Recordkeeping Requirements for Chronic Status

What are the recordkeeping requirements for PSH projects serving chronically homeless persons?

The “Chronically Homeless” Final Rule establishes the corresponding recordkeeping requirements for chronically homeless persons. Documentation must include evidence that an individual was homeless with a disability (per § 401(9) of the McKinney-Vento Homeless Act).

Evidence of Chronic Homelessness Status*

Written intake procedures must follow the established priority order for obtaining evidence. Generally, this is the priority order for establishing a person's chronic homelessness status:

  • 3rd-party documentation
  • Intake worker observation
    • Written observation by outreach and/or intake worker of encounters with person/household (must include description of living conditions)
    • Self-certification* (written) by individual/head of household seeking assistance
    • Does not need to be notarized
    • Must be signed by individual/head of household, and
    • Intake worker must still document living situation of individual/head of household seeking assistance, and
    • Intake worker must document all steps taken to higher order of priority evidence

Looking for definitions of the common CoC and ESG Program terms referenced throughout the Virtual Binders?

Virtual Binders Glossary

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A child with a disability can qualify a household as chronically homeless if:

  • There is no adult present in the household; and
  • They meet all other criteria (e.g. length-of-time homeless)

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Grant recipients must maintain and follow written intake procedures to comply with the chronic homeless definition. Procedures must do the following:

  • Require evidence at intake to verify and document chronic homeless status and disability
  • Establish the order of priority for obtaining evidence to verify status

*100% of all households served by a recipient can use self-certification to document periods of homelessness of up to 3 of the 12 months of homelessness. However, recordkeeping requirements provide that up to 25% of all households served by a recipient can use self-certification as documentation for the full period of homelessness in the rare instances where persons have been unsheltered and out of contact for long periods of time. Attempts to obtain third-party documentation and the reason(s) that documentation was not obtained must be documented. At least 75% of households served in an operating year must have 3rd party documentation for 9 of 12 months of homelessness and self-certification may be used for the remaining months.

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If self-certification of chronic homelessness is received, HUD recommends that the recipient continue to try to obtain third-party documentation within 180 days of the participant’s enrollment in the project. However, breaks in homelessness can be documented by self-certification.

Disability Defined

The term homeless individual with a disability' means an individual who is homeless, as defined in § 103 of the McKinney-Vento Homeless Assistance Act, and has a disability that:

  • Is expected to be long-continuing or of indefinite duration;
    • Substantially impedes the individual's ability to live independently;
    • Could be improved by the provision of more suitable housing conditions; and
    • Is a physical, mental, or emotional impairment, including an impairment caused by alcohol or drug abuse, post-traumatic stress disorder, or brain injury?
  • Is a developmental disability, as defined in section 102 of the Developmental Disabilities Assistance and Bill of Rights Act of 2000 (42 U.S.C. 15002); or
  • Is the disease of acquired immunodeficiency syndrome or any condition arising from the etiologic agency for acquired immunodeficiency syndrome.

Documentation Requirements

View a flowchart of HUD’s Definition of Chronic Homelessness for additional information.

Situation

Documentation of Homelessness

Documentation of Disability

Household is Chronically Homeless

(12 Consecutive Months)

  • HMIS record or record from a comparable database; or
  • Written observation by an outreach worker of the conditions where the individual was living; or
  • Written referral by another housing or service provider; or
  • Where the evidence above is unavailable, there must be a certification by the individual seeking assistance, accompanied by the intake worker’s documentation of the living situation and the steps taken to obtain the evidence listed above.

If the head of household is currently staying in an institution where they have been for less than 90 days (and were in a shelter/street/safe haven immediately prior) their institutional stay can be documented by:

  • Discharge paperwork or written/oral referral from a social worker or appropriate official of the institutional facility, with start/end dates of program participant's residence, or
  • Where evidence above is unavailable, there must be a certification by the individual seeking assistance, accompanied by the intake worker’s documentation of the living situation and the steps taken to obtain the evidence listed above.

Documentation of the head of household’s disability, including:

  • Written verification of the disability from professional licensed by the state to diagnose and treat the disability;
  • Written verification from the Social Security Administration;
  • The receipt of a disability check (e.g. SSDI check or Veteran Disability Compensation);
  • Intake staff-recorded observation of disability that, no later than 45 days from the application for assistance, accompanied by evidence above; or
  • Other documentation approved by HUD.

Household is Chronically Homeless

(4+ Occasions totaling 12 months over three years) *

*May include institution stays of <90 days

  • HMIS record or record from a comparable database; or
  • Written observation by an outreach worker of the conditions where the individual was living; or
  • Written referral by another housing or service provider; or
  • Discharge paperwork or written/oral referral from a social worker or appropriate official of the institutional facility, with start/end dates of program participant's residence (for institutional stays of less than 90 days)
  • Where the evidence above is unavailable, there must be a certification by the individual seeking assistance, accompanied by the intake worker’s documentation of the living situation and the steps taken to obtain the evidence listed above.

* Each separate occasion MUST be documented (minimum of three breaks). 100% of the breaks can be documented by self-report.