County of Riverside Continuum of Care (CoC)

Standards & Evaluation Committee Meeting

December 21, 2017 | 2:00 – 4:00 p.m. DPSS Self Sufficiency Banning Office 63 S. 4th Street, Banning, CA 92220

Chairperson: Linda Barrack, Martha’s Village & Kitchen Vice Chairperson: Susan Larkin, Valley Restart

Purpose • Recommend baseline/performance standards for CoC in compliance with or in addition to funding guidelines/thresholds. • Develop a process to evaluate performance of CoC and Emergency Solutions Grant (ESG) projects. • Establish, train and support an annual funding application work group that consists of non-conflicted individuals.

1. Call to Order: Welcome & Introductions – Roll Call 2. Public Comments 3. New Business:

a. Housing Quality Standards Policies & Procedures Rowena Concepcion/Linda Salas b. Compliance & Performance Monitoring Process Rowena Concepcion/Linda Salas c. Written Standards: Emergency Shelter vs. Transitional Rowena Concepcion

Housing 4. Standing Business:

5. Call for Agenda Items for Next Meeting

6. Adjournment

7. Next Meetings:

• CoC Board of Goverannce Meeting: January 18, 2018, 9:30 a.m. – 11:30 a.m.

Banning DPSS Children/Adult Services Office, 901 E. Ramsey St., Banning, CA 92220 • HMIS Administrators Council: February 7, 2018, 1:00 – 3:00 p.m.

DPSS Staff Development Office, 22690 Cactus Avenue, Moreno Valley, CA 92553 • Housing Committee Meeting: February 13, 2018, 2:00 – 3:00 p.m.

Banning DPSS Children/Adult Services Office, 901 E. Ramsey St., Banning, CA 92220 • Standards & Evaluation Committee Meeting: February 15, 2018, 2:00 – 4:00 p.m.

Banning DPSS Self Sufficiency GAIN Office, 63 S. 4th Street, Banning, CA 92220 • Coordinated Entry System Oversight Committee Meeting: February 22, 2018, 1:00 – 3:00 p.m.

Banning DPSS Children/Adult Services Office, 901 E. Ramsey St., Banning, CA 92220 • CoC Meeting: February 28, 2018, 10:00 a.m. – 12:00 p.m.

City of Banning Council Chambers, 99 E. Ramsey Street, Banning, CA 92220 • Membership Committee Meeting: February 28, 2018, 1:30 – 3:00 p.m.

Banning DPSS Self Sufficiency GAIN Office, 63 S. 4th Street, Banning, CA 92220

County of Riverside Continuum of Care (CoC)

Minutes for County of Riverside Continuum of Care


Thursday, August 17, 2017 2:00 p.m. to 4:00 p.m.

DPSS Banning Self Sufficiency GAIN 63 S. 4th Street, Banning, CA 92220

TOPIC PRESENTER ACTION/ OUTCOME Call to Order Linda Barrack, Standards

& Evaluation Committee Chairperson

• The meeting was called to order at 2:13 p.m.

Approval of Minutes Linda Barrack Motion was made by Sterlon Sims and seconded by Susan Larkin to approve the minutes for June 15, 2017.

ACTIONS & DECISIONS PRESENTER ACTION/ OUTCOME Brown Act Standing Committee Changes

Donyielle Holley, Social Service Planner

• Donyielle asked the committee members if they would like to provide a call in option for this and other committee meetings. The committee agreed that having teleconference availability would provide potential for more participation. Discussion was had surrounding how a committee member is defined; however, they decided to discuss at the next CoC meeting.

• In regards to the Board of Governance meeting, the committee recommended that they would prefer, at a minimum, the opportunity to call in and listen, and if they had public comments on an agenda item, they could advance their written commentary.

Review New Reports Rowena Concepcion, Collab. Applicant

• Rowena Concepcion presented that Joshua Coda, Administrative Services Assistant for HMIS, created two new reports, the Length of Stay Report and the HMIS Timeliness Report:

o Length of Stay Report - Rowena acknowledged the need for the CoC to develop a plan to turn over some of the beds that have been filled for a large number of years.

• Elizabeth Hernandez recommended the committee to look into learning more about the Moving On Initiative to help with a plan for emptying the beds. The links will be sent to the committee.

o The CSH Moving On Toolkit states, “In response to tenant desires and the need to build more supportive housing capacity, several communities are working with local funders and public housing authorities to develop Moving On or Moving Up initiatives that provide tenants who are able and want to move out of supportive housing with a rental subsidy and assistance transitioning to a new apartment. HUD has publicly provided strong support for Moving On but, to date, these initiatives operate on the periphery of supportive housing and only exist on a small scale through scattered pilots.”

• Lynne Brockmeier suggested we begin by focusing on tenants that have been staying 10 years or more. Linda Barrack suggested projects be assessed annually to determine if clients that are staying for more than 10 years, have a valid reason that they cannot move on. Rowena added that

Page 1 of 3 County of Riverside, Standards & Evaluation Committee Minutes –08.17.17 Draft for approval 12.21.17

the CoC is looking for ways to increase housing stock. Susan Larkin recommended that the Housing Committee could also work on this item.

• Susan and Linda both agreed that CoC-wide training on motivational interviewing is needed. Linda also recommended that in-kind training be offered.

o HMIS Timeliness Report – The committee reviewed the timeliness report and recommended to provide bonus points for agencies that are meeting the 7-day window on reporting entries and exits.

CoC Written Standards – NOFA Required Revisions

Donyielle Holley • The committee reviewed a handout of the draft written standards. • Page 4 - 5:

o HUD is requiring that CoCs adopt a non-discrimination policy in compliance with their Equal Access in Accordance with Gender Identity Final Rule. Donyielle informed the committee that the draft written standards includes the required verbiage for the equal access final rule; however training tools will need to be provided and funded agencies will need to post a one page equal access policy notice at their site.

Gaps Analysis Update Linda Barrack • Tabled to the next meeting.

ADJOURNMENT PRESENTER ACTION/ OUTCOME Call for Agenda Items: Linda Barrack • Gaps Analysis Update

• Written Standards

Next meeting Linda Barrack Thursday, October 19, 2017 2:00 p.m. to 4:00 p.m.


Adjournment Linda Barrack The meeting was adjourned by Linda Barrack at 4:33 p.m.


Standards & Evaluation Committee Meeting– August 17, 2017: Attendance Report Total in Attendance: 8 DPSS Staff: 4 CoC At-Large: 4 *Chair **Vice Chair DPSS Homeless Programs Donyielle Holley DPSS Homeless Programs Elizabeth Hernandez Economic Development Agency - ESG Sterlon Sims DPSS Homeless Programs Rowena Concepcion Martha’s Village & Kitchen Linda Barrack* DPSS Homeless Programs Tiffany Nelson Valley Restart Shelter Susan Larkin** Riverside University Health System – Behavioral Health Lynne Brockmeier Guests: 0


Minutes for County of Riverside Continuum of Care


Thursday, October 19, 2017 2:00 p.m. to 4:00 p.m.


TOPIC PRESENTER ACTION/ OUTCOME Call to Order Susan Larkin, Standards

& Evaluation Committee Vice Chairperson

• The meeting was called to order at 2:06 p.m.

Approval of Minutes Susan Larkin • August 17, 2017 minutes – tabled to the next meeting ACTIONS & DECISIONS PRESENTER ACTION/ OUTCOME Brainstorm Alternative Funding

Susan Larkin • The committee discussed the absence of an active Funding/Finance committee. Donyielle Holley, CoC Planner informed the committee that the Planning Committee has recommended to remove the Funding/Finance Committee from the CoC Charter.

• Donyielle provided a USICH handout: Supportive Housing Opportunities Planner (SHOP): Using Supportive Housing to End Chronic Homelessness. The Committee reviewed the handout and brainstormed the following resources for additional funding:

o Social Enterprise o Obtaining a list of all registered non-profit foundations from Regional Access Project –

possibly contacting Leticia DeLara about CoC membership to the Center for Nonprofit Advancement

o IEcapaciteria.org o IEHP is on board, so we can reach out to Molina Healthcare and Kaiser o Insurance agencies o Banks – Wells Fargo used to sit on the BOG, but stepped down o The Pot Growers – cultivators to fund affordable housing

• The committee discussed the lack of affordable housing throughout the county (i.e. difficulty with bad credit, criminal history, not enough income, etc.).

CoC Written Standards – Emergency Shelter

Donyielle Holley, CoC Planner

• Donyielle will be emailing out the full written standards document to the committee for feedback on the Emergency Shelter section.

CoC Gaps Analysis Review Linda Barrack, Standards & Evaluation Committee Vice Chairperson

• Frankie Riddle, City of Palm Desert, asked if any more discussion took place regarding the Independent Review Panel working with the Standards and Evaluations committee. This is still up for discussion.

• Lisa Michelle, Path of Life Ministries, acknowledged that the previous minutes mentioned motivational interviewing as a need. She informed the committee that she is a motivational


interviewer and that she would like to join the Standards and Evaluation Committee.

• Donyielle provided a data handout identifying the following gaps: o Population breakdown o Regional breakdown o Self-reporting subpopulation breakdown

• Examining the handout, Linda Barrack defined that some clients are dually diagnosed, having both substance use and mental health as barriers; which in turn makes for the hardest to serve subpopulation.

• Linda asked to review the unsheltered population. Donyielle referred the committee to the SHOP handout which identified 81 new funded unsheltered beds available in 2017 and 68 unsheltered beds to become available in 2018. Linda announced that she and Donyielle will prepare a presentation of the gaps and send it to the committee for feedback.

• Youth Gaps: Linda stated that the transitional rapid rehousing model is best for unaccompanied youth or transitional age youth (TAY) ages 18-24. Donyielle acknowledged that HUD is expected to release the Youth Demonstration Grant again and our CoC has approved the addition of a Youth Advisory Board; it’s important that we bridge things together with the youth ending youth homelessness group. David Leahy added that there is a new nonprofit for LGBT youth in the Coachella Valley area called Sanctuary Palm Springs. He suggested that they could be reached out to as a part of our initiatives to end youth homelessness.

• Family Gaps: the committee agreed that there is a lack of affordable housing and briefly discussed applying for TH-RRH in future HUD funding cycles.

• Individual Gaps: the committee agreed that individuals experiencing homelessness would best be served with emergency shelter and transitional housing. They discussed signing everyone up for Section 8. Marcus Cannon, RUHS – Behavioral Health, stated that the CES Lead already signs everyone up for Section 8.

• The committee agreed that they need to finalize recommendations to bring before the Board of Governance to heighten discussion surrounding the CoC’s needs.

ADJOURNMENT PRESENTER ACTION/ OUTCOME Call for Agenda Items: Linda Barrack • Approve tabled minutes Next meeting Linda Barrack Thursday, December 21, 2017

2:00 p.m. to 4:00 p.m. DPSS Banning Self Sufficiency GAIN 63 S. 4th Street, Banning, CA 92220

Adjournment Linda Barrack The meeting was adjourned by Linda Barrack at 4:07 p.m.


Standards & Evaluation Committee Meeting– October 19, 2017: Attendance Report Total in Attendance: 9 DPSS Staff: 2 CoC At-Large: 7 *Chair **Vice Chair DPSS Homeless Programs Donyielle Holley DPSS Homeless Programs Tiffany Nelson ABC Recovery Center Inc. David Leahy City of Palm Desert Frankie Riddle Guests: 0 Martha’s Village & Kitchen Linda Barrack* Path of Life Ministries Lisa Michelle Riverside University Health System – Behavioral Health Marcus Cannon Shelter from the Storm Angelina Coe Valley Restart Shelter Susan Larkin**


Riverside County, Department of Public Social Services Homeless Programs Unit

HUD-CoC Program Housing Quality Standards Policies and Procedures 24 CFR 982.401 and § 578.75

Rationale

Housing Quality Standards (HQS) are the HUD-established minimum quality standards for Continuum of Care (CoC) and Emergency Solutions Grant (ESG) Programs. Verification of HQS is required both at initial occupancy and annually during the term of the lease. HQS standards apply to the building and premises, as well as the unit. Newly leased units must pass the HQS inspection before the beginning date of the assisted lease and Housing Assistance Payments (HAP) contract. 24 CFR Part 578.75 of the Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Continuum of Care Program states:

(b) Housing quality standards. Housing leased with Continuum of Care program funds, or for which rental assistance payments are made with Continuum of Care program funds, must meet the applicable housing quality standards (HQS) under 24 CFR 982.401 of this title, except that 24 CFR 982.401(j) applies only to housing occupied by program participants receiving tenant-based rental assistance. For housing rehabilitated with funds under this part, the lead-based paint requirements in 24 CFR part 35, subparts A, B, J, and R apply. For housing that receives project-based or sponsor-based rental assistance, 24 CFR part 35, subparts A, B, H, and R apply. For residential property for which funds under this part are used for acquisition, leasing, services, or operating costs, 24 CFR part 35, subparts A, B, K, and R apply. (1) Before any assistance will be provided on behalf of a program participant, the recipient, or subrecipient, must physically inspect each unit to assure that the unit meets HQS. Assistance will not be provided for units that fail to meet HQS, unless the owner corrects any deficiencies within 30 days from the date of the initial inspection and the recipient or subrecipient verifies that all deficiencies have been corrected. (2) Recipients or subrecipients must inspect all units at least annually during the grant period to ensure that the units continue to meet HQS. (c) Suitable dwelling size. The dwelling unit must have at least one bedroom or living/sleeping room for each two persons. (1) Children of opposite sex, other than very young children, may not be required to occupy the same bedroom or living/sleeping room. (2) If household composition changes during the term of assistance, recipients and subrecipients may relocate the household to a more appropriately sized unit. The household must still have access to appropriate supportive services.

The policies and procedures describe the duties and responsibilities of DPSS as the recipient of HUD-CoC Program funds and the Subrecipients, in conducting HQS inspections. It also includes

DPSS Housing Quality Standards Policy and Procedure Page 1


the responsibilities of the property owner and program participant, as well as the consequences of non-compliance with HQS requirements. Requirements and Guidelines for Inspections 1.0 Acceptability Criteria [24 CFR 982.401(a)] DPSS Housing Quality Standards include all the acceptability criteria defined in 24 CFR 982.401, plus the additional acceptability criteria described below in Section 1.13, Additions to the HQS Acceptability Criteria. DPSS and/or Subrecipients will provide the HQS Inspection Checklist to owners and or program participant at any time upon request. 1.1 HQS Guidelines for Unit Size Selected HQS standards allow two persons per bedroom and permit maximum occupancy levels as shown in the table below, assuming another room, such as a living room or den, is used as a sleeping area when the unit is at maximum occupancy. Rooms besides bedrooms may be used for sleeping as long as all sleeping rooms are in HQS compliance.

Unit Size Maximum Number in Household

0 bedroom 2 1 bedroom 3 2 bedroom 5 3 bedroom 7 4 bedroom 9 5 bedroom 11 6 bedroom 13

At the initial inspection, the inspector shall make a determination as to the number of rooms that are acceptable sleeping rooms for the purpose of deciding maximum occupancy level according to HQS. The inspector’s determination will be made on a case-by-case basis, based on HQS standards, the design of the structure, family composition, and safety of egress. 1.2 HQS Notification Prior to inspection, Subrecipients can use several methods to inform owners about HQS requirements: owner briefing materials, telephone discussion, inclusion of HQS requirements in tenancy approval materials, monthly newsletters to owners in the program, owner workshops, and public meetings with current and prospective owners.



The Subrecipient should have a system to track units requiring reinspection to determine HQS compliance for all fail and inconclusive items. The Subrecipient should provide to the owner and the program participant a written notification of the HQS inspection process. 1.2 Types of Inspections [24 CFR 982.401(a), 982.405] Subrecipient performs the following types of inspections:

1. Initial/move-in: Must be conducted prior to participant move-in; 2. Annual: Must be conducted within 12 months of the initial inspection or the previous

annual inspection; 3. Complaint: An inspection requested by the tenant or the owner based on a perceived

violation of HQS. DPSS will verify that the initial and annual inspections were conducted during project monitoring which will occur approximately 6 months after project implementation. DPSS will monitor Housing Quality Standards (HQS) in accordance with the Code of Federal Regulations 24 CFR 578.75(b) and 24 CFR Part 982, by conducting quality control inspections for a sample of 10% of a project’s actively enrolled units. DPSS performs the following type of inspections:

1. Special: An inspection requested by another agency, such as HUD, or by a third party, asking DPSS to review the unit; and

2. Quality Control: Conducted by DPSS as third party verification to ensure the consistency and accuracy of Subrecipients HQS determinations.

1.3 Initial HQS Inspections [24 CFR 982.401(a), 982.305(b)(2)] After the program participant has located a unit and the unit’s affordability has been confirmed by the housing navigator or case manager, the Subrecipient will call the owner and provide instructions for scheduling an initial HQS inspection of the unit. Subrecipients will perform the initial inspection within 10 business days of the request. Subrecipient’s inspectors cannot pick up keys or open lock boxes, and will not inspect units without the owner or the owner’s representative, who must be over the age of 18, present. For initial inspections, the owner’s representative may not be a member of the participant’s family, even if the family already has occupancy of the unit where they hope to use their assistance. The initial inspection will be conducted to:

1. Determine if the unit and property meet HQS as defined in 24 CRF 982; 2. Determine the number of rooms that are acceptable sleeping rooms for the purpose of

deciding maximum occupancy level; and



3. Document the information to be used, including current condition of the unit, for determining rent-reasonableness.

If the unit fails the initial HQS inspection, the owner will be given up to 10 business days to correct the failed items, at the inspector's discretion, depending on the amount and complexity of work to be completed. The owner will be advised to contact the Subrecipient to schedule a re-inspection once repairs are completed. If 10 business days have elapsed and the Subrecipient has not received an inspection request from the owner, or if the unit fails the re-inspection, the Subrecipient will not approve the tenancy and the participant will be required to select another unit. 1.4 Annual HQS Inspections [24 CFR 982.401(a)] Subrecipients conduct inspections of each assisted unit at least annually, and no later than 365 days after the initial inspection or the previous annual inspection, to determine continuing compliance with HQS. As per 24 CFR 982.551(d), the participant must allow the Subrecipient/DPSS to inspect the unit at reasonable times with reasonable notice. Reasonable times to conduct an inspection are between 8 a.m. and 5 p.m. Upon request by participants, inspections may be performed between the hours of 7 a.m. and 6 p.m., provided an inspector is available. The Subrecipient will notify the participant in writing at least 5 business days prior to the annual inspection. 1.5 Attendance at Annual/Special/Quality Control Inspections An adult family member must be present during annual, special and/or quality control inspections. If no family member is available, the family may ask a representative to be present instead, as long as that person is 18 or older. The presence of the owner or the owner’s representative is encouraged but not required. Subrecipient inspectors will not inspect units without a family member, owner, or representative over the age of 18 present. If no representative is able to be present, the inspection appointment must be rescheduled. 1.6 Re-Inspections The Subrecipient will send written notice of the re-inspection appointment to the owner and participant by email or regular mail. If the unit fails the re-inspection, the participant and owner will be responsible for scheduling a second revisit within the time frame specified for the repairs. Re-inspections must be conducted within 30 days. If the unit still did not pass the re-inspection, the lease should be terminated and the participant must be transferred to another unit. 1.7 Time Standards for Repairs



Emergency items must be corrected by the owner within 24 or 72 hours, depending on the severity of the defect. See Section 1.14 below for a list of emergency repair items and their timeframes for repair. Non-emergency repairs must be made within 30 calendar days of the annual, special, and quality control inspection. 1.8 HQS and Rent Increases Proposed increases to the contract rent that are requested on the Request for Tenancy Continuation (RTC) form will not be considered if the unit was not found to be in HQS compliance during the first visit at the time of the most recently scheduled annual inspection. If the unit was in HQS compliance at that time, then a rent reasonableness assessment will be made to determine whether the requested rent increase is market reasonable. 1.9 Complaint Inspections and Special Inspections [24 CFR 982.405(c)] If at any time the participant or owner notifies DPSS and/or Subrecipient that the unit does not meet HQS, DPSS/Subrecipient will conduct a complaint inspection if the office determines that such an inspection is warranted. When a tenant requests a complaint inspection, DPSS will ask the tenant to furnish proof that the tenant submitted written notification of the issue, with a request to correct, to the owner before the complaint inspection is scheduled, unless the tenant reports that the unit is uninhabitable. DPSS will also conduct special inspections based on information provided by third parties, such as neighbors, public officials, or representatives from HUD, when the office determines that such inspections are warranted. In the case of complaint inspections and special inspections, DPSS will focus on the items that were reported by the tenant, owner or third party making the complaint or report. However, if the inspector notices additional deficiencies that place the unit out of HQS compliance, those additional items will be noted on the inspection report, and the owner will be required to make those repairs as well. If a complaint inspection or a special inspection occurs within 120 days of the annual inspection due date, the complaint or special inspection may serve as the annual inspection as well, as long as the inspector reviews the complete HQS checklist. 1.10 Quality Control Inspections [24 CFR 982.405(b)] DPSS will perform a third party verification of quality control inspections conducted under contract for a sample of 10% of a project’s actively enrolled units. The purpose of quality control inspections is to confirm that each inspector is conducting accurate and complete inspections, and to ensure consistency among DPSS and Subrecipient inspectors in applying



HQS. The sample of units selected for quality control inspections will include units with initial or annual inspections completed, a cross-section of neighborhoods, and a cross-section of inspectors. 1.11 Additions to the HQS Acceptability Criteria In addition to the acceptability criteria defined in 24 CFR 982.401, DPSS HQS standards also include the additional acceptability criteria defined below. All utilities must be in service prior to any inspection, including an initial inspection. If the utilities are not in service when the inspector arrives, the inspector will notify the owner to have the utilities turned on and to contact the inspector to reschedule the inspection. All appliances that are provided according to the lease or that are installed in the unit at lease-up must be in operating order. If the tenant is responsible for supplying the refrigerator, DPSS will allow the refrigerator to be placed in the unit after the unit has passed all other HQS items without requiring a re-inspection. All tenant-paid utilities must be solely for the use of the tenant. If the owner retains use of any portion of the property (for example, a storage shed), the owner-retained portion must have an independent utility source paid by the owner, or the owner must pay all of the applicable utilities. The owner may opt to disconnect the utility to the owner-retained portion of the property. Dead bolt or dead latch locks on exterior doors of the unit shall be constructed so that they may be opened from inside without use of a key. Bars, grilles, grates or similar devices may be installed on bedroom windows and exterior doors, only if such devices are equipped with release mechanisms that are operable from the inside without the use of a key or special knowledge or effort. If more than one window is present in a bedroom, then bars only need to be removed, or equipped with a release mechanism that is operable from the inside, on one window, which will allow for safe egress from the room. In addition,

1. In units where the tenant must pay for utilities, each unit must have separate metering device(s) for measuring utility consumption.

2. A ¾” overflow pipe must be present on the hot water heater safety valves and installed down to within 6 inches of the floor.

3. All units will comply with City Building Codes 1.12 Owner/Program Participant Responsibilities for HQS [24 CFR 982.404, 982.54(d) (14)]



DPSS/Subrecipient generally holds the owner responsible for maintaining a unit in a condition consistent with HQS, except in the following instances:

1. Tenant-paid utilities are not in service; or 2. Participant fails to provide or maintain family-supplied appliances.

If the owner believes the participant is responsible for other violations of HQS, including damages beyond normal wear and tear to the unit or premises by a household member or guest, the owner must enforce the lease terms to hold the participant responsible for restoring HQS, including paying for necessary repairs. It is the owner’s responsibility to enforce the lease, up to and including eviction, should that prove necessary. 1.13 Time Frames for Corrections of HQS Fail Items The following are the standard time frames for repair of HQS fail items on an annual inspection report.

1. Emergency items which endanger the family’s health and safety must be corrected within 24 hours.

2. Repair of refrigerators, range and oven, or a major plumbing fixture supplied by the owner must be completed within 72 hours.

3. Minor repairs must be completed within 30 days. 1.14 Emergency Repair Items [24 CFR 982.404(a)] The following items are considered emergency items that need to be corrected within 24 hours, or HAP will be abated:

1. No hot or cold water; 2. No electricity; 3. Inability to maintain adequate heat; 4. Major plumbing leak; 5. Natural gas leak; 6. Broken lock(s) on first floor doors or windows; 7. Broken windows that allow weather elements into the unit; 8. Electrical outlet smoking or sparking; 9. Exposed electrical wires that could result in shock or fire; 10. Non-working smoke and/or carbon monoxide detectors; 11. Unusable toilet when only one toilet is present in the unit; 12. Security risks such as broken doors or windows that would allow intrusion; 13. Other conditions that pose an immediate threat to health or safety.

1.15 Lead-Based Paint Regulations (24 CFR Part 35) In compliance with HUD’s lead-based paint regulations, DPSS is committed to ensuring that units are free from lead hazards before they enter the HUD-CoC Program.



Federal lead-based paint requirements apply to homes built before 1978 that are occupied, or intended to be occupied, by a child under age six. Subrecipient’s HQS inspectors are encouraged to get the following HUD certified online training to conduct visual lead-based paint assessment on required units, which will be done during HQS inspections.

• Visual Assessment Course https://www.hud.gov/program_offices/healthy_homes/healthyhomes/lead

• HUD Public Housing Online Training https://www.hud.gov/program_offices/public_indian_housing/reac/products/prodpass

The Uniform Physical Condition Standards inspection code (UPCS) is a standardized inspection code created by HUD and Congress in 1998 as a way of establishing a dynamic inspection code that could satisfy the diverse housing stock monitored by the Department of Housing and Urban Development (HUD). 1.16 Time Frame for Compliance when Clearance is Required [24 CFR 982.405(a)] For New Unit inspections, the owner will have up to 15 days from the inspection date to provide a “passed” clearance test. All repairs must be completed prior to the execution of a HAP contract. If the owner declines to proceed with repairs, or does not complete them within the specified time frame, the applicant will be contacted to locate a new unit. For Annual and Complaint inspections, the owner will have up to 30 days from the inspection date to provide a “passed” clearance test. Any requests for an extension for reasonable cause must be submitted in writing prior to the due date for repairs. 1.17 Abatement of the HAP [24 CFR 982.405, 982.453] When DPSS/Subrecipient determine that a unit on the program fails to meet HQS and the owner fails to make the necessary repairs within the time frame specified, DPSS/Subrecipient will abate (cease) the Housing Assistance Payment to the owner. If a unit fails an annual inspection, the owner will be sent a written inspection report and pre-abatement notice that identifies:

1. The fail items that must be corrected for Housing Assistance Payments to continue; 2. The date of the pre-scheduled re-inspection; and 3. The time frame required to repair fail items without abatement.

If all fail items are not corrected within the time frames specified, abatement of the HAP payment will begin on the first of the month following the expired time frame and continue until the unit receives a passed inspection, or the contract terminates.


https://www.hud.gov/program_offices/healthy_homes/healthyhomes/lead

https://www.hud.gov/program_offices/public_indian_housing/reac/products/prodpass


The tenant is not responsible for DPSS/Subrecipient portion of rent that is abated for HQS noncompliance. The participant will be sent a Notification of Pending Termination, based on violation of participant obligations. 1.18 Termination of Contract/Tenancy If a unit fails an annual, complaint, or special inspection, and the fail items are not corrected within the time frame specified, the Subrecipient will send the owner and the participant a notice that the HAP contract will be terminated for failure to maintain HQS, and give the effective date of the termination. If the failed items are the owner’s responsibility, the effective date of termination will be sufficient to give the participant at least a 30-day notice to move to a different unit, coinciding with the end of the month. If the unit passes a re-inspection during the abatement period, payment will resume on the day the unit passes inspection. No retroactive payments will be made to the owner for the period of time the HAP was abated. Termination of contract or tenancy is not the same as termination from the program. If the unit does not meet Housing Quality Standards, the Subrecipient and/or program participant must find a new unit that meets the HQS requirement to relocate. 1.18 HQS for Reasonable Modifications Modifications or adaptations to a unit provided as an accommodation for a household member with a disability must meet all applicable Housing Quality Standards. Extension for repair items not required by HQS will be granted for modifications/adaptations to the unit if agreed to by the tenant and owner. DPSS will allow execution of the HAP contract if the unit meets all requirements and the modifications do not affect the livability of the unit. 1.19 Recordkeeping and Documentation Requirement - § 578.103

1. HQS §578.75(b) - Subrecipient must retain documentation of compliance with the housing standards in including inspection reports. The completed HUD 52580 Inspection Checklist must be in participant’s file (Initial/Move-In and Annual HQS).

2. Lease Agreement §578.51 (l) (1) - for project-based, sponsor-based, or tenant-based

rental assistance, program participants must initially enter into a lease agreement for a term of at least one year, which is terminable for cause. The leases must be automatically renewable upon expiration for terms that are a minimum of one month long, except on prior notice by either party.



3. Rent Reasonableness §578.51 (g) - HUD will only provide rental assistance for a unit if

the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units. A copy of Initial/Move-In HQS, Lease Agreement and Rent Reasonableness must submit to DPSS Fiscal for every new program participant and prior to submitting the first claim.

4. Certificate of Tenant Roll – is to keep an inventory on client units and to track client’s move-in and out of housing unit. It includes the head of household name, address, unit number, move in and/or move out date. The Tenant Roll is due to DPSS by the 10th business day of the month.


Continuum of Care Monitoring

Monitoring Overview “Under 2 CFR Part 200, grantee monitoring of subrecipient activities is required to ensure that (1) subawards are used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward, and (2) subaward performance goals are achieved. When no monitoring or insufficient monitoring occurs, the grantee may risk losing HUD funding. Regulations at 2 CFR Part 200 require grantees to establish and maintain effective internal controls for themselves and ensure that their subrecipients do the same. One way a grantee can develop internal controls is by designing an effective monitoring process.” (Office of Inspector General, U.S. Department of Housing and Urban Development Integrity Bulletin, Summer 2016). The purpose of monitoring is to assess project operations against the standards set by HUD rules and regulations, including:

• Determining and Documenting Participant Eligibility • Tracking Eligible Activities and Expenses • Tracking Match Requirements • Record Keeping and Financial Management • Organizational and Administrative Capacity • Identify technical assistance needs and provide pro-active support • Measuring Project Progress • Evaluating Project Performance

There will be two teams conducting monitoring on each project. The first (CoC Representatives) will review and evaluate performance. The second team (DPSS) will review program, fiscal and HMIS compliance. Project Performance Monitoring by the CoC The HEARTH Act Interim Rule, 25 CFR Part 578 has delineated certain operational requirements of each Continuum to help measure a Continuum’s overall performance at reducing homelessness, in addition to tracking of performance on a project-by-project basis. Under § 578.7 Responsibilities of the Continuum of Care (a) Operate the Continuum of Care, the Continuum of Care must: (6) Consult with recipients and subrecipients to establish performance targets appropriate for population and program type, monitor recipient and subrecipient performance, evaluate outcomes, and take action against poor performers.

The Continuum of Care Monitoring Team will review and evaluate performance including but not limited to:

• Participation in Coordinated Entry System • Implementation of Housing First Approach • Chronic Homeless Prioritization • Target Population: to ensure the project is serving its target population. • Performance Measures/Milestones: to ensure that that the project is achieving its

target/goals. • Occupancy Rate/Bed Utilization: to ensure that beds are fully occupied under the terms

of the contract. • Length of Time Homeless • Return to Homelessness • Job and Income Growth • Successful Placement and Retention • Stabilization through Supportive Services and Mainstream Benefits.

Program Compliance Monitoring by DPSS As a HUD grantee, DPSS has the “contractual responsibility for ensuring that the project described in the application and Technical Submission is successfully carried out”, and compliant with federal statutes, HUD rules and regulations, including ensuring funds are being used for eligible activities under CoC requirements. The DPSS Monitoring Team will review and evaluate the implementation of project components including but not limited to:

1. Program • Program Eligibility: to ensure that participant eligibility has been adequately

documented in terms of their homelessness upon entry to the program. • Income Verification: to ensure residents meet income requirements. • Homeless documentation: to ensure that clients meet the HUD definition of

homelessness as described in the HEARTH Act. • Intake and Assessment Procedure: to ensure that there is a process in place for

assessing clients and that all required supporting data/documents are collected. • Occupancy Rate/Bed Utilization: to ensure that beds are fully occupied under the terms

of the contract. • Rent Calculations: – to ensure accuracy of the rent being charged to the clients. • Lease Agreements: - To ensure lease agreements meet regulation requirements.

• Educational Assurances - to ensure that there are policies and procedures in place to ensure all children are enrolled in early childhood education programs or in school and connected to appropriate services within the community

• Supportive Services: all other services provided to ensure that clients maintain housing and increase income.

• Housing Quality Standards – to ensure all units paid with CoC Program funding meet the HUD’s HQS requirements.

• Termination of Services/Client Exit Survey: to ensure that feedback is collected when clients exit the program.

• Completion of the Annual Performance Report (APR).

2. HMIS • Compliance with HMIS Policies and Procedures

Data Quality (accuracy, completeness and timeliness) HMIS Participating Agency Agreement Mandatory Posting Requirements (Privacy Notice, Mandatory Collection Notice) User Agreement Client Consent Form

• Technical Training

3. Fiscal • Timely Expenditure of Funds • Monthly Submission of Claims • Proper Documentation of Expenses • Documentation of Match • Unresolved Fiscal Issues

Monitoring Process The monitoring consists of on-site review or off-site (or remote) review of participants’ records/files and HMIS reports. On-site reviews are conducted at the grant recipients' office and may include visits to housing sites. HPU will contact subrecipients to schedule the monitoring visit approximately by the 6-month mark from the grant start date, with an arranged date HPU will provide written notice and details of the monitoring visit at least 30 days in advance.

1. On-site Monitoring Visit - an entry and exit meeting will take place. During the entry meeting, the purpose of the monitoring will be explained and the subrecipient will provide an overview of their project. During the exit interview, the Monitoring Team

(MT) will provide verbal observations, recommendations and corrective actions (if necessary).

2. File/Document Review – the MT will complete the monitoring tool from the review of client files and required documents. MT is encourage to ask questions and not have the review become a mechanical series of checkoffs. One way to avoid this problem is to build into the checklist an area to take notes, attach copies (or photos) of what was examined, and document the resulting analysis.

3. Documentation - is key to a monitoring review, demonstrating whether adequate subrecipient oversight is provided. While on site, keep notes about the items reviewed, activities physically inspected, and items unsupported by receipts or ineligible expenditures. Make copies of documentation that supports the review and any findings. Organize the files for easy retrieval. (Reference U.S. Government Accountability Office (GAO) Green Book, OV4.08, for additional guidance.)

4. Monitoring Report - upon completion of the review, DPSS will provide written report to the subrecipient (2 CFR 200.328(d)) within 30 days. The report will summarize the review, document performance, and identify concerns and/or finding. The subrecipient will have 30 days to provide a corrective action plan on how the concerns and/or findings will be addressed.

Duties and Responsibilities of CoC Volunteer CoC members interested in becoming a monitoring representative must:

• Complete the CoC Monitoring Training • Commit to time to conducting the monitoring per the schedule between 4-8 hours

once a month for 6 months. • Not have a conflict of interest

SUBRECIPIENT:

GRANT #:

PROJECT NAME:

PREPARER:

1

2

3

4

5

6

7

8

9

10

11

12

13

14

Agency/Subrecipient

Does the Agency allow family members to retain appropriate assistance

after the death, incarceration or institutionalization for more than 90 days

of the qualifying household member?

Does the Agency document their compliance with the faith-based activities

requirements under § 578.87(b)?

Does the Agency offer religious activities separately, in time or location,

from the CoC Program and services?Does the Agency ensure that participation in religious activities is voluntary

for CoC program participants?

Does the Agency discriminate against a prospective or active program

participant on the basis of religion or religious belief?

General OperationsYES NO NA Comments

24 CFR § 578.75 Sub-Part F Program Requirements

NO N/A Comments

Is there an agency written standards and procedures for assessment,

eligibility, outreach, intake, prioritizing individuals, and reassessing

participants?

Are all records regarding the program participant centrally located and

secure? (24 CFR 578.103(b) & (c))

24 CFR Subpart B § 578.7

YES

Was the most recent APR submitted to DPSS in a timely manner?

Agency Program Review

HUD - CoC Program Requirements - Monitoring Tool

DATE:

GRANT PERIOD:

PROJECT TYPE:

CommentsN/ANO24 CFR § 578.33 (f)

YES

Agency Reporting Requirements

Is there a written termination policy and does it provide for a formal

process that recognizes the due process rights of individuals receiving

assistance?

Is there a policy in place to ensure that families with children under the age

of 18 are not denied admission or separated when entering housing?

NOFA Application

Are the project policies and practices consistent with the laws related to

providing education services to individuals and families?

Does the project have a designated staff person to ensure that the children

are enrolled in school and receive educational services, as appropriate? 24

CFR part § 578.23 (c)(iv)

Period of record retention: Are the records pertaining to the program

participant's qualification for the CoC Program being retained for 5 years

after the expenditure of all funds from the grant under which the program

participant was served? (24 CFR 578.103(c)(1))

Does the agency have a written policy identifying the involvement of

homeless/ formerly homeless individuals on the board of directors or other

equivalent policy making entity? (24 CFR 578.75 (g)(1)-(2))

Program Review - 1

SUB-RECIPIENT:

GRANT #:

PROJECT NAME:

PARTICIPANT'S NAME: CLIENT ID#:

PREPARER:

1

2

3

4

5

6

8Persons coming from an

emergency shelter?

10Persons fleeing domestic

Violence. 578.103 (5)(i)

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a. Written information obtained from third party

regarding the participant’s whereabouts, signed and

dated.

Written referral from the emergency shelter staff.

Participant File

Is the length and duration

of homelessness

documented to qualify a

participant as chronically

homeless?

2. Homeless at least four separate occasions in the

last 3 years where the combined length of time

homeless is at least 12 months? (effective Jan. 15, 2016.

Participants prior to this date do not need to meet this

definition)

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Does the program participant file contain proof of disability of the homeless

individuals or family members? (24 CFR 578.37 (a)(1)(i))

CommentsYES NO N/A

YES NO N/A

HUD - CoC Program Compliance - Monitoring Tool

Evaluation of program participant eligibility

Is there a completed intake form for the client? Specify the type of (e.g., HMIS

intake form, agency intake form, participant application, etc.).

Is there a copy of ID (State issued ID, Driver's License)? (optional)

Is the program participant coming from the target populations (e.g., chronically

homeless, youth, substance abuse, mentally disabled, domestic violence, veterans)

identified and approved in the application?

DATE:

GRANT PERIOD:

PROJECT TYPE:

24 CFR § 578.103 & 578.37(a)(1)(ii)(F)Comments

24 CFR § 576.500(c) & § 578.103

Type of DocumentsHomeless Status

a. Written verification from the institution’s staff that

the participant has been residing in the institution for

less than 90 days.

Written, signed, and dated verification from the

participant.

Was the program participant referred by CES?

Is there evidence of the CES referral?

Does the program participant's intake form or assessment document that the

individuals or families were homeless prior to entry?

b. Outreach/Case Manager written verification.

c. Self-Declaration of Homelessness.

Persons living on the street

(and place meant for

human habitation).

Required for PH

participants.

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Persons from a short-term

stay in an institution who

previously resided on the

street or in an emergency

shelter.

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b. Information on living situation prior to the

institution stay.

1. Homeless for one year?

Program Review - 2

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

Is the verification of disability a Social Security

Administration statement or bank deposit?

Is the disability documentation signed and dated by a

person credentialed to make a diagnosis?13

CommentsN/ANOYES

CommentsYES NO N/A

YES

Did participant received a written notification regarding program exit?

CommentsN/AIncome Documentation & Rent Calculation

NO

Is there evidence of at least annual assessment of service needs to ensure

mainstream benefits are received and renewed? (24 CFR 578.53(a)(2)) &578.75€

Is transportation assistance provided to clients to attend mainstream benefit

appointments, employment training, or jobs?

Is there an initial Individual Service Plan (ISP) developed by the participant and

Case Manager that includes goals and timeline for completion?

Are the supportive services being provided (type and level of service) consistent

with those described in the approved application? List the supportive services

provided.

Is there evidence of referrals to mainstream resources? (24 CFR 578.1(b)(3))

24 CFR § 578.103 (a)(6))

Documentation of Termination YES NO24 CFR § 578.91 (a)(b)(c))

Was an exit survey or interview conducted with participant?

CommentsN/ANOYES

N/A Comments

Participant Disability

Has the participant been terminated from the program? Describe the reason for

termination

Was due process applied on the participant's termination?

If the participant left the program, is there evidence of his/her request and

destination?

Did the participant go to permanent housing at exit?

Is the rent charged accurately calculated, including deductions and utility

allowances, if applicable? (24 CFR 578.77(b)(4))

Is there a completed verification on all sources of income? (24 CFR 578.75 (c)(3))

Is there evidence of referrals to Affordable Healthcare?

24 CRF §578.53, §578.103(a)(7) & (9) & §578.75(e))

Supportive Services & Case Management

If a lead-based paint inspection was required, was it completed? (Required:

Households with a pregnant or 6 years of age or under member)

Is there a completed HQS annual inspection?

Is there a completed HQS move-in inspection?

24 CFR § 578.103 (a)(8) & § 578.73

Housing Quality Standards & Lease Agreement

Is there evidence of monthly case management?

24 CFR § 578.103 (a)

Rapid Rehousing Only

Do program participants have an initial lease or occupancy agreement with a term

of at least 12 months? (24 CFR 78.51(L)(2))

SUBRECIPIENT:

GRANT #:

PROJECT NAME:

PREPARER:

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

HUD-CoC Program Performance - Monitoring Tool

DATE:

GRANT PERIOD:

PROJECT TYPE:

No N/A Comments

Does the project follow a "Housing First" approach?

AGENCY REVIEWYes

What percentage project stayers had new or increased

earned income?

Does the project prioritize beds for use by the

chronically homeless when beds become available?

What percentage of project stayers had new or

increased non-employment income?What percentage of project leavers new or increased

earned income?

What percentage of project leavers new or increased

non-employment income?

How many participants are currently being served in the

project?

How many participants have been referred to

mainstream benefits?

24 CFR § 578.103(c)

On average, how many days participants spend from

project entry to residential move-in?

What percentage of participants moved to permanent

housing ?

What percentage of participants move to permanent

housing without subsidy?

What percentage of participants returned to

homelessness within 12 months of exit to permanent

housing?

Is the number of participants currently being served

consistent with the service number in the approved

application? The subrecipient must serve at least as

many program participants as shown in its

application for assistance (24 CFR 578.51(h)(3)).

Are beds fully occupied? If no, what is the bed utilization

rate? If not at capacity, what actions are being taken to

improve this outcome?

Are units fully occupied? If no, what is the unit

utilization rate? If not at capacity, what actions are

being taken to improve this outcome?

Does this project participate in the CoC Coordinated

Entry System?

County of Riverside Continuum of Care

WRITTEN STANDARDS

APPROVED: AUGUST 23, 2017

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Table of Contents

1. Introduction ...............................................................................................................3 2. CoC and ESG Coordination .........................................................................................4 3. Housing First Model ...................................................................................................4 4. Coordinated Entry System .........................................................................................4 5. Homeless Management Information System (HMIS) ................................................5 6. Gender Identity Equal Access Policy ..........................................................................5 7. Permanent Supportive Housing (PSH) .......................................................................6

a. Chronically homeless definition .....................................................................7 b. Eligible Clients ................................................................................................7 c. PSH Performance Benchmarks ......................................................................7 d. Prioritizing Chronically Homeless ..................................................................8

8. Rapid Rehousing (RRH) ..............................................................................................17 a. Eligible Clients ................................................................................................17 b. RRH Performance Benchmarks ......................................................................18 c. Prioritizing Rapid Rehousing ..........................................................................18

9. Transitional Housing (TH)...........................................................................................23 a. Eligible Clients ................................................................................................24 b. TH Performance Benchmarks ........................................................................24 c. Prioritizing Transitional Housing ....................................................................25

10. Emergency Shelter (ES) ..............................................................................................26 a. Eligible Clients ................................................................................................26 b. Prioritizing Transitional Housing ....................................................................26

11. Street Outreach (SO) ..................................................................................................27 12. Homelessness Prevention (HP) ..................................................................................30

a. Eligible Clients ................................................................................................30 b. HP Performance Benchmarks ........................................................................31

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Riverside Continuum of Care (CoC) Written Standards for Providing Continuum of Care Assistance

The Riverside County CoC is responsible coordinating and implementing a system-wide approach to meet the needs of the population and subpopulation experiencing homelessness within the geographic area of Riverside County. Both the Emergency Solution Grant Rules and Regulations (ESG) and the Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Continuum of Care Program Interim Rules state that the CoC, in consultation with recipients of ESG program funds within the geographic area,

(1) Establish and consistently follow written standards for providing CoC assistance. (2) Establish performance targets appropriate for population and program type. (3) Monitor recipient and sub-recipient performance.

In accordance with Title 24 of the Code of Federal Regulations (24 CFR) Part 578, the Riverside County CoC has developed the following written standards. In conjunction with 24 CFR Part 578, these standards will apply to all projects that receive HUD and ESG funding. The goal of these standards is to synthesize key elements of the HUD regulations with the processes and priorities of the Riverside County CoC to ensure that the CoC programs are administered fairly and methodically. The goals of the written standards are to:

Assist with the coordination of service delivery across the geographic area and will be the foundation of the county-wide coordinated entry system.

Assist in assessing individuals and families consistently to determine program eligibility.

Assist in administering programs fairly and methodically. Establish common performance measurements for all CoC components. Provide the basis for the monitoring of all CoC and ESG funded projects.

These written standards include policies and procedures for evaluating individuals’ and families’ eligibility for assistance for

1. Permanent Supportive Housing (PSH) 2. Rapid Re-Housing (RRH) 3. Transitional Housing (TH) 4. Emergency Shelter (ES) 5. Street Outreach (SO) 6. Homelessness Prevention (HP)

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All programs that receive ESG or CoC funding are required to abide by these written standards. The CoC strongly encourages programs that do not receive either of these sources of funds to accept and utilize these standards.

CoC and ESG Coordination These written standards have been developed in conjunction with ESG recipients (Riverside County Economic Development Agency (EDA), City of Riverside, and the City of Moreno Valley), the CoC Collaborative Applicant and with service providers to allow for input on standards, performance measures and the process for full implementation of the standards throughout the CoC from the prospective of those organization that are directly providing homeless and housing services, Permanent Supportive Housing (PSH), Rapid Re-Housing (RRH), Emergency Shelter (ES), and Transitional Housing (TH). The CoC Written Standards have been approved by the CoC, the County and City ESG recipients. These written standards will be reviewed and revised at least annually. Revisions that would affect the Coordinated Entry process would be made as soon as possible. The Riverside County CoC will continue to build upon and refine this document.

Housing First Model Irrespective of the program type, all HUD and ESG funded programs are required to utilize a housing first approach to housing assistance. The housing first approach incorporates a model of housing assistance that prioritizes rapid placement and stabilization in permanent housing that does not have service participation requirements or preconditions (such as sobriety or a minimum income threshold). Emergency Shelter, Transitional housing and supportive service only projects may be considered to be using a housing first model if they operate with low-barriers, work to quickly move people into permanent housing, do not require participation in supportive services, and, for transitional housing projects, do not require any preconditions for moving into the transitional housing (2015 HUD CoC NOFA).

Coordinated Entry System To minimize barriers to housing access and ensure timely placement, all CoC and ESG subrecipients are required to participate in and receive referrals through Riverside County’s Coordinated Entry System (CES). The CES uses a no-wrong door approach in which homeless individuals who engage with any agency within the Riverside County CoC are entered into the system. This system ensures that every homeless individual is known by name, provides assistance based on individual’s unique needs, and ensure that housing matches are the

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right fit. See Appendix B, Riverside County CoC Coordinated Entry System (CES) Policies & Procedures.

Universal Assessment All individuals will be assessed using a comprehensive, universal assessment tool called the Vulnerability Index Service Prioritization Decision Assistance Tool (VI-SPDAT) which is useful for initial triage and entry assessment. This tool guarantees that individuals’ levels of need and eligibility determinations are made in an informed and objective manner.

Homeless Management Information System All subrecipients are required to participate in the Homeless Management Information System (HMIS) per the ESG and CoC Interim Rule (24 CFR 576 and 578). HMIS provides an opportunity to document homelessness and helps to ensure coordination between service providers while avoiding duplication of services and client data.

Equal Access in Accordance with an Individual’s Gender Identity in Community Planning and Development Funded Programs The Riverside County Continuum of Care non-discriminatory policy, regarding the U.S. Department of Housing and Urban Development (HUD) final rule regarding equal access to Community Planning and Development (CPD) funded programs regardless of sexual orientation, gender identity, and marital status, will ensure that individuals are aware of their rights to equal access to CPD funded programs. Thus, all CPD funded programs, including Continuum of Care and Emergency Solutions Grant funded programs, must comply with the following requirements:

Determine client eligibility for housing regardless of sexual orientation, gender identity, or marital status, and must not discriminate against clients who do not conform to gender or sex stereotypes (i.e., because of gender identity);

Grant equal access to CPD funded programs or facilities consistent with client gender identity, and provide client’s family with equal access;

MUST NOT ask clients to provide anatomical information or documentation (i.e. ID), physical, or medical evidence of gender identity; and

Take non-discriminatory steps when necessary and appropriate to address privacy concerns raised by any residents or occupants.

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These requirements are identical to those provided by HUD in a notice for continuums of care to adopt: see https://www.hudexchange.info/resources/documents/Notice-on-Equal-Access-Rights.pdf. In accordance with the guidance provided by HUD in 24 CFR 5 in the Federal Register, vol. 81, No. 183, all CPD funded programs will

“post on bulletin boards and in other public spaces where information is typically made available a notice entitled ‘‘Equal Access Regardless of Sexual Orientation, Gender Identity, or Marital Status for HUD’s Community Planning and Development Programs.”

The post will include the requirements noted above. In addition, all CPD funded programs will adhere to the requirements concerning record keeping in 24 CFR 5, which states that

“providers must document and maintain, for a period of 5 years, records of compliance with the requirements of this rule regarding establishing or amending policies and procedures.”

Written Standards for Permanent Supportive Housing (PSH) The Riverside County CoC-PSH program provides permanent housing and supportive services to individuals and families with a disability, prioritizing those who are chronically homeless. The program is designed to reintegrate this highly vulnerable population into the community by addressing their basic needs for housing and providing ongoing support. There are two key components of the Riverside County CoC-PSH program: permanent housing and supportive services.

Using a housing first approach, program participants are provided with rapid access to permanent housing with minimal preconditions. Good credit or rental history are not required to receive housing. Tenants can remain in their homes as long as the basic requirements of tenancy are met—paying the rent (as applicable), not interfering with other tenants’ use of their homes, not causing property damage, etc. This ensures participants have a private and secure place to make their home, just like other members of the community, and provides them with a stable foundation from which they can pursue their goals.

https://www.hudexchange.info/resources/documents/Notice-on-Equal-Access-Rights.pdf

https://www.hudexchange.info/resources/documents/Notice-on-Equal-Access-Rights.pdf

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Chronically Homeless Definition

A chronically homeless individual or head of household as defined in 24 CFR 578.3 for whom both of the following are true:

i. The chronically homeless individual or head of household of a family has been homeless and living in a place not meant for human habitation, a safe haven, or in an emergency shelter for at least 12 months either continuously or on at least four separate occasions in the last 3 years, where the cumulative total length of the four occasions equals at least 12 months; Each period separating the occasions must include at least 7 nights of living in a situation other than a place not meant for human habitation, in an emergency shelter, or in a safe haven.

ii. If the individual has been living in the facility for fewer than 90 days and had been living in a place not meant for human habitation, a safe haven, or in an emergency shelter immediately before entering the institutional care facility.

Eligible Clients Eligible clients must also meet eligibility criteria as defined in the NOFA under which the program was funded. For dedicated permanent supportive housing beds, when a participant exits the program, the bed must be filled by another chronically homeless participant unless there are no chronically homeless persons located within the CoC’s geographic area. This concept only applies to permanent supportive housing projects. (24 CFR 578.3, 2015 HUD CoC NOFA). For permanent supportive housing beds within a CoC’s geographic area that are not currently dedicated specifically for use by the chronically homeless, CoCs and projects are strongly encouraged to prioritize the chronically homeless in non-dedicated permanent supportive housing beds as they become available through turnover. This concept only pertains to permanent supportive housing projects (24 CFR 578.3, 2015 HUD CoC NOFA).

PSH Performance Benchmarks

All PSH providers should meet or exceed project quality goals established by HUD and CoC guidelines which include the following:

At least 80 percent of project participants either remained in permanent housing or exited to permanent housing;

At least 20 percent or more of project participants have employment income (or other sources such as SSI and/or SSDI, for those who are not employable);

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At least 54 percent of project participants increased their income from sources other than employment in a given operating year;

At least 56 percent of project participants obtained mainstream benefits; and

100 percent of the project participants came from the street or other locations not meant for human habitation, emergency shelters, or safe havens.

In addition, PSH providers must:

Implement a housing first approach.

Fill vacant beds with only chronically homeless persons.

Prioritizing Chronically Homeless PSH is not a one-size-fits-all approach and should only be offered to those households that truly need that level of support. Thus, in order to use our limited resources in the most effective means possible, the Riverside County CoC is committed to prioritizing those most in need through an established order of priority. Within that order of priority, all CoC-PSH funded programs are required ensure compliance with the “chronically homeless” definition and to fill vacant beds with chronically homeless individuals (CPD-16-011 (7/25/16)). The Riverside County CoC has developed an order of priority to establish a uniform process for prioritizing placement into PSH through the CES. The overarching intent of this order of priority is to ensure that chronically homeless persons with the longest lengths of time homeless and the most severe service needs are prioritized for housing.

1) First Priority–Homeless Individuals and Families with a Disability with Long Periods of Episodic Homelessness and Severe Service Needs

2) Second Priority–Homeless Individuals and Families with a Disability with Severe Service Needs.

3) Third Priority—Homeless Individuals and Families with a Disability Coming from

Places Not Meant for Human Habitation, Safe Haven, or Emergency Shelter Without Severe Service Needs.

4) Fourth Priority–Homeless Individuals and Families with a Disability Coming from Transitional Housing.

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CoC Records In addition to the records required in 24 CFR 578.103, Riverside County CoC documents and maintains the following documentation:

1. Evidence of written standards that incorporate the priorities in Section III. of this Notice, as adopted by the CoC;

2. Evidence of a standardized assessment tool; The use of a standardized assessment tool may be evidenced by written policies and procedures referencing a single standardized assessment tool that is used by all CoC Program-funded PSH recipients within the geographic area.

3. Evidence that the written standards were incorporated into the coordinated assessment policies and procedures.

Recipient Recordkeeping Requirements In addition to the records required in 24 CFR 578.103, recipients of Riverside County CoC Program-funded PSH that is required by grant agreement to document chronically homeless status of program participants in some or all of its PSH beds must maintain the following records:

1. Written Intake Procedures 2. Evidence of Chronically Homeless Status

Leasing Requirements Leasing projects involve the leasing of property or portions of property (including single units) not owned by the recipient for use in providing PSH or supportive services. With leasing projects, the lease is between the subrecipient and the landowner while the occupancy agreement or sublease is between the subrecipient and program participant. Leasing funds may be used to pay up to 100% of the costs of leasing a structure. When electricity, gas, and water are included in the rent, these utilities may be paid from leasing funds. If the landlord does not provide utilities, these utility costs are an operating cost, except for supportive service facilities. Leasing funds cannot be used to lease units or structures owned by the recipient, sub-recipient, or their parent, subsidiary, or affiliated organization. HUD has the authority, however, to grant an exception to the ownership clause for good cause.

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PSH Written Standards #1 – No Designated Length of Stay Program participants are provided housing without a designated length of stay that permits them to live as independently as possible. Consistent with the definition of permanent housing in section 401 of the McKinney-Vento Act and § 578.3 of this interim rule, the permanent housing component is community-based housing without a designated length of stay that permits formerly homeless individuals and families to live as independently as possible. The interim rule clarifies that Continuum of Care funds may be spent on two types of permanent housing: permanent supportive housing for persons with disabilities (PSH) and rapid rehousing that provides temporary assistance (i.e., rental assistance and/or supportive services) to program participants in a unit that the program participant retains after the assistance ends.

Leasing and Occupancy Agreements A key component in CoC leasing and rental assistance is leasing and occupancy agreements. All participants must have a signed agreement outlining the terms of their housing. Two individuals in a shared housing situation must have their own lease and their own bedroom unless the two individuals are presented together as a household.

PSH Written Standards #2 – Lease Agreement The program participant must be the tenant on a lease for a term of at least one year that is renewable and is terminable only for cause. The lease must be renewable for terms that are a minimum of one month long. HUD clarifies that to be permanent housing, “the program participant must be the tenant on a lease for a term of at least one year that is renewable and is terminable only for cause. The lease must be renewable for terms that are a minimum of one month long.” HUD has determined that requiring a lease for a term of at least one year that is renewable and terminable only for cause, assists program participants in obtaining stability in housing, even when the rental assistance is temporary (CFR 578.77).

Rental Assistance & Restrictions Rental assistance grants are differentiated from leasing grants in that these grants provide rental assistance to eligible persons for permanent housing. For rental assistance grants, the lease is between the program participant and the landowner or sub lessor. Grant funds may

11

be used for permanent supportive housing rental assistance. Rental assistance cannot be provided to a program participant who is already receiving rental assistance, or living in a housing unit receiving rental assistance or operating assistance through other federal, State, or local sources.

PSH Written Standards #3 – Restricted Assistance and Disabilities Permanent supportive housing can only provide assistance to individuals with disabilities and families in which one adult or child has a disability.

Supportive Services Once in housing, program participants have access to the support services that they need and want to live as independently as possible. Although PSH is designed for people who need supportive services, accepting these services is not a condition of housing. A person’s home is a place to live rather than a treatment setting. As such, supportive services are voluntary, but can and should be used to persistently engage tenants and ensure housing stability. Tenants receive assistance in defining their needs and preferences through annual assessments of service needs and individualized support plans that reflect those preferences. On-site residential supervision is provided as needed to facilitate the adequate provision of supportive services to the residents (CFR 578.37).

PSH Written Standards #4 – Supportive Services Supportive services designed to meet the needs of program participants must be made available to the program participants.

PSH Written Standards #5 – Duration of Supportive Services Assistance Supportive services to enable program participants to live as independently as possible must be provided throughout the duration of their residence. Recipients and subrecipients may require the program participants to take part in supportive services that are not disability-related services provided through the project as a condition of continued participation in the program. Examples of disability-related services include, but are not limited to, mental health services, outpatient health services, and provision of medication, which are provided to a person with a disability to address a condition caused by the disability. Notwithstanding this provision, if the purpose of the project is to provide

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substance abuse treatment services, recipients and subrecipients may require program participants to take part in such services as a condition of continued participation in the program (CFR 578.75). Supportive services are voluntary, but can and should be used to persistently engage tenants to ensure housing stability - Supportive services are proactively offered to help tenants achieve and maintain housing stability, but tenants are not required to participate in services as a condition of tenancy. Techniques such as harm reduction and motivational interviewing may be useful. Harm reduction techniques can confront and mitigate the harms of drug and alcohol use through non-judgmental communication while motivational interviewing may be useful in helping households acquire and utilize new skills and information.

PSH Written Standards #6 – Supportive Services Agreement Program participants may be required to take part in supportive services that are not disability-related services (including substance abuse treatment services) provided through the project as a condition of continued participation in the program. However, HUD tends to believe that these kind of requirements can be barriers and should be rare and minimal if used as all.

Housing Quality Standards (HQS) Under the CoC Program, all housing that is leased with Continuum of Care program funds, or for which rental assistance payments are made with Continuum of Care program funds, must meet the applicable Housing Quality Standards (HQS) under 24 CFR 982.401 of this title, except that 24 CFR 982.401(j) applies only to housing occupied by program participants receiving tenant-based rental assistance.

HQS dictates that, at a minimum, the unit must have a living room, a kitchen, and a bathroom. HQS requirements also dictates that the bathroom must be contained within the unit, afford privacy (usually meaning a door, although no lock is required), and be for the exclusive use of the occupants. Additionally, the unit must have suitable space and equipment to store, prepare, and serve food in a sanitary manner. This includes a requirement for an oven and stove or range, a refrigerator of appropriate size for the family, and a kitchen sink with hot and cold running water. Hot plates are not acceptable substitutes for stoves or ranges. However, a microwave oven may be used in place of a conventional oven, stove, or range if the oven/stove/range are tenant supplied or if microwaves are furnished in both subsidized and unsubsidized units in the building or premises.

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The CoC Program also allows for shared housing/roommate situations in projects with leasing or rental assistance funds. Each household must have the bedroom size that fits their household size. In other words, 2 individuals in a shared housing situation must have their own lease, and their own bedroom. The only situation where 2 people would be sharing one bedroom would be if they presented together as a household.

PSH Written Standards #7 – One Person per Bedroom Two individuals in a shared housing situation must have their own lease and their own bedroom unless the two individuals are presented together as a household.

Program Income Program income includes the following (CFR 578.97):

(a) Defined. Program income is the income received by the recipient or subrecipient directly generated by a grant-supported activity.

(b) Use. Program income earned during the grant term shall be retained by the recipient, and added to funds committed to the project by HUD and the recipient, used for eligible activities in accordance with the requirements of this part. Costs incident to the generation of program income may be deducted from gross income to calculate program income, provided that the costs have not been charged to grant funds.

(c) Rent and occupancy charges. Rents and occupancy charges collected from program participants are program income. In addition, rents and occupancy charges collected from residents of transitional housing may be reserved, in whole or in part, to assist the residents from whom they are collected to move to permanent housing.

PSH Written Standards #8 – Program Income Program income generated from rent and occupancy charges may be collected from program participants and added to funds committed to the project by HUD and used for eligible program activities.

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Calculating Occupancy Charges and Rent Calculating occupancy charges and rent (b) (1) (2) (3) notes the following about occupancy agreements (CFR 578.77):

(b) Calculation of occupancy charges. Recipients and subrecipients are not required to impose occupancy charges on program participants as a condition of residing in the housing. However, if occupancy charges are imposed, they may not exceed the highest of: (1) 30 percent of the family’s monthly adjusted income (adjustment factors include the number of people in the family, age of family members, medical expenses, and child-care expenses);

(2) 10 percent of the family’s monthly income; or

(3) If the family is receiving payments for welfare assistance from a public agency and a part of the payments (adjusted in accordance with the family’s actual housing costs) is specifically designated by the agency to meet the family’s housing costs, the portion of the payments that is designated for housing costs.

PSH Written Standards #9 – Calculating Occupancy Charges and Rent

If occupancy charges are imposed, they may not exceed the highest of: 1) 30 percent of the family’s monthly adjusted income (adjustment factors include the number of people in the family, age of family members, medical expenses, and child-care expenses); 2) 10 percent of the family’s monthly income; or 3) If the family is receiving payments for welfare assistance from a public agency and a part of the payments (adjusted in accordance with the family’s actual housing costs) is specifically designated by the agency to meet the family’s housing costs, the portion of the payments that is designated for housing costs.

Recipients or subrecipients must examine a program participant’s income initially, and at least annually thereafter, to determine the amount of the contribution toward rent payable by the program participant. Adjustments to a program participant’s contribution toward the rental payment must be made as changes in income are identified (CFR 578.77).

PSH Written Standards #10 – Examining Program Participant’s Initial Income A program participant’s initial income must be examined at least annually to determine the amount of the contribution toward rent payable by the program participant and adjustments to a program participant’s contribution toward the rental payment must be made as changes in income are identified.

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As a condition of participation in the program, each program participant must agree to supply the information or documentation necessary to verify the program participant’s income. Program participants must provide the recipient or subrecipient with information at any time regarding changes in income or other circumstances that may result in changes to a program participant’s contribution toward the rental payment (CFR 578.77).

Recordkeeping Requirements In order to use our limited resources in the most effective means possible, the Riverside County CoC has established uniform recordkeeping requirements for all PSH grant recipients. These requirements ensure compliance with HUD’s definition of homelessness, chronic homelessness, and the recordkeeping requirements set forth in CFR 578.103 and Notice CPD-16-011. The following documentation of annual income must be kept by recipient or subrecipient:

(i) Income evaluation form specified by HUD and completed by the recipient or subrecipient; and

(ii) Source documents (e.g., most recent wage statement, unemployment compensation statement, public benefits statement, bank statement) for the assets held by the program participant and income received before the date of the evaluation;

(iii) To the extent that source documents are unobtainable, a written statement by the relevant third party (e.g., employer, government benefits administrator) or the written certification by the recipient’s or subrecipient’s intake staff of the oral verification by the relevant third party of the income the program participant received over the most recent period; or

(iv) To the extent that source documents and third-party verification are unobtainable, the written certification by the program participant of the amount of income that the program participant is reasonably expected to receive over the 3-month period following the evaluation.

PSH Written Standards #11 – Verifying Program Participant’s Initial Income Each program participant must agree to supply the information or documentation necessary to verify the program participant’s income.

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Recalculating Occupancy Charges and Rent In order to use the resources of the Riverside County CoC in the most effective means possible, the Riverside County CoC has established uniform recordkeeping requirements for all PSH grant recipients. These requirements ensure compliance with HUD’s definition of homelessness, chronic homelessness, and the recordkeeping requirements set forth in 24 CFR 578.103 and Notice CPD-16-011. All records must be retained for the greater of 5 years. Income must be calculated in accordance with 24 CFR 5.609 and 24 CFR 5.611(a). Recipients and subrecipients must examine a program participant’s income initially, and if there is a change in family composition (e.g., birth of a child) or a decrease in the resident’s income during the year, the resident may request an interim reexamination, and the occupancy charge will be adjusted accordingly.”

PSH Written Standards #12 – Recalculating Occupancy Charges and Rent If there is a change in family composition (e.g., birth of a child) or a decrease in the resident’s income during the year, the resident may request an interim reexamination, and the occupancy charge will be adjusted accordingly.

Termination of Assistance PSH program recipients may terminate assistance to a participant who violates program requirements or conditions of occupancy utilizing a formal process that recognizes the due process of law. Recipients may resume assistance to a participant whose assistance has been terminated.

Recipients that are providing permanent supportive housing for hard-to-house populations of homeless persons must exercise judgment and examine all circumstances in determining whether termination is appropriate in the most severe cases.

PSH Written Standards #13 – Termination of Assistance Assistance may be terminated to a program participant who violates program requirements or conditions of occupancy by providing a formal process that recognizes the due process of law.

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Determining Written Standards for Rapid Rehousing (RRH) Rapid rehousing is considered permanent housing. Rapid Re-housing is an intervention designed to move homeless individuals and families into permanent housing as quickly as possible. Rapid Re-housing programs focus on eliminating barriers to moving individuals and families quickly into permanent housing by providing housing location services and financial assistance for housing related expenses (e.g. rent arrears, ongoing rental assistance, moving costs). Rapid Re-housing services are designed with a housing first approach to get individuals and families in permanent housing and keep them stable once they are there. In Riverside County, Rapid Re-Housing is a critical strategy for ending homelessness for households with children due to the shortage of affordable housing. It is also a high priority for single adults who assess as self-sufficient and can address affordability through a combination of shared housing and increasing income.

Types of rapid rehousing assistance include:

Rental assistance; Case management; Supportive services; and Security deposits.

Eligible Clients Eligible clients must meet HUD’s Category 1 definition of homelessness which is: Individuals and families who lack a fixed, regular, and adequate nighttime residence:

An individual or family with a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings, including a car, park, abandoned building, bus or train station, etc.

An individual or family living in a supervised publicly or privately operated shelter designated to provide temporary living arrangements (including congregate shelters, transitional housing, and hotels and motels paid for by charitable organizations or by federal, state, or local government programs for low income individuals);

An individual who is exiting an institution where he or she resided for 90 days or less and who resided in an emergency shelter or place not meant for human habitation immediately before entering that institution; or

An individual fleeing or attempting to flee domestic violence if also literally homeless; Eligible clients must also meet eligibility criteria as defined in the NOFA under which the program was funded.

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RRH Performance Benchmarks

All RRH providers should meet or exceed project quality goals established by HUD and CoC guidelines which include the following:

At least 80 percent of project participants either remained in permanent housing or exited to permanent housing;


At least 54 percent of project participants increased their income from sources other than employment in a given operating year;

At least 56 percent of project participants obtained mainstream benefits; and

100 percent of the project participants came from the street or other locations not meant for human habitation, emergency shelters, or safe havens.

In addition, RRH providers must:


Prioritizing Rapid Rehousing Recently, HUD provided guidance for rapid rehousing in terms of prioritizing subpopulations. HUD noted in a SNAPS In Focus: Rapid Re-Housing As a Model and Best Practice, August 6, 2014, that Rapid re-housing can be effective for many populations, such as families with children, youth aging out of foster care, domestic violence survivors, single adults, and veterans, but should be targeted to those households that would not be able to get out of homelessness without the assistance. It is particularly a key strategy for achieving the Opening Doors goal of ending family, youth, and child homelessness by 2020 (SNAPS In Focus: Rapid Re-Housing As a Model and Best Practice, 8/6/14). Rapid re-housing should prioritize people with more challenges, including those with no income, poor employment prospects, troubled rental histories, and criminal records. Providers should link participants with community resources that will help them achieve longer-term stability and well-being. Now is the time for communities to be working together to establish written standards for administering rapid re-housing and thinking strategically about how this type of assistance will be used most effectively within the CoC (SNAPS In Focus: Rapid Re-Housing As a Model and Best Practice, 8/6/14).” Rapid re-housing is an effective intervention for many different types of households experiencing homelessness, including those with no income, with disabilities, and with poor

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rental history. The majority of households experiencing homelessness are good candidates for rapid re-housing. The only exceptions are households that can exit homelessness with little or no assistance, those who experience chronic homelessness and who need permanent supportive housing, and households who are seeking a therapeutic residential environment, including those recovering from addiction. The Riverside County CoC will prioritize the following subpopulations:

1) families with children 2) domestic violence survivors 3) single adults 4) veterans that can exit homelessness with little or no assistance, those who

experience chronic homelessness and who need permanent supportive housing, and households who are seeking a therapeutic residential environment, including those recovering from addiction.

Lease Requirements In compliance with HUD requirements, Riverside County CoC clarifies that to be permanent housing, the program participant must be the tenant on a lease for a term of at least one year that is renewable and is terminable only for cause. The lease must be renewable for terms that are a minimum of one month long. HUD has determined that requiring a lease for a term of at least one year that is renewable and terminable only for cause, assists program participants in obtaining stability in housing, even when the rental assistance is temporary.

RRH Written Standards #1 – Lease Agreement The program participant must be the tenant on a lease for a term of at least one year that is renewable and is terminable only for cause. The lease must be renewable for terms that are a minimum of one month long.

Rental Assistance The Riverside County CoC and ESG funds may provide supportive services and/or short-term (up to 3 months) and/or medium-term (for 3 to 24 months) tenant-based rental assistance, as necessary to help a homeless individual or family, with or without disabilities, move as quickly as possible into permanent housing and achieve stability in that housing (CFR 578.51, 578.53).

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RRH Written Standards #2 – Rental Assistance Program participants may receive short-term (up to 3 months) and/or medium-term (for 3 to 24 months) tenant-based rental assistance.

Riverside County CoC and ESG programs may set a maximum amount or percentage of rental assistance that a program participant may receive, a maximum number of months that a program participant may receive rental assistance, and/or a maximum number of times that a program participant may receive rental assistance. The recipient or subrecipient may also require program participants to share in the costs of rent. For the purposes of calculating rent for rapid rehousing, the rent shall equal the sum of the total monthly rent for the unit and, if the tenant pays separately for utilities, the monthly allowance for utilities (excluding telephone) established by the public housing authority for the area in which the housing is located (CFR 578.37).

RRH Written Standards #3 – Amount of Rental Assistance Standards for determining the share of rent and utilities costs that each program participant must pay, if any, will be based on the following guidelines:

The maximum amount of rent that a participant will pay can be up to 100% of the rental amount;

The maximum percentage of income paid by participants towards rent at program completion shall be no more than 50%. However, in certain circumstances, on a case-by-case basis, there may be participants whose rental share may exceed 50% of the rent based on their financial circumstances. In general, the goal will be that participants pay generally no more than 50% of their income in rent;

100% of the cost of rent in rental assistance may be provided to program participants. However to maximize the number of households that can be served with rapid re-housing resources, it is expected that the level of need will be based on the goal of providing only what is necessary for each household to be stably housed for the long term;

The rent charged for a unit must be reasonable in relation to rents currently being charged for comparable units in the private unassisted market and must not be in excess of rents currently being charged by the owner for comparable unassisted units.

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RRH Written Standards #4 – Duration of Assistance Program participants may receive up to 24 months of rental assistance. However, it is expected that program participants will only receive the level of assistance necessary to be stably housed for the long-term. Grant funds may be used for rental assistance for homeless individuals and families. Rental assistance cannot be provided to a program participant who is already receiving rental assistance, or living in a housing unit receiving rental assistance or operating assistance through other federal, State, or local sources (CFR 578.51).

RRH Written Standards #5 – Receiving Rental Assistance through Other Sources

Rental assistance cannot be provided to a program participant who is already receiving rental assistance, or living in a housing unit receiving rental assistance or operating assistance through other federal, State, or local sources.

Security Deposits Grant funds may be used for security deposits in an amount not to exceed 2 months of rent. An advance payment of the last month’s rent may be provided to the landlord, in addition to the security deposit and payment of first month’s rent (CFR 578.51).

RRH Written Standards #6 – Security Deposits including Last Month’s Rent Program participants may receive funds for security deposits in an amount not to exceed 2 months of rent.

Case Management

The Riverside County CoC has defined case management as a collaborative process that assesses, plans, implements, coordinates, monitors, and evaluates the options and services required to meet the client’s health and human service needs. It is characterized by advocacy, communication, and resource management and promotes quality and cost-effective interventions and outcomes. Case management focuses on housing stability and placement, with an emphasis on the arrangement, coordination, monitoring, and delivery of services related to housing needs and improving housing stability.

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A meeting with a case manager is required in order to receive RRH assistance, although it is not necessarily the first step. Some communities might have a screening, intake, assessment and eligibility determination process that precedes assignment to a case manager, while other communities will have case managers performing the eligibility task. Regardless of the arrangement, the meeting with the case manager should be regarded not only as a program requirement, but also as an early opportunity to help a household improve its housing stability during and beyond the period of RRH assistance.

RRH Written Standards #7 – Case Management Program participants must meet with a case manager not less than once per month to assist the program participant in ensuring long-term housing stability.

Supportive Services Continuum of Care funds may provide supportive services, as set forth in § CFR 578.53, and/or short-term (up to 3 months) and/or medium-term (for 3 to 24 months) tenant-based rental assistance, as set forth in § CFR 578.51(c), as necessary to help a homeless individual or family, with or without disabilities, move as quickly as possible into permanent housing and achieve stability in that housing.

RRH Written Standards #8 – Supportive Services Program participants may receive supportive services as set forth in § 578.53 (see Appendix B)

RRH Written Standards #9 – Duration of Supportive Services Program participants may receive supportive services for no longer than 6 months after rental assistance stops.

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Re-evaluating Participants In compliance with HUD requirements, CoC and ESG programs must re-evaluate, not less than once annually, that the program participant lacks sufficient resources and support networks necessary to retain housing without Continuum of Care assistance and the types and amounts of assistance that the program participant needs to retain housing. The recipient or subrecipient may require each program participant receiving assistance to notify the recipient or subrecipient of changes in the program participant’s income or other circumstances (e.g., changes in household composition) that affect the program participant's need for assistance. When notified of a relevant change, the recipient or subrecipient must reevaluate the program participant’s eligibility and the amount and types of assistance that the program participant needs (CFR 578.37).

RRH Written Standards #10 – Re-evaluation

Program participants must be re-evaluated, not less than once annually, in order to determine whether program participants lack sufficient resources and support networks necessary to retain housing without Continuum of Care assistance and the types and amounts of assistance that the program participant needs to retain housing.

Determining Written Standards for Transitional Housing (TH) Transitional housing means housing, where all program participants have signed a lease or occupancy agreement, the purpose of which is to facilitate the movement of homeless individuals and families into permanent housing within 24 months or such longer period as HUD determines necessary. The program participant must have a lease or occupancy agreement for a term of at least one month that ends in 24 months and cannot be extended (CFR 578.3). Riverside County CoC understands that there are families and individuals who need more assistance than rapid re-housing offers but who do not qualify for permanent supportive housing. Transitional housing should be reserved for those populations that most need that type of intervention – programs that serve domestic violence survivors and youth and those that provide substance abuse treatment come to mind first – rather than being used either as a holding pattern for those that really need permanent supportive housing or those that need less intensive interventions (SNAPS Weekly Focus (9/18/2013)).

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Eligible Clients Individuals and families defined as Homeless under the following categories are eligible for assistance in TH projects:

Category 1 – Literally Homeless Category 2 – Imminent Risk of Homelessness Category 4 – Fleeting/Attempting to Flee Domestic Violence

HUD’s Category 1 definition of homelessness is: Individuals and families who lack a fixed, regular, and adequate nighttime residence:

An individual or family with a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings, including a car, park, abandoned building, bus or train station, etc.;

An individual or family living in a supervised publicly or privately operated shelter designated to provide temporary living arrangements (including congregate shelters, transitional housing, and hotels and motels paid for by charitable organizations or by federal, state, or local government programs for low income individuals); or

An individual who is exiting an institution where he or she resided for 90 days or less and who resided in an emergency shelter or place not meant for human habitation immediately before entering that institution.

Eligible clients must also meet eligibility criteria as defined in the NOFA under which the program was funded. The 2015 HUD CoC NOFA states that recent research shows that transitional housing is generally more expensive than other housing models serving similar populations with similar outcomes. HUD also recognizes that transitional housing may be an effective tool for addressing certain needs such as:

housing for underage homeless youth; safety for persons fleeing domestic violence; and assistance with recovery from addiction.

TH Performance Benchmarks The Riverside County CoC strongly encourages sub-recipients to carefully review the transitional housing projects for cost-effectiveness, performance, and for the number and type of eligibility criteria to determine if rapid re-housing might be a better model for the CoC’s geographic area. All TH providers should meet or exceed project quality goals established by HUD and CoC guidelines which include the following:

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At least 80 percent of project participants exited from transitional housing to permanent housing;


At least 54 percent of project participants increased their income from sources other than employment in a given operating year; and

At least 56 percent of project participants obtained mainstream benefits. In addition, TH providers are required to answer “yes” as to whether the program implements a housing first approach.

Prioritizing Transitional Housing The Riverside County CoC prioritizes TH as follows (2015 HUD CoC NOFA):

1) Domestic violence survivors and youth ages 18 – 24 will be prioritized for transitional housing if they are not assessed as chronically homeless.1

2) All chronically homeless individuals and families will not be served through transitional housing unless other housing is not available (Coordinated Entry Brief, pg. 5).2 Such households will be served by permanent supportive housing through a Housing First approach.

Leasing Requirements Riverside County program participants in transitional housing must enter into a lease agreement for a term of at least one month. The lease must be automatically renewable upon expiration, except on prior notice by either party, up to a maximum term of 24 months (CFR 578.51).

TH Written Standards #1 – Lease Agreement The program participant must have a lease or occupancy agreement for a term of at least one month that ends in 24 months and cannot be extended.

no adult in the family, a minor head of household) who meets all of the criteria in paragraph (1) of this definition, 2 Chronically homeless households are no longer considered chronically homeless once they become residents of

transitional housing programs. As a result, such households are no longer eligible for permanent supportive housing programs that are restricted to serve only chronically homeless households. In addition, HUD strongly .

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Transitional housing facilitates the movement of homeless individuals and families to PH within 24 months of entering TH. Grant funds may be used for acquisition, rehabilitation, new construction, leasing, rental assistance, operating costs, and supportive services (CFR 578.37).

TH Written Standards #2 –Duration of Leasing Agreement The lease with program participant “must be automatically renewable upon expiration, except on prior notice by either party, up to a maximum term of 24 months.”

Written Standards for Emergency Shelters (ES) Eligible Participants are Individuals and families who are homeless. Essential services apply to persons in emergency shelters, renovating buildings to be used as emergency shelters, and operating emergency shelters.

Eligible Clients

Homeless clients entering into the emergency shelter system must meet the HUD criteria for homelessness as either:

literally homeless (Homeless Category 1);

at imminent risk of homelessness (Homeless Category 2);

homeless under another federal statute (Homeless Category 3); or

fleeing/attempting to flee domestic violence (Homeless Category 4).

In addition, ES providers must:


Prioritization and Referral

Emergency shelters will prioritize individuals/families that:

• Cannot be diverted; and

• Are literally homeless; and

• Can be safely accommodated in the shelter; and

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• Are not in need of emergency medical or psychiatric services or are a danger to self or others.

Also note the following:

• Emergency Shelters cannot discriminate per HUD regulations.

• There are no requirements related to ID, income or employment;

• Transgender placement is based on self-identification of gender.

ES Written Standards #1 – Length of Stay Maximum length of stay for is 90 days.

Written Standards for Street Outreach (SO) The Riverside County Continuum of Care(CoC), ESG program and the Coordinated Entry System understands the importance of Street Outreach efforts in our community to identify and assist the most vulnerable homeless and chronically homeless individuals and families. The CoC defines Street Outreach as follows: Street Outreach (SO) provides “essential services necessary to reach out to unsheltered homeless people; connect them with emergency shelter, housing, or critical services; and provide urgent, non-facility-based care to unsheltered homeless people who are unwilling or unable to access emergency shelter, housing, or an appropriate health facility (24 CFR 576.101).”

SO Written Standard #1 – Engagement Engage unsheltered homeless persons. Unsheltered persons are engaged for the purpose of providing immediate support, intervention, and connections with homeless assistance programs and/or mainstream social services and housing programs. Engagement includes locating, identifying, and building “relationships with unsheltered homeless people and engage them for the purpose of providing immediate support, intervention, and connections with homeless assistance programs and/or mainstream social services and housing programs. These activities consist of making an initial assessment of needs and eligibility; providing crisis counseling; addressing urgent physical needs, such as providing meals, blankets, clothes, or toiletries; and actively connecting and providing information and referrals to programs targeted to homeless people and mainstream social

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services and housing programs, including emergency shelter, transitional housing, community-based services, permanent supportive housing, and rapid re-housing programs (24 CFR 576.101).

SO Written Standard #2 – Emergency Health Services Link to emergency health services. Emergency health services include direct outpatient treatment of medical conditions and are provided by licensed medical professionals operating in community-based settings, including streets, parks, and other places where unsheltered homeless people are living. ESG funds may be used only for these services to the extent that other appropriate health services are inaccessible or unavailable within the area. Eligible treatment consists of assessing a program participant's health problems and developing a treatment plan; assisting program participants to understand their health needs; providing directly or assisting program participants to obtain appropriate emergency medical treatment; and providing medication and follow-up services (24 CFR 576.101).

SO Written Standard #3 – Mental Health Services Link to emergency mental health services. Emergency mental health services are direct outpatient treatment by licensed professionals of mental health conditions operating in community-based settings, including streets, parks, and other places where unsheltered people are living. ESG funds may be used only for these services to the extent that other appropriate mental health services are inaccessible or unavailable within the community. Mental health services are the application of therapeutic processes to personal, family, situational, or occupational problems in order to bring about positive resolution of the problem or improved individual or family functioning or circumstances. (24 CFR 576.101).

SO Written Standard #4 – Transportation Provide transportation. Transportation includes transporting unsheltered people to emergency shelters or other service facilities are also eligible. Transportation includes travel by outreach workers, social workers, medical professionals, or other service providers are eligible, provided that this travel takes place during the provision of services eligible under this section (24 CFR 576.101).

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SO Written Standard #5 – Street Outreach Contacts Street outreach contacts will be entered into the Coordinated Entry Systems (CES). As indicated in the System Performance Measure #7: Destination Classification (https://www.hudexchange.info/resource/4966/system-performance-measure-7-destination-classification/) promotes successful placement from Street Outreach & Successful Placement in Retention of Permanent Housing, and a street outreach entry in HMIS at the first contact. The entry will begin the process of entering homeless persons engaged by Street Outreach workers into the Coordinated Entry System.

SO Written Standard #6 – Measuring street exits Measuring street outreach services that help people exit the streets. As noted in System-wide performance measure #7: Successful Placement from Street Outreach & Successful Placement in Retention of Permanent Housing, “We are measuring how successful street outreach projects are at helping people move off the “street” and towards permanent housing, recognizing this process may be direct or may involve other temporary situations along the way. This is important because we know that people living on the street and other places not meant for human habitation are at an increased risk of death. In this part of the measure a lot of places in addition to permanent housing are considered successful destinations, such as emergency shelter, foster care, temporarily staying with family or friends, safe havens, and transitional housing. The measure is looking for an increase in the percentage of people who exit to positive destinations from a street outreach project during the reporting period.” The Riverside County Coordinated Entry System (CES) will function as the process that connect chronically homeless and homeless individuals and families for individuals identified by Street Outreach Teams to the Continuum of Care (CoC) and Emergency Grants Solutions (ESG) permanent housing programs – Permanent Supportive Housing and Rapid Rehousing. Through the implementation of the Riverside County CoC CES Policies and Procedures, CoC and ESG funded permanent housing programs must accept referrals from the CES.

SO Written Standard #7 – Collaboration Collaboration amongst all Continuum of Care agencies, Community Street Outreach, and Coordinated Entry Street Outreach for the benefit of serving chronically homeless, and homeless individuals and families in Riverside County.

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Written Standards for Homelessness Prevention (HP) The Riverside County CoC Homelessness Prevention (HP) program provides supportive services to prevent persons from becoming homeless in a shelter or an unsheltered situation. Funding may also be used to help such persons regain stability in their current housing or other permanent housing.

Eligible Clients Basic Eligibility Requirements

Initial Consultation & Eligibility Determination: The household must receive at least an initial consultation and eligibility assessment with a case manager or other authorized representative who can determine eligibility and the appropriate type of assistance needed. Clients must meet one of the following definitions of homelessness:

1. Literally homeless

2. At imminent risk of homelessness

3. Homeless under federal status

4. Fleeing/attempting to flee domestic violence

Income: The household’s total income must be below 30 percent of Area Median Income (AMI)

Housing Status: Case files must document the current housing status of the household at application. Housing status will be verified through third party verification whenever possible. Self-certification of housing status will be considered on a case by case basis.

Riverside County Residency: All households receiving prevention or rapid re-housing assistance under ESG must be residents of Riverside County at time of application.

Lack of identifiable financial resources and/or support networks: In order to receive ESG rental financial assistance, applicants must also demonstrate the following:

1. No appropriate subsequent housing options have been identified;

2. The household lacks the financial resources to obtain immediate housing or remain in its existing housing; and

3. The household lacks support networks needed to obtain immediate housing or remain in its existing housing.

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The following guidelines apply to Homelessness Prevention.

FINANCIAL ASSISTANCE

SERVICES

Moving costs Housing search & placement

Rent application fees Housing Stability Case Management

Last month's rent Mediation

Utility payments –up to 24 mos. pmts or

6 mos. Arrears

Credit repair

Security deposit –equal to no more than 2 mos. Rent

Legal Services

Utility Deposits

Types of Rental Assistance Length of Assistance 1. Short Term Rental Assistance up to 3 Months

2. Medium Term Rental Assistance 4 to 24 Months

3. Payment of Rental Arrears months, including any late fees

One-time payment up to 6 on the Arrears

HP Performance Standards

Based on standards and goals of the local Continuum of Care, Riverside County is proposing the following performance standards for the Emergency Solutions Grant and CoC programs:

a. A reduction in the number of homeless individuals and families seeking emergency shelter services.

b. Expected Outcome: At least 35% of participants assisted will remain in permanent

housing six (6) months after the last assistance.

A. Policies and Procedures for coordination among emergency shelter providers, essential service providers, homelessness prevention and rapid re-housing assistance providers, other homeless assistance providers, and mainstream service and housing providers. The ESG and CoC program requires coordination among participating agencies. All subrecipients in Riverside County are experienced homeless providers with a

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demonstrated track record in fiscal management and the provision of housing and supportive services targeted to homeless households. Additionally, the project administration agreement with subrecipients will require coordination among agencies receiving funds to administer emergency shelter, essential services, homelessness prevention, re-housing services, and related assistance, and access to mainstream services and housing providers for clients. Participation in the Continuum of Care ESG and CoC funded agencies have easy access to membership in the Continuum of Care. The Continuum of Care has over 100 member organizations including homeless service providers, veteran service representatives, churches and government organizations. The Continuum of Care meets on a regular basis and shares information about services among participating agencies.

Required Client Information and Referrals To further facilitate collaboration and information sharing, ESG and CoC funded agencies will be required to provide the following information and referrals to program participants:

2-1-1 hotline for social services

Social security benefits

Cal-Works and other income security programs provided by DPSS

Cal-Fresh (formerly known as Food Stamps) assistance

Low Income Energy Assistance Programs

Affordable housing information

Employment assistance and job training programs

Health care and mental health services

Services for victims of domestic violence

Veteran services

Specialized services such as legal services, credit counseling

B. Policies and Procedures for determining and prioritizing which eligible families and individuals will receive homelessness prevention assistance and which eligible families and individuals that will receive re-housing assistance.

Once it is determined that the household meets the basic eligibility guidelines noted above the household will be assessed for the appropriate form(s), level, and duration of financial assistance. The results of this assessment will be formalized in a Housing/Financial Assistance Plan that is signed by both the applicant and the case manager.

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Homeless Prevention Assistance Homeless prevention assistance will be targeted to households who are at risk of losing their present housing and becoming homeless. While there are many people who are housed and have a great need for rental assistance, not everyone will become homeless without assistance. A risk assessment will be used to assess the household’s level of crisis and prioritize those who are at greatest risk of becoming homeless. The assessment tool will include vulnerability criteria including but not limited to; income, housing history, food security, childcare, health care, life skills, and other special needs. Due to the limited amount of funding, assistance will be provided on a first come, first served basis, if the applicant meets the eligibility and risk assessment criteria.

C. Standards for determining the share of rent and utilities costs that each program participant must pay, if any, while receiving homelessness prevention or rapid re-housing assistance. Limitations on Assistance – Homeless Prevention Riverside County’s rental assistance is intended to stabilize individuals and families who have recently endured difficult financial circumstances that have led them into homelessness or who are at imminent risk of becoming homeless. For homeless prevention assistance, the rental assistance consists of short term rental assistance (3 months); extended under certain circumstances to medium term rental assistance (for an additional 3 months). The total maximum length of assistance is 6 months. Not every individual or family in need of rental assistance is a candidate for homelessness prevention or rapid re-housing assistance. Rental assistance is not a substitute for Section 8 rental assistance or a permanent rental subsidy, but a tool to help stabilize families or individuals who are at imminent risk of becoming homeless and lack any other resources to help them stabilize their housing situation. As a general rule, an individual or household should pay approximately 30% of their income towards rent. This requirement may be waived on a case-by-case basis for extreme circumstances. The rental assistance will consist of the remaining portion of the rent, up to $1,000 (excluding the clients’ contribution towards the rent). Clients are required to be reassessed at regular intervals to monitor progress and levels of self-sufficiency. If a client requires assistance beyond the three month mark, the ESG rental subsidy will be reduced and the client will be required to pay a larger portion of the rent

D. Standards for determining how long a particular participant will be provided with rental assistance and whether the amount of that assistance will be adjusted over time.

Rental assistance consists of short term (up to 3 months) to medium term (up to 6 months) rental assistance to allow individuals or families who have recently encountered

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a financial crisis that has led them into homelessness or at imminent risk of homelessness, to gain housing stabilization. Since the program consists of temporary assistance aiming at rapid stabilization of households, clients are required to contribute a portion of their income towards rent. Clients with no potential to earn income may not be suitable candidates for this type of assistance, unless other subsidies can be accessed after the rental assistance expires. Clients assisted under homelessness prevention assistance are eligible to receive the rental assistance for up to 3 months if they meet income eligibility during the 3 month period and comply with the case management requirements of the program. At the end of the third month, clients must be re-assessed to determine if the client’s rental assistance needs to be extended for an additional 3 month period. If the rental assistance is extended for an additional 3 months, the rental assistance will be reduced and/or adjusted over the remaining time. Clients assisted under Rapid Re-housing assistance are eligible to receive rental and utility assistance for up to 6 months if they meet income eligibility during the 6 month period. Re-housing clients must be evaluated at regular intervals during the assistance period. Monthly case management is highly recommended. The rental assistance should be reduced gradually and the client’s portion of the rent should be increased during the 6 month assistance period.

E. Standards for determining the type, amount, and duration of housing stabilization and /or

relocation services to provide a program participant, including the limits, if any, on homelessness prevention or rapid re-housing assistance that each program participant may receive, such as the maximum amount of assistance; maximum number of months the program participant receives assistance; or the maximum number of times the program participant may receive assistance.

*Reasonableness Clause The Riverside County Continuum of Care (CoC) will determine each fiscal year the maximum amount of total homelessness prevention or re-housing assistance that can be given to clients in a given fiscal year and reserve the right to limit established limits as needed. Benefit amount of assistance must be reasonable as determined by the CoC.