SecondAmendmentESGDRAFTWebMarch292012

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DRAFT

SUBSTANTIAL AMENDMENT PROCESS FOR

SECOND ALLOCATION OF FY 2011

EMERGENCY SOLUTIONS GRANTS PROGRAMS

FUNDS

2012

MISSISSIPPI DEVELOPMENT AUTHORITY

COMMUNITY SERVICES DIVISION

May 15, 2012

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TABLE OF CONTENTS

OVERVIEW

Introduction ............................................................................................................. 4

Citizen Participation Process ................................................................................... 5

Summary of Consultation Process………………………………………………………6

Match Requirement ................................................................................................. 7

Proposed Activities .................................................................................................. 8

Discussion of Funding Priorities .............................................................................. 8

Written Standards for Assistance ........................................................................... 9

Process for Sub-awards ........................................................................................ 10

Homeless Participation Requirement ................................................................... 10

FY2011 Detailed Budget Table …………………………………………………. ........ 12

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OVERVIEW

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INTRODUCTION

On November 15, 2011, the Department of Housing and Urban Development

(HUD) posted the interim rule for the Emergency Solutions Grants (ESG) program and Con solidated Plan conforming amendments (Interim Rule) on HUD’s

Homelessness Resource Exchange website at www.hudhre.info

. On December 5,

2011, the Interim Rule was published in the Federal Register (see 76 FR 75954).

Also on November 15, 2011 HUD announced the amounts of the second allocation of FY 2011 Emergency Shelter Grants program/Emergency Solutions Grants program funds.

The funds provided in the second allocation will be subject to all of the ESG requirements under the Interim Rule. These funds must be expended within 24 months after the date HUD signed the amendment to the recipient’s FY2011 grant agreement. When making funding decisions, recipients should take into account that the Interim Rule shifts the focus from emergency shelter to assisting people to quickly regain stability in permanent housing.

HUD is encouraging jurisdictions to target and to focus as much of their funding as possible on rapidly re-housing individuals and families living in emergency shelters or on the streets. Effective rapid re-housing can transition people out of homelessness quickly and decrease the overall number of people that are homeless in a community.

To receive funds from the second allocation, each eligible recipient must prepare, submit and obtain HUD approval of, a substantial amendment to its Fiscal Year

(FY 2011) Consolidated Plan Annual Action Plan (Annual Action Plan), in accordance with the recipient’s citizen participation plan and 24 CFR Part 91, as amended by the Interim Rule. The substantial amendment to HUD must be submitted on later than May 15, 2012.

The Mississippi Development Authority (MDA), Community Services Division

(CSD), has the responsibility for developing preparing the Substantial Amendment for the Second Allocation of FY 2011 ESG funds to their 2011 Consolidated One-

Year Action Plan.

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CITIZEN PARTICIPATION PROCESS

The State of Mississippi (MDA) followed its Citizen Participation Plan by publishing seven announcements in statewide local and regional newspapers on March 4, 2012 and held three public hearings on March 21-23, 2012, at the Holmes Community

College – Grenada, MS; Cabot Lodge Millsaps - Jackson, MS; and MS Power Company

Building Auditorium

– Hattiesburg, MS. We also sent a CSD Instruction #12-006 requesting input from citizens, private consultants, Planning and Development Districts, local units of government, Continuum(s) of Care coalitions, Emergency Shelters and other interested parties in the development of the State's Consolidated Plan.

Provided during the public hearings was information concerning the Substantial

Amendment for the Second Allocation of FY 2011 ESG funds and the intended use of these funds. MDA will post the Substantial Amendment on the MDA website www.mississippi.org/csd.

The State published an announcement in the Clarion Ledger (State-Metro non-legal section) on March 25, 2012 of the availability of the 2012 One-Year Action Plan (Draft).

The Draft Plan will be available on, the MDA website www.mississippi.org/csd . The 30day comment period will opened March 29, 2012 until April 27, 2012.

At the end of the comment period, all written comments will be summarized and will be considered by the State.

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SUMMARY OF CONSULTATION PROCESS

Based on the requirements in 24 CFR 91.320(k) (3) (v)

, each recipient’s substantial amendment must describe how the recipient consulted with the Continuum(s) of Care regarding: determining how to allocate ESG funds for eligible activities; developing the performance standards for activities funded under ESG; and developing funding, policies, and procedures for the operation and administrative of the Homeless

Management Information System (HMIS).

MDA, Housing and Homelessness staff held meetings, February 9, 16, and 23, 2012 in

Jackson and Gulfport with the three Continuum(s) of Care coalitions to discuss the

Second Allocation of FY 2011 ESG funds and the intended use of these funds. Also discussed were the Continuums capacity, completion and closeout of the

Homelessness Prevention and Rapid Re-Housing Program (HPRP) grant and the need for case management.

MDA also held a consultation meeting with the Continuum (s) of Care on March 27,

2012 at the Woolfolk State Office Building in Jackson. Represented at this meeting were each Continuum’s Executive Director, Chair or President, the HMIS Coordinator, and a Case Manager. The following target areas were discussed.

A. How to allocate ESG funds for eligible activities

1. Continue the Emergency Shelters grants for operation, maintenance and essential services.

2. Fund rapid Re-housing to transition people out of homelessness quickly and decrease the overall number of people that are homeless in a community.

3. Homeless Management Information System (HMIS), all projects receiving funding under the ESG program must participate in HMIS.

4. Administrative costs, under the HEARTH Act, the portion of ESG grants that can cover administrative costs is increased from 5 percent to 7.5 percent of a recipient’s entire grant.

B.

Developing the performance standards for activities funded under ESG

MDA meet in consultation with the CoCs to discuss the purpose of the performance standards as an evaluation tool used to provide the measureable effectiveness for ESG service providers. The performance standards should go beyond projecting the number of persons or households who will exit or avoid homelessness under the grant. These standards should how well the services provider succeeded at:

1) targeting those who need the assistance most;

2) reducing the number of people living on the streets or emergency shelters;

3) shortening the time people spend homeless; and

4) reducing each program participant’s housing barriers or housing stability risks.

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It was agreed upon by the MDA staff and all three CoC representatives that they would submit to MDA by April 3, 2012 the performance standards that is in currently use or proposed to be used in their evaluation in the HPRP program.

Additionally, on April 5, 2012 a conference call will convene with the three CoC(s) to review the performance standards submitted in an effort to develop consistency in design of service providers’ programs so that homelessness is shortened.

C. Developing funding, policies, and procedures for the operation and administration of HMIS

The HEARTH Act makes HMIS participation a statutory requirement for ESG recipients and sub-recipients. The interim rule makes certain HMIS costs eligible to the extent necessary to enable this participation.

Victim service providers that do not participate in HMIS must use a comparable database that produces unduplicated, aggregate reports instead. MDA is working in consultation with the CoC to provide training staff on using the HMIS or comparable database.

MATCH REQUIREMENT

In accordance with 24 CFR 91.320(C), states in the substantial amendment process must specify the types, amounts and proposed uses of match resources.

The State of Mississippi, has been designated a 100% match reduction State with a severe fiscal distress determination. No match is required.

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PROPOSED ACTIVITIES

The State of Mississippi (MDA) has selected to contract with a Continuum of Care to provide statewide use of rapid re-housing services and to allocate funds for the use of

HMIS. The financial assistance includes the following activities: short-term rental assistance, medium-term rental assistance, security deposits, and utility deposits.

Optional activities may include: utility payments, motel or hotel vouchers and moving cost assistance.

The HMIS system will provide the data reporting requirements, gathering and maintaining the data needed and completing and reviewing the collection of information.

To the extent that any information collected is of a confidential nature, there will be compliance with Privacy Act requirements.

The program participants and clients will be referred from emergency shelters and other agencies who serve the homeless population.

Discussion of Funding Priorities

MDA is committed to the national strategies and objectives of homeless prevention and ending homelessness through coordinated activities with the Continuum(s) of Care providing greater and rapid response to an individual experiencing homelessness.

Throughout the planning process, it has been the shared goal of MDA, the CoCs, and other agencies that priority be given in any and all discussions and decision to focus funding efforts in addressing the needs of homeless people in emergency or transitional shelters to assisting people to quickly regain stability in permanent housing.

Grantees should ensure that sufficient planning is in place to begin to expend funds shortly after the grant agreement is executed.

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Written Standards for Provision of ESG Assistance

Appendix B: Checklist of Requirements for the Substantial Amendment, states that

“If the recipient is a state, they can require subrecipients to establish and implement written standards for the use second allocation funds for ESG assistance.

MDA is funding the second allocation funds for the rapid re-housing assistance. Once the grant award has been made, MDA will require the grantee(s) to develop specific written standards for the assistance. The standards must include:

1) Standards for determining the share of rent and utilities costs that each program participant may pay, if any, while receiving homelessness prevention or rapid rehousing assistance.

2) Policies and procedures for determining and prioritizing which eligible families and individuals will receive homelessness prevention assistance and which eligible families and individuals will receive rapid re-housing assistance.

3) 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.

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

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Describe Process for Making Sub-awards

The Second Allocation of FY2011 ESG funds will be made by means of a grant agreement. MDA will consider among one or more of the Continuum(s) of Care as the grant recipient(s). Selection of a grantee will be evaluated based on the organization’s capacity, performance, over site experience, monitoring, administration and timeliness of expenditure and use of its own HPRP funds, as well as those used by it subgrantees.

After the determination and selection of the grantee has been made, an award will be made once HUD has approved MDA’s amended action plan.

Homeless Participation Requirement

According to CFR 576.405, the State require its subrecipient shelter boards provide participation of not less than one (1) current or former homeless individual on the board of directors or other equivalent policy-making entity of the recipient, to the extent that the entity considers and makes policies and decisions regarding any facilities, services, or other assistance that receive funding under ESG.

The subrecipient application must describe how their programs are designed to involve homeless individuals and families in the operation of the ESG funded program. This involvement may include activities such as construction, renovation, maintenance, general operation of facilities, or provision of services. The involvement can include paid and/or volunteer work.

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First Allocation

Second Allocation

Grant Amount

Total Administration

$1,441,015.00

$810,571.00

$2,251,586.00

MISSISSIPPI DEVELOPMENT

AUTHORITY

FY 2011 Detailed Budget Table

FY 2011

Emergency Shelter Grants/Emergency Solutions Grants

Program Allocations

Eligible Activities

Homeless Assistance

Rehab/Conversion

Operations

Essential Services

Homelessness Prevention

$168,868.95

First Allocation

Second Allocation Total Fiscal Year 2011

Activity Amount

$1,369,015

$0.00

$1,369,015

Reprogrammed

Amount

$0.00

$0.00

$0.00

$0.00

Activity Amount Activity Amount

$1,369,015.00

$0.00

$1,369,015.00

$0.00

$0.00

Administration

Emergency Shelter Grants Subtotal

$72,000.00

$1,441,015.00 $0.00

$72,000.00

$1,441,015.00

Emergency Shelter** $0.00 $0.00

Renovation**

Operation**

Essential Service**

URA Assistance**

$0.00 $0.00

$0.00 $0.00

$0.00 $0.00

$0.00 $0.00

Street Outreach - Essential Services** $0.00 $0.00

HMIS

Rapid Re-housing

Housing Relocation and

Stabilization Services

Tenant-Based Rental Assistance

Project-Based Rental Assistance

Homelessness Prevention

Housing Relocation and

Stabilization Services

Tenant-Based Rental Assistance

Project-Based Rental Assistance

Administration

$0.00

$0.00

$0.00

$50,000.00 $50,000.00

$720,571.00 $720,571.00

$0.00 $0.00

$40,000.00 $40,000.00

Emergency Solutions Grants Subtotal $0.00 $810,571.00 $810,571.00

Total Grant

Amount:

**Allowable only if the amount obligated for homeless assistance activities using funds from the first allocation is less than the expenditure limit for emergency shelter and street outreach activities (see Section III.B. of this Notice).

$2,251,586.00

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$0.00

$0.00

$0.00

$0

$0

$0.00

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