CoC FAQ
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What may be considered acceptable (but not third party) documentation for an individual or head of household's history of residing in a place not meant for human habitation, emergency shelter, or safe haven in light of the final rule on the definition of chronically homeless?

Date Published: April 2016

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The Final Rule on Defining “Chronically Homeless” clarifies that the order of priority for obtaining documentation of an individual or head of household’s history of residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven is first third-party documentation, followed second by the written observation of an intake worker, and third by the self-certification of the individual or head of household seeking assistance.

The following are examples of what may be considered documentation for the second and third orders of priority.

  • Written Observation of an Intake Worker: A written observation from an intake worker would count as this second order of priority and not as third-party if their only encounter with the individual or head of household is at the current point in which they are seeking assistance and the intake worker has not physically observed where the individual or head of household is currently residing. The intake worker may provide a written observation of why, based on their professional judgment, they believe that the individual or head of household has been living in a place not meant for human habitation, in an emergency shelter, or in a safe haven for the months in which they have not personally encountered the individual or head of household. This could include months in which the individual or head of household could not remember but where the intake worker believes, based on their professional judgment that it is reasonable to assume that the individual or head of household had been residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven.

    The intake worker should exercise due diligence to obtain third-party documentation and the written observation must include what attempts were made to obtain third-party documentation. This documentation does not count towards the requirement that at least 9 months of the individual or head of household’s period of homelessness be documented based on third-party documentation. For all program participants in an operating year, up to 3 months of the documentation could be based on a written observation of an intake worker as described here. Only up to 25 percent of program participants that were admitted after January 16, 2016 in an operating year could have more than 3 months (up to the full period of homelessness) documented exclusively through written observation from an intake worker.

  • Written Certification from the Person Seeking Assistance: Where no other documentation is available, the individual or head of household seeking assistance may provide a written self-certification of the specific months in which they report that they had been residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven.

    The self-certification must be accompanied with documentation of the intake workers attempts to obtain third-party documentation. This documentation does not count towards the requirement that at least 9 months of the individual or head of household’s period of homelessness be documented based on third-party documentation. For all program participants in an operating year, up to 3 months of the documentation could be based on a self-certification from the individual or head of household seeking assistance. Only up to 25 percent of program participants that were admitted after January 16, 2016 in an operating year could have more than 3 months (up to the full period of homelessness) documented through self-certification alone.

Tags: CoC Program Requirements - Definition of Chronic Homelessness

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2761