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					                Sonoma County

   Community Development Commission
                1440 Guerneville Road,
                Santa Rosa, CA 95403


             Subrecipient Handbook
                      For
          CDBG, HOME and ESG Funding




                   Public Service
       Countywide and Unincorporated Projects
City/County-Owned Public Facilities and Improvements
          Affordable Housing Development
                Home Rehabilitation
                                               Table of Contents

A. General ........................................................................................................................... 4
   National Environmental Policy Act (NEPA) ....................................................................... 5
   CDBG Program................................................................................................................. 7
     Eligible Public Service Activities .................................................................................... 7
     Ineligible Public Service Activities ................................................................................. 8
     Homeowner Rehabilitation ............................................................................................ 8
   ESG Program ................................................................................................................... 9
     Eligible Uses of ESG Funds .......................................................................................... 9
     Homeless Participation Requirement ............................................................................ 9
B. Sample Required Policies ............................................................................................10
   Policies, Procedures and Plans .......................................................................................11
   Conflict of Interest Policy .................................................................................................11
   Sample Non-Discrimination Policy ...................................................................................11
   Grievance Policy ..............................................................................................................12
   Section 504 Requirements ...............................................................................................12
   EEO State and Policy Prohibiting Illegal Discrimination and Harassment ........................13
   Procurement Policy ..........................................................................................................14
   Minority & Women’s Business Enterprise Outreach Policy ...............................................15
   Limited English Proficiency Policy (LEP) ..........................................................................16
   Language Access Plan (LAP) ..........................................................................................17
C. Reimbursement Requests ............................................................................................18
   Subrecipient Reimbursement Request Instructions ..........................................................19
   Subrecipient Reimbursement Request .............................................................................20
   Reimbursement Request Summary .................................................................................21
D. Reporting.......................................................................................................................22
   Quarterly Reporting Due Dates ........................................................................................23
   Ethnicity and Race ...........................................................................................................24
   Etnicidad Y Raza .............................................................................................................25
   Ethnicity and Race Definitions .........................................................................................26
   Certification of Family Income ..........................................................................................27
   Certificacion de Ingresos de Familia ................................................................................28
   Quarterly Status Report ...................................................................................................29
     Public Service Projects.................................................................................................29
     ESG Addendum ...........................................................................................................31
     Fair Housing Addendum...............................................................................................32
     Economic Development Addendum .............................................................................33
     County/City-Owned Public Facility & Improvement Projects .........................................34
      Countywide and Unincorporated Area Projects ............................................................35
      PART II - Summary of Other Funding Sources .............................................................37
E. Monitoring .....................................................................................................................38
   Monitoring Objectives ......................................................................................................39
   Nonprofit Financial Records .............................................................................................40
   Payroll Pamphlet..............................................................................................................40
     Basic Requirements .....................................................................................................40
     Allowability ...................................................................................................................41
     References...................................................................................................................41
     Time Sheet Example A.................................................................................................42
     Time Sheet Example B.................................................................................................43
   Monitoring Questionnaire .................................................................................................44
     I. Program and Facility Operations ...............................................................................44
     II. Record Keeping .......................................................................................................45
     III. Non-Discrimination ..................................................................................................45
     IV. Property Management ............................................................................................45
     V. Financial Management Systems ..............................................................................45
   HMIS Agency Data Standards Compliance Checklist v 1.0 ..............................................47
F. HMIS ...............................................................................................................................49
   Homeless Management Information System ....................................................................50
           A. General




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                      National Environmental Policy Act (NEPA)

                        Requirements for HUD Funded Projects

All Subrecipients awarded HUD funding must obtain environmental clearance under the National
Environmental Policy Act (NEPA) prior to incurring costs, executing agreements or expending any
funds on the project. The cost of completing the appropriate level of environmental review is an
eligible expense and may be paid with the allocated funds, whether the environmental work is
completed in-house or by a consultant. Commission staff will determine the appropriate level of
environmental review required at the time project proposals are submitted for funding. All projects that
are allocated funding in the Action Plan must have the appropriate Environmental Review (ER)
completed by October 1st of that program year. Projects designated as contingency projects must
have the ER completed within three months of the written notification of funding availability. Once the
Board of Supervisors adopts the Annual Action Plan; work may begin on the ER to ensure completion
by October 1. The Commission maintains a contract with an environmental consultant to prepare
environmental reviews. If a subrecipient elects to have the environmental consultant complete the ER,
the October 1 deadline is waived.

Projects funded by the Community Development Commission typically fall into one of three
categories: Exempt, Categorically Excluded and Environmental Assessment. Projects that require an
Environmental Impact Statement are generally not funded due to the limitation of available project
funding.

Exempt Projects

Projects that are Exempt are, for the most part, public services that will not have a physical impact or
result in any physical changes, including but not limited to services concerned with employment, crime
prevention, child care, health, drug abuse, education, counseling, energy conservation and welfare or
recreational needs. Commission staff will prepare all documentation required by HUD for projects
exempt from the NEPA requirements.

Categorically Excluded Projects

Projects that are Categorically Excluded fall into one of two sub-categories: those subject to additional
laws and authorities, and those that are not. Projects that have little or no physical impact, such as
tenant-based rental assistance, supportive services to low-income individuals and associated
operating cost, homebuyer assistance and some affordable housing pre-development expenses are
not subject to the additional laws and authorities, and much like exempt projects, Commission staff
will prepare all documentation required by HUD for the projects.

Environmental Assessments

More extensive projects, such as new construction, must undergo a more thorough environmental
review in the form of an Environmental Assessment. This assessment includes the consideration of
other laws and authorities contained in the statutory worksheet, plus an additional evaluation of the
impact the project will have on several facets of the human environment. The resultant study must be
offered for public comment, and a formal request for release of funds submitted to HUD. An
environmental assessment may be undertaken in-house, but the Commission strongly recommends
that Subrecipients retain a professional third party environmental consultant to complete the

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environmental assessment if the project is subject to that level of analysis. The aforementioned
timeline applies to environmental assessments as well.

Commission staff will publish all required notices and obtain releases from HUD appropriate to the
scope of the project. Some construction-related projects are undertaken in phases such as
acquisition, design and predevelopment and finally, the actual construction. The expenditure of CDBG
funds on the early stages is eligible only in relation to the eligibility of the completed project.
Therefore, the environmental review process appropriate for the completed project must be
undertaken for any phase of the project allocated funding.

The NEPA environmental review requirements are specific to each individual project. Please
consult with Commission staff regarding the level and timeline of environmental evaluation
relevant to your project.




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                                          CDBG Program
Funds may be used by non-profits or governmental jurisdictions for one or more of the following
activities:

          Housing
          Economic Development
          Public Facilities
          Public Services     (up to a maximum of 15% of CDBG allocation)

Eligible Public Service Activities

The CDBG regulations allow the use of grant funds for a wide range of public service activities,
including, but not limited to:
         Employment Services (e.g., job training)
         Crime Prevention And Public Safety
         Child Care
         Health Services
         Substance Abuse Services (e.g., counseling and treatment)
         Fair Housing Counseling
         Education Programs
         Energy Conservation
         Services for Homeless Persons
         Welfare Services (excluding income payments)
         Down Payment Assistance
         Recreational Services

CDBG funds may be used to pay for labor, supplies, and material as well as to operate and/or
maintain the portion of a facility in which the public service is located. This includes the lease of a
facility, equipment, and other property needed for public service. To utilize CDBG funds for a public
service, the service must meet either:

A new service; or a quantifiable increase in the level of an existing service which has been provided
by the grantee or another entity on its behalf through state or local government funds in the 12 months
preceding the submission of the grantee’s Consolidated Plan Annual Action Plan to HUD.

An exception to this requirement may be made if HUD determines that any decrease in the level of a
service was the result of events not within the control of the local government.

This provision was put into place to ensure that localities did not use CDBG funds to replace state or
local monies to fund essential services typically offered by the local government entity.

Specifically, the public services provision applies in the following manner:
         If a service is new, it may be funded.
         If a service is existing, determine whether it was provided by or on behalf of the unit of
            local government with local or state funding.
         If it was not provided by or on behalf of the local government with funding from the local
            government, it may be funded,

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              If it was provided by or on behalf of the local government with funding from the local
               government, grantees must determine whether the proposed service will be a quantifiable
               increase in the level of service. If it can be documented that the service is a quantifiable
               increase in the level of service being provided, it may be funded.

The regulations do not prohibit a grantee from continuing to provide funding to a CDBG funded public
service at the same or decreased level in subsequent program years.

Ineligible Public Service Activities

Income Payments - The provision of “income payments” is an ineligible CDBG funded public service
at the same or decreased level in subsequent program years.

Income payments are payments to an individual or family, which are used to provide basic services
such as food, shelter (including payment for rent, mortgage, and/or utilities) or clothing.

However, such expenditures are eligible under the following conditions:
      The income payments do not exceed three consecutive months: and
      The payments are made directly to the provider of such services on behalf of an individual
          or family.

Political Activities are also     ineligible.

Homeowner Rehabilitation

Homeowner rehabilitation is one of the most common community development programs
administered nation-wide. CDBG funds provide a wide range of flexibility with rehabilitation of projects
and design considerations. Grantees can choose to do emergency repair programs, spot rehabilitation
or full house rehabilitation.

CDBG can be used for grants, loans, loan guarantees, interest subsidies, or other forms of assistance
to homeowners for the purpose of repairs, rehabilitation, or reconstruction.

CDBG-eligible costs include:
      Labor and materials,
      Replacement of principal fixtures and components of existing structures;
      Water and sewer connections;
      Installation of security devices, including smoke detector; and
      Initial homeowner warranty premium;
      Hazard insurance premium (except when grant is provided);
      Flood insurance premium;
      Conservation costs for water and energy efficiency;
      Landscaping, sidewalk, garages, and driveways when accompanied with other
          rehabilitation needed on the property; and
      Evaluating and treating lead-based paint.




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                                             ESG Program
HUD”S Emergency Shelter Grants Program (ESG), authorized under the Stewart B. McKinney
Homeless Assistance Act of 1987, provides funding to state and local governments to help improve
the quality of existing emergency shelters for the homeless, to help make available additional
emergency shelters, to help meet the costs of operating homeless shelters and of providing certain
essential social services to homeless individuals. The program is also intended to restrict the increase
of homelessness by funding preventative programs/activities.

Eligible Uses of ESG Funds

Emergency Shelter Operations

           Up to 10% of the grant may be used for staff costs related to shelter operations. (Staff
           costs for maintenance and security are operating costs and are not included in the 10%
           calculation)

Essential Services                                                maximum of 30% of grant amount

           Includes assistance in obtaining permanent housing, medical and psychological
           counseling and supervision, employment counseling, nutritional counseling, substance
           abuse treatment and counseling, assistance in obtaining other Federal, State and local
           assistance, other services such as child care, transportation, job placements and job
           training, and staff salaries necessary to provide these essential services.

Homeless Prevention Activities                                    maximum of 30% of grant amount

           Includes short-term subsidies to pay delinquent rent and utility payments for families
           that have received eviction or utility termination notices, security deposits or first
           month’s rent to permit homeless families to move into their own housing, mediation
           programs for landlord-tenant disputes, legal services programs for the representation
           of indigent tenants in eviction proceedings, payment to prevent foreclosure on a home
           and other innovative programs and activities designed to prevent the incidence of
           homelessness. Staff costs are not an eligible expend=se under this category.

Match Requirement

           Each recipient must match the ESG funding with an equal amount of funds from other
           sources. Match funds must be provided after the date of the grant award.

Homeless Participation Requirement

    1. Each recipient must provide for the participation of at least one homeless or formerly homeless
       individual on the recipient’s board of directors or other equivalent policy making entity.

    2. To the maximum extent practical, Subrecipeint must involve homeless individuals and families
       to assist in carrying out activities funded through the ESG program.




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     B. Sample Required
          Policies




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                               Policies, Procedures and Plans
In order to be eligible to receive federal funding, each agency must demonstrate compliance with all
federal requirements listed in the Subrecipient Agreement, Part B. These include, but are not limited
to:

          Civil Rights Act of 1964 (Title VI)
          Fair Housing Act of 1968
          Executive Order 11063 – Equal Opportunity in Housing
          Section 109 of the Housing and Community Development Act of 1974
          Executive Order 11246 – Employment and Contracting Opportunities
          Section 3 Requirements
          Section 504 of the Rehabilitation Act of 1973
          Age Discrimination Act of 1975
          Executive Order 11625, 12432, 12138 – Minority and Women Owned Business Opportunities
          Compliance with OMB Circulars A-122, A-110, A-87 and 24 CFR Part 85

Some of these requirements specify the enactment of policies and procedures, while others simply
state the compliance guidelines. The CDC suggests that each agency adopt specific policies and
procedures as a vehicle to clearly define what the agency-wide goals are, and to provide
documentation of the commitment made to attaining those goals. Included in the following pages are
examples of some of the common policies adopted by various agencies. The samples have been
garnered from several sources, and are provided in this handbook solely as examples for review. You
are not required to utilize any of these samples, however, compliance with the aforementioned
regulations will be topic covered during any subrecipient monitoring conducted by the Commission.

Conflict of Interest Policy
No employee, officer, or agent shall participate in the selection, award, or administration of a contract
supported by federal funds if a real or apparent conflict of interest would be involved. Such a conflict
would arise when the employee, officer, or agent, any member of his or her immediate family, his or
her partner, or an organization which employs or is about to employ any of these parties indicated
herein, has a financial or other interest in the firm selected for an award. The officers, employees, and
agents shall neither solicit nor accept gratuities, favors, or anything of monetary value from
contractors, or parties to subagreements. Any officer, employee or agent violating this policy shall be
subjected to disciplinary action commensurate with the infraction.

Reference: Circular No. A-110 – Uniform Administrative Requirements for Grants and agreement,
Section _____.42

Sample Non-Discrimination Policy
No person shall be excluded from participation or be denied benefits on the basis of race, color,
national origin, age handicap or sex, in accordance with Section 109 of the Housing and Community
Development Act of 1974, the Age Discrimination Act of 1975 (42 U.S.C. 6101 et seq.) and section
504 of Rehabilitation Act of 1973 (29 U.S.C 794) prohibiting discrimination under any program or
activity funded in whole or in part with federal funds.

Reference: Executive Order 11063, as amended by Executive Order 12259, and regulations pursuant
thereto (24 CFR Part 107)


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Grievance Policy
[Agency Name] wishes to provide a model of communication and conflict resolution when considering
any grievance expressed by the served by the agency. The procedures below should be followed
regarding concerns about [Agency Names]’s programs, staff or partners:

          If you feel that there is inappropriate conduct or productivity on the part of the agency,
           management staff, partners, or any other persons or entities related to the agency, please
           bring this concern to the immediate attention of the Case Manager or any other persons or
           entities related to the agency please bring this concern to the immediate attention of the case
           manager with whom you most often interact, at a time and place that will allow full attention to
           your concerns.

          If you have discussed this matter previously and you do not believe that you have received a
           sufficient response, or if the Case Manager is the source of the concern, please present your
           concerns to the Program Manager in writing. Please indicate what the problem is, those
           persons involved in the problem, and any suggested solution you may have to the problem.

          If you don not receive a sufficient response to your written complaint within five (5) working
           days after providing it to the Program Manager, you should express your concern, including
           what actions you have already taken, in writing, to the Executive Director.

          If you do not receive a sufficient response to your written complaint within ten (10) working
           days after providing it t0 the Executive Director, or if your concern involves the Executive
           Director, you may formally express your concern, in writing, to the Board of Directors. The
           Board of Directors will provide a written response within twenty (20) working days of receipt.

          It is the client’s responsibility to pursue the communications listed above, in writing, indicating
           that the previously required steps have been undertaken. [Agency Name] cannot promise that
           your specific grievance or complaint will result in the action you requested or that you will be
           satisfied with the outcome of the grievance procedure.



Section 504 Requirements
Program Accessibility

Individuals with handicaps must be able to find out about, apply for and participate in federally
assisted programs or activities.

Special communication systems may be needed for outreach and ongoing communication (e.g.,
Telecommunications Devices for the Deaf (TDD), materials on tape or in Braille, accessible locations
for activities and meetings.)

Policies and procedures must be non-discriminatory (e.g., housing providers may not; 1) ask people
with handicaps questions not asked of all applicants, 2) screen individuals with handicaps differently
or 3) assess an individual’s ability to live independently).

Reference: 24 CFR Part 8


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  EEO State and Policy Prohibiting Illegal Discrimination and Harassment
[Agency Name] is committed to the principals of Equal Employment Opportunity and is committed to
making employment decisions based on merit and value. We are committed to complying with all
Federal, State, and local laws providing Equal Employment Opportunities, as well as all laws related
to terms and conditions of employment. We desire to keep a work environment with is free of
harassment or discrimination because of sex, race, religion, color, national origin, sexual orientation,
physical or mental disability, marital status, age or any other status protected by Federal, State or
local laws. We value diversity and are willing to employ men and women of all ethnic and racial
groups, ranging in age from the teens to the sixties and older, and representing a broad spectrum of
religions and national origins. The company will make every reasonable effort to accommodate those
physical or mental limitation of an otherwise qualified employee, unless undue hardship would result
for the company.

Just as the company bears a responsibility towards this policy, each of us must clearly communicate
our disinterest in, or offense taken to, any perceived verbal or physical discrimination or harassment.
We are all responsible for upholding this Equal Employment Opportunity policy and commitment.
Equal Employment laws afford each one of us the chance to succeed or fail based on individual merit.

Prohibited sexual harassment is defined as follow: “Unwelcome sexual advances, requests for sexual
favors, and other verbal or physical conduct of a sexual nature constitutes sexual harassment when
(1) submission to such conduct is made either explicitly or implicitly a term or condition of an
individual’s employment (2) submission to or rejections of such conduct by an individual is used as the
basis for employment decisions affecting such individual or (3) such conduct has the purpose or effect
of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or
offensive work environment.

[Agency Name] will not tolerate any form of discrimination or harassment. Any employee who fees
that he or she has witnessed, or been subject to, any form of discrimination or harassment should
immediately notify their supervisor, personnel administrator or other manager at the company. We will
promptly investigate any claim and take appropriate action. We will seek to impose appropriate
sanctions against any person found to be in violation of this policy. Such sanctions may include but
are not limited to, reprimand, suspension, demotion, transfer and discharge.

[Agency Name] prohibits retaliation against any employee who brings forth any complaint or assists in
the investigation of any complaint.

If you feel we have not resolved your complaint, and after you have followed the company grievance
procedure, you can complaint, and after you have followed the company grievance procedure, you
can complain to the EEOC, or State Fair Employment Office found in the local phone book.




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                                             Procurement Policy
[Agency Name] will:

  (1)      Avoid purchasing unnecessary items.

  (2)      Where appropriate, make an analysis of lease and purchase alternatives to determine which
           would be the most economical and practical.

  (3)      Solicit for goods and services.

  (4)      Utilize small businesses, minority-owned firms, and women’s business enterprises, whenever
           possible.

  (5)      Use procuring instruments appropriate for the particular procurement and for promoting the
           best interest of the program or project involved.

  (6)      Contract only with responsible contractors who possess the potential ability to perform
           successfully under the terms and conditions of the proposed procurement. Consideration shall
           be given to such matters as contractor integrity, record of past performance, financial and
           technical resources or accessibility to other necessary resources.

  (7)      Make available for the Federal awarding agency, pre-award review and procurement
           documents, such as request for proposals or invitations for bids, independent cost estimates,
           etc.

  (8)      Make and document some form of cost or price analysis for the procurement files in
           connection with every procurement action.

  (9)      Maintain procurement records and files for purchases in excess of the small purchase
           threshold that shall include the following at a minimum: (a) basis for contractor selection, (b)
           justification for lack of competition when competitive bids or offers are not obtained, and (c)
           basis for award cost or price.

  (10) Maintain a system for contract administration to ensure contractor conformance with the terms,
       conditions and specifications of the contract and to ensure adequate and timely follow up all
       purchases. Evaluate contractor performance and document, as appropriate, whether
       contractors have met the terms, conditions and specification of the contract.

  (11) For all contracts in excess of the small purchase threshold, include a condition that allows for
       administrative, contractual, or legal remedies in instances in which a contractor violates or
       breaches the contract terms, and provide for such remedial actions as may be appropriate.
       Provide suitable provisions for termination by the recipient, including the manner by which
       termination shall be effected and the basis for settlement. Provide for bid guarantees,
       performance bonds, and payment bonds for all the construction contracts or subcontracts
       exceeding $100,000.

  (12) Include a provision granting the Federal awarding agency, the Comptroller General of the
       United States, or any of their duly authorized representatives, shall have access to any books,
       documents, papers and records of the contractor which are directly pertinent to a specific
       program for the purpose of making audits, examinations, excerpts and transcriptions.

Please reference: OMB A110, Uniform Administrative Requirements for Grants and Agreements,
___.44-___.52
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               Minority & Women’s Business Enterprise Outreach Policy
Executive Order 11625 and 12432 (concerning Minority Business Enterprise and 12138 (concerning
Women’s Business Enterprise) contain requirements to further the participation of such enterprises in
federally funded programs. Consistent with these orders, ___________________________________
will encourage the use of minority and women’s business enterprises in connection with CDBG,
HOME and ESG funded activities in order to ensure the inclusion, to the greatest extent practicable,
of minorities and women, and entities owned by minorities and women, in all contracts for service.
Such services may include, but are not limited to, real estate, construction, appraisal, property
management, lending, investment banking, underwriting, accounting and legal.

All procurements will be done I accordance with Affirmative Fair Marketing principals, Affirmative
steps will be taken to assure that minority and women’s business enterprises (MBE/WBEs) are used
whenever possible as sources supplies, equipment, construction, and services. The steps
__________________________________ will undertake include but are not limited to:

    1. Include qualified MBE/WBEs on solicitation mailing lists;

    2. Whenever MBE/WBEs are potential sources, encourage their participation through direct
       solicitation of bids or proposals. Include in newspaper advertisements soliciting bid language
       as follows: “Women and minority owned firms are encourage to submit a bid for (construction
       projects)/ proposals for (services)”;

    3. Divide total requirements, when economically feasible and not inconsistent with other
       applicable regulations such as Davis-Bacon, into smaller tasks or quantities, t0 permit
       maximum participation by MBE/WBEs;

    4. Establish delivery schedules, where the requirement permits, which encourage participation by
       MBE/WBEs;

    5. Use the service and assistance of the Small Business Administration and the Minority
       Business Development Agency of the Department of Commerce;

    6. Include in contracts a clause requiring contractors, to the greatest extent feasible, to provide
       opportunities for training and employment for lower income residents of the project area and to
       award sub-contracts for work in connection with the project to business concerns which are
       located in, or owned in substantial part by person residing in the area of the project;

    7. Require prime contractors, when subcontracting is anticipated, to take the positive steps in
       number 1-6 above.

    8. Provide subcontractors with a current list of Women/Minority Owned Businesses.
       Subcontractors are to use this list when soliciting bids for construction for CDBG, HOME and
       ESG funded projects.

    9. Require the following be incorporated into the bid documents for subcontractors:

           “It is the policy of (name of Subcontractor) to take positive steps to maximize the
           utilization of minority and women’s business enterprises in all contract activity
           administered by ___________________________.




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           (Name of Subcontractor) will utilize its best efforts to carry out this policy in the award
           of subcontracts to the fullest extent consistent with the efficient performance of this
           contract. As used in this contract, the term “minority and women’s owned business
           enterprise” means a business at least fifty percent (50%) of which is owned by minority
           group members or women. For the purpose of this definition, minority group members
           are Black, Hispanic, Asian, Native American, Alaskans, and Pacific Islanders.”

           The subcontractor will submit the following statement as part of its bid:

           “I have taken affirmative action to seek out and consider minority and women’s
           business enterprises for the portion of work to be subcontracted. Such actions are fully
           documented in my records and available upon request.”

Results of the affirmative steps taken will include the names and addresses of MBE/WBEs firms the
subcontractor anticipates using, the category of work, the dollar value of the participation, the total bid,
the total subcontract amount and the total MBE/WBE portion of the subcontract amount.

                           Limited English Proficiency Policy (LEP)
The Sonoma County Community Development Commission (CDC), including the Housing Authority
and Redevelopment Agency, has developed this policy to protect the individual recipients of its
services from the effects of discrimination because of their race, color, or national origin. The goal of
this policy is to provide meaningful access to translation or interpreter services, for person with
Limited English Proficiency.

A person with Limited English Proficiency (LEP) is a person who does not speak English as their
primary language and who has a limited ability to read, write, speak or understand English. The CDC
will take affirmative steps to communicate with people who need services or information in a language
other than English. This policy was developed to serve applicants, participants, and/or person eligible
for housing assistance and support services.

The CDC will analyze the various kinds of contacts it has with the public, to assess language needs
and decide what reasonable steps should be taken. In order to determine the level of access needed
by LEP person, the CDC will balance the following four factors; the number or proportion of LEP
person eligible to be served or likely to be applying for program services: the frequency with which
LEP person utilize these programs and services; the nature and importance of the program activity, or
service provided; and the benefits from providing LEP service, and the resources available and costs
to the CDC for those services.

Balancing these four factors will ensure meaningful access by LEP persons to critical services while
not imposing undue burdens on the CDC.

In addition, this policy extends to all partners in the Commission’s programs that provide direct
services to individual members of the public, including but not limited to local government entities,
assisted housing providers, public service providers, and affordable housing developer. These groups
shall provide the Commission with copies of their own LEP Policies.

In consideration of these policies, the commission has developed the following language access plan
to implement solutions to the identified needs of the LEP populations it serves.




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                                    Language Access Plan (LAP)
The Commission will use the following five steps to effectively implement its LAP.

          Identify LEP individuals who need language assistance and assess the number or proportion
           of individuals eligible to be served or that are encountered and the frequency of encounters.

          Determine the type of language services needed, obtain those services, respond to LEP
           callers and in-person contact, respond to written communications, and ensure competency of
           interpreters and translation service.

          Train staff on their obligations to provide access to information and services for LEP persons.

          Provide notices to LEP person, in appropriate languages of the availability of language
           services by posting sign, through statements in outreach documents, through grassroots and
           faith-based organizations, in telephone voice mail menus, and through media providers.

          Monitor and update, as appropriate, new documents, programs, services, and activities that
           require accessibility by LEP persons.

The CDC has bilingual staff to assist non-English speaking families in Spanish. The CDC also
translates documents into Spanish. Interpreter services will be provided on an as-needed basis for
clients who speak languages other than Spanish or English. Where LEP persons desire, they will be
permitted to use, at their own expense, an interpreter of their own choosing, in place of or as a
supplement to the free language services offered by the CDC or provided by an outside vendor. The
interpreter may not be less than 18 years of age, but may be a family member or friend. The CDC will
analyze the various kinds of contacts it has with the public, to assess language needs and decide
what reasonable steps should be taken. Services may not be provided where the costs imposed
substantially exceed the benefits. Where feasible and possible, the CDC will encourage the use of
qualified community volunteers.

In determining whether it is feasible to translate documents into other languages, the CDC will
consider the following factors:

          Number of applicants and participants who do not speak English and speak the other
           languages.
          Cost to translate into the other languages.
          Evaluation of the need for translation by the bilingual staff and by agencies that work with non-
           English speaking clients.
          The availability of organizations to translate documents, letter and forms for non –English
           speaking families.
          Availability of bilingual staff to explain un-translated documents to clients.

In cases where a significant number of Spanish speaking, LEP residents are expected to attend public
hearings or meetings in connection with Commission business, the Commission will supply a
Spanish-speaking interpreter.

For all major or significant public hearings and meetings, the CDC will publish contact information
where non-Spanish speaking LEP persons my request special accommodation.


                                                                                                         17
rev 6/11
           C. Reimbursement
               Requests




                              18
rev 6/11
                Sonoma County Community Development Department

                 Subrecipient Reimbursement Request Instructions
Please type or print legibly. The following general instructions explain how to use the form. You may
contact Heather Bond at 565-7522 or Cristin Tuider at 565-7524 if you need additional information
regarding the use of the Subrecipient Reimbursement request form.

Item                  Entry
Part 1
Items 1, 2, 3         Self-Explanatory

Part II
Item A                This Section lists the activities for which reimbursement is allowed. The
                      activities should be consistent with Attachment B, Budget in the subrecipient
                      agreement.

Item B                This Section show budget amounts for each eligible activity. The amounts
                      should be consistent with Attachment B, Budget of the subrecipient agreement.

Item C                Enter total gross program outlays to beginning of report period for each eligible
                      activity. This should be the amount reimbursed to date.

Item D                Enter the total gross program outlays or cost incurred during the report period
                      for which reimbursement is requested.

Item E                Enter the total gross program outlays to date. This amount should include
                      reimbursements received to date and the reimbursement requested during the
                      report period. The number should be the sum of Item C and Item D.

Item F                Enter the remaining funds available for each eligible activity.
                      The number should be the difference between Item B and Item E.
                      Note: The remaining funds available may not be less than zero for any budget
                      line item.

Part III
Item 1                Signature of Executive Director or Designee requesting reimbursement

Item 2, 3             Self-Explanatory




                                                                                                        19
rev 6/11
                  Sonoma County Community Development Department

                               Subrecipient Reimbursement Request


                                                             Part I
Subrecipient Organization:

Program/Year: __ - __

Period Covered From:                        to

Name of Project:

Fund Type:



                                                             Part II


                                                            Cumulative
                                                            Expended to
                                                            Beginning of         Expended           Total
           Eligible Activity                 Budget           Report            this Report      Expended to       Unliquidated
   (As shown in Attach B, Budget)            Amount           Period               Period           date            Balance
                  A                            B                 C                   D               E                  F

           Operating Costs


           Wages / Benefits




                                 Total $                    $                  $                 $                 $



                                                            Part III

Authorized Certifying Official

Name and Title

Date Report Submitted


Certification: I certify to the best of my knowledge and belief that this report is complete and that all outlays and unliquidated
funds are for the purposes set forth in the award contract.



                                                                                                                              20
rev 6/11
             Sonoma County Community Development Commission

                             Reimbursement Request Summary
                            (Attach to Subrecipient Reimbursement Request)

Attach two accounting reports from your General Ledger system:
    1) A general ledger detail for this fund only for the reporting period being submitted;
    2) A general ledger fiscal (7/1 – 6/30) year-to-date report for this fund only that includes the
        reporting period.

If your accounting fund designation is numeric, not descriptive, please list the fund number here that
uniquely identities the CDC fund:     ______________________
                                      (Example: 20 34 865 XXXX)

Payroll Summary
                                                                   Salary Amt
     Name         Position/Title      Program Function                                     Notes
                                                                    Benefits
                                                                    $ 563.85    Works in other programs too,
Example:       Resource            Independent Living Skills
                                                                                timecard breaks out
Jane Jones     Specialist          Coach – Shelter Program          $ 164.77    separately




                                                      Total    $



Operational (non-payroll) Expense Summary
   Vendor      Item or Service        Program Function              Amount                 Note
  Example:        Food Prep
                                     For meals in shelter           $69.93               Inv. #5329
   Costco          Supplies




                                                      Total    $


                                              Grand Total: ______________




                                                                                                         21
rev 6/11
           D. Reporting




                          22
rev 6/11
                            Quarterly Reporting Due Dates


           Quarter                       From                              Due Date

           1st Quarter             July 1st – Sept. 30th                  October 10th

           2nd Quarter              Oct. 1st – Dec. 31st                  January 10th

           3rd Quarter             Jan 1st – March 30th                      April 10th

           4th Quarter              April 1st – June 30th                    July 10th


**Part II – Summary of Other Funding Sources needs to accompany the 4th Quarterly Report.




                                                                                            23
rev 6/11
                                                          Ethnicity and Race
                                                   Complete one box for each family member
                            Ethnicity                                                                      Ethnicity
   Hispanic or Latino                                                             Hispanic or Latino
   Not Hispanic or Latino                                                         Not Hispanic or Latino
                  Race (Mark all that apply)                                                     Race (Mark all that apply)
     White                                                                          White
     Black or African American                                                      Black or African American
     Asian                                                                          Asian
     Mexican or American Indian or Alaska Native                                    Mexican or American Indian or Alaska Native
     Native Hawaiian or Other Pacific Islander                                      Native Hawaiian or Other Pacific Islander

                            Ethnicity                                                                      Ethnicity
   Hispanic or Latino                                                             Hispanic or Latino
   Not Hispanic or Latino                                                         Not Hispanic or Latino
                  Race (Mark all that apply)                                                     Race (Mark all that apply)
     White                                                                          White
     Black or African American                                                      Black or African American
     Asian                                                                          Asian
     Mexican or American Indian or Alaska Native                                    Mexican or American Indian or Alaska Native
     Native Hawaiian or Other Pacific Islander                                      Native Hawaiian or Other Pacific Islander


                            Ethnicity                                                                      Ethnicity
   Hispanic or Latino                                                             Hispanic or Latino
   Not Hispanic or Latino                                                         Not Hispanic or Latino
                  Race (Mark all that apply)                                                     Race (Mark all that apply)
     White                                                                          White
     Black or African American                                                      Black or African American
     Asian                                                                          Asian
     Mexican or American Indian or Alaska Native                                    Mexican or American Indian or Alaska Native
     Native Hawaiian or Other Pacific Islander                                      Native Hawaiian or Other Pacific Islander

If an applicant fails to complete the race category and, for instance, only chooses Hispanic, it is the responsibility of the assisting agency to
follow up with the completion by basing the race upon the personal observation of the interviewer. If no indication is made, racial category
defaults to White.
                                                For Official Use Only – Do not write below this line


                                                                                             Number of individuals          Number also of
                                     Race Categories                                        or households assisted          Hispanic/Latino
                                                                                                   (Race)                      Ethnicity
   White
   Black or African American
   Asian
   Mexican or American Indian or Alaska Native
   Native Hawaiian or Other Pacific Islander
   Mexican or American Indian or Alaska Native and White
   Asian and White
   Black or African American and White
   Mexican or Amer. Indian or Alaska Native and Black or African American
   Other Multi-Racial
   Total number assisted (must equal the total number shown on the income
   chart:)

   A combination of two of the above race categories, as is outlined in the template provided to each agency for report purposes, is also
   acceptable. Any person with more than 2 combined race categories are counted in the “Other Multi-Racial” category.


                                                                                                                                                    24
   rev 6/11
                                                           Etnicidad Y Raza
                                                 Llene uncuadro para cada meimbro del la familia
                             Etnicidad                                                                     Etnicidad
   Hispano o Latino                                                               Hispano o Latino
   No Hispano o Latino                                                            No Hispano o Latino
                Raza (Indique todo lo que aplique)                                             Raza (Indique todo lo que aplique)
     Blanco                                                                         Blanco
     Negro o Afroamericano                                                          Negro o Afroamericano
     Asiatico                                                                       Asiatico
     Mexicano o Indio Americano o Nativo de Alaska                                  Mexicano o Indio Americano o Nativo de Alaska
     Nativo de Hawaii u otra isla del pacifico                                      Nativo de Hawaii u otra isla del pacifico

                             Etnicidad                                                                     Etnicidad
   Hispano o Latino                                                               Hispano o Latino
   No Hispano o Latino                                                            No Hispano o Latino
                Raza (Indique todo lo que aplique)                                             Raza (Indique todo lo que aplique)
     Blanco                                                                         Blanco
     Negro o Afroamericano                                                          Negro o Afroamericano
     Asiatico                                                                       Asiatico
     Mexicano o Indio Americano o Nativo de Alaska                                  Mexicano o Indio Americano o Nativo de Alaska
     Nativo de Hawaii u otra isla del pacifico                                      Nativo de Hawaii u otra isla del pacifico


                             Etnicidad                                                                     Etnicidad
   Hispano o Latino                                                               Hispano o Latino
   No Hispano o Latino                                                            No Hispano o Latino
                Raza (Indique todo lo que aplique)                                             Raza (Indique todo lo que aplique)
     Blanco                                                                         Blanco
     Negro o Afroamericano                                                          Negro o Afroamericano
     Asiatico                                                                       Asiatico
     Mexicano o Indio Americano o Nativo de Alaska                                  Mexicano o Indio Americano o Nativo de Alaska
     Nativo de Hawaii u otra isla del pacifico                                      Nativo de Hawaii u otra isla del pacifico

If an applicant fails to complete the race category and, for instance, only chooses Hispanic, it is the responsibility of the assisting agency to
follow up with the completion by basing the race upon the personal observation of the interviewer. If no indication is made, racial category
defaults to White.
                                         Para Uso Oficial Solamente- No Escriba Abajo De Esta Linea


                                                                                         Number of individuals or             Number also of
                                    Race Categories                                     households assisted (Race)        Hispanic/Latino Ethnicity
      White
      Black or African American
      Asian
      Mexican or American Indian or Alaska Native
      Native Hawaiian or Other Pacific Islander
      Mexican or American Indian or Alaska Native and White
      Asian and White
      Black or African American and White
      Mexican or Amer. Indian or Alaska Native and Black or African American
      Other Multi-Racial
      Total number assisted (must equal the total number shown on the
      income chart:)
        A combination of two of the above race categories, as is outlined in the template provided to each agency for report purposes, is
           also acceptable. Any person with more than 2 combined race categories are counted in the “Other Multi-Racial” category.

                                                                                                                                                    25
   rev 6/11
                                      Ethnicity and Race Definitions

    The two ethnic categories as revised by the OMB are defined as follows:

         a) Hispanic or Latino- A person of Cuban, Mexican, Puerto Rican, South or Central
            American, or other Spanish culture or origin, regardless of race. The term, “Spanish
            Origin,” can be used in addition to “Hispanic or Latino”.
         b) Not Hispanic or Latino- A person not of Cuban, Mexican, Puerto Rican, South or
            Central American, or other Spanish Culture or origin, regardless of race.


    Definitions for the Five Racial Categories as revised by the OMB are as follows:

         a) White- A person having origins in any of the original peoples of Europe, the Middle East
            or North Africa.
         b) Black or African American- A person having origins in any of the black racial groups of
            Africa. Terms such as “Haitian” or “Negro” can be used in addition to “Black” or “African
            American.”
         c) Asian- A person having origins in any of the original peoples of the Far East, Southeast
            Asia, or the Indian subcontinent including, for example, India and the Philippines Islands.
         d) American Indian or Alaska Native- A person having origins in any of the original
            peoples of North and South America (including Central America), and who maintains
            tribal affiliation or community attachment.
         e) Native Hawaiian or Other Pacific Islander- A person having origins in any of the
            original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.

         Lists below are only examples of Country Location – not a complete list

                                         Black or                          American Indian           Native
               White                      African         Asian            or Alaska Native       Hawaiian or
                                         American                                                     Other
Europe                 Middle East                     Far East &           South America        Pacific Islander
Albania                Afghanistan                     SE Asia              Argentina
Andorra                Bahrain         Africa          Burma                Bolivia
Armenia                Iran            Algeria         Cambodia             Brazil               Pacific Islands
Austrian               Iraq            Burundi         China                Chili                Australia
Azerbaijan             Israel          Cameroon        Indonesia            Colombia             Cook Islands
Belgium                Jordan          Chad            Japan                Cuba                 Fiji
Bosnia                 Kuwait          Conga           Korea                Ecuador              French Polynesia
Bulgaria               Lebanon         Eritrea         Malaysia             Guyana               Futuna
Croatia                Saudi Arabia    Egypt           Myanmar              French Guiana        Indonesian
Czech Repub            Syria           Ethiopia        Mongolia             Paraguay             Provinces
Estonia                Turkey          Guinea          New Guinea           Peru                 Kiribati
Finland                Yemen           Kenya           Philippines          Suriname             Marshall Island
Georgia                                Liberia         Thailand             Uruguay              Nauru
Iceland                North Africa    Madagascar      Vietnam              Venezuela            New Zealand
Italy                  Algeria         Morocco                                                   Niue
Lithuania              Canary          Nigeria         Indian               Central America      N Mariana Islands
Portugal               Islands         Rwanda          Subcontinent         Belize               Palau
Romania                Egypt           Zambia          Bangladesh           Costa Rica           Pitcairn
Serbia                 Libya           Zimbabwe        Bhutan               El Salvador          Tokelau
Slovenia Slovakia      Morocco                         India                Guatemala            Tonga
Ukraine                Portugal                        Maldives             Honduras             Tuvalu
                       Sudan                           Nepal                Jamaica              Wallis
                       Tunisia                         Pakistan             Nicaragua
                       West Sahara                     Sri Lanka            Panama


                                                                                                    26
    rev 6/11
                                     Certification of Family Income
          Use as an example only – Income Limits are updated annually by HUD. Please refer to the CDC Website
           http://www.sonoma-county.org/cdc/cdadmin_forms.htm for the most current forms.


The income information below is required as a condition of the receipt of program funding from
the U. S. Department of Housing and Urban Development (HUD). The most current form is also
posted on the CDC website at: http://www.sonoma-county.org/cdc/cdadmin_cdbg.htm

The information requested on this form will be used to assure that HUD funds are being used to
benefit low- and moderate- income persons without racial or ethnic discrimination.

    FAMILY INCOME

    Please circle your family size and appropriate income level range on the same line:
Income Range by Family Size

Family              Below 30%                     31% to 50%                    51% to 80%                   Over 80%
 Size             (Extremely Low)                 (Very Low)                    (Moderate)                   (Non-Low)
    1              Below $1,429 /m            $1,430 to $2,379 /m           $2,380 to $3,775 /m          $3,756 /m & above

    2              Below $1,633 /m            $1,634 to $2,717 /m           $2,718 to $4,313 /m          $4,314 /m & above

    3              Below $1,838 /m            $1,839 to $3,058 /m           $3,059 to $4,850 /m          $4,851 /m & above

    4              Below $2,038 /m            $2,039 to $3,396 /m           $3,397 to $5,388 /m          $5,389 /m & above

    5              Below $2,204 /m            $2,205 to $3,671 /m           $3,672 to $5,821 /m          $5,822 /m & above

    6              Below $2,367 /m            $2,368 to $3,972 /m           $3,973 to $6,250 /m          $6,251 /m & above

    7              Below $2,529 /m            $2,530 to $4,213 /m           $4,214 to $6,683 /m          $6,689 /m & above

    8              Below $2,692 /m            $2,693 to $4,487 /m           $4,488 to $7,113 /m          $7,114 /m & above



    I hereby certify that the information above is true and correct.


_________________________                        ___________
      Signature                                     Date

                                      For Official Use Only – Do not write below this line


                                             Number of Persons Directly Assisted

     No. of
                     Below 30%             31% to 50%           51% to 80%             Over 80%          Female Head of
    Persons
                   (Extremely Low)          (Very Low)          (Moderate)             (Non-Low)           Household
    Assisted




                                                                                                                      27
rev 6/11
                                Certificacion de Ingresos de Familia
           Use as an example only – Income Limits are updated annually by HUD. Please refer to the CDC Website
            http://www.sonoma-county.org/cdc/cdadmin_forms.htm for the most current forms.

     La información de ingresos debajo de es requerido como una condición del recibo de la
     financiación del programa forma el U. S. El departamento de Envoltura y Desarrollo
     Urbano (HUD).

     La información solicitada en esta forma será utilizada para asegurar que los fondos de
     HUD son utilizados para beneficiar bajo- y moderar- personas de ingresos sin la
     discriminación racial o étnica.

     INGRESOS DE FAMILIA

     Por favor rodee su tamaño de familia y asigne la variedad de nivel de ingresos en la misma
     línea:
 Variedad de Nivel de Ingresos

Tamaño de          Debajo del 30 %              El 31 % al 50 %               El 51 % al 80 %               Más del 80 %
  Familia          (Sumamente Bajo)                (Muy Bajo)                   (Moderado)                   (No bajo)
     1            Menos de $1,429 /m           $1,430 a $2,379 /m            $2,380 a $3,775 /m           $3,756 /m y Arriba

     2            Menos de $1,633 /m           $1,634 a $2,717 /m            $2,718 a $4,313 /m           $4,314 /m y Arriba

     3            Menos de $1,838 /m           $1,839 a $3,058 /m            $3,059 a $4,850 /m           $4,851 /m y Arriba

     4            Menos de $2,038 /m           $2,039 a $3,396 /m            $3,397 a $5,388 /m           $5,389 /m y Arriba

     5            Menos de $2,204 /m           $2,205 a $3,671 /m            $3,672 a $5,821 /m           $5,822 /m y Arriba

     6            Menos de $2,367 /m           $2,368 a $3,972 /m            $3,973 a $6,250 /m           $6,251 /m y Arriba

     7            Menos de $2,529 /m           $2,530 a $4,213 /m            $4,214 a $6,683 /m           $6,689 /m y Arriba

     8            Menos de $2,692 /m           $2,693 a $4,487 /m            $4,488 a $7,113 /m           $7,114 /m y Arriba


 Por este medio certifico que la información encima es verdadera y correcta.


 _________________________                        ___________
       Firma                                       Fecha

                                  Para Uso Oficial Solamente- No Escriba Abajo De Esta Linea

                                             Number of Persons Directly Assisted

      No. of
                      Below 30%             31% to 50%           51% to 80%             Over 80%          Female Head of
     Persons
                    (Extremely Low)          (Very Low)          (Moderate)             (Non-Low)           Household
     Assisted




                                                                                                                        28
 rev 6/11
              Sonoma County Community Development Commission
                      Community Development Program

                                       Quarterly Status Report
Public Service Projects
ESG please attach addendum                                              Grant Funding Year ______ - _______

Subrecipient Name:

Program Title:

Reporting is required by HUD and a condition of funding. The CD Committee will receive
quarterly updates based on the information provided in this report. Reports can be submitted
electronically as long as report has a signature.

A. Quarterly Performance Reporting Period and Due Dates:

           1st Quarter: July 1 - September 30 (Part I)                  Due October 10th

           2nd Quarter: October 1- December 1 (Part I)                  Due January 10th

           3rd Quarter: January 1 – March 31 (Part I)                   Due April 10th

           4th Quarter: April 1 – June 30 (Parts I & II*)               Due July 10th

    * Attach PART II of this report listing all other funding sources and their amounts that were
    used for this project.

PART I (To be submitted every quarterly)

Name and ID of HMIS Provider for this grant (Complete only if using ServicePoint HMIS)

____________________________________________________________________________


A. Narrative:
    1. Please provide any information that you would like reported to the CD Committee. (35
    words max)



B. Direct Benefit Data (Cumulative, for the fiscal year beginning July 1) from the ServicePoint
Homeless Management Information System (HMIS). If your agency is not required to participate
in the HMIS, please use your other agency data sources:

    1. HUD PERFORMANCE INDICATOR DATA:
       Persons Assisted Year to Date with:
           (HUD 40118 APR version 4.05 printed for each program. Total cells 2a and 2b for each program type)

           Emergency Shelter: _____           Transitional Housing: _____ Total Reported _____

                                                                                                                29
rev 6/11
     2. INCOME DETERMINATION; complete the table below indicating the number of
        PERSONS assisted. For each year in which ANY grant funds were expended, direct
        benefit data will be required for the entire year. (ServicePoint users ART
           >sonoma_liveart_folder>0608_CDBG_CAPER_Sonoma_EE – Tab B Income)

                                     Number of Persons Directly Assisted
              Total                                                                          Over 80%
                                 Below 30%         31% to 50% (Very      51% to 80%
         No. of Persons                                                                      (Non-low
                               (Extremely Low)           Low)            (Moderate)
           Assisted                                                                          Moderate)



           HMIS Data


3.   RACE/ETHNICITY DETERMINATION; The total number of individuals shown in the first
     column below should equal the number of persons directly assisted in #2 above. HMIS
     columns are for comparison only. (HUD 40118 APR version 4.05 printed for each program. Use cells 7a
     & b, and 8a-k for each program type)

                                                          (Total)                         HMIS      HMIS
                                                          No. of       (Supplemental)
                                                                                         No. of     No. of
                                                         persons          No. of
                                                                                        persons    Hispanic
                                                         assisted        Hispanic
                                                                                        assisted
                 Race/Ethnicity Data                       YTD             YTD
                                                                                          YTD         YTD
                                                          (Race)        (Ethnicity)
                                                                                         (Race)    (Ethnicity)
White
Black or African American
Asian
Mexican/American Indian/Alaskan Native
Native Hawaiian/Other Pacific Islander
Mexican/American Indian or Alaska Native and White
Asian and White
Black/African American and White
Mexican American Indian/Alaska Native & Black/African
American
Other multi-racial
Total number assisted
(must equal the total number of persons in #1 and #2
above):

C. Agencies that participate in ServicePoint HMIS, attach the following reports –

1. Business Objects - ART 0242 – Data Completeness Report Card (Tab B only)
2. Business Objects - ART 0213 - Completeness_Entry_Exit_Workflows (multiple pages - submit
   electronic only)
3. ServicePoint - HUD 40118-APR 4.02 Version (2 pages) (printed from the ServicePoint Reports
   Menu)

D. Agencies that utilize non-HMIS data sources, check all that apply-

_________Spreadsheet _________Internally Developed Database (please identify) ________
_________ Other Software (please identify) _________________________________________


Signature:                                                          Date:

Name:                                                               Phone:
                           (type/print)
Title:
                                                                                                         30
rev 6/11
  ESG Addendum
  Please complete the following tables for Non-Residential Services including Homeless Prevention and Homeless
  Assistance using your agency’s data. If you are obtaining the data from ServicePoint HMIS please use the
  supplemental columns to compare to actual. All numbers are cumulative.

                                          Non-Residential Services-Homeless Prevention
                                              (Deposit, Rental and Utility Assistance)
                                                                            Number of Persons                     Number of Persons Served
                       Beneficiary Data
                                                                                Served                            per HUD 40118-APR Sec. 2
Persons Served with Financial Assistance                                    Cumulative to Date                        Cumulative to Date
        Adults
        Children
        Households


                               Residential Services-Homeless Assistance
                                                                 (Shelter Programs)
 Persons Served
     Annual Number Adults Served
     Annual Number Children Served
     Annual Number of Households

 Persons Served by Housing Type
     Barracks
     Group/Large House
     Single Room Occupancy

       Beneficiary Characteristics                                                                        Number of Persons Served
                                                           Number of Persons Served
          (Cumulative to Date)                                                                           per HUD 40118-APR – Sec. 5
 Unaccompanied 18 and Over                               Male:                Female:                 Male:          Female:
 Unaccompanied Under 18                                  Male:                Female:                 Male:          Female:
 Single Parent 18 and Over with Children                 Male:                Female:                 Male:          Female:
 Single Parent Under 18with Children                     Male:                Female:                 Male:          Female:
 Two Parents 18 and Over with Children
 Two Parents Under 18 with Children
 Families With No Children

                                      Non-Residential Services and Residential Services
                                      (Homeless Prevention and Shelter Programs - All Clients)
                                                                                                                       Number of Persons
                                                                                                                             Served
                     Subpopulations Served                               Number of Persons Served
                                                                                                                      per HUD 40118-APR –
                                                                                                                          6.a & 9.a / 9.b
  Number of Persons Served who are:                                            Cumulative to Date                      Cumulative to Date
    Chronically Homeless (Emergency Shelter Only)*
    Severely Mentally Ill
    Chronic Substance Abuse
    Other Disability**
    Veterans
    Persons with HIV / AIDS
    Victims of Domestic Violence
    Elderly

         Combined total Number of Persons Served
      Combined total Number of Households Served

*HUD defines a chronically homeless person as “An unaccompanied homeless individual with a disabling condition** who has either
been continuously homeless for a year or more OR has had at least four (4) episodes of homelessness in the past three (3) years.”

**HUD’s definition of a disabling condition is, “A diagnosable substance use disorder, serious mental illness, developmental disability, or chronic
physical illness or disability, including the co-occurrence of two or more of these conditions.”

                                                                                                                                                 31
  rev 6/11
Fair Housing Addendum
    Please complete the following tables with the numbers of those assisted

                                               Number of         Number of     Number of
           Fair Housing Service
                                               Instances          People      Households
    Landlord/Tenant Mediation
    Referred to HCA

    Discrimination Testing

    Assistance with Complaint

    Complaints submitted to HUD

    Community Presentations

    Referral to PPSC
    Referral to Legal Aid Services

    Responses to Email Questions
    Website Hits

    Narratives:
    1. What updates to the Fair Housing Website have been made this quarter? Are current
       laws posted online?




    2. Synopsis of material activities, emerging trends, new issue identification and general
       program activities, barriers and successes.




    3. Summary of progress on quantified and non-quantifiable program objectives listed in
       Exhibit A of the funding agreement.




                                                                                                32
rev 6/11
Economic Development Addendum

CAFÉ:

                                                                             Weekly Number
                                       Number of FT       Weekly Number
                    Number of FT                                               of Part Time
           Jobs                         jobs held by       of Part Time
                       jobs                                                  Hours held by a
                                      Low/Mod person          Hours
                                                                             Low/Mod person
Created
Retained

Please provide a summary of general program activities, barriers and successes.




Art Co-op:

                                                                             Weekly Number
                                       Number of FT       Weekly Number
                    Number of FT                                               of Part Time
           Jobs                         jobs held by       of Part Time
                       jobs                                                  Hours held by a
                                      Low/Mod person          Hours
                                                                             Low/Mod person
Created
Retained

Please provide a summary of general program activities, barriers and successes.




                                                                                          33
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                   SONOMA COUNTY COMMUNITY DEVELOPMENT COMMISSION
                           COMMUNITY DEVELOPMENT PROGRAM

                                       Quarterly Status Report
County/City-Owned Public Facility & Improvement Projects

Subrecipient Name:                                                 Grant Funding Year ______ - _______

Program Title:

Reporting is required by HUD and a condition of funding. The CD Committee will receive quarterly
updates based on the information provided in this report.

A. Quarterly Performance Reporting Period and Due Dates:
            st                                                                 th
           1 Quarter: July 1 - September 30 (Part I)        Due October 10
            nd                                                                 th
           2 Quarter: October 1- December 1 (Part I)        Due January 10
            rd                                                            th
           3 Quarter: January 1 – March 31 (Part I)         Due April 10
            th                                                         th
           4 Quarter: April 1 – June 30 (Parts I & II*)     Due July 10

    * Attach PART II of this report listing all other funding sources and their amounts that were used for
    this project.

PART I (To be submitted every quarter)

A. Narrative:
    1. Please provide any information that you would like reported to the CD Committee. (35 words
    max)


B. Project Schedule: Is the program still in compliance with the original program schedule?

YES____ NO ____ If no, please explain why and attach a revised schedule.

C. Subcontract: Complete the chart below for the subcontracts entered into during this quarter, which will
    be paid in whole or in part using CDBF, ESG and HOME funds. Attach a copy of each subcontract to
    this report.

                                                                                                               Women
Date of           Dollar                                          Employer            Race       Hispanic
                               Name and Address of Contractor                                                  Owned
Contract         Amount                                           Tax ID #          (write in)   Ethnicity?
                                                                                                              Business?




Signature: ___________________________Date: ___________________

Name: ______________________________                        Phone: __________________
           (type/print)

Title: _______________________________


                                                                                                                  34
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                   SONOMA COUNTY COMMUNITY DEVELOPMENT COMMISSION
                           COMMUNITY DEVELOPMENT PROGRAM

                                      Quarterly Status Report
Countywide and Unincorporated Area Projects

Subrecipient Name:                                                 Grant Funding Year ______ - _______

Program Title:

Reporting is required by HUD and a condition of funding. The CD Committee will receive quarterly
updates based on the information provided in this report.

Quarterly Performance Reporting Period and Due Dates:
            st                                                                 th
           1 Quarter: July 1 - September 30 (Part I)        Due October 10
            nd                                                                 th
           2 Quarter: October 1- December 1 (Part I)        Due January 10
            rd                                                            th
           3 Quarter: January 1 – March 31 (Part I)         Due April 10
            th                                                         th
           4 Quarter: April 1 – June 30 (Parts I & II*)     Due July 10

    * Attach PART II of this report listing all other funding sources and their amounts that were used for
    this project.


PART I (To be submitted every quarter)

A. Narrative:
    1. Please provide any information that you would like reported to the CD Committee. (35 words
    max)




B. Project Schedule: Is the program still in compliance with the original program schedule?

YES____ NO ____ If no, please explain why and attach a revised schedule.

C. Subcontracts: Complete the chart below for the subcontracts entered into during this quarter, which
    will be paid in whole or in part using CDBG, ESG and HOME funds. Attach a copy of each
    subcontract to this report.

                                                                                                               Women
Date of           Dollar                                          Employer            Race       Hispanic
                               Name and Address of Contractor                                                  Owned
Contract         Amount                                           Tax ID #          (write in)   Ethnicity?
                                                                                                              Business?




                                                                                                                  35
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D. Direct Benefit Data (Cumulative, for the fiscal year beginning July 1):

1. Income Determination: Complete the table below indicating the number of PERSONS assisted.
For each year in which ANY grant funds were expended, direct benefit data will be required for
the entire year.

                                     Number of Persons Directly Assisted
                                                                                                Over 80%
                                 Below 30%           31% to 50% (Very     51% to 80%
       No. of Persons                                                                           (Non-low
                               (Extremely Low)             Low)           (Moderate)
         Assisted                                                                               Moderate)
      Owner Occupied

      Renter Occupied


2. Race / Ethnicity Determination:
                                                                 Owner                    Renter

                Race / Ethnicity Data                      Number of    Hispanic    Number of     Hispanic
                                                            Persons     Ethnicity    Persons      Ethnicity
                                                             (Race)                   (Race)
  White
  Black or African American
  Asian
  American Indian/Alaskan Native
  Native Hawaiian/Other Pacific Islander
  Mexican, American Indian or Alaska Native and White
  Asian and White
  Black/African American and White
  American Indian/Alaska Native & Black/African American
  Other multi-racial
  Total number assisted
  (must equal the total number of persons in #2 above):

3. Homeowner Rehabilitated Unit Information:

   Of the Total Owner Units,                                                    Number of Units
 Occupied by disabled
 Occupied by elderly
 Moved from substandard to standard (HQS or local code)
 Section 504 accessible units
 Qualified as Energy Star
 Brought into compliance with lead safety rules (24 CFR Part 35)



Signature: ___________________________                      Date: ___________________

Name: ______________________________                        Phone: __________________
           (type/print)

Title: ______________________________




                                                                                                              36
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PART II - Summary of Other Funding Sources

Summary of Other Funding Sources

To be submitted with all 4th Quarter Reports


Organization: ______________________________________________

Program or Project: _________________________________________

Instructions: Please specifically list ALL funding sources for entire program (other than CDBG,
ESG, or HOME funds that you received from the CDC.) Avoid using miscellaneous categories,
abbreviations, such as HSC< MCH, SASCA, etc., and general categories such as “HUD”,
“State” and “County”. List specific departments and grant names, differentiate between
donation, grant and loan. Don’t forget interest income, program/membership fees, etc.

                                                                           DOLLAR       TYPE OF
 #                          FUNDING SOURCE                                 AMOUNT      FUNDING*
 1
 2
 3
 4
 5
 6
 7
 8
 9
 10
 11
 12
 13
 14
 15
 16
 17
 18
 19
 20
                                                                TOTAL


Submitted by: ___________________________                             *Type of Funding
                                                                         1. Federal**
Title: __________________________________                                2. State/Local Public***
                                                                         3. Private
Date: ______________


** ALL CDBG / ESG funding is Federal – regardless of who distributes the grant.
***Local Public means Cities

                                                                                                37
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           E. Monitoring




                           38
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                                  Monitoring Objectives


    1. To determine if a subrecipient/developer is carrying out it Community Development
       Program, and its individual activities, as described the application for CDBG, ESG or
       HOME assistance and the subrecipient/developer or Development Agreement.

    2. To determine if a subrecipient/developer is carrying out its activities in a timely manner,
       in accordance with the schedule included in the Agreement.

    3. To determine if a subrecipient/developer is charging costs to the project, which are
       eligible under applicable laws and CDBG, ESG and HOME regulations, and reasonable
       in light of the services or products delivered.

    4. To determine if a subrecipient/developer is conducting its activities with adequate control
       over program and financial performance and in a way that minimizes opportunities for
       waste, mismanagement, fraud and abuse.

    5. To assess if the subrecipient/developer has continuing capacity to carry out the
       approved project, as well as other grants for which it may apply.

    6. To identify potential problem areas and to assist the subrecipient/developer in complying
       with applicable laws and regulations.

    7. To assist subrecipient/developer in resolving compliance problems through discussion
       and the identification of technical assistance and training needs.

    8. To provide adequate follow-up measures to ensure that performance and compliance
       deficiencies are corrected by subrecipient/developer, and not repeated.

    9. To comply with Federal Monitoring Requirements of 24 CFR 570.501 and 24 CFR 85.40.

    10. To determine if any conflicts of interest exist in the operation of the CDBF, ESG or
        HOME programs per 24 CFR 570.611.

    11. To ensure that required records be maintained to demonstrate compliance with
        applicable regulations.

    12. To identify areas in which the subrecipient/developer requires technical assistance and
        to plan for such training as necessary.




                                                                                                 39
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                               Nonprofit Financial Records
Nonprofit agencies accepting federal funds must be familiar with OMB circular A-122. They
must employ a bookkeeper that is knowledgeable with generally accepted accounting principles
(GAAP).

An agency’s financial reports should be the source of a reimbursement request.

Transaction should be recorded on a timely basis.

A fund accounting system must be maintained. Each transaction should be associated with a
specific activity and/or funding sources. The accounting system must include procedure for
tracking the transactions associated with the SCCDC agreement.

The SCCDC may require copies of financial statements from time to time. Your system should
be able to produce the following reports:

    -      An agency-wide balance sheet as of a specific date
    -      An agency-wide income statement covering a specific time period
    -      A balance sheet for the SCCDC-supported fund
    -      An income statement for the SCCDC-supported fund

Appropriate internal control procedures must be in place.


                                      Payroll Pamphlet
This document has been prepared by the Sonoma County Community Development
Commission in an effort to answer questions about timesheets. Nonprofit subrecipients must
maintain timesheets that meet fund accounting standards if payroll costs are an element of the
subrecipient agreement. Contracts between nonprofit subrecipients and the Sonoma County
Community Development Commission (CDC) that are federally funded refer to OMB circular A-
122: Cost Principles for Nonprofit Organizations. Subrecipients that enter into agreements with
the CDC attest to the fact that, during the contract period, they will have a system in place that
adheres to the requirements of OMB circular A-122.

This payroll pamphlet only applies to CDC subrecipients that are being reimbursed with federal
funds for payroll expenses. This document represents a combination of federal regulations and
local policies.

Basic Requirements

    1. Each person working on the CDC funded activity will complete a timesheet.

    2. The timesheet should provide for the following items:
        Employee name
        Employee job title
        Pay period start and end dates
        Dates worked
        Time worked
        Field for employee signature
        Field for supervisor signature

                                                                                                40
rev 6/11
    3. All of the employee hours must be reported on the timesheet. Reporting only the CDC
       funded portion is not acceptable.

    4. The timesheet will have columns where employees will indicate what type of work they
       were performing. There should be at least one column to be used for hours spent on
       activities under the CDBG/ESG subrecipient agreement that are eligible for
       reimbursement under the CDBG/ESG subrecipient agreement. There should be at least
       one column to be used for hours that are not eligible for reimbursement.

Allowability

    1. Hourly rates must be reasonable.

    2. The CDC prefers to reimburse payroll cost of those persons working directly on the
       eligible activity. For example: We would prefer to support a portion of the payroll costs
       for an Employment Counselor and would not prefer to reimburse a portion of the payroll
       costs for the Executive Director.

    3. The CDC does not reimburse for payroll costs that have flowed through an indirect
       allocation. We reimburse payroll costs that are directly associated with the eligible,
       funded activity.

    4. Timesheets should be completed after the hours have been worked (after the fact).

    5. Payroll expenses should be distributed based on the time reported on the timesheets.
       Payroll expenses should not be distributed based on budget ratios.

    6. Pay periods must follow a reoccurring pattern (for example: every two weeks, twice a
       month, monthly). Payroll expenses should be posted to the agency’s general ledger in a
       pattern that coincides with the pay period pattern.

    7. There must be a job description in the agency’s written procedures for any position
       supported by CDC funds. If your timesheet does not have a column specifically for the
       CDC funded subrecipient agreement then the job description should be on file with the
       SCCDC.

    8. Ineligible activities will not be reimbursed (fund raising for example).

    9. Unfunded activities will not be reimbursed.


References

    1. Please read your subrecipient agreement and its attachments.

    2. Please read OMB circular A-122.

    3. Two example timesheets are attached.

    4. If you have questions about how to apply the requirements within the payroll pamphlet or
       if you have questions about how to develop a timesheet that works best for your
       organization, feel free to contact the CDC’s accounting department at 565-7511.

                                                                                                41
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Time Sheet Example A

                                        Daily Time Record


Pay Period: From ____________________through ______________________

_____________________________________
(Employee Name)


     Date
                    Mon   Tue   Wed    Thur     Fri    Mon     Tue    Wed      Thur   Fri
              IN

            OUT

              IN

            OUT
                                                                                            Totals
 Work Hours

Vacation/Sick

      Holiday

   Pay Hours
                                                                                            Totals
   Activity A

   Activity B

   Activity C

 Counseling

     Housing

           Office

 Work Hours


I certify that the foregoing is an accurate account of my daily time record.


_____________________________________                        _____________________________
Employee Signature                                           Supervisor Signature


_____________________________________
Employee Job Title




                                                                                               42
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Time Sheet Example B
                                                               Daily Time Record

_____________________________________                        Pay Period: From ____________________through ______________________
(Employee Name)

                                                     Total                          Total
                                                              Vacation/                     Activity   Activity   Activity
     DATE     IN       OUT         IN       OUT     Hours                 Holiday   Hours                                    Counseling   Housing   Admin
                                                                Sick                          A          B          C
                                                    Worked                          Paid
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15


I certify that the foregoing is an accurate account of my daily time record.
____________________________ _________________________                         _____________________________
Employee Signature           Title                                             Supervisor Signature

                                                                                                                                                      43
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                                                Monitoring Questionnaire
          This is a sample questionnaire. Actual questionnaire will be sent to subrecipient upon monitoring.


The following table lists the most current agency information on file with the CDC. Please verify
whether these are the most current available. If not, please attaché copies of the most current
information when you return this questionnaire.

                                                                                              Date of form in   Is this the most
                                         Policy
                                                                                                 CDC file           current?
Personnel Policy, including Grievance Policy
Equal Employment Opportunity/ Affirmative Action
Minority Business and Women-Owned Business Enterprises
Policies
Procurement Policy and Procedure
Comprehensive List of Board of Directors Members
(*New-see template and sample at:
http://www.sonoma-county.org/cdc/cdadmin_forms.htm)
Conflict of Interest Policy
Program Procedures and Policies
(Should include client grievance policy)
Minutes of the Board of Directors meetings
(Please be sure the CDC is on current mailing list)
Limited English Proficiency (LEP) Policy

Answer the following questions as thoroughly as possible. If you need more room, please feel free to
attach additional information at the end of the questionnaire.

I. Program and Facility Operations

1. Will you accomplish all of your objectives as cited in Exhibit A of your Subrecipient Agreement? If
   not, what challenges, obstacles or problems did you have or do you foresee in the future?

2. How practical and realistic is your budget to achieve stated objectives and continue operations?

3. Which services have been increased or decreased and why? What changes have been made to
   program policies and procedures?

4. How does your agency ensure the prohibition against religious or political activities?

5. In what CDC-provided technical assistance training has staff participated? What additional training
   would be helpful?

6. Does the facility have working smoke alarms and/or sprinklers? Where are these located? Are
   those designed for hearing-impaired residents?

7. Does the facility have an evacuation plan in place?

                                                                                                                              44
rev 1/11
8. Is the facility retrofitted?

9. Please describe your agency’s disaster plan.

10. Please describe the condition of your building(s) and any deferred maintenance.

11. Please describe the role of staff and clients for facility maintenance and cleaning.

12. Do you serve food at the facility and if so, how do you ensure proper food handling and sanitation?

II. Record Keeping

1. Who processes the quarterly reports to the CDC?

2. What comments or problems do you have regarding the quarterly reports?

3. Please describe how your agency ensures the confidentiality and security of current and archived
   client files:

4. Where are all the located? Who has access to client files?

5. How long are records kept before disposal?

6. What method is used to dispose of records?


III. Non-Discrimination

1. Please describe any policies or procedures to ensure non-discrimination, both to employees and in
   the provision of services:

2.   Which sites are accessible to the disabled and elderly, including parking lots and restrooms?

3. When purchasing goods or services, how do you include minority and women’s business
   enterprises before making the purchase decision? How do you document these actions in agency
   records?

IV. Property Management

1. What equipment or assets have been purchased with federal funding received from the CDC?

2. How long are purchase records maintained?

3. Have you disposed of any assets?

4.   Provide the inventory tracking for the equipment or assets.

 V. Financial Management Systems
    (To be completed by accounting staff)
1. Who processes the reimbursement requests to the CDC?

                                                                                                      45
rev 1/11
2. What questions or problems do you have concerning the reimbursement process?

3.   Has your accounting staff reviewed the Subrecipient Agreement between your agency and the
     CDC?      Yes _____      No_____

4. When was the last fiscal year your agency was audited by an independent auditor?
   _____________

5. Has this audit been provided to the CDC?         Yes _____      No_____

6. Did the agency’s most recent audit reveal any findings and if so, what steps have been taken to
   correct weak points?

7.   Is payroll processed internally or by an outside payroll processing company?

8. Does your agency use time and activity reports to measure time spent on your agency’s various
   activities? If so, are salary expenses allocated to your various funding sources based on the time
   and activity reports?

9. How does your agency separate the transaction of the CDC-funded project from other projects?
   (Separate checking account, fund accounting system, other?)

10. Are the funding and expenditures for programs funded by the CDC still in line with the original
    projected budget provided in the application? If not, please explain the changes.

11. Does your agency receive federal funds from any other agency besides the CDC?

12. Is your agency familiar with OMB Circular A-122: Cost Principles for Non-Profit Organizations?

13. Does your program generate income for your agency and if so, how is it used? For example: are
    there any auxiliary sources of income such as fee for services, room rental or seminar admission
    fees?




                                                                                                        46
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                SONOMA COUNTY CONTINUUM OF CARE
            HMIS Agency Data Standards Compliance Checklist v 1.0

Data Collection
Does the agency have a data collection form and/or protocol that captures mandated Universal and
Program specific (where applicable) data elements?
Data collection form or protocol?                                        □ Yes        □ No
Agency is capturing Universal data on all Program Clients?               □ Yes        □ No
Agency is capturing Program level data as required for APR?              □ Yes        □ No
Users have been trained and are current on protocol?                     □ Yes        □ No
Agency monitors data quality?                                            □ Yes        □ No
Special population considerations:



Privacy: Posted Notice
Does the agency have a purpose for data collection sign posted at the intake desk?
Location(s):
Includes purpose for data collection?                                      □ Yes          □ No
Is a copy available?                                                       □ Yes          □ No
Privacy: Privacy Policy
Does the agency have a privacy policy?
Last date amended: ____/____/______
Specifies purpose for collection of PPI?                                   □ Yes          □ No
Defines uses and disclosures?                                              □ Yes          □ No
Copy available upon Client request?                                        □ Yes          □ No
User Authentication
Does the agency abide by the HMIS policies for unique user names and password?
Agency abides by HMIS policy group decisions?                              □ Yes          □ No
Users are aware not to share username and passwords?                       □ Yes          □ No
Users are aware not to keep username and password in public location (i.e. no sticky notes on
monitors)                                                                  □ Yes          □ No
Hard Copy Data
Does agency have procedures in place to protect hard copy PPI information generated from or for the
HMIS?
Has procedure that includes:
        1) Security of hard copy files
               - locked drawer/file cabinet                                □ Yes          □ No
               - locked office                                             □ Yes          □ No
        2) Procedure for client data generated from HMIS
               -printed screen shots                                       □ Yes          □ No
               -HMIS client reports                                        □ Yes          □ No
               -downloaded data (i.e. to excel)                            □ Yes          □ No
Copy of policy/procedure available                                         □ Yes          □ No
Agency staff received training on hard copy data protections               □ Yes          □ No
PPI Storage
Does the agency dispose of or remove identifiers from a client record after a specified period of time?
(Minimum standard: 7 years after PPI was last changed if record is not in current use.)
Has procedure?                                                             □ Yes          □ No

                                                                                                      47
rev 1/11
Describe procedure:



Virus Protection
Do all computers have virus protection with automatic update?
        Spot check several computers:
               Virus software and version:
               Auto-update turned on:
               Date last updated: ___/___/______
Person responsible for monitoring/updating:
Physical Access
Are all HMIS workstations in secure locations or are they manned at all times if they are in publicly
accessible locations?
All workstations are in secure locations (i.e. locked offices)?            □ Yes           □ No
All workstations are manned at all times?                                  □ Yes           □ No
All workstations have password protected workstations?                     □ Yes           □ No
Data Disposal
Does the agency have policies and procedures to dispose of hard copy PPI or electronic media?
The agency shreds all hardcopy PPI before disposal?                        □ Yes           □ No
        The agency reformats before disposal:
               -disks                                                      □ Yes           □ No
               -CD’s                                                       □ Yes           □ No
               -computer hard-drives                                       □ Yes           □ No
               -other media (tapes, jump drives, etc)                      □ Yes           □ No




                                                                                                        48
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           F. HMIS




                     49
rev 1/11
                         Homeless Management Information System


The Homeless Management Information Systems initiative was passed by Congress in 2004. All
Covered Homeless Organizations (CHO’s) who receive funding are required to participate in Sonoma
County’s HMIS web-based data tracking system, ServicePoint managed by Bowman Systems,
Shreveport, LA.


Participating organizations must adhere (at a minimum) to the following standards:


    1.      All Client intake, assessment, and program entry/exit data must be entered into the HMIS within
           five days of initial client assessment, program entry or exit.
    2. All program services delivered to a Client must be entered in the HMIS within five days of the
       end of the month.
    3. Staff persons who have any affiliation with HMIS must receive the following training:
              a. Security and Ethics – annually
              b. User Training – prior to first system entry and annually updated thereafter
              c. User Community Groups – periodic throughout the year as required
    4. All client personally protected information (PPI) must be safeguarded according to HMIS
       security policies and best practices at all times.
    5. Scoring for data completeness and quality must at all times reflect a 95% score or higher to be
       considered acceptable.
    6. Data entered into ServicePoint must be able reflect the reality of the intake process and client
       information should be traceable back to hard copy intake/assessment and exit forms.
    7. Staff members departing their role with HMIS through job transfer, resignation or termination
       MUST be reported immediately to the HMIS Coordinator to assure timely removal of login
       credentials from ServicePoint.




                                                                                                          50
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