Issue Date
September 20, 2011
Audit Report Number
2011-NY-1015
TO: Anne Marie Uebbing, Director, Office of Community Planning and
Development, 2FD
FROM: Edgar Moore, Regional Inspector General for Audit, 2AGA
SUBJECT: Weaknesses Existed in Essex County, NJ’s Administration of Its Homelessness
Prevention and Rapid Re-Housing Program
HIGHLIGHTS
What We Audited and Why
We audited Essex County, NJ’s Homelessnes Prevention and Rapid Re-Housing
Program (HPRP) in support of the U.S. Department of Housing and Urban
Development (HUD), Office of Inspector General’s (OIG) goal to review the
expenditure of American Recovery and Reinvestment Act funds and contribute to
improving HUD’s execution and accoutability of fiscal responsibilites. We
selected Essex County based on a risk assessment that considered that the County
received approximately $2.5 million in HPRP funds and received a score of 43, as
compared to the median score of 34, in HUD’s HPRP risk assessment. The audit
objective was to determine whether Essex County officials obligated and
expended HPRP funds within prescribed timeframes and implemented adequate
controls to ensure that grant awards complied with HPRP program requirements.
What We Found
While Essex County officials ensured that HPRP funds were obligated and
expended within prescribed timeframes, they had not established adequate
controls to ensure that the County’s HPRP was administered in accordance with
program requirements. We attribute these conditions to Essex County and
subrecipient officials’ unfamiliarity with program requirements. Consequently,
its subrecipient expended at least $43,833 contrary to program requirements,
disbursed $141,260 on behalf of recipients whose eligibility was not adequately
supported, and awarded grants that did not always comply with administrative
requirements. As a result, Essex County officials cannot adequately assure HUD
that HPRP funds were expended in accordance with HPRP requirements.
What We Recommend
We recommend that the Director of HUD’s New Jersey Office of Community
Planning and Development instruct Essex County officials to (1) reimburse the
HPRP line of credit $43,833 for funds expended on ineligible HPRP costs, (2)
provide documentation to adequately support the $141,260 in unsupported
disbursements, and (3) strengthen subrecipient monitoring procedures before
administrating future similar HUD-funded programs.
For each recommendation in the body of this report without a management
decision, please respond and provide status reports in accordance with HUD
Handbook 2000.06, REV-3. Please furnish us copies of any correspondence or
directives issued because of the audit.
Auditee’s Response
We provided a draft audit report to Essex County officials on August 31, 2011,
and held an exit conference with Essex County officials on September 9, 2011.
Essex County Officials provided written comments on September 13, 2011. They
generally agreed with our report. The complete text of the auditee’s response,
along with our evaluation of that response, can be found in appendix B of this
report.
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TABLE OF CONTENTS
Background and Objective 4
Results of Audit
Finding 1: Weaknesses Existed in Essex County’s Administration of Its 5
Homelessness Prevention and Rapid Re-Housing Program
Scope and Methodology 11
Internal Controls 13
Appendixes
A. Schedule of Questioned Costs 15
B. Auditee’s Comments and OIG’s Evaluation 16
C. Criteria 19
3
BACKGROUND AND OBJECTIVE
The Homelessness Prevention and Rapid Re-Housing Program (HPRP) is a new housing
assistance program under the U.S. Department of Housing and Urban Development (HUD)
Office of Community Planning and Development. It was funded on February 17, 2009 under the
American Recovery and Reinvestment Act of 2009, which provided $1.5 billion for temporary
financial assistance and housing relocation and stabilization services to individuals and families
that are homeless, or would be homeless but for this assistance. Accordingly, HPRP assistance is
targeted at individuals and families that are (1) currently in housing, but are at risk of becoming
homeless and need temporary rent or utility assistance, or assistance to move to another unit and
(2) experiencing homelessness (residing in emergency or transitional shelters or on the street),
and need temporary assistance to obtain housing.
HPRP funding was distributed by HUD based upon the formula used for its Emergency Shelter
Grant program. HUD awarded more than $2.5 million in HPRP funds to Essex County, NJ,
which designated its Division of Housing and Community Development to administer the
program. On September 30, 2009, the County subsequently executed a subrecipient agreement
with its Division of Community Action, which reportedly had experience with similar programs,
through which it awarded $2,457,860 to be used for HPRP activities. On April 6, 2010,
authorization to administer the program was reassigned from the County’s Division of
Community Action to the Division of Training and Employment. The Division of Housing and
Community Development retained $63,022 for its administrative costs.
The objective of this audit was to determine whether Essex County officials obligated and
expended HPRP funds within prescribed timeframes and implemented adequate controls to
ensure that grant awards complied with HPRP program requirements.
4
RESULTS OF AUDIT
Finding: Weaknesses Existed in Essex County’s Administration of Its
Homelessness Prevention and Rapid Re-Housing Program
While Essex County officials ensured that HPRP funds were obligated and expended within
prescribed timeframes, they had not established adequate controls to ensure that the County’s
HPRP was administered in accordance with program requirements. Specifically, Essex County
officials provided inadequate training and oversight to a subrecipient, and the subrecipient
awarded grants for ineligible and unsupported costs, and that did not comply with administrative
requirements. We attribute these conditions to Essex County and subrecipient officials’
unfamiliarity with program requirements. Consequently, its subrecipient expended at least
$43,833 contrary to program requirements, disbursed $141,260 on behalf of recipients whose
eligibility was not adequately supported, and awarded grants that did not always comply with
administrative requirements. As a result, Essex County officials cannot adequately assure HUD
that HPRP funds were expended in accordance with HPRP requirements.
HPRP Funds Obligated and
Expended Within Prescribed
Timeframes
Essex County officials were awarded $2.5 million on July 16, 2009. In spite of
difficulties in the initial implementation of the HPRP, officials obligated and
expended HPRP funds within prescribed timeframes. The notice of funding
availability for the HPRP required that grantees obligate funds by September 30,
2009. Further, the American Recovery and Reinvestment Act required that 60
percent of the funds be expended within 2 years of the date that the funds became
available to a grantee and that 100 percent be expended within 3 years of that
time. Essex County officials obligated the funds in a timely manner by executing
a subrecipient agreement on September 30, 2009 with the County’s Division of
Community Action.
Essex County officials believed the Division of Community Action had the ability
to administer the HPRP; however, they later released the Division from
administrating the program because they thought it was progressing too slowly in
its implementation of the HPRP. Consequently, on April 6, 2010, the County
reassigned administration of the HPRP to the County’s Division of Training and
Employment.
Based on reports obtained from HUD’s Integrated Disbursement and Information
System, $2.3 million, or 91.7 percent of the Essex County’s more than $2.5
million in HPRP funds were expended as of March 31, 2011, thereby exceeding
the 60 percent requirement that $1.5 million be expended before July 16, 2011. In
5
addition, Essex County officials had expended $18,000 of the more than $63,000
they had set aside for administrative costs.
Inadequate Training and
Oversight Provided to the
County’s Subrecipient
There were weaknesses in the training and oversight provided to Essex County’s
subrecipient. Specifically, Essex County officials did not provide the Division of
Training and Employment staff adequate technical assistance, conduct quarterly
monitoring reviews as planned, or follow up to ensure that deficiencies noted
during monitoring had been corrected. While Section 2 of the County’s HPRP
Manual provided that the County would give support and technical assistance to
the subrecipient, County officials provided little training or technical assistance to
the Division of Training and Employment officials. Officials of the Division of
Training and Employment stated that they did not have experience with programs
comparable to HPRP, and that training provided was less than an hour during a
meeting arranged by Essex County officials with an HPRP specialist from HUD
to answer their questions. This deficiency occurred because Essex County
officials did not have sufficient staff to provide training and technical assistance
to its subrecipient.
Regulations at 24 CFR (Code of Federal Regulations) 85.40(a), Monitoring and
Reporting Program Performance, require HPRP grantees to monitor grant and
sub-grant supported activities to assure compliance with applicable Federal
requirements. Further, section C of Essex County’s substantial amendment for its
program year 2008 Action Plan (Amendment) provided that County officials
would conduct quarterly onsite monitoring visits of all subgrantees to ensure that
services identified in the contract were provided. However, County officials did
not conduct visits as planned; they conducted three monitoring visits between
October 2009 and January 2011, one to the Division of Community Action in
November 2009, and two to the Division of Training and Employment in June
2010 and January 2011.
Review of the subrecipient monitoring reports disclosed that the reports were not
always adequate and follow-up was not conducted to ensure that the corrective
action needed had been taken. For instance, review of three cases included in the
County’s reports disclosed potential participant ineligibility issues that were not
addressed by the subrecipient or followed-up on by County officials. For
example, in one case, there was no explanation in the file as to why the income, if
any, of the participant to whom an eviction notice was given was not considered
in determining eligibility. Also, in two other cases, County officials did not
inquire about the participants’ financial resources other than salary.
6
Further, while County officials provided the subrecipient with a report of
deficiencies found, along with recommendations for corrective action, County
officials did not ensure that the subrecipient implemented the recommended
corrective action. For instance, the monitoring review report dated January 11,
2011 noted that an HPRP case file did not contain a bill to support $590 in
moving expenses that were paid from HPRP funds and recommended that the
subrecipient’s staff obtain a copy of the bill. However, at the time of our review,
subrecipient staff had not requested the bill and County officials had not
followed-up to ensure that a copy of the bill was obtained or request that the
unsupported moving expense be reimbursed. Nevertheless, County officials did
provide a copy of the bill at the exit conference.
Grants Awarded for Ineligible
Purposes
Essex County’s subrecipient disbursed $43,833 for ineligible HPRP costs. This
deficiency occurred because County officials did not properly monitor the
County’s subrecipient nor ensure that subrecipient staff was adequately trained.
As noted below, the ineligible funds were disbursed for either participants who
were ineligible for the benefit received or for ineligible expenses.
Ineligible Use of HPRP Funds Number of Cost
Participants
Assistance to ineligible HPRP participants 11 $34,783
Payment to landlords and management
companies for their legal and court fees 21 $6,068
Payment of recurring rental assistance for more
than 3 months without recertifying the 3 $1,657
participants
Payment of recurring rental assistance to HPRP
participants who were receiving housing 3 $1,325
assistance from other housing programs for the
same period and the same type of cost
Total Ineligible Cost 371 $43,833
HPRP participants were determined to be ineligible because the file did not
comply with program requirements published in HUD Federal Register Notice
FR-5307-N-01 and/or the HUD HPRP Eligibility Determination and
Documentation Guidance (see Appendix C) for one of the following reasons: (1)
annual income exceeded 50 percent of the area median income for a household
with a comparable number of household members, (2) participant applied for and
received utility assistance by using a utility bill, dated 1 year prior to the
1
Total does not add because one participant received benefits for ineligible legal fees incurred by a landlord and
ineligible recurring rental assistance.
7
participant’s application date, or (3) a utility shutoff notice was not included on
the utility bill used to qualify the participant for utility assistance.
Grant Awards Inadequately
Supported
Essex County officials disbursed $141,260 on behalf of 38 participants whose
eligibility was inadequately supported. This condition occurred because County
officials did not properly monitor the subrecipient or ensure that subrecipient staff
was adequately trained. The eligibility of the 382 participants was determined to
be unsupported because file documentation did not comply with HUD Federal
Register Notice FR-5307-N-01 and/or the HUD HPRP Eligibility Determination
and Documentation Guidance (see Appendix C) for the following reasons:
17 cases - Lack of documents to support that utility assistance
provided was related to a utility balance that was not greater than 6
months in arrears.
14 cases – No bank statements to support those participants did not
have other financial resources, while documents in the files indicated
that the participants had bank accounts.
9 cases – No lease agreement for the assisted units.
9 cases – Lack of documents or notes to support that participants with
minor children did not have income from child support.
7 cases – Lack of a completed and signed declaration form for
household members older than 18 and evidence that they were full
time students.
4 cases – Lack of lease agreements or participants’ self certification
when the participants were evicted from houses or apartments rented
by participants’ friends or relatives.
4 cases - An eviction notice, a lease agreement, or an HPRP
application was provided that included individuals who, along with
any potential income, were not included when determining eligibility.
4 cases - Included utility assistance for utility charges that were based
on estimated utility consumption rather than actual consumption.
2
The deficiencies are not independent of one another; each of the 38 participant files exhibited one or more of the
reasons for which they were determined to be unsupported.
8
3 cases – Lack of documents or notes to explain significant
drawdowns listed on participants’ bank statements.
1 case - No eviction notice to support that the participant was being
evicted.
1 case - No documents or notes to support that the participant was at
risk of becoming homeless.
Grant Awards Did Not always
Comply with Administrative
Requirements
Review of the sampled HPRP participants’ case files and discussion with
subrecipient staff disclosed that the subrecipient did not always comply with
HUD HPRP Eligibility Determination and Documentation Guidance (see
Appendix C) because they did not always (1) conduct an initial consultation with
each HPRP participant, (2) evaluate whether each HPRP participant had other
financial resources and other housing options, (3) conduct a habitability
inspection for all HPRP-assisted units when required, (4) conduct a lead based
paint assessment for all HPRP-assisted units when required, (5) conduct rent
reasonableness analysis when required, (6) have information related to
participants’ housing status after HPRP housing assistance ended, and (7) obtain
and maintain documents to support that paid utility assistance was not greater than
6 months in arrears. Further, 34 of the 62 HPRP participants’ case files included
subrecipient staff self-certification forms that were not signed by a staffmember
or a staff supervisor, and 6 lacked a signed subrecipient staff self-certification
form. These deficiencies occurred because (1) Essex County officials did not
properly monitor the subrecipient to ensure that the subrecipient administered the
County’s HPRP in accordance with the HPRP program requirements and (2)
subrecipient officials were not experienced or trained to administer the County’s
HPRP program.
Conclusion
Essex County officials ensured that HPRP funds were obligated and expended
within prescribed timeframes; however, they had not established adequate
controls to ensure that their HPRP was administered in accordance with program
requirements. We attribute these conditions to Essex County and subrecipient
officials’ unfamiliarity with program requirements. Consequently, the County’s
subrecipient expended at least $43,833 contrary to program requirements,
disbursed $141,260 on behalf of recipients whose eligibility was not adequately
supported, and awarded grants that did not always comply with administrative
9
requirements. As a result, Essex County officials cannot adequately assure HUD
that HPRP funds were expended in accordance with HPRP requirements.
Recommendations
We recommend that the Director of the New Jersey Office of Community Planning
and Development instruct County Officials to
1A. Reimburse the $43,833 awarded for ineligible costs to the HPRP line of
credit.
1B. Provide adequate documentation for the $141,260 disbursed on behalf of the
38 participants whose eligibility was unsupported, and if adequate
documentation is not provided, reimburse the HPRP line of credit from
nonfederal funds.
1C. Develop procedures that will ensure that adequate subrecipient monitoring is
established before administrating similar HUD-funded programs.
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SCOPE AND METHODOLOGY
The audit focused on whether Essex County officials administered the County’s HPRP in
compliance with HPRP program requirements.
To accomplish our objectives, we
Reviewed relevant HPRP program requirements and applicable Federal regulations.
Interviewed staff from the HUD New Jersey Office of Community Planning and
Development, Essex County Division of Housing and Community Development
(grantee), and the Division of Training and Employment (subrecipient).
Obtained an understanding of the County’s management controls and procedures through
analyzing the grantee’s responses to internal control questionnaires, and reviewing the
County’ audited financial statements for fiscal year 2009.
Analyzed reports from HUD’s computer systems, including the Integrated Disbursement
and Information System, and Line of Credit Control System. Assessment of the
reliability of the data in these systems was limited to the data sampled, which was
reconciled to the County’s records.
Reviewed Essex County’ substantial amendment to its program year 2008 Action Plan.
Reviewed Essex County’s HPRP and its accounting policy.
Reviewed the HPRP subrecipient agreement between the County and its subrecipient.
Reviewed County monitoring reports of its subrecipient.
Reviewed documents such as purchase requisitions, purchase orders, landlords’ bills, and
cancelled checks to support disbursements associated with 87 HPRP case files sampled.
Selected a statistical sample of 62 HPRP participant files from the universe of 635 HPRP
participants based on a 90 percent confidence level, 50 percent estimated error rate, and
precision of plus or minus 10 percent to determine whether HPRP participants were
certified in accordance with the HPRP requirements. The results of reviewing the 62
HPRP participants’ case files revealed that 61.28 percent or 38 HPRP participants, were
either ineligible to receive HPRP assistance or their eligibility to receive HPRP assistance
was inadequately supported.
11
Reviewed an additional 25 participant files to follow-up on issues raised through
analytical procedures that identified risk factors, such as potential duplicate addresses or
names and significant reported monthly income by HPRP participants.
The audit generally covered the period October 1, 2009, through December 31, 2010, and was
extended as needed to accomplish the objectives. We performed the audit fieldwork from March
through June 2011 at the County Division of Housing and Community Development and the
Division of Training and Employment.
We conducted the audit in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective.
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INTERNAL CONTROLS
Internal control is a process adopted by those charged with governance and management,
designed to provide reasonable assurance about the achievement of the organization’s mission,
goals, and objectives with regard to
Effectiveness and efficiency of operations,
Reliability of financial reporting, and
Compliance with applicable laws and regulations.
Internal controls comprise the plans, policies, methods, and procedures used to meet the
organization’s mission, goals, and objectives. Internal controls include the processes and
procedures for planning, organizing, directing, and controlling program operations as well as the
systems for measuring, reporting, and monitoring program performance.
Relevant Internal Controls
We determined that the following internal controls were relevant to our audit
objective:
Program operations – Policies and procedures that management has
implemented to reasonably ensure that a program meets its objectives.
Compliance with laws and regulations – Policies and procedures that
management has implemented to reasonably ensure that resource use is
consistent with laws and regulations.
Safeguarding resources – Policies and procedures that management has
implemented to reasonably ensure that resources are safeguarded against
waste, loss, and misuse.
Validity and reliability of data – Policies and procedures that management
has implemented to reasonably ensure that valid and reliable data are
obtained, maintained, and fairly disclosed in reports.
We assessed the relevant controls identified above.
A deficiency in internal control exists when the design or operation of a control does
not allow management or employees, in the normal course of performing their
assigned functions, the reasonable opportunity to prevent, detect, or correct (1)
impairments to the effectiveness or efficiency of operations, (2) misstatements in
financial or performance information, or (3) violations of laws and regulations on a
timely basis.
13
Significant Deficiency
Based on the review, we believe the following items are significant deficiencies:
Essex County officials had not established and implemented adequate policies and
procedures to ensure:
Compliance with laws and regulations when they did not conduct quarterly
on-site monitoring of the County’s subrecipient and ensure that its
subrecipient implemented corrective action to address deficiencies disclosed
during the County’s monitoring of its subrecipient’s administration of the
County’s HPRP (see finding).
That resources were safeguarded when their subrecipient disbursed HPRP
funds on ineligible program costs and for participants whose eligibility was
not adequately supported (see finding).
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APPENDIXES
Appendix A
SCHEDULE OF QUESTIONED COSTS
Recommendation
number Ineligible 1/ Unsupported 2/
1A $43,833
1B $141,260
Total $43,833 $141,260
1/ Ineligible costs charged to a HUD-financed or HUD-insured program or activity that the
auditor believes are not allowable by law; contract; or Federal, State, or local policies or
regulations.
2/ Unsupported costs are those costs charged to a HUD-financed or HUD-insured program
or activity when we cannot determine eligibility at the time of the audit. Unsupported
costs require a decision by HUD program officials. This decision, in addition to
obtaining supporting documentation, might involve a legal interpretation or clarification
of departmental policies and procedures.
15
Appendix B
AUDITEE COMMENTS AND OIG’S EVALUATION
Ref to OIG Evaluation Auditee Comments
16
Ref to OIG Evaluation Auditee Comments
Comment 1
Comment 2
Comment 3
Comment 4
Comment 5
Comment 6
Comment 7
17
OIG Evaluation of Auditee Comments
Comment 1 County officials stated that they did not detect any concern on the part of the
subrecipient in its ability to administer the program during its monitoring visits
and phone conversations. However, our review of the County monitoring reports
noted that the reports identified deficiencies with subrecipient files and that
County officials had not performed follow-up to ensure that correction action was
taken. Further, OIG’s review of case files reviewed by County officials revealed
noncompliance issues that were not noted by the County.
Comment 2 As agreed, County officials should have conducted quarterly monitoring visits in
compliance with its substantial amendment to its year 2008 Action Plan.
Comment 3 HUD used the Homeless Resource Exchange (HUDHRE.INFO) to disseminate
program requirements, policy updates and answers to frequently asked questions.
Comment 4 At the exit conference County officials provided a copy of the invoice to support
$590 in moving expenses; consequently, we adjusted the report to note that this
expense was properly supported.
Comment 5 County officials stated that the fees cited in the report ($6,068) were court ordered
and if not paid the tenants would have literally become homeless. The County
believes that these costs should not be disallowed since the subrecipient properly
applied the criteria found in the HUD issued Eligibility Determinations and
Documentation guidelines, which states “subgrantees must assess and document
whether the household would become literally homeless “but for” HPRP
assistance”. The “but for” criteria applies to determining whether an individual is
eligible for HPRP assistance, and then determinations must be made as to the
types of eligible costs for which assistance would be provided. The HPRP notice-
(Part IV.A.2.d) provided that HPRP funds may be used for legal service to assist
program participants with legal advice and presentation in administrative or court
proceeding related to tenant or landlord or housing issues, but not for legal fees
incurred by landlords.
Comment 6 During the audit and at a pre-exit conference, subrecipient officials were provided
the applicable citations used to determine that the $37,765 was ineligible, and the
applicable citations are included in appendix C of the draft audit report, which
was provided to the grantee and the subgrantee prior to the exit conference.
Comment 7 County officials stated that the County will continue to work with the subrecipient
to provide documentation to support the $141,260. As such, this documentation
should be provided to the HUD field office as part of the audit resolution process.
18
Appendix C
CRITERIA
A. HUD Federal Register Notice FR-5307-N-01, effective March 19, 2009, outlined the
allocation formula and amounts, the list of grantees, and requirements for HPRP.
The notice included the following:
While HUD will allow grantees the discretion to develop prevention or rapid rehousing
programs that meet locally defined needs, HUD also expects that these resources will be
targeted and prioritized to serve households that are most in need of this temporary
assistance and are most likely to achieve stable housing, whether subsidized or
unsubsidized, outside HPRP after the program concludes. (Part I.A.)
To receive HPRP-funded financial assistance or housing relocation and stabilization
services, a household must meet at least the following minimum criteria:
1. Applying households must receive at least an initial consultation and eligibility
assessment with a case manager or other authorized representative who can determine
eligibility and the appropriate type of assistance needed. (Part IV.D2.1)
2. The household’s total income must be at or below 50 percent of area median income.
(Part IV.D2.2)
3. The household must be either homeless (to receive rapid rehousing assistance) or at
risk of losing its housing (to receive homelessness prevention assistance) and meet both
of the following circumstances: (1) no appropriate subsequent housing options have been
identified, and (2) the household lacks the financial resources to obtain immediate
housing or remain in its existing housing. (Part IV.D2.3)
After 3 months, if program participants receiving short-term rental assistance need
additional financial assistance to remain housed, they must be evaluated for eligibility to
receive up to 15 additional months of medium-term rental assistance, for a total of 18
months. HUD is requiring grantees and subgrantees to certify eligibility at least once
every 3 months for all program participants receiving medium-term rental
assistance.(Part IV.A.1.a(1)
Rental assistance payments cannot be made on behalf of eligible individuals or families
for the same period and for the same cost types that are being provided through another
Federal, State, or local housing subsidy program. (Part IV.A.1.a(5))
HPRP funds may be used for up to 18 months of utility payments, including up to 6
months of utility payments in arrears, for each program participant, provided that the
program participant or a member of his or her household has an account in his or her
name with a utility company or proof of responsibility for making utility payments, such
as cancelled checks or receipts in his or her name from a utility company. (Part IV.A.1.c)
19
HPRP funds may be used for legal services to help people stay in their homes, such as
services or activities provided by a lawyer or other person(s) under the supervision of a
lawyer to assist program participants with legal advice and representation in
administrative or court proceedings related to tenant or landlord matters or housing
issues. (Part IV.A.2.d)
The rental assistance paid cannot exceed the actual rental cost, which must comply with
HUD’s standard of “rent reasonableness.” “Rent reasonableness” means that the total
rent charged for a unit must be reasonable in relation to the rents being charged during
the same period for comparable units in the private unassisted market and must not
exceed rents being charged by the owner during the same period for comparable
nonluxury unassisted units. To make this determination, the grantee or subgrantee should
consider (1) the location, quality, size, type, and age of the unit and (2) any amenities,
housing services, maintenance, and utilities to be provided by the owner. Comparable
rents can be checked by using a market study, by reviewing comparable units advertised
for rent, or with a note from the property owner verifying the comparability of rents
charged for other units owned (for example, the landlord would document the rents paid
in other units). (Part IV.A.3)
Grantees are responsible for ensuring that HPRP amounts are administered in accordance
with the requirements of this notice and other applicable laws. Each grantee is
responsible for ensuring that its subgrantees carry out the HPRP-eligible activities in
compliance with all applicable requirements. (Part V.F.)
Based on lead-based paint requirements, a lead-based paint visual assessment must be
completed for all units that meet the three following conditions: (1) the household living
in the unit is being assisted with HPRP financial assistance (rent assistance, utilities
assistance, utility or security deposits, or arrears), the unit was constructed before 1978,
and a child under the age of 6 is or will be living in the unit. (Part VI.F.)
Organizations providing rental assistance with HPRP funds will be required to conduct
initial and appropriate follow-up inspections of housing units into which a program
participant will be moving. Units should be inspected annually and upon a change of
tenancy. (Part VII.C.)
B. HUD HPRP Eligibility Determination and Documentation Guidance, Revised
March 17, 2010:
A staff certification of eligibility form must be completed for each household deemed
eligible for HPRP assistance certifying that the household meets all eligibility criteria for
HPRP assistance, that true and complete information was used to determine eligibility,
and that no conflict of interest exists related to the provision of HPRP assistance. The
form must be completed and signed by the person determining eligibility and his or her
supervisor for all households determined eligible or recertified on or after November 1,
2009. (Section 2, Assessment, p.4)
20
Documentation requirements for persons at risk of homelessness require that a copy of an
eviction notice from the landlord/property manager of the unit or a court order based on
eviction action that notifies the applicant that he or she must leave and a copy of the lease
naming the applicant as the leaseholder must be in the file. If the lessor is a family or
friend, a copy of an eviction notice from that party notifying the applicant that he or she
must leave and a copy of the lease naming the host family/friend as the leaseholder must
be in the file. (Section 5, Documentation, p.16-17)
Documentation requirements for persons at risk of potential loss of housing due to utility
non-payment include a copy of a utility shut-off notice from the utility company. (Section
5, Documentation, p.16)
In evaluating each HPRP participant’s other financial resources, an assessment form or
other documentation must
1. Be documented by an HPRP case manager or other authorized existing housing staff,
2. Include a review of current account balances in the checking and saving account held
by the applicant household,
3. Include an assessment summary or other statement indicating that the applicant lacks
financial resources and support networks to obtain other appropriate subsequent
housing or remain in current housing, and
4. Be signed and dated by an HPRP case manager or other authorized HPRP staff.
(Section 5, Documentation, p.20)
21
Weaknesses Existed in Essex County, NJ's Administration of Its Homelessness Prevention and Rapid Re-Housing Program
Published by the Department of Housing and Urban Development, Office of Inspector General on 2011-09-20.
Below is a raw (and likely hideous) rendition of the original report. (PDF)