Emergency HOME TBRA Toolkit

This page contains guidance and resources for HOME Participating Jurisdictions (PJs) implementing emergency Tenant-Based Rental Assistance (TBRA) programs in response to the COVID-19 pandemic. General guidance and resources on TBRA can be found on the HOME Tenant-Based Rental Assistance topics page.

Visit the HOME COVID-19 Guidance page for additional information and resources related to COVID-19 response for the HOME Program.

Regulatory Resources

CPD Memo: Suspensions and Waivers to Facilitate Use of HOME-Assisted TBRA for Emergency and Short-term Assistance in Response to COVID-19 Pandemic

On April 10, 2020, HUD issued this memorandum which provides guidance and the necessary statutory suspensions and regulatory waivers to enable HOME PJs affected by the COVID-19 pandemic to use HOME TBRA funds to facilitate urgent housing assistance to the communities and families experiencing financial hardship.

HOME Program COVID-19 Response: Statutory Suspensions and Regulatory Waivers Webinar

On April 20, 2020, staff from OAHP hosted this webinar for HOME PJs and provided information and answered participant questions on topics including:

  • Statutory suspensions and regulatory waiver flexibility for COVID-19 response
  • Using HOME funds for emergency TBRA
  • Applicability of the CARES Act eviction moratorium to HOME projects
  • Answers to FAQs

Program Planning and Design

Designing and Implementing an Emergency HOME TBRA Program Webinar Part 1: Pre-Planning and Design

The first webinar in the series, held on June 10, 2020, focused on critical initial pre-planning steps involved in determining whether and how to implement a TBRA program using flexibility provided by statutory suspensions and regulatory waivers announced on April 10, 2020. While suspensions and waivers will help PJs accelerate program implementation, there are key issues PJs must consider when designing a local TBRA program to ensure it will be effective and compliant.

Designing and Implementing an Emergency HOME TBRA Program Webinar Part 2: Developing Policies and Procedures

The second webinar in the series, held on June 17, 2020, focused on developing policies and procedures for an emergency TBRA program. While statutory suspensions and regulatory waivers announced on April 10, 2020 will help PJs accelerate program implementation, PJs must develop policies and procedures to ensure the efficient and compliant rollout of such programs.

Designing and Implementing an Emergency HOME TBRA Program Webinar Part 3: Office Hours

The third webinar in the series, held on June 24, 2020, focused on answering questions from HOME PJs developing emergency TBRA programs in response to the COVID-19 pandemic. This webinar provided clarification on topics and addressed questions from the first two webinars in the series.

Emergency HOME TBRA Program - Design Crosswalk

This crosswalk provides an overview of the HOME Program regulations applicable to the design and management of a TBRA program and highlights those statutory provisions suspended and regulations waived by HUD on April 10, 2020 in response to the COVID-19 pandemic.

Emergency HOME TBRA Program - Program Design Decisions

This tool provides PJs with an outline of key policy decisions and program planning steps that will expedite program planning and ensure compliance with HOME rules, including those not modified by waivers. The guidance is organized into three phases – initial program design decisions, the process for approving the program and notifying HUD of waivers elected, and the design of detailed policy and procedures to ensure fairness and transparency when providing assistance.

Designing and Implementing an Emergency HOME TBRA Program: Environmental Review Video FAQ

This video FAQ summarizes the environmental requirements applicable to the emergency TBRA programs being funded by HOME PJs in response to the COVID-19 pandemic.

Emergency HOME TBRA Sample CENST Environmental Review Form

This sample CENST form is intended for use by HOME PJs implementing a HOME COVID-19 emergency TBRA program. It is assumed that the rental assistance activity is conducted without any associated repairs, rehabilitation, new construction, or other activities with physical impacts.

Program Administration

Emergency HOME TBRA Sample Subrecipient Agreement

In accordance with the HOME regulations at §92.504(c), PJs must enter into a written agreement with any subrecipient that will manage a portion of the PJ’s HOME program, including any portion of the emergency TBRA program. This sample Subrecipient Agreement may be used by PJs who are funding nonprofit or public subrecipients to implement an emergency TBRA program. The sample form assumes the use of all available waivers related to emergency TBRA as outlined in the April 2020 TBRA Memo.

HOME FACTS Vol. 9, No. 1: Set Up, Fund, and Complete HOME TBRA Activities in IDIS

This issue of HOME FACTS provides guidance on how PJs should set up, fund, and complete HOME TBRA activities in IDIS.

Project Management

Emergency HOME TBRA Sample Application

This Emergency HOME TBRA Sample Application may be used by PJs to implement their local programs in response to the COVID-19 pandemic. The sample form assumes the use of all available waivers related to emergency TBRA as outlined in the April 2020 TBRA Memo. It may be used both for existing tenants seeking assistance to remain in a unit they already occupy or for households seeking a new unit to rent.

HOME Sample Self-Certification of Annual Income Form

The sample form is provided as a guide and should be adapted to include the PJ's policy and procedures regarding income eligibility requirements for emergency TBRA/rental assistance. The income sources listed on the form reflect annual income as defined by 24 CFR 5.609 (a)-(c) (Part 5) which is commonly used in HUD's rental and TBRA programs. PJs must update this form if they use the IRS 1040 adjusted gross income definition for its TBRA/rental programs.

Emergency HOME TBRA Sample Owner Certification

This Emergency HOME TBRA Sample Owner Certification may be used by PJs to implement their local programs in response to the COVID-19 pandemic. The sample form assumes the use of all available waivers related to emergency TBRA as outlined in the April 2020 TBRA Memo and is a companion to the Emergency HOME TBRA Sample Application that a low-income household would complete. PJs may use the sample form to assess the physical condition of a unit in lieu of a physical inspection to reduce the risk of exposure of inspectors and tenants. It may be used in situations involving existing tenants seeking assistance to remain in a unit they already occupy or in situations where a household is seeking a new unit to rent.

Emergency HOME TBRA Sample Rental Assistance Contract

HOME PJs may reference this sample tri-party rental assistance contract between the Program Administrator, Owner, and Tenant (the “Sample Rental Assistance Contract”) to provide rental assistance to or on behalf of individuals and families experiencing financial hardship, either permanently or temporarily, due to impacts of the COVID-19 pandemic. A rental assistance contract that complies with federal requirements, including HOME requirements at 24 CFR part 92 and the April 2020 TBRA Memo must accompany the application for assistance and be kept as a record in the tenant/project file.