Outreach and Goal-Setting

Module 2.3: Contract of Participation and Individual Training and Services Plan

Contract of Participation and Individual Training and Services Plan

When a new participant begins the FSS program, he or she completes two related documents:

  1. A Contract of Participation, and
  2. An Individual Training and Services Plan (ITSP), which is part of the Contract of Participation.

Let’s take a closer look at each of these documents.

Contract of Participation

The Contract of Participation (HUD-52650) describes the rights and responsibilities of the FSS participant and the organization administering the FSS program. FSS program coordinators should walk through each section of the Contract of Participation with FSS participants to ensure they understand all of the provisions and program requirements and benefits. The Contract is then signed by both parties and records the commitments made by the resident and the program to work together to achieve identified goals. Once signed, a Contract of Participation is effective for five years, beginning the first of the month following the day it was executed.

The Contract lists, upon admission to the program, the family’s annual income, earned income, and the Family Rent, defined as 30 percent of the monthly adjusted income for Housing Choice Voucher participants or the Total Tenant Payment for public housing residents. Calculations of monthly escrow deposits will be based on increases from the family’s starting earnings and Family Rent, and so it is important to have current income information for new FSS participants. If the FSS participant is signing a contract more than 120 days after the household’s most recent income certification, HUD requires a new income reexamination be conducted. The “120-day rule” is only found in the instructions on the FSS Contract of Participation in the section “FSS Escrow Account” in form HUD-52650. Please click on the picture to the left for the highlighted reference.

 

The Contract of Participation, and other documentation families provide to the FSS program, contains information that is considered sensitive and is protected by The Privacy Act of 1974. FSS program staff should handle participant information with care and maintain appropriate administrative, technical, and physical safeguards to protect the security and confidentiality of program participants’ records.

Here are a few tips to keep to participant information secure.

  1. Know what information you have and where it is stored
    - Desk, file cabinet, removable media (e.g., flash drives, CDs)
  2. Determine whether the information is sensitive or protected by law
    - Personally Identifiable Information (PII)
    - Protected Health Information (PHI)
  3. Practice good information security at all times
    - Lock your keyboard when not in use (Control/Alt/Delete)
    - Select a secure password, containing at least 8 characters, with one upper case letter, one lower case letter and a symbol or special character
    - Know your document retention, return, and destruction policy

PIH Notice 2015-06 provides further guidance on PHAs’ responsibilities for safeguarding personally identifiable information.

Individual Training and Services Plan

The Individual Training and Services Plan (ITSP) is part of the Contract of Participation and is where the goals identified by the participant are recorded. The ITSP includes:

  1. Services provided to the participant
  2. Activities and the steps that he or she will take
  3. Estimated, agreed-upon completion dates for services and activities

While the Contract of Participation must be signed by the Head of Household, other adult family members can establish their own FSS goals. Each participating adult family member should complete his or her own ITSP.

Learn more about the goals and objectives of the ITSP in this video.

FSS © 2017 | U.S. Department of Housing and Urban Development

All participants must include two goals in their ITSP:

  1. To become independent of income assistance from federal or state welfare programs for at least 12 months. (The requirement applies solely to ongoing cash maintenance. Food stamps, Medicaid, or short-term non-recurring payments are not considered income assistance.)
  2.  To seek and maintain suitable employment.

Participants can set other, additional goals in their ITSP, so long as they can reasonably be achieved within the program period. Each of these goals must be achieved before a household can graduate and receive its full escrow savings.

 Sample ITSP with the two required HUD goals - City and County of Honolulu

 

 Sample ITSP with education and homeownership interim goals - Lincoln Housing Authority

 

 Sample ITSP with an interim goal of preparing for homeownership - Sioux City Housing Authority

 Sample ITSP with an interim goal of completing the GED - Sioux City Housing Authority

 Sample ITSP with an interim goal of increasing self-employment income - Sioux City Housing Authority

Modifying the ITSP

Flexibility is an important feature of the FSS program, and FSS participants and coordinators may modify the ITSP at any time if allowed in their FSS Action Plan. There are several reasons why participants may modify their FSS goals, including:

  1. Participants’ goals may change over the 5-year program period due to changing interests or circumstances.
  2. Participants may not know what they want or need at the beginning of the program period, when goals are initially established.
  3. New enrollees may not initially understand their full range of opportunities.
  4. Participants may achieve their goals before the end of the program period and wish to add new goals.
  5. Participants who have made substantial progress may nevertheless need to adjust goals that initially seemed obtainable in order to graduate.

HUD encourages FSS program coordinators to be flexible and understanding of participants’ changing needs, a best practice used by these FSS practitioners who stress the importance of flexibility in ITSP goal setting.

Graduation From FSS

FSS participants are eligible to graduate from the program and receive the full amount that has accrued in the escrow account when one of these two situations occurs:

  • The family has completed all of its obligations under the Contract of Participation before the expiration of the contract including the two required goals (independence from welfare cash assistance for at least the last 12 months and suitable employment), as well as any additional goals.
  • Household earnings have increased to the point where 30 percent of the monthly adjusted income equals or exceeds the published Fair Market Rent for the size of the unit for which the FSS family qualifies based on the PHA’s occupancy standards. Note that HUD interprets that this regulatory provision is applicable only to FSS participants assisted under the HCV program and was not intended to apply to FSS participants in the public housing program.

    Families in this second category must be free of welfare cash assistance, but the 12 month requirement does not apply.

The following tips may be useful to consider when working with participants approaching FSS program graduation:

  • Participants who are near the end of their Contract of Participation period or close to meeting the maximum income threshold should be closely monitored in consultation with PHA or owner management staff to determine eligibility to receive escrowed funds.
  • There is no penalty for completing FSS goals early. Participants who achieve their final goals may access their escrow account in less than the five years permitted under the Contract of Participation.
  • Participants who need more time to achieve their goals may request an extension of up to two years for “good cause,” as determined by the FSS program, for a maximum of seven years.
  • FSS graduates can continue to receive Housing Choice Voucher or public housing assistance as long as they continue to be eligible.

 Download This List

Terminating Participants From the FSS Program

When a family’s participation in the FSS program ends before completion criteria have been met, the participant loses accrued escrow funds. FSS programs may end a family’s participation for several reasons, including:

  • The participant’s public housing assistance, Housing Choice Voucher assistance or project-based Section 8 assistance is terminated
  • Mutual consent of the FSS participant and FSS coordinator
  • Failure of the family to honor the terms of the Contract of Participation
  • The family withdraws from the FSS program
  • Any other act deemed inconsistent with the purpose of the FSS program

Policies for termination from the FSS program must be included in the FSS Action Plan, and must include grievance procedures if a family disagrees with the decision to terminate the contract.

As of December 29, 2014, HUD no longer permits housing assistance to be terminated or withheld as a consequence of failing to complete the Contract of Participation. (PIH Notice on Waivers and Alternative Requirements for the Family Self-Sufficiency Program). Note that the current form for the Contract of Participation (HUD-52650) has not yet been updated to reflect this change, and provision (3) under the heading “Corrective Actions for Failure to meet Family Responsibilities” on this form, stating that assistance can be terminated for families participating in the Housing Choice Voucher program, is no longer valid. Program coordinators should disregard or strike this line in the form.

Re-Enrollment in FSS

It is not unusual for families to exit the FSS program without graduating. FSS programs can determine whether to permit these families to re-enroll based on a number of factors, including:

  • The total number of residents interested in the FSS program
  • Whether there is a waiting list to participate
  • The current caseload and capacity of FSS program coordinator staff
  • The reason(s) why the family previously left the program
  • The reasons(s) why the family has requested to re-enroll, including changes in their circumstances
  • The length of time the family previously participated in the FSS program
  • The amount of time that has elapsed since the family was previously enrolled

Some FSS programs also allow FSS graduates to re-enroll. Policies on re-enrollment for FSS graduates or previous participants should be reflected in the PHA's or owner's Action Plan.

This video explains that FSS re-enrollment is a local policy decision.

Please complete this quiz before you proceed to the next module. To take the quiz, use the arrow keys or click the correct answer choice. If you answer incorrectly, you will be able to try again until you select the correct response.
Scores will not be recorded.

1. A Contract of Participation is effective for five years, beginning the first of the month following the day it was executed. Following the five year enrollment period, what is the maximum extension participants can request if they need more time to fully achieve their goals? (PHAs and owners may limit the conditions under which extensions are granted.)

A - 6 months, for a total of 5 years, 6 months in FSS.Incorrect.FSS participants may request a 6 month extension, but the maximum extension period is two years.B - 1 year, for a total of 6 years in FSS.Incorrect.FSS participants may request a 1 year extension, but the maximum extension period is longer than 1 year.C - 2 years, for a total of 7 years in FSS.Correct!Participants may request an extension of up to two years, for a maximum of seven years in FSS.D - 5 years, for a total of 10 years in FSS.Incorrect.FSS participants may request an extension, but the maximum extension period is two years.E - There is no limit on extensions as long as the participant is making progress toward his or her goals.Incorrect.HUD does not permit participants to remain in FSS indefinitely. The maximum extension period is two years.

2. Which of the following are required goals that must be included in the ITSP for every FSS participant?

A - To become independent of income assistance from federal or state welfare programs for at least 12 months.Partially correct.One of the two goals required by HUD is participants must achieve independence from federal or state income assistance programs for at least 12 months before graduating. Food stamps, Medicaid, or short-term non-recurring payments are not considered income assistance.B - To secure full-time employment with earnings above the federal poverty level.Incorrect.While an FSS participant may choose to identify this as another goal in his or her ITSP, it is not one of the two goals required by HUD. Those are: to become independent of income assistance from federal or state welfare programs for at least 12 months, and to seek and maintain suitable employment.C - To stop receiving Housing Choice Voucher or public housing assistance and secure housing without federal rent assistance.Incorrect.While an FSS participant may choose to identify this as another goal in his or her ITSP, it is not one of the two goals required by HUD. Those are: to become independent of income assistance from federal or state welfare programs for at least 12 months, and to seek and maintain suitable employment.D - To seek and maintain suitable employment.Partially correct.One of the two goals required by HUD is for the participant to work with their FSS program coordinator to determine what employment is suitable based on the participant’s skills, education, and job training, and the available job opportunities in the area.E - A and BIncorrect.Becoming independent of income assistance from federal or state welfare programs for at least 12 months is one of the two goals required by HUD. While an FSS participant may choose to identify securing full-time employment with earnings above the federal poverty level as another goal in his or her ITSP, it is not the other goal required by HUD.F - B and CIncorrect.While an FSS participant may choose to identify these as goals in his or her ITSP, they are not the two goals required by HUD. Those are: to become independent of income assistance from federal or state welfare programs for at least 12 months, and to seek and maintain suitable employment.G - A and DCorrect!The two goals required by HUD are that participants become independent of income assistance from federal or state welfare programs for at least 12 months, and that they seek and maintain suitable employment.

3. Which of the following is not permissible in the FSS program?

A - Modifying the ITSP to change or add new goals.Incorrect.Participants may modify the ITSP throughout their enrollment in the FSS program, as their circumstances and interests change, although some PHAs and owners do place modest limits on the circumstances in which a participant can modify his or her goals, such as disallowing modifications within 6 months of graduation.B - Graduating and accessing the escrow account before the five-year period is complete.Incorrect.The Contract of Participation initially lasts for up to five years, but residents can graduate sooner and access the full amount that has accrued in the escrow account so long as they have achieved their goals.C - Developing an ITSP for more than one adult in a household.Incorrect.The Contract of Participation and the ITSP are required for the Head of Household, but each interested adult in a household signing up for FSS may develop his or her own ITSP.D - Re-enrolling in the program after exiting without graduating.Incorrect.At the discretion of the program coordinator, participants who have formerly exited the FSS program without graduating may be permitted to re-enroll.E - None of the above – all are permissibleCorrect!All of the above are permissible under HUD program rules, although some activities may be at the discretion of the FSS coordinator. For example, some PHAs and owners do not allow modifications to the ITSP within six months of graduation, some programs limit re-enrollment based on the current caseload and capacity of program staff, etc.

 

<            >

Back
to Top