HUD AAQ# 87377: Equal Access + Fair Housing + Housing First

Question Response for CoC Question ID 87377 - HUD Exchange Ask A Question


Question Related To: Continuum of Care Program

Question ID: 87377

Question Subject: Equal Access + Fair Housing + Housing First

Question Text:
  • Fair Housing + Equal Access
    • QUESTION #1: If a CoC has a Coordinated Entry system where a call center screens all homeless services calls to place them into the appropriate project and program (ES, TH, RRH, PSH, Shelter Diversion, etc.) where some of the projects may only serve certain population/household types, but the CoC has plenty of projects to serve the needs of all population/household types, is this considered to be in compliance with Fair Housing in regards to non-discriminatory practices? 
    • DETAIL: For example, a CoC may have seven ES projects where one of the projects may serve only single adult males, but the other six projects fulfill the needs of all other population/household types.  This pertains to a non-federally funded ES project.
  • Housing First + Equal Access
    • QUESTION #2: (similar to question above) If a CoC has a Coordinated Entry system where a call center screens all homeless services calls to place them into the appropriate project and program (ES, TH, RRH, PSH, Shelter Diversion, etc.) where some of the projects may only serve certain population/household types, but the CoC has plenty of projects to serve the needs of all population/household types, is this considered to be in compliance with Housing First and Fair Housing?  
    • DETAIL: For example, a CoC may have twelve PSH projects where one of the projects may serve only chronically homeless single females with age of 55+, but the other projects fulfill the needs of all other population/household types.  This pertains to a COC funded project, but we would also like to know if this applies to non-federally funded projects, as well.
Response:
Thank you for your question. The questions you pose are fairly general, and whether or not those placements are allowed will depend on the circumstances. Regarding the specific examples you provided, we can give some clarity, and also some contextual information. 

Coordinated entry processes need to follow their own non-discriminatory requirements, including ensuring full access, standardized assessments, and referrals that do not exclude persons on the basis of any protected classes or any persons on the basis of sexual orientation, gender identity or marital status. 

HUD encourages the CoC to work with providers to be sure they understand Fair Housing and civil rights law requirements, and that all shelter and housing is equally available to all, unless there is a statutorily approved limitation on the shelter or housing. Operators of the coordinated entry are not expected to be able to evaluate whether or not a project is compliant with fair housing and civil rights requirements. Some violations are easily spotted, such as operating single sex housing when it doesn't meet the criteria to do so, but other violations might not be so obvious and might require a little bit of research.

For those shelter and housing projects that are funded by CoC or ESG Program funding, they must follow all applicable fair housing and civil rights requirements, e.g., only operating as single-sex when a facility meets the exemption criteria to do so. The examples provided don't give enough information to know if they're out of compliance or not. It is possible to have single sex emergency shelter if it meets the criteria to do so, and it is possible to have housing limited to individuals over 55 if it meets the criteria to do so. 

Here's a bit more detail on limiting projects to single sex:

The designation of "single sex" is intended for structures that prevent personal privacy, so if residents have both private bedrooms and access to a bathroom in which they are the only occupant, there is not a prevention of personal privacy in these spaces. 

Single-sex facilities may be acceptable, but only under certain limited conditions. 
  • The facility must be for individuals only. A facility that accepts families with children cannot be single sex. An example of this might be a shelter that serves single women only (women not in families, without children under 18); AND
  • The facility must not be considered a "dwelling unit" or it must have a shared bathing facility. This policy is stated most clearly in the CoC interim rule, at §578.93 (pgs 38-40,104-105): "The housing may be limited to one sex where such housing consists of a single structure with shared bedrooms or bathing facilities such that the considerations of personal privacy and the physical limitations of the configuration of the housing make it appropriate for the housing to be limited to one sex."

NHSDC Preliminary Agenda



NHSDC Preliminary Agenda!
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NHSDC


Check it out!

Here is the Preliminary Agenda for the Spring 2017 NHSDC conference. The final agenda will be released in the next few weeks.

We are pleased to announce our pre-conference, Data Quality Institute! The Institute will take place from 1:00pm to 5:00pm on April 25, 2017. It is split into three segments: 1) Introducing the HMIS Data Quality Framework; 2) Reducing Data Quality Impacts on System Performance Measures; and 3) Building a Data Quality Management Program. Attendees are encouraged to bring their Data Quality Plans, System Performance Measures, and local Data Quality reports. Register soon as space is limited.

Please register here to join us in Salt Lake City, April 26-27 to hear how communities across the country are Putting It All Together: Uniting Data, Technology, and People.

Rooms are still available at the conference rate of $165, make your online reservation here.
We look forward to seeing you in April!

SSVF Program Update February 24, 2017 (Please Read)



Hi Team,

I hope that you had a great weekend. Please find the most recent SSVF Program Update. As always, I need you to read this information in detail. I am going to highlight a few items; however, this should not replace your very thorough read of the information in the Update.

Program Change Requests Due this Week
·         Program Change Requests are due on Wednesday, March 1st.
·         Late submissions will not be accepted.
·         The Companion Guide to Program Changes can be found: https://www.va.gov/homeless/ssvf/?page=/official_guide/reporting_and_monitoring_requirements   (Under the last blue rectangle called "SSVF Online Grants Management System-GIFTS", 5th bullet)
·         The Program Update below reviews some common mistakes. Please pay close attention to this information and to your submission.
·         Incomplete and/or incorrect submissions will be rejected.
·         If you have any questions at all, please feel free to reach out to me today or tomorrow via email.


SSVF National Webinar-Thursday, March 9th
·         Please save the date for the SSVF national webinar next Thursday, March 9th.
·         The registration link will be sent later this week.

Mandatory Return of Funds
·         This is very important. We reviewed it on the national call on 2/9, and our regional call on 2/14, but I need every grantee and every grantee's financial team to understand.
·         Please share it with your finance team and include it in your regular, planned, strategic discussions between your program and financial teams.
·         If you have questions, please email ssvf@va.gov and cc me. Please include "Mandatory Return of Funds Question and your grant number" in the subject of the email.

Thanks so much!

Adrienne



Adrienne Nash Melendez, MLD
Regional Coordinator
U.S. Department of Veterans Affairs
267-683-2386

-----Original Message-----
From: SSVF Program Office [mailto:mail@grantapplication.com]
Sent: Friday, February 24, 2017 7:12 PM
To: ssmithson@cssalaska.org
Subject: [EXTERNAL] SSVF Program Update February 24, 2017


Topics:

1.            SSVF Program Change Requests: Due March 1, 2017
2.            SAVE THE DATE!  SSVF National Webinar on March 9, 2017 at 2PM EDT
3.            NOTICE: Independent Audit Solicitations
4.            REMINDER: Mandatory Return of SSVF Grant Funds
5.            REMINDER: Regional Meeting Travel Expense Guidance
6.            REMINDER: SSVF Participant Telephone Survey Update


SSVF Program Change Requests: Due March 1, 2017
This is a reminder that the deadline for submitting program change requests to the SSVF Program Office is 3/1/2017.  The requests must be submitted using the SSVF online grants management system.  Grantees can access the Program Change Form on the "Requirements" tab of their grant account.  Please note that the form will be inactive after the deadline.  Therefore, SSVF is unable to accept submissions after this point. 

Remember, avoid the common mistakes! 
·         Submit the necessary attachments. 
·         Ensure that explanations for budget modifications are sufficient. 
·         Verify that the total amount of the grant award equals the awarded amount from the VA, if there are adjustments to the HHS subaccount balances. 

If Program Change Request does not contain sufficient information, the request will be denied by the Program Office.

SAVE THE DATE!  SSVF National Webinar on March 9, 2017 at 2PM EDT

Topic:  SSVF National Updates

The SSVF National Grantee Webinar will review the key Program Updates.   A registration link will be provided.

NOTICE: Independent Audit Solicitations

It has come to the attention of the SSVF Program Office that Best Value Technologies, Inc (BVT) has been contacting SSVF grantees to solicit business for agencies required to have an annual independent audit.   This organization is not affiliated in any way with the SSVF Program Office and we do not recommend, endorse or suggest that your agency utilize this agency.  Your agency should follow the established guidelines in 2 CFR 200 when determining if an independent audit is required, along with the requirements and qualifications of the selected independent auditor.  Please remember that any official oversight, monitoring or auditing requirements will come directly from the SSVF Program Office.  If you have any questions please email ssvf@va.gov

REMINDER: Mandatory Return of SSVF Grant Funds

During the current grant year, FY 2017, the SSVF Program Office is implementing the mandatory return of unspent grant funds. Per the grant agreement between VA and SSVF grantees, the SSVF Program Office will recoup funds from grantees who are not meeting the minimum expenditure rates.  This is the first year mandatory returns will be implemented.  The grant agreement (MOA) describes that, after each quarter, grantees are required to have a minimum percentage of funds drawn from the HHS Payment Management System; 1st quarter – 15% or more; 2nd quarter – 40% or more; 3rd quarter – 65% or more.  The SSVF Program Office is currently developing the procedures for how this will be completed and will inform grantees as soon as possible.  In the meantime, please review your grant expenditures and your projected spending for the remainder of the grant year. The first mandatory return of funds will take place immediately following the end of the 2nd quarter (April). If you have questions about this new process for FY2017, please contact the SSVF Program Office at ssvf@va.gov


REMINDER:  SSVF Regional Meeting Travel Expense Guidance

SSVF grantees should not be using grant funds to pay for VA staff travel. In order to attend any SSVF supported training, VA staff must go through the appropriate VA approval process. SSVF grantees can continue to support the travel of key stakeholders, such as CoC leads, when the SSVF program office has indicated that their attendance at a SSVF sponsored event in permitted. If you have any questions, please contact your Regional Coordinator or email SSVF@VA.gov.

REMINDER:  SSVF Participant Telephone Survey Update

As of 1/3/17, if Veterans are unable to take the SSVF Participant Survey via internet or smart phone, they have the opportunity to take the survey over the telephone with a live interviewer.  All Veterans still need to be registered within 30 days of exit using your organization's link.  When you register a Veteran, you will receive a unique registration number for each Veteran.  This number should be given to the Veteran if he/she plans to take the survey by phone.  When the Veteran calls, he/she will be asked for this unique registration number that will allow the survey response to be linked to your organization.  The Veteran ID # presented on the webinar slide was only an example.  DO NOT GIVE THIS NUMBER TO VETERANS.   Again, each Veteran will have a unique registration number created at the time they are registered into the survey system.

Questions regarding the SSVF Participant Surveys should be sent to vassvf@mdavisco.com or call 215-790-8900 ext. 132 (staff will respond within 24 hours).   If you need to leave a message, someone will return your call by the next business day.



Thank you,

SSVF Program Office

NOTE:  If you are receiving this email in error, please disregard.  We request your patience as the SSVF Program Office continues to address system issues with the grants management database.