be assisted in a property that is owned by the grantee, subgrantee, or the parent/subsidiary/affiliated organization of the subgr... |
| 9/11/09 | HPRP | Can a Metropolitan City or Urban County HPRP grantee subgrant funds to Public Housing Agencies, Housing and Redevelopment Authorities, and other Special Purpose Governmental Organizations? | Metropolitan Cities and Urban Counties may subgrant to private non-profit organizations or other units of general purpose local government. In the vast majority of cases, a city or county PHA, HRA, or other special purpose public agency is not recognized as a unit of gen... |
| 9/11/09 | HPRP | Can a State HPRP grantee subgrant funds to Public Housing Agencies, Housing and Redevelopment Authorities, and other Special Purpose Governmental Organizations? | State HPRP grantees may only subgrant to private non-profit organizations and units of general purpose local government. In the vast majority of cases, the State cannot subgrant its HPRP funds to a PHA or HRA because these are not units of general purpose local governmen... |
| 8/14/09 | HPRP | In Section III, Part A, the HPRP Notice indicates that state grantees may subgrant directly to private nonprofit organizations “if the local government for the locality in which the program is located certifies that is approves of the program.” When does this rule apply, and what does certification entail? (REVISED) | The only instance that local certification is required is when state grantee is allocating HPRP funds to non-profit organizations located in an area outside of the state’s Consolidated Plan jurisdiction. That is, when a state subgrants HPRP funds to a non-profit organiza... |
| 6/10/09 | HPRP | Will subgrantees (cities, counties and non-profit organizations) be required to register with the Central Contractor Registry (CCR) and obtain a DUNS number? | As stated in Section IV (E) (8) of the HPRP Notice, “All grantees and subgrantees are required to register with Dun and Bradstreet to obtain a DUNS number, if they have not already done so, and complete or renew their registration with the Central Contractor Registration... |
| 6/10/09 | HPRP | Where can a list of "entitlement communities" or HPRP grantees be found? | To find this information, please refer to the HPRP Eligible Grantees with CDBG Contact Information document which is posted on the HUD HRE website at http://www.hudhre.info/ |
| 5/8/09 | HPRP | Can HPRP funds awarded to an entitlement city or county be used outside of the city or county’s jurisdiction? | Grantees may provide rental assistance or services to eligible program participants who are residing or would like to reside outside their jurisdiction. They may also fund subgrantees that serve persons outside of the jurisdiction, subgrantees that are located outside of... |
| 4/24/09 | HPRP | Who are eligible grantees for HPRP funding? (REVISED) | States, U.S. territories, metropolitan cities, or urban counties are eligible grantees for HPRP funding. Grantees may subgrant to local units of government, which may include metropolitan cities and urban counties that receive HPRP funds directly from HUD, and/or to priv... |
| 4/24/09 | HPRP | Can non-urban areas apply for funds through this application? (REVISED) | Appendix A of the HPRP Notice provides a list of eligible grantees that can apply and receive HPRP funding directly from HUD through the Consolidated Plan Substantial Amendment process. Local governments that are not eligible grantees and nonprofit organizations must con... |
| 4/24/09 | HPRP | Can a state grantee sub-grant funds to another state agency, such as a state mental health or foster care agency? | A state grantee may not subgrant HPRP funds to another state agency. The American Recovery and Reinvestment Act cites Section 413 of the ESG statute as to how the funds must be allocated, and per Section 413(a), funds are intended for “distribution to local governments a... |
| 4/24/09 | HPRP | Are tribal units of government eligible recipients of funds in a subgrantee capacity from the State? | No, tribal governments are not eligible subgrantees. State HPRP grantees must subgrant funds to either units of general local government in the state – which may include metropolitan cities and urban counties that receive grants amounts directly from HUD – or private nonp... |
| 4/3/09 | HPRP | Are non-profits eligible to apply for funds directly from HUD? | Nonprofit organizations are not eligible to submit an application for HPRP funding directly to HUD. States, urban counties, metropolitan cities, and U.S. territories are eligible applicants under HPRP. Once these eligible applicants become grantees, they may subgrant wi... |
| 3/20/09 | HPRP | Why was $500,000 chosen as the minimum amount that will be allocated to grantees? | HPRP funds were allocated according to the Emergency Shelter Grants (ESG) formula. In the ESG program, the minimum grant amount is 0.05 percent; however, the Recovery Act gave the Secretary discretion to set the minimum grant amount. At $500,000 (approximately 0.033 per... |
| Return to Topics | |||
| Topic: Substantial Amendment Requirements and Process | |||
| Date | Program/System |
Question | Answer |
| 8/14/09 | HPRP | At what point must a grantee prepare a budget amendment? For the Supportive Housing Program, budget amendments are triggered if there is a change in a particular budget category that exceeds 10 percent. | HUD has not set a specific percentage for changes to the HPRP budget submitted in the grantee's substantial amendment. The Consolidated Plan regulations require grantees to establish criteria in their Citizen Participation Plan for what constitutes a substantial amendment... |
| 6/10/09 | HPRP | Will subgrantees (cities, counties and non-profit organizations) be required to register with the Central Contractor Registry (CCR) and obtain a DUNS number? | As stated in Section IV (E) (8) of the HPRP Notice, “All grantees and subgrantees are required to register with Dun and Bradstreet to obtain a DUNS number, if they have not already done so, and complete or renew their registration with the Central Contractor Registration... |
| 5/14/09 | HPRP | With regard to Form SF-424, what is the Catalog of Federal Domestic Assistance (CDFA) number and CDFA title? (REVISED) | The CFDA number and title is 14.257: Homelessness Prevention and Rapid Re-Housing Program (item 11). Please note that there is no Applicant Identifier (item 4), Federal Entity Identifier (item 5a), Federal Award Identifier (item 5b), Funding Opportunity Number (item 12),... |
| 5/14/09 | HPRP | Where should the substantial amendment be sent? | As stated in the Notice under Section IV (E) – Application Requirements #4, each grantee must provide HUD with two hard copies of the completed substantial amendment. The original should be sent to HUD Headquarters in Washington, DC: U.S. Department of Housing and Urban... |
| 5/8/09 | HPRP | How should a grantee calculate the budget for Data Collection and Evaluation costs? Is there a recommended or maximum amount that grantees should budget for Data Collection and Evaluation costs? | HPRP grantees are required to collect client-level data through the CoC’s Homeless Management Information System (HMIS) or a comparable database to comply with the HPRP monitoring and reporting requirements. HPRP funds may be used to pay reasonable costs associated with... |
| 4/24/09 | HPRP | Where is the application and what does it include? (REVISED) | Appendix A of the HPRP Notice provides a list of the eligible grantees that can apply and receive HPRP funding directly from HUD through the Consolidated Plan Substantial Amendment process. HUD has developed a Substantial Amendment form that these eligible grantees must... |
| 4/24/09 | HPRP | Where can I find the latest version of Form SF-424? (REVISED) | Use the SF-424 posted online at: http://www.grants.gov/ |
| 4/24/09 | HPRP | Form 40119 does not have much space on it for narrative. Is the form itself considered the "substantial amendment" or should we write a longer, more narrative amendment and attach it to the form? | Grantees are required to use the actual form (HUD-40119) posted on the HRE and on HUD's website. Since this form is in a Word format, grantees may enter as much information as needed to amend their Annual Action Plan appropriately. However, please be mindful of the maxi... |
| 4/24/09 | HPRP | How long does it generally take for subgrantees to be issued a DUNS number? Is there any available guidance to help subgrantees as they register to get a DUNS number? | Please seek the following link regarding registration for a DUNS number: http://fedgov.dnb.com/webform/ |
| 4/24/09 | HPRP | When preparing our amendment, would we have to spell out how we are going to allocate the entire HPRP grant in that initial amendment? For example, if a grantee is receiving $1,000,000 in HPRP funds and wants to set aside $600,000 for utility deposit assistance and short/medium term rental assistance, but is unsure how they are going to allocate the remaining $400,000, would it be acceptable to state that the remaining funds will be used for other HPRP-eligible projects? | The substantial amendment, which must be postmarked no later than May 18, 2009, requires grantees to indicate the estimated amount for each of the four activity types (financial assistance, housing relocation and stabilization services, data collection and evaluation, and... |
| 4/24/09 | HPRP | Will all the HPRP funds obligated by September 30, 2009 continue to be part of the 2008 Action Plan even if it is spent over the three year period? In year 2, could the grantee again amend the 2008 Action Plan to adjust allocations or subgrantees? | The Substantial Amendment to the Consolidated Plan 2008 Action Plan is the grantee’s plan for spending HPRP funds. Grantees do not include their subgrantee selections and awards in their Substantial Amendment form. The subgrantee selection and award information will be... |
| 3/20/09 | HPRP | Do HPRP funds have a match requirement? | No, grantees are not required to match HPRP funds with any other funding. |
| 3/20/09 | HPRP | When will HUD complete their review of the substantial amendments? | HUD will complete its review of all correctly completed substantial amendments within 45 days of receipt of each substantial amendment, but no later than July 2, 2009. Jurisdictions with disapproved substantial amendments may revise and resubmit a substantial amendment... |
| 3/20/09 | HPRP | What happens if the eligible grantee wants to decline funding? | If an eligible grantee receives an allocation of funds under HPRP and wishes to decline the funding, the legally authorized official must notify the local HUD field office in writing of the grantee’s intent to decline the HPRP funding on or before May 18, 2009. |
| 3/20/09 | HPRP | What happens if the eligible grantee wishes to request less funding than the total allocation amount? | If an eligible grantee wishes to request less than the total allocation amount for which it is eligible, the legally authorized official must notify the local HUD field office in writing of the amount the grantee will request on or before May 18, 2009. |
| 3/20/09 | HPRP | What happens if the eligible grantee does not submit a completed application within the timeframe allotted? | If an eligible grantee fails to submit a completed application package (substantial amendment, certifications and SF-424) for its grant allocation per the requirements detailed in the Notice, HUD will notify the jurisdiction of the cancellation of all or part of its alloc... |
| 3/20/09 | HPRP | Is the HPRP part of the Consolidated Plan process? | Portions of the Consolidated Plan process related to the application and approval process for receiving HPRP funds do apply, as indicated in the Notice. Grantees must submit an amendment to the Consolidated Plan 2008 Action Plan in order to receive funds, and grantees ar... |
| 3/20/09 | HPRP | What is the deadline to submit the substantial amendment? | Substantial amendments, certifications, and the SF-424 (the application package) must be postmarked by May 18, 2009. |
| Return to Topics | |||
| Topic: Funds Distribution & Subgrantee Selection | |||
| Date | Program/System |
Question | Answer |
| 1/6/10 | HPRP | What information must the grantee submit to request a conflict of interest waiver? | There are two situations that are often referred to as a “conflict of interest.” 1) The first is when HPRP program participants are to be assisted in a property that is owned by the grantee, subgrantee, or the parent/subsidiary/affiliated organization of the subgr... |
| 9/11/09 | HPRP | What is the September 30th deadline and what are the consequences if we cannot meet it? Can we request a waiver of this deadline? | Section V.A.1. of the HPRP Notice requires grantees to “award or enter into legally binding agreements with all subgrantees by September 30, 2009.” If a grantee issues award letters to subgrantees by the deadline, HUD will consider the grantee to have met the requirement... |
| 8/14/09 | HPRP | Must grantees obligate 100% of funds by September 30, or can they reserve a portion of the funding to be awarded in years 2 and 3 based on subgrantee performance? | As indicated in the Notice, all funds must be obligated to subgrantees by September 30, 2009. However, grantees may establish spending or performance expectations, and they may recapture and reallocate funds from subgrantees who do not meet the requirements. |
| 8/14/09 | HPRP | In Section III, Part A, the HPRP Notice indicates that state grantees may subgrant directly to private nonprofit organizations “if the local government for the locality in which the program is located certifies that is approves of the program.” When does this rule apply, and what does certification entail? (REVISED) | The only instance that local certification is required is when state grantee is allocating HPRP funds to non-profit organizations located in an area outside of the state’s Consolidated Plan jurisdiction. That is, when a state subgrants HPRP funds to a non-profit organiza... |
| 6/10/09 | HPRP | When will grantees release their requests for subgrantee applications to community organizations? | Grantees were required to submit their Substantial Amendments to HUD by May 18, 2009 and are required to obligate funds to subgrantees by September 30, 2009. In that amendment, grantees had to explain the process they will use to distribute funds. Grantees are not requir... |
| 6/10/09 | HPRP | Can a State use a combination process and award HPRP funds directly to units of general local government (for example, counties) and directly to a regional or statewide non-profit? | HUD is providing all grantees, including state grantees, with the discretion to subgrant to local nonprofits or local governments to carry out HPRP activities (see section III.C of the HPRP Notice). HUD also provides discretion for grantees to develop a subgrantee selecti... |
| 6/10/09 | HPRP | If a city is not a grantee, must it apply to the State grantee or, if the county in which the city is located is an HPRP grantee, must the city apply to the county? | The county, as a grantee, has the discretion to distribute HPRP funds to the cities within its jurisdiction as subgrantees. The city is also eligible to receive funds from the State as a subgrantee, at the discretion of the State grantee. Further, cities and counties may... |
| 6/10/09 | HPRP | Can a grantee or subgrantee procure services from a for-profit organization to implement the local HPRP program? Services could include particular aspects related to program administration (e.g., inspections), technical assistance, etc. | Grantees and sub-grantees can procure services from for-profit organizations. Grantees and sub-grantees must follow the applicable federal procurement rules: -24 CFR Part 85, applicable to States and local governments -OMB Circular A-110 as implemented thro... |
| 6/10/09 | HPRP | With regard to the obligation of funds, page 32 of the Notice states that “grantees must award or enter into legally binding grant agreements with all subgrantees by September 30, 2009.” Is there a difference between “awarding funds” and entering into a “legally binding agreement”? | No, there is no difference. Section V. J. of the Notice on page 36 states "Grantee signs agreements with subgrantees by September 30, 2009." Therefore, "grantees must award" means that the grantee must have signed agreements with the subgrantees by Se... |
| 5/8/09 | HPRP | What process would an eligible municipality use to allow another eligible entity to carry out HPRP activities cooperatively, combining both jurisdictions’ funds? | A metropolitan city or urban county that receives a grant allocation directly from HUD may subgrant to another local government. By subgranting their allocation, the grantee maintains responsibility for oversight and all other grantee responsibilities that are required w... |
| 4/24/09 | HPRP | Does the grantee have to engage in a competitive process for the selection of sub-grantees? Does this process have to be included in the Consolidated Plan submission? | HUD is giving discretion to grantees to develop their own allocation process. The grantee's plan for distribution, administration, and oversight of funds needs to be addressed in the Substantial Amendment that is submitted to HUD to receive HPRP funding. Note that it is... |
| 4/24/09 | HPRP | Can a state grantee sub-grant funds to another state agency, such as a state mental health or foster care agency? | A state grantee may not subgrant HPRP funds to another state agency. The American Recovery and Reinvestment Act cites Section 413 of the ESG statute as to how the funds must be allocated, and per Section 413(a), funds are intended for “distribution to local governments a... |
| 4/3/09 | HPRP | Can a State award HPRP funds in an area that receives its own HPRP allocation, or is the State restricted to distributing funds in non-entitlement areas? | Under HPRP, a state may subgrant with areas that receive a direct allocation from HUD. |
| 3/20/09 | HPRP | What is the deadline for grantees to obligate funds? | Grantees must select all subgrantees and obligate funds to them by September 30, 2009. |
| Return to Topics | |||
| Topic: Grants Management and Monitoring | |||
| Date | Program/System |
Question | Answer |
| 1/6/10 | HPRP | When completing the Staff Affidavit, is a case manager required to determine if the applicant has a familial connection to any grantee or subgrantee staff? If an individual seeking assistance is related to a grantee or subgrantee staff member, is he/she automatically disqualified? | A familial connection between an applicant and a staff member of the grantee or subgrantee agency does not necessarily mean that there is a conflict of interest, and it would not automatically disqualify him/her from receiving assistance. It does, however, disqualify the... |
| 1/6/10 | HPRP | What information must the grantee submit to request a conflict of interest waiver? | There are two situations that are often referred to as a “conflict of interest.” 1) The first is when HPRP program participants are to be assisted in a property that is owned by the grantee, subgrantee, or the parent/subsidiary/affiliated organization of the subgr... |
| 10/29/09 | HPRP | Is the Staff Affidavit required only when financial assistance is being provided? | No – the Staff Affidavit must be used regardless of whether the household is receiving financial assistance or housing relocation and stabilization services. Both represent an expenditure of HPRP grant funds for eligible households. |
| 10/29/09 | HPRP | Why is HUD making HPRP grantees sign the Staff Affidavit? | The HPRP Staff Affidavit is intended to protect HUD and grantees against fraud and abuse charges. The Staff Affadavit serves to remind HPRP program staff that they are legally bound to determine and document the eligibility of applicants according to HPRP requirements bef... |
| 10/29/09 | HPRP | What is the HPRP Staff Affidavit and who must sign it? | The Staff Affidavit is a new requirement for all households determined to be eligible for HPRP assistance. The Staff Affidavit documents that the HPRP household meets all eligibility criteria for HPRP assistance, certifies that true and complete information was used to de... |
| 8/14/09 | HPRP | How will HUD’s monitoring for HPRP be conducted? | HUD will conduct on-site monitoring using the CPD Monitoring handbook 6509.2 as a guide, as is done with ESG or CDBG and other CPD programs. HUD is currently developing specific monitoring procedures for HPRP. HUD will also conduct desk (off-site) monitoring, and will b... |
| 8/14/09 | HPRP | At what point must a grantee prepare a budget amendment? For the Supportive Housing Program, budget amendments are triggered if there is a change in a particular budget category that exceeds 10 percent. | HUD has not set a specific percentage for changes to the HPRP budget submitted in the grantee's substantial amendment. The Consolidated Plan regulations require grantees to establish criteria in their Citizen Participation Plan for what constitutes a substantial amendment... |
| 6/10/09 | HPRP | What is the timeframe to spend HPRP funds? (REVISED) | The Recovery Act requires grantees to draw down from IDIS 60 percent of HPRP grant funds within two years of the date that HUD signed the grant agreement, and 100 percent of funds within three years of this date. If a grantee receives any reallocated funds, these must all... |
| 6/10/09 | HPRP | Will a Single Audit be acceptable for the HPRP program or will a project audit be required? | All grantees and subgrantees must conduct audits as required under the OMB Circulars for the type of organization and the funding streams received by the organization. In general, an HPRP-specific project audit will not be required in addition to a Single Audit (see OMB C... |
| 6/10/09 | HPRP | Can a grantee or subgrantee procure services from a for-profit organization to implement the local HPRP program? Services could include particular aspects related to program administration (e.g., inspections), technical assistance, etc. | Grantees and sub-grantees can procure services from for-profit organizations. Grantees and sub-grantees must follow the applicable federal procurement rules: -24 CFR Part 85, applicable to States and local governments -OMB Circular A-110 as implemented thro... |
| 5/8/09 | HPRP | Grantees and subgrantees have three years from the date the grant agreement is executed to expend all funds. Will there be a grace period so that a client enrolled near the end of the grant agreement period can continue to receive assistance for the entire length of time deemed necessary to stabilize that client? | HPRP funds may not be expended after three years from the date of the grant agreement. This means that grantees and subgrantees will need to plan in advance - in order for a program participant to receive a full 18 months of rental assistance, they would need to begin rec... |
| 5/8/09 | HPRP | What process would an eligible municipality use to allow another eligible entity to carry out HPRP activities cooperatively, combining both jurisdictions’ funds? | A metropolitan city or urban county that receives a grant allocation directly from HUD may subgrant to another local government. By subgranting their allocation, the grantee maintains responsibility for oversight and all other grantee responsibilities that are required w... |
| 4/24/09 | HPRP | Can grantees draw down funds as a cash advance, or do they have to be reimbursed? (REVISED) | The preferred method is reimbursement. However, grantees and subgrantees may be paid in advance, pursuant to procedures outlined in 24 CFR 84.22 for nonprofit organizations and 24 CFR 85.21 for units of government. All requirements in 24 CFR 84.22 or 24 CFR 85.21, as ap... |
| 4/3/09 | HPRP | Will there be flexibility to adjust budgets among the four eligible funding areas during the contract period? | HPRP grantees may adjust budgeted amounts for the eligible activities just as they do under ESG. The Substantial Amendment to the grantee's 2008 Annual Action Plan, completed by the grantee to receive HPRP funds, is only a planned budget. Actual budgets may vary during i... |
| 4/3/09 | HPRP | Is there a cap on any of the funding categories? For example, is there a cap on services or data collection and evaluation? | The only limit is on administrative costs, which are limited by statute to 5 percent of the grant amount. Grantees should consider the extent and variety of needs in their communities in order to determine how much to spend on any given type of activity. |
| 3/20/09 | HPRP | What happens if the grantee cannot meet the expenditure threshold? | If the grantee cannot meet this threshold, HUD may then proceed to recapture the unused HPRP funds and reallocate them. |
| 3/20/09 | HPRP | What happens if the grantee does not spend at least 60 percent of the grant amount within the 2 year timeframe? | Any grantee failing to meet the statutory requirement to expend at least 60 percent of its grant amount within 2 years of the date of the obligation, will be notified by August 1, 2011 and given 21 days to submit information to HUD regarding additional eligible expenses f... |
| Return to Topics | |||
| Topic: Eligible Participants (Clients) | |||
| Date | Program/System |
Question | Answer |
| 1/6/10 | HPRP | How is a household defined for purposes of HPRP? | Under the HPRP program, a household is a single individual or group of persons who together apply to an HPRP-funded program for assistance and together meet the conditions outlined in the HPRP Notice for eligible program participants. Note that if two unrelated individua... |
| 1/6/10 | HPRP | If otherwise eligible for HPRP assistance, can ex-offenders or offenders who are scheduled for release but have no suitable housing options be assisted with HPRP? | HPRP regulations do not require grantees to disqualify individuals or families based on criminal history. HUD requires only that all program participants meet the minimum eligibility criteria and that grantees comply with all local and Federal requirements. Grantees... |
| 1/6/10 | HPRP | If a client is terminated from HPRP for non-compliance, are they eligible to re-apply for services? | Each grantee has the discretion to decide whether to allow participants that have been terminated for non-compliance to re-apply for assistance, and if so, the timeline for re-application. Please note that the HPRP Notice requires grantees to have a formal termination pr... |
| 1/6/10 | HPRP | Can HPRP funds be used to assist illegal immigrants? If so, what type of identification documentation is acceptable? | In accordance with Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, an alien (a person who is not a U.S. citizen or national) may be eligible for assistance under HPRP only if he or she is a “qualified alien” (defined in 8 U.S.C. 16... |
| 1/6/10 | HPRP | What information must the grantee submit to request a conflict of interest waiver? | There are two situations that are often referred to as a “conflict of interest.” 1) The first is when HPRP program participants are to be assisted in a property that is owned by the grantee, subgrantee, or the parent/subsidiary/affiliated organization of the subgr... |
| 8/14/09 | HPRP | In a situation where there are two unrelated individuals on a lease - one who is eligible, and one who is not – can a grantee assist the eligible individual? | If two unrelated individuals are joint parties to a lease, a grantee must consider total household income to determine eligibility (i.e., either the whole household is eligible for assistance, or the whole household is not). |
| 8/14/09 | HPRP | HUD has indicated that grantees may provide rental assistance or services to eligible program participants who are residing or would like to reside outside their jurisdiction. Does this mean that grantees can serve persons in another state? | It is up to the grantee to determine if they wish to assist persons in another state. This may be common where a metropolitan community or Continuum of Care crosses state boundaries. However, if they do so, the grantee retains responsibility for ensuring that all requir... |
| 8/14/09 | HPRP | If a participant is receiving rental assistance through another program, can they also receive HPRP assistance? | HPRP assistance cannot be provided to eligible individuals or families for the same period of time and for the same cost types that are being provided through another Federal, state, or local subsidy program. There are six cost types: rental assistance, security deposit... |
| 6/10/09 | HPRP | The activities funded under the prevention and re-housing categories seem to be the same. How do I know the category under which to draw down funds in IDIS? Is the distinction between participants who are assisted to stay in their existing housing and those that are placed in new housing? | All persons assisted with HPRP funds—whether it is considered prevention or rapid re-housing assistance—may receive assistance from any of the HPRP eligible activities. The distinction is related to the population served. The difference is that persons receiving preventi... |
| 6/10/09 | HPRP | What assistance can be provided to homeowners? (REVISED) | While mortgage assistance is not eligible under HPRP, homeowners who become homeless are eligible for all HPRP activities, provided they meet the other eligibility criteria as listed in the Notice. Homeowners who are housed but are at risk of becoming homeless and meet al... |
| 6/10/09 | HPRP | If an individual has severe and persistent physical or mental health issues that would make them a good fit for a permanent supportive housing program (like Shelter Plus Care-funded housing), but there are no available openings in such programs, can the person access HPRP funds while they sit on the waiting list? (REVISED) | The intent of the legislation is to assist persons who need temporary assistance to obtain or remain in housing, and hopefully be able to sustain housing, subsidized or unsubsidized, once HPRP ends. That said, persons who are disabled and eligible for permanent supportiv... |
| 6/10/09 | HPRP | Under HPRP, if homeless families are re-housed and receive short or medium-term rental assistance, will this make them ineligible for a CoC-funded transitional or permanent supportive housing program? In other words, does participation in HPRP eliminate an individual’s homeless status? (REVISED) | HPRP assistance is temporary. Persons who were homeless before receiving HPRP assistance (Rapid Re-housing assistance) do not lose their homeless status and remain eligible for assistance under other CoC-funded programs. However, chronically homeless persons that receive... |
| 6/10/09 | HPRP | Are set-asides allowed for any specific population who may be, at some point, at risk of losing their jobs? | No. Grantees may not set aside funds for a specific group of people who are not yet eligible for HPRP funds. HPRP eligibility must be determined on a case-by-case basis, upon the required initial visit with a case manager or other professional who is qualified to determin... |
| 6/10/09 | HPRP | Under HPRP, is there an age restriction on persons receiving assistance? | No, there are no age restrictions. However, just as with McKinney-Vento programs, HPRP funds may not be used to serve youth who are wards of the state. |
| 6/10/09 | HPRP | Under HPRP, are people living doubled-up with friends or family considered to be at risk of homelessness? Are they eligible to receive HPRP funds? | Families or individuals who are precariously housed may be eligible for HPRP prevention assistance if is determined that they would be “homeless but for this assistance” and they meet all other HPRP eligibly criteria, as specified in the Notice. |
| 6/10/09 | HPRP | If a program participant initially received short-term rental assistance for 3 months and needs additional assistance, are they eligible to receive more funding through the HPRP? (REVISED) | Yes, after 3 months, if program participants receiving short-term rental assistance need additional financial assistance to remain housed, they must be re-evaluated for eligibility and appropriateness of services/assistance (ie, would the participant be homeless “but for”... |
| 5/8/09 | HPRP | Can HPRP funds be used to assist individuals/families in transitional housing? | HPRP funds may not be used to move an individual or family into a transitional housing program, nor may it be used to assist persons residing in a transitional housing program. However, HPRP funds may be used to assist persons that are graduating from or timing out of a t... |
| 5/8/09 | HPRP | Can HPRP funds awarded to an entitlement city or county be used outside of the city or county’s jurisdiction? | Grantees may provide rental assistance or services to eligible program participants who are residing or would like to reside outside their jurisdiction. They may also fund subgrantees that serve persons outside of the jurisdiction, subgrantees that are located outside of... |
| 4/3/09 | HPRP | I have lost my job and I am losing my home. I will be homeless soon. How do I apply for HPRP funds? | The Homelessness Prevention and Rapid Re-Housing Program (HPRP) is a new program funded under the American Recovery and Reinvestment Act of 2009. Funds have been awarded to eligible cities, counties, states, and territories. HUD does not provide funding directly to indiv... |
| 4/3/09 | HPRP | Will citizens returning to the community following discharge from a state correctional system (who meet all stated eligibility requirements) be eligible for receipt of short-term housing assistance? | Yes, persons who are discharged from publicly funded institutions and who meet all HPRP eligibility requirements may receive financial assistance and/or services under HPRP. |
| 3/20/09 | HPRP | Who can receive HPRP assistance? | There are two populations of persons facing housing instability that are eligible to receive funding under the HPRP: 1) individuals and families who are currently in housing but are at risk of becoming homeless and need temporary rent or utility assistance to prevent them... |
| 3/20/09 | HPRP | Does a program participant need to have a child or children in the household to be eligible to receive assistance? | No, a program participant can be an individual or a household with or without children. |
| 3/20/09 | HPRP | As a grantee, can I establish more strict requirements than HUD has established? | Yes. HUD is providing grantees with discretion to establish requirements that further target community needs. Grantees may elect to implement more stringent targeting and/or eligibility requirements as long as all program participants meet the minimum eligibility criter... |
| Return to Topics | |||
| Topic: Eligible Activities/Costs - Financial Assistance | |||
| Date | Program/System |
Question | Answer |
| 1/6/10 | HPRP | Are costs related to the conduct of the inspections an eligible cost under the category of financial assistance? (REVISED) | The costs associated with conducting a habitability (or HQS) inspection are eligible under the financial assistance category. The costs should generally be charged to Rental Assistance, unless the agency is providing the household with, for example, security deposit or u... |
| 1/6/10 | HPRP | Can HPRP financial assistance be used to cover "excess utilities" for public housing tenants, over and above the amount subsidized in public housing? | No. As explained in the Notice, HPRP assistance cannot be provided to eligible individuals or families for the same period of time and for the same cost types that are being provided through another Federal, state, or local subsidy program. If a participant is receiving... |
| 1/6/10 | HPRP | If a household is receiving LIHEAP assistance for help with a gas bill, are they eligible for HPRP assistance for other utilities? | No. As explained in the Notice, HPRP assistance cannot be provided to eligible individuals or families for the same period of time and for the same cost types that are being provided through another Federal, state, or local subsidy program. If a participant is receiving... |
| 1/6/10 | HPRP | Can HPRP funds be paid to a collection agency for rental or utility debt? | No, HPRP funds may not be paid to collection agencies or other third-party debt collectors. |
| 1/6/10 | HPRP | If a grantee is providing both rent and utility assistance for the same household, can the rental payment include a utility allowance, or must rental assistance and utility assistance be paid and tracked separately? | All payments must go to third parties. Generally speaking, rental payments must be paid to landlords, and utility payments to the utility company. In addition, because the 18 months of rental assistance and utility assistance must each be tracked and reported separately i... |
| 1/6/10 | HPRP | Can HPRP funds be used to pay rent in a group home, assisted living facility, or board and care setting? | As long as each resident of a group home, assisted living facility, or boarding house has an individual lease, and has been assessed and certified to be eligible to receive HPRP assistance, HPRP funds may be used to assist persons residing in these types of housing. Howe... |
| 1/6/10 | HPRP | According to the Notice, payment of credit arrears (e.g., credit cards, loans) is an ineligible financial assistance activity. At the same time, the Notice indicates that credit repair is an allowable housing relocation and stabilization service. What is the difference? | Credit repair is an eligible activity under Housing Relocation and Stabilization Services and refers to such services as helping clients develop a household budget, access credit reports, negotiate with banks, etc. It does not include paying down consumer debt. |
| 1/6/10 | HPRP | May financial assistance funds be used to move an individual or household to live with family in another state? | HPRP is not a reunification or relocation program. Therefore, HPRP assistance for moving costs related to reuniting eligible applicants with family members is not eligible unless the participant can live with the family member permanently. If the HPRP program participan... |
| 1/6/10 | HPRP | Are utility reconnect fees an eligible expense? | Yes. Late fees and reconnect fees that are sometimes associated with arrears are an HPRP-eligible expense, as long as the assistance is needed to prevent homelessness for the household. |
| 1/6/10 | HPRP | If HPRP funds are used to assist an eligible client with arrears, does each month of arrears count as one month of HPRP assistance? | Yes. Although the payment would be a lump sum payment (and recorded as such in HMIS), each month of arrears would count against the 6 month limit on arrears as well as the 18 month overall limit on rental assistance allowed under HPRP. |
| 1/6/10 | HPRP | How would the 18-month timeline for the receipt of assistance be calculated for participants receiving different types of assistance? | The 18-month limitation applies to services as well as rental and utility assistance. They are each calculated separately, and the months need not be concurrent. The intent of separate clocks is to provide flexibility to grantees, but HUD expects that in most cases, hous... |
| 1/6/10 | HPRP | Can grantees provide utility-only assistance? What is the qualifying hardship? And what type of documentation is required in such instances? | Grantees can provide utility-only assistance, but HUD expects that this will be rare. First, there are laws governing public utilities in many states that prevent utility companies from shutting off power to a unit during winter months, and which may also require the uti... |
| 10/29/09 | HPRP | Can HPRP program participants receive assistance in tax credit projects? | Tax credit projects could be eligible to house HPRP program participants—the rental “subsidy” received from a tax credit property is not considered the same "cost type" (as defined in the HPRP Notice) as direct rental assistance. However, if a grantee or subgra... |
| 10/29/09 | HPRP | Can HPRP funds be used to assist with late fees and/or unit damages that are sometimes included with bills for rent arrears? | HPRP funds may be used to pay for late fees associated with rent or utility arrears, as long as the payment enables the program participant to remain housed or become rehoused. However, HPRP funds may not be used to pay for damage costs incurred by the tenant. |
| 10/29/09 | HPRP | Can HPRP funds be used to pay for pet deposits? | Fees for pet deposits are not an eligible HRPP expense. |
| 10/29/09 | HPRP | Can HPRP funds be used to pay for application fees, credit reports, and/or criminal background checks? | Fees for rental applications are not an eligible HRPP expense. With regard to credit reports and other background checks, grantees and subgrantees electing to conduct credit and background checks on HPRP participants in an effort to understand the client's credit i... |
| 8/14/09 | HPRP | Can HPRP funds be used to help a household purchase furniture? | As stated in the Notice, HPRP funds may not be used to help participants purchase furniture. However, there are a number of resources available to help households who need assistance furnishing an apartment. Visit View Full |
| 8/14/09 | HPRP | Is there any cap on relocation expenses? In other words, can a grantee use HPRP funds to help a client relocate to a different state, or from one end of a state to another? | There is no cap on relocation expenses. However, as explained in the Notice, moving cost assistance is limited to truck rental fees, moving company fees, short-term storage, and related expenses. Transportation costs for participants (e.g., bus, train, plane tickets) ar... |
| 8/14/09 | HPRP | HUD has indicated that grantees may provide rental assistance or services to eligible program participants who are residing or would like to reside outside their jurisdiction. Does this mean that grantees can serve persons in another state? | It is up to the grantee to determine if they wish to assist persons in another state. This may be common where a metropolitan community or Continuum of Care crosses state boundaries. However, if they do so, the grantee retains responsibility for ensuring that all requir... |
| 8/14/09 | HPRP | Can grantees pay off a client’s rental debt owed to a previous landlord if it enables the household to obtain new housing? | Yes. Grantees/subgrantees can pay up to six months of rental and utility arrears regardless of when they were incurred, provided that the existence of the arrears prevents the eligible participant from obtaining housing, and it is likely that the participant will be able... |
| 8/14/09 | HPRP | When a grantee provides security deposit assistance, must they recover the deposit if/when the household moves? | HUD is giving grantees the discretion to determine how to handle security deposits. Assuming the landlord is not retaining the security deposit to pay for costs incurred by the tenant (e.g., damages), the grantee may recover the security deposit, in which case it must be... |
| 8/14/09 | HPRP | Is payment of rented trailer pads/lots on which a mobile home residence rests an eligible expense under HPRP? | Rental assistance or arrears to pay for a lot on which a trailer is located can be eligible under financial assistance, although it is up to the grantee to determine whether to use HPRP funds for financial assistance costs associated with manufactured homes/trailer pads.... |
| 8/14/09 | HPRP | Can landlords be reimbursed for court costs if it prevents a client’s eviction? | No. Eligible legal expenses under HPRP include those incurred by the client only. Grantees may not use HPRP funds to reimburse landlords for any costs they may have incurred to begin the eviction process. |
| 8/14/09 | HPRP | Can grantees provide assistance to households in a rent-to-own or lease-in-place situation? | Yes, as long as the individual would be homeless “but for” the assistance, the full amount of the financial assistance is going towards rent or utilities (for example, no HPRP funds may be used for taxes or fees that may be associated with homeownership), a rent-to-own s... |
| 8/14/09 | HPRP | If a participant is receiving rental assistance through another program, can they also receive HPRP assistance? | HPRP assistance cannot be provided to eligible individuals or families for the same period of time and for the same cost types that are being provided through another Federal, state, or local subsidy program. There are six cost types: rental assistance, security deposit... |
| 8/14/09 | HPRP | Can a municipal grantee or subgrantee provide a client with utility assistance in cases where the city owns the utility company? | HPRP funds may be used to pay for utility assistance provided by a municipal utility company, provided the program participant meets all eligibility requirements, the assistance will prevent the participant's homelessness, and the municipal department is not treating HPRP... |
| 8/14/09 | HPRP | Does a lease have to be in place in order to pay rental assistance? For example, could the funding go to pay for a tenant’s rent at a relative or friend’s house if they are not on the lease? (REVISED) | A lease must be in place and the program participant must be on the lease in order to use HPRP funds for the rent or security deposit. Therefore, assistance could not be provided to an individual renting from a friend or relative if a legal lease is not in place. In cas... |
| 6/10/09 | HPRP | Can HPRP funding help me with my mortgage payments? (REVISED) | No, HPRP is not a mortgage assistance program. Also, HPRP may not be used to pay for any taxes or fees related to homeownership. |
| 6/10/09 | HPRP | If a program participant initially received short-term rental assistance for 3 months and needs additional assistance, are they eligible to receive more funding through the HPRP? (REVISED) | Yes, after 3 months, if program participants receiving short-term rental assistance need additional financial assistance to remain housed, they must be re-evaluated for eligibility and appropriateness of services/assistance (ie, would the participant be homeless “but for”... |
| 6/10/09 | HPRP | Can the rental assistance be used to pay unpaid rental debt? (REVISED) | Yes, rental assistance may also be used to pay up to 6 months of rental arrears for eligible program participants facing eviction for non-payment of rent if the payment enables the program participant to remain in the housing unit for which the arrears are being paid. In... |
| 6/10/09 | HPRP | On page 16, the Notice states, “HPRP funds may be used for reasonable and appropriate motel and hotel vouchers for up to 30 days if no appropriate shelter beds are available and subsequent rental housing has been identified but is not immediately available for move-in by the program participants.” Is this to be taken literally? Can a hotel/motel voucher be used only if a unit has been identified for that participant/household? | Yes, as stated in the Notice, a hotel/motel voucher can only be used when a unit has been identified and no shelter beds are available. Because it could take a few weeks to locate suitable rental housing, it would be advisable for grantees to try to identify an alternate... |
| 6/10/09 | HPRP | Can HPRP funds be used for shelters? (REVISED) | No. HPRP funds may not be used for shelter operations. However, as stated on page 16 of the Notice, "HPRP funds may be used for reasonable and appropriate motel and hotel vouchers for up to 30 days if no appropriate shelter beds are available and subsequent rental h... |
| 6/10/09 | HPRP | What types of utility expenses are eligible under HPRP? | Assuming that the participant meets all HPRP eligibility requirements, utility assistance related to housing may be provided. Utilities eligible for assistance are: heat, electricity, water, sewer and garbage collection. Telephone and cable services are not eligible. |
| 6/10/09 | HPRP | Could HPRP funds be used to pay continued room and board costs of foster care for youth who would otherwise have to leave foster care at age 18? In other words, could these funds be used to extend the foster care placement beyond age 18 when Title IV-E is no longer available as a funding source? | HPRP funds can be used to prevent homelessness for youth aging out of foster care, as long as they meet the minimum requirements defined in section D.2. of the Notice, and as long as the program participant's name is on the lease in the assisted unit. Continued room and b... |
| 6/10/09 | HPRP | Can funds be used to house persons in an emergency shelter on a short term basis? | No. HPRP funds may not be used for shelter operations. However, as stated on page 16 of the Notice, "HPRP funds may be used for reasonable and appropriate motel and hotel vouchers for up to 30 days if no appropriate shelter beds are available and subsequent rental ho... |
| 6/10/09 | HPRP | May HPRP funds be used to make buildings more energy efficient? Can they be used for lead-based paint remediation? | HPRP funds may not be used for rehabilitation. However, there are many other programs being funded by HUD, DOE, EPA, and other departments/agencies that would fund these types of improvements. Please see http://www.recover... |
| 5/8/09 | HPRP | Would the assistance to pay for up to 30 days of motel/hotel stay, a security deposit, or three months of storage count toward the 18 month limitation for rental assistance? For example, if a program participant receives a voucher for a 30-day stay at a motel, and then receives security deposit assistance, would that participant be eligible for 18 months of rental assistance? | The only activity that counts towards the 18-month maximum is the payment of rental arrears. Motel/hotel vouchers, security/utility deposits, and moving assistance (including the storage fees) do not count toward the 18-month maximum of rental assistance. |
| 4/24/09 | HPRP | The guidance indicates that up to 6 months of utility arrears can be paid under the eligible activities within financial assistance. Is the eligible amount the actual charges accrued during the most recent 6 months, or any timeframe, up to a maximum of 6 months of total expenses? | Utility arrears may be paid for any 6 months, as long as the program participant meets all eligibility criteria, and as long as the payment of the arrears allows the program participant to either remain in the housing or obtain new housing. The maximum amount that can be... |
| 4/24/09 | HPRP | Is the amount of rental assistance provided under HPRP based on the HOME TBRA program, where the household must pay 30% of its income for rent, or can their entire rent cost be subsidized? | HUD is providing grantees with a great deal of flexibility in determining their local programs and adding any restrictions. The grantee may decide whether to subsidize the full rent of a program participant or only a portion, depending on local priorities and need. |
| 4/3/09 | HPRP | Are grantees allowed to charge a program fee (e.g., 30% of a participant’s adjusted gross income) and use it to establish a savings account for the participant? | Grantees and subgrantees may not charge program fees to participants. However, programs may be designed to require participants to pay a portion of their income for rent and/or into escrow/savings accounts for the purpose of maximizing their housing stability. |
| 3/20/09 | HPRP | Does HPRP assistance provide long-term assistance? | The maximum amount of rental assistance that may be provided under HPRP is 18 months. The purpose of HPRP short- and medium-term rental assistance is to help eligible program participants to quickly obtain and/or sustain stable housing. It is not intended to provide long... |
| 3/20/09 | HPRP | What are the eligible financial assistance expenses? | Financial assistance is limited to the following activities: short-term rental assistance, medium-term rental assistance, security deposits, utility deposits, utility payments, moving cost assistance, and motel and hotel vouchers. |
| 3/20/09 | HPRP | What is considered short-term rental assistance and what is considered medium-term rental assistance? | Short-term rental assistance may not exceed rental costs accrued over a period of 3 months. Medium-term rental assistance may not exceed actual rental costs accrued over a period of 4 to 18 months. |
| 3/20/09 | HPRP | Will the condition of a unit or building impact a household's ultimate eligibility to receive financial assistance? | For persons residing in buildings that have been condemned or otherwise not suitable for human habitation, HPRP funds may be used to relocate them to more suitable housing. The HPRP assistance may include financial assistance and housing relocation and stabilization servi... |
| 3/20/09 | HPRP | How is HPRP different from the Rapid Re-housing (RRH) demonstration program? | UNDER THE RRH PROGRAM: - Eligible Participants: Households with dependent children (families) - Rental Subsidy Period: 3-6 months OR 12-15 months - Centralized Intake Process: Required - Community-wide Screening Tool... |
| 3/20/09 | HPRP | What are the eligible categories for activities under the HPRP? | There are four categories of activities eligible as HPRP expenditures: financial assistance, housing relocation and stabilization services, data collection and evaluation, and administrative costs. |
| Return to Topics | |||
| Topic: Eligible Activities/Costs - Housing Relocation and Stabilization Services | |||
| Date | Program/System |
Question | Answer |
| 1/6/10 | HPRP | According to the Notice, payment of credit arrears (e.g., credit cards, loans) is an ineligible financial assistance activity. At the same time, the Notice indicates that credit repair is an allowable housing relocation and stabilization service. What is the difference? | Credit repair is an eligible activity under Housing Relocation and Stabilization Services and refers to such services as helping clients develop a household budget, access credit reports, negotiate with banks, etc. It does not include paying down consumer debt. |
| 1/6/10 | HPRP | How would the 18-month timeline for the receipt of assistance be calculated for participants receiving different types of assistance? | The 18-month limitation applies to services as well as rental and utility assistance. They are each calculated separately, and the months need not be concurrent. The intent of separate clocks is to provide flexibility to grantees, but HUD expects that in most cases, hous... |
| 8/14/09 | HPRP | HUD guidance requires that all grantees report client-level data in an HMIS or comparable system. In states where there are numerous CoCs, many agencies within these various CoCs are likely to be state subgrantees for HPRP. These CoCs may use different HMIS systems that are not set up to communicate with each other. Can the state require that subgrantees report HMIS data directly to HUD as opposed to the State administering agency? | All reports must be submitted to HUD by the grantee. The grantee cannot require that subgrantees report directly to HUD. However, it is possible to use HPRP "Data Collection and Evaluation" funds to develop a data warehouse for use in aggregating the data that... |
| 8/14/09 | HPRP | Not all households assessed under HPRP will be eligible for assistance. Is the time spent assessing such households an eligible expense? | Yes, the time spent assessing all households is an eligible expense under the Outreach and Engagement portion of Housing Relocation and Stabilization Services. |
| 8/14/09 | HPRP | Can HPRP funds be used to help a household purchase furniture? | As stated in the Notice, HPRP funds may not be used to help participants purchase furniture. However, there are a number of resources available to help households who need assistance furnishing an apartment. Visit View Full |
| 6/10/09 | HPRP | Is assisting homeless or those at risk of becoming homeless to obtain expungements and/or pardons of their criminal records an eligible activity under HPRP? Is re-entry advocacy to help ex-offenders get jobs and/or social services an eligible activity? | Assisting homeless or soon-to-be-homeless persons in obtaining expungements and/or pardons of their criminal records is not an eligible activity under HPRP. Furthermore, advocacy is not an eligible expense, nor is helping persons get jobs. All eligible HPRP activities are... |
| 6/10/09 | HPRP | Can grantees provide housing stabilization supports to households that are relocated from shelter to unsubsidized housing, even if HPRP rent assistance is not used in that re-housing activity? | Eligible program participants who are rapidly re-housed from shelter to unsubsidized housing may receive Housing Relocation and Stabilization Services without also receiving HPRP rental assistance, as long as they meet all of the eligibility criteria and would be homeless... |
| 6/10/09 | HPRP | What kinds of legal assistance are eligible activities under HPRP? | Legal services are limited to the activities described in the HPRP Notice. Eligible legal services may include assisting program participants with legal advice and representation in administrative or court proceedings related to tenant/landlord matters or housing issues.... |
| 6/10/09 | HPRP | Under HPRP, is case management considered an eligible cost under the administrative category? | Case management expenses must be charged under the Housing Stabilization and Relocation Services category and are not eligible under the Administrative cost category. |
| 6/10/09 | HPRP | In the HPRP Notice, under Ineligible and Prohibited Activities, it states that transportation and travel costs are ineligible. Does this refer to the transportation/travel expenses of case managers, or does it refer to the client? | This prohibition on transportation and travel costs refers to program participants. Case managers may travel if needed to serve eligible HPRP program participants. |
| 6/10/09 | HPRP | Under HPRP, is there a minimum or maximum cost that can be expended on case management/staff? | As explained in the HPRP Notice, HUD has not established minimum or maximum funding amounts for any HPRP activity category, except for administrative funds which are capped at 5% of the HPRP grant. |
| 6/10/09 | HPRP | Are there education or qualification requirements for case managers under HPRP? | HUD has not set any specific minimum criteria for case management staff that conduct the required initial assessment of program participants. However, HUD strongly encourages grantees to set minimum qualifications or credentials for these staff persons since they are the... |
| 6/10/09 | HPRP | Is working with a housing counseling agency an eligible activity under HPRP? | Housing Counseling agencies largely work with homeowners facing foreclosure. As mortgage assistance is not an eligible activity under HPRP, homeowners seeking this type of service should be referred to the appropriate Housing Counseling programs within your community. A h... |
| 5/8/09 | HPRP | Can HPRP funds be used to purchase and implement a Housing Search/ Locator System? Would this activity be funded under Data Collection and Evaluation or Housing Relocation and Stabilization? | HPRP funds under the Data Collection and Evaluation activity may be used to increase the scope of the HMIS to include a web-based housing search/housing locator module in the CoC’s HMIS. This would include purchasing a module available through the CoC’s HMIS software prod... |
| 4/3/09 | HPRP | Can HPRP be used to create a regional or state-wide prevention hotline? If yes, under what activity could the costs be incurred? | Yes, a regional or state-wide prevention hotline would be eligible as an outreach and engagement activity under Housing Relocation and Stabilization Services. |
| 4/3/09 | HPRP | Where would assisting clients to access mainstream benefits/entitlements (e.g., SSI/SSDI) fit under HPRP? Would they be considered a case management service and funded as such? | Yes, assisting a program participant to access public benefits would be considered case management. As stated in the HPRP Notice, "HPRP case management funds may be used for activities for the arrangement, coordination, monitoring, and delivery of services related to... |
| 4/3/09 | HPRP | What category does staff time for screening clients for eligibility and processing client applications fall under? Are these considered administration costs or service costs? | Staff time associated with administering a particular program activity is charged to that program activity. Staff time for screening clients and processing client applications would be considered case management and are eligible under housing relocation and stabilization... |
| 3/20/09 | HPRP | What are the eligible categories for activities under the HPRP? | There are four categories of activities eligible as HPRP expenditures: financial assistance, housing relocation and stabilization services, data collection and evaluation, and administrative costs. |
| Return to Topics | |||
| Topic: Eligible Activities/Costs - Data Collection and Evaluation | |||
| Date | Program/System |
Question | Answer |
| 1/6/10 | HPRP | Can HPRP Data Collection and Evaluation funds be used for travel to attend HUD’s national HMIS training conference? | Yes, HPRP Data Collection and Evaluation funds can be used for expenses related to attending HUD’s national HMIS training conference. |
| 10/29/09 | HPRP | Can an HPRP grantee require that a subgrantee use a grantee-identified HMIS instead of, or in addition to, the CoC's established HMIS? | HPRP grantees have the right to establish data collection requirements as a condition for awarding HPRP funds to subgrantees. However, where a grantee wishes to establish additional data collection requirements, those requirements cannot compel subgrantees to complete di... |
| 8/14/09 | HPRP | Are grantees required to contract for HPRP HMIS with the current HMIS lead agency, or may they contract with a new lead agency specifically for administration (of the same system-software) for HPRP? | A CoC may have only one HMIS lead agency to administer the HMIS on behalf of the CoC. Since HPRP data collection and reporting is part of the HMIS, the CoC's HMIS lead agency is responsible for HMIS-related activities for HPRP. Therefore, an HPRP grantee may not select an... |
| 8/14/09 | HPRP | Under data collection and evaluation, the notice says that reporting must be done through HMIS or a “comparable client-level database”. Could you please explain what type of comparable client-level database would be acceptable? And who makes that determination? (REVISED) | In order to be considered a comparable client-level database, it must comply with the HMIS Data and Technical Standards. The use of a comparable database is allowable under the following circumstances: (1) The grantee's jurisdiction is not located within a CoC; (2) The Co... |
| 5/8/09 | HPRP | Can HPRP funds be used to purchase and implement a Housing Search/ Locator System? Would this activity be funded under Data Collection and Evaluation or Housing Relocation and Stabilization? | HPRP funds under the Data Collection and Evaluation activity may be used to increase the scope of the HMIS to include a web-based housing search/housing locator module in the CoC’s HMIS. This would include purchasing a module available through the CoC’s HMIS software prod... |
| 5/8/09 | HPRP | How should a grantee calculate the budget for Data Collection and Evaluation costs? Is there a recommended or maximum amount that grantees should budget for Data Collection and Evaluation costs? | HPRP grantees are required to collect client-level data through the CoC’s Homeless Management Information System (HMIS) or a comparable database to comply with the HPRP monitoring and reporting requirements. HPRP funds may be used to pay reasonable costs associated with... |
| 4/3/09 | HPRP | It states in the HPRP Notice that for HMIS, funds can be used for Data Collection and Evaluation costs, but is limited to jurisdictions that do not have an HMIS already implemented. How does this address the cost of data entry for existing HMIS users? And, if a new subgrantee receives HPRP funds but does not currently use HMIS, can HPRP funds be used to pay for their training, computer equipment, and other associated costs, including access to DSL? | There are five eligible HMIS cost categories for HPRP, which would fall under Data Collection and Evaluation: (1) Equipment. Leasing or purchase of hardware (computers, servers, printers), networking, and security; (2) Software. User licensing for existin... |
| 3/20/09 | HPRP | What are the eligible categories for activities under the HPRP? | There are four categories of activities eligible as HPRP expenditures: financial assistance, housing relocation and stabilization services, data collection and evaluation, and administrative costs. |
| Return to Topics | |||
| Topic: Eligible Activities/Costs - Administrative Costs | |||
| Date | Program/System |
Question | Answer |
| 8/14/09 | HPRP | How should indirect costs be allocated? | Organizations with an approved indirect cost rate cannot charge that rate to a single "indirect cost" line item in the grant. Instead, they should break out the costs necessary to operate the program and charge them directly under either Financial Assistance or... |
| 6/10/09 | HPRP | In the Notice, HUD states that administrative costs includes training “case managers who will serve program participants, as long as this training is directly related to learning about HPRP.” Does such training include case management skills to provide services in rapid re-housing programs or training in other skills critical to homelessness prevention, such as the skills necessary to connect HPRP participants to mainstream programs offering employment services? (REVISED) | General training for case manager to enhance their ability to provide services, counseling, or linkages with other programs – even Recovery Act programs – is NOT an eligible cost. These are considered general skills that a case manager would need in order to do their job,... |
| 6/10/09 | HPRP | Can HPRP funds be used as match for SHP? | HPRP may be used to match activities under SHP that are also eligible under HPRP. This would include services related to rapid re-housing of homeless persons, for example. It would not include operating costs associated with a transitional housing facility since operating... |
| 6/10/09 | HPRP | Can HPRP administrative funds be used to fund general CoC staff positions? | HPRP administrative funds may be used for the administration of HPRP grants only. General CoC operations are not eligible costs under HPRP. |
| 6/10/09 | HPRP | Under HPRP, is case management considered an eligible cost under the administrative category? | Case management expenses must be charged under the Housing Stabilization and Relocation Services category and are not eligible under the Administrative cost category. |
| 5/20/09 | HPRP | Is it true that administrative costs may not be used for staff engaged in the general administration of the program (e.g., bookkeeping costs)? (REVISED) | HUD's policy for eligible administrative activities limits the costs to the items listed in Section IV.A.4 of the Notice because administrative funds are statutorily limited to 5% of the total grant. Bookkeeping costs may be charged under administration, financial assist... |
| 5/8/09 | HPRP | Can HPRP administrative funds be used to pay for technical assistance? | Grantees were allowed to hire a contractor to help prepare their substantial amendment, which was an eligible pre-award cost. Now that all grant agreements have been executed, grantees may use administrative funds to hire a consultant to assist with aspects of grant admi... |
| 4/24/09 | HPRP | What costs are eligible pre-award costs? Must these be pre-approved? Can housing inspections be considered a pre-award cost? (REVISED) | Grantees may incur eligible pre-award costs, which are limited to administrative costs. These costs must be directly related to preparing the application for submission to HUD, for the period of time between the publication of the Notice on March 19, 2009 through the exe... |
| 4/24/09 | HPRP | Is the grantee required to share administrative funds with subgrantees? If so, are there guidelines for determining what constitutes a “reasonable and appropriate amount”? | Yes, grantees are required to share administrative funds with their subgrantees. HUD has not defined “reasonable share,” however, grantees should consider their fixed and variable costs related to conducting the eligible administrative functions when calculating the amou... |
| 4/3/09 | HPRP | Are there any notification requirements to HUD if jurisdictions wish to exercise the option of incurring pre-award administrative expenses? | There are no notification requirements. Grantees, however, must make sure that the pre-award costs are eligible and, of course, maintain documentation of all expenses. If a grantee has questions about any costs, it should contact its local HUD field office to verify wheth... |
| 3/20/09 | HPRP | What are the eligible categories for activities under the HPRP? | There are four categories of activities eligible as HPRP expenditures: financial assistance, housing relocation and stabilization services, data collection and evaluation, and administrative costs. |
| Return to Topics | |||
| Topic: Determining and Documenting Client Eligibility | |||
| Date | Program/System |
Question | Answer |
| 1/6/10 | HPRP | How is a household defined for purposes of HPRP? | Under the HPRP program, a household is a single individual or group of persons who together apply to an HPRP-funded program for assistance and together meet the conditions outlined in the HPRP Notice for eligible program participants. Note that if two unrelated individua... |
| 1/6/10 | HPRP | With regard to verifying and documenting an individual’s risk of homelessness, is an actual eviction notice required? | HUD has issued documentation requirements for HPRP grantees. Please see "HPRP Housing Status Eligibility Determination and Documentation Requirements"on the HRE at http://hudhre.in... |
| 1/6/10 | HPRP | Can HPRP funds be used to assist illegal immigrants? If so, what type of identification documentation is acceptable? | In accordance with Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, an alien (a person who is not a U.S. citizen or national) may be eligible for assistance under HPRP only if he or she is a “qualified alien” (defined in 8 U.S.C. 16... |
| 1/6/10 | HPRP | When completing the Staff Affidavit, is a case manager required to determine if the applicant has a familial connection to any grantee or subgrantee staff? If an individual seeking assistance is related to a grantee or subgrantee staff member, is he/she automatically disqualified? | A familial connection between an applicant and a staff member of the grantee or subgrantee agency does not necessarily mean that there is a conflict of interest, and it would not automatically disqualify him/her from receiving assistance. It does, however, disqualify the... |
| 1/6/10 | HPRP | HUD’s HPRP Income Determination and Documentation Requirements publication indicates that the definition of income under HPRP reflects household’s income at the time of application, and as such, documents and information collected to verify income must be “recent.” What is considered recent for public assistance benefits? | As explained in the guidance, documentation dated within 30 days of application is acceptable. However, for public assistance benefits (e.g., SSI), a benefits statement received anytime within the past year reflecting current benefits approved for and received by an appl... |
| 1/6/10 | HPRP | What should grantees do if they determine an individual applying for assistance has knowingly provided false information? | Grantees must terminate assistance to any program participant who violates program requirements established by HUD (and/or any more restrictive requirements established by the grantee). As described in Section V.E. of the HPRP Notice, the grantee must have a formal proces... |
| 1/6/10 | HPRP | Can grantees provide utility-only assistance? What is the qualifying hardship? And what type of documentation is required in such instances? | Grantees can provide utility-only assistance, but HUD expects that this will be rare. First, there are laws governing public utilities in many states that prevent utility companies from shutting off power to a unit during winter months, and which may also require the uti... |
| 1/6/10 | HPRP | Do applicants for HPRP assistance have to deplete all of their liquid assets in order to be eligible for HPRP funds? Similarly, must a household's retirement and educational savings accounts be tapped prior to becoming eligible for HPRP assistance? | As described in HUD’s publication “HPRP Housing Status Eligibility Determination and Documentation Requirements,” part of determining eligibility is assessing the household’s situation to determine if the household has any other financial resources, support networks, or s... |
| 1/6/10 | HPRP | Where do I find the AMI table that is used to determine income eligibility for HPRP assistance? | As explained in the Notice, the income limit data set is available at http://www.huduser.org/datasets/il/il09/index.html. HUD updates the dataset each year (typically in the spring), so conti... |
| 1/6/10 | HPRP | Does HPRP financial assistance count as income for participants for the purpose of determining eligibility under other state and Federal benefit programs? | Financial assistance received under HPRP may be required to be declared under other Federal or state tax laws, or in calculating benefits under other programs. The client is ultimately responsible for providing information required under Federal and state tax laws, and a... |
| 1/6/10 | HPRP | If an applicant is assessed for program eligibility, and the applicant ultimately does not meet program requirements, should the client be entered into HMIS? | Although the time spent assessing all households is an eligible expense, only HPRP program participants that actually receive financial assistance and/or housing relocation and stabilization services need to be entered into HMIS. Only those program participants who recei... |
| 1/6/10 | HPRP | If a client refuses to sign a Release of Information for HMIS to share non-confidential client level data with other agencies, can they be denied services? | An individual or family can refuse to participate in HMIS, and the provider must still provide services to that household, just as with HUD's Continuum of Care programs. However, persons applying for HPRP assistance must provide enough information for the staff person doi... |
| 10/29/09 | HPRP | Is the Staff Affidavit required only when financial assistance is being provided? | No – the Staff Affidavit must be used regardless of whether the household is receiving financial assistance or housing relocation and stabilization services. Both represent an expenditure of HPRP grant funds for eligible households. |
| 10/29/09 | HPRP | Why is HUD making HPRP grantees sign the Staff Affidavit? | The HPRP Staff Affidavit is intended to protect HUD and grantees against fraud and abuse charges. The Staff Affadavit serves to remind HPRP program staff that they are legally bound to determine and document the eligibility of applicants according to HPRP requirements bef... |
| 10/29/09 | HPRP | What is the HPRP Staff Affidavit and who must sign it? | The Staff Affidavit is a new requirement for all households determined to be eligible for HPRP assistance. The Staff Affidavit documents that the HPRP household meets all eligibility criteria for HPRP assistance, certifies that true and complete information was used to de... |
| 10/29/09 | HPRP | What guidance is available on calculating household income? (REVISED) | Requirements related to calculating household income for HPRP applicants is available in the HUD publication “HPRP Income Eligibility Determination and Documentation Requirements” (http://hudhre... |
| 10/29/09 | HPRP | Can the last month of a participant's income be used as a qualifying factor versus the last year of income? Could a person who has just recently lost his/her job and is on the verge of becoming homeless, whose previous annual income was above 50% of AMI, qualify for assistance? (REVISED) | Yes, the 50% AMI limit is not based on the household's previous income, but on its income at the time of application to the program. If an individual recently lost his/her job, and household income at the time of application is at or below 50% of AMI, the household is el... |
| 8/14/09 | HPRP | Can HMIS be used as third-party documentation of an applicant’s homeless status? | HMIS may be used to document homelessness in three ways: 1. Data on the program participant's residence in an emergency shelter or transitional housing program for homeless persons was collected in the HMIS; 2. A street outreach program entered data about a program partic... |
| 8/14/09 | HPRP | The HPRP Notice indicates that HUD is requiring grantees and subgrantees to certify eligibility at least once every 3 months for all program participants receiving medium-term rental assistance. Can these assessments be conducted by telephone? | The reassessments can be conducted by telephone in cases where distance prohibits a face-to-face assessment, though HUD encourages face-to-face assessments whenever possible. Local travel for program employees (e.g., mileage) is an eligible case management expense. |
| 8/14/09 | HPRP | Is there an HPRP process for handling appeals if a potential client is denied service by a grantee/subgrantee and wants to file an appeal? | The HPRP Notice does not prescribe an appeal process; however, HUD recommends that grantees and subgrantees develop and make public such a process. |
| 8/14/09 | HPRP | Not all households assessed under HPRP will be eligible for assistance. Is the time spent assessing such households an eligible expense? | Yes, the time spent assessing all households is an eligible expense under the Outreach and Engagement portion of Housing Relocation and Stabilization Services. |
| 6/10/09 | HPRP | As stated on page 14 of the Notice, HUD is requiring grantees and subgrantees to reassess household and certify eligibility at least once every 3 months. What happens if a household is determined to be at 51 percent Area Median Income (AMI) at the point of recertification? Is there a grace period? | Unfortunately, there is no grace period under HPRP. If a household is at 51 percent of AMI at the time it is reassessed, that household is no longer eligible for HPRP assistance. This underscores the importance of providing ongoing case management for program participan... |
| 6/10/09 | HPRP | Page 22 of the Notice states that “HUD requires grantees and/or subgrantees to evaluate and certify the eligibility of program participants at least once every 3 months for all persons receiving medium-term rental assistance.” Does the reassessment/recertification requirement apply only to those households receiving financial assistance? | No, the reassessment/recertification requirement applies to all households served under HPRP, whether they are receiving financial assistance and services or just services. |
| 6/10/09 | HPRP | Does the recertification of program participants who relocate to another jurisdiction have to be conducted face to face? If so, which party (subgrantee or program participant) is expected to travel to complete the recertification? | HUD recommends that the recertification process be conducted in person if possible. The costs associated with grantee and subgrantee staff traveling to meet the participants are eligible under either Financial Assistance or Housing Relocation and Stabilization Services.... |
| 3/20/09 | HPRP | As a grantee, can I establish more strict requirements than HUD has established? | Yes. HUD is providing grantees with discretion to establish requirements that further target community needs. Grantees may elect to implement more stringent targeting and/or eligibility requirements as long as all program participants meet the minimum eligibility criter... |
| Return to Topics | |||
| Topic: Housing and Lead Inspections | |||
| Date | Program/System |
Question | Answer |
| 1/6/10 | HPRP | Are costs related to the conduct of the inspections an eligible cost under the category of financial assistance? (REVISED) | The costs associated with conducting a habitability (or HQS) inspection are eligible under the financial assistance category. The costs should generally be charged to Rental Assistance, unless the agency is providing the household with, for example, security deposit or u... |
| 1/6/10 | HPRP | What are the lead-based paint inspection requirements? (REVISED) | The Lead-Based Paint requirements are more stringent than the habitability standards. A lead-based paint visual assessment must be completed for all units that meet the three following conditions: • The household living in the unit is being assisted with HPRP financ... |
| 1/6/10 | HPRP | If a Section 8 or public housing resident is seeking HPRP assistance for a security deposit, utility assistance, or arrears, and the unit has already passed an HQS inspection by the PHA, must the HPRP grantee conduct separate habitability and lead inspections? | If a unit has already passed a Housing Quality Standards (HQS) inspection by the PHA with the past 12 months, the HPRP grantee is not required to repeat the inspection. However, it is the HPRP grantee’s responsibility to obtain documentation from the PHA for the HPRP cas... |
| 1/6/10 | HPRP | In addition to assessing habitability standards, the guidelines also say that the homes occupied by HPRP recipients must meet all state and local requirements. What documentation is required to satisfy that state and local housing requirements are met? | The Notice indicates that housing must be in compliance with state and local housing codes to ensure that grantees understand the habitability standards do not replace state and local codes. Likewise, if a local Certificate of Occupancy or other inspection is required by... |
| 1/6/10 | HPRP | Does a rent reasonableness determination have to be conducted for households living in Section 8 units or public housing? | Grantees must remember that HPRP assistance cannot be provided to eligible individuals or families for the same period of time and for the same cost types that are being provided through another Federal, state, or local housing subsidy program. As such, HPRP may not be u... |
| 10/29/09 | HPRP | What type of documentation does HUD require related to the housing habitability inspection? (REVISED) | Grantees and subgrantees are responsible for documenting that each unit meets the habitability standards as described in Appendix C of the Notice. However, HUD is not requiring a particular form of documentation. A sample form is available on the HRE at View Full |
| 8/14/09 | HPRP | What are the on-site habitability inspection requirements, when do they apply, and who can conduct them? (REVISED) | The standards for housing unit inspections are the housing habitability standards described in Appendix C of the Notice. These standards apply only when a program participant is receiving financial assistance and moving into a new unit. They do NOT apply to persons receiv... |
| 8/14/09 | HPRP | Who can conduct the Lead-Based Paint Visual Assessments? (REVISED) | Visual assessments must be conducted by a HUD-Certified Visual Assessor. Anyone may become a HUD-Certified Visual Assessor by successfully completing a 20-minute online training on HUD’s website at: View Full |
| 6/10/09 | HPRP | Appendix C of the HPRP Notice outlines the habitability standards for HPRP. Must the local housing code be used if it meets a higher standard than the identified requirements in Appendix C? Several sections indicate that grantees may use either standard. | The grantee or subgrantee is responsible for ensuring that a housing inspection is conducted, to ensure that units assisted with HPRP funds meet the housing habitability standards described in Appendix C of the Notice. Local housing codes also apply to the units, but the... |
| 3/20/09 | HPRP | Will the condition of a unit or building impact a household's ultimate eligibility to receive financial assistance? | For persons residing in buildings that have been condemned or otherwise not suitable for human habitation, HPRP funds may be used to relocate them to more suitable housing. The HPRP assistance may include financial assistance and housing relocation and stabilization servi... |
| Return to Topics | |||
| Topic: Lease and Rent Requirements | |||
| Date | Program/System |
Question | Answer |
| 1/6/10 | HPRP | Can HPRP funds be used to assist a unit that exceeds the Fair Market Rent? | Fair Market Rents (FMRs) are not applicable under HPRP. As explained in the HPRP Notice, HPRP rental assistance may only be used to assist eligible households in units that meet rent reasonableness standards. Therefore, assistance may be provided for units that exceed t... |
| 8/14/09 | HPRP | When does the rent reasonableness requirement apply? | Grantees/subgrantees must determine and document rent reasonableness for all units for which HPRP rental assistance (including arrears) and/or security deposit assistance is being provided. The requirement applies whether homelessness prevention assistance or rapid re-ho... |
| 8/14/09 | HPRP | Does a lease have to be in place in order to pay rental assistance? For example, could the funding go to pay for a tenant’s rent at a relative or friend’s house if they are not on the lease? (REVISED) | A lease must be in place and the program participant must be on the lease in order to use HPRP funds for the rent or security deposit. Therefore, assistance could not be provided to an individual renting from a friend or relative if a legal lease is not in place. In cas... |
| 8/14/09 | HPRP | Under HPRP, may a program participant have a legal sublease? (REVISED) | HPRP financial assistance funds may only be spent on behalf of program participants where there is a legal lease that includes the participant's name on the document. A sublease is considered a legal lease. However, the grantee should be sure that the relationship betwe... |
| 8/14/09 | HPRP | Can grantees provide assistance to households in a rent-to-own or lease-in-place situation? | Yes, as long as the individual would be homeless “but for” the assistance, the full amount of the financial assistance is going towards rent or utilities (for example, no HPRP funds may be used for taxes or fees that may be associated with homeownership), a rent-to-own s... |
| 8/14/09 | HPRP | In a situation where there are two unrelated individuals on a lease - one who is eligible, and one who is not – can a grantee assist the eligible individual? | If two unrelated individuals are joint parties to a lease, a grantee must consider total household income to determine eligibility (i.e., either the whole household is eligible for assistance, or the whole household is not). |
| 4/24/09 | HPRP | How is rent reasonableness determined? | Rent reasonableness is determined on a case-by-case basis. Rent reasonableness should be determined by considering the following: (1) The reasonableness in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quali... |
| 4/24/09 | HPRP | Will HUD be issuing sample Housing Assistance Payment (HAP) contracts to be used for short-term and medium term rental assistance similar to the HOME TBRA forms available on HUD's website? | No, HUD is giving grantees the discretion to determine which documents to use under its local HPRP program. However, sample documents used by other communities are available in the HRE’s TA Resource Database at http://hudhre.in... |
| 4/24/09 | HPRP | Is the amount of rental assistance provided under HPRP based on the HOME TBRA program, where the household must pay 30% of its income for rent, or can their entire rent cost be subsidized? | HUD is providing grantees with a great deal of flexibility in determining their local programs and adding any restrictions. The grantee may decide whether to subsidize the full rent of a program participant or only a portion, depending on local priorities and need. |
| 4/3/09 | HPRP | Is completion of "Rent Reasonableness Checklist and Certification" required documentation for payments related to rental arrears, security deposits, utility deposits, or other financial assistance? | In the Notice, HUD set a requirement that rents must be in compliance with the HUD standard of "rent reasonableness." This would include rental payments, rental arrears, and security deposits. However, it is up to the grantee to determine exactly which document... |
| Return to Topics | |||
| Topic: Collecting Client-Level Data (HMIS & Comparable Databases) | |||
| Date | Program/System |
Question | Answer |
| 1/29/10 | HPRP | The 2009 HMIS Data Standards state that “for each Financial Assistance Provided record, the start date must correspond to the first day of the month for which rental assistance applies and the end date must correspond to the last day of the last month for which rental assistance applies.” Does this mean that Service Transactions for these records aren’t necessarily the dates that the assistance is actually provided? | For one-time payments of rental assistance for a current month or first month and for one-time or multiple payments of rental assistance for consecutive months, the start date in the Financial Assistance Provided record must correspond to the first day of the month for wh... |
| 1/6/10 | HPRP | Can an arrears payment for multiple months be made in one lump sum and recorded in HMIS as financial assistance for one month, and then the actual months paid be notated in the case file? If the actual months must be entered into HMIS, should it be back-dated or dated forward from the program entry date? | Financial assistance for arrears should be noted in HMIS as a single lump sum payment, with start and end dates being the same and entered as the date the financial assistance is approved (i.e., not back-dated). The actual number of months covered by the arrears payment... |
| 1/6/10 | HPRP | If an applicant is assessed for program eligibility, and the applicant ultimately does not meet program requirements, should the client be entered into HMIS? | Although the time spent assessing all households is an eligible expense, only HPRP program participants that actually receive financial assistance and/or housing relocation and stabilization services need to be entered into HMIS. Only those program participants who recei... |
| 1/6/10 | HPRP | At what point is it appropriate to "exit" a client household from HMIS - upon the provision of final assistance or at a later date? Does HUD require the grantee to track the housing stability of households following the receipt of HPRP assistance? | Grantees and subgrantees should exit a program participant and record a Program Exit Date that coincides with the date the participant is no longer considered a program participant. The exit date may represent the last day a service was provided or the last date of a per... |
| 1/6/10 | HPRP | Within HMIS, "Income & Sources" and "Non-Cash Benefits" information is collected more than once. Does any of the historic information need to be retained? Or should those elements just reflect the latest response? | Historical data must be retained in the HMIS. The APRs for HPRP, SHP, and S+C programs require that grantees report income and non-cash benefits at program entry, exit, and the most recent annual reassessment if the period between program entry and exit exceeds one year.... |
| 1/6/10 | HPRP | Since all HPRP programs must collect the HMIS universal data elements and the HPRP program-specific data elements from each participant, is there a template available that incorporates these data fields? | Yes, sample data collection templates are available on the HRE at http://hudhre.info/ |
| 1/6/10 | HPRP | According to the QPR Instructions, grantees have to report expenditures for each of the Housing Relocation and Stabilization Services subcategories (e.g., outreach and assessment, case management, housing search and placement) as well as by assistance type (prevention versus rapid re-housing). Does HUD expect case managers to track their hours at this level of detail? | The housing status of each program participant is a mandatory data element that must be tracked for each participant at program entry. This field is used to classify all activities as either prevention or rapid re-housing assistance for purposes of the HPRP QPR and APR -... |
| 1/6/10 | HPRP | If an individual is homeless and applies for HPRP assistance, should this individual’s housing status be changed from “homeless assistance” to “prevention” once housing is secured? If so, is the person exited out of homeless assistance and re-entered as a new prevention client? | A program participant’s Housing Status at program entry must be based on the response categories defined in HUD’s HMIS Data Standards found at http://www.hudhre.info/ |
| 1/6/10 | HPRP | If a client refuses to sign a Release of Information for HMIS to share non-confidential client level data with other agencies, can they be denied services? | An individual or family can refuse to participate in HMIS, and the provider must still provide services to that household, just as with HUD's Continuum of Care programs. However, persons applying for HPRP assistance must provide enough information for the staff person doi... |
| 1/6/10 | HPRP | The HUD QPR instructions ask for a report of persons served by persons and households. Does this mean that each child should be entered as an individual client and be assigned a separate Personal Identification Number? | Every client receiving services must be assigned a Personal Identification Number (PIN). The PIN is permanent and unique to each person and is automatically generated by the HMIS. The PIN is used to obtain unduplicated counts of persons served within individual programs... |
| 10/29/09 | HPRP | If a household contains multiple people, but only one person directly received a service, how many persons served should be reported in the QPR? For example, if a household consists of one adult and one child, but only the adult participated in a case management session, how many people should be counted as receiving the service? How should unaccompanied individuals be counted? | In the QPR and IPR, a person should be considered as receiving a service if anyone in the household received the service. If, as in the example above, a household consists of one adult and one child, but only the adult participated in a case management session, this woul... |
| 10/29/09 | HPRP | Can an HPRP grantee require that a subgrantee use a grantee-identified HMIS instead of, or in addition to, the CoC's established HMIS? | HPRP grantees have the right to establish data collection requirements as a condition for awarding HPRP funds to subgrantees. However, where a grantee wishes to establish additional data collection requirements, those requirements cannot compel subgrantees to complete di... |
| 8/14/09 | HPRP | When will the revised HMIS technical standards be published, and what are the HMIS requirements under HPRP? | The HMIS Data Standards Revised Notice is currently available at http://hudhre.info/ |
| 8/14/09 | HPRP | Creating a homeless prevention hotline or 211 call center is an eligible activity under HPRP. What are the HMIS reporting requirements for such activities? | An agency administering a homeless prevention hotline or 211 call center is not subject to the HMIS data collection and reporting requirements due to the limited nature of the client contact. Instead, it is the programs receiving the referrals from the call centers and a... |
| 8/14/09 | HPRP | HUD guidance requires that all grantees report client-level data in an HMIS or comparable system. In states where there are numerous CoCs, many agencies within these various CoCs are likely to be state subgrantees for HPRP. These CoCs may use different HMIS systems that are not set up to communicate with each other. Can the state require that subgrantees report HMIS data directly to HUD as opposed to the State administering agency? | All reports must be submitted to HUD by the grantee. The grantee cannot require that subgrantees report directly to HUD. However, it is possible to use HPRP "Data Collection and Evaluation" funds to develop a data warehouse for use in aggregating the data that... |
| 8/14/09 | HPRP | Are grantees required to contract for HPRP HMIS with the current HMIS lead agency, or may they contract with a new lead agency specifically for administration (of the same system-software) for HPRP? | A CoC may have only one HMIS lead agency to administer the HMIS on behalf of the CoC. Since HPRP data collection and reporting is part of the HMIS, the CoC's HMIS lead agency is responsible for HMIS-related activities for HPRP. Therefore, an HPRP grantee may not select an... |
| 8/14/09 | HPRP | Under data collection and evaluation, the notice says that reporting must be done through HMIS or a “comparable client-level database”. Could you please explain what type of comparable client-level database would be acceptable? And who makes that determination? (REVISED) | In order to be considered a comparable client-level database, it must comply with the HMIS Data and Technical Standards. The use of a comparable database is allowable under the following circumstances: (1) The grantee's jurisdiction is not located within a CoC; (2) The Co... |
| 7/7/09 | HPRP | Is there specific reporting guidance available for domestic violence providers? | Yes. On July 7, 2009 HUD released additional reporting guidance for victim service providers funded by the Homelessness Prevention and Rapid Re-Housing Program (HPRP). This guid... |
| 4/24/09 | HPRP | Will client-level data need to be entered into IDIS reports and into the HMIS system? Or will the HPRP IDIS reports only have financial data? | Beneficiary data will not be entered into IDIS, however, grantees will draw HPRP funds through IDIS. HUD plans to use a current electronic system to begin collecting beneficiary data and outcomes in October 2009. HUD will provide additional guidance on both financial an... |
| 4/3/09 | HPRP | Participation in HMIS is mandated by this program. Is HUD taking the lead to make sure that grantees funded directly through entitled jurisdictions comply? Often, a CoC has little influence over another jurisdiction within the CoC to mandate participation. | The HPRP Operating Instructions for Field Offices and the HPRP Grant Agreement will include HMIS participation requirements. HUD will monitor HPRP grantees for compliance with the requirements. |
| Return to Topics | |||
| Topic: Reporting Aggregate Data (e-snaps, QPR/APR, FederalReporting.gov, IDIS) | |||
| Date | Program/System |
Question | Answer |
| 1/6/10 | HPRP | If I have already reported in FederalReporting.gov, must I also report in e-snaps? | Yes. FederalReporting.gov is managed by the White House Office of Management and Budget (OMB), whereas e-snaps is managed by HUD. OMB is requiring all Recovery Act grantees to submit data common to all Recovery Act programs in FederalReporting.gov each quarter. In cont... |
| 1/6/10 | HPRP | The QPR instructions indicate that QPRs are due within 10 days of the end of each Federal fiscal quarter in e-snaps, but that grantees will have 20 additional business days to submit a final QPR to correct errors or omissions in the preliminary report. If grantees do not anticipate making changes, should they submit their reports as final instead of preliminary in e-snaps? | Grantees should submit QPRs in e-snaps as preliminary to meet the quarterly filing deadline (i.e., 10 days after the close of the quarter). HUD will be examining all QPRs and may contact grantees if changes are needed. If a report is submitted as final, it is much more... |
| 1/6/10 | HPRP | I am a grantee. Can I have my subgrantees submit reports directly into e-snaps on my behalf? | No. Grantees must aggregate all data from subgrantees and file only one report in e-snaps. Under no circumstances should subgrantees be submitting reports in e-snaps. |
| 1/6/10 | HPRP | I am a grantee, and I accidentally created multiple reports in e-snaps. How can I delete them? | Once created, a report cannot be deleted. However, as long as it is not submitted, the system will ignore it and HUD will not receive it. If multiple reports were submitted, either for the grantee or for subgrantees, the grantee must create one correct report that compi... |
| 1/6/10 | HPRP | As a grantee, I will not receive all reimbursement requests from my subgrantees by the quarterly report deadline. By "expenditures during the reporting period," does HUD mean expenditures that we, as the grantee, have received and reimbursed for that quarter? Or does it mean all expenditures, whether they have been submitted or not? | Per QPR instructions, the accounting method for financial reporting is left to grantees to determine. The grantee may base reporting either on their expenses (i.e., what they have paid) or on expenses incurred by the grantee and subgrantees (i.e., accrued expenses, but no... |
| 1/6/10 | HPRP | Does HUD expect that quarterly expenditures as reported in the QPR will actually be drawn down from IDIS by the time the report is submitted? In other words, will HUD be comparing draws in IDIS with the information reported in the QPR? | The QPR requires grantees to report on the HPRP expenses incurred, whether or not the grantee has been reimbursed by IDIS. Grantees must draw down from IDIS at least quarterly (preferably before the quarterly reports are due), and are urged to draw down from IDIS monthly... |
| 1/6/10 | HPRP | For reporting on FederalReporting.gov, what is the difference between a vendor and a subgrantee? | The following definitions should be used for the purpose of HPRP reporting: • A grantee for HPRP is the legal entity to which the HPRP grant is awarded and that is accountable for the use of grant funds; grantee and recipient are synonymous. Each grantee is respons... |
| 1/6/10 | HPRP | The QPR/IPR asks for expenditures by type of Financial Assistance as well as by type of Housing Relocation and Stabilization Services. However, the 2009 HMIS Data Standards do not include HPRP expenditures. Are grantees required to provide expenditure amounts for HPRP services and assistance? | As explained in the QPR/IPR Instructions, grantees may report expenses for HPRP services (Financial Assistance and Housing Relocation and Stabilization Services) based on HMIS data or by other accounting means as determined by the grantee. HMIS data elements were not spe... |
| 1/6/10 | HPRP | The QPR requires grantees to submit information both on households served and expenditures. What happens if the expenditure occurs at the end of one quarter, but the assistance is actually for the following quarter? | It is possible that an assisted household and the expenditure for that household could appear in two different quarterly reports. For example, the grantee should report a participant as receiving HPRP rental assistance based on the "start date" and “end date” e... |
| 1/6/10 | HPRP | Does a rental arrears payment impact whether a client is reported as having received short-term or medium-term assistance? For example, would payment of 1-3 months be considered short-term assistance and 4-6 months be considered medium-term assistance? | The QPR does not require grantees to differentiate between persons/households who receive short-term and medium-term rental assistance. However, grantees must still document the number of months of rental assistance provided, whether for arrears or current rent, to ensur... |
| 1/6/10 | HPRP | According to the QPR Instructions, grantees have to report expenditures for each of the Housing Relocation and Stabilization Services subcategories (e.g., outreach and assessment, case management, housing search and placement) as well as by assistance type (prevention versus rapid re-housing). Does HUD expect case managers to track their hours at this level of detail? | The housing status of each program participant is a mandatory data element that must be tracked for each participant at program entry. This field is used to classify all activities as either prevention or rapid re-housing assistance for purposes of the HPRP QPR and APR -... |
| 10/29/09 | HPRP | If a household contains multiple people, but only one person directly received a service, how many persons served should be reported in the QPR? For example, if a household consists of one adult and one child, but only the adult participated in a case management session, how many people should be counted as receiving the service? How should unaccompanied individuals be counted? | In the QPR and IPR, a person should be considered as receiving a service if anyone in the household received the service. If, as in the example above, a household consists of one adult and one child, but only the adult participated in a case management session, this woul... |
| 8/14/09 | HPRP | When will the QPR report format be available? | The information that grantees will be required to collect and submit to HUD for the Initial Quarterly Report (the data elements) has been published, and is available on the HUD HRE. Because HUD anticipates that grantees will complete the QPRs electronically, HUD is not d... |
| 8/14/09 | HPRP | Will HUD require that grantees submit their QPRs to HUD Headquarters and the appropriate HUD Field Office? | Reports are submitted electronically through e-snaps. As such, the reports will be available to both Field Office and Headquarters staff. Guidance on HPRP reporting is available on the HRE at ht... |
| 4/24/09 | HPRP | Will there be new IDIS reporting requirements, other than the ones needed for ESG? If so, when will these requirements be published? | The IDIS reporting requirements for HPRP differ somewhat from the IDIS reporting requirements for the Emergency Shelter Grants (ESG) program. Guidance for HPRP grantees is available at htt... |
| 4/24/09 | HPRP | Will client-level data need to be entered into IDIS reports and into the HMIS system? Or will the HPRP IDIS reports only have financial data? | Beneficiary data will not be entered into IDIS, however, grantees will draw HPRP funds through IDIS. HUD plans to use a current electronic system to begin collecting beneficiary data and outcomes in October 2009. HUD will provide additional guidance on both financial an... |
| 4/3/09 | HPRP | When will HUD issue the Quarterly Progress Reports required for this funding? | HUD is currently developing the formats and data elements that will be included in the Initial, Quarterly, and Annual Performance Reports referenced in the HPRP Notice. The data elements will be made available for public review and comment (through the OMB Paperwork Reduc... |
| 4/3/09 | HPRP | It appears that the Performance Reports will require grantees to report on "the number of jobs created and retained." What entity is responsible for creating the jobs and who are the potential employees to be hired? | One of the requirements of the Recovery Act of 2009 is that jobs that are created and/or retained through the use of these funds be tracked and reported. For HPRP, this could be jobs created or retained at the grantee or subgrantee levels. For example, a subgrantee may ne... |
| Return to Topics | |||
| Topic: Technical Assistance | |||
| Date | Program/System |
Question | Answer |
| 1/6/10 | HPRP | How can grantees request/apply for technical assistance? | All requests for HPRP technical assistance (TA) must be submitted through the HPRP Virtual Help Desk at http://hudhre.info/ |
| 6/10/09 | HPRP | What resources are available to help grantees implement and manage their programs? | HUD's national technical assistance providers are working on the development of HPRP-specific tools and resources. These items are being posted on the HRE at http://hudhre.info/ |
| 5/8/09 | HPRP | Can HPRP administrative funds be used to pay for technical assistance? | Grantees were allowed to hire a contractor to help prepare their substantial amendment, which was an eligible pre-award cost. Now that all grant agreements have been executed, grantees may use administrative funds to hire a consultant to assist with aspects of grant admi... |
| 4/3/09 | HPRP | When will HPRP Technical Assistance and Training be available to grantees? | HUD hosted a webcast on April 8, 2009, 2:00-4:00 PM EDT, which is archived on HUD’s web site and may be viewed at any time by going to: http://www.hud.gov/webcasts/archives/. Additionally, the Departmen... |
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