INDIANA HOMELESS PREVENTION AND RAPID RE-HOUSINGContinuum of CareEligible Populations

August 28, 2009

Indiana Housing and Community Development Authority

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IHCDA Community Services Staff Rodney Stockment, Manager

317.233.1814 rstockment@ihcda.in.gov

Lynn Morrow, Department Assistant 317.233.1810 lymorrow@ihcda.in.gov

Lori Dimick, Homeless Program Manager 317.232.7117 ldimick@ihcda.in.gov

Kelli Barker, ESG and HPRP Program Representative 317.233.4611 kbarker@ihcda.in.gov

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IHCDA Community Services Staff

Megan Maxwell, Special Needs Representative 317.233-1517 mmaxwell@ihcda.in.gov

Kirk Wheeler, HMIS and HPRP Project Director 317.709.3441 kiwheeler@ihcda.in.gov

Kelly Pickell, HMIS Program Representative 317.709.6447 kpickell@ihcda.in.gov

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Resources IN - HPRP Power Point Posted

http://www.in.gov/ihcda/3120.htm HUD – HPRP Notice and Webcasts – wealth of good information!

www.hudhre.info Virtual helpdesk and searchable FAQs

National Alliance to End Homelessness www.endhomeless.org Best Practices, guides

Corporation for Supportive Housing www.csh.org Information on permanent supportive housing

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Eligible PopulationsThe HPRP notice defines eligible participants as

having only moderate barriers to housing stability and as:

Being at or below the 50% AMI income levelBeing 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.

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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.

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Eligible PopulationsIn 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: ________________________________________________________________________

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Eligible PopulationsUsing 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: ________________________________________________________________________

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Eligible Populations:Persons graduating from or timing out of a

transitional housing programVictims of domestic violence

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Prevention, Diversion and Rapid RehousingIt 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.

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DefinitionsThe 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.

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Hearth ActThe 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 …”

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Hearth ActThe 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.

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Hearth ActAdditional requirements include:The individual or family has no subsequent

residence identified andThey 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,

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Hearth ActAdditional 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.

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Hearth ActAdditionally, 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.

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So –What does all this

mean?

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IHCDA and DiversionFor 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.

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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.

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PreventionThe 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.

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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)

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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.

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Housing Relocation and Stabilization: Ineligible Activities

Employment trainingEducation (i.e. fees, tuition, books, etc.)TransportationGeneral credit services, e.g. debt consolidation,

debt reduction negotiation or filing bankruptcy.Legal services unrelated to housing.

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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.

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HPRP