Rapid Rehousing Collaborative

Procedures

SUBJECT: Pinellas Rapid Rehousing Collaborative

PROGRAM GUIDE:

During the summer of 2016, both the Pinellas County Board of County Commissioners (BCC) and the City of St. Petersburg City Council (City) passed Resolutions to Endorse Housing First and the Coordinated Entry System. As part of a comprehensive approach to systematically reduce homelessness in the County, the City of St. Petersburg City Council and the BCC authorized a substantial investment for a Rapid Rehousing Initiative in fiscal year 2017 (FY17).

Rapid Rehousing (RRH) is a Housing First intervention designed to help individuals and families to quickly exit homelessness and return to permanent housing. Housing First is an approach to serving unhoused individuals that recognizes the need for permanent housing as an intervention to help facilitate stability, improve health, establish or increase income, and reduce harmful behaviors. Housing First also values client choice throughout the process which fosters participation in the process to ensure more long-term success.

Funding for this initiative is derived from multiple sources, including City and County General Fund. The cooperative partners anticipate the program will serve for an estimated 85-100 homeless families and individuals annually. The service population often has experienced financial crisis leading to homelessness, legal issues, poor rental history, disabilities and other health concerns, history of family violence, and little to no current income.

Locally, RRH processes will align with the Coordinated Entry System and the RRH Standards of Care, as established in 2021. The program will also align with other assistance programs to maximize efficiencies and outcomes.

During the summer of 2024, an extension of the RRH initiative was created under a Shallow Subsidy Service (SSS) which provides an extension of services, at a reduced level, for households who have received RRH services but require ongoing support to maintain their housing and prevent re-entry to the system of care. Households engaged in this service component shall be weighted at 50% for case management caseload considerations. Each household receiving SSS will count as half a case when determining case management capacity and workload distribution. This adjustment reflects the differing levels of case management intensity required for households in this service component compared to those receiving full subsidy or more intensive support services.

Shallow Subsidy Service offers a set percentage of rental support over a defined time period. Generally, Shallow Subsidy is targeted to clients who remain rent burdened and require longer term rental assistance than is traditionally available in RRH to maintain housing. Shallow Subsidy is typically part of a progressive engagement approach, where clients have received RRH rental assistance to secure and stabilize housing prior to beginning this service. Under the SSS, as best practice, the program can make a longer-term commitment, up to an additional 12 months of assistance, to the landlord and the household – unless the household terminates their housing or receives another permanent rental subsidy. The program will provide in person light-touch case management services one to two times per month. While case management may be less intensive for households receiving shallow subsidy services, the program requires, at minimum, in-person monthly check-ins with participants to ensure that the assisted household is living in the housing unit, that the tenant portion of rent is being paid, and that the household is stable. If needed, referrals for additional support or resources must be pursued.

The RRH Program is split into two (2) distinct components, which may be filled by one or more organizations: 1) Fiscal Administrator (FA) and 2) Direct Service Provider (DSP). A competitive procurement process through the Pinellas County Purchasing Department was utilized to select the organizations to administer this cooperative program. The contract provides for case management, housing navigation, and support services to homeless County individuals and families in collaboration with Human Services, the City of St. Petersburg, the Homeless Leadership Alliance of Pinellas (HLA) and the local Continuum of Care (CoC) governing body. All individual and family referrals will be identified through the HLA’s Coordinated Entry System (CES). The organizations agree to perform the responsibilities outlined in the statement of work and adhere to the Countywide Rapid Rehousing Policies and Procedures (RRH Policies and Procedures) as amended from time to time by the County/City in coordination with the Rapid Rehousing Working Group.

At a minimum, the RRH Program shall offer three (3) components:

• Housing Identification

• Rent and Move-in Assistance

• RRH Case Management and services to potentially include SSS

ATTACHMENTS:

1. Resolution No. 16-53 to Endorse Housing First and the Coordinated Entry System

2. General Fund Reimbursement Documentation

A. Financial Assistance Checklist B. RRH Staff Certification of Eligibility C. Homeless Verification C-1. RRH Self-Declaration of Housing Status (if not verified in HMIS) D. RRH Household Declaration of Income E. RRH Self- Certification of Assets F. RRH Temporary Financial Assistance Request Form G. RRH Landlord/Agent Vendor Agreement (if no lease)

PROCEDURES:

1. PROGRAM IMPLEMENTATION

a. Coordinated Entry:

Assistance will be provided to eligible individuals and families, identified as literally homeless at first intake through the Coordinated Entry System (CES). Individuals and families in need of RRH who are literally homeless and have not been assessed using the VI-(F)SPDAT shall be first referred to the Homeless Leadership Alliance of Pinellas, Homeless Street Outreach Teams, First Contact Homeless Helpline, or an Emergency Shelter Program to be assessed for prioritization. Referrals for RRH program services will be facilitated through the Homeless Leadership Alliance via the Coordinated Entry System which is described below.

b. Case Managers (CM)

The Case Managers (CMs) will intake clients referred from the CES Prioritization List to the Program Supervisor. Coordinated Entry staff review the Coordinated Entry Assessment scores, currently the VI-SPDAT for individuals (4-9) or VI-FSPDAT for families (4-10) and should align with CoC priority. The Coordinated Entry Assessment range of scoring is determined by the CoC and may vary from this upon approval. CMs will coordinate with the Homeless Leadership Alliance of Pinellas, the RRH Housing Specialists (HS), Homeless Street Outreach Teams, and emergency shelters to locate referred individuals and families, and prevent duplication of efforts.

The CMs are responsible for assisting clients in obtaining all necessary documentation for application to RRH, including obtaining replacement identification, when necessary. CMs should work with clients to develop a specific stabilization plan within the first thirty (30) days of entry into the RRH program based on client availability, even if suitable housing has not yet been located. Upon program entry, case notes will document progression towards the housing stabilization plan. The stabilization plan will include a housing/self-sufficiency plan, and a household budget, at a minimum. The stabilization plan will address the household’s housing needs and preferences, strengths, barriers to housing, and identify possible alternatives and resources for self-sufficiency. Once the household enters permanent housing, regular reassessments provided through follow-up, should be built into the stabilization plan to determine if the level of assistance should be increased, decreased, or discontinued. The budget worksheet will identify monthly income and expenditures to aid in reaching self-sufficiency, and to help determine the level of temporary financial assistance needed.

Through these plans, the CMs will work to develop and ensure the on-going stability of clients upon placement into permanent housing. CMs should be familiar with a multitude of wrap-around services and providers to meet the needs of their clients. CMs should make referrals to programs for which a client expresses a need, including, but not limited to Pinellas County Health Program/Health Care for the Homeless Program, and other local providers for job/skills training for all adults who are unemployed, underemployed, or not stable in their employment, furniture and incidental support, childcare, etc.

CMs will be experts in the RRH Program Standards and continually evaluate clients for eligibility and ongoing support while building a support system. Documentation of ongoing need is required on a monthly basis for continued financial assistance from the program. The CM shall strive to ensure that program standards are implemented consistently throughout the CoC by attending Individual Prioritization Meetings, Family Prioritization Meetings, Veteran Meetings, and RRH Program Meetings. The CM shall also attend training opportunities offered by the CoC and participate in workgroups when applicable.

c. Housing Specialists (HS)

Housing Specialists (HS) are responsible for identifying and engaging landlords through a variety of methods in order to develop a sufficient affordable housing stock for a successful RRH program. HSs must be familiar with landlord/tenant law, applicable Housing Codes and grant-specific housing requirements, particular challenges to the rental market within the CoC, local housing authority voucher programs, and public transportation. HSs will ensure that all housing units meet Housing Quality Standards (HQS) as established by HUD (Appendix A). HSs will continually seek out landlords willing to house hard-to-place tenants and must be strategic in addressing housing barriers. HSs will work with clients, CMs and the FA to collect necessary documentation to secure a lease in an approved unit. After a lease is signed, the HSs will continue to serve as a contact for landlords experiencing any challenges with tenants by providing outreach with CMs, and if necessary, a cooperative and timely move out of housing to avoid penalty. HSs will coordinate with other HSs within the CoC to develop mutual landlord partnerships and when possible, promote the Floridahousingsearch.org utilization by landlords and housing partners.

d. Fiscal Administration (FA)

Financial assistance funds will be administered through an agreement with the Fiscal Administration (FA). FA staff will be available Monday through Friday from 8:00am to 5:00pm to process documentation packages and respond to CMs and HSs inquiries.

The FA will maintain eligibility information within the Fund financial system of the First Contact software, or other software program as determined appropriate by the County and the City of St. Petersburg. Financial assistance information shall be readily available for review and audit by the program partners. The FA will maintain a full, separate accounting of all dispersed funds associated with each instance of assistance. All disbursed funds will be reconciled to the FA bank statements on a monthly basis or as required by funders.

The FA will receive completed requests for financial assistance from CMs and HSs and is responsible for ensuring all documentation necessary for verification, processing, and approval of request is provided. The FA will maintain ongoing contact with the CMs and HSs as necessary to correct any deficits in the documentation and provide communication as to request status. Cases with continued contact and document submission by a CM will remain in pending status until all required documentation is received and verified, and the assistance is approved.

Based upon the information provided in each application, the FA shall be responsible for adhering to the eligibility guidelines for the City of St.

Petersburg and County General Fund. If additional information is needed to determine specific eligibility, the FA will work with the CMs or HSs to obtain this information. At the start of each fiscal year the funders will determine which fund to utilize first.

The FA will review all documentation scanned into the First Contact software to verify citizenship, residency, income, identification, and eligibility prior to issuing a request for payment for eligible items.

All requests for payment will be handled within one (1) business day once all required documentation is received and eligibility for RRH is confirmed.

If a request is not processed, FA staff will contact the CM and Supervisor directly within two (2) business days and notify them of the reason and the information or requirements needed to verify the payment. All requests are recorded in the Fund financial system.

No funds will be distributed, or checks/guarantees/credit card payments, without appropriate verifications and approvals documented in the First Contact software. For approved financial assistance, payment will be made by credit card for utilities and checks will be cut for rental assistance. A CM/HS or Supervisor will be responsible for picking up checks directly from the FA and delivering them to the appropriate landlord within 48 hours.

e. Payment Approvals

When submitting for financial assistance the CM and DSP leadership are in alignment with the request and need for the assistance based off eligibility and continued participation in the program. All initial requests for assistance, and subsequent requests for $2,000.00 and above, are transmitted electronically to the Fiscal Administration’s Director/Designee for document verification prior to submitting for approval by Pinellas County Human Services Director, and City of St. Petersburg representative, or their designees, (“Exceptions Committee”) for joint (two) approvals when all eligibility documentation has been submitted. All parties are expected to update status of application within two (2) business days of receipt and follow up is expected when request is outstanding.

1. Requests for assistance from $0.01 to $299.99 are entered into Fund financial system by FA staff and paid online or by check. Requests for assistance from $300.00 to $1999.99 are reviewed by the FA program supervisor for document verification approval or denial. This verification process may be updated from time to time to suit program needs by mutual agreement of all program partners.

2. Any subsequent requests, where the total financial assistance is over $12,000, or over 6 months, will be submitted for approval by the Exceptions Committee. Approvals in First Contact software is updated with approved, not approved, or denied and comments including additional information, and clarifying questions, as needed, and reduce the turnaround time between questions and reconsiderations, when applicable. All partners agree to appoint a designee to ensure timeliness of approvals and payments are met when unavailable.

2. ELIGIBILITY:

a. Rapid Rehousing Eligibility:

RRH assistance is offered without preconditions (such as employment, income, absence of criminal record, or sobriety) and the resources and service delivery provided are typically tailored to the unique needs of the household. Eligibility for RRH services is determined based on the following criteria below:

i. Meets HUDs definition of Literal Homelessness

ii. Referred by CoC through Coordinated Entry System

iii. United States Legal Status – Citizenship or Residency

iv. Pinellas County Resident

v. AMI Assistance is limited to low-income Pinellas County households, below 80% AMI with at least one adult aged 18 and older or a legally emancipated youth and able to provide proof of income and assets

vi. VI-SPDAT for individuals (4-9) or VI-FSPDAT for families (4-10); or as determined by the CoC

b. Shallow Subsidy Eligibility:

Eligibility for Shallow Subsidy services will be determined based on the following criteria below:

i. Household has demonstrated their ability to cost share at 30%, 40%, and 50% over the course of 3 months in the RRH program, as outlined in the client’s housing stability plan.

ii. Household has been linked to community resources and are actively engaged in RRH.

iii. The household has displayed that intensive case management services are no longer necessary but would still benefit from services.

iv. The household was determined to need additional financial support to maintain housing long-term.

v. The case manager has received confirmation that the household is in good standing with their rental agreement, property owner(s), and has not received late notices or additional lease violations within the past three (3) months.

vi. Target population:

1. Households enrolled in Rapid Rehousing Collaborative

Program.

2. Household needing long-term financial assistance.

3. Individuals and families.

4. Household who can pay 30-50% of their rent.

5. Household who may be pending an affordable housing opportunity.

c. Eligibility Documentation

Residents must provide documentation of citizenship, residency, identification, income, assets and need. The FA is responsible for maintaining and verifying eligibility and financial assistance documentation for the program.

i. Document Collection Assistance:

For households with more than one adult/emancipated youth or families who seek assistance, documentation must be provided regarding each adult/emancipated youth’s identification, income, and assets. If required documents do not exist or are unavailable, CMs and HSs will assist the applicant in obtaining needed documents.

Financial assistance can be provided to assist in obtaining documentation. A provisional amount of $100.00 can be issued directly to a pre-qualified applicant to assist with obtaining documentation. The CM shall work with each client to ensure the intended documentation is obtained. Receipts must be submitted to account for the provisional funds prior to further assistance being issued.

In the event that sufficient documentation is provided to process assistance, but one or more pieces of identification have expired, a check for the provisional amount may be issued by the FA to the DSP to allow the client to obtain updated identification. In this circumstance, the case may continue to be processed by the FA without the need to wait for receipts. If a receipt for identification is not received prior to case closure, the FA may submit evidence of the cashed check as proof of expenditure.

ii. Proof of Citizenship: (Required) One form for Head of

Household ONLY:

Applicants must be a U.S. citizen by birth, a naturalized citizen, a legal permanent resident immigrant, or a refugee or asylum seeker.

Undocumented noncitizens or persons in the U.S under any sort of temporary status, such as a student or tourist visa, do not meet citizenship requirements. A social security card may demonstrate citizenship if it meets the criteria outlined in the “USCIS” Cards and Codes. Other official government documentation demonstrating a https://www.uscis.gov/i-9-central/form-i-9-acceptable-documents https://www.uscis.gov/i-9-central/form-i-9-acceptable-documents client social security number is NOT acceptable documentation of citizenship. If an individual’s Social Security Card is unavailable, the following other documents are acceptable proof of citizenship:

1. Citizen by birth: Applicants must be born in any state in the

U.S., Puerto Rico, U.S. Virgin Islands, Northern Marianna Islands, American Samoa, Swain’s Island, Guam, or born abroad to parents who are U.S. citizens. Applicants claiming to be a U.S. citizen by birth but born outside U.S. must provide documentation (e.g. birth certificate) of citizenship status.

Application for a birth certificate is acceptable temporary documentation (if accompanied by a receipt) of citizenship.

The birth certificate must be submitted for the case file as soon as it is received and prior to case closure.

2. Naturalized citizen: A person born in another country but who has since obtained U.S. citizenship. Citizens who claim to be naturalized must provide documentation in the form of a Certificate of Naturalization or a valid U.S. passport.

3. Legal Permanent Resident Immigrant: Acceptable documentation includes a “green card,” or I-551. A visa or other official United States document stamped: “Processed for I-551; temporary evidence of lawful admission for permanent residence; valid until mm-dd-yy; employment authorized,” is acceptable as proof.

4. Refugee or Asylum Seeker: Includes applicants from the current USCIS’s list of countries that may be eligible including but not limited to applicants from Albania, Vietnam, Bosnia, Cuba, Haiti or other countries who legally reside in the U.S.

as political refugees or asylum seekers. Documentation is the INS form I-94 stamped to identify the applicant as a refugee or asylum seeker.

*Note: Sponsored non-citizens are individuals who have been granted permanent resident status under the sponsorship of an American citizen. Sponsored non-citizens are not eligible for this program.

iii. Identification: (Required) Two forms (Valid Driver’s License or State ID and 1 other) for each adult in household:

Applicants must provide two forms of identification. Proof of citizenship from Section (a) above may count as one form. An acceptable second form of identification may be:

1. Social Security Card

2. Pinellas County Driver’s License or State Identification

3. Birth Certificate

4. Valid Passport

5. Marriage License

6. Voter Registration Card

7. Veterans Administration Identification

8. School Records

9. Electronic Benefits Transfers (EBT) card or determination letter.

10. Immigration Records

*Note: Documentation from a foreign country may be accepted as a second form of identification provided that documentation of refugee, asylum seeker, or legal permanent resident immigrant is also included.

In the event that one or more pieces of identification have expired, CMs and HSs will assist the applicant in obtaining needed documents.

iv. Proof of Pinellas County Residency: (Required) Two forms for head of household ONLY:

Assistance may only be provided to applicants who are current residents of Pinellas County. Applicants must provide two of the following:

1. Copy of a valid Florida Driver’s License or Florida Identification card showing a Pinellas County address

2. Previous mortgage documents, rental lease, rent receipts or letter from a landlord or property owner

3. Proof of previous Homestead Exemption

4. Recent water, electric, gas, telephone, cable television or other utility bill in the name of the applicant indicating a previous address within Pinellas County

5. Vehicle registration in the name of the applicant indicating an address within Pinellas County

6. Pinellas County Voter Identification card

7. Recent historical record of residence documented by another social service agency within Pinellas County. Includes Mobile Medical Unit.

8. Cancelled mail from a Federal, State, County, or City agency addressed to the applicant at a Pinellas County address

9. Declaration of Domicile recorded with the Pinellas County Clerk of the Circuit Court

10. Current professional license indicating a home address in Pinellas County

11. Record of criminal activity indicating a Pinellas County address when arrested

12. Employment record indicating a home address in Pinellas County

13. Bank, credit union, or similar documents indicating a home address in Pinellas County

14. Homeless Verification Letter from Pinellas County Shelter or Homeless Service Provider stating Pinellas County residency

v. Proof of Income: (Required) All income reported for household

1. Income must be at or below 80% Area Median Income.

Income Limits | HUD USER

2. Income consists of wages, self-employment, contributions, child support, and benefits (including SNAP), either earned or non-earned, from legal sources.

3. All reported income and non-cash benefits must be documented with the most recently available 30 days’ pay or check stubs, employer letter, or benefits letter. Unless by exception, documentation must have been generated within 30 days prior to the submitted request.

4. If self-employed, bank statements or self-employment records must be documented for the last three (3) months.

5. If back-child support is a source of income, documentation must be provided that the child is over 18 years of age or no longer living in the home. If unemployment benefits are a source of income, documentation of future employment or length of receipt of benefits must be provided.

6. In instances where recent overtime, bonuses, or supplemental income may cause an applicant to be over the income limits based upon the last 30 days, but the supplemental income is not regular or dependable, income should be calculated from the year-to-date total on a paystub, divided by the number of months covered.

vi. Proof of Assets: Required for each adult in household

For requests $1,000.00 and above, applicants must not have available liquid assets above $2,500.00, subject to Director/Designee review. Liquid assets include the applicant’s savings and checking accounts, and an entire bank statement showing the past 30 days deposits, withdrawals, and charges (or statement received within the last 30 days) for each account. A statement from a child support resource, SSI card, or a reloadable employment debit card may be used to verify assets if no bank account is held. Assessment of liquid assets will be included in the approval by the exceptions committee.

vii. Required Documentation for Temporary Financial

Assistance https://www.huduser.gov/portal/datasets/il.html#year2025

Requests for temporary financial assistance shall be submitted to the FA through the First Contact software and shall include all necessary documentation referenced in Attachment 2A-Temporary Financial Assistance Documentation Checklist. No payments will be issued prior to final approval by the exceptions committee in the First Contact Software. Additional forms required for General Fund reimbursement include:

• 2B. RRH Staff Certification of Eligibility

• 2C. Homeless Verification

• 2C-1. RRH Self-Declaration of Housing Status (if not verified in HMIS)

• 2D. RRH Household Declaration of Income

• 2E. RRH Self- Certification of Assets

• 2F. RRH Temporary Financial Assistance Request Form

• 2G. RRH Landlord/Agent Vendor Agreement (if no lease)

1. Rent and Rental Deposits

a. An executed lease (minimally 7 months but preferably

12 months) and a W9 from the landlord are required for all rental deposit and assistance requests. Once the initial lease expires, it may be appropriate for the client(s) to continue on a month-to-month basis. If an executed lease is unavailable, a draft of the proposed lease, with the client’s name and the specific residence listed may be submitted, or the landlord may complete Attachment 2G- Landlord/Agent Vendor Agreement. A W-9 must be provided. Use and Occupancy Agreement does not qualify as an executed lease.

b. If landlord is an individual and not a management or leasing company, the FA will make every effort to verify property ownership in the Pinellas County Property Appraiser database at www.pcpao.org. The search may be done by owner name or property address.

c. If the applicant receives Section 8 Tenant-Based Assistance, a Housing Assistance Payment Contract (HAP Contract) is required in addition to the lease agreement.

d. All rent deposits will be made in the client’s name and will be held by the landlord in trust pursuant to standard landlord/tenant law. Any deposits will be returned to the client upon termination of the lease in accordance with landlord/tenant law for further use in establishing new residence.

e. A Housing Quality Standard will be performed for all prospective units and a copy of the inspection will be placed in the client’s case file (Appendix A).

f. Note for application fees: Housing application fees may http://www.pcpao.org/ be paid on an as-needed basis prior to submitting a full case request IF the RRH CM is able to document client need, no other available resources for the payment, and performance of due diligence to ensure the likelihood of client approval. Documentation of client eligibility for RRH (ID, residency, citizenship) and written or emailed statement from the prospective landlord stating the terms of the application fee are required. FA shall verify ownership or agency relationship with property owner listed on www.pcpao.org.

g. Note for proration: FA will prorate rent payments as close to the move-in date as possible. The amount paid need not match the Temporary Financial Assistance Request Form (TFA) if the prorated amount at the time of payment is lower than estimated. If the full monthly payment is required by the Landlord regardless of move-in date, then this should be noted on the TFA and may be paid in full on a case-by-case basis.

2. Utilities, Utility Deposits, and Utility Arrears

a. Deposit Letters from utility providers.

b. Current utility bills including past due amounts necessary to establish or maintain service.

c. All utility deposits will be made in the client’s name and will be held by the DSP in accordance with applicable laws and regulations. Any deposits will be returned to the client upon service termination for use in establishing future services.

3. Other Financial Assistance Other financial requests are approved by exception only.

These requests require a detailed explanation of need, documentation of cost and company information, and documentation of no other available resources.

a. Storage Units

b. Moving costs

c. Rental Arrears

d. Household needs

e. Bus Passes

4. Subsequent Requests for Assistance

Subsequent requests for assistance in the same enrollment period may contain reduced documentation paperwork but should refer back to the Client name/Client ID and original date of submission of eligibility paperwork. The following documentation is needed for subsequent requests:

http://www.pcpao.org/

a. Rent Requests

i. Temporary Financial Assistance Form

ii. Head of Household ID

iii. W-9 (required for FA finance department)

b. Utility Requests

i. Temporary Financial Assistance Form

ii. Head of Household ID

iii. Utility Bill

3. DURATION/AMOUNT OF ASSISTANCE:

Households are eligible for monthly assistance on a case-by-case basis, coupled with a housing case plan to establish the minimum financial assistance necessary to successfully stabilize the household.

The Rapid Rehousing Working Group will meet no less than bimonthly and will communicate regularly regarding program expectations. The amount of assistance will vary depending on the unique characteristics of the household’s crisis situation. All new RRH requests, and any requests more than $2,000.00, over 6 months of assistance, or exceeding $12,000 must go through the Exceptions Committee. This requirement applies to RRH services only and does not apply to Shallow Subsidy Service (SSS) approvals. SSS may provide additional support for up to 12 months. Due to the unique service delivery model of the Shallow Subsidy Service, the initial request will be submitted to the Exceptions Committee, as well as at the six-month mark. SSS approvals are not subject to the Exceptions Committee threshold of $12,000 or more. However, the total assistance combining both RRH and SSS cannot exceed 24 months. The program will monitor and conduct regular staffing’s for households that meet any of the following criteria:

• RRH exceeds $18,000;

• Households have been in RRH for more than 15 months; or

• Combined RRH and SSS assistance exceeds 18 months.

The review will help ensure future sustainability within the program’s 24-month limit.

Updates will be provided during contract meetings using program data. Additionally, case management services may be offered and may continue for up to six (6) months following program completion.

If a household receiving SSS experiences a change in income or financial hardship that impacts their ability to contribute toward monthly rent, the program will conduct a reassessment to determine the household’s updated rent contribution. Any increase in assistance will be reviewed by the Exceptions Committee to evaluate the continued need and to support the household in working toward full rent responsibility when feasible.

The program will assess each household’s situation and may temporarily increase rental assistance up to the full cost of rent to prevent eviction or housing loss. This temporary increase may be approved up to two times per household in cases of verified hardship.

Examples of qualifying hardships may include, but are not limited to:

• Changes in household composition

• Significant reduction in income

• Major medical event

If the household continues to experience hardship that prevents them from meeting their cost share under the SSS program, they will be reassessed for Traditional Rapid Re- Housing (RRH), provided they have not already exhausted that assistance. All decisions will be made on a case-by-case basis, taking into account the household’s needs, barriers, and length of enrollment in the program.

4. FINANCIAL ASSISTANCE PAYMENT PROCESS:

a. Payments Online payments of verified requests are made directly to the vendor using purchasing cards. If the vendor cannot be paid or the item cannot be purchased online, a check request is submitted for payment directly to the vendor.

b. Fund Accountability and Reimbursement

The FA is responsible for tracking and reporting RRH applicant data, client demographic, eligibility and expenditure data, processing performance measures and approval rates. Most of this information will be reported from the First Contact software and the fund software. Human Services will have direct access to First Contact software/Fund Manager for ad-hoc reports as needed.

i. County General Fund Reimbursement:

1. Funding for financial assistance will be advanced to the FA and shall be held in a separate bank account. A separate invoice will be submitted to the County for the financial assistance and will consist of a cover letter signed by an authorized DSP representative, required General Fund reimbursement documentation and a copy of the monthly bank account statement for the bank account in which the pool is held. Documents should be grouped by Client, with the Temporary Financial Assistance form for that client on top of each grouping of documents. For any exception committee-approved payments, an email of each Designee’s approval shall be attached to the client backup documentation. A summary spreadsheet should be submitted with the invoice, listing the items requested, by client in the same order in which the backup documentation is provided. The summary spreadsheet should include the client’s name/ID number with each line, as well as a column listing the month that a client’s original eligibility/documentation was submitted.

2. Upon reconciliation and approval of the monthly or bimonthly invoices for the financial assistance pool, the County will reimburse the FA for expenditures until the entire contracted financial assistance pool amount is reached. The FA will then continue to submit separate monthly invoices but will draw down against the emergency assistance pool until it is extinguished, or the term of the contract is reached. In the event that funds remain in the assistance pool at the end of the contract term, the remainder shall be remitted to the County within thirty (30) days of the final reconciliation or rolled over into the new contract term upon continuation of the program.

ii. St. Petersburg General Fund Reimbursement:

1. For applicants eligible for reimbursement by the City of St.

Petersburg General Fund, an invoice will, instead, be submitted to the City for the RRH financial assistance, and will consist of a cover letter signed by an authorized DSP representative, required General Fund reimbursement documentation, a copy of the monthly bank account statement for the bank account in which the pool is held, and a report of the director-approved exception expenditures for the month.

For any exception committee approved payments, an email of each Designee’s approval shall be attached to the client backup documentation.

2. Upon reconciliation and approval of the monthly or bimonthly invoices for RRH financial assistance the City will reimburse the FA who will then replenish the County-funded assistance pool. The FA will then continue to submit eligible monthly invoices until the City General Fund balance is extinguished or the term of the contract is reached.

3. Any supporting documentation submitted by a client MUST have the client’s name visible on the document.

5. ADMINISTRATIVE REQUIREMENTS:

a. Use of Encryption

i. Emails containing personal identifiable information (PII), personal health information (PHI), or other sensitive information about a client or caller should be encrypted prior to be sent to any and all receivers.

ii. Emails should be encrypted to the recipient when the following items are included: personal identifiable information: client names, social security numbers or cards, dates of birth, gender, zip codes,

iii. Personal Health Information: medication, diagnostic, treatment, or disease identification. Sensitive Information: case or call details, names of minors, income information, leases, utility bills, bank statements, addresses, phone numbers, or email addresses.

b. Grievance Process

i. Eligibility Determination: Concerns regarding the eligibility determination of an applicant shall be submitted to the Exceptions

Committee and are subject to Program Directors/Designee review.

All decisions of the Exceptions Committee are final.

1. Eligibility Appeals Process: A letter detailing the reason for the grievance and any evidence that supports the claim must be mailed to Society of St. Vincent de Paul CARES attention to the program within 10-business days of receiving this notice. The RRH Program Manager will review the information and evidence presented and provide to the Exceptions Committee within one (1) business day to make a determination.

The written request must contain the following information:

• Applicants Name

• Date the assistance was denied

• Reason for denial

• Written documentation indicating why there is disagreement with the reason for denial

• Written request must be signed and dated

If the Exceptions Committee determines that the applicant is eligible, he/she will be notified by phone or mail within two weeks of receipt of the grievance to process to reschedule an intake date.

If the decision to not to enroll the participant in the program is upheld, he/she will be notified in writing within two weeks of receipt of grievance. In accordance with Federal laws this institution is prohibited from discriminating based on race, color, national origin, gender, sexual orientation, sexual identity, age, or disability. Assistance will be provided to those with disabilities upon request to ensure that equal access to an appeal is available.

Please submit your written appeal by mail or email to the address below:

Mailing Address:

Will be updated to selected vendor

Email Address:

Will be updated to selected vendor

Staff reviewing the written appeal will have 5 business days to respond by phone or in writing to the request. The review will be completed based on the information that was provided on the application requesting assistance.

c. Client Non-Responsiveness and Program Discharge Policy To ensure effective use of resources and support for clients actively engaging in housing stabilization, the Rapid Rehousing (RRH) program has established the following policy regarding client non-responsiveness:

i. Definition of non-responsiveness

1. A client is considered non-responsive if there is no successful contact or meaningful engagement (e.g., return calls, emails, meetings, or follow-through on service plan goals) with RRH staff for 30 consecutive calendar days, despite reasonable and documented attempts by staff to re-engage.

ii. Re-Engagement Efforts

1. Program staff will make a minimum of three documented attempts to contact the client through multiple communication methods (phone, text, email, home visits if appropriate). These efforts will be made over the course of the 30-day period.

iii. Notice of Pending Discharge

1. If the client remains unresponsive after 30 days, a formal written notice (by mail and/or email) will be sent informing the client of their pending discharge from the program. The notice will include:

a. A summary of attempted contacts

b. A final date by which the client may respond to avoid discharge (typically 7-10 business days)

c. Contact information for program staff

iv. Discharge from the Program

1. If no response is received by the deadline in the notice, the client will be formally discharged from the Rapid Rehousing program. Documentation of the discharge and all outreach efforts will be maintained in the client’s file.

v. Re-Entry Consideration

1. Clients who are discharged due to non-responsiveness may be eligible for re-entry into RRH; however, re-entry is not guaranteed.

a. If a client has not been enrolled into RRH, the client may be returned to the Coordinated Entry (CE) List.

b. If a client has been enrolled, to be considered for services, the client must initiate a new assessment through Coordinated Entry (CE) and be re-prioritized based on current vulnerability and eligibility criteria. Re-entry is contingent upon program capacity, funding availability, and CE referral.

d. Conflict of Interest and Program Integrity Policy

i. Prohibition of Personal Interest Cases and Financial

Transactions Any employee, contractor, or representative involved in the funding or administration of the program must avoid any situation that could create a conflict of interest. This includes, but is not limited to, personal relationships with clients, landlords, or other individuals involved in the program. Specifically:

1. Case managers and staff members: Must not handle cases involving individuals who are personal acquaintances, such as friends, family members, or individuals with whom they share a community, faith-based, or work relationship.

2. Property managers and landlords: Any individual who is employed by or affiliated with PCHS or a RRH partner organization must not receive payments directly or indirectly from the sale, rental, or provision of services to participants in the programs designed to assist vulnerable populations. This does not apply to registered non-profit organizations serving low-income or homeless housing.

ii. Reporting and Transparency

1. Case managers: Must immediately report any case with a potential personal interest conflict to Management. If any discrepancy or potential conflict arises regarding a client or landlord, it must be disclosed to avoid any undue influence.

2. All partners: Are prohibited from maintaining personal relationships with clients or landlords involved in the programs to prevent conflicts of interest and preserve the integrity of program delivery. Any potential conflict must be disclosed immediately.

iii. Exception for Eligible Employees

Employees or affiliated individuals who are eligible as clients for the program may still receive assistance in accordance with all applicable policies and procedures, including section 112.313(6) Florida Statutes.

iv. Oversight of Employee Requests In the event that an employee or affiliated individual requests assistance from the program, the request may be elevated to a higher level of review (Level 3), regardless of the dollar amount, to ensure fairness and prevent any perception of bias or conflict of interest.

v. Legal and Ethical Compliance

Personal information collected for program eligibility is protected by relevant laws, including the Privacy Act of 1974, the HITECH Act of 2010, and Florida statutes. Any violations of these laws or the policies outlined above will result in disciplinary action.

6. MEASURES, OUTCOMES & REPORTS

The DSP and FA agree to submit monthly program data reports to the County, consistent with the data elements, collection standards, and performance measures outlined in the contractual agreement(s). The Program will adhere to the current CoC RRH Performance Benchmarks as updated from time to time.

Required service delivery outcomes may be amended to ensure compliance and achievement of County and community goals.

6. MEASURES, OUTCOMES & REPORTS