INDIANA HOMELESS PREVENTION AND RAPID RE-HOUSING Continuum of Care Eligible Populations August 28, 2009 Indiana Housing and Community Development Authority

IN - HPRP IHCDA Community Services Staff  Rodney Stockment, Manager    Lynn Morrow, Department Assistant    Lori Dimick, Homeless Program Manager    Kelli Barker, ESG and HPRP Program Representative  

IN - HPRP IHCDA Community Services Staff  Megan Maxwell, Special Needs Representative    Kirk Wheeler, HMIS and HPRP Project Director    Kelly Pickell, HMIS Program Representative  

IN - HPRP Resources IN - HPRP Power Point Posted  HUD – HPRP Notice and Webcasts – wealth of good information!   Virtual helpdesk and searchable FAQs National Alliance to End Homelessness   Best Practices, guides Corporation for Supportive Housing   Information on permanent supportive housing

IN - HPRP Eligible Populations The HPRP notice defines eligible participants as having only moderate barriers to housing stability and as: Being at or below the 50% AMI income level Being presently homeless, according to the HUD definition of living in a shelter, being on the streets or living in a dwelling unfit for human habitation or Being at imminent risk of becoming homeless due to eviction or other defined event, e.g. utility shut-off.

IN - HPRP Eligible Populations: HUD defines imminent risk using the “but for” test. Ask if the eligible person or family would be homeless but for this assistance. HPRP funds cannot substitute for any other sources of emergency support. For example, if a family is eligible for Trustee support and could remain housed for another month with that support, they would not qualify for HPRP enrollment.

IN - HPRP Eligible Populations In every case, the HPRP definition requires that the person or family have no other available supports. This presumably includes family or friends. The HPRP notice does not consider “doubling up” to be an example of eligibility. There is not explicit detail about when crowding would be considered extreme enough to allow a person or family to be considered eligible. ___Concern: _________________________________________________________________________ Response: ________________________________________________________________________ ___Concern: _________________________________________________________________________ Response: ________________________________________________________________________

IN - HPRP Eligible Populations Using the HPRP Notice alone, the following persons are eligible for rapid rehousing financial assistance: Persons living in a shelter or temporary motel/ hotel room supported by an agency, Persons living in a place not meant for human habitation, e.g. on the street or in their vehicles (assuming that is not a $250,000 RV.) Persons staying in a hospital or other institution for up to 180 days who were homeless at admission ___Concern: _________________________________________________________________________ Response: ________________________________________________________________________ ___Concern: _________________________________________________________________________ Response: ________________________________________________________________________

IN - HPRP Eligible Populations: Persons graduating from or timing out of a transitional housing program Victims of domestic violence

IN - HPRP Prevention, Diversion and Rapid Rehousing It is clear that participants who meet the HUD definition of homelessness should receive Rapid Rehousing services. Less clear is what participants should be considered as requiring “diversion” to avoid imminent homelessness. Diversion is the category of interventions that directly and actively prevent a participant from entering into the homeless serving system, e.g. shelters.

IN - HPRP Definitions The distinction between prevention and diversion is important in the Indiana BOS HPRP because of the requirement that 65% of Financial Assistance be used for rapid rehousing. IHCDA intends to use the newly developed HEARTH Act definitions in assessing whether a subgrantee has met the requirement for 65% usage. The effect of this is to extend the definition of “homeless” to a broader population.

IN - HPRP Hearth Act The Hearth Act of 2009 (S 896) defines homelessness to include the existing HUD categories plus “an individual or family who will imminently lose their housing, including housing they own, rent, or live in without paying rent, are sharing with others and rooms in hotels or motels not paid for by Federal, state or local government programs …”

IN - HPRP Hearth Act The act defines evidence of imminent risk as: A court order resulting in eviction within 14 days. Living in a room in a hotel or motel where the person lacks the resources necessary to reside more than 14 days. Credible evidence that an owner or renter of the housing will not allow the individual or family to stay more than 14 days. 

IN - HPRP Hearth Act Additional requirements include: The individual or family has no subsequent residence identified and They lack the resources or support networks needed to obtain permanent housing. This requirement will normally mean that the participant has already accessed all possible family and friendship resources,

IN - HPRP Hearth Act Additional covered persons include: Unaccompanied youth and homeless families who have experienced a long term period without living independently in permanent housing, have experienced persistent instability as evidenced by frequent moves … and can be expected to continue in such status … because of chronic disabilities, chronic physical health or mental health conditions, substance abuse, … histories of domestic violence or multiple barriers to employment.

IN - HPRP Hearth Act Additionally, the act provides that “… any individual or family who is fleeing or attempting to flee domestic violence, dating violence, sexual assault, stalking or other dangerous or life-threatening conditions in the … current housing situation…” shall be considered to be homeless.

IN - HPRP So – What does all this mean?

IN - HPRP IHCDA and Diversion For the Indiana BOS HPRP, IHCDA will in part apply the Hearth Act definition to “homelessness.” This means that a wider variety of circumstances will be covered under the requirement that 65% of the financial assistance funds be spent on diversion and rapid rehousing. Diversion for the IHCDA HPRP means that a person or family has or is about to apply for entry into a shelter or other emergency housing program. Persons on waiting lists for family shelters would be eligible as would persons temporarily in hotel/motel housing provided by family, friend or church.

IN - HPRP _______________________________________________________________________ Direct Assistance: IHCDA will consider any financial assistance provided to persons meeting the HUD definition of homeless or the adapted HEARTH Act definition for diversion as being under the required 65% for “rapid rehousing.” This includes all eligible activities under the financial assistance category and not just rental assistance. Please understand that this will be an active and continuing discussion. For example, persons on a waiting list for Section 8 would not automatically qualify for diversion.

IN - HPRP Prevention The distinction between diversion and prevention for the purposes of the HPRP is probably the closeness of the threatened homelessness. In other words, the intent of the program remains addressing the needs of households with only moderate barriers to permanency. However, prevention does not necessary require that a housing crisis is imminent. IHCDA is concerned that this can become a “fuzzy” line between general welfare and trustee support and that legitimately intended by the HPRP.

IN - HPRP Target Prevention Populations: Households experiencing a sudden, significant and likely to be prolonged loss of income. Households with a severe housing cost burden (> 50% of income for housing costs.) Households with a young (under 25 y/o) single head of household with children under the age of 6. Households with extremely low incomes (< 30% of AMI) Households with severe medical debt (>$50,000)

IN - HPRP Housing Relocation and Stabilization: Prevention Participants Prevention participants should generally receive as intense case management as rapid rehousing participants. It should include linking participants to mainstream resources, including Section 8 application where appropriate. Goals need to be exclusively related to housing stability.

IN - HPRP Housing Relocation and Stabilization: Ineligible Activities Employment training Education (i.e. fees, tuition, books, etc.) Transportation General credit services, e.g. debt consolidation, debt reduction negotiation or filing bankruptcy. Legal services unrelated to housing.

IN - HPRP Handling Populations: Some sub grantees will have funds from IHCDA and from an entitlement city. Just as the funds cannot co-mingle for reporting purposes, neither can the participants who are assisted. This is in part because of HMIS limitations. In other words, once a participant is supported under one grant, he/she should receive all of their HPRP from that grant. HUD has determined that assistance can be provided across jurisdictional boundaries and we strongly urge that you obtain agreement to do so.

IN - HPRP Next Week’s Topics: Vendor contracts MOUs

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