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 subgrantee. In this instance, a grantee must submit a letter to the CPD Director requesting a waiver for good cause. The waiver must:

• Include a description of the benefit(s) to HPRP participants;

• Explain how the grantee/subgrantee disclosed the conflict and addresses/mitigates any potential issues;

• Demonstrate that the grantee/subgrantee has looked for other appropriate housing and it is not available, or there is a good reason why the grantee/subgrantee housing is better for the clients;

• Demonstrate that the subsidy is not tied to a unit (clients have to be able to choose the grantee/subgrantee housing);

• Demonstrate that an attorney has reviewed the housing selections and determined that the activities proposed do not violate state and local law; and

• Demonstrate that there is no implied benefit to any individual or organization.

2) The second type of conflict of interest that can occur is at the individual level (as opposed to the grantee/subgrantee level). The HPRP Notice states: “No person who is an employee, agent, consultant, officer, or elected or appointed official of the grantee and who exercises or has exercised any functions or responsibilities with respect to assisted activities, or who is in a position to participate in a decision-making process or gain inside information with regard to such activities, may obtain a personal or financial interest or benefit from the activity, or have an interest in any contract, subcontract, or agreement with respect thereto, or the proceeds thereunder, either for himself or herself or for those with whom he or she has family or business ties, during his or her tenure or for one year thereafter.” (emphasis added)

Please note that employees of a grantee or subgrantee and their families are not automatically disqualified from receiving HPRP assistance, as long as they meet the qualifications of the above paragraph (i.e., they are not in a position to exercise any responsibilities, make decisions about, gain inside information into, or obtain a personal benefit from HPRP). This situation would be more likely in a large grantee/subgrantee agency than it would in a very small grantee/subgrantee agency.

When this type of conflict of interest exists, the grantee may seek an exception by writing to the local HUD Field Office, including the following information:

• For states and other governmental entities, a disclosure of the nature of the conflict, accompanied by an assurance that there has been public disclosure of the conflict and a description of how the public disclosure was made; and

• For all grantees, an opinion of the grantee’s attorney that the interest for which the exception is sought would not violate state or local law.

If there is a question or the appearance of a conflict of interest of any type, please contact the local HUD field office to determine if an exception or waiver is needed.

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 government. HUD relies on the classifications in the Census of Governments in determining whether an entity is a unit of general purpose local government. For information on these classifications, see “Structure of Governments” at http://www.census.gov/govs/go/index.html.

Please note the following:

a. HUD cannot waive this requirement because it is statutory. The provisions under which HPRP was authorized in the American Recovery and Reinvestment Act of 2009, Public Law 111-5, specify that funding for HPRP “be allocated to eligible grantees (as defined and designated in sections 411 and 412 of subtitle B of title IV of the McKinney-Vento Homeless Assistance Act (the ‘Act’)) pursuant to the formula authorized by section 413 of the Act.” Section 413 of the Act states that “[t]he Secretary [of HUD] shall allocate assistance . . . to . . . States (for distribution to local governments and private nonprofit organizations in the States).” 42 U.S.C. 11373. Section 411 of the Act defines the term “local government” as a “unit of general purpose local government.” 42 U.S.C. 11371. It is this parenthetical that sets the requirement, and since it is statutory, it cannot be waived.

b. A state subgrantee may not further subgrant state HPRP funds to a PHA, HRA, or other special purpose local government agency that is not a unit of general purpose local government.

c. A state subgrantee that adheres to the requirements of 24 CFR § 85.36 may procure the services of any entity, including a PHA, HRA, to carry out the eligible activities under HPRP. However, the procurement rules are based on free and open competition for the grantee/subgrantee to get the best deal for its grant dollars in obtaining goods and services from a qualified organization. The noncompetitive proposal method (procurement through solicitation of a proposal from only one source, or after solicitation of a number sources, competition is determined inadequate) is only permitted by 24 CFR § 85.36(d)(4) if other methods of procurement are infeasible and one of the specified circumstances applies.

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 (CCR).” For more information see 73 FR 23483, April 30, 2008 or go to www.dnb.com. The Recovery Act requires that all grantees be verified through the CCR, therefore HUD will not release an HPRP grant agreement for a grantee until their registration is verified. Specific questions or troubleshooting regarding the status of a CCR registration can be referred to Loyd Lamois in HUD’s Office of Administration at Loyd.LaMois@hud.gov.

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 the jurisdiction, and subgrantees that serve multiple jurisdictions. A grantee may establish more stringent requirements, such as requiring that HPRP funds be spent within the jurisdiction or establishing a residency requirement, but HUD is not setting these requirements.

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 contact the local or state grantee for information about becoming a subgrantee. It is up to each grantee to determine the appropriate eligibility and application requirements for their allocation. Contact your local and/or state grantee for HPRP application information.

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 nonprofit organizations.

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 percent), more metropolitan cities and urban counties can receive funds directly than in ESG. The intent is to expedite the process of getting the funds to the program participants, who need the assistance quickly.

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 (CCR).” For more information see 73 FR 23483, April 30, 2008 or go to www.dnb.com. The Recovery Act requires that all grantees be verified through the CCR, therefore HUD will not release an HPRP grant agreement for a grantee until their registration is verified. Specific questions or troubleshooting regarding the status of a CCR registration can be referred to Loyd Lamois in HUD’s Office of Administration at Loyd.LaMois@hud.gov.

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 Development, Office of Special Needs Assistance Programs, Robert C. Weaver Building, 451 Seventh Street, SW, Room 7262, Washington, DC 20410, Attention: Homelessness Prevention and Rapid Re-Housing Program.

The copy should be send to the grantee’s Field Office. For Field Office contact information, please visit HUD’s website at http://www.hud.gov/local/

Please note that Federal Express will not deliver packages to Federal buildings without a contact name. Please address the original to Kevin Turner in Washington (phone 202-402-5060). Please address the copy to your Field Office CPD representative.

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 submit to HUD in order to receive HPRP funding. Local governments that are not eligible grantees and nonprofit organizations must contact the local or state grantee for information about becoming a subgrantee. It is up to each grantee to determine the appropriate eligibility and application requirements for their allocation.

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 maximum word guidelines.

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 administration) within the two program types (homelessness prevention and rapid re-housing). The budget in the substantial amendment does not require grantees to indicate estimated budgets at a more granular level. The total requested must match the total HPRP amount budgeted. Grantees will report their final allocations and subgrantee selections in the Initial Performance Report due in October 2009.

No, grantees are not required to match HPRP funds with any other 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.

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 allocation amount and proceed to reallocate the funds.

Substantial amendments, certifications, and the SF-424 (the application package) must be postmarked by May 18, 2009.

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. HPRP is a part of the Recovery Act, and therefore, it is vital that subgrantees have access to the funds so that the assistance can reach those in need as soon as possible. HUD strongly encourages grantees to do everything possible to meet this deadline, and will not grant waiver requests. As with all program requirements, noncompliance with the September 30th deadline will increase the grantee’s risk level for monitoring and may result in monitoring findings and/or sanctions.

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 organization located in an entitlement area covered by another Consolidated Plans, the local government for the area in which the office of the non-profit organization is physically located must certify that it approves of the program. If funds are being provided to a non-profit organization in an area covered by the state’s Consolidated Plan, certification is not required.

To obtain certification by the local unit of government, grantees should use a form similar to the one used by state grantees under the Emergency Shelter Grants (ESG) program. This form is posted on the HRE at hudhre.info/documents/HPRPAttachmentD.doc

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 selection process, provided it is fair and reasonable.

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 through 24 CFR Part 84, applicable to nonprofits.

Additionally, most states and many local governments have laws and regulations regarding procurement. Each grantee and sub-grantee receiving HPRP funds should aware of the state and/or local laws that may affect procurement policies.

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 when they subgrant funds to another entity. Please note that this is different from carrying out HPRP activities cooperatively through a "joint agreement" – joint agreements are not allowed under HPRP. Therefore, the HPRP grantee must submit a substantial amendment, and then complete a subgrant agreement with the other local government.

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 and private nonprofit organizations in the states." So, as under ESG, states cannot directly provide financial assistance or services and they cannot subgrant to another state agency.

Grantees must select all subgrantees and obligate funds to them by September 30, 2009.

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 subgrantee. In this instance, a grantee must submit a letter to the CPD Director requesting a waiver for good cause. The waiver must:

• Include a description of the benefit(s) to HPRP participants;

• Explain how the grantee/subgrantee disclosed the conflict and addresses/mitigates any potential issues;

• Demonstrate that the grantee/subgrantee has looked for other appropriate housing and it is not available, or there is a good reason why the grantee/subgrantee housing is better for the clients;

• Demonstrate that the subsidy is not tied to a unit (clients have to be able to choose the grantee/subgrantee housing);

• Demonstrate that an attorney has reviewed the housing selections and determined that the activities proposed do not violate state and local law; and

• Demonstrate that there is no implied benefit to any individual or organization.

2) The second type of conflict of interest that can occur is at the individual level (as opposed to the grantee/subgrantee level). The HPRP Notice states: “No person who is an employee, agent, consultant, officer, or elected or appointed official of the grantee and who exercises or has exercised any functions or responsibilities with respect to assisted activities, or who is in a position to participate in a decision-making process or gain inside information with regard to such activities, may obtain a personal or financial interest or benefit from the activity, or have an interest in any contract, subcontract, or agreement with respect thereto, or the proceeds thereunder, either for himself or herself or for those with whom he or she has family or business ties, during his or her tenure or for one year thereafter.” (emphasis added)

Please note that employees of a grantee or subgrantee and their families are not automatically disqualified from receiving HPRP assistance, as long as they meet the qualifications of the above paragraph (i.e., they are not in a position to exercise any responsibilities, make decisions about, gain inside information into, or obtain a personal benefit from HPRP). This situation would be more likely in a large grantee/subgrantee agency than it would in a very small grantee/subgrantee agency.

When this type of conflict of interest exists, the grantee may seek an exception by writing to the local HUD Field Office, including the following information:

• For states and other governmental entities, a disclosure of the nature of the conflict, accompanied by an assurance that there has been public disclosure of the conflict and a description of how the public disclosure was made; and

• For all grantees, an opinion of the grantee’s attorney that the interest for which the exception is sought would not violate state or local law.

If there is a question or the appearance of a conflict of interest of any type, please contact the local HUD field office to determine if an exception or waiver is needed.

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 before providing assistance. Use of the form, which went into effect on November 1, 2009, will be reviewed by HUD as part of the monitoring process.

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 be examining grantee draws and financial reporting in IDIS to evaluate rates of spending and to ensure that the grantees are drawing HPRP funds for eligible activities. Grantees will be monitored for compliance with applicable lead-based paint requirements in accordance with the CPD Monitoring handbook, chap. 24, Lead-Based Paint.

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 be expended within three years of the grantee’s initial grant agreement as well. No expenses may be incurred after the 3-year expenditure deadline, but grantees may draw down funds to be reimbursed for eligible HPRP expenses incurred during the 3-year grant period for up to 90 days after the grant period ends.

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 through 24 CFR Part 84, applicable to nonprofits.

Additionally, most states and many local governments have laws and regulations regarding procurement. Each grantee and sub-grantee receiving HPRP funds should aware of the state and/or local laws that may affect procurement policies.

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 when they subgrant funds to another entity. Please note that this is different from carrying out HPRP activities cooperatively through a "joint agreement" – joint agreements are not allowed under HPRP. Therefore, the HPRP grantee must submit a substantial amendment, and then complete a subgrant agreement with the other local government.

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 implementation.

A grantee should consult its citizen participation plan (in the grantee's Consolidated Plan) to determine if the grantee provides a threshold amount for budget changes for which local citizen participation and consultation is required.

The HPRP grantee must document changes in IDIS via funds committed to projects and activities. The grantee should use its own internal process to document contract changes with subgrantees.

If the grantee cannot meet this threshold, HUD may then proceed to recapture the unused HPRP funds and reallocate them.

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 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).

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 process in place that recognizes the rights of individuals receiving assistance to due process of law. Although the HPRP Notice does not prescribe an appeal process, HUD recommends that grantees and subgrantees develop and make public such a process.

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 subgrantee. In this instance, a grantee must submit a letter to the CPD Director requesting a waiver for good cause. The waiver must:

• Include a description of the benefit(s) to HPRP participants;

• Explain how the grantee/subgrantee disclosed the conflict and addresses/mitigates any potential issues;

• Demonstrate that the grantee/subgrantee has looked for other appropriate housing and it is not available, or there is a good reason why the grantee/subgrantee housing is better for the clients;

• Demonstrate that the subsidy is not tied to a unit (clients have to be able to choose the grantee/subgrantee housing);

• Demonstrate that an attorney has reviewed the housing selections and determined that the activities proposed do not violate state and local law; and

• Demonstrate that there is no implied benefit to any individual or organization.

2) The second type of conflict of interest that can occur is at the individual level (as opposed to the grantee/subgrantee level). The HPRP Notice states: “No person who is an employee, agent, consultant, officer, or elected or appointed official of the grantee and who exercises or has exercised any functions or responsibilities with respect to assisted activities, or who is in a position to participate in a decision-making process or gain inside information with regard to such activities, may obtain a personal or financial interest or benefit from the activity, or have an interest in any contract, subcontract, or agreement with respect thereto, or the proceeds thereunder, either for himself or herself or for those with whom he or she has family or business ties, during his or her tenure or for one year thereafter.” (emphasis added)

Please note that employees of a grantee or subgrantee and their families are not automatically disqualified from receiving HPRP assistance, as long as they meet the qualifications of the above paragraph (i.e., they are not in a position to exercise any responsibilities, make decisions about, gain inside information into, or obtain a personal benefit from HPRP). This situation would be more likely in a large grantee/subgrantee agency than it would in a very small grantee/subgrantee agency.

When this type of conflict of interest exists, the grantee may seek an exception by writing to the local HUD Field Office, including the following information:

• For states and other governmental entities, a disclosure of the nature of the conflict, accompanied by an assurance that there has been public disclosure of the conflict and a description of how the public disclosure was made; and

• For all grantees, an opinion of the grantee’s attorney that the interest for which the exception is sought would not violate state or local law.

If there is a question or the appearance of a conflict of interest of any type, please contact the local HUD field office to determine if an exception or waiver is needed.

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 requirements associated with the program are met, either by the grantee or another grantee. This includes documentation of rent reasonableness, conducting the habitability and lead-based paint inspections, and conducting reassessments every three months.

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 prevention assistance are housed at the time they begin receiving HPRP assistance, and persons receiving rapid re-housing assistance are homeless (according to the HUD definition) at the time they begin receiving assistance.

If the applicant does not meet the HUD homeless definition, the assistance would be classified as prevention. For example, an individual who has been in a hospital, prison, or other institution for less than 180 days and who was sleeping in an emergency shelter or on the streets immediately prior to entry into the institution meets the HUD definition and therefore would be served under the rapid re-housing category. In contrast, a person who has been a resident of an institution for more than 180 days would still be eligible (assuming he/she meets other HPRP eligibility criteria), but in this case, the individual would be served under the prevention category.

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 supportive housing are eligible to receive tenant-based rental assistance available through HPRP. Therefore, persons on a permanent supportive housing program waiting list may be served with HPRP assistance until a permanent supported housing unit is available, provided the permanent supportive housing unit will be available within 18 months, does not violate conflict of interest leasing requirements, the services provided are limited to the HPRP Housing Relocation and Stabilization services described in the Notice, and the assessment reveals that the person is likely to be able to maintain the HPRP housing until the permanent supportive housing unit is available.

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 determine eligibility for the program. This is why unemployment is not the only criteria that a grantee or subgrantee may look at for participation in HPRP - a program participant must meet all of the eligibility criteria described in section IV.A.2. of the HPRP Notice. There is no way for the grantee to know, without the careful, initial assessment by a case manager, which of the workers that may be laid off would become homeless without HPRP assistance, so a "set-aside" is not allowed.

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.

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 transitional housing program to obtain permanent housing.

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 individuals. Individuals needing assistance can access services from an organization in their local community. Please contact your local grantee to find out if HPRP funds are available now, whether you are eligible to receive this assistance, and how to access it. For contact information, please see the following document: hudhre.info/documents/HPRPContactInfoDec09.pdf.

Individuals and families seeking immediate assistance are also encouraged to contact their local Continuum of Care. For contact information, visit HUD’s Continuum of Care locator. Select your state, and then look for your city or county. If you do not see your city or county listed, look for a Balance of State continuum. Contact the Point of Contact for Homeless Persons. Your local CoC representative can refer you to resources that are currently available in your community.

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 from becoming homeless or assistance to move to another unit (prevention), and 2) individuals and families who are experiencing homelessness (residing in emergency or transitional shelters or on the street) and need temporary assistance in order to obtain housing and retain it (rapid re-housing).

The eligibility criteria are as follows:

Homeless individuals and families, and individuals and families at risk of becoming homeless, must meet the following three criteria in order to receive HPRP financial assistance or services:

- Household must be at or below 50 percent of Area Median Income (AMI)

- Household must meet both of the following circumstances:

(1) no appropriate subsequent housing options have been identified; AND

(2) the household lacks the financial resources and support networks needed to obtain immediate housing or remain in its existing housing.

- Any individual or family receiving rental assistance must have at least an initial consultation with a case manager to determine need.

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 criteria and the grantees comply with all local and federal requirements. For example, grantees may set limits on the amount of assistance any household may receive, may pay for only a portion of a program participant’s rent, may require participants be at 30% or less of Area Median Income (AMI) or may require participants have additional risk factors.

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 utility assistance under another program (either a full or partial subsidy), HPRP funds may not be used for utility assistance during that same time period.

No, HPRP funds may not be paid to collection agencies or other third-party debt collectors.

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. However, grantees must remember that in order to be eligible to receive HPRP assistance, the person must be about to become homeless, or homeless "but for" HPRP assistance.

Grantees must also remember that HPRP is tenant-based assistance, and HPRP funds cannot be used for assistance in any project-based programs. The assistance cannot be attached to a unit; an eligible HPRP program participant must be able to choose whether to reside in the group housing or in another unit. Further, HPRP is a temporary assistance program with limited services that are provided separate from the housing, and is intended to assist persons who can remain stably housed after the assistance ends. If someone needs more intensive supports, HPRP may not be the most appropriate program for that individual.

Finally, grantees must remember that financial assistance for persons in a group home setting is limited to rent, security deposits, utility deposits, and utility payments. Service fees that might be applied at assisted living facilities are not eligible. In addition, if there is another rental subsidy being provided, HPRP cannot be used for rent, and if there is a utility subsidy being provided, HPRP cannot be used for utilities.

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 participant has been assessed and determined to meet all HPRP eligibility criteria described in the HPRP Notice, and they have permanent affordable housing identified in another location, HPRP funds may be used to pay for moving costs to another state. However, note that transportation costs (including bus, train, and airplane tickets) for program participants are not eligible. As described in the HPRP Notice, eligible moving costs include truck rental fees, moving company fees, and similar costs.

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.

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 utility company to offer payment plans to households that miss payments. Second, staff must confirm that no other utility assistance, such as LIHEAP, is available to prevent the shut-off.

If neither of these conditions exist, however, utility-only assistance may be justified under a couple of different scenarios. First, if utilities are shut off during winter months, this can result in a dangerous situation for the occupants. If the household is going to have to abandon the housing due to a lack of utilities and can avoid moving to a shelter by having utilities paid, then HPRP funds may be used for this purpose. Under another scenario, an applicant’s lease may include a provision requiring utilities be maintained for the unit by the tenant. As a result, a utility shut-off could constitute a lease violation, thus placing the household at risk for eviction. In both cases, it is the grantee or subgrantee's responsibility to confirm and document in the case file that the utility company will in fact shut-off the utility if the amount due is not paid.

If the household is going to have to leave the housing due to a lack of utilities, can avoid literal homelessness by having utilities paid, and meets other HPRP eligibility requirements, then a household may be assisted under the Homelessness Prevention category with utility-only assistance.

With regard to documentation, a copy of a utility shut-off notice or arrears statement is not sufficient by itself to document program eligibility. In addition to documenting, via an assessment, that the household has no other financial resources, support networks, or other housing options, grantees/subgrantees must also assess and document that a household with a utility shut-off notice will become literally homeless but for HPRP assistance. In practical terms, this means that HPRP staff must assess whether the household will lose their housing if the utility is shut-off (i.e., it will constitute a lease violation causing lease termination and/or will cause housing to be unfit for human habitation). HPRP staff should attempt to obtain a copy of the participant's lease and highlight the provision related to utility obligations and consequences. If unable to obtain a lease, HPRP staff should assess and record such circumstances in the HPRP participant case file. As with other HPRP eligibility documentation, HPRP staff must first attempt to obtain third-party verification. Participant self-declaration is only acceptable if third-party documentation cannot be obtained.

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.

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 issues and other barriers to stable housing (i.e., as part of the client assessment) may use HPRP funds to pay the costs associated with the credit and background checks. However, grantees and subgrantees may NOT use HPRP funds to reimburse landlords for their costs associated with conducting credit and/or background checks.

NOTE: If grantees or subgrantees elect to conduct credit and/or background checks on HPRP participants, they must do so universally so as to not violate Fair Housing Law or otherwise discriminate among HPRP participants. The costs associated with the credit and/or background checks can be charged to housing search and placement under Housing Relocation and Stabilization.

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) are not eligible.

If a grantee decides to help a client relocate to a different state or another area of a state, the grantee retains responsibility for ensuring that all requirements associated with the program are met, either by the grantee or another grantee. This includes documentation of rent reasonableness, conducting the habitability and lead-based paint inspections, and conducting reassessments every three months.

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 to maintain the housing. All other arrears--e.g., credit card, car payments, medical expenses, cable, or phone bills--are considered bad debt and are not eligible expenses.

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. HUD does not prohibit it.

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 situation is permissible.

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 participants differently than non-HPRP participants (e.g., with regard to fees or disconnections). A waiver is not required.

No, HPRP is not a mortgage assistance program. Also, HPRP may not be used to pay for any taxes or fees related to homeownership.

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 cases where an eviction cannot be prevented, rental arrears can still be paid if it satisfies the grievance with the evicting landlord and thereby allows the participant to obtain different housing. Note that rental arrears can be paid on behalf of a person receiving a subsidy from another public program (e.g., Section 8) because it represents a different time period and cost type than the rental subsidy (ie, the arrears represents a back payment of the client portion, and the current rental assistance is a forward payment).

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 housing has been identified but is not immediately available for move-in by the program participants." This is the only circumstance that HPRP funds can be used to pay for emergency housing costs – i.e., when permanent housing has been identified but it not yet available, and when shelter beds in the community are full.

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 board costs in the youth's foster home would not be eligible, but moving the youth to a unit of his/her own would enable him/her to be eligible as long as he/she meets all of the eligibility criteria. As described in section IV.C, persons who are being imminently discharged into homelessness from publicly funded institutions are eligible to receive financial assistance or services through HPRP and is considered prevention assistance. However, developing or updating system discharge plans and policies is not an eligible expense.

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 www.recovery.gov for more information.

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 paid is the total arrears accrued during the 6 month period.

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.

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.

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 services. The unit into which the program participants move must meet habitability standards as defined Appendix C of the Notice.

Grantees and subgrantees are encouraged to consider local and state building and housing codes when providing financial assistance to persons to allow them to remain in their housing.

Keep in mind that HPRP funds may not be used for the construction or rehabilitation of a building.

There are four categories of activities eligible as HPRP expenditures: financial assistance, housing relocation and stabilization services, data collection and evaluation, and administrative costs.

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, households will need services that are concurrent with financial assistance in order to increase housing stability. Grantees must remember that all households – even those receiving services only – must be reassessed every three months to verify that they meet all HPRP eligibility criteria and that the assistance is needed to prevent homelessness.

Yes, the time spent assessing all households is an eligible expense under the Outreach and Engagement portion of Housing Relocation and Stabilization Services.

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 directly related to housing. Helping eligible program participants to obtain other Recovery Act or mainstream resources is an eligible Housing Relocation and Stabilization Service.

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. Legal assistance related to mortgages is not eligible.

This prohibition on transportation and travel costs refers to program participants. Case managers may travel if needed to serve eligible HPRP program participants.

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 ones who will determine participant eligibility and therefore the program's compliance with the HPRP Notice.

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 product or, when the CoCs HMIS software product does not have a housing search/housing locator module available, purchasing a “customizable off-the-shelf” (COTS) product. However, if a COTS product is purchased, it must interface with the HMIS. Data Collection and Evaluation funds may not be used to purchase and implement a stand-alone housing locator/housing search product that is not integrated with the HMIS.

The costs associated with implementing the housing locator/housing search functionality, including staff time for data entry, user training, and software licensing and support, are also eligible under the Data Collection and Evaluation activity, but the research conducted to identify landlords and/or properties for populating the housing locator is eligible under the Outreach and Engagement activity of Housing Relocation and Stabilization Services.

Please note that HPRP Administrative funds may not be used to purchase or implement housing search/housing locator functionality since the use of Administrative funds is limited to costs associated with reporting, audits, and grant management.

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 meeting the housing needs of program participants and helping them obtain housing stability." This activity would be considered an arrangement and coordination of public benefits.

There are four categories of activities eligible as HPRP expenditures: financial assistance, housing relocation and stabilization services, data collection and evaluation, and administrative costs.

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 direct entry of client level data into a second database. HUD has established the CoC's HMIS as the point of collection for client level data by subgrantees, except when the CoC has not implemented an HMIS, the subgrantee is not located in a CoC, or an agency-specific comparable database is appropriate (e.g., victim service provider). Additionally, HUD requires subgrantees to report unduplicated aggregate data to grantees and does not require identified data be provided to grantees.

If a subgrantee does not want to enter data in two databases to accommodate the grantee's data collection requirements, then the subgrantee, or HMIS administering agency as appropriate, must extract the necessary data from the HMIS and provide it to the grantee. The costs associated with this activity are the responsibility of the subgrantee unless other arrangements are agreed to by all parties. If the grantee does not want to import the exported data directly into the grantee database, especially when that database is an HMIS that covers other CoCs, the grantee may establish another database for analytical purposes and import the data from other data systems into this analytical database. The costs associated with importing data and establishing an analytical database are the responsibility of the grantee unless other arrangements are agreed to by all parties.

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 CoC does not have an HMIS; (3) The grantee and/or subgrantee has a long-standing, client-level legacy data collection system that meets requirements established in the HMIS Data and Technical Standards and will integrate data with HMIS data periodically; or (4) The subgrantee is a domestic violence provider (e.g. organization's primary mission is serving victims of domestic violence/sexual assault/date rape/stalking) or a legal services provider and requires client-level information to remain confidential, and will establish a comparable client-level database internally to its organization (e.g. no identifying data shared with the HMIS or the grantee) and will provide only aggregate data to the grantee as required. The HMIS administering agency, as an agent of the CoC, determines if an alternative database meets the standards for a comparable client-level database, including compliance with the HMIS Data and Technical Standards.

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 data collection, data entry, data analysis, reporting and participation in HUD evaluation for HPRP.

While preparing the substantial amendment, grantees should realistically budget for existing and future HMIS costs related to HPRP, remembering that HPRP funds must be expended by September 30, 2012. HUD encourages grantees to carefully consider costs for the following items when developing their budgets for Data Collection and Evaluation.

• Hardware costs

• Software costs (e.g., user licenses, annual support)

• Participation fees

• HMIS training (e.g., users, system administrator)

• Staff costs, recognizing possibility of staff turnover (e.g., data collection/entry/analysis, reporting, system operation)

• Data integration with comparable database (e.g., DV providers, legal services, legacy database)

• Connectivity

• Participation in national or regional HMIS training events (including travel)

• Providing data to HUD for the national evaluation

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. HUD encourages grantees to carefully consider potential costs to be incurred for expanding HMIS for HPRP data collection, reporting and participation in the HUD evaluation of HPRP, and to budget accordingly.

There are four categories of activities eligible as HPRP expenditures: financial assistance, housing relocation and stabilization services, data collection and evaluation, and administrative costs.

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, regardless of HPRP. HUD's intent is to allow persons providing services or administering the local HPRP program to attend training provided by HUD, the grantee, an authorized HPRP technical assistance provider or other HPRP training held in partnership with HUD in order to learn about HPRP eligible activities, eligible participants, and other requirements, and intent of HPRP. Training on the specific policies and procedures of a grantee's HPRP program may also be an eligible expense, but general training on rapid re-housing or homelessness prevention programs is not.

HPRP administrative funds may be used for the administration of HPRP grants only. General CoC operations are not eligible costs under HPRP.

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 assistance, or housing relocation and stabilization services depending on the type of activity being conducted by the bookkeeper. For example, costs for a bookkeeper to pay for rental assistance, security deposits, etc., are allowable under the category of Financial Assistance because it is directly related to the delivery of financial assistance. The costs for the bookkeeper to pay the for salaries of case managers is a payroll function and, as such, is an administrative cost. Therefore, grantees need to break out the bookkeeper's time based on the activities performed (i.e., the delivery of direct service activities or administrative activities).

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 execution of the grant agreement between HUD and the grantee. This includes, but is not limited to, staff costs for preparing the substantial amendment, other costs related to the public comment process, hiring a consultant for preparation of the Substantial Amendment, and attending HUD-sponsored HPRP meetings and trainings. Note that costs related to the provision of financial assistance, including housing inspections, and housing relocation and stabilization services are not considered administrative costs, and therefore, are not eligible pre-award costs.

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 whether they are eligible.

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 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).

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. 1641). This means that no entity that receives funds under HPRP may knowingly provide HPRP assistance to an alien who is not a qualified alien.

The law requires all state and local governments that directly administer HPRP assistance to first verify that an alien is a qualified alien before using HPRP funds to assist him or her. Nonprofit organizations that administer HPRP assistance are not required, but may, verify that an alien is a qualified alien in order to provide him or her with HPRP assistance. However, if a nonprofit organization pursues verification, it must follow the requirements set forth in the interim guidance published by the Department of Justice.

For more information on these requirements (including documentation), see the “Interim Guidance on Verification of Citizenship, Qualified Alien Status, and Eligibility under Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996,” 63 Federal Register 61344 (Nov. 17, 1997), available at http://www.gpoaccess.gov/fr/advanced.html. (Select 1997 Federal Register and search for page 61344. Scroll down through the list provided to find “Interim Guidance of Verification of Citizenship, Qualified Alien.”)

Grantees/subgrantees with additional questions are encouraged to contact their local US Citizenship and Immigration Services (USCIS) office. An office locator is available at https://egov.uscis.gov/crisgwi/go?action=offices

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 applicant household and/or a copy of a recent bank deposit slip showing receipt of benefits is acceptable.

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 utility company to offer payment plans to households that miss payments. Second, staff must confirm that no other utility assistance, such as LIHEAP, is available to prevent the shut-off.

If neither of these conditions exist, however, utility-only assistance may be justified under a couple of different scenarios. First, if utilities are shut off during winter months, this can result in a dangerous situation for the occupants. If the household is going to have to abandon the housing due to a lack of utilities and can avoid moving to a shelter by having utilities paid, then HPRP funds may be used for this purpose. Under another scenario, an applicant’s lease may include a provision requiring utilities be maintained for the unit by the tenant. As a result, a utility shut-off could constitute a lease violation, thus placing the household at risk for eviction. In both cases, it is the grantee or subgrantee's responsibility to confirm and document in the case file that the utility company will in fact shut-off the utility if the amount due is not paid.

If the household is going to have to leave the housing due to a lack of utilities, can avoid literal homelessness by having utilities paid, and meets other HPRP eligibility requirements, then a household may be assisted under the Homelessness Prevention category with utility-only assistance.

With regard to documentation, a copy of a utility shut-off notice or arrears statement is not sufficient by itself to document program eligibility. In addition to documenting, via an assessment, that the household has no other financial resources, support networks, or other housing options, grantees/subgrantees must also assess and document that a household with a utility shut-off notice will become literally homeless but for HPRP assistance. In practical terms, this means that HPRP staff must assess whether the household will lose their housing if the utility is shut-off (i.e., it will constitute a lease violation causing lease termination and/or will cause housing to be unfit for human habitation). HPRP staff should attempt to obtain a copy of the participant's lease and highlight the provision related to utility obligations and consequences. If unable to obtain a lease, HPRP staff should assess and record such circumstances in the HPRP participant case file. As with other HPRP eligibility documentation, HPRP staff must first attempt to obtain third-party verification. Participant self-declaration is only acceptable if third-party documentation cannot be obtained.

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 continue to use the 2009 dataset until the 2010 data becomes available.

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 receive HPRP assistance, as recorded in HMIS or a comparable data system, are reported in the QPR and APR.

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.

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 determine eligibility, and certifies that no conflict of interest exists related to the provision of HPRP assistance.

The Staff Affidavit must be completed and signed by the person determining eligibility and his or her supervisor for all households determined eligible on or after November 1, 2009. A new Staff Affidavit is only required to be completed if a different staff person re-determines eligibility at a later date. For example, if an intake worker makes the initial determination of eligibility on November 15th, the Staff Affidavit must be signed by the intake worker and his/her supervisor. If the household’s eligibility is then recertified three months later by a case manager (not the same person as the intake worker), a new Staff Affidavit – signed by the case manager and his/her supervisor – would be required. However, if the same individual recertifies the household, he/she would not need to complete an additional Staff Affidavit form.

Assuming the grantee is not administering funds directly, the grantee does not need to sign the Staff Affidavit. However, when grantees conduct periodic monitoring of subgrantees, they should ensure that signed forms appear in approved program participants’ case files.

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 eligible to receive HPRP assistance (assuming it meets all the other eligibility criteria). HUD requirements on determining and documenting income eligibility for HPRP applicants is available at hudhre.info/documents/hprp_IncomeDocReqs.pdf.

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.

Yes, the time spent assessing all households is an eligible expense under the Outreach and Engagement portion of Housing Relocation and Stabilization Services.

No, the reassessment/recertification requirement applies to all households served under HPRP, whether they are receiving financial assistance and services or just services.

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 criteria and the grantees comply with all local and federal requirements. For example, grantees may set limits on the amount of assistance any household may receive, may pay for only a portion of a program participant’s rent, may require participants be at 30% or less of Area Median Income (AMI) or may require participants have additional risk factors.

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 financial assistance (rent assistance, utility assistance, utility/security deposits, or arrears).

• The unit was constructed prior to 1978.

• A child under the age of six is or will be living in the unit.

Under HPRP, the lead requirements apply regardless of whether a household is remaining in an existing unit or moving to a new unit. The visual assessment must be completed prior to HPRP assistance being provided, and annually thereafter.

Detailed guidance on the Lead-Based Paint requirements and sample tools are available on the HRE at http://hudhre.info/HPRP/index.cfm?do=viewHPRPTools.

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 local code, it cannot be used in place of the HPRP habitability inspection unless the grantee can verify that it meets all of the standards in Appendix C of the HPRP Notice (including the frequency with which the inspection is required). If there are requirements that are covered in both the habitability standards and state/local housing code, grantees must comply with the more stringent of the two. However, compliance with state and local codes is a local matter. Typically, landlords should have a Certificate of Occupancy or other documentation that ensures that the building complies with local requirements. If grantees have questions about their state or local housing code, they are encouraged to contact their state or local housing agency for more information.

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 hudhre.info/documents/HabitStandardsChecklist.doc

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: http://www.hud.gov/offices/lead/training/visualassessment/h00101.htm. The training teaches individuals how to identify deteriorated paint and how deteriorated paint must be treated.

Note that a HUD-certified Visual Assessor is not equivalent to a Lead Risk Assessor or Certified Clearance Examiner, whose services may be needed if lead hazards are identified during the visual assessment.

Detailed guidance on the Lead-Based Paint requirements and sample tools are available on the HRE at http://hudhre.info/HPRP/index.cfm?do=viewHPRPTools .

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 services. The unit into which the program participants move must meet habitability standards as defined Appendix C of the Notice.

Grantees and subgrantees are encouraged to consider local and state building and housing codes when providing financial assistance to persons to allow them to remain in their housing.

Keep in mind that HPRP funds may not be used for the construction or rehabilitation of a building.

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-housing assistance is provided (i.e. when participants are moving into units and when there is a current lease in place). If the rent for the unit does not meet the rent reasonableness standard, then HPRP funds may not be used to assist the household in that unit. Further, HPRP funds cannot be used to pay the rent up to the rent reasonable standard, while the tenant pays the remainder. However, an eligible household could receive HPRP assistance to relocate to another unit that does comply with rent reasonableness standards, and is ultimately more affordable to the household.

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 between the participant/grantee/subgrantee and the landlord is not in violation of the conflict of interest provisions as stated in the HPRP Notice. For example, the sublease agreement should not be between relatives, friends, or other parties when there is a potential conflict of interest. That is, the grantee or subgrantee would have to document that the rent charged and the terms of the sublease are the same for the participant as they are for all other tenants renting comparable units from that landlord.

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).

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.info Grantees and subgrantees are encouraged to review these documents to determine which they could adapt for their local program.

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 documentation it will require in order to ensure that the rent reasonableness standard is met.

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 can be noted in the case file or case management notes.

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 period of ongoing assistance. Programs should have a clear and consistent procedure for determining when a client who is receiving supportive services is no longer considered a program participant. For example, if a person has been receiving weekly case management as part of a rapid re-housing program and either formally terminates his or her involvement or fails to keep appointments such that the program no longer considers the individual to be a program participant, then the last date of service and exit date may be the date of the last case management session.

For HPRP programs, the Program Exit Date may be the same as the Program Entry Date if participation begins and ends on the same day (e.g., in the case of a one-time payment for arrears, a security deposit, or one month of rental assistance). For a program participant receiving ongoing assistance for two or more consecutive months, the Program Exit Date should be equivalent to the last day of the last month for which the rental assistance payment applies.

HUD does not require follow-up reporting on housing stability. The housing status identified at program exit should be the agency’s best assessment of the household’s near-term stability as of the time of exit.

Yes, sample data collection templates are available on the HRE at http://hudhre.info/hprp/index.cfm?do=viewHPRPData

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/documents/HMISDataStandards_July2009.pdf. The type of assistance (homelessness prevention or homeless assistance/rapid re-housing) is based on the Housing Status recorded at program entry. Specifically, program participants with a Housing Status of “literally homeless” at entry would be classified as receiving homeless assistance (rapid re-housing); clients with a Housing Status other than “literally homeless” would be classified as receiving homelessness prevention assistance. The Housing Status at program entry field should not be changed/updated even if the housing status of the program participant changes subsequent to program entry. Thus, if an individual is literally homeless at the time of application, the type of HPRP assistance for the whole period is considered to be homeless assistance (rapid-rehousing). This is true even if the program participant begins receiving assistance from a different subgrantee. If the participant later returns for additional assistance after he/she has formally exited the program (and is still housed), then the client would be recorded under homeless prevention.

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 and throughout the entire CoC. All clients served by a program, including dependent children, are considered program participants and must be entered into the HMIS so that they can receive a PIN. All individuals in the same household should receive the same Household Identification Number. A household is defined as a single individual or a group of persons who together apply to an HPRP funded program for assistance.

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 direct entry of client level data into a second database. HUD has established the CoC's HMIS as the point of collection for client level data by subgrantees, except when the CoC has not implemented an HMIS, the subgrantee is not located in a CoC, or an agency-specific comparable database is appropriate (e.g., victim service provider). Additionally, HUD requires subgrantees to report unduplicated aggregate data to grantees and does not require identified data be provided to grantees.

If a subgrantee does not want to enter data in two databases to accommodate the grantee's data collection requirements, then the subgrantee, or HMIS administering agency as appropriate, must extract the necessary data from the HMIS and provide it to the grantee. The costs associated with this activity are the responsibility of the subgrantee unless other arrangements are agreed to by all parties. If the grantee does not want to import the exported data directly into the grantee database, especially when that database is an HMIS that covers other CoCs, the grantee may establish another database for analytical purposes and import the data from other data systems into this analytical database. The costs associated with importing data and establishing an analytical database are the responsibility of the grantee unless other arrangements are agreed to by all parties.

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 actually assisting clients with HPRP funds that are subject to the data collection and reporting requirements. If the agency operating the hotline provides additional HPRP-funded services beyond intake and referral, they would be required to report client-level data per the HMIS Data Standards.

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 and fund another agency to administer HMIS data collection and reporting for HPRP.

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 guidance document will assist HPRP grantees, subgrantees and HMIS administering agencies to understand and comply with data collection requirements for domestic violence providers.

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.

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 difficult to make a change to the report. If no changes are required, a grantee does not have to resubmit the report as final; HUD will accept the preliminary report as final, and the e-snaps system will change it to “final” status at the end of the review period if it is the only report appearing in the system.

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 compiles data for all subgrantees and name it such that a reviewer could easily identify it as the correct version. In such instances, grantees can also send a note through the Virtual Help Desk to inform HUD which report is the correct version.

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. HUD will monitor disbursements, but does not expect the draws in IDIS to match exactly what is reported in the QPR. HUD recognizes that due to differences in timing of draws and expenditures, the information in both systems could vary. However, if there are large differences between the amounts reported as drawn and expended between the two systems, HUD may contact the grantee. Grantees can use existing IDIS reports (e.g., the PR02 report) to monitor their commitments and expenditures.

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 specifically designed to provide for accounting and reporting of all HPRP expenditures to HUD. Thus, it is up to grantees to determine the most appropriate financial records upon which to generate financial information for the QPR.

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 ensure participants receive no more than the maximum 18 months of total rental assistance.

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 would count as two people served and one household served. An unaccompanied individual should be counted as one person and one household.

The report is intended to describe the number of people benefiting from the service, regardless of who directly participates in the activity. While only the adult directly participated in the service, the service benefited the entire household. Similarly, all persons in the household should be counted as served by financial assistance.

In most cases, only one household member directly interacts with the service provider. If only that person is counted as receiving the service, then the total number of persons would almost always be equivalent to the total number of households, and the “person” count would not be meaningful for determining the actual number of persons in households served.

The count of total number of persons inclusive of all household member can be generated in multiple ways: (1) Grantees and subgrantees can specifically enter a service record for each member of the household enrolled in the program, regardless of whether the person received the service directly. (2) The software can automate the process of adding service records to all household members whenever one member receives the service. (3) When reports are generated, queries can automatically tally all members of a household whenever any household member is associated with a service record.

The automated approaches can only be used if the other household members have the same household identification and housing status as the person directly interacting with the service provider, and if those other household members are actually enrolled in the program on the date in which the service was delivered.

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 http://hudhre.info/HPRP/index.cfm?do=viewHPRPData

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 and beneficiary reporting by July 2009.

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 need to hire three case managers to operate a new Homelessness Prevention program in a particular County. These three jobs will be reported as "created" through the use of HPRP funds.

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/hprp/ as they become available, so check back frequently.

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 Department plans to host nine 1-1/2 day regional meetings during May and June. As soon as the schedule for the regional meetings is finalized, HUD will publish the dates and locations as well as registration information. Additional technical assistance and training initiatives are also being planned and will be announced via the listserv and the HRE.