CoC RA Monitoring

1. CoC RA Monitoring Provider Meeting - March 20, 2019 Howard Burchman & Lauren Pareti Hburchman@HousingInnovations.us LPareti@HousingInnovations.us

2. Agenda • Monitoring Goals • Common Monitoring Findings • What to Expect During Monitoring • Recent Changes to DMHAS Monitoring Guide • Overview of Monitoring Guide • Provider Feedback and Suggestions • Tips and Tools to Avoid Common Findings • Preparing for HUD Monitoring • Questions and Answers

3. Compliance Training • Date: Thursday, March 21, 2019 • Location: Community Resource Team, 555 Windsor Street, Hartford, CT (Lumsden Room) • Session #1: Overview of Fiscal Components of Managing CoC Grants; 9:30 a.m. to 12:30 p.m. • Session #2: Focus on De Minimis Indirect Rate and Project Administrative Costs,  1:30 p.m. to 4:00 p.m. • Advance registration is required.   • To register for Session #1:https://www.eventbrite.com/e/managing-coc-grants-session-1-overview-of-fiscal-components-tickets-55455495881 • To register for Session #2: https://www.eventbrite.com/e/managing-coc-grants-session-2-focus-on-de-minimis-indirect-rate-and-project-administrative-costs-tickets-55455639310

4. Monitoring Goals

5. Monitoring Goals • Ensure projects are prepared for HUD monitoring visits; • Reduce the risk of funding recapture by HUD; • Support compliance with the DMHAS Permanent Supportive Housing Rental Assistance Administrative Plan, Federal and CT BOS requirements; and • Identify areas of need for training and technical assistance.

6. Common Findings

7. Common Findings Staff are: • Compassionate • Client-Centered • Caring • Creative in finding ways to build trust with and keep clients housed • Flexible in meeting clients needs • Navigating complicated and difficult situations with limited resources

8. Common Findings (2) • Projects not consistently and adequately conducting and/or recording: • Homeless and/or chronic homeless status • Frequency of services commensurate with need • Rent reasonableness determinations • Housing Quality Standards inspections • VAWA Notice and Lease requirements • Providers are unclear on amount of CoC funding received from DMHAS and what budget line items are funded, resulting in: • Insufficient documentation of expenditures and/or match • Inconsistent documentation of staff time per budget line items • Lack of understanding and documentation of administrative expenses

9. Common Findings (3) • Inconsistent understanding and implementation of Housing First • Compliance based service plan goals • Projects with no services funding serving chronically homeless and people with intensive service needs: • No assigned case manager • May only be contacted once per year • May be discharged for failure to engage • Unable to meet HUD and CoC requirements • Most have no protocol for regular internal chart audits.

10. What to Expect During Monitoring

11. Elements of Monitoring • Pre-visit documentation submission and review • Entrance/Exit Conferences • Participant Chart and Financial Record Review • Brief Program Tour • Staff and Client Interviews • Report & Follow-up Plan

13. Recent Changes to Monitoring Guide

14. Alignment with CSH QI Process • Coordinate scheduling to minimize multiple visits to CoC RA projects at same agency within a year - some exceptions. • Align standards

15. Indirect Costs – new itemIf using Indirect costs: • Does the recipient have a Negotiated Indirect Cost Rate Agreement? • Is recipient allocating costs consistent with the negotiated rate? • Does the recipient observe the expenditure limits for administrative funding at 578.59(a) – no more than 10% of the total grant amount? [578.63(c)] • Recipient is claiming the 10% de minimis indirect rate [200.414(F)] Has the recipient calculated the Modified Total Direct Costs in accordance with 200.68? • Does the recipient observe the expenditure limits for administrative funding at 578.59(a) – no more than 10% of the total grant amount? [578.63(c)]

16. Administrative + Housing Assistance new items • Record Retention: Retain records for the greater of 5 years or the period specified for special circumstances • General Health and Safety Checklist: Completed with tenant annually approx. 6 months following HQS during home visit. Observe and discuss potential hazards in home with tenant, ensuring plan to eliminate same and prevent accidents (available at www.ctbos.org)

17. Services – New (Best Practice Recommendations) • Assertive Engagement: Project makes regular attempts using a variety of methods • Upon reluctance to engage, strategies such as phone, text, in person, invites to rec. opportunities and attempts to provide concrete services are offered • Home Visits: Staff meets with client(s) in housing unit at least once every six months • Frequency commensurate with participant need • Less frequent visits supported by assessment

18. Services - new (2) (Best Practice Recommendations) • Housing Stabilization Services: Participants are educated about lease terms & assisted to avoid violations/eviction. Staff understand difference between their role and property manager/landlord’s role. • Service Plans for PSH: • Completed within 60 days of entry, updated every 6 months • Include specific and measurable action steps indicating responsible party and date • Goals are individualized and person-centered • Signed by staff, participant & supervisor • Case notes document that assistance with advancing goals/objectives is regularly provided to participants • Moving-On from PSH: Project assesses clients who have stabilized in housing for interest in and provides assistance with moving on, including applying for other affordable housing

19. Other Possible Changes • Selection of projects at agencies that have not previously been monitored • Increased use of remote monitoring: • Give HI time limited remote access to your electronic record system; or • Redact selected documents and submit to HI via Dropbox or email; or • Upload undredacted documents into client HMIS records.

20. Overview of Monitoring

21. Visual Observations • Financial records and valuables secured in limited access area • Client information maintained in confidential manner • Drug free work place statement posted • Units: adequate space, light, ventilation, etc.

22. Financial Requirements • Fiscal policies, procedures and records • Source and application of funds • Internal controls • Recording of expenses • Expense eligibility • Allocation of salaries to eligible CoC activities • Match

23. Administrative Requirements • Program Fees: May not charge any fees other than rent. • Homeless participation on board of directors • Client Bill of Rights • Nondiscrimination and Fair Housing • Conflicts of Interest

24. Reporting and Contract Requirements APR • Submitted within 90 days of program end date • Participate • Submit data for all clients HMIS Grant Amendment • Executed doc on file • Prior approval • Consistent with or above application Number of Clients • Adhere to HUD ER Requirements Environmental Review

25. Housing Assistance • CAN timely notification and referral • Housing Quality Standards • Leases, HAP Contract and Owner Assurances • Security Deposits and Damages

26. Housing Assistance (2) Rent Reasonableness • Must take place prior to lease-up • Must include 3 comparable units • Units must be in close proximity/same neighborhood as proposed rented unit and be comparable in size (sq. footage) and number of bedrooms • VAWA: • Prohibitions against discrimination • Compliance with Emergency Transfer Plan • Lease requirements and bifurcation • Required notices to each adult program participant at required times

27. Housing Assistance (3) • PSH Calculation of Occupancy Charges/Rent • Calculate rent properly • Use rent calculation spreadsheet • Be mindful of appropriate deductions and adjustments • Aligns with lease (e.g., rent amount, utility allowance, # of adults) • Income Review • Annually or when change in income • Timely annual recertification letter • Income, deductions, lack of income documented • Aligns with lease

28. Housing Assistance (4) Equal Access Regardless of household composition Family Change Allow to alter family composition change at any time **exceptions HouseholdChange Relocate to right-sized unit & services as appropriate Dwelling Size At least 1 bedroom &/or sleeping room per 2 ppl

29. Coordinated Entry and Eligibility • Use of CAN & Statewide By-Name List • Eligibility documentation – homeless status, chronic homeless status and disabling condition (latter 2, PSH only) • Written Intake Procedures • Sample available at www.ctbos.org

30. Services Services for PSH – supportive services are made available and tailored to the specific needs of program participants. Housing First – All PH projects follow HF principles (available at www.ctbos.org) Confidentiality – adequate procedures and releases Education - Designated Staff and updated Policies & Practices (available at www.ctbos.org) Termination and Discharge – meet HUD requirements

31. Provider Feedback and Suggestions

32. Tips and Tools to Avoid Common Findings

33. Tips and Tools • Ensure you are correctly billing Administrative Costs • Use cash match and don’t overcommit • For staff working on multiple projects, or budget line items, complete personnel activity logs • Supervisory review of eligibility documentation • Conduct regular internal chart review • Participant Chart Monitoring Prep Guidance (available at www.ctbos.org ) • CT BOS Monitoring Links to Helpful Resources • Be sure current staff are signed up to receive CT BOS emails -be sure to select “HUD Grantees”

34. HUD Monitoring

35. HUD Monitoring Exhibits • HUD monitoring exhibits available at: • http://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/handbooks/cpd/6509.2

36. HUD Monitoring Areas

37. HUD Requirements • CoC Interim Rule: • https://www.hudexchange.info/resource/2033/hearth-coc-program-interim-rule/ • OMB Circular A-87 (for governments) : • https://www.govinfo.gov/app/details/CFR-2012-title2-vol1/CFR-2012-title2-vol1-part225 • OMB Circular A-122 (for nonprofit organizations): • https://www.govinfo.gov/app/details/CFR-2012-title2-vol1/CFR-2012-title2-vol1-part230

38. Questions?

39. Contact Info Suzanne Wagner swagner@housinginnovations.us Howard Burchman hburchman@housinginnovations.us Lauren Pareti lpareti@housinginnovations.us Andrea White awhite@housinginnovations.us Myles Wensek mylesw@housinginnovations.us Liz Isaacs lisaacs@housinginnovations.us Shannon Quinn-Sheeran shannon@housinginnovations.us