CoC FAQ
Q

For many persons experiencing chronic homelessness, obtaining required third-party documentation can take a long period of time. Are recipients of PSH required to have all third-party documentation at the point of intake and enrollment of a program participant into a project?

Date Published: July 2016

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The recordkeeping requirements included in the Final Rule on Defining “Chronically Homeless” are meant to ensure that, when applicable, permanent supportive housing (PSH) that is dedicated to serving persons experiencing chronic homelessness is being used to serve persons that meet the definition. It was never HUD’s intention that these requirements act as a barrier to housing those most in need of PSH as quickly as possible. In fact, HUD believes that its final recordkeeping requirements for the definition of chronically homeless strike the appropriate balance and do not create a level of documentation that is too burdensome. This is part of the reason that HUD permitted each project to serve up to 25 percent of the individuals and families in a given operating year who do not have at least 9 months of their stays in a place not meant for human habitation, safe haven, or emergency shelter documented by third-party documentation.

However, even with this 25 percent allowance, HUD has received comments that some additional time is often needed by recipients and subrecipients to obtain the appropriate documentation of an individual or head of household’s chronic homeless status. Therefore, although the final rule requires documentation of eligibility at intake to the project, it does not require that all third-party documentation be acquired at the point of intake. HUD recognizes that it may take a little bit more time to obtain third-party documentation for documenting chronic homeless status in accordance with the final rule for prior months or occasions. Therefore, HUD has determined that although the recipient must follow the order of priority for obtaining evidence as required in the final rule, written self-certification at the point of intake for up to the full period of time homeless required by the definition of chronically homeless is sufficient (if no other documentation can be obtained at that point in time) for the recipient to enroll the household into the project. The recipient then must work to obtain the required third-party documentation within 180 days from the point in which the project participant is enrolled in the project. Project participants that have been enrolled in the project for less than 180 days may be excluded from the calculation for determining whether or not at least 75% of program participants have at least 9 months of third-party documentation.

Following the first 180 days from the point of a program participant’s enrollment, if the recipient or subrecipient has not been able to obtain third-party documentation for at least 9 months of the individual or head of household’s residence in a place not meant for human habitation, a safe haven, or an emergency shelter, then one of the following applies:

  1. If the recipient or subrecipient has not already reached their 25 percent cap, the program participant can continue to be assisted in the project and the recipient or subrecipient must consider this program participant as counting towards their 25 percent allowance; or
     
  2. If the recipient or subrecipient has already reached their 25 percent allowance, no additional CoC Program funds can be used to continue serving this household in that project. For this reason, HUD encourages recipients that are currently at their 25 percent allowance to use this additional time carefully and only for program participants where they are fairly certain that the required third-party documentation can be obtained. It is also for this reason that HUD encourages recipients and subrecipients to continue to obtain at least 9 months of third-party documentation for program participants, even after a program participant has been enrolled in the program for some time, because if a recipient is ultimately able to obtain 9 months of third-party documentation of a head of household’s homeless status, then that household can be removed from the 25 percent calculation.

Example: Henry is a program participant that entered a project on June 1st. He reports that he has been living in a place not meant for human habitation, a safe haven, or an emergency shelter for the last 12 months. At the point of intake, there was only 2 months of third-party documentation of Henry residing in one of these locations. The recipient of PSH may obtain a self-certification from Henry for the remaining 10 months in order to enroll Henry in the program and get him into housing. The recipient then has up to 180 days from the point of his enrollment to obtain at least 7 additional months of third-party documentation (to add to the 2 months that had been obtained at the point of intake) to get to the 9 months of required third-party documentation. At any point in time, the program will calculate whether or not they are meeting the requirement that at least 75 percent of program participants have third-party documentation for at least 9 months of their homelessness history based on program participants that enrolled after January 15, 2016 and had been enrolled in the program for 180 days or more. If the recipient is not able to do so, and is not at their 25 percent allowance, then they could continue to serve Henry, but must count him towards their 25 percent allowance. But, if the recipient was already at their 25 percent allowance, the recipient could no longer serve Henry in that project.

Please note, recipients must continue to obtain third-party documentation of the head-of-household’s disability within 45 days, as required by the final rule.


Tags: CoC Permanent Supportive Housing Program Requirements - Definition of Chronic Homelessness

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FAQ ID:

2872