HUD-VASH HUD - VA Supportive Housing Program

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HUD-VASHHUD-VASH

HUD - VA Supportive Housing ProgramHUD - VA Supportive Housing Program

The VA’s Role in HUD-VASH

HUD-VASH Operating Requirements

HUD-VASH Reporting Requirements

Project-Based Voucher (PBV) Requirements for HUD-VASH

VA and HUD Commitment

• VA is committed to the Federal Plan to Prevent and End Homelessness and is implementing a Five-Year Plan to Eliminate Homelessness among Veterans, which calls for coordinated strategic cooperation with our community partners

• VA and HUD have established the nation’s largest supported permanent housing initiative

• HUD and VA work together on the U.S. Interagency Council on Homelessness

HUD-VASH

The HUD-VASH Program combines:

• 30,000 Housing Choice vouchers to PHAsHave 301 participating PHAs

• Case management and supportive services to promote housing stability and recovery

Almost 1,000 case managers

In 2010, over 100 Substance Use Disorder

Specialists on VA case management teams

PARTNER RESPONSIBILITIES

VA HUD-VASH Case Managers determine clinical eligibility and homeless status

PHAs determine if the Veteran meets HUD criteria for income and is not a lifetime registered sex offender under a State sex offender registration program.

VA Eligibility Criteria

Eligible for VA Health Care

Homeless per McKinney Vento definition

Needs, and agrees to participate in, case management

Does NOT include the following:

Prior treatment or other homeless programsTreatment compliancePeriod of sobrietyIncome verification by VACriminal Background Check

McKinney Vento Definition of Chronic Homelessness

A chronically homeless Veteran is: • A VA healthcare eligible person who has been

• Continuously homeless for 1 year or more,

• At least four episodes of homelessness in the past 3 years

HEARTH Act The HEARTH Act amends McKinney Vento

• Changes include defining: – Prevention and re-housing

– Homelessness for families

– Allows specific doubled up housing situations

– Changes time-frame for transitional housingsituations from 30 days to 90 days

VA and HUD are working towards implementing the HEARTH Act in HUD-VASH

Assessment

Promoting a low barrier, engaging approach

• Veteran assessed using standardized assessment

o New HOMES template will be piloted soon

• Veteran to obtain Vesting physical, if needed

• Focus on issues related to housing stability

o Employment, income and legal assistance o Family/Social concerns

• Seek mental health and/ or Substance Use disorder evaluations, if Veteran agrees

“Housing First” Approach

Offers permanent housing with treatment & supportive services to homeless individuals

Early engagement/low demand model

Few requirements for treatment participation prior to housing

A model that allows us to target and assist the most chronically homeless

Priority and focus is on housing

http://www.endhomelessness.org/section/tools/housingfirst

Housing Recovery Plan

This plan reflects the goals of the Veteran, identifyingo Strengthso Barriers to maintaining housing placement

Establish a process to monitor the progress of the plano Housing stability (rent paid, following rules, etc)o Employment and income needs meto Legal and financial issues (credit history) resolvedo Physical, mental, social and substance

use health supported

PHA and Housing Process

Referral is made in writing to the PHA from the VA

Case manager assistance (if needed):

o Complete forms

o Work out transportation issues

o Locate suitable housing following PHA guidelines

o Request PHA inspection and approval of selected unit

o Address obstacles and barriers

o Facilitate communication between PHA and Veteran

Housing Placement

• Housing Assistance Payments (HAP) Contract issued by PHA to the landlord following passing unit inspection

• If indicated, case manager assists the Veteran and landlord to complete the lease

• Prepare for the move by helping Veteran

– Turn on utilities – Obtain furnishings and supplies– Plan and arrange move in

Completion

Case manager and Veteran meet with PHA to discuss successful graduation from case management

If PHA has a regular Housing Choice Voucher (HCV) available for the Veteran, then the veteran will convert to the HCV program, and the HUD-VASH voucher will become available for another eligible homeless Veteran

If PHA does not have a regular voucher available, the Veteran continues using the HUD-VASH voucher until it is no longer needed

HUD-VA High Priority Goal

Place 30,000 Veterans in HUD-VASH permanent housing

Time period: October 1, 2009 – June 30, 2012

Report to Office of Management and Budget on a quarterly basis – FY 11 metrics expected to stay the same

• # of referrals from VAMCs to PHAs• # of vouchers issued to families• # of units leased

HUD-VA High Priority Goals

Strategies for meeting High Priority Goals

Improve reporting tools Produce monthly reports on progress Monitor PHA and VA progress toward goals Conduct on-site reviews for high and low performers Establish action plans for improvement Determine best practices in use Involve multiple training strategies and opportunities Improve evaluation tool

VOUCHERAWARDS

30 - 95

145 - 200

215 - 370

405 - 585

605 - 4,680

ALLOCATION OF HUD-VASH VOUCHER AWARDSFY 2008 - FY 2010

Total Allocated Vouchers: 29,500

CA4,680

FL2,665

NY2,505

TX2,005

GA1,075

PA1,020

NV585 IL

Guam30

Puerto Rico80

HUD-VASH Operating Requirements

Published in the Federal Register on May 6, 2008, but part of the section on portability/mobility was not included.

The missing section was published in the Federal Register on May 19, 2008.

The complete text can be found at:• http://www.hud.gov/offices/pih/programs/hcv/vash/

Operating Requirements

• Normal HCV requirements at 24 CFR 982 apply to HUD-VASH vouchers unless they are waived or an alternative requirement has been specified, as discussed in this presentation.

HUD-VASH Eligibility

• The VA first identifies homeless veterans and determines initial eligibility.

• Unlike the earlier HUD-VASH program from the 1990s, veterans are not required to be chronically mentally ill or have chronic substance abuse disorders.

• All eligibility screening is conducted by the VAMC, except for income eligibility and sex offender status.

• Homeless veterans must agree to participate in case management in order to receive a HUD-VASH voucher.

• After VAMC screening determines a veteran is initially eligible, the veteran is referred to the PHA.

• Written documentation of the referrals must be maintained in the tenant file at the PHA.

• Veterans found eligible by the PHA will be issued a voucher.

Denial of Assistance

• If assistance is denied, the PHA must promptly send the denial notice that states the reason and provides for an informal review.

• A copy of this notice must be sent to the veteran’s VAMC case manager.

PHA Screening

• PHA screening limited to:– Income eligibility– Lifetime registration under a state sex offender

registration program.• Under portability, the receiving PHA must also

comply with the HUD-VASH screening procedures.

Prohibited Screening Criteria

At the time of admission, PHAs may not determine eligibility or deny assistance for the following:

• Homeless status• Money owed to the PHA• Criminal or drug activity(This prohibition applies to all family members at

the time of admission.)

Income Eligibility

• The PHA determines eligibility in accordance with 24 CFR 982.201.

• Income targeting requirements do not apply to HUD-VASH vouchers.

(However, PHAs may choose to include the admission of extremely low income HUD-VASH families in their income targeting numbers for the year the family admitted to HUD-VASH.)

Lifetime Sex-Offender Status

• If the homeless veteran is subject to a lifetime-sex offender registration requirement under a state program, the PHA cannot issue a voucher.

• If another family member is the lifetime registrant, the family may be eligible if that family member is removed from the household.

Initial Search Time

• HUD-VASH families must have a housing search term of at least 120 days.

• Any extensions, suspensions and progress reports will remain under policies in the PHA’s administrative plan, but will apply only after 120 days.

Initial Lease Term

• The initial lease term may be less than 12 months, even if this is not the prevailing market practice .

Eligible Housing

• All housing types eligible in the regular HCV program including special housing types such as SROs, congregate housing and group homes.

• Standard HCV requirements regarding unit size, HQS and payment standards apply.

Eligible Housing

• Unlike regular HCV participants, HUD-VASH families may live on the grounds of a VAMC in units owned by the VA.

Case Management

• Participation in case management is an eligibility requirement of the HUD-VASH program.

• HUD-VASH assistance may be terminated if the family refuses, without good cause, to participate in required case management as verified by the VAMC.

When Case Management is no longer required:

• However, a VAMC’s determination that case management is no longer needed is not grounds for termination of HCV assistance.

• When such a determination occurs, a family may be offered a regular voucher to free up the HUD-VASH voucher for another eligible homeless veteran.

Turnover of HUD-VASH Vouchers

• Upon turnover, HUD-VASH vouchers must continue to be issued to eligible veteran families referred by the VAMC.

• Since leasing of HUD-VASH vouchers will be dependent on referrals from the VAMC, the unit months and budget authority associated with the vouchers will NOT be included in the SEMAP leasing indicator.

• Utilization of HUD-VASH vouchers will be monitored separately.

Mobility/Portability Policies

• Are dependent on whether the family moves within or outside of the referring VAMC’s catchment area.

Move Within a VAMC’s Catchment Area

• The HUD-VASH family can move under portability within the referring VAMC’s catchment area if the same VAMC continues to provide case management.

• Some VAMCs have more than one partner PHA.• If the receiving PHA did not have its own

allocation of HUD-VASH vouchers, the receiving PHA MUST BILL the initial PHA.

• If the receiving PHA has its own allocation of HUD-VASH vouchers, the receiving PHA may either absorb the family or bill the initial PHA.

• In either case, the VA must be consulted prior to the move and agree that case management services will be provided.

• Non-VASH PHAs should be advised of program requirements including using the HUD-VASH code when preparing the form HUD-50058 for the family.

• They should also be given the name and contact information for the veteran’s VA case manager.

Move OUTSIDE the catchment area of the referring VAMC

• A HUD-VASH family can move to another HUD-VASH catchment area, if the referring VAMC confirms that the new HUD-VASH VAMC has an available case management slot and the new VAMC’s partner PHA has an available HUD-VASH voucher.

Move OUTSIDE the catchment area of the referring VAMC

• HOWEVER, the receiving HUD-VASH PHA must use one of its HUD-VASH vouchers to absorb the family.

MTW Agencies

• HUD-VASH vouchers must be administered in accordance with HUD-VASH notices.

• Not eligible for fungibility under an agency’s MTW agreement.

• Must be reported separately from MTW vouchers, using the regular form HUD-50058.

• HUD-VASH Housing Assistance Payments (HAP) funds may not be used to support a greater number of unit months than have been awarded for the PHA’s HUD VASH program under the PHA’s ACC.

• PHAs must track HUD-VASH HAP funding separately from other HCV HAP funding.

HUD-VASH HAP Funding

Voucher Management System (VMS) Reporting

• HUD-VASH vouchers leased and HUD-VASH HAP expenses are to be reported to VMS monthly using the appropriate VMS fields.

VMS Records & Quality Review

• Each PHA must retain appropriate records to support VMS submissions as they are subject o on-site review by HUD.

• VMS data are subject to review by our Quality Assurance Division (QAD).

VMS Quality Review

• Recalculation will occur if a QAD review demonstrates that costs were incorrectly reported resulting in excess funding.

HUD-VASH Renewal Funding For Existing Programs

Renewals are based on leasing and cost data.The FY’08 HUD-VASH vouchers have been

renewed.The FY’09 HUD-VASH vouchers will be renewed in

Calendar Year 2011.

HUD-VASH Renewal Funding For Existing Programs

HUD will schedule a separate broadcast on HUD-VASH funding renewal issues.

Administrative Fees

• Administrative fees are based on the unit months leased as reported in VMS.

• Administrative fees are advanced on a monthly basis.

• The amount advanced is based on the most recent validated month of VMS data.

Administrative Fees

• HUD-VASH administrative fees are included with the HCV fees that are sent out monthly.

HUD-VASH and FSS

• HUD-VASH participants may benefit from participation in the HCV/FSS program.

• FSS coordinators should coordinate with VA case managers to obtain appropriate training and services for the HUD-VASH participant.

Voucher Homeownership Option

• HUD-VASH participants may participate in the HCV Homeownership option.

Frequently Asked QuestionsFrequently Asked Questions

If a veteran is interested in participating in the HUD-VASH program, who should he or she contact?Any interested homeless veterans should

contact their local VAMC directly. HUD has posted a list of VAMCs and participating PHAs on the HUD-VASH website.

Is it acceptable for the VA case managers to review original documents on the PHA's behalf? The PHA is responsible for income and citizenship

verifications. The case manager may compile the documents and look them over, but the PHA has the final say regarding their appropriateness.

Can the PHA deny admission to an adult family member, other than the veteran, based on the previous behavior of that family?No. The prohibition against screening families

for anything other than lifetime sex offender status applies to all family members, not just the veteran.

Can a veteran receive assistance through both the HUD-VASH program and the Homelessness Prevention and Rapid Re-housing Program (HPRP)?Six types of HPRP assistance are available for

eligible families or individuals: security deposits, utility deposits, rental assistance, utility assistance, moving cost assistance, and hotel/motel vouchers.

● Families or individuals cannot receive duplicative forms of assistance from Federal, state or local subsidy programs.

● Therefore, families participating in the HUD-VASH program cannot receive HPRP rental or utility assistance, but they are eligible to receive HPRP assistance for security deposits, utility deposits, and moving costs.

While HUD-VASH families cannot receive HPRP rental or utility assistance, HPRP can be used to help the household pay for up to 6 months of back payments on rent or utilities owed from previous housing situations.

For more information on HPRP and local agencies that administer the program, visit the HPRP website at http://www.hudhre.info/HPRP/.

Frequently Asked QuestionsFrequently Asked Questions What procedures must the PHA follow when adding a

member to the assisted HUD-VASH family?The provisions of 24 CFR 982.551(h)(2) apply

when a family member is added after occupancy.

Other than the birth, adoption, or court-awarded custody of a child, any other family member must be approved in accordance with the PHA’s policies.

What happens when a veteran, as the head of household of a family with a HUD-VASH voucher, commits an act of domestic violence?The Department is currently developing guidance

that will provide PHAs with further guidance on the implementation of VAWA protections under 24 CFR part 5, subpart L.

Until such guidance is available, PHAs should keep in mind the following points:

● When a veteran’s family member is receiving protection as a victim of domestic violence, dating violence, or stalking, and the veteran is the perpetrator of such violence, the victim must continue to be assisted.

● Dating violence, domestic violence, and stalking are each violations of the family obligations under 24 CFR 982.551(l). Therefore, the perpetrator may be terminated from assistance for committing such acts.

● Upon termination of a perpetrator’s HUD-VASH voucher due to the perpetrator’s acts of domestic violence, the victim receiving protections should be given a regular HCV if one is available.

● The perpetrator’s HUD-VASH voucher should be used to serve another eligible veteran family.

● If a regular HCV is not available for the victim, the victim will continue to utilize the HUD-VASH voucher.

● In the case of the victim utilizing the HUD-VASH voucher upon termination of the perpetrator, this HUD-VASH voucher must be issued to another eligible veteran family upon the voucher’s turnover.

Can a participant use a HUD-VASH voucher to move long distance? For example, a HUD-VASH voucher wants to move from California to Florida.This type of move is permissible if the Florida

VAMC can serve the family and its partnering PHA has an available HUD-VASH voucher. The receiving PHA in Florida must absorb the family.

When a HUD-VASH family no longer needs case management and can convert to the regular HCV program, is the family subject to the PHA’s waiting list?

No, the family is not subject to the PHA’s waiting list, because the family is already a participant in the PHA’s HCV program.

If a HUD-VASH family is denied assistance or has its assistance terminated, is it entitled to an informal review and informal hearing, respectively? Yes. Families are entitled to an informal review or

hearing in accordance with the PHA’s administrative policies, and in accordance with 24 CFR 982.554 or 982.555, as applicable.

What happens to the voucher if the homeless veteran dies?The PHA could use one of its own vouchers, if

available, to continue assisting this family and free up the HUD-VASH voucher for another veteran family.

If a regular voucher is not available, the family would continue utilizing the HUD-VASH voucher.

Once the HUD-VASH voucher turns over, however, it must go to a homeless veteran family.

What happens to the voucher if there is a divorce?Since the set-aside of HUD-VASH voucher is for

veterans, the voucher must remain with the veteran in the case of a separation of divorce.

Can a PHA terminate a family at the time of a reexamination for a violation that occurred before the HUD-VASH program?

Example: The family owes money to the PHA. The PHA cannot deny admission for that reason, but would like to terminate the family at reexam time.

A PHA cannot terminate a family for a reason that cannot be used for denying admission.

However, a HUD-VASH family can be terminated for program violations that occur after the family is admitted to the HUD-VASH program.

Prior to any termination action, the PHA is strongly encouraged to contact the VA case manager to determine if there are extenuating circumstances that should be considered to avoid the termination.

Can a PHA refuse to readmit veterans that have been terminated from the HUD-VASH program due to serious lease violations, program fraud, criminal activity, etc?In accordance with the HUD-VASH Operating

Requirements, a PHA cannot deny HUD-VASH assistance to a veteran for any grounds under 24 CFR 982.552 and 982.553.

Therefore, for any reason other than a member of the household being subject to a state lifetime registration requirement, the PHA may not deny HUD-VASH assistance to a veteran that is re-referred by the VA case manager.

In order to avoid such cases, prior to the PHA’s termination of the veteran, HUD recommends that the PHA contact the VA case manager to discuss the reasons for the veteran’s potential termination.

Frequently Asked QuestionsFrequently Asked QuestionsPHA and VA case manager should work together to

agree on the appropriate action and determine if termination of the veteran’s assistance can be avoided.

If it is decided that termination is the appropriate action, the PHA staff and VA case manager should discuss the circumstances under which, if any, the VA may choose to re-refer the veteran family.

What safeguards has HUD put in place to ensure VASH funding continues to be available to homeless veterans upon turnover of a HUD-VASH voucher? HUD will track these vouchers in the Public and

Indian Housing Information Center (PIC) system, through an additional code (VASH) on the family report (Form HUD- 50058).

Will HUD-VASH vouchers be fully renewed? It is the Department’s intent to fully renew all HUD-

VASH vouchers. However, such renewals are always subject to Congressional appropriations.

HUD-VASH Reporting Requirements

• HUD issued PIH Notice 2010-12 on April 13, 2010.

• The notice has been posted to the website for HUD-VASH:

• http://www.hud.gov/offices/pih/programs/hcv/vash/

Initial PHA

• The initial PHA is the PHA that partners with the VA Medical Center and issues vouchers when a homeless veteran family is referred

• The initial PHA will either deny the family assistance or issue a voucher.

Issuance of Voucher

• If the PHA issues a voucher to the family, the PHA must enter a 50058 report into PIC where line 2a=10 (Issuance of Voucher) and VASH is recorded on line 2n.

• In cases of portability, a receiving PHA must issue a voucher of its own and is required to enter a 50058 report into PIC for action code 10.

Leasing by Initial PHA

• When the family is leased by the Initial PHA, a 50058 must be entered into PIC with action code 2a=1.

• The VASH code must be maintained on line 2n throughout the participation of the family.

Leasing by Receiving PHA

• In cases of portability, the receiving PHA must enter action code 2a=1 (new admission) if this is the initial lease-up or 2a=4 (port-in).

• The receiving PHA must continue to enter VASH on line 2n.• The receiving PHA MUST always bill the initial PHA for tracking

purposes. • If the receiving PHA also has been awarded HUD-VASH

vouchers , it can absorb the family if case management can be provided.

Long Distance Portability

• Applies to families that move out of the catchment area of the original VAMC

Reporting requirements for the receiving PHA are the same.

• However, these families must be absorbed

Portability Attachment

• There is an Attachment to Portability form for the HUD-VASH program also available on the HUD-VASH website with reporting and alternative requirements for the receiving PHA

HUD-VASH Project-Based Vouchers

• HUD published PIH 2010-23 on this subject effective June 25, 2010

Limits on HUD-VASH PBV Units

• No more than 50 percent of a PHA’s HUD-VASH allocation of tenant-based vouchers may be project based.

• HUD-VASH PBV units are counted in the maximum 20 percent of voucher budget authority that may be project based.

HUD-VASH PBV Proposals

• Headquarters must approve a PHA’s proposal to project base HUD-VASH voucher units.

• Proposals may be for existing, new construction and substantially rehabilitated units.

• PHA PBV proposals must be supported by the VAMC.

Proposal Information

• Why the PHA wants to project-base these vouchers rather than providing tenant-based assistance.

• Success rate of HUD-VASH voucher holders and other voucher holders

• Utilization rate in SEMAP87

Proposal Information cont’d

• Amount of time, if any, HUD-VASH vouchers would be shelved for development

• A description of the project (details in notice)

Continued Assistance for Families that Move

• PBV regulations provide that a family may terminate the lease anytime after the first year of occupancy.

• Also, the PHA must offer the family continued tenant-based assistance in the form of a voucher or comparable tenant-based rental assistance.

Continued Assistance - 2

• A HUD-VASH family that no longer requires case management cannot be terminated for this reason.

• The PHA may offer the family a regular voucher to free up the HUD-VASH voucher.

• If there is no regular voucher available, the family retains its HUD-VASH voucher.

a. If a HUD-VASH voucher is not available at the time the family wants to move, the PHA could require the family to wait 180 days for a HUD-VASH voucher.b. If a HUD-VASH voucher is still not available, the family must be allowed to move and the PBV assistance would be replaced with a regular voucher assistance unless the unit is taken out of the PBV contract.

c. If after 180 days, a HUD-VASH voucher does not become available and the PHA does not have sufficient funding to attach assistance to the PBV unit, the family may be required to remain in its PBV unit until such funding becomes available.

HUD-VASH PBV Set Aside Funding

• HUD will make available approximately 500 PBVs for HUD-VASH families

• Funding will be competitive• PHAs can request no more than 50 PBVs• These PBVs will not count against the 50% limit

that a PHA can project-base now.

HUD-VASHHUD-VASH

THANKS, AND KEEP UP THANKS, AND KEEP UP THE GOOD WORK!THE GOOD WORK!

HUD-VASH HUD - VA Supportive Housing Program

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