SUBSTANTIAL AMENDMENT PROCESS FOR

SECOND ALLOCATION OF FY 2011

EMERGENCY SOLUTIONS GRANTS PROGRAMS FUNDS

MISSISSIPPI DEVELOPMENT AUTHORITY

COMMUNITY SERVICES DIVISION

May 15, 2012

TABLE OF CONTENTS

INTRODUCTION...... 1

CITIZEN PARTICIPATION PROCESS...... 2

SUMMARY OF CONSULTATION PROCESS...... 3

MATCH REQUIREMENT...... 4

PROPOSED ACTIVITIES...... 5

Discussion of Funding Priorities...... 5

Describe Process for Making Sub-awards...... 5

WRITTEN STANDARDS- ESG Assistance...... 6

HOMELESS PARTICIPATION ...... 8

CENTRALIZED ASSESSMENT SYSTEM...... 9

MONITORING PROCEDURE...... 10

BUDGET...... 11

MDA FY 2011 Detailed Budget Table...... 12

FY 2010 Grant Fund Commitments...... 13

CERTIFICATIONS...... 14

HUD FORM 424...... 19

CITIZEN COMMENTS...... 21

MDA ACKNOWLEDGEMENT LETTERS...... 24

FY11 ESG Second AllocationPage | 1

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 Consolidated Plan conforming amendments (Interim Rule) on HUD’s Homelessness Resource Exchange website at 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.

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, 2012and 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 Sheltersand other interested partiesin 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.

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 The 30-day comment period opened March 29, 2012 until April 27, 2012.

At the end of the comment period, two (2) comments were received concerning the ESG program. The comments were reviewed and discussed at the division bureau level, staff level and management level, consideration was given to all comments received.

Based on comments received and input from the public hearings, it was determined that the eligible activities will be those identified.

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.

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.

PROPOSED ACTIVITIES

Discussion of Funding Priorities

HUD strongly encourages each State to give a high priority of its new ESG funding as possible on rapidly re-housing individuals and families move into and achieve housing stability. The State has allocated of the Second Allocation of FY11 ESG funds to be used for Rapid Re-housing Assistance. Effective rapid re-housing programs help people transition out of the homeless assistance system as quickly as possible, decreasing the number of persons who are homeless within the community. Rapid re-housing also ensures that emergency shelter resources are used to serve individuals and families with the most urgent housing crises.

The Mississippi Development Authority, Community Services Division (CSD) will set aside an allocation of $704,360.00 of ESG funds to the Rapid re-housing assistance program and MDA will consider among one or more of the Continuum(s) of Care as the program recipient(s). The State will reserve two percent ($16,211) to assist in the administration of the rapid re-housing funds.

PROPOSED ACTIVITIES

  • Housing Relocation and Stabilization Services
  • Short and Medium- Term Rental Assistance

ESG financial assistance cannot be provided to eligible individuals or families for the same period of time and for the same cost types, for which they are being provided assistance through another federal, state, or local housing subsidy program. These costs include, but are not limited to: rent payments, security deposits, utility deposits, utility payments, and moving cost assistance. For example, if a client is receiving rental assistance from another source (either a full or partial subsidy), ESG funds may not be used for rental assistance during that same time period.

SELECTION PROCESS FOR AWARD

The CoC(s) Selection process will consist of the following: The State will design a specific selection criteria that will be used to objectively select one or more of the CoC(s) based on the demonstration of the capacity to carry out rapid re-housing activities.

Written Standards for Provision of ESG Assistance

Written policies and procedures must address admission to assistance and services and must at a minimum: The first step in the ESG program activity is to determine client eligibility.

  1. Standard policies and procedures for evaluating individuals’ and families’ eligibility for assistance under ESG:
  1. Each “client” will have an initial consultation and eligibility assessment with a case manager who will determine eligibility and the appropriate type of assistance.
  2. Detail on determining AMI will follow the standards set by ESG.
  3. The household must be either homeless to receive rapid re-housing assistance or at risk of losing its housing to receive homeless prevention assistance, all in accordance with the HUD accepted definition of homelessness. Also this determination will also follow the “but for” guideline.
  4. These procedures will also use a standard intake form that will ascertain all household information; i.e., name, last address, social security number, age etc. and use of HMIS.
  1. 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.
  1. Sustainability is the key in prioritizing households for eligibility in this program. What is their work history? What is the reason for their situation now? Before this situation did the household demonstrate sound financial practices? What is their prospect for employment in the next 30 to 60 days? Will they need job training, GED or other training to assist them in bettering their chance for reentry into the job market? Do they demonstrate the willingness to take responsibility for achieving these necessary goals?
  2. Again, Homeless “But For” this assistance rule is used in determining eligibility.
  1. 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.
  1. The CoC determines the amount of short-term and medium-term rental and utility assistance provided, such as a developed sliding scale (payment of a portion of the rent etc. or graduated/declining subsidies) or payment of 100 percent of the rent charged. A grantee may also set a maximum amount of assistance that an individual or family may receive, or may set a maximum number of times that an individual or family may receive assistance, as long as the total amount of assistance that any individual or family receives does not exceed an amount equal to the limit established by ESG.
  2. As determined by the case manager through financial assessment, the household may be required to share in the cost of rent, utilities, security deposits and other expenses as a condition of receiving financial assistance.
  3. The case manager should determine the amount of assistance based on the minimum amount needed to prevent the household from becoming homeless or returning to homelessness in the near term, leading to secure sustainability.
  1. 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.
  1. The case manager will establish goals and standards with each household in accordance with ESG standards and regulations.
  2. The case manager will develop a list of client strengths. This will enable them to develop a service plan that will maximize their strengths to achieve sustainability as quickly as possible.
  3. For the success of these plans a face to face contact with the household will need to take place at least once a month if not more frequent.
  1. 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 the 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 participants receives assistance; or the maximum number of times the program participants may receive assistance.

With the previous areas addressed (a-e) these questions of (f) should be addressed on a case by case basis. However with looking at success rates throughout the country, most would agree that sustainability success takes 1 to 2 years with a range of 50 to 85% success rates relative to the time frame mentioned. The maximum amount of assistance again will be determined by each household’s service plan and the “sliding” scale according to household income.

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 the ESG program.

If the recipient is unable to meet the homeless participation requirement, it must instead develop and implement a plan to consult with homeless or formerly homeless individuals in considering and making policies and decisions regarding any facilities, services, or other assistance that receive funding under the ESG program

To the maximum extent practicable, the recipient or subrecipient must involve homeless individuals and families in constructing, renovating, maintaining, and operating facilities assisted under the ESG program. The involvement includes employment or volunteer services.

CENTRALIZED ASSESSMENT SYSTEM

Mississippi United to End Homelessness (Balance of State Continuum of Care)

(MUTEH) has developed a centralized assessment system as a part of implementation of the third year of HPRP funding. The centralized or coordinated assessment systems are important in ensuring the success of homeless assistance and homeless prevention programs in communities MDA will continue to work in consultation with MUTEH and the other CoC(s)in the continued development and use of a centralized assessment systemoutlined in the McKinney-Vento Act, as amended by the HEARTH ACT.

MUTEH, Inc. has implemented a centralized intake system to implement HPRP in the 3rd year of funding. When the contracts with our service providers ended, we developed a system that allowed the Jackson office to act as the assessment office for client assistance. When our case managers received a referral from local agencies or a client inquiry, they were instructed tell the client to call our Jackson office – or send a request through our website – to request services. The Case Managers could not schedule a client intake without first contacting our intake staff in the Jackson office who would conduct an initial assessment to determine eligibility. The client was asked a few key questions by our intake staff, which allowed them to make the determination as to whether or not HPRP could be an appropriate resource to assist the client. MUTEH is planning to develop an online tool – such as survey monkey – to assist with consistent intake assessments in the near future.

If the client could benefit from HPRP services, they were asked to fax or email some basic eligibility documentation to the intake worker. Once that information was received the intake worker assigned the client to a case manager and an appointment was made for the initial assessment for HPRP services. The intake worker loaded the documents in our HMIS system so the Case Manager had access to all eligibility information when the client arrived at their appointment. It is at the face to face interview appointment that the planning for case management begins and the allocation of financial assistance dollars could be made.

MONITORING PROCEDURE

MDA, Community Services Division, Grants Management Bureau, has developed monitoring procedures during the Homelessness Prevention and Rapid Re-Housing Program (HPRP). Additional procedures will be developed to allow sufficient monitoring standards and procedures for compliance with the new requirements of the ESG program.

Monitoring Procedures will look at the following areas of compliance:

  • Financial Management
  • Overall Grant Management
  • Sub-grantee Management
  • Program Participants
  • Housing Assistance
  • HMIS

Section 416(f) of the McKinney-Vento Act, as amended by the HEARTH Act requires projects receiving funding under ESG program must participate in the Homeless Management Information System (HMIS). With the HUD’s data collection, management, and reporting standards and will be used to collect client-level data and data on the provision of housing and services to homeless individuals and families and persons at-risk of homelessness. The data collected is essential to measuring what works and what doesn’t. Accurate HMIS data will enable HUD to gain more informed understanding of the problems of homelessness in our communities; the Continuum(s) of Care will assist in the participation of HMIS.