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.
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:
- 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:
- 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):
- 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 withthe landlordto 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 shalloutline theservices 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:
- 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.)
- 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
- 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.