HUD Waiver Question & Answer Session - April 6, 2020
This session provides an overview of HUD waivers, their applicability, and the process to apply for waivers. Learn about the documentation requirements and HUD's regulatory waivers for CoC, ESG, and HOPWA programs. Explore the HUD Waiver released on March 31, 2020, by HUD's Office of Community Planning and Development (CPD) for formula programs and program-specific waivers.
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Presentation Transcript
HUD Waiver Question & HUD Waiver Question & Answer Session Answer Session April 6, 2020 3:30-4:30pm
This webinar will begin in 15 minutes For audio via telephone United States: : +1 (213) 929-4232 Access Code: 181-946-877 Audio PIN: Shown after joining the webinar
This webinar will begin in 10 minutes For audio via telephone United States: : +1 (213) 929-4232 Access Code: 181-946-877 Audio PIN: Shown after joining the webinar
This webinar will begin in 5 minutes For audio via telephone United States: : +1 (213) 929-4232 Access Code: 181-946-877 Audio PIN: Shown after joining the webinar
This webinar will begin soon For audio via telephone United States: : +1 (213) 929-4232 Access Code: 181-946-877 Audio PIN: Shown after joining the webinar
HUD Waiver Question & HUD Waiver Question & Answer Session Answer Session April 6, 2020 3:30-4:30pm
Questions/Chat Questions/Chat All lines are muted Use the Question/Chat Box to submit questions, ideas, comments, resources, etc.
Goals Goals Overview of the HUD Waivers & Applicability Ability to apply for a waiver Understanding of documentation for waiver
HUDs Regulatory Waivers for HUD s Regulatory Waivers for CoC ESG & HOPWA ESG & HOPWA CoC, ,
Overview of the HUD Waiver Overview of the HUD Waiver Released on March 31, 2020 (announced April 1, 2020) HUD s Office of Community Planning and Development (CPD) Formula programs and program-specific waivers for the following CPD programs: Continuum of Care(CoC); Emergency Solutions Grant(ESG); and Housing Opportunities for Persons with AIDS(HOPWA). These waivers are intended to prevent the spread of COVID-19 and to facilitate assistance to eligible communities and households economically impacted by COVID-19. Effects participants enrolled or housing entered into after March 31, 2020
HUD Waiver Breakdown by Program Type HUD Waiver Breakdown by Program Type CoC ESG HOPWA Con Plan 7 Waivers 4 Waivers 4 Waivers 2 Waivers City of Chicago or direct Grantees CoC Program Grantees City of Chicago City of Chicago
HUD Waiver Breakdown by Program Type: HUD Waiver Breakdown by Program Type: Consolidated Plan Consolidated Plan Normal: 30 Days Waiver: 5 days Citizen Participation Public Comment Period for Consolidated Plan Amendment Normal: Follow Citizenship Participation Plan Waiver: Requirement waived Citizen Participation Reasonable Notice and Opportunity to Comment
HUD Waiver Breakdown by Program Type: HUD Waiver Breakdown by Program Type: Emergency Solution Grants (ESG) Emergency Solution Grants (ESG) Normal: Costs to HMIS Lead Waiver: Costs to any recipient HMIS Lead Activities Re-evaluations for Homelessness Prevention Assistance Normal: Every 3 months Waiver: Once every 6 months Normal: Monthly Waiver: As needed Housing Stability Case Management Restriction of Rental Assistance to Units with Rent at or Below FMR Normal: At or below FMR Waiver: Can be above
HUD Waiver Breakdown by Program Type: HUD Waiver Breakdown by Program Type: HOPWA HOPWA Self-Certification of Income and Credible Information on HIV Status Normal: Income & HIV Status documented Waiver: Self-certify income and credible HIV. Obtain documentation within 3 months post-COVID crisis Normal: Use FMR Waiver: Does not need to use FMR but be reasonable for 1 year after HUD Memo FMR Rent Standard Normal: Must meet HQS Waiver: Visually inspect and reinspect post-COVID crisis for 1 year after HUD Memo Property Standards for TBRA Normal: Adequate space & security for self and belongings Waiver: Can use optional space for households affected by COVID-19 Space and Security
HUD Waiver Breakdown by Program Type: HUD Waiver Breakdown by Program Type: Continuum of Care Continuum of Care Normal: Units paid with leasing (BLI) cannot exceed FMR Waiver: FMR is waived for TH & PSH executed leases. Rent must be reasonable. For 6 months from HUD memo. Fair Market Rent for Individual Units & Leasing Costs Normal: Must document disability within 45 days after intake worker observation Waiver: Documentation is not required. 6 months from HUD memo. Self- certification is sufficient. Disability Documentation for PSH Normal: Eligible costs include credit counseling, accessing a free personal credit report, and resolving personal credit issues Waiver: Funds may be used for utility arrears and rent arrears(up to 6 months), when those arrears make it difficult to obtain housing. 1 year from HUD memo Limit on Eligible Housing Search and Counseling Services Normal: Required monthly meeting with case manager Waiver: Provide case management as needed; 2 months from date of HUD memo Rapid Re-housing Monthly Case Management
HUD Waiver Breakdown by Program Type: HUD Waiver Breakdown by Program Type: Continuum of Care Continuum of Care Normal: Physically inspect any leasing or rental assistance unit for HQS Waiver: Inspect using technology and reinspect physically post- COVID within 3 months. For 6 months from HUD memo date. Housing Quality Standards (HQS) Initial Physical Inspection of Unit Normal: Annual inspection to ensure HQS Waiver: Waived for 1 year from HUD memo date. HQS Re-Inspection of Units Normal: PSH units must have a one year lease term that is renewable and terminable for cause Waiver: Initial lease term must be for at least one month. 6 months from HUD memo One-Year Lease Requirement
Applying for the HUD Waiver Applying for the HUD Waiver
Steps for the HUD Waiver Steps for the HUD Waiver 1. Determine which waiver(s) you will use 2. Determine when you wish to start using the waiver(s) 3. Complete written notification to send to HUD 4. Send written notification to local HUD office 5. Implement waiver(s) & document written justification for their use 6. Obtain documentation when COVID crisis ends
Steps for the HUD Waiver Steps for the HUD Waiver 1. Determine which waiver(s) you will use Review Availability of Waivers of CPD Grant Program and Consolidated Plan Requirements to Prevent the Spread of COVID-19 and Mitigate Economic Impacts Caused by COVID-19 Review Guidance from All Chicago 2. Determine when you wish to start using the waiver(s) You can start using the waiver 2 calendar days after you send your notification to HUD.
3. Complete written notification to send to 3. Complete written notification to send to HUD HUD Appendix A lists the required elements for the notification to HUD Requestor s name, title, and contact information; Declared-disaster area(s) where the waivers will be used; Date on which the grantee anticipates first use of the waiver flexibility; and A list of the waiver flexibilities the grantee will use: PROTIP: Use the HUD Waiver Notification Template created by All Chicago
3. Complete written notification to send to 3. Complete written notification to send to HUD HUD Sample Written Notification to HUD
4. Send written notification to local HUD office 4. Send written notification to local HUD office All notifications for Chicago & Illinois are sent to the Chicago HUD CPD Office CPD_COVID-19WaiverCHI@HUD.gov
5. Implement waiver(s) & document written 5. Implement waiver(s) & document written justification for their use justification for their use 1. Start using the waiver(s) 2 calendar days after notifying HUD. 2. Update your program records to include written documentation of the specific conditions that justify your use of the waiver, consistent with the justifications and applicability provisions Used for each time that each waiver is used Consider Interim Recordkeeping Protocol Template as a guide.
6. Obtain documentation when COVID crisis 6. Obtain documentation when COVID crisis ends ends 1. Public health department determines COVID crisis has ended. 2. Obtain documentation for waivers that require it Examples: HQS (CoC, HOPWA), Income & HIV (HOPWA)
Questions & Answers Questions & Answers
THANK YOU! THANK YOU! Contact us at CoCPrograms@allchicago.org