Manatee County

					                                         Manatee County
                       Homeless Prevention Rapid Re-Housing Program (HPRP)
               FAQs Updated March 31, 2010 (newest questions are listed first)

The following FAQs are compiled based on Partner Organization questions. As we receive
questions from Partner Organizations, we will update Partner Organizations with the answers.

 1) Q: When the Partner Organization provides security deposit assistance to an
    applicant and the applicant moves, who does the security deposit go back to? A: The
    security deposit moves with the applicant. If the applicant/tenant moves, the security
    deposit is refunded to the applicant/tenant by the landlord.

 2) Q: If a client is living in a hotel that is being paid for by a church, and their time is
    about to run out, are they 'homeless' or 'at risk of homeless'. I don't see living in a
    hotel listed under either on the Housing Status Criteria form.
   A: If the client Will be homeless, but for the HPRP assistance, then they are considered
   homeless. Likewise, if client is being exited from transitional housing, a residential treatment
   program or getting out of jail these situations also qualify the client as homeless.

 3) Q: How many individuals of the household must provide a social security number?
    A: Current federal regulations require a social security number for every family member.

 4) Q: Is the funding provided to clients in HPRP considered as income?
    A: HPRP assistance does not count as income for HPRP income eligibility purposes (i.e., if
    a program is reassessing eligibility for a household receiving rental assistance, they would
    not count the HPRP assistance already provided as household income).

 5) Q: If a student is on scholarship for a program that is not on the approved list of
    programs, can he/she qualify for rental assistance?
    A: Yes, with supporting documentation from the institution/school defining the scholarship
    and/or the program of study and approval from Suncoast Partnership.
NOTE: This question about illegal aliens appears on the www.hudhre.info website.

6) a) Q: Can HPRP funds be used to assist illegal immigrants? If so, what type of
identification documentation is acceptable?

HUD’s answer is: In accordance with Title IV of the Personal Responsibility and Work Opportunity
Reconciliation Act of 1996, an alien (a person who is not a U.S. citizen or national) may be eligible for
assistance under HPRP only if he or she is a “qualified alien” (defined in 8 U.S.C. 1641). This means that
no entity that receives funds under HPRP may knowingly provide HPRP assistance to an alien who is not
a qualified alien. For the definition of Qualified Alien, go to http://law.onecle.com/uscode/8/1641.html

 6) b) Q: If a household member is either a) an illegal alien (adult) OR b) a child born in
    another country/not a citizen yet - Does the presence of that person in the household
    prevent the head of household from qualifying for HPRP funds?
     A: No, the illegal alien may be included in the household if they are a “qualified alien” based
    on the language in US Code 1641.

February 11, 2010
7) Q: If the illegal resident/family member is not counted in the number of persons in a
   household can the head of household still qualify based on the adjusted household
   size?
    A: Yes. If the alien is not qualified, then that person will not be counted in household size
   and the rest of the household will qualify for assistance with the applicant.


8) Q: Is there a policy regarding whether/when an individual who had received rental
   assistance prior to HPRP would be eligible for assistance under HPRP. So, I am
   asking if there are re-application time limits?
   A: There is nothing in HUD or Manatee County guidelines prohibiting someone from getting
   HPRP rental assistance if they have received another form of assistance in the past.

9) Q: The Currently Employed or Proof of Future Management Model, it states that
   applicant must have either lost a job or had unexpected medical expense that
   prevented them from paying their rent. Can this model be used for a client that is
   employed, has been employed, but fell behind with rent due to loss of hours?
   A: To increase income the client should consider: either participating in an Education
   program, OR performing a Job Search to get a better paying job, or a second job. Then
   they would be considered either a Job Seeker or Enrolled in Training.

10) Q: For the purpose of HPRP Income Qualification, can we include the legally
    dependent Son and Daughter attending college out of state?
    A: Yes you can. Be sure to get via fax or email the Disclosure Statement for Collection of
    Social Security Numbers from each college student.

11) Q: A client who lives in a trailer she owns, which is on a rented lot, has applied for
    HPRP assistance. She is in arrears on her rent on the lot because of unemployment,
    and she does have an eviction notice. She does not have a lease on the property.
     The management company does not issue leases, but rather a statement of
    scheduled payment due dates. If the tenant signs this schedule; can it be substitute
    for a lease?
    A:Yes. It is important to provide supporting third party verification of an agreement between
    tenant and landlord. This be documented by the existence of an eviction notice which
    corresponds with the lot fee schedule.

12) Q: Does the County do inspections on (trailer/mobile home) lots only?
    A: Neither the Rent Reasonableness nor an inspection will be required in this case. .
13) Q: The forms that are on the Case File Checklist, are all of these required regardless
    if they applicable to the client?
    A: No, only the forms necessary to qualify and follow an eligible client should be used.
    These-will be somewhat different for each client.
14) Q: The Preliminary Plan and the Comprehensive Plan- will these forms be made
    available or are we just to use our agency forms?
    A: The agencies will use their own forms/process.


February 11, 2010
15) Q: Is there a job search form?
    A: We will provide this. In some cases, the client will be on Unemployment and we can
    accept those forms. IF they are checking in with Unemployment office weekly and using that
    system for Job Search we can use the same forms to document their search.
16) Q: .Who is the contact person for unit inspections- Where are the requests faxed?
    A:Fax to Suzie Dobbs (941) 742-5848 fax number. This information is in your program
    guidelines.

17) Q: Regarding Utility Allowances: new sheets rec‟d 12/21/09; Why aren‟t the costs for
    range and refrigerator included on any of the 3 forms?
    A: This information is included on the updated Utility Allowance sheets dated 1/1/10. NOTE:
    Read page two of the instructions for utility allowances to understand why Range and
    Refrigerator are listed separately from the Utility Expenses for Electricity/other power. This
    has to do with the tenants providing their own apps or renting them. The line items for R/R
    have to do NOT with utility cost of these, but if they were to be rented or paid on time as
    opposed to the common practice of these being provided by landlord as an amenity.

18) .Q: The HPRP Eligibility Release Form does not indicate that it would allow
    participating agencies to get info from the landlord at the 3,6 and 12 month follow-
    ups; it is for „eligibility and continued participation‟. Do we write in “follow-ups to
    establish housing status” in the “Other” space?
    A: Yes. This is important to include the landlord so that follow-ups may be done.

19) Q: HPRP-Manatee Boards & Staff („Conflict of Interest‟ list). Does checking this list
    fulfill all of the requirements of the Participating Agencies to establish that no
    conflict of interest exists? The quoted section of HPRP above the list states that
    „family or business ties‟ with the landlord would constitute conflict of interest,
    making the case ineligible. We would not know if the landlord who would be
    receiving HPRP funds might be a relative/have business ties with anyone on this list.
    Please verify what our responsibility is.
    A: There are two processes, which must be included to establish no conflict of interest.
    First you check the landlord’s name against the list provided. Secondly, there is the
    statement underneath the landlord’s signature on the Request for Unit Approval.

20) Q: Utility Allowance Charts: I would like clarification on when the use of these charts
    is required.
    A: The purpose of the Utility Allowance is to establish whether the proposed unit falls within
    Rent Reasonableness and this info is still required for the comps on the Rent
    Reasonableness Checklist. These charts are a reference for use when any of the comps
    includes a different combination of utilities provided by landlord.

21) Q: Rent Reasonableness: Suppose a Proposed Unit cannot be shown to be equal to
    or less than the Payment Standard of the Comparable Units. Are we allowed to
    consider important benefits existing in the Proposed Unit that may be lost in a move
    to a “less expensive” unit. If a client has lived at a Proposed Unit for a significant
    period of time, this unit is „home‟. Do the clients get a voice as to whether the change
    is a good one for them?
    A: If it can be shown that the move would be more costly to the client then it is not a good
February 11, 2010
    move. In the client file provide written description of why the new location costs more.

22) Q: Rent Reasonableness Instructions 1/12/10: Where do we get info on the Housing
    Condition?
    A: Since inspections are not being done on the comps, it will be safe to use the term
    “Average” for the property condition in most cases.

23) Q: Request for Unit Approval form: instructs landlord to read the sample Lease
    Addendum and info about Housing Habitability Standards. Is the Housing Habitability
    Standards Inspection Checklist acceptable for this purpose, or do we need to copy
    Appendix C of the HPRP Notice as referred to in the Housing Habitability Standards
    Inspection Checklist?
    A: Yes providing this information would be helpful for some landlords. Appendix C can be
    found on pages 56 and 57 of the HUD Notice of Allocations in tab 5 of your HPRP manual.

24) Q: Is a list of eligible Education and Training programs being worked on?
    A: Yes it is. We have this list and have placed it on the HPRP website.

25) Q: What are NSP rental units?
    A: Neighborhood Stabilization Program.

26) Q: If HPRP funding is used to provide a client a hotel/motel voucher, can a Partner
    Organization provide additional HPRP funding for rent and/or utilities?
    A: Yes. Once a client has been placed in an approved unit they may qualify for help in the
    first few months of their lease. The number of months of rent covered depends upon
    whether they are eligible as an Active Job Seeker, Enrolled in Training, Currently
    Employed/Future Management or Approved for other cash benefits.

27) Q: I thought it had been decided at one of the trainings that a client has to stay with
    the same HPRP Case Manager (or at least the Partner Org) throughout the program.
    Are hotel/motel vouchers an exception to this?
    A: No

28) Q: Sec.1 Guidelines: III. Additional Eligibility Requirements: 1) states client either lost
    a job or had an unexpected medical expense that prevented them from paying their
    rent. Is medical expense the only kind of unexpected expense eligible? I have a client
    who is a senior, reportedly disabled, living on a limited Social Security income. He
    had to pay to have his car repaired, which took his rent money, and now he reports
    he has been given a 3-day notice. Is he ineligible? Is the determination being made
    that he doesn‟t need his car (doctors, groceries etc) and should abandon it because
    his rent comes first?
    A: Unexpected medical expenses are shown as a valid reason for inability to pay housing
    costs. Personal expenses such as auto repairs will have to be addressed either by the
    HPRP Committee or Manatee County.

 29) Q: If a client owns his trailer, pays lot rent for which he has a lease, and appears
     eligible, does Manatee inspect the client-owned trailer and force the client to make
     required repairs or no HPRP funds?
     A: There is no inspection of trailers or lots.
February 11, 2010
30) Q: Will/can the county force the trailer owner to repair the trailer even if they don‟t get
    HPRP? If the client could afford the required repairs, they may not have needed lot
    rent assistance. The required repairs could easily put client right back in the same
    predicament.
    A: This is a situation where outreach needs to be done to find either an organization or
    individual who would pay for or provide the repairs. NOTE: Since inspections are not
    being done on trailers/mobile homes, this question is moot.

31) Q: Sec.2: „Request for Unit Approval‟ form: Asks for tenant name and Application No.
    What is the Application No.? I thought maybe the HMIS number, but the county
    doesn‟t use HMIS.
    A: Application number is the HMIS number. HMIS is to be used by all Partner Organizations
    providing HPRP assistance.

32) Q: Rent Reasonableness Checklist and Certification form: There are columns for 3
    unit comparisons. Do we have to show 3 comparisons for each Proposed Unit?
    A: Yes, three comparisons must be obtained. Note, one of the comps can be for a similar
    unit within the same complex, when applicable.

33) Q: „Request for Unit Approval‟ form: „Conflicts of Interest‟ at bottom: The reference
    to „Partner Organization‟ in this section is not adequate information. How can the
    landlord sign this without that specific info? (Other than the fact that we know
    through experience that small print is so often not read at all)
    A: SPEH has provided the directory of names for reference when obtaining landlord names.
    Names on this list include Manatee County Commissioners, PO board members and
    employee names. The conflicts of interest statement needs to stay on the form.

34) Q: Section 2: The „HPRP Lease Addendum‟ indicates, in Sec A and Sec. D, that the
    participating agency will make „monthly payments‟ to the landlord. Sec. C indicates
    that the term of this lease (addendum) shall continue until termination by tenant or
    landlord, or termination of the HPRP Rental Assistance Program by government or
    participating agency. If we are assisting with only one or two delinquent month‟s
    rent, and no ongoing rent, this form is not a good fit.
    A: The form has been modified enough to fit the HPRP program and really needs to be
    utilized to the best of your ability. When assistance is no longer being provided (which
    should be the end term for the lease addendum) then the terms and conditions of the lease
    addendum are not applicable.

 35) Q: Child Support documentation: It had been mentioned during training that there is
     a way to check of a client gets child support. We used to be able to get the
     depository number from the child support checks, and then get a short history of
     payment from this site. Now that clients do not get these informative check stubs,
     the documentation they have does not show the depository number which is
     required for the search on the website. I could not find – How to use the case
     number provided to get child support history at
     www.myfloridacounty.com/services/child_support/index.shtml
     A: If you have questions about using the online service or if you encounter any technical
     difficulty, please email webmaster@MyFloridaCounty.com. You may also telephone
February 11, 2010
    their office at 877.eCounty (877.326.8689) during business hours of 8:00am-5:00pm
    weekdays. NOTE: Julia called this number and the only way to get a return call from the
    office is if you have EITHER the case number from the court order OR the depository
    number from a check stub or statement.

36) Q: How many individuals of the household must provide a social security number?
    A: Current federal regulations require a social security number for every family member.

37) Q: What procedure is used to determine “rent reasonableness”?
   A: To determine “rent reasonableness” Partner Organizations can find comparables in
   newspaper ads, Craig’s List, www.floridahousingsearch.org or similar sources, obtain a note
   from the property owner/agent verifying comparable rents charged for similar units owned,
   or by using information provided by owners/agents of similar units. Please refer to page 15
   of the HUD HPRP Notice for additional information.

38) Q: May a Partner Organization submit a reimbursement request more often than once
    a month?
    A: Yes. Manatee County will accept reimbursement requests two times per month. The
    SPEH must receive a Partner Organization reimbursement requests no later that the 10th
    and 25th of the month for submittal to Manatee County by the 15th and 30th of the month.
    Note: Please submit reimbursement as early as possible during these time periods.
    Reimbursement requests will be reviewed and processed the order they are received and
    payment for last minute reimbursement requests may be delayed.

39) Q: How many copies of the reimbursement requests and support documentation are
    required for submission?
    A: Partner Organizations are required to submit one original plus two copies of all
    reimbursement requests paperwork.

40) Q: Does household income need to be verified at either 30% AMI and 50% AMI?
    A: No. For HPRP eligibility, the only requirement is that household income must be at or
    below 50% AMI.

41) Q: Can HPRP be used with NSP rental units?
     A: If participants meet all requirements for HPRP and payments to the nonprofit are for
    rent and not for mortgages, you can use the HPRP funds if there is no conflict of financial
    interest between the owner of the property and the administrator of the HPRP program. If a
    conflict of financial interest exists, the grantee may request a waiver for good cause from
    the CPD Director. Note: For further information on conflict of financial interest and request
    of waiver request, you may refer to www.hudhre.info, FAQ’s of August 14, 2009 and
    October 29, 2009.

 42) Q: Are people that rent a room, in halfway houses, or trailers eligible for HPRP,
     assuming they meet all other eligibility requirements?
     A: HPRP cannot be used to pay for any fees associated with Transitional Housing. But if a
     client is graduating/exiting from a TH program they may receive HPRP assistance for the
     next housing situation, provided it meets all the rent reasonableness criteria and a lease is
     in place. HUD does not specifically exclude trailers or lot rental fees from the HPRP
     program.
February 11, 2010
43) Q: Is payment of rent for a mobile home pad or lot an eligible HPRP expense?
    A:Yes - As long as the lot rental arrangement can be documented with a lease agreement.
    REVISED- OR If a lease is not in place then we need to see a current schedule of lot rental
    fees and a notice from the management showing past due lot rental fees.

44) Q: Is an applicant required to provide documentation that he/she is an active job
    seeker at the time of application or only after they have been determined to be
    eligible for HPRP as an “active job seeker?”
    A: A client receiving HPRP assistance is only required to provide job search documentation
    only after they begin receiving HPRP assistance and for every week thereafter while
    receiving assistance.

45) Q: What documentation is required to verify Manatee County residency?
    A: Florida Driver License or ID and if currently housed, a copy of the lease. Note: In some
    cases, a client may be a Manatee County resident yet has a Sarasota postal address.

46) Q: If HPRP funding is used to provide a client a hotel/motel voucher, can a Partner
    Organization provide additional HPRP funding for rent and/or utilities?
    A: Yes. Once the client has been placed in approved rental housing, the deposits for utility
    and rental security for that housing unit may be eligible expenses.

47) Q: Will SPEH provide a list of Manatee County employees and commissioners and
    SPEH and Partner Organization employees and board members to determine whether
    there is any conflict of interest in maintaining/placing a client in a HPRP housing unit.
    A: Yes. SPEH has compiled this list and provided it to the POs.

48) Q: If an applicant is being released from jail, are they eligible for a motel/hotel
    voucher if they meet other HPRP eligibility requirements?
    A: Yes, a person being released from jail, with no place to live, is considered homeless
    under the HPRP HUD Notice.

49) Q: If a case manager determines a client’s eligibility for HPRP by telephone can this
    time be included as case management expense?
    A: No. All case management meetings must be face-to-face.

50) Q: What is the requirement for data collection and verification of income process for
    victims of domestic violence?
    A: Agencies that serve clients who are victims of domestic violence are not required to use
    HMIS. Several alternative options are available including using an anonymous "identifier"
    number, however, verification of income and other forms and procedures must be followed
    to determine HPRP eligibility.




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