CoC Desk
Guide Training
City of San Francisco
Human Services Agency
June 8, 2015
Training Overview
Debbie
Raucher
Katharine
Gale
Kate
Bristol
Agenda
 Introduction/Context
 CoC Requirements
 Eligible Costs
 Grant Administration and Management
What is Included?
Introduction/Context
Continuum of Care
Emergency Solutions Grant
General provisions
pp. 4-5
Key Terminology
Program
component
Program
operator
Program
participant
Project
Recipient
Subrecipient
How to Use This Manual
pp. 6-10
How to use this manual
Reference guide
Tool for staff training
Basis for agency policies
and procedures manual
Manual Organization
Program
overview
Financial
management
Eligibility
guidelines
Housing &
unit
requirements
Ongoing
program
operations
Exit requirements
Grant
management
S+C Policies
ESG Program
General
requirements
pp. 7-10
Sample Program Component Guide
pp. 14
Key Changes with HEARTH
General
Eligibility
Emphasis on outcomes
Expansion of chronically homeless
definition
Written standards
Streamlined match requirements
Expansion of definition of
homelessness
Administrative costs
COC
Coordinated entry
Streamlining programs
Collaboration
Addition of rapid re-housing
Protecting teenage family members
No overlap in assistance types
Continuum of
Care
pp. 18-20
Overview of Program Components
 Permanent
Housing

Permanent supportive housing

Rapid rehousing

Transitional Housing

Support Services Only
pp. 17-18
Overview of Expense Types
Leasing
Rental assistance
Supportive services
Operating costs
HMIS
Administrative costs
pp. 23-25
Eligibility – Homeless Status
Literally
homeless
Imminent risk of
homeless
Fleeing
domestic
violence
Streets or
shelter. Exiting
institution
where resided
<90 days and
literally
homeless prior
to entering
Losing
residence
within 14 days.
No
subsequent
residence,
resources or
support
DV in
residence or
made
individual
afraid to
return home.
No resources
or support
Chronically
homeless
Literally
homeless for 1
year or 4
occasions in 3
years and has
disability
pp. 23 & 140-146
Documentation
 Certification
of homeless status form +
third party verification
 Self declaration of homeless status – only if
all other means to obtain verification
have failed
 Chronic homelessness documented with



HMIS data;
A written referral; or
Written verification from outreach worker
 Complete
requirements in Appendix B
p. 26
When Does Homeless Status
End?
 TH
residents continue to meet definition of literal
homelessness but not chronic homelessness
 Veterans
in transitional VA GPD program
maintain homeless/chronic status
 RRH
recipients maintain homeless/chronic
status for PSH and VASH
pp. 27-29
Other Eligibility Criteria

PSH must serve disabled (may be
further restricted to chronic
homeless)

May be further restricted to
serving certain subpopulations

Immigration status restrictions
may apply
p. 30
Enrollment
Document eligibility
Enroll in your program
HMIS entry (requires
calculation of income)
pp. 31-35
Housing Requirements – All
Programs
Geographic restrictions
Dwelling size
HQS/Lead paint
Rent reasonableness & FMR
pp. 35-41
Housing Requirements (cont.)
 PSH




and TH
Rent requirements
Utility allowance
Calculating income
Lease requirements
 Permanent

Payment upon vacancy
 RRH


Housing (PSH and RRH)
only
Time limits
No double dipping
Rent Amount Quiz – rental assistance
A case manager has identified a 2-bedroom
RRH unit at $1,600 per month, not including
utilities (the tenant’s responsibility). The utility
allowance established by the SFHA is $150.
What is gross rent?
A check of three similar units in the
neighborhood through Craigslist reveals that the
average rent for the three comparable units
(without utilities) is $1,900. The FMR is $1725.
What is the gross comparable rent?
Can the program use the unit?
Rent Amount Quiz - leasing
A PSH program is looking to lease a 3bedroom unit. The program finds a housing
unit for $2,400, including all utilities. A check
of three similar units in the neighborhood
through Craigslist reveals that the average
rent for the three comparable units is
$2,500. The FMR for 3-bedroom units is
$2,200.
Can the program lease the unit?
pp. 41-43
Housing Requirements (cont.)


Rental assistance

Use of funds upon move-in

Lease requirements

Rent charged to tenant
Programs serving families with
children


Educational needs of children
Prohibition against involuntary family
separation
pp. 43-45
Ongoing Operations – All
Programs
Changes to household composition
Changes to income
Services requirements
Case notes
Services supervision
pp. 45-46
Ongoing Operations (cont.)
PSH
Support services
Death, institutionalization or
incarceration
RRH
Timelines
Case management
Re-evaluation
pp. 46-47
Ongoing Operations (rental
assistance)

Use of rental assistance during
institutionalization/incarceration

Changing site location
p. 48
Annual Recertification
Income/
Rent
HQS
Update
to HMIS
Services
plan
pp. 48-50
Exit Requirements
 TH
time limits
 Use of funds for property damage
 Termination of participants
 HMIS exit
pp. 79-102
S+C Rules
 Application
process
 General information
 Program rules








Intake
Exit
Income changes
Violations
Reporting
Unit transfer
Temporary vacancies
Appeals






Communicating rules
Reunification
Survivor rights
Internal transfers
Adding adults to lease
Domestic violence
Allowable
Costs
Overview of Expense Types
Leasing
Rental assistance
Supportive services
Operating costs
HMIS
Administrative costs
Pp 50-51
Allowable Costs – Leasing
Rent
reasonableness and FMR
Utilities
Security
deposits
Prohibition
ownership
on
pp. 51- 53
Allowable Costs – Rental Assistance
 Types
– tenant, sponsor or projectbased
 Rent reasonableness
 Duration
 Use of excess funds
 Security deposits
 Damages
 Vacancies
Costs for administering rental assistance including
conducting HQS are part of rental assistance (not admin)
pp. 53 - 54
Allowable Costs – Support
Services

Expenses related to provision of
an eligible service

Operations costs for support
services facility

6 months following exit from TH or
homelessness
p. 54
Support Services - Eligible Services
Assessment
Legal services
Moving costs
Life skills training
Case management
Outpatient mental health services
Child-care
Outpatient health services
Education services
Outreach services
Employment assistance and
job training
Outpatient substance abuse
treatment
Food
Transportation
Housing search and
counseling
Utility deposits
p. 54
Ineligible Services
 Recreational
activities
 Criminal background checks for participants
 Direct payments to participants or gift cards –
including client stipends
 Staff training
 Obtaining professional licenses or
certifications
 A services program with an inherently religious
component
 Anything not listed as an eligible service
pp. 56-57
Allowable Costs - Operations
 Maintenance
and repair
 Property taxes and insurance
 Replacement reserve
 Security

When more than 50% of units is paid with
grant funds
 Electricity,
gas & water
 Furniture
 Equipment
Operating Cost Quiz
Are the following costs eligible or ineligible?
 Salary
for a maintenance person
 Property management staff training
 New refrigerators for units
 Cable TV for participants
 Desks for property management staff
 Installing a playground structure on site
p. 56-57
Allowable Costs - HMIS
Hardware
Office space & utilities
Software and licenses Travel to HMIS training
Equipment (phones,
furniture)
Travel to conduct
intakes
Technical support
Participation fees of
HMIS Lead
Salaries for
 Data entry
 Monitoring and reviewing data quality
 Data analysis
 Reporting
 HMIS training
pp. 57-59
Allowable Costs - Admin




Salaries and related costs of staff for:
 Preparing budgets
 Developing systems for compliance
 Developing agreements with subrecipients
 Monitoring and evaluation
 Preparing reports
 Resolving audit and monitoring findings
Travel costs for monitoring subrecipients
Third-party contracts including general legal
services, accounting, and audit
Rental or purchase of equipment, insurance, utilities,
office supplies, and rental and maintenance of
office space
pp. 59-60
Misc. Cost Guidelines
 Restrictions
on combining
funds
 Program income (including
rental income) must be used
for eligible activities
 TH rent may be reserved to assist
residents to move into permanent
housing
 Pro-rating costs use for multiple purposes
pp. 60-63
Match Requirements
 25%
match (except leasing)
 Match is for total grant amount – not line
by line match
 Program income cannot be used as
match
 All match subject to HUD restrictions
 Cash match can be from any non-CoC
source (cannot be used as match for any
other federal program)
 Direct benefits (CalWORKs, SSI) are not
match
Match Quiz
 Example
A
Rental Assistance funding = $95,000
Project Administration funding = $5,000
Total HUD funding = $100,000
 Example
B
Leasing funding = $40,000
Supportive Services funding = $55,000
Project Administration funding = $5,000
Total HUD funding = $100,000
pp. 66-78
CoC Grant Management








Technical submission
LOCCS
Reporting
Changes to project
Close out
Performance review
Participation of
homeless
people
Grant renewal
pp. 74-75
Common Areas of Findings
Program participants’ eligibility
Supportive services
Financial documentation
Resident rents
Match
Staff time distribution
HMIS
A Peek into ESG
Eligibility
Prevention
and RRH
requirements
Coordination
and linkage
Program exit
Emergency
shelter
requirements
Eligible costs
Matching
requirements
Program
components
Grant
administration
Grant
Administration &
General Policies
pp. 103-114
General Requirements – Financial
Management & Cost Allocation
 Accounting
controls
 Source documentation
 Fund and cost accounting
 Documentation of match
 Cost allocation




Allowable, reasonable and allocable
Direct and indirect costs
Allocating shared costs
Time and activity reporting
pp. 115-117
Other Policies
Fair Chance
policy
Subsidy
layering
Restrictions on
faith based
activity
pp. 117-123
Fair Housing
 Affirmative
marketing requirements
 Ensure effective communication with
persons with disabilities
 Equal access with regard to sexual
orientation, gender identity, or marital
status


Cannot limit to only women with children
Couples cannot be required to be married
 Discrimination
prohibited
 Physical accessibility
pp. 123-127
Reasonable Accommodations
 Reasonable
accommodations must be
provided
 Not required if “undue financial and
administrative burden, or if they would be
a fundamental alteration of the provider’s
program”
 Live in Aides




Housing provider may screen individual
Income excluded from rent calculation
Must include when determining unit size
Should not be signatory on lease
pp. 127-131
Other Requirements

Conflict of interest






Specific rules related to procurement
Must maintain codes of conduct
Avoid organization conflict
Confidentiality
Subrecipient awards >$25K must be reported
Uniform admin requirements - financial
management, property and equipment
standards, procurement, reporting
requirements, termination, enforcement, and
close-out
pp. 132-134
Other Requirements
Drug-free workplace
Anti-lobbying
Equipment records – physical inventory must be
taken every two years
Relocation provisions apply
pp. 50 and 147-150
Recordkeeping
 Eligibility
 Income
 Services
provided
 HQS
 Conflict
of interest policy
 Homeless participation
 Fair housing
 Other federal requirements
 Match
 Subrecipients and contractors
Must be kept for
5 years after
expenditure of
all funds
pp. 135-200
Appendices
Appendix A - Glossary of Terms
Appendix B - Eligibility Documentation Requirements
Appendix C - CoC Recordkeeping Requirements
Appendix D - CoC Supportive Services Eligible Costs
Appendix E - RRH Differences Between ESG and CoC
Appendix F - ESG Recordkeeping Requirements
Appendix G - Other Resources
Appendix H - Forms
Q&A
Manual is available for download at
http://sfgov.org/lhcb/hearth-implementationworkgroup/meeting/2015-june-8-supportingdocuments