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Updated July 13, 2021

Pinellas County Continuum of Care FL 502 Written Standards

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Table of Contents Introduction

Overview of Programs

Continuum of Care Program

Emergency Solutions Grant Program

Definitions

Standards for All Project Types

Guiding Principles

Homeless Management Information System (HMIS) Participation

Access to Mainstream Resources

Grievance Procedures

Intervention Specific Standards

General Requirements for ESG

Homelessness Prevention

Emergency Shelter

Shelter Habitability

Shelter Policies and Procedures

Rapid Rehousing

Program Component Chart

Coordinated Entry and Assessment

Workflow

Other Standards

Conflicts of Interest

Fair Housing & Civil Rights Requirements

Equal Participation of Religious Organizations

Lobbying and Disclosure Requirements

Drug-Free Workplace Requirements

Emergency Procedures

System Performance Monitoring

Monthly and Quarterly Reviews

ESG-CV Written Standards Addendum

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ESG-CV Flexibilities

ESG-CV Prioritization Policies

Rapid Rehousing Under ESG-CV

Prevention Under ESG-CV

Emergency Shelter Under ESG-CV

Determining Costs and Length of Time for Activities Under ESG-CV

Appendices

COVID-19 Mitigation Policies and Procedures for Emergency Shelters

Homeless Prevention Coordinated Entry Assessment (CEA) Form

Federal Regulations Program Component Descriptions & System Coordination Requirements

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Introduction The Pinellas County Continuum of Care (CoC) is responsible for coordinating and implementing a coordinated homeless response system to meet the needs of persons experiencing or at imminent risk of homelessness within our geographic area (Pinellas County).

Both the Emergency Solution Grant (ESG) and the Homeless Emergency Assistance and Rapid Transition to

Housing (HEARTH) program rules state that each Continuum of Care must establish written rules for the administration of ESG and CoC assistance. All programs that receive ESG or CoC funding are required to abide by these written standards. The CoC strongly encourages programs that do not receive either of these funds to utilize these written standards for consistency purposes.

Most of these standards are informed by the ESG and/or HEARTH Rules and were developed in consultation with CoC and ESG recipients. These partners provided valuable input from the perspective of direct service providers including Homelessness Prevention (HP), Street Outreach (SO), Emergency Shelter

(ES), and Rapid Re-housing (RRH).

Additional standards from the State of Florida are also included to support Coordinated Entry (CE) goals, enhance CoC performance outcomes, and to help the CoC reach the goal of ending homelessness in our region. This is a living document that will evolve with service needs and funder requirements.

Overview of Programs

Continuum of Care Program

The Continuum of Care is a local planning body that coordinates funding for housing and services for homeless families and individuals in Pinellas County, Florida. The Lead Agency for the CoC is the Homeless

Leadership Alliance of Pinellas.

The Continuum of Care is focused on reducing first time homelessness and helping individuals who are literally homeless as defined by the U.S. Department of Housing and Urban Development (HUD). Projects funded through the CoC aim to assist persons experiencing homelessness obtain and maintain permanent housing by providing wraparound services to increase the participant’s likelihood of success.

Emergency Solutions Grant Program

The U.S. Department of Housing and Urban Development awards the Emergency Solutions Grant (ESG) program to entitlement jurisdictions and the State of Florida. The State is required to distribute the grant for projects operated by local government agencies, private non-profit organizations, or a combination of the two. ESG Funds are awarded to CoC Lead Agencies by the Florida Department of Children and Families

(DCF) through an annual grant application process.

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The ESG program is designed to improve the quality and quantity of emergency shelters for persons experiencing homelessness and assist with the costs associated with operating emergency shelters. ESG funds allow persons experiencing homelessness to have access to safe, sanitary, habitable, and functional shelter. These funds also provide services and assistance to those experiencing homelessness with a focus on homelessness prevention. ESG funds can be used for a variety of services, including emergency shelter, short or medium-term rental assistance, housing search and placement, utility arrears, and housing stability case management.

In 2017, the updated ESG Interim Rule broadened existing emergency shelter and homelessness prevention activities by expanding prevention as an eligible use and adding a rapid rehousing component.

The interim rule updated the annual action plan requirements to include written standards for the provision of ESG assistance and performance standards for evaluating ESG activities. The Pinellas County

CoC is a recipient of HUD ESG funds, and the HLA administers the funds to eligible organizations referred to as sub-subrecipients.

The funds under this program are intended to target two populations:

• Individuals and families who are currently in housing, but are at risk of becoming homeless, and in need of temporary rent, utility, or moving assistance to prevent them from becoming homeless.

• Individuals and families who are experiencing homelessness and need temporary assistance to obtain and retain housing.

HUD expects these resources to be targeted and prioritized to serve households that are most in need of temporary assistance and are most likely to achieve stable housing, whether subsidized or unsubsidized, after ESG concludes. ESG assistance is not intended to provide long-term support for program participants, nor will it be able to address all the financial and supportive services needs of households that affect housing stability. Rather, ESG assistance should be focused on housing stabilization, linking program participants to community resources and benefits, and helping them develop a plan for future housing instability.

ESG funds may be used for administrative activities as well as the following program components:

• Street outreach,

• Emergency shelter,

• Homelessness prevention,

• Rapid re-housing assistance, and

• Homeless Management Information Systems (HMIS)

Full details on eligible program components and activities are set forth in 24 CFR 576.101 through 24 CFR

576.107.

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Definitions Literal Homelessness

1. An individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning:

a. A primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings, including a car, park, abandoned building, bus or train station, airport, or camping ground; or

b. A supervised publicly or privately operated shelter designated to provide temporary living arrangements including congregate shelters, transitional housing, hotels, and motels paid for by charitable organizations or government programs; or

c. An individual who is exiting an institution where he or she resided for 90 days or less and who resided in an emergency shelter or place not meant for human habitation immediately before entering that institution.

2. An individual or family who will imminently lose their primary nighttime residence, provided that:

a. The residence will be lost within 14 days of the date of application for assistance; and

b. No subsequent residence has been identified; and

c. The individual or family lacks the resources or support networks, (e.g., family or friends needed to obtain other permanent housing.)

3. Unaccompanied youth under 25 years of age, or families with children who do not otherwise qualify as homeless under this definition, but who:

a. Are defined as homeless under:

i. Section 387 of the Runaway and Homeless Youth Act (42 U.S.C. 5732a)

ii. Section 637 of the Head Start Act (42 U.S.C. 9832)

iii. Section 41403 of the Violence Against Women Act of 1994 (42 U.S.C. 14043e-2)

iv. Section 330(h) of the Public Health Service Act (42 U.S.C. 254b(h))

v. Section 3 of the Food and Nutrition Act of 2008 (7 U.S.C. 2012)

vi. Section 17(b) of the Child Nutrition Act of 1966 (42 U.S.C. 1786(b)) or

vii. Section 725 of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11434a)

b. Have not had a lease, ownership interest, or occupancy agreement in permanent housing at any time during the 60 days immediately preceding application for homeless assistance;

c. Have experienced persistent instability as measured by two moves or more during the 60-day period immediately preceding the date of applying for homeless assistance;

d. Can be expected to continue in such status for an extended period because of chronic disabilities, chronic physical or mental health conditions, substance addiction, histories of domestic violence or childhood abuse (including neglect), the presence of a child or youth with a disability, or two or more barriers to employment. Barriers to employment include the lack of a high school degree or General Education Development (GED), illiteracy, low

English proficiency, a history of incarceration or detention for criminal activity, and a history of unstable employment.

4. Any individual or family who is fleeing, or is attempting to flee, domestic violence, including dating violence, sexual assault, stalking, or other dangerous or life-threatening conditions that relate to

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a. Has no other residence; and

b. Lacks the resources or support networks like family, friends, faith-based or other social networks, to obtain other permanent housing.

At-Risk of Homelessness

1. An individual or family who:

a. Has an annual income below 30% of the median family income for the area, as determined by HUD; and,

b. Does not have sufficient resources or support networks immediately available to prevent them from moving to an emergency shelter or another place unfit for human habitation;

and meets one of the following conditions:

i. Has moved because of economic reasons two or more times during the 60 days immediately preceding the application for assistance;

ii. Is living in the home of another because of economic hardship;

iii. Has been notified in writing that their right to occupy their current housing or living situation will be terminated within 21 days after the date of application for assistance;

c. Lives in a hotel or motel not paid by charitable organizations or government programs;

d. Lives in a single-room occupancy or efficiency apartment unit in which there reside more than two persons;

e. Lives in a larger housing unit in which more than 1.5 persons reside per room, as defined by the U.S. Census Bureau;

f. Is exiting a publicly funded institution, or system of care (such as a health- care facility, a mental health facility, foster care or other youth facility, or correction program or institution); or

g. Otherwise lives in housing that has characteristics associated with instability and an increased risk of homelessness, as identified in the recipient's approved consolidated plan.

2. A child or youth who does not qualify as homeless under this section, but qualifies as “homeless” under section 387 of the Runaway and Homeless Youth Act (42 U.S.C. 5732a(3)), section 637(11) of the Head Start Act (42 U.S.C. 9832(11)), section 41403(6) of the Violence Against Women Act of

1994 (42 U.S.C. 14043e-2(6)), section 330(h)(5)(A) of the Public Health Service Act (42 U.S.C.

254b(h)(5)(A)), section 3(m) of the Food and Nutrition Act of 2008 (7 U.S.C. 2012(m)), or section

17(b)(15) of the Child Nutrition Act of 1966 (42 U.S.C. 1786(b)(15)); or

3. A child or youth who does not qualify as homeless under this section but qualifies as “homeless” under section 725(2) of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11434a(2)), and the parent(s) or guardian(s) of that child is living with her or him.

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Chronically Homeless

A homeless individual with a disability who lives either in a place not meant for human habitation, a safe haven, an emergency shelter, or an institutional care facility.

• The individual must have been living as described above continuously for at least 12 months, or on at least 4 separate occasions in the last 3 years, where the combined occasions total a length of time of at least 12 months. Each period separating the occasions must include at least 7 nights of living in a situation other than a place not meant for human habitation, in an emergency shelter, or in a safe haven.

Continuum of Care (CoC)

A group of representatives who plan for and provide a system of outreach, engagement, and assessment to address the various needs of homeless persons and persons at risk of homelessness for a specific geographic area.

• Representatives may include nonprofit homeless providers, victim service providers, faith‐based organizations, governments, businesses, advocates, public housing agencies, school districts, social service providers, mental health agencies, hospitals, universities, affordable housing developers, law enforcement, organizations that serve homeless and formerly homeless veterans, and homeless and formerly homeless persons.

Emergency Shelter

Any facility, the primary purpose of which is to provide a temporary shelter for the homeless in general or for specific populations of the homeless which does not require occupants to sign leases or occupancy agreements.

Homeless Management Information System (HMIS)

The information system designated by the Continuum of Care to comply with HUD’s data collection, management, and reporting standards. HMIS is used to collect client‐level data on the provision of housing and services to homeless individuals, homeless families, and persons at‐risk of homelessness.

Homelessness Prevention

Housing relocation and stabilization services and short or medium‐term rental assistance to prevent the individual or family from moving to an emergency shelter, a place not meant for human habitation, or another place described in Homeless Category 1 of Appendix A: HUD Definition for Homeless.

Private Nonprofit Organization

A secular or religious organization described in section 501(c) of the Internal Revenue Code of 1986 which is exempt from taxation under subtitle A of the Code. A private nonprofit organization has a voluntary board and does not include a governmental organization. A private nonprofit organization must have an accounting system and must practices nondiscrimination in the provision of assistance.

Program Participant An individual or family who is assisted under any CoC or ESG program.

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Rapid Re‐Housing (RRH) Housing relocation and stabilization services and/or short or medium‐term rental assistance to help individuals or families living in emergency shelters or in places not meant for human habitation move as quickly as possible into permanent housing and achieve stability in that housing.

Street Outreach (SO)

Essential services related to reaching out to unsheltered homeless individuals and families, connecting them with emergency shelter, housing, or critical services, and providing them with urgent, non‐facility-based care.

Subrecipient A local government or private nonprofit organization to which a recipient makes available CoC and/or ESG funds.

Victim Service Provider

A private nonprofit organization whose primary mission is to provide services to victims of domestic violence, dating violence, sexual assault, or stalking. This term includes rape crisis centers, battered women’s shelters, domestic violence transitional housing programs, and other programs.

Standards for All Project Types

Guiding Principles

Housing First

Housing First is a programmatic and systems approach that prioritizes the provision of permanent housing to people experiencing homelessness quickly and without preconditions or service participation requirements. This approach is guided by the belief that people need necessities like food and shelter before they can attend to secondary concerns like getting a job, budgeting, or substance use issues.

Housing first is not only about housing. It is housing plus participant driven services, connection to mainstream resources, and community integration. Housing is the foundation upon which healing begins for persons experiencing homelessness.

Core Elements of Housing First at the Project Level:

• Access to projects is not contingent on sobriety, minimum income requirements, lack of a criminal record (including status on the sex offender registry), completion of treatment, participation in services, or other unnecessary conditions.

• Projects do everything possible not to reject a household based on poor credit or financial history, poor or lack of rental history, minor criminal convictions, or behaviors that are interpreted as indicating a lack of “housing readiness.”

• People with disabilities are offered clear opportunities to request reasonable accommodations during screening processes and tenancy. Building and apartment units include special physical features that accommodate disabilities.

• Housing and service plans are highly tenant-driven.

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• Participation in services is voluntary and not a condition of tenancy but can and should be used to engage participants and ensure housing stability persistently and progressively.

• Services are informed by a harm-reduction philosophy that recognizes that drug and alcohol use and addiction are a part of some tenants’ lives. Tenants are engaged in non-judgmental communication regarding drug and alcohol use and are offered education regarding how to avoid risky behaviors and engage in safer practices.

• Substance use in and of itself, without other lease violations, is not considered a reason for eviction

Housing Focused Problem Solving

Assistance provided to households at-risk of or experiencing homelessness is focused on moving to and maintaining permanent housing. Wherever possible, persons arriving at the “front door” of the homelessness emergency response system should be diverted to a permanent housing situation rather than being serviced by emergency shelters and transitional housing.

Housing focused problem-solving involves strengths-based conversations to empower households that help to identify alternative housing options either to avoid homelessness or to exit homelessness as quickly as possible.

Housing focused problem-solving can be utilized to divert households not prioritized for more intensive housing and service options.

The goal of problem-solving is to explore creative, flexible, and safe, cost-effective solutions to quickly resolve the housing crisis. problem-solving seeks to empower households by having an unwavering respect for their strengths, goals, and preferences. The homeless emergency response system can help the household regain a sense of control by focusing on their strengths and resiliency.

No Wrong Door Coordinated Entry and Resource Prioritization

The Coordinated Entry process (CE) aims to help each household that experiences homelessness get the appropriate type of service intervention in the most efficient manner. Assistance is prioritized based upon level of acuity, vulnerability, severity of service needs, and length of time homeless. The CoC operates a coordinated entry process in which there is “no-wrong-door” to access housing and services. Any provider can participate in the coordinated entry referral process. Individuals can self-refer through the 2-1-1 Tampa Bay Cares’ Homeless

Hotline (HHL) and are provided access to a HHL Care Coordinator for diversion mediation and referral.

Person Centered Approach

A person-centered approach is where the person is placed at the center of the service and treated as a person first. The focus is on the person and what they can do, not their homelessness or the circumstances that brought them to homelessness. Support focuses on achieving the person's aspirations and should be tailored to their needs and unique circumstances. The CoC integrates a person-centered approach into participant choice, which includes location and type of housing, level of services, and other options where households can participate in their decisions.

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Trauma Informed Care

Homeless services have an important role in addressing the long-lasting effects of trauma and also in preventing further trauma. It is important that services recognize the significance of violence and trauma exposure in understanding their clients’ problems and address them successfully by developing trauma-informed approaches. Trauma from the experience of homelessness reflects a failure of services to provide housing and support, and at worst re-traumatization because of punitive power structures and responses to the behaviors arising from the experience of compound trauma. The bigger the delay in getting the person into housing, the more psychological barriers are created by the experience of homelessness. To prevent a vicious cycle, housing should be obtained as quickly as possible to minimize the potential of additional traumatic experiences. A trauma informed service incorporates an understanding of trauma in its work. This also means that the providers and staff become aware how various symptoms and behaviors represent adaptations to traumatic experiences. This includes staff training that is monitored by the CoC to ensure services such as routine screening for traumatic histories and an assessment of safety are completed.1

Strength/Asset-Based Approach

An asset-based approach focuses on the inherent strengths of participants and utilizes these personal strengths to aid in the achievement of the participants’ goals. Specific CoC values include:

• Every individual, group, family, and community have strengths.

• Trauma, illness, and struggle may be harmful, but they may also be sources of challenge and opportunity.

• There is no limit to a person’s growth, achievement, or success.

• We best serve participants by collaborating with them.

• Every environment is full of resources.

• Supportive services culture incorporates a progressive engagement model and Motivational

Interviewing as a best practice for delivery of services.

Homeless Management Information System (HMIS) Participation

The Homeless Management Information System (HMIS) is the backbone of service coordination and collaboration. Per HUD regulation, all CoC and ESG funded projects are required to track program and client level data in HMIS and comply with Pinellas HMIS Policies and Procedures2 and workflows. All agencies serving persons experiencing homelessness are encouraged to contribute to HMIS. Victim service providers are not required to enter or track data through HMIS as a safety measure for survivors, however another comparable database must be maintained that meets all HMIS data standards when utilizing CoC and/or ESG funds.

1 EUROPEAN FEDERATION OF NATIONAL ORGANIZATIONS WORKING WITH THE HOMELESS, (2017)

HTTPS://WWW.FEANTSA.ORG/DOWNLOAD/FEANTSA_TRAUMAANDHOMELESSNESS03073471219052946810738.PDF 2 HTTPS://PINELLASHMIS.ZENDESK.COM/HC/EN-US/CATEGORIES/115000252954-POLICIES-AND-FORMS

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Access to Mainstream Resources CoC and ESG funded projects are required to certify coordination and integration of homeless programs with other federal mainstream resources (i.e., health, social service, and employment programs) for which people may be eligible. Utilizing mainstream resources provides program flexibility, meets HUD match requirements, increases movement out of homelessness, and leverages other resources.

• Examples of mainstream resources include Medicaid, State Children’s Health Insurance Program, VA Healthcare, Food Stamps, Temporary Aid for Needy Families (TANF), Supplemental Security

Income (SSI/SSDI), and Workforce Investment Act (WIA).

Grievance Procedures The CoC Grievance Subcommittee acts on behalf of the Pinellas CoC Board to resolve grievances and determine a course of action. Grievance Subcommittee Membership consists of the Executive Committee

Chair and Vice Chair, and three (3) additional members. The Grievance Subcommittee resolves issues with respect to funding, HMIS issues, and denial of membership. The Subcommittee establishes its own rules, processes, and procedures for submitting and resolving grievances.

Intervention Specific Standards

General Requirements for ESG

1. All client files must contain documentation on the current housing status at intake and determination of a client meeting one of the established HUD definitions of “homelessness” to help determine the type of assistance to be provided.

a. Re-evaluations, including income using 24 CFR Part 5 requirements are required upon intake and once every three months to ensure continuous eligibility.

b. Case management meetings with heads of households are required at least once per month.

2. Duration of rental assistance:

a. Short Term - Up to 3 months

b. Medium Term - An additional 9 months (Total of 12 months)

3. Maximum Level of Assistance:

a. Financial Assistance: Maximum of $3,000 per household for rent deposits, moving costs, storage, utility, and rental arrears.

b. Rental Assistance: Maximum of $1,300 per household, per month in combined rent and utilities.

c. Total Maximum: Up to $10,000 (not including financial assistance) over 12 months.

i. To exceed the maximum, the provider must case conference with Homeless

Leadership Alliance of Pinellas’ (HLA) Director of Quality and Performance

Improvement.

4. Landlord and utility vendor payments must be paid directly to the landlord or vendor.

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a. ESG Minimum Habitability Standards must be satisfied.3

b. Fair Housing market rates apply.4

c. Lead-based paint remediation and disclosure applies to all ESG funded housing.

Homelessness Prevention

The CoC encourages homelessness prevention programs to focus on serving households that are most likely to become homeless. By targeting these households, communities increase their odds limited resources will return maximum results.

Prevention Requirements

1. Individuals and families must have incomes below 30% of the area median income (AMI) at intake, and incomes that do not exceed 30% of AMI at re-evaluation which must take place no less than once every 3 months.

2. Prevention must involve case management to develop and implement case plans for the individuals, which link individuals to supportive services that help them maintain stable housing.

3. Sub-recipients who receive funding through ESG for homelessness prevention will be subject to the following requirements:

a. Staff and volunteers who interact with clients must participate in diversion training offered by the CoC annually.

b. Staff must provide information on programs and give assistance accessing these programs if the programs may meet identified client needs. Programs may include but are not limited to:

i. 211

ii. Social security benefits

iii. Food stamps assistance

iv. Affordable housing database

v. Job training programs

vi. Health services

vii. Education programs

viii. Services for victims of domestic violence

ix. Veteran services

Eligible Prevention Services

1. Housing relocation and stabilization services including but not limited to:

a. Rental application fees, security deposits, last month’s rent, utility payments, moving costs, housing search and placement, housing stability case management, mediation, and legal services.

2. Short-term or medium-term rental assistance.

a. Assistance can be short-term or long-term and can be more than one-time assistance.

3 HTTPS://FILES.HUDEXCHANGE.INFO/RESOURCES/DOCUMENTS/ESG-EMERGENCY-SHELTER-AND-PERMANENT-HOUSING-STANDARDS.PDF

4 HTTPS://WWW.HUDUSER.GOV/PORTAL/DATASETS/FMR/FMRS/FY2021_CODE/2021SUMMARY.ODN

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Individuals and families experiencing homelessness must not be required to receive treatment or perform any other prerequisite activities as a condition for receiving housing or rental assistance.

Performance Indicators for Prevention Programs

• At least 90% of individuals remain in or exit to permanent housing at program exit.

• At least 75% of individuals will remain in housing 12 months after project exit.

Emergency Shelter The CoC has established minimum standards for emergency shelters operating within the CoC and/or those who are funded through the ESG Program. The following standards for safety, sanitation, and privacy align with the ESG Program interim rule. Standards for Emergency Shelter ESG-CV can be found on page 29.

Shelter Habitability

1. The facility must comply with all applicable building, housing, zoning, environmental, fire, health, and safety codes including but not limited to:

a. Properly operational windows and doors

b. An adequate number of showers and toilets

c. Heating units for Winter and the ability to create airflow in the Summer.

2. A bed, crib, cot, or a mat with clean and appropriate bedding must be provided for each client except in extenuating overflow situations.

3. First aid equipment and supplies are always available and accessible.

Shelter Policies and Procedures

1. The following policies are required to be posted in each emergency shelter:

a. Emergency contact numbers

b. Emergency procedures

c. House rules and regulations

d. Disciplinary and grievance procedures

e. Consent and non-consent to searches

i. Clients must also be verbally informed of the policy and receive it in writing. This does not apply to temporary shelter due to emergency situations.

2. A designated space for locking and securing client files is required.

a. A written intake and client record file that includes intake interviews and records of services provided must be maintained.

3. A cultural competency plan is required.

a. This should include access to translation services for persons with limited English proficiency.

4. A policy and procedure for storing, securing, and retrieving residents’ medication is required.

a. A medication log must be maintained as client medications are distributed.

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5. A policy and procedure for referring residents to a medical facility for health examinations and medical care, emergency treatment, and follow-up visits is required.

6. A policy and procedure for reporting child and elder abuse is required.

Intake Procedures and Client Rights

1. Support services must be voluntary and allow for participant choice.

2. Shelters must have a written document outlining clients’ rights.

a. A copy must be provided to residents upon intake and receipt of this policy must be acknowledged in writing by the residents and maintained by the provider.

b. Accommodations for literacy and language barriers must be made.

c. Clients’ rights must include:

i. If/how rules and regulations are modified during a State of Emergency.

ii. Instructions for grievances and appeals.

iii. Access to public education for children and youth.

iv. Participation in any program ordered by the justice system.

3. Shelters must review project rules and guidelines upon intake and receipt of this policy must be acknowledged in writing by the residents and maintained by the provider. Guidelines may include but not limited to:

a. The re-release of information

b. Confidentiality and privacy

c. Data collection

d. HIPPA rules

Staff and Volunteer Requirements

1. All staff and volunteers must be identifiable to clients and visitors.

2. Annual training is required for staff and volunteers in the following areas:

a. Relevant community resources and social service programs

b. Client rights

c. Ethics, code of conduct, and confidentiality

d. Safety

e. HIPPA

f. ADA

3. Additionally, annual training is required for staff in the following areas:

a. Emergency evacuation

b. First aid and CPR procedures

c. Counseling skills and de-escalation

d. Screening procedures and reporting protocols for confirmed or suspected infections

e. Trauma-informed communication

f. Cleaning & Disinfecting Surfaces

g. Cleaning Bodily Fluids

h. Hand Hygiene

i. Proper Waste Disposal

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j. Using Personal Protective Equipment

k. Safe Food Handling

Performance Indicators for Shelter Programs

• At least 30% of individuals in ES projects will exit to anywhere other than homelessness.

• ES projects will have no more than 23% of individuals who exited to permanent housing return to ES, SH, TH or SO within 6 months of exit (based off SPM, clean data).

• ES projects will have no more than 37% of individuals who exited to permanent housing return to ES, SH, TH or SO within two years of exit (based off SPM, clean data).

Rapid Rehousing Rapid Re-Housing (RRH) is available to help those who are experiencing homelessness be quickly and permanently housed. RRH provides housing relocation and stabilization services, and short or medium-term rental assistance as needed. Households experiencing homelessness should move as quickly as possible to permanent housing and achieve stability in that housing. Programs must follow any additional eligibility criteria set forth in the NOFA/RFP through which a project was funded and the grant agreement.

Minimum Standards for Rapid Re-Housing Assistance:

• Participation in RRH programs cannot exceed 24 months in any three-year period.

• Supportive services must be offered throughout the duration of stay in housing.

• Participants are required to meet with a Housing Stability Case Manager not less than once per month to assist in ensuring long-term housing stability.

• Participants must enter into a lease agreement for a term of at least one year, which is terminable for cause. The lease must be automatically renewable upon expiration for terms that are a minimum of one month long, except on prior notice by either party.

• A participant’s resources and support networks necessary to retain housing without assistance must be revaluated quarterly through the Service Prioritization Decision Assistance Tool (SPDAT).

• Rental assistance will only be provided if the total rent for the unit does not exceed the fair market rent established by HUD5, complies with HUD’s standards of rent reasonableness6 and follows the

CoC’s program rent requirements within the RRH Standards of Care.7

• Program participants will be reassessed quarterly to determine that income is not greater than

30% of AMI, as established by HUD.

5 HUD Fair Market Rents https://www.huduser.gov/portal/datasets/fmr.html 6 HUD ESG Standards of Rent Reasonableness https://files.hudexchange.info/resources/documents/ESG-Rent- Reasonableness-and-FMR.pdf 7 CoC RRH Standards of Care https://pinellashomeless.sharepoint.com/HLA%20NonProfit/Forms/AllItems.aspx?id=%2FHLA%20NonProfit%2FQuali ty%20and%20Performance%20Improvement%2FRapid%20Rehousing%2F2021%2D06%2D01%20RRH%20Standards% 20of%20Care%20FINAL%20%2Edocx&parent=%2FHLA%20NonProfit%2FQuality%20and%20Performance%20Improve ment%2FRapid%20Rehousing

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• Rapid Rehousing subrecipients are expected to:

o Use CES to receive all referrals.

o Comply with CES policies and procedures.

o Ensure dwellings meet HUD ESG Habitability Standards and should be inspected at least once every five years or upon request.

o Complete and maintain a copy of the “Notice of Occupancy Rights under the Violence

Against Women Act” based on HUD form 5380, and the “Certification of Domestic

Violence, Dating Violence, Sexual Assault, or Stalking,” HUD form 5382 must be completed if the applicant or Program Participants are seeking VAWA protections.

o Refer eligible families to mainstream resources including, but not limited to

▪ TANF

▪ Early Learning Coalition

▪ Head Start

▪ Medicaid

▪ Social security benefits

▪ Food stamps assistance

▪ Affordable housing database

▪ Job training programs

▪ Education programs

▪ Services for victims of domestic violence

▪ Veteran services

Performance Indicators for Rapid Re-Housing Programs

• RRH projects will have an average household length of stay of no more than 270 days.

• RRH projects will have a median household length of stay of no more than 149 days.

• RRH projects will place individuals into permanent housing within 90 days of project entry.

• At least 85% of housed individuals remain in permanent housing at program exit.

• At least 15% of individuals in RRH projects will increase earned income during the reporting period or at exit.

• At least 20% of individuals in RRH projects will maintain earned income during the reporting period or at exit.

• At least 20% of individuals in RRH projects will increase unearned income during the reporting period or at exit.

• At least 15% of individuals in RRH projects will maintain unearned income during the reporting period or at exit.

• The average VI-SPDAT score on RRH project is greater than 7.

• RRH projects will have no more than 10% of adults who exited to permanent housing that return to ES, SH, TH, or SO within 6 months of exit.

• RRH projects will have no more than 20% of adults who exited to permanent housing that return to ES, SH, TH or SO within two years of exit.

https://www.hudexchange.info/resource/3766/esg-minimum-habitability-standards-for-emergency-shelters-and-permanent-housing/

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Program Component Chart

Program Description

Program Elements Eligible Clients Client Requirements

Prevention Activities or programs designed to prevent the incidence of homelessness

• Up to 24 months of rental assistance;

• Deposits

• Utilities

• Rent arrears

One of the following:

• Doubled up

• Fleeing DV

• Within 21 days of eviction (written notice)

• Moved 2+ times in the past 6 months

• Pay 30% of income

• Anticipation of increased income

• Participation in

CM

• Apply for mainstream resources

Non- Congregate Emergency Shelter

Temporary shelter for homeless persons with a link to housing focused services.

Ideally for less than 45 days.

• Case Management

• Referral for services

• Transportation

• Showers

• Laundry

• Meals

• Phone & internet

• Safe sleeping

• Category 1 & 4 Homelessness

• No other supports or resources to secure housing

• Diversion was unsuccessful

• Required to engage housing planning.

• Required to engage in case management 1x per week.

Rapid Re- Housing

Housing and supportive services for persons moving from homelessness to permanent housing.

• Short- or medium-term rent or utility subsidies

• Housing Stability Case Management

• Security deposits or first month's rent

• Housing navigation

• Mediation programs for landlord-tenant disputes

• Workforce development and education

• Financial assistance for basic needs

Individuals with low to moderate barriers exiting homelessness who have a strong chance of increasing their income and stabilizing their housing with short to medium term support.

NA

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Coordinated Entry and Assessment The Coordinated Entry process (CE) creates access to the emergency crisis homeless response system, provides standardized assessment, prioritization, and referral through the best fit housing intervention.

Persons experiencing homelessness can be assessed by going to community access points (Emergency

Shelter) or meeting with Street Outreach.

The Coordinated Entry System is open to all who meet the HUD definition of homeless, as outlined in the

HEARTH Act8 regulations. The system uses the person’s level of vulnerability (described in Definitions) to determine priority for housing and supportive services. The person with the highest priority is offered housing and supportive services first.

CoC prioritization includes:

• Households with a disability, long periods of episodic homelessness and severe service needs.

• Households with a disability and severe service needs.

• Households with a disability, coming from places not meant for human habilitation, Safe Haven, or

Emergency Shelter without severe service needs.

• Households with a disability coming from Transitional Housing or Domestic Violence Survivor.

CE is designed to assess eligibility for housing programs targeted to homeless persons. It is not a guarantee that the individual will meet the final eligibility requirements for - or receive a referral to - a particular housing option. The CE System (CES) is not a stand-alone solution to end homelessness or a solution to the shortage of affordable housing. The CES supports the purpose of the CoC: to facilitate a comprehensive and integrated system of services in Pinellas County designed to ensure that any experience of homelessness is rare, brief, and a onetime experience.

Workflow

Assessment

Participating service providers gather information on people’s needs, preferences, and the barriers they face to regaining housing by administering a standardized assessment. This standard assessment includes consent via the Release of Information, gathering basic household data via the HMIS CoC Entry, and gauging the vulnerability through administering the Vulnerability Index – Service Prioritization Decision

Assistance Tool (VI-SPDAT).

Referral

Once the assessment has identified the most vulnerable people with the highest needs, they are prioritized on a by-name list. The CE reviews the referral and person’s eligibility, decides on eligibility and what program would best fit the client’s needs, using the VI- SPDAT to guide the referral process. CE then makes a referral in Pinellas HMIS to the appropriate housing intervention provider.

Housing Provider Contact Protocols and Policy

1. Housing providers must contact the household within 48 business hours of receiving the referral.

8 https://www.hudexchange.info/homelessness-assistance/hearth-act/

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a. If contact is not made during the first attempt, housing providers should attempt contact for a period of 10 business days from the data of referral.

b. Within this 10-day period there are to be at a minimum, of three contacts using various means during different days and different times.

2. If the individual or household is staying in shelter, shelter staff must be contacted to coordinate a meeting within 48 hours of the referral from Coordinated Entry.

3. After 11 business days, if no contact has been made with the household, the housing provider will respond within Pinellas HMIS to indicate “declined” referral and request a new referral due to the household not being able to be contacted.

a. Within 15 business days of receiving the initial CE referral, housing providers must update the household’s status toward project enrollment by selecting CES: Accepted or CES:

Declined.

b. After a household cannot be initially located but the contact the housing provider within a

30-day period of the referral, they have not been referred to another provider, and the housing provider has referral capacity, the housing provider can contact

Drandall@hlapinellas.org and request the household be re-referred.

4. Individuals/households that cannot be located after two consecutive referrals to different housing provider projects will not be referred again until they have an updated VI-SPDAT within HMIS.

5. Individuals/households being referred through CE can deny up to two (2) housing provider referral opportunities, after the second offered and denial, the household will not be considered for any further housing opportunities and be removed from the CoC By-Name list.

6. Any housing provider may request an extension to the Interim Timeliness Standard by emailing

Drandall@hlapinellas.org

Other Standards

Conflicts of Interest Subrecipients must avoid any conflict of interest in carrying out activities funded by the CoC program and

ESG. Upon written request by the recipient, HUD may grant exceptions on a case-by-case basis. (See 24

CFR 576.404(b)(3)(ii)). Conflicts of interest may include:

• Organizational Conflicts of Interest o The provision of ESG assistance may not be conditioned on an individual’s or family’s acceptance or occupancy of emergency shelter or housing owned by the recipient, the sub-recipient, or a parent or subsidiary of the sub-recipient.

o Subrecipients must not conduct initial evaluation or provide homelessness prevention assistance to persons living in property owned by the subrecipient or parent/subsidiary of the subrecipient.

• Individual Conflicts of Interest o Recipients and subrecipients must comply with HUD’s Administration requirements (24

CFR 85.36 or 84.42 for procurement of goods and services. For all other transactions and activities:

▪ Restrictions on financial interests and benefits apply to employees, agents, mailto:Drandall@hlapinellas.org mailto:Drandall@hlapinellas.org

21 | Page consultants, officers and elected or appointed officials of the recipient or subrecipient if they have certain types of responsible positions.

▪ Restrictions pertain to financial gain for self, family, or those with business ties.

Fair Housing & Civil Rights Requirements Agencies must comply with all applicable fair housing and civil rights requirements in 24CFR 5.105(a). In addition, agencies must make known that rental assistance and services are available to all on a nondiscriminatory basis and ensure that all citizens have equal access to information about equal access to the financial assistance and services provided under this program. Among other things, this means that each subgrantee must take reasonable steps to ensure meaningful access to programs to persons with limited English proficiency (LEP), pursuant to Title VI of the Civil Rights Act of 1964. This may mean providing language assistance or ensuring that program information is available in the appropriate languages for the geographic area served by the jurisdiction and that limited English proficient persons have meaningful access to assistance. In addition, all notices and communications shall be provided in a manner that is effective for persons with hearing, visual, and other communication related disabilities consistent with section 504 of the Rehabilitation Act of 1973 and implementing regulations at 24 CFR 8.6.

If the procedures that the agency intends to use to make known the availability of the rental assistance and services are unlikely to reach persons of any race, color, religion, sex, age, national origin, familial status, or disability who may qualify for such rental assistance and services, the agency must establish additional procedures that will ensure that such persons are made aware of the rental assistance and services.

Under section 808(e)(5) of the Fair Housing Act, HUD has a statutory duty to affirmatively further fair housing. HUD requires the same of its funding recipients. Agencies will have a duty to affirmatively further fair housing opportunities for classes protected under the Fair Housing Act. Protected classes include race, color, national origin, religion, sex, disability, and familial status. Examples of affirmatively furthering fair housing include:

• Marketing the program to all eligible persons, including persons with disabilities and persons with limited English proficiency

• Making buildings and communications that facilitate applications and service delivery accessible to persons with disabilities (see, for example, HUD’s rule on effective communications at 24 CFR 8.6)

• Providing fair housing counseling services or referrals to fair housing agencies

• Informing participants of how to file a housing discrimination complaint, including providing the toll-free number for the HUD Housing Discrimination Hotline: 1-800-669-9777

• Recruiting landlords and service providers in areas that expand housing choice to program participants.

Equal Participation of Religious Organizations Agencies that are religious or faith-based are eligible, on the same basis as any other organization, to participate in the CoC. Neither the federal government nor a grantee shall discriminate against an organization based on the organization's religious character or affiliation.

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Agencies may not engage in inherently religious activities, such as worship, religious instruction, or proselytization as part of the programs or services. If an organization conducts such activities, the activities must be offered separately, in time or location, from the programs or services, and participation must be voluntary for the program participants.

A religious organization that participates in the CoC will retain its independence from federal, state, and local governments, and may continue to carry out its mission, including the definition, practice, and expression of its religious beliefs, provided that it does not use direct funds to support any inherently religious activities, such as worship, religious instruction, or proselytization. Among other things, faith-based organizations may use space in their facilities to provide services, without removing religious art, icons, scriptures, or other religious symbols. In addition, a religious organization retains its authority over its internal governance, and it may retain religious terms in its organization's name, select its board members on a religious basis, and include religious references in its organization's mission statements and other governing documents.

Agencies that participate in the CoC shall not, in providing program assistance, discriminate against a program participant or prospective program participant based on religion or religious belief.

Lobbying and Disclosure Requirements The disclosure requirements and prohibitions of section 319 of the Department of the Interior and Related

Agencies Appropriations Act for Fiscal Year 1990 (31 U.S.C. 1352) (the Byrd Amendment), and implementing regulations at 24 CFR part 87, apply to the CoC. Applicants must disclose, using Standard

Form LLL (SF-LLL), “Disclosure of Lobbying Activities,” any funds, other than federally appropriated funds, that will be or have been used to influence federal employees, members of Congress, or congressional staff regarding specific grants or contracts.

Drug-Free Workplace Requirements The Drug-Free Workplace Act of 1988 (41 U.S.C. 701, et seq.) and HUD’s implementing regulations at 24

CFR part 21 apply to the CoC.

Emergency Procedures The Homeless Leadership Alliance of Pinellas (HLA) has been appointed…