CoC FAQ
Q

What are the recordkeeping requirements that were established in the final rule on the definition of chronically homeless?

Date Published: April 2016

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The Final Rule on Defining “Chronically Homeless” establishes recordkeeping requirements for the following criteria, which must be documented for the individual or head of household presenting for assistance:

  • The history of residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven, including where the individual or head of household is coming from currently;
  • Stays in institutions;
  • Breaks of seven nights or more residing in a place meant for human habitation; and
  • The qualifying disability.

For each of the criteria above, with the exception of documenting breaks of seven nights or more in a place meant for human habitation, the final rule requires that recipients maintain and follow written intake procedures which establish the order of priority for obtaining evidence as third-party documentation first, intake worker observation second, and written certification from the person seeking assistance third. Breaks between occasions may be documented entirely by the individual or head of household’s written certification that they resided in a place meant for human habitation, such as in the home of a friend or in a hotel paid for by the household, for at least seven consecutive nights.

The definition of chronically homeless in the final rule requires that an individual or head of household be coming directly from a place not meant for human habitation, an emergency shelter, or a safe haven and that they have been residing in one of these locations in a place not meant for human habitation, an emergency shelter, or a safe haven for a period of at least 12 months either continuously or cumulatively over a period of at least four occasions over the last three years.

In general, HUD expects recipients to document at least 9 of the 12 months the individual or head of household resided in a place not meant for human habitation (e.g., under a bridge, a car), in an emergency shelter, or in a safe haven with third-party documentation. The remaining months can be documented by the individual or head of household’s own written certification that they had resided in one of these locations. For up to 25 percent of program participants served by the project in an operating year, recipients may document up to the full 12 months through the individual or head of household’s written certification of where they were living, but this must be accompanied by the intake workers notes that demonstrate that they have exercised due diligence to obtain a higher level of documentation. It should be noted that the final rule clarifies that a single encounter in a month is sufficient documentation to consider the individual or head of household as residing in that location for the entire month unless there is clear evidence of a break (such as an HMIS record of a stay in transitional housing where the household is not also enrolled in permanent supportive housing and actively seeking a unit) of more than seven nights.


Tags: CoC Program Requirements - Definition of Chronic Homelessness

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