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Proposed Rapid Re-Housing Policies & Procedures

Open forum regarding HMIS support, resources, and information.
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GaitherStephens
Posts: 127
Joined: Wed Aug 09, 2017 8:59 pm
Location: Punta Gorda, FL
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Wed Dec 26, 2018 2:05 pm

We've had some questions on how to handle RRH clients, especially when they are enrolled in multiple projects. I wrote up some policies and procedures and would appreciate any feedback.

Thanks!

Rules for recording Rapid Re-Housing (RRH) clients in ServicePoint 5
1. RRH clients must come from a homeless situation such as Emergency Shelter or Place Not Meant for Habitation.
2. Every client requires an entry/start into the RRH project.
3. Each time a case note is recorded for a client, an accompanying service transaction must also be created.
4. A Housing Move in Date (HMID) is only recorded after a client has signed a lease, possesses a key to their new residence, and has physically slept there. The day immediately following the first night the client sleeps in their new residence is recorded as the HMID.
5. HMID’s must be on or after the entry/start date.
6. HMID’s must be on or before the exit date.
7. HMID’s must be recorded as an interim update.
8. Clients are exited from a project according to the specific parameters of each RRH program.
9. If a client has been exited from an RRH project, becomes homeless again, and then rejoins the RRH project again at a later time, the client should get a new entry/start date into the project.
10. If a currently enrolled client becomes homeless again, it is unnecessary to exit the client from the RRH project. However, if the client is re-housed while still enrolled in the RRH, a new HMID should be recorded.

Enrolling a client that is already enrolled in an RRH project into an additional RRH project
1. RRH clients can be enrolled in multiple RRH projects simultaneously.
2. When a client that is in an existing RRH Project (Project A) is then also enrolled in a subsequent RRH Project (Project B), the homeless information for Project B must match the homeless information from Project A.
3. When a client that is in an existing RRH Project (Project A) is then also enrolled in a subsequent RRH Project (Project B), the entry/start date for Project B will be the date the client enters into Project B and the HMID must be the same day as the entry/start date for Project B. NOTE: This means the HMID for Project A and the HMID for Project B will NOT match.


Wally
Posts: 1
Joined: Mon Nov 19, 2018 8:35 am
Location: West Palm Beach, FL

Thu Feb 07, 2019 8:33 am

I these guidelines could be beneficial to our community.

I have a few questions:
Have you received any feedback on this? From your community or others?
Have you implemented these P&P's? And if so, which part of your CoC (subcommittee) approved the addition/change?
Are they part of the RRH P&P or the HMIS? Both?

Thank you for posting this.

Wally Lugo
HMIS Administrator
Palm Beach County, FL
Wally Lugo
HMIS Admin
Palm Beach County, FL
User avatar
GaitherStephens
Posts: 127
Joined: Wed Aug 09, 2017 8:59 pm
Location: Punta Gorda, FL
Contact:

Thu Feb 07, 2019 10:23 am

Hi Wally,

I've received feedback on this from those in the community and other HMIS administrators. The first part is pretty solid, the second part I put together based on an AAQ I submitted to HUD.

Once I've established what the existing rules are, these will be submitted to the CoC for review.

Here's the AAQ that I submitted to HUD:

Question Text:
I have a question about how to handle a client that is enrolled in multiple RRH projects at the same time.
Let's say that a client is entered into project RRH-A on January 1, 2017...is then housed on January 15, 2017...and then the project runs out of money on January 31, 2017. The agency then enters the client into project RRH-B on February 1, 2017. What would the Housing Move-In Date be for project RRH-B?
Thank you.
Gaither Stephens

Response:
Our response assumes that a single ESG subrecipient has provided assistance to a client by sequentially using two different ESG rapid rehousing funding sources (ESG-funded RRH-A and ESG-funded RRH-B) without exiting the client from the ESG program. If we have misunderstood your question, please re-open this question following the instructions below and provide us with clarifying information.

Move-In Date & HMIS Guidance
RRH providers that receive an ESG award from more than one ESG recipient must create separate projects within an HMIS for the separate grant sources (e.g., City-funded RRH and State-funded RRH) in order to distinguish clients for reporting purposes, or the project must otherwise be able to distinguish clients for reporting purposes.

HUD recommends that ESG recipients and subrecipients:
• work together to design projects that use funds from one ESG recipient to support 100 percent of the ESG costs for each household; and
• not provide ESG assistance to the same household with two different funding sources, if it can be avoided (e.g., providing 2 months of ESG city-funded rental assistance followed by 3 months of ESG State-funded rental assistance)–but rather fully fund assistance for fewer program participants with one source of ESG funding, and assist other program participants with the second source of ESG funding.

However, with regard to your specific question (and assuming the client remained housed throughout the grant source change), the Housing Move-In Date for project RRH-B would be February 1, 2017 (which would also be the same date as the Project Start Date for RRH-B). In order for the client to show up as "housed" according to any number of reports, the project start date for the second project is considered to be the housing move in date for that project as well. Please follow all the data collection instructions in the HMIS Data Manual. We recognize that certain circumstances can arise where project eligibility requirements and data collection requirements in HMIS do not always perfectly align. At this time, however, data entry in HMIS should comport with the instructions provided in the manual. When exiting the first rapid re-housing project and when starting the second rapid re-housing project, the HMIS records should reflect the actual destination, living situation, start and exit dates, and housing move-in date(s) as instructed.

Restrictions on Providing ESG Assistance from Multiple Funding Sources to One Program Participant/ Household
Recipients and subrecipients are discouraged from providing an eligible program participant with assistance from two different ESG funding sources. However, providing assistance from two sources is allowable, provided that the following requirements are met:
1) The documentation of eligibility gathered at the intake evaluation must be available to both the state and the city recipients. Both the state and city recipients and the subrecipient are required to maintain records of each program participant served in accordance with the ESG Interim Rule, 24 CFR § 576.500(f);

2) If either the state or city recipient has additional, more restrictive, eligibility requirements, then the program must ensure that they are in compliance with any additional recipient criteria at the time the corresponding city or state funds are used;

3) The ESG assistance must be accounted for and reported on separately by both the city and state recipients. In terms of HMIS and reporting, both recipients must still ensure they are complying with HMIS participation requirements (see 24 CFR 576.400(f)); and

4) Both ESG recipients must be informed that this type of activity is taking place with its portion of the funds, and recipients and subrecipents should discuss the best ways to ensure accurate reporting and performance tracking between the two funding streams.

ESG CAPER Reporting
If a program participant is assisted with ESG funds that were sub-awarded to a subrecipient from two different recipients, the program participant must be counted on both recipients' ESG CAPER. We recommend that you work with your HMIS implementation team to ensure that the system has this functionality, or submit a new question to the HMIS help desk for assistance.

Eligibility Determinations
Once a program participant has been determined eligible to receive ESG rapid re-housing assistance the recipient or subrecipient is not required to evaluate the program participant's eligibility more than once annually. If a program participant receives utility assistance from a second subrecipient, that subrecipient could use the initial eligibility determination documentation rather than repeating a second eligibility determination. Both subrecipients are still required to enter client data in HMIS for the program participant's project entry.

Please note, however, that if HUD monitoring finds that the initial intake evaluation and documentation did not comply with HUD program requirements and, as a result, ESG funds were not used in compliance with program requirements, the new recipient and/or subrecipient would also be held responsible for this non-compliance even though it resulted from the first subrecipient's intake evaluation.

Finally, keep in mind that regardless of which funding source is providing the assistance, a program participant may not receive more than 24 months of any one type of assistance during any 3-year period, as set forth in 24 CFR 576.105(a)(5) and 576.106(a).


Regards,

Gaither
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