Housing Authority of Portland & Central City Concern
SHELTER PLUS CARE DOL Grant
Tenant Based-Rent Assistance Program (TRA)
MANAGEMENT PLAN
Shelter Plus Care (S+C) is a federally funded program, which provides long-term
rental assistance to homeless persons with disabilities. Appropriate supportive
services designed to enable persons to achieve and maintain independent living
must be available to the participants. The value of the services must equal the
amount of housing assistance over the five-year period of the grant.
The Housing Authority of Portland (HAP) provides the rent assistance and the
participating service agency Central City Concerns (CCC) will provide the
support services.
Scope of Services
The Housing Authority of Portland received a Shelter Plus Care grant of
$2,991,900 for five years of rent assistance from the Department of Housing and
Urban Development starting in 2003.
Contracts
HAP will develop and enter into contracts with landlords renting to clients
sponsored by CCC with the Shelter Plus Care grant. Prior to making rental
assistance payments, HAP will ensure that all necessary agreements are in
place.
Rental Assistance
HAP will administer the rental assistance funds from the S+C grant according to
the terms of this agreement and in a manner consistent with all federal
requirements. Up to eight percent of the grant will be retained by HAP as an
administrative fee.
Accounting
All accounting services will be provided by HAP. HAP will manage the fiscal
aspects of S+C in accordance with all federal, state, and local laws. HAP will
provide the necessary information to the Internal Revenue Service in accordance
with IRS regulations. HAP will provide for an annual audit, which will be
consistent with HUD requirements.
Shelter Plus Care DOL Management Plan 01/2004
Eligibility and Rent Determination
HAP will verify the eligibility of all applicants who must meet the definition of
chronic homelessness and have a disability. Once it is determined that the
person is eligible for the S+C program, HAP will determine the person’s rent.
The participant’s portion of the rent is thirty percent (30%) of the household’s
adjusted monthly income. When the participant is responsible for paying utilities,
the participant’s portion of the rent is thirty percent (30%) of the person’s
adjusted monthly income minus the utility allowance.
Calculation of Income
HAP will examine the household’s income initially, and at least annually
thereafter, to determine the amount of rent payable by the participant.
Adjustments to a participant’s rental payment must be made as necessary.
As a condition of participation in the program, each participant must agree to
supply the information or documentation necessary to verify the household’s
income. Participants must provide information at any time regarding changes in
income or other circumstances that may result in changes to a participant’s rental
payment.
Unit Eligibility and Rent
HAP is responsible for inspecting all units to ensure they meet federal Housing
Quality Standards. HAP will ensure that rents comply with HUD regulations
regarding Fair Market Rents. HAP staff will use the Rent Reasonableness
survey developed for Section 8 and insure that documentation is on file if rents
are approved in excess of the average rents for the specific geographic area.
File and Records
HAP will maintain files on all S+C participants and units. HAP will require CCC to
provide all necessary documentation prior to making rental assistance payments.
HAP also will require CCC to provide reasons for termination of participants prior
to closing a file. HAP will maintain accurate records on all S+C funds received
and paid. All closed files will be kept for the duration of five (5) years.
Training of Agency Personnel
HAP will provide training for agency personnel in the requirements of and their
responsibilities for the S+C program. An initial workshop will occur prior to
program implementation, followed with training by HAP’s S+C Program
Coordinator with the individual designated by CCC as Application Coordinator
Periodically HAP will meet with CCC to plan, train, and problem solve.
Rental Assistance Management Procedures
Authorize Agency S+C Personnel
In an effort to ensure accurate communications, CCC will designate one staff
member as contact person for the S+C program: Application Coordinator. This
contact person will sign off on all applications and annual renewals, and HAP will
not conduct an HQS inspection or make housing assistance payments without
the approval of the authorized agency contact person.
Request for Payment
Before HAP makes a payment for a new unit and tenant, HAP must have the
following information and documentation from CCC:
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Documentation of the applicant’s eligibility on the S+C application form
An agency agreement between CCC and the participant
The verification of the applicant’s income
Verification of Chronic Homelessness Form
Verification of Disability Form
Rent Calculation Worksheet
HAP release of information form signed by the applicant
Federal HUD release of information signed by the applicant
Passed HQS inspection documentation
A signed lease (initial lease for one year)
A signed contract between the landlord and HAP
Lead Based Paint disclosure form
Copies of photo ID for all adults in house
Copies of Social Security cards for all members (ages 6+)
Housing Assistance Payments
HAP will mail initial rent subsidy payment upon receipt of the signed contracts,
and all subsequent rent subsidies on the first day of the month directly to
landlords. HAP will maintain records of all S+C payments made.
Vacancy Payments
CCC and Landlords must notify HAP immediately upon termination of tenancy
(within five working days) so that HAP may determine any allowable vacancy
payments. Landlord must provide HAP with documentation regarding
termination of participants from the S+C program and Vacancy payment only will
be made by request within limits allowed by program.
Security Deposits and Damage Claims
Landlords may request up to one (1) month’s rent for a security deposit for a
participant. The security deposit requested must be the same as required of
other tenants renting at the complex and may not include any ‘administrative
fees’. In the event the tenant causes damage to the unit, the landlord may
withhold the security deposit to pay the actual cost of repairing the damages, with
proof of damages provided to HAP and tenant in accordance with Oregon
Landlord – Tenant law.
Program Delivery Requirements
Outreach Activities
CCC must use their best efforts to ensure that the S+C program serves eligible
hard-to-reach persons. Outreach should be primarily directed toward eligible
persons who have a nighttime residence that is an emergency shelter or a public
or private place not designed for, or ordinarily used as, a regular sleeping
accommodation. Applicants who are in treatment (residential alcohol/drug and/or
mental health related) for up to 90 days will be considered; individuals living in
transitional housing do not meet this definition.
Selection of Participants
The authorized contact person at CCC will coordinate the screening and
selection process. The agency will use the following selection criteria for the
individual receiving S+C rent assistance:
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The individual meets the criteria for chronic homelessness (as defined in
Verification of Chronic Homelessness Form – see application materials)
The individual is diagnosed with a disability, and
The individual is willing to work with a case manager and follow a
treatment plan.
CCC will maintain a waiting list of applicants for the S+C program. Specific
participants will be selected from those eligible on a first-come first-serve basis.
The selection process will be based on the applicant’s ability to function in the
community at the time a slot is available. If CCC determines that the applicant is
not able to function independently, or assesses that there is a high probability
that the person will become unstable, this is just cause for passing the person on
the waiting list. Should the landlord, through screening, refuse to allow a person
to occupy a unit, this also is a valid reason to pass by the applicant on the waiting
list.
CCC will maintain its waiting list with documentation as to the reason that
applicants were passed by, and provide this information on request to HUD,
and/or HAP.
Acceptance into the Program
When a slot becomes available, CCC identifies an eligible applicant from its
waiting list. If a person on the waiting list is passed over, CCC must document
the reason for doing so.
HAP will perform the Housing Quality Standards inspections and will maintain
inspection related documentation on file. HAP will ensure that units are occupied
by the number of tenants appropriate for that unit. Within five (5) working days of
notification by CCC that a housing unit is available, HAP will perform the HQS. If
the unit meets HQS and all the documentation has been provided to HAP, the
client is eligible to move in upon HAP approval. The day after a passed
inspection will be considered the start up date on the contract/lease unless
otherwise negotiated between the landlord, agency (on behalf of the tenant) and
HAP.
Rent Calculation
Staff from CCC will provide the following documentation in order for HAP to
determine the participant’s portion of the rent (See also Request for Payment,
page 3 of this document):
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Application for Shelter Plus Care Program completed;
Release of information signed by the applicant; and
Income verification for the applicant.
After HAP has verified the applicant’s eligibility, determined the household’s
portion of the rent, the unit has been inspected and met HQS, HAP will enter into
a contract with the landlord to provide rental assistance. Rental assistance will
be paid only when all necessary paperwork is completed and on file with HAP.
Occupancy Agreements
At this time landlords must enter into an occupancy agreement (contract/lease)
with the participant for a term of one year. This agreement will be automatically
renewed upon expiration on a month-to-month basis, except on prior notice by
either party.
Agency Agreement with Participant
CCC must have an agency agreement between CCC and the participant on file.
The agreement must be signed and dated by the participant. The agreement
shall outline the services provided by the Shelter Plus Care program, and
activities or behaviors that can lead to program termination. Grievance
procedure, should a participant be terminated from the program or have other
grievances with the program, shall be outlined in the agreement. CCC must
provide the participant with a copy of the agreement.
In addition, CCC agrees to coordinate and assist participants it sponsors to sign
up for other permanent long-term housing programs such as the Section 8
Housing Choice Voucher Program and Low Rent Public Housing when such an
opportunity is available. This activity will assist participants in obtaining and
keeping housing assistance as necessary should their service needs diminish
and alternative programs become appropriate, or as dictated with funding
changes.
Termination Policy
Termination from the program can be the result of the mutual agreement of CCC
and the participant, by action of CCC, or by the participant acting alone. A
planned move may occur because another situation is clinically advisable, such
as a more structured or specialized program. Some participants may request
termination because they can live more independently and no longer need the
supportive services. Some participants may move without notifying either the
agency or landlord.
Some terminations may be due to violence, property damage, drug dealing or
other felony behavior, or other serious disruptive behavior of the participant.
CCC will consider whether there are alternatives other than termination to deal
with factors such as non-payment of rent, drug use, and disruptive behavior. The
agency also may terminate a participant who violates program requirements, but
should do so only in the most severe cases.
In terminating assistance to a participant, CCC must provide a formal process
that recognizes the rights of individuals. The process at a minimum must consist
of:
1. Written notice to the participant containing a clear statement of the
reasons for termination of rental assistance. This is in addition to any
legal eviction notice. (The agency will provide HAP with a copy of the
termination notice.)
2. A review of the decision, in which the participant is given the opportunity to
present written or oral objections before a person other than the person
who made or approved the termination decision; and
3. Prompt written notice of the final decision to the participant.
CCC will include the termination notice, a copy of the eviction notice (if any), and
written record of the response in the client’s clinical record a copy shall also be
sent to HAP to be kept in the participants file.
As legal eviction may accompany termination from the program, CCC will make
every reasonable effort to stop the problem behavior or to find alternative
housing for the participant. Legal responsibility for eviction is that of the landlord.
A former participant may be reconsidered for re-admission into the program
should CCC believe that the issues that resulted in termination have been
resolved.
Grievance Policy
CCC will have a grievance policy. This policy will be provided to persons when
they apply for S+C rent assistance. Participants will be encouraged to utilize this
grievance policy when they do not agree with housing or treatment decisions
made by the agency. All grievances will be handled by CCC. HAP will not hear
grievances.
CCC will submit to HAP a copy of its grievance policy.
Program Coordination and Assessment
HAP and CCC will meet individually at least every six months during the first year
and as needed there afterwards. Meetings may involve problem solving, training,
planning, or any other activities related to the S+C Program.
HAP will conduct a site visit during the first year to determine that documentation
is being kept per the Management Plan and required file record keeping. Site
Visits will occur every other year there afterwards unless the initial site visit
indicates the need for further monitoring.
HUD Required Reporting
HAP will coordinate the collection of data for the annual report to HUD. CCC is
responsible for collecting information during the year and forwarding necessary
information in a timely manner when HAP requests it. CCC also will respond to
any other reasonable requests for information from HUD and/or HAP.