TRANSITIONAL HOUSING, OPERATING AND RENT (THOR) PROGRAM RENTAL ASSISTANCE GUIDELINES
I. Authorization This program is authorized under the provisions of the Revised Code of Washington (RCW), Chapter 43.63A and Washington Administrative Code (WAC) Chapter 365-120, "State Funding of Local Emergency Shelter and Transitional Housing, Operating and Rent Programs." II. Program Overview The Rental Assistance Program assists homeless families with children with case management and move-in, deposit, and rent costs for up to two years. These funds are intended to help fill the gap between emergency shelter assistance and affordable permanent housing. III. Eligible Activities A. No less than 91 days and up to 12 months of rent assistance to help pay the cost of monthly rent and utilities. Up to 12 additional months of assistance may be approved by the administering agency on a case-by-case basis. (Contractors who make a good faith effort to retain families for 91 days will not be held responsible if any family leaves in violation of this rule.) Exception: if there are less than 91 days left in the State Fiscal Year, the contractor may accept new families into the program up until funding runs out or the end of the fiscal year, whichever occurs first. B. Security and utility deposits, first and last month's rent, criminal background checks, and tenant costs of credit checks and for amounts consistent with local market practices. Security deposits and credit checks for clients who are leaving the program to move into permanent housing, AND have successfully met the all the requirements and goals of their Housing Stability Plans (see Section V E) C. Initial move-in costs for clients entering the THOR program. The contractor may approve movein costs for any subsequent moves if the move is critical to the tenant’s health and safety. D. Up to 10 percent of the total grant amount may be used for administrative costs, including the cost of the six-month follow-up survey of former clients. E. Up to 40 percent of the total grant amount may be used for the costs of case managers who provide client counseling, intake assessments, and inspections, and link clients to the services necessary for the successful completion of their Housing Stability Plans. All case management
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costs must be directly related to the case management of THOR clients and may include salaries, benefits, space costs, office supplies, telephone, travel, the costs of criminal background checks, and the costs of urinalyses for drug testing. After the family leaves the program, case management funds may be used to pay for move-in costs (other than rent or deposits) and to extend case management services for up to 6 additional months. IV. Ineligible Activities A. Assistance exceeding 24 months. B. Housing assistance for less than 91 days. C. Overnight shelter assistance. D. In combination with THOR operating subsidies. E. Direct client services other than the cost of staff time for case management or eligible costs related to housing assistance. F. Payment of rent arrearages. G. Deposits without rent assistance. H. Rent payments for clients who have left the program. I. Any costs that are the responsibility of the tenant. V. Eligibility for Assistance A. Families must be Income-Eligible Participants may have incomes up to 50% of median income for the area being served. The Department of Housing and Urban Development (HUD) publishes median income information annually. B. Families must be Homeless Participant families must be homeless, as defined by the Emergency Shelter Assistance Program as persons who, on one particular day or night, do not have a decent and safe shelter or sufficient funds to purchase a place to stay. This includes families who can provide proof of imminent housing loss or are currently residing in homeless shelters.
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C. Eligible Family Composition 1. Homeless families must include persons who are pregnant or have one or more children under the age of 18. Homeless families whose only children are at or over the age of 18 and under the age of 21 may qualify for THOR assistance if: a. The adult children are living with the applicant family, and b. They can provide proof that the adult children are enrolled in high school, and c. The family is otherwise eligible for THOR assistance. 2. Pregnant or parenting youth under the age of 18 may qualify as independent families if they are legally emancipated or reside in DSHS licensed or approved facilities. 3. Persons temporarily absent from the home may be counted as family members. A family whose only children are temporarily absent from the home may participate in the program when there is a documented likelihood that a child will be returned to their custody within 30 days of their admission to the program. Extensions may be granted on a case-by-case basis for no more than an additional 60 days. D. Eligibility Verification and Documentation 1. Agencies must complete the CTED Eligibility Verification Checklist. Eligibility must be verified and documented by local program staff. There are four acceptable methods of verifying program eligibility: a. Written: the staff person gets third party written verification directly from the information source; i.e., employer, DSHS, Employment Security, etc. b. Oral: If verification is oral, the staff person must document the conversation in the client file. This documentation should include the name, telephone number, and position/title of the third party, the date and time of the conversation, and the name of the person requesting the verification. c. Documented: This type of verification is used when the information desired does not require verification by a third party, such as birth certificates or social security cards. d. Self-Declared: Client written statements or affidavits are acceptable only when other verifications are not available. Since this method is self-serving, it should be viewed with caution and accepted only as a last resort. 2. Verification of homelessness may include an eviction notice or referral from a shelter or other service provider. If the client is living with family or friends, the family/friends must provide a written statement indicating they are only willing to provide temporary shelter until the client finds alternative housing.
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2. Verification of eligible children may include visual confirmation by housing support staff, birth certificates, military or Department of Licensing identification cards, or doctor statements if verification of pregnancy is needed. a. Adult children over the age of 18 and under the age of 21 who are living at home and are still enrolled in high school must produce proof of address and school enrollment. b. Youth under the age of 18 who wish to participate as an independent family must provide proof of legal emancipation or proof of residence in a DSHS-licensed or approved facility. c. Verification of temporarily absent children must include written court or social service documentation of pending custody, or third party verification from the court or social service agency that has been carefully documented by the THOR case manager in the client file. 3. Verification of income eligibility may include pay stubs, tax statements, verification from employers, and DSHS/Employment Security/Social Security documents. E. Housing Stability Plans The family, with the assistance of local housing support staff shall conduct a personal needs assessment and establish a housing stability plan for long and short-term goals that will aid the family in transitioning to stable housing and self-sufficiency. The housing stability plan is the backbone of the program and each family’s key to success. It must include short- and long-term goals and an action plan that is updated on a regular basis. If the family is not following through with their plan, then they may need to redefine their goals or the steps needed to reach them. The family must sign an agreement that they will follow through with the requirements of their housing stability plan, and that they understand that their assistance can be terminated for noncompliance. Copies of the agreement and the plan must be kept in the client file. VI. Tenant Selection A. Administering agencies must have written tenant selection policies clearly specifying how families to be assisted will be selected. B. Administering agencies may establish local preferences for specific categories of individuals, as long as the categories are identified in the community’s Ten-Year Homeless Plan. C. Local preferences cannot be administered in a manner that limits the opportunities of persons based on race, color, gender, sexual preference, religion, national origin, or handicap. A person given a local preference may still apply for other forms of assistance.
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VII. Housing Safety Standards A. The local contractor must establish rental housing safety standards to ensure that every THOR tenant lives in decent, safe housing. The administering agency may adopt the HUD Housing Quality Standards (HQS) and inspection procedures or the CTED Housing Safety Standards (HSS) and procedures. B. All units occupied by THOR clients must pass a HSS or HQS safety inspection conducted by the contractor or authorized agency. The rental subsidy will commence on or after the date the unit passes inspection. No rent subsidy will be paid for the time a unit is occupied by a THOR client before it passes inspection. If a tenant moves in before the unit passes, the tenant will be responsible for the full amount of the rent until the unit passes inspection. C. Every participating landlord and tenant must sign the Housing Safety Standards Certifications prior to the first subsidy payment. Complete records of all certifications, inspections, and follow-up actions must be kept in the clients’ files. D. Tenants must receive a copy of the Landlord-Tenant Law and be informed on how to use this law when problems arise. (Copies of the law are available from the Tenant Union of Washington State at 206.723.0500 or from your local branch of Columbia Legal Services. The law can also be found on the Office of the Attorney General’s website at www.atg.wa.gov and the NW Justice Project’s website at www.nwjustice.org.) VIII. Income and Rent A. Income Limits and Deductions In order to be eligible for the program, a client’s income (gross or net (after taxes), as determined by the local contractor) must not exceed 50% of the median income for the area. After eligibility is established, the income may be adjusted for family circumstances before the rent is calculated. The contractor may use the income inclusions, exclusions, and deductions established by HUD for the Section 8 Program, or develop its own income and deduction guidelines as long as the method for determining them is consistently used for all eligible families. B. Rent Limits 1. Rents for THOR-subsidized rental units may not exceed the locally established rent standards for the area. Rent standards are usually the Fair Market or Exception Rents (FMRs) established by HUD for the county. They include the cost of utilities, except for telephone services, and are revised annually. 2. If the FMRs are not representative of the area rents for modest, safe units, then the contractor may establish local rent standards. Local rent standards must be developed from documented evidence of area rents, such as newspaper advertisements, real estate
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listings, or rent surveys. Local documentation must be revised at least annually to accurately reflect the current rates. Local rent standards must be consistent for all THOR units. 3. If the contractor wishes to include the cost of utilities in the rent calculations, it may use utility allowance schedules established by the local housing authority, or it may establish its own. A utility allowance schedule must estimate the average monthly cost of utilities for each unit type (single family, apartment, duplex, manufactured housing, etc.) C. Tenant Rent Share Upon entering the program, the tenant’s share of the rent must be at least $1.00, but not exceed 30% of his/her adjusted monthly income. As the tenant stabilizes and makes progress toward obtaining permanent, unsubsidized housing, his/her share of the rent should gradually increase, as described in local program policies and procedures. Rents may increase proportionately as the tenant’s income increases, or the contractor may choose to increase the tenant rent at predetermined milestones. The tenant’s rent share may never exceed 30% of adjusted income in the first month of assistance or 50% of adjusted income in all subsequent months. IX. Portability Tenants may not transfer their assistance to areas outside of the contractor’s jurisdiction. X. Graduation, Denial and Termination of Tenancy A. THOR clients whose incomes exceed 50% of the median for the area will graduate from the program and stop receiving rent assistance. Administering agencies may allow families an adjustment period of up to 30 days before the rent assistance is discontinued. Case management, on an “as needed” basis, may be continued for up to six months after a family leaves the program. B. Causes for denial of assistance include but are not limited to the client’s failure to produce verifiable evidence of program eligibility, and failure to include at least one child in the household within the time prescribed. C. Causes for termination from the program include but are not limited to failure to comply with the terms of the Housing Stability Plan. D. Administering agencies must have written policies and procedures for applicant denial and participant termination of assistance. XII. Extending Case Management after Program Graduation A. THOR funds may be used to continue Case Management services for up to six months after a family graduates from the program, if the family needs additional services in order to
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complete his or her Housing Stability Plan. B. In order to qualify for extended Case Management services, the family must have demonstrated consistent compliance with the terms and conditions of their Housing Stability Plan and motivation to become self-sufficient (as determined by the administering agency.) C. Case Management may be extended for eligible clients who move into subsidized or unsubsidized housing, when there is no other case management funding available. XIII. Program Administration A. Contractor Eligibility A THOR lead agency for each county will be determined through a local community planning process according to policies currently under development by CTED. The lead agency will be the applicant for CTED funding. There should be no more than one application per county. An application from one agency for multiple counties is encouraged when the need for THOR assistance exists in a county that has little or no capacity for operating the program. An eligible applicant for THOR Contractor must: 1. Be the designated lead agency; 2. Be the only applicant for the county for which it is applying; 3. Be a public agency or private nonprofit organization with an IRS 501(c)(3) status; 4. Possess the management capability to administer subcontracts with one or more local agency providers of transitional housing services; 5. Have established internal control and fund accounting procedures to assure the proper disbursement of, and accounting for, all funds provided, and submit one copy of an independent audit to the CTED; 6. Practice non-discrimination in all programs. B. Contractor Responsibilities 1. Submit all required reports and information to CTED within specified timeframes; 2. Enter into written subcontract agreements with subcontractors (as needed); 3. Distribute THOR funds to all participating subcontractors; 4. When subcontractors are involved, collect all required reporting forms and information
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from subcontractors and submit them to CTED within specified timeframes; 5. Annually monitor terms of the subcontracts to ensure timely expenditure of funds and balanced service provision, ensure the program is administered correctly according to all applicable rules, regulations and contracts, and review the accounting practices of participating programs that do not have an independent audit; 6. Ensure all funds are spent according to the contract; 7. Spend no more than 10% of the grant amount on administrative costs; and 8. Spend no more than 40% of the grant amount on case management costs. C. Eligible Expenses The administration, case management, and rent subsidy costs of a tenant-based, transitional, rental housing assistance program may be charged to the THOR grant amount. 1. Administration Administration includes costs for functions directly related to the provision of transitional housing units for homeless families with children. These functions include planning, budgeting and accounting, and the establishment and direction of contractor policies, goals, and objectives. Administrative costs may also be used for the cost of the annual housing status survey. Reimbursement for administration costs may not exceed 10 percent of the grant amount set aside for rental assistance, and must be shared with subcontractors. Any unused funds set aside for administration costs may be used for rental assistance costs. 2. Case Management Case management includes the costs of case management staff performing client intake, assessments, inspections, and counseling for homeless families with children. These costs must be directly related to the case management of THOR clients and may include salaries, benefits, space costs, office supplies, telephone, travel, the costs of criminal background checks, and urinalysis for drug testing. Case management funds may also be used for additional case management for up to six months after the family moves to permanent housing. Reimbursement for case management costs may not exceed 40 percent of the grant amount set aside for rental assistance. Unused dollars set aside for case management costs may not be used for administration costs. 3. Rent Assistance Rent assistance includes the cost of rent assistance to eligible homeless families. This includes the initial move-in costs for tenants entering the program; monthly rent and utilities (for no less than 91 days and no more than 24 months); security and utility
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deposits; first and last month's rent; and the tenant costs of credit checks. Rent assistance funds may also be used for the costs of any subsequent moves if the move is critical to the family’s health and safety. All costs associated with moving into and renting a home that is reimbursed by this grant must be consistent with local market practices. D. Billing Procedures Contractors must bill CTED on a monthly basis for reimbursement of allowable costs, using the CTED THOR Voucher Distribution. Payment will be made upon receipt of all required documents and reports. If required reports are not submitted in a timely manner, CTED will delay payment until the reports are received. If the contractor fails to file a monthly invoice within any two-month period, CTED may elect to terminate the contract. E. Financial Management Systems The contractor must maintain copies of all reimbursement requests and backup documentation from subcontractors. The contractor must maintain records that disclose all costs allowable for reimbursement. F. Reports The contractor is responsible for submitting required reports by the dates due using required forms. Report Voucher Distribution Client Data Report Annual Housing Status Report Annual Audit Quarterly Projections G. Budget Revisions The THOR approved budget is outlined on the Contract Face Sheet. Budget revisions are subject to the following parameters: 1. Increases to the contract amount of up to ten percent (10%) can be made by amendment by CTED alone. 2. The contractor may make budget revisions of up to ten percent (10%) of the total budget without an amendment. Funds may be transferred between the Case Management, Operating Subsidies, Rental Assistance, or Administration categories as long as Case Management never exceeds forty percent (40%) and Administration never exceeds ten percent (10%) of the total contract amount. A description of the budget change(s),
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Due Date Monthly on the 15th of month following provision of services except in July, when it is due on the 10th. Twice annually: January 15 and July 15 March 15 As soon as available Revised as needed
including the amount(s) transferred, must be submitted to CTED prior to submitting expenditure reports reflecting the revisions. 3. Budget revisions exceeding ten percent (10%) of the total contract amount require a contract amendment. Requests must be submitted to, and approved by, CTED before the contractor submits expenditure reports reflecting the revisions. H. Acknowledgement of State Funding Publications such as reports and pamphlets which are developed totally or in part with THOR funds must give credit to the funding source by including the following: “Funds made available through the Department of Community, Trade and Economic Development, State of Washington.” I. Monitoring CTED will monitor every Service provider once every two years. This monitoring can consist of either a desk monitor or an on-site visit. Agencies will be given a minimum of six weeks notice and a copy of the monitoring tool will be made available before the review. J. Performance Measures 1. Number of Families Served The Contractor must serve at least 90 percent of the number of families identified in the Scope of Work for the first fiscal year of the biennium. If the Contractor fails to meet these standards, the Contractor must submit a written explanation. CTED may accept the explanation and require the Contractor to submit a revised Scope of Work for the remainder of the current contract, or choose to reduce the Contractor’s grant amount for the next fiscal year. 2. Expenditures In January, and every month thereafter until the end of the fiscal year, CTED will review the contract expenditures as reported on the monthly THOR invoices and compared to the expenditure projections. If the Contractor fails to expend THOR funds at the projected rate, the Contractor must submit a written explanation. CTED may accept the explanation and require an updated budget that reflects the Contractor’s ability to spend down the grant by June 30, or choose to reduce the Contractor’s grant amount for the current State Fiscal Year. 3. Funds Reduction The level of funds reduction for failure to meet performance standards shall be negotiated between CTED and the Contractor, with CTED retaining the authority to set the reduction level. Any unused funds will be reallocated to other THOR contractors.
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4. Program Outputs/Outcomes The contractor is responsible for measuring and tracking the following outputs/outcomes: Destinations of exiting families including number of assisted households transitioning to unsubsidized housing other than that of friends, family or shelter programs and number of assisted households transitioning to subsidized housing other than that of friends, family or shelter programs; Income and source of income of exiting families; Number of assisted households increasing income; Percent of income exiting families will pay for rent and utilities; The self-reliance of exiting families, based on one indicator of the contractor’s choice; Number of assisted households maintaining housing at least 6 months after leaving the program.
K. Client Records The local program administrator must create a client file for every applicant accepted for the program. At a minimum, all client files must contain the following: Program application THOR Eligibility Checklist and verification documents Date the client entered the program and date the subsidy commenced All rent and subsidy calculations Reasons for and amounts of rent increases and decreases Unit lease or equivalent Housing Stability Plan or equivalent containing all the elements required in Section VI E. HQS or HSS inspection form showing that the unit passed inspection before the subsidy was paid, and records of all inspections, follow-up communications, and actions Signed Housing Safety Standards Certifications form Reasons for and date of assistance termination
L. Local Program Design Local THOR Rent Assistance programs must conform to the Rent Assistance Guidelines listed above. Local agencies must also design additional policies and procedures to ensure consistency with their local Ten-Year Plan. All local policies and procedures must be available to CTED upon request. New lead agencies must submit the minimum policy requirements with their THOR application for funding. The following list of minimum policy requirements and options is offered to assist agencies with local program design:
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1. Minimum Policy Requirements a. Choose rent standard. b. Describe the process of rent increases. c. Describe tenant selection policies (see options, below). Ensure that families will be selected without regard to race, color, religion, gender, sexual preference, handicap, or national origin. d. Identify forms of assistance (see options, below). e. Set income limits and adjustments (see options, below). f. Choose housing inspection standards and procedures (see options, below.) g. Set procedures for application denial and termination of tenancy. 2. Policy Design Options a. Local Applicant Preferences (e.g. victims of domestic violence, disabled, working families, etc.): Specify. If two or more, how will they be ranked during the selection process? b. Setting Up a Waiting List: First come first served? Preferences? c. Tenant Screening Policies: Based on motivation, readiness, other? How will these qualifiers be measured? d. Identifying Forms of Assistance: Rent only? Rent w/security and utility deposits and/or 1st and last months rent? Credit checks? Moving costs? e. Setting Income Limits and Adjustments: At or less than 50% of median income? What, if any, income adjustments will be allowed? Which definition of income will be used? f. Housing Safety Standards: HUD Housing Quality Standards?
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CTED Housing Safety Standards? Subsequent inspections?
g. Changes in Circumstances: Death of family members? Miscarriage when there are no other children? Loss of custody? M. Changes to Guidelines CTED may issue revised or new guidelines at any time. All lead agencies will be sent revised copies as they are published. XIV. Community Planning Process for THOR Lead Agency A. Identify Stakeholders and Potential Service Providers Stakeholders are those members of your community who will be affected, either directly or indirectly, by the outcomes of this process. Be sure to also invite potential service providers who may qualify for funding. Because of this requirement, you may have participants who are new to this process. Since these service providers and community members may not be familiar with these program resources, it may be difficult to ensure their attendance at a meeting with a single invitation. It will be important to explain the importance of community involvement and eligibility requirements for funding when extending invitations. B. Share Information Many community stakeholders probably have a basic idea about services, but may not entirely understand requirements and eligibility. Because funding decisions will be made, it is imperative that all participants come to the meeting with enough information to make proposals or decisions about how to allocate funding. It is important to share these THOR Program Guidelines with them. C. Identify and Prioritize Needs of Families Experiencing Homelessness in Your Community This must include, but not be limited to, assessing existing services and identifying gaps in services relative to transitional housing. Having broad stakeholder input is an important part of identifying these needs. Your local 10-Year Plan will likely have identified and prioritized these needs. However, in many communities, the time may be right for a review of the local plan. Your community meetings can serve to keep your 10-Year Plan up-to-date and relevant. D. Determine Allocation Criteria This is a very important step and should be done before selecting a lead agency and any potential subcontractor and allocating awards. These criteria are the basis for a fair process
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and should be straightforward enough that any other region in the state could use them. At a minimum, the criteria must include how funded programs will be consistent with the local 10-Year Plan. Other criteria that should be included but are not limited to the following: capacity to meet the identified needs (ex. % staff FTE compared to service numbers, agency board involvement, agency financial health) capacity to successfully deliver eligible services (based on overall agency performance, spending history, data, contract compliance if CTED contractor) capacity to provide appropriate case management (staff training and experience) for previous providers, a review of biennium spending (under spent, spent out early) for previous providers, a review of client numbers (projected to serve and actual reported data)
E. Identify Eligible Agencies Identify which eligible agencies can provide services to meet the identified and prioritized needs. Once the above criteria are determined, participants can then move onto selecting eligible agencies that can meet these standards. F. Understand the Role and Responsibilities of a Lead Agency Potential lead agencies must be clear about the role and responsibilities associated with CTED contracting (Section XIII B). This is also an important opportunity to talk about the relationship and expectations between the lead agency and the subcontractors. The Program Guidelines and general contract documents are excellent resources. G. Determine a Process for Selecting a Lead Agency and Subcontractors CTED advises that the process determined for selecting a lead agency and subcontractors be unanimously agreed upon and well documented. For instance, while there may be a number of stakeholders present at the community meeting, will every participant be allowed to vote on the selection of a lead agency and subcontractors? Once a lead agency and subcontractors are selected, how will allocations be decided upon? Make sure there is agreement on the process and it is documented before decisions are made. H. Notification of Lead Agency Determination Lead Agencies will be required to describe their community planning process in detail in the CTED THOR application. If a community planning process is challenged by an agency that feels the decision-making was incomplete, a written complaint may be submitted to CTED. CTED will consider the matter and determine if the Lead Agency application will be accepted. If appropriate, CTED will hold a meeting with all of the stakeholders to help facilitate an agreement. CTED retains the right to make local funding allocations if an agreement cannot be reached between the interested parties.
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The Lead Agency’s application for funding will need to summarize: The community planning process and how it was organized; The allocation criteria; and The Lead and participating agency selection criteria.
I. Consistency with Ten-Year Plan Finally, the county (or counties) for which the Lead Agency is applying will need to certify that the application is consistent with the local Ten-Year Plan, thereby approving the application for submission. There will be a certification letter in the application that will need to be signed by a county official.
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