e-snaps FAQ
Q

If my project chooses to become DedicatedPLUS, what documentation will HUD expect to see in the client’s file to demonstrate compliance with the expanded population? 

Date Published: September 2017

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Recipients who receive funding as a DedicatedPLUS project must document eligibility of all program participants served. As a reminder, DedicatedPLUS projects must serve individuals and families with one or more disability and who meet one or more of the following criteria at project entry:

  1. experiencing chronic homelessness as defined in 24 CFR 578.3;
     
  2. residing in a transitional housing project that will be eliminated and meets the definition of chronically homeless in effect at the time in which the individual or family entered the transitional housing project;
     
  3. residing in a place not meant for human habitation, emergency shelter, or safe haven; but the individuals or families experiencing chronic homelessness as defined at 24 CFR 578.3 had been admitted and enrolled in a permanent housing project within the last year and were unable to maintain a housing placement;
     
  4. residing in transitional housing funded by a Joint TH and PH-RRH component project and who were experiencing chronic homelessness as defined at 24 CFR 578.3 prior to entering the project;
     
  5. residing and has resided in a place not meant for human habitation, a safe haven, or emergency shelter for at least 12 months in the last three years, but has not done so on four separate occasions; or
     
  6. receiving assistance through a Department of Veterans Affairs (VA)-funded homeless assistance program and met one of the above criteria at initial intake to the VA's homeless assistance system.

For all program participants, recipients must obtain the following documentation:

  1. Evidence that the individual or family member (if qualifying as chronically homeless or previously chronically homeless, this must be the head of household) has a qualifying disability as defined in section 401(9) of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11360(9)). 
     
  2. Evidence that the program participant is currently residing in a location that makes them eligible.
     
  3. Where the program participant does not presently meet the definition of chronically homeless, evidence of the length of time they resided in an emergency shelter, safe haven, or place not meant for human habitation prior to residing in the location that made them lose their chronically homeless status to determine whether they previously met the criteria for chronic homelessness at 24 CFR 578.3.

In obtaining the documentation above, recipients must follow HUD’s documentation requirements. This means to document disability status of the head of household (#1 above), recipients must obtain third-party documentation that meets the standards described in FAQ 2763.

For all other criteria (#2 and #3 above), recipients must follow HUD’s orders of priority for obtaining evidence as third-party documentation first, intake worker observation second, and certification from the person seeking assistance third. Recipients of DedicatedPLUS projects are not required to follow the recordkeeping requirements included in the final rule on Defining Chronically Homeless for beds not dedicated to individuals and families experiencing homelessness. However, HUD expects recipients to obtain as much third-party evidence as possible when documenting length of time homeless. Recipients should demonstrate due diligence at collecting third-party evidence (e.g., phone calls or emails to other providers) as well as case worker judgement when third-party evidence is limited.

To ensure consistency across all recipients within the Continuum of Care (CoC), CoCs should consider adopting specific standards for DedicatedPLUS projects on the extent in which third-party documentation is required for documenting the length of time program participants resided in a place not meant for human habitation, an emergency shelter, or a safe haven.

Below are some examples of the type of documentation that HUD would accept as adequately documenting that an individual or family met the DedicatedPLUS criteria.

  • For individuals and families experiencing chronic homelessness as defined in 24 CFR 578.3, the documentation required in the Defining Chronically Homeless Final Rule;
     
  • For individuals and families who are residing in transitional housing project that will be eliminated through reallocation, transitional housing funded through the Joint TH and PH-RRH Component project, or receiving assistance through a Department of Veterans Affairs (VA)-funded homeless assistance program evidence that the individual or head of household:
     
    • has a qualifying disability,
       
    • was residing in an emergency shelter, safe haven, or place not meant for human habitation immediately prior to entering one of these projects, and
       
    • Met the criteria of the definition of chronic homelessness as defined at 24 CFR 578.3 prior to entering the permanent housing project.

    In addition, the intake worker should include in the case file one of the following, depending upon the location from which the individual or family is currently residing:
     
    • For individuals and families coming from TH that is being eliminated through reallocation, evidence that the TH project was eliminated in the FY 2017 CoC Program Competition through reallocation (e.g., a copy of the CoC’s reallocation charts)
       
    • For individuals and families coming from TH funded through a Joint TH and PH-RRH Component project, evidence that the individual or family is coming from that project (e.g., a written referral on letterhead from the agency that identifies the name of the project); or
       
    • For individuals and families receiving assistance through a VA-funded homeless assistance program, evidence that they are receiving assistance through a VA-funded homeless assistance program (e.g., a written referral from the VA program that identifies the name of the project and that it is funded by the VA).

  • For individuals and families that are currently residing on the streets, in a safe haven, or in an emergency shelter that do not currently meet the definition of chronically homeless because they recently resided in a permanent housing project, evidence that the individual or head of household:
     
    • Is currently residing in a place not meant for human habitation, emergency shelter, or safe haven;
       
    • Resided in a permanent housing project within the last year prior to intake;
       
    • Has a qualifying disability; and
       
    • Met the criteria of the definition of chronic homelessness as defined at 24 CFR 578.3 prior to entering the permanent housing project.

      Note, if the individual or family had multiple permanent housing project placements in the prior year, the evidence should come from the first permanent housing project the individual or family resided in.
       
  • For individuals and families who had experienced episodic homelessness over the past three years whose total length of time residing on the streets or in emergency shelters or safe havens equaled 12 months, evidence that the individual or head of household:
     
    • has a qualifying disability,
       
    • was residing in an emergency shelter, safe haven, or place not meant for human habitation immediately prior to entering one of these projects, and
       
    • had resided in an emergency shelter, safe haven, or in a place not meant for human habitation for at least than 12 months in the last three years in fewer than four occasions.

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FAQ ID:

3298