Date Published: May 2006
No. STRMU can only be used to assist someone currently in housing as an intervention to prevent homelessness. Other HOPWA components can be used to assist someone who is homeless in obtaining housing and other support.
HOPWA funds may only be used for eligible activities as cited in 24 CFR 574.300. These "uses" are intended to address unmet housing needs, including costs when no other funding or insurance is available, and assistance must be consistent with OMB-circular standards for real needs. As provided in section 574.300, HOPWA funds may be used to assist all forms of housing designed to prevent homelessness including costs to develop and/or operate emergency housing facilities, which could assist an eligible person who is homeless. The STRMU activity, however, is established in statute to prevent a household from becoming homeless and could be used to addresses urgent financial needs in order to prevent eviction or loss of the housing unit that is occupied by eligible persons, and thereby continues residency in the current unit. This is an important distinction to be tracked in undertaking the different eligible activities.
Often households may find themselves in an emergency situation, which should be resolved quickly at the local level with HOPWA funds or other related assistance. In providing assistance, it is important to assess the reasons for household's debt. Grantees should not pay for housing-related costs if the client's need is a result of other expenses resulting from poor money management, such as credit card debt or unnecessary entertainment expenses. If these issues are present, a case management plan should be put in place to address budgeting and money management issues. If the client does not demonstrate compliance with the case plan, on-going STRMU or other assistance should not be provided. While it is not easy to separate needs related to living with the challenge of HIV/AIDS, the intent of the HOPWA program is to address the housing needs for eligible persons.
Also, subject to compliance with applicable civil rights requirements, grantees may add additional conditions of eligibility, but the needs test for HOPWA eligibility established by law is that a person must demonstrate their HIV positive status or AIDS diagnosis and the low-income status for the eligible person and their family. The grantee or sponsor must also assess the specific level of need they require to remain housed.
Various communities make eligibility requirements more restrictive due to the limited amount of HOPWA resources and the need to integrate program support with other efforts and to help address the most pressing housing needs for a large population of consumers who may ultimately qualify for benefits. To meet the needs of the higher risk population, the grantee must identify the needs in their Consolidated Plan planning process, involving local consultations and public participation. HUD permits the use of local preference as a means of prioritizing benefits to those who are most needy. "Local Preferences" are to be approved through HUD's Field Office of Fair Housing and Equal Opportunity (FHEO) to ensure that such practices do not discriminate or inadvertently exclude any persons either by design or omission.