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Board and Care Eligibility
Sent by Allison Davenport on 01/19/2016 01:54 PM (ET)
A chronically homeless client referred to us from the Coordinate Entry System for our Permanent Supportive Housing program was placed in a Board and Care facility (in which the client is paying on their own) with the intention of using this as bridge housing until they were placed into PSH. They have been there for less than 90 days but are able to stay longer.
Is this client still eligible for PSH?
02/16/2016 10:12 AM (ET)
Thank you for your inquiry and providing more information.
We believe the following FAQ (FAQ 1913) addresses your question because, based on the information you provided, it appears the individual was referred to and accepted into a PSH program where there is an actual vacancy and the individual or head of household is in process of locating a unit.
Question: If a person is accepted into a permanent housing program but the project has not secured a permanent housing unit, does their chronic homeless status change if they do not remain on the streets or in an emergency shelter during the period while they are waiting for a unit? Does the chronically homeless household have to remain on the streets or in an emergency shelter during the period from being accepted into the project to lease-up of the unit or can they maintain their eligibility regardless of where they reside during that interim period?
Answer: To be served in HUD’s Homeless Assistance Programs, projects funded under the Continuum of Care (CoC) or Emergency Solutions Grants (ESG) Programs, a household must meet the eligibility criteria under the specific program and applicable component type. Staff must document a client’s chronically homeless status at intake into the project and should follow HUD’s stated preferred order for documentation as described in the Prioritization Notice.
HUD understands that once a chronically homeless household has been determined eligible and accepted into a CoC Program-funded permanent supportive housing program, a unit is not always immediately available. During this time, unless they have other options such as living temporarily with friends or family, the household will generally continue to reside in an emergency shelter or on the streets, prolonging their period of homelessness. Communities should continuously work to improve the system to decrease the amount of time it takes to secure a unit for program participants once accepted into a PSH program.
Because these types of changes and improvements can take time, HUD has determined that after an individual or family has been accepted into a program but before an appropriate unit has been identified, a household may stay with a friend or family or in a hotel or motel without losing their eligibility for the permanent supportive housing program in which they have already been accepted. HUD would also allow a CoC to temporarily house the participant in an available transitional housing bed while a permanent housing unit is identified. This allowance is only permitted in the circumstances described here and does not apply to persons enrolled in transitional housing that were considered chronically homeless prior to entry into the program and the following requirements apply:
- Since the program participant has been accepted into a permanent supportive housing project, the transitional housing provider cannot place any requirements on the program participant, including requiring a program participant to participate in additional services as a condition of occupancy or requiring the program participant to meet sobriety requirements.
- The permanent supportive housing provider must be actively assisting the program participant to identify a unit as quickly as possible and must be able to document attempts at locating a unit in the case file. Under no circumstances, should the placement in transitional housing slow down placement into permanent housing. This means that placing a program participant into a permanent housing unit should not take any longer than the time it would normally take to place someone in permanent housing who is residing on the streets or in an emergency shelter.
- There cannot be duplication in billing for the program participant. For example, both programs cannot provide and then seek reimbursement from HUD for housing search or other services. The permanent supportive housing provider and the transitional housing provider must coordinate to ensure that appropriate services are provided and the same services are not being paid for out of both grants.
In addition to working to decrease the length of time it takes to locate and house a program participant in a permanent supportive housing unit, HUD expects CoCs to routinely review their portfolio of homeless assistance housing options to ensure the supply reflects the need. This means that if a CoC recognizes it has many homeless persons eligible for permanent supportive housing, for example, but they have more transitional housing available, then they should seriously consider developing a reallocation strategy that would allow them to reduce the number of transitional housing options in favor of creating more permanent supportive housing. HUD recognizes this takes time and is offering CoCs this flexibility, when the criteria above has been met, so chronically homeless persons have an alternative to sleeping on the streets when waiting for housing placement.
HUD encourages CoCs and recipients to follow a Housing First approach and establish policies and procedures that reduce barriers to obtaining a unit and reduce the amount of time households wait for units. This could include strategies such as identifying landlords who are willing to work with the recipient, inspecting units for Housing Quality Standards in advance of a household being shown the unit, and identifying landlords who are willing to rent units already in compliance with HUD’s standards of Fair Market Rent and rent reasonableness.
Be aware, the aforementioned guidance does not apply if the individual is only on a waiting list for PSH. If the individual is on a waiting list only and they are waiting for a vacancy within the program, their eligibility must be determined at the point in which there is an actual opening in the program which they have been offered and accepted. If they were on the waiting list prior to January 16, 2016 but there is not an actual opening in the program until after that date, their eligibility must be determined based on the new definition of chronically homeless that was included in the Final Rule on Defining “Chronically Homeless.”
Of further note, the following information applies to Board and Care housing for the purposes of determining if the housing is considered permanent housing, transitional housing, or an institution:
There are different kinds of board and care arrangements, so without additional details, this help desk cannot determine whether the board and care facility you reference in your question would be considered permanent housing (independent living), transitional housing, an institution, or none of the above. Some things that HUD considers when making this determination include how the project is funded, the conditions upon which an individual can stay there, and the rules placed upon program participants while they reside there. We also recommend you check with your CoC to determine if this board and care house is reported on the CoC's Housing Inventory Count. Once you determine how the Board and Care Housing should be identified, you should review the definition of homeless in section 578.3 of the CoC Program interim rule to determine if the people residing there are homeless. If you have additional questions about this Board and Care House, please submit an additional question with additional information.
Please note: the response provided in this email is specific to the question you submitted and may not apply to similar questions. Therefore, please use discretion in providing the response to others, as the answer may not apply to their particular situations