Berkeley City Council
May 9, 2023

City of Berkeley ESG Policies and Procedures
ESG Manual and Forms – Berkeley

8.9 INTERIOR AIR QUALITY
Is the unit free from abnormally high levels of
air pollution from vehicular exhaust, sewer
gas, fuel gas, dust, or other pollutants?

8.10 SITE AND NEIGHBORHOOD

CONDITIONS
Are the site and immediate neighborhood free

8.11 LEAD PAINT: OWNER CERTIFICATION
If the owner of the unit is required to treat or
cover any interior or exterior
surfaces, has the certification of

Not Applicable

9. MISCELLANEOUS DECISION

Item #

Description
Yes,
PASS
No,
FAIL Repairs Required

9.1 Is there sufficient sleeping place for each
individual?

9.2 Is there adequate natural or artificial
illumination to permit activities in the
home?

9.3 Is home and equipment maintained
in a sanitary condition?

Summary of Repairs Needed:

Item Number: Repair Needed:

Owner/Manager’s Signature:

City of Berkeley ESG Policies and Procedures
ESG Manual and Forms – Berkeley

Rental Assistance Agreement Letter
(click here to return to relevant section of the manual)

(date)

(landlord address)

(Head of Household) has been approved to receive temporary financial assistance through the Emergency Solutions Grant program. The program is designed to help the participant secure and/or retain housing and be a successful tenant. Our agency will maintain regular contact during his/her time in t he program to assist him/her with any problems related to his/her housing or tenancy. The program does not, however, assume any responsibility for the tenant’s rent or for compliance with the lease. The tenant is fully responsible for complying with the terms of the lease he/she has with you.

The person named above has been approved for assistance with (check all that apply):
 A rental deposit in the amount of $
 A short-term rent subsidy in the amount of$ (currently approved until

date. This subsidy may be extended at the program’s discretion)  Assistance with past due rent in the amount of $

All other payments under the terms of the lease are the responsibility of the tenant.

[Name of Housing Agency] , will provide the above housing assistance payments to you beginning [date].

By signing below, you agree to apply all payments you receive on the tenant’s behalf toward the specified housing -related costs on the check. The termination of housing assistance payments shall not affect the household's other rights under the lease.

The tenant is required to notify us if he or she moves; however, if you ever receive a subsidy check for a tenant who has mov ed, it is your responsibility to return the check to us. Financial assistance from this program can only be used toward the housing - related costs of the tenant named above while he/she resides in your housing. You also must notify us if during the term of t his agreement you notify the tenant to vacate or if you lodge any complaint under state or local law to commence an eviction.

You are welcome to contact me if you have any questions or concerns regarding the program or this tenant’s housing. [name, title at 510 XXX-XXXX or housing specialist @ agency.org]. Thank you for working with us.

Sincerely,

I have read this agreement and I agree to accept payments on behalf of the tenant listed above as described in this letter. I have provided a W-9 form to the agency.

Property Owner/Property Manager Name:

Signature: Date:

City of Berkeley ESG Policies and Procedures
May 12, 2020

FRHP
City of Berkeley ESG Policies and Procedures
May 12, 2020
Three Month Reassessment of Eligibility
(click here to return to relevant section of the manual) Reassessment Date: / /
Staff Name: Agency:

Program: ESG Other:

Before beginning this Reassessment form, collect copies of updated income documentation for the household.

Has there been a change in address or phone since the last assessment?  No Change
 Address and/or phone has changed; new information below (Enter into HMIS Housing Sub- assessment) Current STREET Address: Apartment or Unit Number:

City: State: Zip:

Phone Number: Alternate Phone:

Start Date (Date moved into Permanent Housing) / /
a) Total Household Members living/will live at this address:
b) Total ADULTS living/will live at this address: _
c) Total CHILDREN living/will live at this address (NOTE: a – b = c)

Time in Program
Has household a) received 24 months of ESG assistance in last 36 months or b) exceeded other program time limits?  Yes
If household has exceeded eligible time in program, record the determination below, and complete the HMIS Exit Form for all adults.

Income Status Eligibility (Complete the income reassessment form attached for each adult and enter into HMIS) What is the total gross household monthly income (include all household members)? $ What is the total gross household annual income? $ (monthly amount x 12) Using the chart below, circle the household size and determine the percent of Area Median Income (AMI)

No
Head of Household Name:

Service Point ID:

City of Berkeley ESG Policies and Procedures
May 12, 2020

Household Size 1 2 3 4 5 6
30% AMI $26,050 $29,750 $33,450 $37,150 $40,150 $43,100 31-50% AMI $43,400 $49,600 $55,800 $61,950 $66,950 $71,900

AMI information current as of 2019

Please check the household’s current income status AND the documentation attached

 No Income
□ 1-30% AMI
□ 31-50% AMI
□ Over 50% AMI
Copy of Payment
Statement / Benefit
Notice
 Alimony, spousal
or child support
 GA, SSI, SSDI, or
TANF
 Private Disability
 Pension /
Retirement
 Unemployment
or Workers’
Comp
 Interest /
Dividend Income

Copy of Pay Stubs

 Earned Income
Copy of Federal or
State Tax Return

Self-Employment
Income Self-
Certification
 No Income

City of Berkeley ESG Policies and Procedures
May 12, 2020
ESG Manual and Forms – Berkeley

If household has income greater than 30% of Median Income for the ESG program, or greater than 50% of AMI for the PRCS or FRHP program, discontinue assistance. Record the determination below, and complete the Exit Form for all adults.

Is household receiving now or going to begin to receive a housing subsidy from another program?  Yes
Subsidy: Start date: / /
No

City of Berkeley ESG Policies and Procedures
May 12, 2020
ESG Manual and Forms – Berkeley

If household receives another subsidy, household is not eligible for continued financial assistance at the same time.

Household may continue to receive supportive services if needed to prevent homelessness. Skip to Housing Stability Plan Progress.

Rent as Portion of Income
Is the household receiving Financial Assistance to remain housed? Yes No
What is the TOTAL monthly rent? (the total rent, not the portion currently paid by tenant) Rent to Income ratio:

Total Monthly Rent ( ) X 100 = %
Gross Monthly Household Income ( )

Housing Stability Plan Progress
Progress toward Obtaining or Maintaining Appropriate Housing:
 Achieved and Complete Making adequate progress Not making adequate progress

Progress toward Income or Employment Goals:

Progress toward Other Stability Goals:
 Achieved and Complete Making adequate progress Not making adequate progress Does Not Apply Comments on Plan Progress, Accomplishments and Barriers:

Does household have financial resources and/or support networks that can help them gain/remain in housing?

If household has other resources or support networks that can help them gain or remain in housing that are adequate to secure their housing, discontinue assistance. Record the determination below, and complete the HMIS Exit Form for all adults.
 Achieved and Complete
Making adequate progress
Not making adequate progress
Does Not Apply

City of Berkeley ESG Policies and Procedures
May 12, 2020
ESG Manual and Forms – Berkeley

RESULT OF REASSESSMENT:

Discontinuing Program Assistance:

 Received maximum permitted assistance
Over Income
Below targeted rent to
Receiving housing income ratio and does not subsidy and does not require services.  Completed Housing Stability Plan Goals
 Has other resources

Continuing Assistance:
 Continue housing stability if income has changed
 Continue financial assistance, revise/update housing stabilization plan and prepare new budget  New Budget (if applicable)

Attached:
 Revised Housing Stability Plan

After completing the reassessment of eligibility, I have been informed that I/my household am/are eligible for continued assistance from this program. I understand that my participation agreement remains in force and that a new stability plan, budget and financial contribution may be required. I understand that I will be reassessed again within three months or less and that assistance may be discontinued at any time.

Head of Household Signature: Date:

Staff member signature: Date:

City of Berkeley ESG Policies and Procedures
May 12, 2020
ESG Manual and Forms – Berkeley

Assessment Date: / / (Forbackdatemode) ServicePoint ID# Program/Provider: _

Client Profile
First: Middle: Last: Suffix:

Monthly Income
Have you received income from any source in
the past 30 days?
 No Yes
 Don’t Know Refused
Non-Cash Benefits
Have you received any of the non-cash benefits listed
below in the past 30 days?
 No Yes
 Don’t Know Refused
Source Monthly
Amount
 Alimony or other spousal support $ .00

 Child support $ .00

 Earned Income $ .00
 General Assistance (GA) $ .00
 Pension from a former job $ .00

 Private disability insurance $ . 00
 Social Security (retirement income) $ .00
 Social Security Disability Income $
.00 (SSDI)
 Supplemental Security Income or SSI $ .00
 (TANF) Temporary Assistance for $
.00 Needy Families
 Unemployment Insurance $ .00
 A veteran’s disability payment $ .00
Source
 Supplemental Nutrition Assistance Program
(SNAP) (Previously known as Food
Stamps)
 MediCAL health
insurance program
(MEDICAID)
 MEDICARE health insurance program
 Healthy Families Insurance program (SCHIP)
 Special Supplemental Nutrition Program
for Women, Infants, and Children
(WIC)
 Veteran’s Administration (VA)Medical Services
 TANF/CalWORKS Child Care services
 TANF/CalWORKS transportation services

 Other TANF/ CalWORKS-funded services
 Section 8, public housing, or other
rental assistance

 Other source
 Temporary Rental Assistance

Total monthly income $ .00

Complete one income reassessment for each adult in the household and combine for total household income for program reassessment purposes.

3 MO. INCOMEREASSESSMENT FORM

City of Berkeley ESG Policies and Procedures
May 12, 2020
ESG Manual and Forms – Berkeley

Notification of Termination of ESG Assistance
(click here to return to relevant section of the manual)

You/your household has violated the terms of your ESG Participation Agreement, signed by on (date.) The program violation(s) consist of

.

The program is hereby advising you that as no further
of _/
/

 financial assistance
 housing stabilization services

Will be provided to you/your household.

You/your household will be solely responsible for covering all housing/utility costs as of that date.

(Staff signature) (Date)

I have reviewed and authorized this notification:

(Supervisor signature and date)

Procedure for due process: If you disagree with this determination, you may request a review of this decision within 10 days of the date of this notice by making a request in writing* to:

{Job title}
{Address}
{Address}

The {job title} will review your request and may investigate your claims, ask to interview you, members of your household, your landlord, or call a hearing with yourself, agency staff and any others that may be needed to review this decision. The {job title} must review your request and make a final determination within 14 calendar days. A written notice of the final decision will be provided to you.

*Reasonable accommodation: If you are unable to prepare a request in writing due to a disability and need a reasonable accommodation, you may request a specific accommodation, such as assistance in preparing the request, from the program manager or another staff member.

City of Berkeley ESG Policies and Procedures
May 12, 2020

Appendix Part III: Monitoring of Subrecipients

1. General Information
City of Berkeley
Contract Monitoring Guide
Agency Administrative Review
Housing and Community Services Department
2180 Milvia Street/2nd Floor
Berkeley, CA 94704

Agency:

Address:

Phone:

Date of Last Visit: Review file for last monitoring. Make note of findings.

Visit Date: Later summer – fall. Done by end of November for RFP Contract Number:

Monitoring Review Period: 1st year of a two year contract Amount of Contract:

Funding Sources:

Agency Staff Interviewed During Visit:
(Name and Job Title) Executive Director, Operations Director, HR Director Monitoring Type:

2. Administration
A. Contract Review Y N N/A Comments

1. Are copies of current contracts, subcontracts and
amendments kept on file at agency for review? (If no,
note where items are kept.)

2. Has agency submitted reports, invoices, and other
required materials on a timely basis? (If no, state
actions taken to resolve problem.)
Monitor check prior to visit.

3. 501(c)(3) Letter of Determination uploaded in CDS? “ “

4. Is the agency in good standing with the State of CA? https://www.ftb.ca.gov/businesses/Exempt_organizatio
ns/Entity_list.shtml
“ “

5. Is the agency in good standing with the IRS? IRS
Agency Check https://www.irs.gov/Charities-&-Non-
Profits/Exempt-Organizations-Select-Check
“ “

6. Articles of Incorporation uploaded in CDS? “ “

7. Agency By-Laws uploaded in CDS? “ “

8. Authorized Signatory uploaded in CDS? “ “

9. Berkeley Business License uploaded in CDS? “ “

10. Certificates of Insurance uploaded in CDS?: (Article

12.C.)
“ “
a. Workers' Compensation “ “
b. General Liability, including Endorsement
Certificate
“ “
c. Vehicle “ “

B. Agency Policy and Procedures Y N N/A Comments

1. Does the agency have an Operations Manual? Ask for copy if not on file.

2. Is the agency’s current organizational chart on file? Monitor check prior to visit.

3. Is the agency’s current Non-discrimination Assurance Policy on file? (See City Ordinance No. 5876 N.S. and
Americans with Disabilities Act of 1990, Civil Rights,
Housing & Community Development, and Age
Discrimination Acts, Section 504 of the Rehabilitation
Act of 1973 (29 U.S.C. 794), and others listed in COB
contract Articles 13.A.5&6. & 21.)
“ “

4. Is the Agency’s Written Conflict of Interest Policy with “ “

Contract Monitoring Guide

B. Agency Policy and Procedures Y N N/A Comments
appropriate safeguards in place on file? (See 2 CFR
Part 215.42) (Article 15.) “
“https://www.whitehouse.gov/sites/default/files/omb/as
sets/omb/circulars/a110/2cfr215-0.pdf

5. Have there been any problems with conflicts of
interest within the agency? (If yes, explain how
agency has addressed the conflict.)

C. Board of Directors Review (reference: Brown Act, By Laws) Y N N/A Comments

1. What is the date of the last board meeting? Check for on-site copies.

2. How many meetings were held during the contract
review period? Is the number of meetings in
compliance with the Agency's By-Laws?

3. Is a current list of Board Members (Board Roster) on file with HCS?
Monitor check prior to visit.
a. Does the board composition comply with
Agency by-laws? (Contact information, titles,
committees, low- income representatives,
etc.)

4. Is there a copy of agenda and board minutes for each meeting on file at agency? (If no, explain.)

5. Has the Board or board committee members
conducted any closed meetings, Executive Sessions
or special meetings during contract review period?
(If yes, explain.)

6. Describe any strategic planning/organizational
development activities undertaken since last visit in
comments section.

Monitoring Results: Administration
Finding, Concern or Recommendation Correction Action Needed (For Findings and Concerns only)
Deadline for
Corrective Action
Finding or Concern
Resolved? (Y/N)

1. 2.

3. Personnel Management
A. Personnel Management Y N N/A Comments

1. Does the agency have a personnel manual with clear
and comprehensive policies and procedures?

a. If yes, does the manual contain an employee
grievance procedure?

2. Does the agency require all of its employees to sign a code of conduct or conflict of interest statement?
(Article 15.)

3. Does the agency service clients under the age of 18? If yes, does the agency have a policy and procedure
for complying with the following requirements:

a. TB Testing (Article 17.B.)
b. Criminal Background Check (Article 17.A.)
c. Is the agency’s Child Abuse Reporting Policy on
File? (Agencies with Mandated Reporters only.)

4. Does the agency have an Adult Abuse Report policy
on file? (Agencies with Mandated reporters only.)

5. Are current job descriptions prepared for all COB Obtain any new/updated documents.

Contract Monitoring Guide

A. Personnel Management Y N N/A Comments
positions? Are they on file? (Article 6.)

6. Are the resumes of all staff included in the COB
contract budget/Statement of Expense reports on file?
(Article 1.A.)
Check all, within reason. Some
exceptions may apply (such as
rotating clinical staff).

7. Was there any violation to the City’s Employment of
Near Relatives Policy during the review period?

a. Waiver Requested?
b. Waiver Approved?
c. If yes, explain the exception and how the agency
is managing the personnel functions of employees
involved.

8. Are there significant staff vacancies for the program? (Explain.)

9. Does the agency adequately supervise staff?
(Describe the method.)
Describe method and frequencies.

10. Does the agency provide staff development and
training? (Describe the efforts.)

11. Does the agency conduct regular staff meetings to
coordinate program activities? (Provide the
frequency.)

12. Does the agency make efforts to hire Berkeley
residents, patronize Berkeley businesses, and/or hire
women- and minority-owned business?

Monitoring Results: Personnel Management
Finding, Concern or Recommendation Correction Action Needed (For Findings and Concerns only)
Deadline for
Corrective Action
Finding or Concern
Resolved? (Y/N)

1. 2.

4. Agency Strengths
Note agency strengths below:

1. 2.

3. 4.

_ _
Contract Monitor Date

_ _
Division Manager Date

1. General Information
City of Berkeley
Contract Monitoring Guide
Program Review
Housing and Community Services Department
2180 Milvia Street/2nd Floor
Berkeley, CA 94704

Agency:

Program Name:

Address:

Phone:

Date of Last Visit:

Visit Date:

Contract Number:

Monitoring Review Period:

Amount of Contract:

Funding Sources:

Agency Staff Interviewed During Visit:
(Name and Job Title) Program Manager, Case Manager, line staff, etc.

Monitoring Type:

2. Resource Coordination (complete this section for each program reviewed) A. Volunteer Resources Y N N/A Comments

1. Does the program seek and receive volunteer support
from the local community or past clients? (describe
how services are documented in comments)

B. Collaboration Y N N/A Comments

1. Does the program have a mutual referral system
established with other CBO’s?

2. Does the agency/program participate in other
collaborations to maximize services/minimize
duplication of services?

3. If the program is required to collaborate with other COB funded agencies, do they have supporting
documentation providing evidence of this collaboration
and/or referral system?

Monitoring Results: Resource Coordination
Finding, Concern or Recommendation Correction Action Needed (For Findings and Concerns only)
Deadline for
Corrective Action
Finding or Concern
Resolved? (Y/N)

1. 2.

3. Facility Safety (complete this section for each program reviewed) A. Safety Y N N/A Comments

1. Does the program site(s) have an Emergency
Evacuation Plan?

2. Does the program have a First Aid kit on site(s)?

3. Does the agency/program have a Disaster Response
Plan?

4. Are relevant material safety data sheets (MSDS)

Contract Monitoring Guide

A. Safety Y N N/A Comments
sheets posted on site?

Monitoring Results: Facility Safety
Finding, Concern or Recommendation Correction Action Needed (For Findings and Concerns only)
Deadline for
Corrective Action
Finding or Concern
Resolved? (Y/N)

1. 2.

4. Client Services (complete this section for each program reviewed) A. Outreach Y N N/A Comments

1. Does the agency/program conduct outreach to inform
potentially eligible recipients of available assistance? Note what type of outreach below.

a. Public Services Announcements
b. Presentations
c. Mail
d. Flyers
e. Brochures/Pamphlets
f. Internet
g. Other

2. Are outreach materials available in languages other
than English? (Note other languages if applicable.)

B. Program Accessibility Y N N/A Comments

1. Is the program’s facility close to public transit?

2. Is the program’s facility accessible to clients with disabilities?
ADA checklist and other resources
available for agencies in monitor
tools.

3. Are the program hours accessible to the desired
population?

4. Did the agency maintain records regarding the
implementation of procedures intended to:

a. Advertise the eligibility of facilities and
services on a non-discriminatory basis to all
persons regardless of race, color, religion,
sex, age, national origin, familial status and
disability? (Obtain copy.)

b. Make available to interested persons
information concerning the availability and
location of services and facilities accessible to
persons with disabilities?

C. Policies and Procedures Y N N/A Comments

1. Does the program have a written “policies and
procedures” manual? Does this manual include how
clients engage with the program?
Monitor review available information
prior to visit for full discussion during
visit.

2. Does the program have a written policy that provides a clear description of eligibility criteria for program services? (If yes, obtain copy.)
“ “

3. Is there a process or procedure by which higher-level management (supervisor) reviews documentation of
services delivered for each client, as well as eligibility determinations?
“ “

Contract Monitoring Guide

C. Policies and Procedures Y N N/A Comments

4. Does the agency have a written statement of client
rights?
“ “

5. Does the agency have a written client grievance policy and procedure? (Obtain a copy.)
“ “
a. Does this policy and procedure include denial
of services or termination of a client’s
participation in services?
“ “
b. Does this policy include appeals for clients
who have been denied services? (If yes,
obtain a copy.)
“ “
c. How and when are clients provided a copy of
the policy? (I.e.: enrollment, intake, denial of
service?)
“ “
d. Is a signed copy kept in the client file? “ “
e. Is the policy reviewed at intake? “ “
f. Is the policy posted on site? “ “
g. Is the policy easy to understand? “ “
h. Does the policy describe how to initiate
appeals?
“ “
i. Does the policy include a clear description of
staff positions and contact information?
“ “
j. Does the policy include timelines for appeal
and appeal response at each stage of the
appeal?
“ “
k. Is the client informed in writing of the result of
the appeal at each stage of the appeal?
“ “
l. Does the policy allow for an advocate or other
assistance to file grievance/appeal?
“ “
m. Are clients provided a written notice when
denied services explaining the reason for
denial?
“ “
n. Does the written notice provide the appeal
process?
“ “

6. How are grievances tracked by the agency?
a. Have any grievances been filed against the
agency in the period?

b. If yes, how many?

D. Client Files Y N N/A Comments

1. Are adequate files maintained to document services
provided to each client?
Obtain a list of clients prior to visit
and/or alert program to have this
available in order to identify the client
files to review (min. 10% or 10 count).

2. Do the files include adequate documentation of
program eligibility?

3. Do the files contain adequate documentation of
income level? Note below which method the agency
uses to document income:

a. Income verified through copies of paychecks
or verification from other income source

b. Income verified through self-certification
c. Income verified through classification in a
presumed category.

4. If the agency uses the presumed category, does the
client file demonstrate that the service provided is
limited to one or a combination of the 8 population

Contract Monitoring Guide

D. Client Files Y N N/A Comments
segments presumed to be low- and moderate-income
by HUD: (Note which categories apply below.)

a. Abused children
b. Battered spouses
c. Elderly persons
d. Adults meeting the Bureau of Census’
Population Report definition of “severely
disabled” that applied at the time of this review

e. Homeless persons
f. Illiterate adults
g. Persons living with AIDS
h. Migrant farm workers

5. Do the client files include adequate documentation of client contacts, referrals made, and progress in
reaching client goals and appropriate service
outcomes?

6. Does the agency charge rent/fees to clients?
a. If yes, described how rent/fee is calculated in
the comments section.

b. Does the client file indicate that client
rents/fees were charged correctly?

7. Are client files kept in a secure and locked manner to ensure confidentiality?

8. Are computerized client files kept in a secure manner to ensure confidentiality?

9. Does the agency have an electronic data backup
system?

10. What is the agency’s policies and procedures related to retaining client files? Is the agency complying with Article 6 of the contract and retaining files for a
minimum of 5 years?

11. How are client files destroyed?

E. Payee and Money Management Services Y N N/A Comments

1. Does the agency provide payee or money
management services? (If NO, skip section)

2. Does the agency have written policies on how these
services are provided? (Obtain copy.)

3. Can the agency demonstrate client fund balance, both aggregate fund balance and individual client balance?

4. Does the agency have a bank statement for accounts?

5. What is the frequency of reconciliation? Please
provide the last date of reconciliation.

6. Is there supporting documentation for expenses paid
on behalf of the client?

7. Are there records of client approval of expenses paid on his/her behalf?

8. Are any cash, checks and other fiscal records kept in a secure, locked location?

9. Are financial services managed by more than one
person (separation of duties)? (Describe.)

F. Shelter Plus Care Matching Services Y N N/A Comments

1. Does the agency provide services to City of Berkeley Shelter Plus Care clients? (If NO, skip section)
Needs to be yes. Coordinate with S+C
staff for policies and procedures.

2. Does the agency provide matching services to City’s “ “

Contract Monitoring Guide

Shelter Plus Care program?

3. How is the agency’s matching services calculated?
(describe in the comments section)
“ “

4. Does the agency have on-site support for previously- submitted match reports?
“ “

Monitoring Results: Client Services
Total Number of Files: _ Total Number of Files Reviewed:

Finding, Concern or Recommendation Correction Action Needed (For Findings and Concerns only)
Deadline for
Corrective Action
Finding/Concern
Resolved? (Y/N)

1. 2.

5. Program Reporting and Evaluation (complete this section for each program reviewed) A. Program Reporting (Article 7.) Y N N/A Comments

1. Were Program Reports submitted on or before due
date?

2. Were the reports accurate?

B. Program Outcomes

1. Do more than 51% of clients served have incomes
below 80% of Area Median Income?
http://www.hcd.ca.gov/
Print out program reports.

2. Has the agency accomplished the outcomes goals as
stipulated in the contract? (If no, explain.)

3. Does the agency have adequate back-up
documentation for the outcomes reported in the
(client) file? (If yes, describe documentation method in comments. If no, explain why.)

4. Has the agency accomplished the service measures
as stipulated in the contract? (If no, explain.)

5. Does the agency have adequate back-up
documentation for the service measures reported in
the (client) file? (If yes, describe documentation
method. If no, explain why.)

6. Does the agency make additional efforts to monitor
and evaluate the effectiveness of agency services?
Explain how in the comments section.

Monitoring Results: Program Outcomes
Finding, Concern or Recommendation Correction Action Needed (For Findings and Concerns only)
Deadline for
Corrective Action
Finding or Concern
Resolved? (Y/N)

1. 2.

Contract Monitoring Guide

6. Rehab Services (complete this section for each rehab program reviewed) A. Single Family Y N N/A Comments

1. Does the project file for the CDBG assistance provide a full description sufficient to show that the activity is eligible and has been properly classified under
Subpart C of Part 570? [24 CFR 570.506(a)]

2. Is there documentation that shows that the applicant is low- and moderate-income, based on the applicant’s
household size and household income at the time the
assistance was provided?
[24 CFR 570.208(a)(3) and 24 CFR 570.506(b)(4)(iii)]

3. Is there a copy of a written agreement (lease) between the program participant and the landlord receiving
CDBG assistance? [24 CFR 570.506(b)(4)(i)]

4. Is there a copy of an initial property inspection on file?

5. Does the file contain a Work Write-Up and Cost
Estimate that addresses the issues raised in the initial inspection?

6. Is there a contract between the owner and the
subrecipient, or the owner and the contractor in the
file, which contains either: (i) a list of all of the work to be performed, or (ii) refer to some other document
(e.g., a work write-up) that lists all of the work to be performed?

7. Was a local building permit obtained for the job? Did the building official sign off on the permit, indicating that the work was completed?

8. If applicable, were Davis-Bacon requirements met?

9. Were the environmental requirements at Part 58 met?

B. Other Y N N/A Comments

1. Monitoring Results: Rehab Services
Finding, Concern or Recommendation Correction Action Needed (For Findings and Concerns only)
Deadline for
Corrective Action
Finding or Concern
Resolved? (Y/N)

1. 2.

7. Program Strengths
Note program strengths below:

1. 2.

3. 4.

_ _
Contract Monitor Date

Contract Monitoring Guide

_ _
Division Manager Date

1. General Information
City of Berkeley
Contract Monitoring Guide
Financial Services Review
Housing and Community Services Department
2180 Milvia Street/2nd Floor
Berkeley, CA 94704

Agency:

Address:

Phone:

Date of Last Visit:

Visit Date:

Contract Number:

Monitoring Review Period:

Amount of Contract:

Funding Sources:

Agency Staff Interviewed During Visit:
(Name and Job Title) Executive Director, Financial Officer, Accountant, etc.

Monitoring Type:

2. Financial Management
A. Fiscal Policies and Procedures (Article 8.) Y N N/A Comments

1. Does the Agency have clear and comprehensive fiscal
policies and procedures?

2. If yes, do they include the following key internal
controls?

a. Do the policies include procedures for
determining the reasonableness, allowability,
and allocability of costs?

b. A fiscal records retention policy that complies
with the 5-year minimum retention policy listed
in the COB Contract. (Article 6.)

c. How does the agency assure security of
agency funds and property so they are used
solely for authorized purposes? (Article 8.)
Provide onsite confirmation.

Check for red flag items like petty
cash box, cash/credit cards, valuable
equipment, etc.
d. Adequate segregation of duties?
e. Do the policies outline who is authorized to
approve financial transactions?
Segregation of duties.
f. How does the Agency secure storage of
assets, blank checks, and confidential
documents. Provide onsite confirmation.

Agency should submit a list of assets
at 4th quarter (in CDS).

B. Record Keeping (Article 6 & 8.) Y N N/A Comments

1. What is the agency’s basis for accounting? (Note in
comments: Cash, Accrual, Modified Accrual, Other.)
See glossary of accounting terms in
monitoring tools.

2. Are books of accounts and financial statements
prepared in-house, and supported by a clear and
comprehensive accounting manual? (If no, note where
in comments.)
Obtain a copy.

3. Does the financial system contain sufficient
information and reflect proper accounting treatment of
financial transactions, including:

a. Bank accounts and cash balances?
b. Disbursement details, including date, payee,

Financial Management Monitoring Guide

B. Record Keeping (Article 6 & 8.) Y N N/A Comments
name, account, expense classification, and
other relevant information?

c. Segregation of funds from different sources?
Does agency have existing standard financial
record keeping system to be used for
accounting for grant/COB contract funds?
(Article 6.A.3.a & 8.A. in COB contract.)

d. Comparison of expense against budgets?
(Article 8.A. & 8.C. in COB contract.)

e. Initial records and subsequent clearing of
cash advances?

f. Accrual of expenditures to match costs to
proper period (if accrual method is used).

C. Financial Reports (Article 6.) Y N N/A Comments

1. Are financial records (including balance sheet and
statement of revenue and expense) reconciled,
maintained, up-to-date, and reviewed by Executive
Director on a monthly basis? (Note the frequency.)

2. Does the Board review the financial reports? (Note the frequency.)

3. Are the financial statements audited by an
independent account? Or has the agency been
monitored by any other funder during the period?
(Note date of most recent Audited Financial Statement
in comments.)

a. If yes, were there any findings? (Findings
must be included in City Desk Audit and their
resolution tracked.)

b. Did the agency correct the findings? (Note
how corrected.)

4. If the agency was not independently audited, were
year-end financial statements prepared and available
for review?

5. Did the Agency receive more than $750,000 in federal funds during the review period? 2 CFR Part 200.501.
https://www.gpo.gov/fdsys/pkg/FR-2013-12-
26/pdf/2013-30465.pdf

a. If so, what is the date of the Agency’s most
recent Single Audit? Please provide a copy.

Search Audit Database here:
https://harvester.census.gov/facdissem/main.a
spx

D. Cash/Check Handling Y N N/A Comments

1. Are disbursements properly authorized prior to check issuance or cash outlay?

2. Is there proper segregation of duties for signing
checks and withdrawing sub-grant funds?

3. Were checks signed by authorized signatories?

4. Were invoices marked “paid” to avoid double
payment?

5. Are bank accounts reconciled monthly? (Note
frequency and responsible staff.)

6. Are bank reconciliation statements reviewed by
appropriate staff? (Note responsible staff.)

7. Are petty cash balances kept at the office premises?

Financial Management Monitoring Guide

D. Cash/Check Handling Y N N/A Comments
Provide Policies & Procedures. (Note size of petty
cash fund.)

a. How often was petty cash fund count
conducted?

b. Was petty cash fund count conducted by
someone other than the person handling the
fund?

c. Was individual handling the petty cash fund
different from the staff authorizing
replenishment of petty cash?

E. Procurement/Commodity Tracking (Articles 9 & 11.) Y N N/A Comments

1. Does the agency have clear and comprehensive
written procurement policies and procedures that are
aligned with the COB contract, Article 11, as it relates to OMB 2 CFR Part 215.40? Website:
https://www.whitehouse.gov/sites/default/files/omb/ass
ets/omb/circulars/a110/2cfr215-0.pdf
Obtain a copy.

2. Does the agency require competitive bidding for all
major (over $5,000) procurement?

a. Is the bidding process adequately
documented? Provide documentation.

b. Are the functions for solicitation and
evaluation of bids separate from the selection
of winning bid? Is there evidence of proper
separation of duties?

3. Has the agency purchased any equipment valued at
over $600 with COB funds? (Article 9.)

a. Were the purchases approved as part of the
contract budget? If no, agencies need written
approval and must add the item to the
equipment inventory located at the bottom of
the Q4 SOE.

4. If applicable, has the agency submitted an equipment inventory along with their Q4 SOE?

5. Has the agency disposed of any property paid for with COB funds during the period? (Article 9.)

a. If so, how was the property disposed of and
did the agency follow the use and disposition
requirements contained in Article 9 of the
COB contract?

6. Does the agency have a fixed assets listing/equipment inventory containing sufficient information to identify items acquired by grant/contract funds?

7. Does the agency subcontract with other agencies or
vendors? (If no, skip to next section.)

a. Do written agreements contain provisions
which allow for legal remedies in case of
breach of contract and for termination in case
of default or other similar instance?

b. Does the agency have an appropriate and
adequate record-keeping system for
monitoring its sub-grant-related activities?
Example: financial reports, statements
of expenses, timesheets.

Financial Management Monitoring Guide

3. City of Berkeley Reporting
A. Budget Review Y N N/A Comments

1. What is the agency’s total budget for the current year? (Note amount.)
Cross check with contract.

2. Did the agency/program expenditures stay on track
with the expenditure budget in the contract?
Print out SOEs. Check for budget
modifications.

B. Statement of Expense (SOE) Reporting and Advance
Payment (AP) Requests (Article 7.)
Y N N/A Comments

1. Are requests for advances/reimbursements prepared,
reviewed and approved properly and submitted by
required deadlines?

2. Are financial reports prepared, reviewed and approved properly and submitted by required deadline?

3. In the period under review, were the SOEs accurate? Typical review period is 4th quarter.

4. Are receiving reports and inventory records used to
evidence receipt of commodities and supplies?
Supplies tracking sheet. Can review
this as SOE line item.

5. Are shared direct costs allocated to funding sources? Needs to be yes. Ask for the cost allocation plan.
a. If yes, is the method for allocated shared
direct costs documented?
Obtain related documents. If no, this
is a finding to be corrected.
\\

C. Line Item #1: Salaries and Payroll (Article 6 & 23.) Y N N/A Comments

1. Does the agency have an appropriate and adequate
timecard/reporting systems for hours worked?

2. Was the payroll register/ledger available for review? Use Payroll Worksheet in monitoring tools. Accrued (payroll) vs. taken
leave (timecards) tracking.

3. Did timecards reflect distribution of hours worked by fund? Specifically, does the timesheet include
distribution of hours of hours charged to the City of
Berkeley contract?
See sample timecards in monitoring
tools.
a. Were timecards signed by the employee?
b. Were timecards approved by the supervisor?

4. Are salary rates consistent with the contract rate
schedule?
Refer to contract budget.

5. Were fringe benefits such as medical and dental
insurance supported by invoices and agency
payments towards invoice?
Ask to see invoices and/or payroll
docs.

6. Are all payroll deductions remitted to the appropriate government agency on a timely basis?
Found in check/payroll register.
a. Did the agency pay Berkeley Living Wage for
all applicable positions funded under this
program? (Article 23.)

b. Living Wage Ordinance (2016)
http://www.ci.berkeley.ca.us/Finance/Home/V
endors__Living_Wage_Ordinance.aspx
Make sure these rates are correct
prior to your visit.
i. Without Benefits: $16.37
ii. With Benefits: $14.04
c. Did the agency pay Berkeley Minimum Wage
for all positions funded under this program?
http://www.cityofberkeley.info/MWO/
Make sure these rates are correct
prior to your visit.
i. Minimum wage in Berkeley $11,
effective Oct.1, 2015, $12.50 effective
Oct. 1, 2016.

7. Was the agency in compliance with the Equal Benefit
Ordinance? (Article 24.)
Self-certification with signatory
document on file.

Financial Management Monitoring Guide

C. Line Item #1: Salaries and Payroll (Article 6 & 23.) Y N N/A Comments

8. Have any bonuses been paid to employees with City
funds? (If yes, please explain.) (Article 16.)
COB does not allow for City funds
paid in bonus. Red flag.

9. Are appropriate documents or vouchers prepared and
signed by the recipient of the payroll funds?

a. Do those vouchers clearly indicate the rate
and period covered by the payroll payment?

D. Line Item #2: Example: Client expenses/cash-like $ Y N N/A Comments

1. Are expenses fully supported by invoices, receipts, or similar documents?
See Sampling of Expenses worksheet
in monitor tools. Check 10% or min. of
10 charges in category.

2. Other

E. Line Item #3: Review past file for prior items of concern Y N N/A Comments

1. Are expenses fully supported by invoices, receipts, or similar documents?
See Sampling of Expenses worksheet
in monitor tools. Check 10% or min. of
10 charges in category.

2. Other

Monitoring Results: Financial Management
Finding, Concern or Recommendation Correction Action Needed (For Findings and Concerns only)
Deadline for
Corrective Action
Finding or Concern
Resolved? (Y/N)

1. 2.

4. Strengths

Note agency financial management strengths below:

1. 2.

3. 4.

_ _
Contract Monitor Date

_ _
Division Manager Date

Financial Management Monitoring Guide

Sampling of Expenses

Program

Total Number of charges

Sampling Number:
(10% of total charges or minimum 10 records)

Date Check
Number
Payee Type of Expense Are there
supports for
check? (y/n)
Is expense
Allowable?
(y/n)
Comments

Exhibit 28-3
Emergency Solutions Grants
6509.2 REV-7
28-1 02/2017

Guide for Review of ESG Subrecipient Grant Management
Name of Recipient:

Name of Subrecipient(s):

Staff Consulted:

Name(s) of Reviewer(s) Date

NOTE: All questions that address requirements contain the citation for the source of the requirement (statute, regulation, or grant agreement). If the requirement is not met, HUD must select “NO” in response to the question and make a finding of noncompliance. All other questions that do not contain the citation for the requirement do not address requirements, but are included to assist the reviewer in understanding the participant's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding."

Instructions: This Exhibit is designed to assess the recipient’s compliance with subrecipient grant management requirements of the Emergency Solutions Grants (ESG) program. HUD reviewers should use a combination of the information in program files and subrecipient staff interviews to answer the questions below. The Exhibit is divided into eight sections: Subgrants Management and Oversight; Systems Coordination Requirements; Recordkeeping; Homeless Management Information System (HMIS); Other ESG-Specific Requirements; Administrative Costs and Financial Management; Other Federal Requirements; and Additional 2 CFR 200 Review for Sub-Subawards.

As previously noted, the ESG rule at 24 CFR part 576 generally incorporates the uniform administrative requirements, cost principles, and audit requirements, which were recently revised and codified at 2 CFR part 200. This Exhibit contains both questions to monitor compliance with 2 CFR part 200 and questions to monitor compliance with the former uniform administrative requirements, cost principles, and audit requirements (i.e., 24 CFR parts 84 and 85 (2013), 2 CFR 225 and 230 (2013), OMB Circular A-133). For HUD’s expectations on monitoring for compliance with the uniform administrative requirements, cost principles, and audit requirements during the period of transition to 2 CFR part 200, please see HUD’s April 13, 2016, Notice CPD-16-04 (http://portal.hud.gov/hudportal/documents/huddoc?id=16-04cpdn.pdf ).

The HUD reviewer must supplement this Exhibit with Exhibit 28-9 (covering the procurement requirements in 24 CFR parts 85 and 84) and Exhibit 34-3 (covering the procurement requirements in 2 CFR part 200), as applicable.

Where ESG funds were used for rental assistance or services, the HUD reviewer MUST complete the applicable Exhibits in Chapter 24 of this Handbook, Lead-Based Paint Compliance. NOTE: See Exhibit 24-2 (Services), Exhibit 24-3 (Tenant-Based Rental Assistance), or Exhibit 24-4 (Project- Based Rental Assistance).

This Exhibit can be used to either monitor a single subrecipient or multiple subrecipients. It is the responsibility of the HUD reviewer to ensure that the responses provide sufficient documentation to support the basis for the conclusions. Keep in mind that, if multiple entities are reviewed and a deficiency is identified for a single entity, a “No” response is required.

6509.2 REV-7 Exhibit 28-3
Emergency Solutions Grants
02/2017 28-2

Questions:

A. SUBGRANTS MANAGEMENT AND OVERSIGHT

1. Eligible Subrecipients:
a. If the organization is a subrecipient of a state, is it a unit of general purpose local government (which can include a metropolitan city or urban county that receives ESG funds directly from HUD, or a combination of general purpose local governments recognized by HUD), or a private nonprofit organization within the state; or b. If the organization is a subrecipient of a metropolitan city, urban county, or territory, is it a private nonprofit organization? NOTE: A private nonprofit organization does not include a governmental organization, such as a public housing agency or housing finance agency.
[24 CFR 576.2; 24 CFR 576.202]

Yes No N/A
Describe Basis for Conclusion:

2. Obligation Requirements (State subrecipients that are units of general purpose local government): Within 120 days after the date the state obligated its funds to a unit of general purpose local government, did the subrecipient obligate all of those funds by: a subgrant agreement with, or a letter of award requiring payment to, a private nonprofit organization; a procurement contract; and/or the written designation of a department within

the government of the subrecipient to directly carry out an eligible activity? [24 CFR 576.203(a)(1)(ii)]

Yes No N/A
Describe Basis for Conclusion:

3. Payments to Subrecipients (Units of General Purpose Local Government) :

If the subrecipient is a unit of general purpose local government, did it pay each of its subrecipients for allowable costs within 30 days after receiving the subrecipient’s complete payment request?
[24 CFR 576.203(c)]

Yes No N/A
Describe Basis for Conclusion:

Exhibit 28-3
Emergency Solutions Grants
6509.2 REV-7
28-3 02/2017

B. SYSTEMS COORDINATION REQUIREMENTS

4. Coordination with Other Targeted Homeless Services: Does each subrecipient’s records reflect that it coordinated and integrated, to the maximum extent practicable, ESG-funded activities with the programs, including those listed under 24 CFR 576.400(b), that are targeted to homeless people in the area covered by the Continuum of Care (CoC) or area over which the services are coordinated to provide a strategic, community-wide system to prevent and end homelessness for that area? [24 CFR 576.400(b); 24 CFR 576.500(m)]

Yes No N/A
Describe Basis for Conclusion:

5. System and Program Coordination with Mainstream Resources: Does each subrecipient’s records reflect that it coordinated and integrated, to the maximum extent practicable, ESG-funded activities with mainstream housing, health, social services, employment, education, and youth programs for which homeless and at-risk persons might be eligible? [24 CFR 576.400(c); 24 CFR 576.500(m)]

Yes No N/A
Describe Basis for Conclusion:

6. Use of the Coordinated Assessment System: If the CoC for the area in which the program or project is located has established a coordinated assessment system that meets HUD’s requirements, do the records show:
a. that the subrecipient (unless it is a victim service provider) uses that assessment system; and
b. all initial evaluations were conducted in accordance with the coordinated assessment system requirements?
NOTE: ESG-funded victim service providers may choose not to use the CoC’s coordinated assessment system.
[24 CFR 576.400(d); 24 CFR 576.401(a); 24 CFR 576.500(g)

Yes No N/A
Describe Basis for Conclusion:

7. Coordinated Assessment (Consistency with Written Standards): Did each subrecipient work with the CoC to ensure that the screening, assessment, and referral of program participants are consistent with the ESG written standards required under 24 CFR 576.400(e)?
[24 CFR 576.400(d)]

Yes No N/A
Describe Basis for Conclusion:

02/2017 28-4

6509.2 REV-7 Exhibit 28-3
Emergency Solutions Grants

8. Establishing Written Standards (State Subrecipients): If a subrecipient of a state is required to establish its own written standards, did the subrecipient follow the state recipient’s requirements for the establishment and implementation of these standards?
[24 CFR 576.400(e)]

Yes No N/A
Describe Basis for Conclusion:

9. Written Standards (Content): If a subrecipient of a state is required to establish its own written standards, did the written standards include the minimum required elements described in 24 CFR 576.400(e)(3)? [24 CFR 576.400(e)(3)]

Yes No N/A
Describe Basis for Conclusion:

C. RECORDKEEPING

10. Recordkeeping (Subrecipients): If applicable, did the subrecipient retain copies of all solicitations of and agreements with its subrecipients, records of all payment requests by and dates of payments made to subrecipients, and documentation of all monitoring and sanctions of subrecipients? [24 CFR 576.500(v)]

Yes No N/A
Describe Basis for Conclusion:

11. Recordkeeping (Eligibility): Does each subrecipient’s records document that staff followed the recipient’s policies and procedures to:
a. conduct an initial evaluation and re-evaluations as required, and b. document eligibility in accordance with HUD’s requirements? [24 CFR 576.400(e)(3); 24 CFR 576.401(a), (b), and (c); 24 CFR 576.500(a), (b), (c), and (e)]

Yes No N/A
Describe Basis for Conclusion:

12. Recordkeeping (Program Participant Records): Did each subrecipient ensure that each program participant record documented compliance with applicable requirements for providing services and assistance to that program participant under the program components and eligible activities provisions at 24 CFR 576.101 through 24 CFR 576.106?
[24 CFR 576.500(f)]

Yes No N/A
Describe Basis for Conclusion:

28-5 02/2017

Exhibit 28-3 6509.2 REV-7
Emergency Solutions Grants

13. Confidentiality: Did each subrecipient have written procedures to ensure confidentiality, including:
a. all records containing personally identifying information of any individual or family who applies for and/or receives ESG assistance are kept secure and confidential;
b. the address or location of any domestic violence, dating violence, sexual assault, or stalking shelter project assisted under ESG; and c. the address or location of any program participant housing? [24 CFR 576.500(x)]

Yes No N/A
Describe Basis for Conclusion:

14. Recordkeeping (Record Retention): Did the recipient or its subrecipients retain copies of the required records for the greater of 5 years or the applicable time period below:
a. for emergency shelters subject to a 10-year minimum period of use:
at least 10 years from the date that ESG funds were first obligated for the major rehabilitation or conversion of the building; or b. for program participant files: at least 5 years after the expenditure of all funds from the grant under which the program participant was served?
[24 CFR 576.500(y)]

Yes No N/A
Describe Basis for Conclusion:

D. HOMELESS MANAGEMENT INFORMATION SYSTEM (HMIS)

15. Data Collection and Recordkeeping: Do records reflect that each subrecipient entered data on all persons it served under ESG and on all of its ESG activities into the applicable community-wide HMIS or, for victim services providers (and legal services providers that opt out), into a comparable database, in accordance with HUD’s HMIS data standards? NOTE: Each subrecipient must be able to provide documentation, such as HMIS reports, that shows subrecipient client-level and activity-level data are being entered into the applicable CoC’s HMIS (or a comparable database).
[24 CFR 576.400(f); 24 CFR 576.500(n); 2014 HMIS Data Standards]

Yes No N/A
Describe Basis for Conclusion:

02/2017 28-6

6509.2 REV-7 Exhibit 28-3
Emergency Solutions Grants

16. Eligible costs (HMIS): If the subrecipient is not a victim service provider, or a legal service provider that uses a comparable database, did the subrecipient use ESG funds only for costs eligible for the purpose of contributing data to the HMIS designated by the CoC?
[24 CFR 576.107(a)(1)]

Yes No N/A
Describe Basis for Conclusion:

17. Data entry (Comparable database): If the subrecipient is a victim service provider, or a legal services provider that uses a comparable database, were data maintained in the comparable database and not contributed or entered into an HMIS?
[24 CFR 576.400(f)]

Yes No N/A
Describe Basis for Conclusion:

18. Eligible costs (Comparable database): If the subrecipient is a victim service provider, or a legal services provider that uses a comparable database, were funds used for establishing and operating a comparable database that complies with HUD’s HMIS requirements, including collecting client-level data over time (i.e., longitudinal data) and generating unduplicated aggregate reports?
[24 CFR 576.400(f); 24 CFR 576.107(a)(3); 24 CFR 576.107(b)]

Yes No N/A
Describe Basis for Conclusion:

E. OTHER ESG-SPECIFIC REQUIREMENTS

19. Matching Requirements: If the recipient required its subrecipients to contribute match, did the subrecipients’ records reflect that they met the applicable requirements, including records of the source and use of matching funds?
[24 CFR 576.201; 24 CFR 576.500(o) and (v)(3)]

Yes No N/A
Describe Basis for Conclusion:

20. Conflicts of Interest (Organizational): Did a representative sample of the subrecipients’ records reveal zero instances where:
a. any type or amount of ESG assistance was conditioned on acceptance of shelter or housing owned by the recipient, subrecipient, contractor, or any parent or subsidiary of the subrecipient or contractor; or b. a subrecipient or contractor carried out the initial evaluation for a program participant while the individual or family was occupying housing owned by the subrecipient or contractor, or any parent or subsidiary of the subrecipient or contractor; or

Yes No N/A

28-7 02/2017

Exhibit 28-3 6509.2 REV-7
Emergency Solutions Grants

c. a subrecipient or contractor administered any homelessness prevention assistance to an individual or family occupying housing owned by the subrecipient or contractor, or any parent or subsidiary of the subrecipient or contractor?
[24 CFR 576.404(a); regarding contractors, 24 CFR 576.404(c); 24 CFR 576.500(p)]

Describe Basis for Conclusion:

21. Conflicts of Interest (Individual): Does each subrecipient’s records:
a. contain personal conflicts of interest policy or codes of conduct developed and implemented to comply with requirements;
b. demonstrate that the officers and staff of the subrecipient and any contractors complied with the individual conflict of interest requirements at 24 CFR 576.404(b); or
c. contain documentation supporting any exceptions to the personal conflicts of interest prohibition?
[24 CFR 576.404(b); 24 CFR 576.500(p)]

Yes No N/A
Describe Basis for Conclusion:

22. Homeless Participation: Did each subrecipient involve homeless individuals and families, to the maximum extent practicable, in constructing, renovating, maintaining, and operating facilities assisted under ESG, in providing services assisted under ESG, and in providing services for occupants of facilities assisted under ESG (could include employment or volunteer services)?
[24 CFR 576.405(c)]

Yes No N/A
Describe Basis for Conclusion:

23. Faith-Based Activities: Did each subrecipient ensure that it did not engage in inherently religious activities as part of the programs or services funded under ESG? If the subrecipient conducted these activities, were they offered separately, in time or location, from the programs or services funded under ESG, and was participation voluntary for all program participants? [24 CFR 576.406(b); 24 CFR 576.500(r)]

Yes No N/A
Describe Basis for Conclusion:

24. Faith-Based Activities: Did each subrecipient ensure that it did not discriminate against a program participant or prospective program participant on the basis of religion or religious belief? [24 CFR 576.406(d); 24 CFR 576.500(r)]

Yes No N/A
Describe Basis for Conclusion:

02/2017 28-8

6509.2 REV-7 Exhibit 28-3
Emergency Solutions Grants

25. Faith-Based Activities (Rehabilitation): Did each subrecipient ensure that ESG funds were not used for the rehabilitation of sanctuaries, chapels, or other rooms that an ESG-funded religious congregation uses as its principal place of worship?
[24 CFR 576.406(e); 24 CFR 576.500(r)]

Yes No N/A
Describe Basis for Conclusion:

26. Faith-Based Activities (Rehabilitation): If a structure is used for both eligible and inherently religious activities, did the subrecipient ensure that the amount of ESG funds used was limited to the costs of those portions of the rehabilitation that are attributable to eligible activities in accordance with the cost accounting requirements applicable to ESG funds? [24 CFR 576.406(e); 24 CFR 576.500(r)]

Yes No N/A
Describe Basis for Conclusion:

F. ADMINISTRATIVE COSTS AND FINANCIAL MANAGEMENT

27. Eligible activities: Were subrecipients’ expenses allowable? NOTE: To answer this question with respect to 2 CFR 200.403, the HUD reviewer MUST complete Exhibit 34-2, Guide for Review of Cost Allowability.
[24 CFR 576.100-576.109; 24 CFR 576.500(u)(2); 24 CFR 84.21(b)(6); 24 CFR 85.22, 2 CFR 200.403]

Yes No N/A
Describe Basis for Conclusion:

28. Eligible Costs: Did each subrecipient charge staff and overhead costs directly related to carrying out activities eligible under one of the components to the applicable activity, and retain supporting documentation for all costs charged to the grant?
[24 CFR 576.100(d); 24 CFR 576.108(a); 24 CFR 576.500(u)]

Yes No N/A
Describe Basis for Conclusion:

29. Eligible Administrative Costs: If a subrecipient received Administrative funds:
a. were all administrative costs eligible in accordance with 24 CFR 576.108; and
b. were the costs of carrying out the environmental review charged as an Administrative activity?
[24 CFR 576.108(a)(1), (2), and (4)]

Yes No N/A
Describe Basis for Conclusion:

28-9 02/2017

Exhibit 28-3 6509.2 REV-7
Emergency Solutions Grants

30. Training Costs: If any staff time was spent on training:
a. was it only for providing training on ESG requirements, attending HUD-sponsored ESG training, training staff on using HMIS or a comparable database, or attending HUD-approved training on HMIS

and the ESG program; and
b. was it charged to the appropriate component (only HMIS for HMIS- related training, and Administrative costs for all other training)? [24 CFR 576.108(a)(1), (2), and (4); 24 CFR 576.107]

Yes No N/A
Describe Basis for Conclusion:

31. Indirect Costs: If any indirect costs were charged to the grant, were allocations made to each eligible activity and consistent with an indirect cost rate proposal developed in accordance with the Uniform Administrative Requirements?
[24 CFR 576.109; 2 CFR 576.500(u)]

Yes No N/A
Describe Basis for Conclusion:

32. Eligible activities: Did a review of personnel costs charged to ESG, including a review of job descriptions, reveal that, for all staff time paid for with ESG funds, the staff member was working on eligible ESG activities? [24 CFR 576.500(u)]

Yes No N/A
Describe Basis for Conclusion:

G. OTHER FEDERAL REQUIREMENTS

33. Drug-Free Workplace: Did each subrecipient have a drug-free workplace statement per the requirements of 2 CFR part 2429?
[24 CFR 5.105(d) and 24 CFR 576.407(a)]

Yes No N/A
Describe Basis for Conclusion:

34. If the requirements of the Drug-Free Workplace Certification were reviewed, is each subrecipient in compliance?
[24 CFR 5.105(d); 24 CFR 576.407(a); 2 CFR part 2429]

Yes No N/A
Describe Basis for Conclusion:

02/2017 28-10

6509.2 REV-7 Exhibit 28-3
Emergency Solutions Grants

35. Non-Discrimination, Section 504 of the Rehabilitation Act of 1973, and Other Equal Opportunity Requirements: Did records demonstrate that each subrecipient is in compliance with the applicable requirements in 24 CFR part 5, Subpart A, including the nondiscrimination and equal opportunity requirements at 24 CFR part 5.105(a)? (Use pertinent Exhibits in Chapter 22, as necessary.)
[24 CFR part 5, Subpart A; 24 CFR 576.407(a); 24 CFR 576.500(s)(1)]

Yes No N/A
Describe Basis for Conclusion:

36. Affirmative Outreach: Do the records indicate that the recipient and its subrecipients:
a. make known that the use of the facilities, assistance, and services are available to all on a nondiscriminatory basis, and establish additional procedures, as required under 24 CFR 576.407(b), to ensure that the “target population” who may qualify are made aware of the availability of these facilities, assistance, or services; and b.
take appropriate steps to ensure effective communication with persons with disabilities; and
c. take reasonable steps to ensure meaningful access to programs and activities for persons with limited English proficiency (LEP)? (Use pertinent Exhibits in Chapter 22 as necessary.)
[24 CFR part 5, Subpart A; 24 CFR 576.407(b); 24 CFR 576.500(s)(1)]

Yes No N/A
Describe Basis for Conclusion:

37. Applicability of Uniform Administrative Requirements and OMB Circulars:

If this area was reviewed, did each subrecipient maintain records documenting compliance with the applicable requirements outlined in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards?
[24 CFR 576.407(c); 24 CFR 576.500(s)(2)]

Yes No N/A
Describe Basis for Conclusion:

38. Audits: If this area was reviewed, was each subrecipient in compliance with the Single Audit Act of 1984, as amended, and implementing regulations? NOTE: To answer this question with respect to 2 CFR 200.501, the HUD reviewer MUST complete Exhibit 34-1, section K (“Audit Requirements”).
[24 CFR 84.26; 24 CFR 85.26; 24 CFR 576.407(c); 2 CFR 200.501]

Yes No N/A
Describe Basis for Conclusion:

28-11 02/2017

Exhibit 28-3 6509.2 REV-7
Emergency Solutions Grants

39. Lead-Based Paint: Where ESG funds were used for rental assistance (TBRA or PBRA) or supportive services, do records reflect that the subrecipient complied with all lead-based paint requirements? NOTE: See Chapter 24, Lead-Based Paint Compliance, in this Handbook: Exhibit 24-2 (Supportive Services), Exhibit 24-3 (TBRA), or Exhibit 24-4 (PBRA), as applicable, MUST be completed to answer this question.
[24 CFR 35.700-730 (PBRA); 24 CFR 35.1000-1020 (Supportive Services); 24 CFR 35.1200-1225 (TBRA); 24 CFR 576.403(a)]

Yes No N/A
Describe Basis for Conclusion:

40. In making an award to the subrecipient, did the recipient evaluate the subrecipient’s risk of noncompliance with the Federal statutes, regulations, and terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring?
NOTE: This evaluation may include consideration of factors such as:
• the subrecipient’s prior experience with the same or similar subawards;
• the results of previous audits, including whether or not the subrecipient receives a Single Audit in accordance with Subpart

F of 2 CFR part 200, and the extent to which the same or similar subaward has been audited as a major program;
• whether the subrecipient has new personnel or new or
substantially changed systems; and
• the extent and results of previous HUD monitoring, if the subrecipient also receives funds directly from HUD.
[24 CFR 576.407(c) and 2 CFR 200.331(b)]

Yes No N/A
Describe Basis for Conclusion:

41. Section 3: If applicable, was each subrecipient in compliance with the applicable requirements of Section 3 of the Housing and Urban Development Act of 1968?
[24 CFR part 135; 24 CFR 576.407(a); 24 CFR 576.405(c)]

Yes No N/A
Describe Basis for Conclusion:

H. ADDITIONAL 2 CFR PART 200 REVIEW FOR SUB-SUBAWARDS

NOTE: The following questions apply when a subrecipient carries out its subgrant by making subgrants to a lower tier of subrecipients. To ensure clarity and consistency with part 200, the term “pass-through entity” refers to the first or higher-tier subrecipient, and the term “subrecipient” refers to the subrecipient(s) at the lower tier.

02/2017 28-12

6509.2 REV-7 Exhibit 28-3
Emergency Solutions Grants

42. If the pass-through entity provides funds through either a subrecipient agreement or a contract, has it followed the criteria in 2 CFR 200.330 for making case-by-case determinations of whether the entity is receiving the funds in the role of either a subrecipient or contractor? [24 CFR 576.407(c); 2 CFR 200.330]

Yes No N/A
Describe Basis for Conclusion:

43. In making an award to a subrecipient, has the pass-through entity evaluated each subrecipient’s risk of noncompliance with the Federal statutes, regulations, and terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring?
NOTE: This evaluation may include consideration of factors such as:
• the subrecipient’s prior experience with the same or similar subawards;
• the results of previous audits, including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of

2 CFR part 200, and the extent to which the same or similar subaward has been audited as a major program;
• whether the subrecipient has new personnel or new or substantially changed systems; and
• the extent and results of previous HUD monitoring, if the subrecipient also receives funds directly from HUD.
[24 CFR 576.407(c); 2 CFR 200.331(b)]

Yes No N/A
Describe Basis for Conclusion:

44. For
each subaward provided to a subrecipient, has the pass-through entity clearly identified it as a subaward to a subrecipient and included the following information at the
time of the subaward:
a. Federal award identification?
b. Subrecipient name (which must match the name associated with the unique entity identifier)?
c. Subrecipient’s unique entity identifier?
d. HUD award identification number?
e. Federal award date, as defined in 2 CFR 200.39 (the date that HUD signed the award to the recipient)?
f. Subaward period of performance start and end date?
g. Total amount of the Federal award committed to the subrecipient by the pass-through entity?
h. Amount of Federal funds obligated by this action by the pass- through entity to the subrecipient?
i. Total amount of Federal funds obligated to the subrecipient by the pass-through entity,
including the
current obligation?

02/2017 28-12

Yes No
N/A

28-13 02/2017

Exhibit 28-3 6509.2 REV-7
Emergency Solutions Grants

j. Federal Award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA)?
k. HUD’s name, the name of the pass-through entity, and contact information for the awarding official of the pass-through entity? l. Catalog of Federal Domestic Assistance (CFDA) number and name of the HUD program under which the award is made?
m. Identification of whether the award is Research & Development (R&D), if applicable?
n. Indirect cost rate for the HUD award to the recipient? o. Indirect cost rate for the subaward (which must be an approved Federally-recognized indirect cost rate negotiated between the subrecipient and the Federal government or, if no such rate exists, either a rate negotiated between the pass-through entity and the subrecipient (in compliance with 2 CFR part 200), or a de minimis indirect cost rate as defined in §200.414(f))?
p. All requirements imposed by the pass-through entity on the subrecipient so that the subaward is used in accordance with the Federal statutes, regulations, and the terms and conditions of the HUD award to the recipient?
q. Any additional requirements imposed by the pass-through entity on the subrecipient in order for the pass-through entity to meet its own obligations under the ESG program, including identification of any required financial or performance reports?
r. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet its requirements under 2 CFR part 200?
s. Appropriate terms and conditions concerning closeout of the subaward?
[24 CFR 576.407(c); 2 CFR 200.331(a)]

Describe Basis for Conclusion:

45. a. For subawards provided to subrecipients, has the pass-through entity monitored the activities of the subrecipient as necessary, to ensure that the subaward was used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are being, or have been,

achieved?
[24 CFR 576.407(c); 2 CFR 200.331(d)]

Yes No N/A
Describe Basis for Conclusion:

02/2017 28-14

6509.2 REV-7 Exhibit 28-3
Emergency Solutions Grants

b. Did the pass-through entity’s monitoring of the subrecipient include:
• Reviewing financial and performance reports required by the pass- through entity?
• Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the subaward detected through audits, on-site reviews, or other means? • Issuing a management decision for audit findings pertaining to the subaward a required by 2 CFR 200.521?
[24 CFR 576.407(c); 2 CFR 200.331(d)(1) – (3)]

Yes No N/A
Describe Basis for Conclusion:

46. a. For each subrecipient provided a subaward, has the pass-through entity determined whether the subrecipient met or exceeded the audit threshold set in 2 CFR 200.501 for the respective fiscal year?
[24 CFR 576.407(c); 2 CFR 200.331(f)]

Yes

No

N/A
Describe Basis for Conclusion:
b. If a subrecipient meets the audit threshold in 2 CFR 200.501, has the pass-through entity verified that the subrecipient is audited as required by Subpart F of 2 CFR part 200?
[24 CFR 576.407(c); 2 CFR 200.331(f)]

Yes

No

N/A
Describe Basis for Conclusion:

47. For each subrecipient receiving a subaward, has the pass-through entity considered whether the results of the subrecipient’s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity’s own records?
[24 CFR 576.407(c); 2 CFR 200.331(g)]

Yes No N/A
Describe Basis for Conclusion:

48. If the pass-through entity found any subrecipient non-noncompliant, did the pass-through entity consider taking enforcement action against the subrecipient per 2 CFR 200.338 and the program regulations? [24 CFR 576.407(c); 2 CFR 200.331(h)]

Yes No N/A
Describe Basis for Conclusion:

Exhibit 28-6 6509.2 REV-6 CHG-2
Emergency Solutions Grants

Guide for Review of ESG Rapid Re-housing and Homelessness Prevention Requirements Name of Recipient:

Name of Subrecipient(s):

Staff Consulted:

Name(s) of Reviewer(s) Date
NOTE: All questions that address requirements contain the citation for the source of the requirement (statute, regulation, or grant agreement). If the requirement is not met, HUD must select “NO” in response to the question and make a finding of noncompliance. All other questions that do not contain the citation for the requirement do not address requirements, but are included to assist the reviewer in understanding the participant's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding." Instructions: This Exhibit is designed to assess the recipient’s compliance with the Rapid Re- housing and/or Homelessness Prevention component(s) of the Emergency Solutions Grant (ESG) program. The eligible activity areas of review include: Housing Relocation and Stabilization Services – Services; Housing Relocation and Stabilization Services – Financial Assistance; and Short- and Medium-term Rental Assistance. These activities are eligible when necessary to either (1) help a homeless individual or family move as quickly as possible into permanent housing and achieve stability in that housing, or (2) prevent an individual or family from moving into an emergency shelter or another place described in paragraph (1) of the “homeless” definition in 24 CFR 576.2. The Exhibit is divided into three sections: General Requirements; Housing Relocation and Stabilization Services; and Short- and Medium-term Rental Assistance.

Section B is broken down into sub-sections for Financial Assistance Costs and Services Costs.

Section C is broken down into sub-sections for General Requirements and Project-based Rental Assistance. Every question has a header identifying the specific area of review. If the ESG recipient has not funded a particular activity or cost, check the N/A box and continue on to the next section, sub-section, or question of the Exhibit.

This Exhibit can be used to monitor a recipient, a single subrecipient, or multiple subrecipients.

It is the responsibility of the HUD reviewer to ensure that the responses provide sufficient documentation to support the basis for the conclusions. Keep in mind that, if multiple entities are reviewed and a deficiency is identified for a single entity, a “No” response is required.

Questions:

A. GENERAL REQUIREMENTS

1. Initial Evaluation: Did the recipient or its subrecipient conduct an initial evaluation to determine each individual’s or family’s eligibility for rapid re-housing or homelessness prevention assistance and the amount and types of assistance the individual or family needs to regain stability in permanent housing?
[24 CFR 576.401(a)]

Yes No N/A
Describe Basis for Conclusion:
28-1 12/2015

6509.2 REV-6 CHG-2 Exhibit 28-6
Emergency Solutions Grants

2. Eligibility Criteria (Homelessness Prevention): Did the recipient or its subrecipient document that all program participants who received homelessness prevention assistance:
a. met the eligibility criteria of the “at risk of homelessness” definition or categories 2, 3, or 4 (if category 4, not sleeping in a place described in category (1)) of the “homeless” definition; and
b. have an annual income (as determined in accordance with 24 CFR 5.609) below 30% AMI?
[24 CFR 576.103; 24 CFR 576.401(c); 24 CFR 576.500(b); 24 CFR 576.500(c); 24 CFR 576.500(e); 24 CFR 576.500(f)]

Yes No N/A
Describe Basis for Conclusion:

3. Eligibility Criteria (Rapid Re-housing): Did the recipient or its subrecipient document that all program participants who received rapid re-housing assistance met the eligibility criteria:
a. under category (1) of the homeless definition, or
b. under category (4) and live in an emergency shelter or place described in category (1) of the homeless definition?
[24 CFR 576.104; 24 CFR 576.500(b); 24 CFR 576.500(f)]

Yes No N/A
Describe Basis for Conclusion:

4. Re-evaluations (Rapid Re-housing/Homelessness Prevention): Do program participant records document that the recipient or its subrecipient re-evaluated program participants’ eligibility and the types and amounts of assistance the program participant needs not less than once every 3 months for program participants receiving homelessness prevention assistance and not less than once annually for program participants receiving rapid re-housing assistance?
[24 CFR 576.401(b)(1); 24 CFR 576.500(f)]

Yes No N/A
Describe Basis for Conclusion:

12/2015 28-2

Exhibit 28-6 6509.2 REV-6 CHG-2
Emergency Solutions Grants

5. Written Standards:
a. Did the recipient and/or its subrecipients adopt written standards for the provision of homelessness prevention and rapid re-housing assistance, as required by 24 CFR 576.400(e)(1) and 24 CFR 576.400(e)(2)? b. Did these written standards cover the following topics (listed in 24 CFR 576.400(e)(3)):

1. evaluating individuals’ and families’ eligibility for assistance under ESG;

2. coordination among emergency shelter providers, essential services providers, homelessness prevention and rapid re-housing assistance providers, other homeless assistance providers, and mainstream service and housing providers;

3. determining and prioritizing which eligible families and individuals would receive homelessness prevention assistance and which eligible families and individuals would receive rapid re-housing assistance;

4. determining what percentage or amount of rent and utilities costs each program participant must pay while receiving homelessness prevention or rapid re-housing assistance;

5. determining how long the program participant will be provided with rental assistance and whether and how the amount of that assistance would be adjusted over time;

6. determining the type, amount, and duration of housing stabilization and/or relocation services to provide to the program participant? c. Do the program participant records show that homelessness prevention and rapid re-housing assistance were provided in accordance with the applicable written standards?
[24 CFR 576.400(e)(1); 24 CFR 576.400(e)(2); 24 CFR 576.400(e)(3)(i); 24 CFR 576.400(e)(3)(v); 24 CFR 576.400(e)(3)(vi); 24 CFR
576.400(e)(3)(vii); 24 CFR 576.400(e)(3)(viii); 24 CFR 576.400(e)(3)(ix); 24 CFR 576.500(f)]

Yes No N/A
Describe Basis for Conclusion:

6. Re-evaluations (Rapid Re-housing/Homelessness Prevention): Do program participant records document that each re-evaluation of eligibility established that the program participant:
a. did not have an annual income that exceeds 30% AMI as established by HUD; and
b. lacked sufficient resources and support networks necessary to retain housing without ESG assistance?
[24 CFR 576.401(b)(1)(i)-(ii); 24 CFR 576.500(e); 24 CFR 576.500(f)]

Yes No N/A
Describe Basis for Conclusion:

28-3 12/2015

6509.2 REV-6 CHG-2 Exhibit 28-6
Emergency Solutions Grants

7. Recordkeeping (Ineligibility): For each individual and family determined ineligible to receive ESG assistance, did the recipient or its subrecipient document the reason for that determination?
[24 CFR 576.500(d)]

Yes No N/A
Describe Basis for Conclusion:

8. Eligible Costs (Homelessness Prevention): Were all homelessness prevention costs eligible and necessary to help the program participant regain stability in the program participant’s current housing or to move into other permanent housing and achieve stability in that housing? [24 CFR 576.103; 24 CFR 576.500(f)]

Yes No N/A
Describe Basis for Conclusion:

9. Housing Stability Case Management: While providing rapid re-housing or homelessness prevention assistance to a program participant, does the program participant file document that the program participant met with a case manager at least once per month to assist the participant in ensuring long-term housing stability?
[24 CFR 576.401(e)(1); 24 CFR 576.500(f)]

Yes No N/A
Describe Basis for Conclusion:

10. Housing Stability Case Management: While providing rapid re-housing or homelessness prevention assistance to a program participant, did the recipient or its subrecipient document in the program participant’s file that it developed a plan to assist the program participant to retain permanent housing after the ESG assistance ends, taking into account all relevant considerations, such as the program participant’s current or expected income and expenses, other public or private assistance for which the program participant will be eligible and likely to receive; and the relative affordability of available housing in the area?
[24 CFR 576.401(e)(2); 24 CFR 576.500(f)]

Yes No N/A
Describe Basis for Conclusion:

12/2015 28-4

Exhibit 28-6 6509.2 REV-6 CHG-2
Emergency Solutions Grants

11. Connections to Mainstream and Other Resources: While providing rapid re-housing or homelessness prevention assistance to program participants, did the recipient or its subrecipients assist each program participant to obtain mainstream and other resources as needed?
[24 CFR 576.401(d)(1); 24 CFR 576.401(d)(2); 24 CFR 576.500(f)]

Yes No N/A
Describe Basis for Conclusion:

12. Recordkeeping (Program Participant Records): Did each program participant record document:
a. the services and assistance provided to that program participant, including, as applicable, security deposit, rental assistance, and utility payments made on behalf of the program participant; and b. compliance with all applicable requirements for providing services and assistance to that program participant?
[24 CFR 576.500(f)]

Yes No N/A
Describe Basis for Conclusion:

13. Terminating Assistance:
a. If the recipient or any of its subrecipients terminated any participants from the program, did they do so in accordance with a formal process established by the recipient or its subrecipient(s) that recognizes the rights of individuals affected, that met the following requirements:
(1) written notice to the program participant containing a clear statement of the reasons for termination,
(2) a review of the decision, in which the program participant is given the opportunity to present written or oral objections before a person other than the person (or a subordinate) who made or approved the termination decision, and
(3) prompt written notice of the final decision to the program participant?
b. Did the recipient and/or its subrecipient examine all extenuating circumstances in determining when violations warrant termination so that a program participant’s assistance is terminated only in the most severe cases?
[24 CFR 576.402(a); 24 CFR 576.402(b)]

Yes No N/A
Describe Basis for Conclusion:

28-5 12/2015

6509.2 REV-6 CHG-2 Exhibit 28-6
Emergency Solutions Grants

14. Lead-Based Paint: Where ESG funds were used for rental assistance (TBRA or PBRA) or supportive services, do records reflect that the recipient and subrecipient complied with all lead-based paint requirements? NOTE: Exhibit 24-2 (Supportive Services), Exhibit 24-3 (TBRA), or Exhibit 24-4 (PBRA), as applicable, MUST be completed to answer this question. See Chapter 24, Lead-Based Paint Compliance, in this Handbook.
[24 CFR 35.700-730 (PBRA); 24 CFR 35.1000-1020 (Supportive Services); 24 CFR 35.1200-1225 (TBRA); 24 CFR 576.403(a)]

Yes No N/A
Describe Basis for Conclusion:

15. Minimum Habitability Standards: Did the recipient and its subrecipients ensure that all housing units met the minimum habitability standards before incurring any costs to help program participants remain in or move into those housing units?
[24 CFR 576.403(c); 24 CFR 576.500(j)]

Yes No N/A
Describe Basis for Conclusion:

16. Conflicts of Interest (Organizational): Did the recipient and its subrecipients ensure that:
a. no type or amount of ESG assistance was conditioned on an individual or family’s acceptance of housing owned by the recipient, subrecipient, contractor, parent, or subsidiary of the subrecipient; and b. no subrecipient (nor any of its parent or subsidiary organizations) that owns housing, carried out the initial evaluation under 24 CFR 576.401, or administered homelessness prevention assistance for occupants of that subrecipient’s housing?
[24 CFR 576.404(a)]

Yes No N/A
Describe Basis for Conclusion:

12/2015 28-6

Exhibit 28-6 6509.2 REV-6 CHG-2
Emergency Solutions Grants

B. HOUSING RELOCATION AND STABILIZATION SERVICES

Financial Assistance Costs: If the recipient has not expended ESG funds on Financial Assistance costs, check the N/A boxes and skip to the Services Costs subsection of this Exhibit.

17. Financial Assistance Costs: Did the recipient and its subrecipients ensure that:
a. no program participant received financial assistance under 24 CFR 576.105(a) that was of the same type of assistance that the program participant was receiving through other public sources; and b. no program participant who received replacement housing payments under the Uniform Relocation Act (URA) received financial assistance under 24 CFR 576.105(a) during the period of time covered by the URA payments?
[24 CFR 576.105(d)]

Yes No N/A
Describe Basis for Conclusion:

18. Financial Assistance Costs: Were eligible costs listed in 24 CFR 576.105(a) paid only to a housing owner, utility company, or other third party (not directly to the program participant)?
[24 CFR 576.105(a)]

Yes No N/A
Describe Basis for Conclusion:

19. Financial Assistance Costs (Rental Housing Application Fees): Were rental housing application fees paid for with ESG funds a standard charge issued by the owner to all applicants?
[24 CFR 576.105(a)(1)]

Yes No N/A
Describe Basis for Conclusion:

28-7 12/2015

6509.2 REV-6 CHG-2 Exhibit 28-6
Emergency Solutions Grants

20. Financial Assistance Costs (Security Deposits): Were security deposits paid for with ESG funds equal to no more than 2 months’ rent? [24 CFR 576.105(a)(2)]

Yes No N/A
Describe Basis for Conclusion:

21. Financial Assistance Costs (Last Month’s Rent): Were costs for the last month’s rent paid for with ESG funds:
a. necessary to obtain housing for a program participant; b. paid to the owner of the housing at the time the owner was paid the security deposit and first month’s rent;
c. less than or equal to one month’s rent; and
d. included in calculating the program participant’s total rental assistance? [24 CFR 576.105(a)(3)]

Yes No N/A
Describe Basis for Conclusion:

22. Financial Assistance Costs (Utility Deposits): Were utility deposits paid for with ESG funds only for eligible types of utility services (gas, electric, water, and sewage) and required by the utility company for all customers? [24 CFR 576.105(a)(4)]

Yes No N/A
Describe Basis for Conclusion:

23. Financial Assistance Costs (Utility Payments): Were utility payments paid for with ESG funds:
a. within the limit of 24 months of utility payments per program participant, per service, including up to 6 months of utility payments in arrears, per service;
b. only provided when the program participant or a member of the same household has an account in his or her name with a utility company or proof of responsibility to make utility payments; and
c. only for eligible types of utility services (gas, electric, water, and sewage)?
[24 CFR 576.105(a)(5)]

Yes No N/A
Describe Basis for Conclusion:

12/2015 28-8

Exhibit 28-6 6509.2 REV-6 CHG-2
Emergency Solutions Grants

24. Financial Assistance Costs (Moving Costs): Were moving costs paid for with ESG funds only for moving-related activities such as truck rental, hiring a moving company, and allowable temporary storage fees (up to 3 months, fees accrued after the date the program participant began receiving services and before the program participant moves into permanent housing, and excluding storage fees in arrears)?
[24 CFR 576.105(a)(6)]

Yes No N/A
Describe Basis for Conclusion:

Services Costs: If the recipient has not expended ESG funds on Services costs, check the N/A boxes and skip to the Short- and Medium-Term Rental Assistance section of this Exhibit (Section C).

25. Services Costs (Housing Search and Placement): Were housing search and placement costs paid for with ESG funds:
a. necessary to assist program participants in locating, obtaining, and retaining suitable permanent housing; and
b. one of those listed in 24 CFR 576.105(b)(1)(i)-(viii)? [24 CFR 576.105(b)(1)]

Yes No N/A
Describe Basis for Conclusion:

26. Services Costs (Housing Stability Case Management): Were the activities paid for with ESG funds:
a. one of those listed in 24 CFR 576.105(b)(2)(A)-(H), and b. for the purposes of assessing, arranging, coordinating, or monitoring the delivery of individualized services to:
(1) facilitate housing stability for a program participant who resides in permanent housing; or
(2) to assist a program participant in overcoming immediate barriers to obtaining housing?
[24 CFR 576.105(b)(2)(A)-(H)]

Yes No N/A
Describe Basis for Conclusion:

28-9 12/2015

6509.2 REV-6 CHG-2 Exhibit 28-6
Emergency Solutions Grants

27. Services Costs (Housing Stability Case Management): Were the housing stability case management costs paid for with ESG funds:
a. under the Rapid Re-housing component, limited to:
(1) 30 days during the period the program participant is seeking permanent housing; and
(2) 24 months during the period the program participant is living in permanent housing; and
b. under the Homelessness Prevention component, limited to 24 months? [24 CFR 576.105(b)(2)]

Yes No N/A
Describe Basis for Conclusion:

28. Services Costs (Mediation Costs): Were mediation costs paid for with ESG funds necessary to prevent the program participant from losing permanent housing in which the program participant currently resides, and used for mediation between the program participant and the owner or person(s) with whom the participant is living?
[24 CFR 576.105(b)(3)]

Yes No N/A
Describe Basis for Conclusion:

29. Services Costs (Legal Services): Did the recipient and its subrecipients ensure that the legal services costs paid for with ESG funds consisted only of the following types of costs:
a. for either: hourly fees for legal advice and representation by attorneys licensed and in good standing with the bar association of the State in which the services are provided, or by person(s) under the supervision of the licensed attorney; or fees based on the actual service performed (i.e., fee for service), where the recipient/ subrecipient documented that such costs were less than what the cost of hourly fees would have been; b. for filing fees and other necessary court costs;
c. subrecipients’ employees’ salaries and other costs necessary to perform the services (if the subrecipient is a legal services provider and performs the services itself); and
d. for the following component services:
(1) client intake;
(2) preparation of cases for trial;
(3) provision of legal advice;

Yes No N/A

12/2015 28-10

Exhibit 28-6 6509.2 REV-6 CHG-2
Emergency Solutions Grants

(4) representation at hearings;
(5) counseling?
[24 CFR 576.102(a)(1)(vi)(A); 24 CFR 576.102(a)(1)(vi)(D); 24 CFR 576.102(a)(1)(vi)(E); 24 CFR 576.105(b)(4)]

Describe Basis for Conclusion:

30. Services Costs (Legal Services): Did the recipient and its subrecipients ensure that the legal services costs paid for with ESG funds were only used:
a. to the extent necessary to resolve a legal problem that prohibits the program participant from obtaining permanent housing or will likely result in the program participant losing the permanent housing in which they currently reside;
b. for the following subject matters:
(1) landlord/tenant matters;
(2) child support;
(3) guardianship;
(4) paternity;
(5) emancipation;
(6) legal separation;
(7) orders of protection and other civil remedies for victims of domestic violence, dating violence, sexual assault, and stalking; (8) appeal of veterans and public benefit claim denials; and (9) the resolution of outstanding criminal warrants; and c. to the extent that other appropriate legal services were unavailable or inaccessible in the community?
[24 CFR 576.105(b)(4); 24 CFR 576.102(a)(1)(vi)(B); 24 CFR 576.102(a)(1)(vi)(C)]

Yes No N/A
Describe Basis for Conclusion:

31. Services Costs (Credit Repair): Were credit repair costs paid for with ESG funds for counseling or other services necessary to assist program participants with critical skills related to household budgeting, managing money, accessing a free personal credit report, or resolving personal credit problems?
[24 CFR 576.105(b)(5)]

Yes No N/A
Describe Basis for Conclusion:
28-11 12/2015

6509.2 REV-6 CHG-2 Exhibit 28-6
Emergency Solutions Grants

32. Services Costs (Credit Repair): Did credit repair costs paid for with ESG funds exclude the payment or modification of a debt?
[24 CFR 576.105(b)(5)]

Yes No N/A
Describe Basis for Conclusion:

C. SHORT- AND MEDIUM-TERM RENTAL ASSISTANCE
General Requirements: If the recipient has not expended ESG funds on Short- or Medium- Term Rental Assistance, check the N/A boxes and skip to the next section.

33. Rental Assistance (Limit): Did each program participant’s total rental assistance, including any rental arrears and last month’s rent, stay within the limit of 24 months during any 3-year period?
[24 CFR 576.106(a)]

Yes No N/A
Describe Basis for Conclusion:

34. Rental Assistance (Changes in Household Composition): Did the recipient and its subrecipients apply the limits on rental assistance to the total assistance each individual received, either as an individual or as part of a household?
[24 CFR 576.106(j)]

Yes No N/A
Describe Basis for Conclusion:

35. Rental Assistance (Use with Other Subsidies): Except for a one-time payment of rental arrears on the tenant’s portion of the rental payment, did the provision of rental assistance exclude:
a. program participants who were receiving tenant-based rental assistance or living in a housing unit receiving project-based rental assistance or operating assistance through other public sources; and
b. program participants who were provided with replacement housing payments under the URA during the period of time covered by the URA payments?
[24 CFR 576.106(c)]

Yes No N/A
Describe Basis for Conclusion:

12/2015 28-12

Exhibit 28-6 6509.2 REV-6 CHG-2
Emergency Solutions Grants

36. Rental Assistance (Fair Market Rent and Rent Reasonableness): Did the recipient and its subrecipients ensure that ESG rental assistance was only provided to units for which the rent complied with HUD's standard of rent reasonableness and did not exceed the applicable Fair Market Rent? NOTE: For this purpose, rent equals the sum of the total monthly rent for the unit, any fees required for occupancy under the lease (other than late fees and pet fees) and, if the tenant paid separately for utilities, the monthly allowance for utilities (excluding telephone) established by the public housing authority for the area in which the housing is located. [24 CFR 576.106(d)(1); 24 CFR 576.106(d)(2); 24 CFR 576.500(i)]

Yes No N/A
Describe Basis for Conclusion:

37. Rental Assistance (Rental Assistance Agreement): Does the documentation show that the recipient or its subrecipients entered into a rental assistance agreement with each owner before providing the owner with rental assistance payments, including rental arrears?
[24 CFR 576.106(e); 24 CFR 576.500(h)]

Yes No N/A
Describe Basis for Conclusion:

38. Rental Assistance (Rental Assistance Agreement): Did each rental assistance agreement:
a. set forth the terms under which rental assistance will be provided, including the requirements that apply under 24 CFR 576.106; b. provide that, during the term of the agreement, the owner must give the recipient or its subrecipient a copy of any notice to the program participant to vacate the housing unit, or any complaint used under state or local law to commence an eviction action against the program participant; and
c. contain the same payment due date, grace period, and late payment penalty requirements as the program participant’s lease? [24 CFR 576.106(e); 24 CFR 576.106(f)]

Yes No N/A
Describe Basis for Conclusion:
28-13 12/2015

6509.2 REV-6 CHG-2 Exhibit 28-6
Emergency Solutions Grants

39. Rental Assistance (Payments): Did the recipient or its subrecipient make timely payments to each owner in accordance with the rental assistance agreement?
[24 CFR 576.106(f)]

Yes No N/A
Describe Basis for Conclusion:

40. Rental Assistance (Payments): Did the recipient and its subrecipients pay any late payment penalties that they incurred only with non-ESG funds (i.e., no ESG funds were used to pay late payment penalties incurred by the recipient or subrecipient)?
[24 CFR 576.106(f)]

Yes No N/A
Describe Basis for Conclusion:

41. Rental Assistance (Leases):
a. Does each program participant receiving rental assistance have a file that contains a legally binding, written lease between the program participant and the owner of the property or his/her agent for the rental unit; OR
b. If the assistance was solely for rental arrears for a program participant who had an oral lease agreement in place:
(1) does each agreement give the program participant an enforceable leasehold interest under state law; and
(2) are the agreement and rent owed sufficiently documented by the owner’s financial records, rent ledgers, or canceled checks? [24 CFR 576.106(g); 24 CFR 576.500(h)]

Yes No N/A
Describe Basis for Conclusion:

42. Rental Assistance (Rental Arrears): Were the rental arrears paid for with ESG funds one-time payments that did not exceed 6 months of rent in arrears (including any late fees on those arrears)?
[24 CFR 576.106(a)(3)]

Yes No N/A
Describe Basis for Conclusion:

12/2015 28-14

Exhibit 28-6 6509.2 REV-6 CHG-2
Emergency Solutions Grants

43. Recordkeeping (Homelessness Prevention and Rapid Re-housing): Did the recipient or its subrecipient keep records, including copies of documentation of payments made to owners for rental assistance provided, and supporting documentation for these payments, including dates of occupancy by program participants?
[24 CFR 576.500(h)]

Yes No N/A
Describe Basis for Conclusion:

44. Rental Assistance (TBRA): For tenant-based rental assistance, did the recipient and its subrecipients terminate the rental assistance agreement with the owner and stop providing rental assistance payments under that agreement when any of the following conditions were met:
a. the program participant moved out of the unit for which the program participant has a lease;
b. the lease terminated and was not renewed; or
c. the program participant became ineligible to receive ESG assistance? [24 CFR 576.106(h)(3)(i)-(iii)]

Yes No N/A
Describe Basis for Conclusion:

Project-Based Rental Assistance (PBRA): If the recipient has not expended funds on PBRA, check the N/A boxes. This is the final subsection of the Exhibit.

45. Rental Assistance (Project-based Rental Assistance): If the recipient or any of its subrecipients used ESG funds to pay the rent for a project-based unit before a program participant moved into the unit, does the program participant file reflect that :
a. the program participant signed a lease and moved into the unit before the end of the month for which the first month’s rent was paid; and b. the amount paid was less than or equal to the rent to be charged under the program participant’s lease and included when determining that program participant’s total rental assistance?
[24 CFR 576.106(i)(2)]

Yes No N/A
Describe Basis for Conclusion:

28-15 12/2015

6509.2 REV-6 CHG-2 Exhibit 28-6
Emergency Solutions Grants

46. Rental Assistance (PBRA): Did the recipient and its subrecipients make monthly rental assistance payments only for months when a unit was leased to a program participant (either partial or the whole month)? [24 CFR 576.106(i)(3)]

Yes No N/A
Describe Basis for Conclusion:

47. Rental Assistance (PBRA): For program participants living in housing with project-based rental assistance, does the program participant’s file contain a lease with an initial term of at least 1 year AND did the recipient or its subrecipient (whoever signed the agreement) enter into a rental assistance agreement with the owner for an initial term of 1 year? [24 CFR 576.106(g); 24 CFR 576.106(i)(5)]

Yes No N/A
Describe Basis for Conclusion:

48. Rental Assistance (PBRA): If a program participant was determined ineligible or reaches the maximum number of months over which rental assistance could be provided, did the recipient or its subrecipient suspend or terminate the rental assistance payments for the unit?
[24 CFR 576.106(i)(4)]

Yes No N/A
Describe Basis for Conclusion:

49. Rental Assistance (PBRA): Did the recipient and its subrecipients ensure that the term of occupancy in each program participant’s lease was not conditioned on the provision of rental assistance payments, and if ESG- funded rental assistance was suspended, was the program participant allowed to remain in the unit as permitted under the lease? [24 CFR 576.106(i)(4)]

Yes No N/A
Describe Basis for Conclusion:

50. Rental Assistance (PBRA – Expenditure Deadline): Did the recipient and its subrecipients commit ESG funds only to be expended:
a. within the expenditure deadline in 24 CFR 576.203; and b. for current ESG grants (i.e., not before a grant is awarded)? [24 CFR 576.106(i)(5)]

Yes No N/A
Describe Basis for Conclusion:

12/2015 28-16

Exhibit 28-8 6509.2 REV-7
Emergency Solutions Grants

Guide for Review of ESG Financial Management and Cost Allowability Name of Recipient:

Name of Subrecipient(s):

Grant Number:

Staff Consulted:

Name(s) of Reviewer(s) Date
NOTE: All questions that address requirements contain the citation for the source of the requirement (statute and regulation). If the requirement is not met, HUD must select “NO” in response to the question and make a finding of noncompliance. All other questions (questions that do not contain the citation for the requirement) do not address requirements, but are included to assist the reviewer in understanding the participant's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding." Instructions: This Exhibit is designed to assess a recipient’s and/or its subrecipient’s financial management system, as well as the eligibility of the program’s expenditures. Note: This Exhibit is designed only to monitor compliance with the ESG interim rule, the Uniform Administrative Requirements (24 CFR part 84 and 85), and the cost principles at 2 CFR part 225 (OMB Circular A-87) and 2 CFR part 230 (OMB Circular A-122), as in effect prior to December 26, 2014.

Accordingly, this Exhibit includes citations to regulations and OMB Circulars that pre-dated HUD’s implementation of 2 CFR Part 200 (e.g., 24 CFR Part 576 (2013 edition), OMB Circular A-87, 24 CFR Part 85 (2013), 24 CFR Part 84 (2013), and OMB Circular A-122). CPD staff should use the citations in this Exhibit when making findings.

To monitor compliance with the new requirements at 2 CFR part 200, the HUD reviewer must complete Exhibit 34-1, Guide for Review of Financial Management and Audits and Exhibit 34-2, Guide for Review of Cost Allowability. For HUD’s expectations on monitoring for compliance with the uniform administrative requirements, cost principles, and audit requirements during the period of transition to 2 CFR part 200, please see HUD’s April 13, 2016, Notice CPD-16-04 (http://portal.hud.gov/hudportal/documents/huddoc?id=16-04cpdn.pdf ). When completing this
Exhibit or Exhibits 34-1 and 34-2, the HUD reviewer must also complete Exhibit 28-7, Guide for Review of ESG Match Requirements.

This Exhibit can be used to either monitor the recipient alone, the recipient with a single subrecipient, or the recipient with multiple subrecipients. It is the responsibility of the HUD reviewer to ensure that the responses provide sufficient documentation to support the basis for the conclusions. Keep in mind that, if multiple entities are reviewed and a deficiency is identified for a single entity, a “No” response is required.

Questions:

1. Did the recipient and its subrecipients have written policies and procedures to ensure that ESG funds are used in accordance with ESG requirements and sufficient records to enable HUD and the recipient to determine whether ESG requirements are being met?
[24 CFR 576.500(a)]

Yes No N/A
Describe Basis for Conclusion:

28-1 02/2017

6509.2 REV-7 Exhibit 28-8
Emergency Solutions Grants

2. Did the recipient and its subrecipients maintain records that identify adequately the source and application of funds for federally-sponsored activities?
NOTE: These records shall contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, outlays, income and interest.
[24 CFR 576.407(c); 24 CFR 576.500(s)(2); 24 CFR 84.21(b)(2); 24 CFR

85.20]

Yes No N/A
Describe Basis for Conclusion:

3. Eligible Activities: Are the recipient’s and its subrecipients’ expenses allowable, allocable, and reasonable?
[24 CFR 576.100-576.109; 24 CFR 576.500(u)(2); 24 CFR 84.21(b)(6); 24 CFR 85.22]

Yes No N/A
Describe Basis for Conclusion:

4. Do the fiscal records indicate evidence that the recipient and its subrecipients have effective internal control over, and accountability of, all grant funds, property and other assets?
[24 CFR 576.500(u); 24 CFR 84.21(b)(3); 24 CFR 85.20]

Yes No N/A
Describe Basis for Conclusion:

Internal Controls (Reference for some of the questions: GAO/AIMD-98-21.2.1, “Framework for Federal Financial Management System Checklist,” May 1998)

5. a. Do the recipient and its subrecipients have an organization chart that illustrates the actual lines of authority/responsibility?

Yes No N/A
Describe Basis for Conclusion:

b. Are primary duties for key employees of the recipient and its subrecipients defined?

Yes No N/A
Describe Basis for Conclusion:
02/2017 28-2

Exhibit 28-8 6509.2 REV-7
Emergency Solutions Grants

c. Does the recipient’s and its subrecipients’ chart of accounts include a complete listing of the account numbers used to support the control required to ensure that resources used do not exceed resources authorized?

Yes No N/A
Describe Basis for Conclusion:

d. Do the approval controls provide reasonable assurance that appropriate individuals approve recorded transactions in accordance with management’s general or specific criteria?

Yes No N/A
Describe Basis for Conclusion:

e. Do the controls over the design and use of documents and records provide reasonable assurance that transactions and events are properly documented, recorded, and auditable?

Yes No N/A
Describe Basis for Conclusion:

f. In the normal course of the position’s requirements, are duties segregated to effectively reduce the opportunity for someone to perpetrate or conceal errors or irregularities?

Yes No N/A
Describe Basis for Conclusion:

g. Is it clear that all personnel are responsible for communicating to appropriate supervisory officials the recipient’s or its subrecipients’ operating problems and noncompliance with laws and regulations?

Yes No N/A
Describe Basis for Conclusion:

h. Do the internal control procedures support the ability to prepare financial statements that are accurately presented in conformity with generally accepted or other relevant and appropriate accounting principles and regulatory requirements? (One level of assurance of the accuracy and integrity of data is provided by the recipient attaining an unqualified opinion on the audited annual financial statements and internal controls.)

Yes No N/A
Describe Basis for Conclusion:

28-3 02/2017

6509.2 REV-7 Exhibit 28-8
Emergency Solutions Grants

6. Do the recipient and its subrecipients identify expenditures in their accounting records according to eligible program activities identified in the program regulation, the recipient’s Action Plan, and the drawdown activity information?
[24 CFR 576.100; 24 CFR 576.500(u); 24 CFR 84.21(b)(2); 24 CFR 85.20]

Yes No N/A
Describe Basis for Conclusion:

7. Does a review of the sample transaction records indicate that grant expenditures were eligible costs under regulations, were necessary and reasonable for proper and efficient administration of the program, were allocable to the program, and supported by adequate source documentation (invoices, contracts, or purchase orders)?
[24 CFR 576.100-576.109; 24 CFR 576.500(u); 24 CFR 84.21(b); 24 CFR

85.20(b)]

Yes No N/A
Describe Basis for Conclusion:

8. Does the source documentation support the amount drawn down from the payment requests?
[24 CFR 576.500(u); 24 CFR 84.21(b); 24 CFR 85.20]

Yes No N/A
Describe Basis for Conclusion:

9. Do the recipient’s financial information (e.g., drawdowns, unexpended balances) records match the information in HUD’s financial systems (e.g., Line of Credit Control System (LOCCS), Integrated Disbursement and Information System (IDIS)) for the period under review? [24 CFR 576.500(aa); 24 CFR 85.20]

Yes No N/A
Describe Basis for Conclusion:

10. Are payments for salaries and wages supported by documented payrolls and personnel activity reports as specified in the applicable cost principles? [24 CFR 576.500(u)(2); OMB Circular A-122, Attachment B, 8(m); OMB Circular A-87, Attachment B, 8(h)]

Yes No N/A
Describe Basis for Conclusion:

02/2017 28-4

Exhibit 28-8 6509.2 REV-7
Emergency Solutions Grants

11. Are charges to the grant by both governmental units and nonprofit organizations for salaries and wages, whether treated as direct or indirect costs, based on payrolls documented in accordance with generally accepted accounting principles and approved by a responsible official(s) of the organization being monitored?
[24 CFR 576.500(u)(2); OMB Circular A-122, Attachment B, 8(m); OMB Circular A-87, Attachment B, 8(h)]

Yes No N/A
Describe Basis for Conclusion:

12. For government employees working solely on the grant, are charges for their salaries and wages supported by periodic certifications that the employees worked solely on that program for the period covered by the certification?
[24 CFR 576.500(u)(2); OMB Circular A-87, Attachment B, 8(h)(3)]

Yes No N/A
Describe Basis for Conclusion:

13. For government employees, were the certifications prepared at least semi - annually and signed by the employee or a supervisory official having first- hand knowledge of the work performed by the employee?
[24 CFR 576.500(u)(2); OMB Circular A-87, Attachment B, 8(h)(3)]

Yes No N/A
Describe Basis for Conclusion:

14. Does a random selection of administrative costs reflect that grant funds were used for eligible administrative costs?
[24 CFR 576.108; 24 CFR 84.21; 24 CFR 85.20]

Yes No N/A
Describe Basis for Conclusion:

15. Are all of the administrative costs reviewed allocable to the program, and necessary and reasonable for proper and efficient administration of the program?
[24 CFR 576.108; 24 CFR 576.500(u)(2); OMB Circular A-122; OMB Circular A-87]

Yes No N/A
Describe Basis for Conclusion:

28-5 02/2017

6509.2 REV-7 Exhibit 28-8
Emergency Solutions Grants

16. Is the recipient in compliance with the component or activity caps imposed by program regulations, and are all costs subject to the expenditure caps properly classified?
[24 CFR 576.100; 24 CFR 576.500(u)]

Yes No N/A
Describe Basis for Conclusion:

17. If the recipient advances grant funds to subrecipients, are there procedures to minimize the time elapsed between the transfer of funds to, and disbursement by, the subrecipients?
[24 CFR 576.407(c); 24 CFR 84.22(b)(1); 24 CFR 85.21(c)]

Yes No N/A
Describe Basis for Conclusion:

18. If the recipient uses advances, is there evidence that any interest earned on grant advances over the amount specified in the uniform administrative requirements has been remitted to the U.S. Treasury as required by HUD? [24 CFR 576.407(c); 24 CFR 85.21(i)]

Yes No N/A
Describe Basis for Conclusion:

19. If indirect costs are charged to the grant program by the recipient or its subrecipients, are the costs supported by an Indirect Cost Rate Proposal or Cost Allocation Plan prepared in accordance with OMB Circular A-87 (for governments) or OMB Circular A-122 (for nonprofit organizations)? [24 CFR 576.109; OMB Circular A-87; OMB Circular A-122]

Yes No N/A
Describe Basis for Conclusion:

20. a. If single audits are required, does the recipient or its subrecipients have a system or methodology to ensure that such audits are conducted? [24 CFR 576.407(c); 24 CFR 85.26; 24 CFR 84.26]

Yes No N/A
Describe Basis for Conclusion:

b. If single audits are required for any recipient or subrecipient, is there documentation that the audits have been reviewed for compliance and that the recipient or subrecipient has taken appropriate follow-up actions, if necessary?
[24 CFR 576.407(c); 24 CFR 85.26; 24 CFR 84.26]

Yes No N/A
Describe Basis for Conclusion:

02/2017 28-6

Exhibit 28-8 6509.2 REV-7
Emergency Solutions Grants

21. Do the recipient and its subrecipients maintain records of their receipt and use of program income?
[24 CFR 576.500(u)(3)]

Yes No N/A
Describe Basis for Conclusion:

22. Do the recipient and its subrecipients use program income as the nonfederal share of eligible costs (i.e., match)?
[24 CFR 576.201(f); 24 CFR 576.407(c); 24 CFR 84.24(b) or 24 CFR

85.25(g)]

Yes No N/A
Describe Basis for Conclusion:

23. Does a review of program expenditures indicate the absence of any unallowable costs including entertainment, contributions and donations, fines and penalties, or general governmental expenditures including salary and expenses of the chief executive officer of the recipient or its subrecipients?
[24 CFR 576.100(d); 24 CFR 576.500(u)(2); OMB Circular A-87 or OMB Circular A-122]

Yes No N/A
Describe Basis for Conclusion:

24. Does a review of the expenditures indicate that costs related to lobbying political activities have not been charged to the program? [24 CFR 576.100(d); 24 CFR 576.500(u)(2); OMB Circular A-87 or OMB Circular A-122]

Yes No N/A
Describe Basis for Conclusion:

28-7 02/2017

City of Berkeley – Priority Home Partnership Program File Review Check List

Last Name: First Name: HMIS ID:

Staff Name:

Supervisor Approval - Name:

I. Eligibility Documentation
ESG Application for Assistance and Eligibility Determination Form (8 pages) Rapid Rehousing Assistance

Homeless Prevention

Attached Document COB
Review
Homeless Status Supporting Documentation (Rapid Rehousing-RR) At Imminent Risk Housing Status Supporting Documentation (Homeless Prevention-HP)

Income Eligibility Supporting Documentation (RR&HP)
Asset Verification Supporting Documentation (RR&HP)
Current ROI - Date:

II. Documentation of Assistance/Ongoing Services

Attached Document COB
Review

1. Request for Tenancy Approval

2. Household Budget

3. Housing Stability Plan

4. Financial Assistance Calculation Form

5. Program Participation Agreement

6. Lease Between Participant and Landlord

7. Rental Assistance Agreement with Landlord

8. W-9 Form
Three Month Reassessment(s) (if applicable, insert dates)

1. 2.

Budget/Housing Stability Plan, if recertified for additional 3 months Exit Form (HMIS form), if exited from program.

Termination of Housing Assistance (if applicable)
Other

City of Berkeley – Priority Home Partnership Program File Review Check List

Inspection Documentation Verification

Last Name: First Name: HMIS ID:

Unit
Address:

In File Document Inspector’s
Signature
Unit
Pass
Unit Inconclusive
/Fail
Date
Rent Reasonableness

Habitability Inspection
(includes Lead
Assessment)

FMR certification

NOTES:

City of Berkeley
Program Monitoring File Checklist
Client File Reviewed: (first initial, last initial)
Staff Reviewer
Date: Case Manager:

Signature
Item (All Files) Yes No N/A Comments

Client Intake

Needs Assessment

Income Verification

Disability Verification

Homelessness Verification

Client ID

Program Participation Agreement

Notice of Grievance Policies

Notice of Privacy Policies

Release of Information

Individual Service Plan (current)

Case Notes: Documentation of case
management sessions (note frequency) and
of ongoing efforts to achieve ISP goals.

Documentation of Referrals to other needed
services

Documentation of Increased Income
Documentation of Housing Placement
(address)

Exit Documentation

Emergency Contact
Is file stored in secure area with restricted
access?

Is file organized, complete, uses standard
forms, entries legible?

File clearly notes client’s status? (active,
closed, inactive)

SHELTER OR TRANSITIONAL HOUSING SERVICES
Savings Program?
Documentation of deposits and
withdrawals?

Other Info:

Other Info:

TB Test In File

OVERALL COMMENTS

NOTATIONS ON REVIEW ITEMS
INCOME VERIFICATION: If program uses “presumed income” category, file must include verification of qualification for presumed category.

HOMELESS VERIFICATION: HUD guidelines indicate that third-party verification is best practice; self-certification and homeless history are also acceptable.

DISABILITY VERIFICATION: For programs funded to serve disabled, verification should be by a licensed professional.

City of Berkeley ESG Policies and Procedures
May 12, 2020

Excerpted ESG Interim Regulations as Applicable to Subrecipients Subpart A— General Provisions

§ 576.1 Applicability and purpose.

This part implements the Emergency Solutions Grants (ESG) program authorized by subtitle B of title IV of the McKinney - Vento Homeless Assistance Act (42 U.S.C. 11371– 11378). The program authorizes the Department of Housing and Urban Development (HUD) to make grants to States, units of general purpose local government, and territories for the rehabilitation or conversion of buildings for use as emergency shelter for the homeless, for the payment of certain expenses related to operating emergency shelters, for essential services related to emergency shelters and street outreach for the homeless, and for homelessness prevention and rapid re-housing assistance.

§ 576.2 Definitions.

At risk of homelessness means: (1) An individual or family who: Has an annual income below 30 percent of median family income for the area, as determined by HUD; Does not have sufficient resources or support networks, e.g., family, friends, faith-based or other social networks, immediately available to prevent them from moving to an emergency shelter or another place described in paragraph (1) of the ‘‘homeless’’ definition in this section; and

1. Meets one of the following conditions:
 Has moved because of economic reasons two or more times during the 60 days immediately preceding the application for homelessness prevention assistance;  Is living in the home of another because of economic hardship;  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;  Lives in a hotel or motel and the cost of the hotel or motel stay is not paid by charitable organizations or by Federal, State, or local government programs for low-income individuals;  Lives in a single-room occupancy or efficiency apartment unit in which there reside more than two persons or lives in a larger housing unit in which there reside more than 1.5 persons reside per room, as defined by the U.S. Census Bureau;
 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  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(3) 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 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 11434a(2)), and the parent(s) or guardian(s) of that child or youth if living with her or him.

Consolidated plan means a plan prepared in accordance with 24 CFR part 91. An approved consolidated plan means a consolidated plan that has been approved by HUD in accordance with 24 CFR part 91.

Continuum of Care means the group composed of representatives of relevant organizations, which generally includes 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 that are organized to plan for and provide, as necessary, a system of outreach, engagement, and assessment; emergency shelter; rapid re-housing; transitional housing; permanent housing; and prevention strategies to address the various needs of homeless persons and persons at risk of homelessness for a specific geographic area.

Emergency shelter means 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 and which does not require occupants to sign leases or occupancy agreements. Any project funded as an emergency shelter under a Fiscal Year 2010 Emergency Solutions grant may continue to be funded under ESG.

City of Berkeley ESG Policies and Procedures
May 12, 2020

Homeless means:
(1) An individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning:
(i) An individual or family with 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;
(ii) An individual or family living in a supervised publicly or privately operated shelter designated to provide temporary living arrangements (including congregate shelters, transitional housing, and hotels and motels paid for by charitable organizations or by federal, state, or local government programs for low- income individuals); or (iii) 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:
(i) The primary nighttime residence will be lost within 14 days of the date of application for homeless assistance; (ii) No subsequent residence has been identified; and
(iii) The individual or family lacks the resources or support networks, e.g., family, friends, faith-based or other social networks, needed to obtain other permanent housing;
(3) Unaccompanied youth under 25 years of age, or families with children and youth, who do not otherwise qualify as homeless under this definition, but who:
(i) Are defined as homeless under section 387 of the Runaway and Homeless Youth Act (42 U.S.C. 5732a), section 637 of the Head Start Act (42 U.S.C. 9832), section 41403 of the Violence Against Women Act of 1994 (42 U.S.C. 14043e –2), section 330(h) of the Public Health Service Act (42 U.S.C. 254b(h)), section 3 of the Food and Nutrition Act of 2008 (7 U.S.C . 2012), section 17(b) of the Child Nutrition Act of 1966 (42 U.S.C. 1786(b)) or section 725 of the McKinney -Vento Homeless Assistance Act (42 U.S.C. 11434a);
(ii) Have not had a lease, ownership interest, or occupancy agreement in permanent housing at any time during the 60 days immediately preceding the date of application for homeless assistance; (iii) 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; and (iv) Can be expected to continue in such status for an extended period of time because of c hronic disabilities, chronic physical health 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, which 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; or (4) Any individual or family who:
(i) Is fleeing, or is attempting to flee, domestic violence, dating violence, sexual assault, stalking, or other dangerous or life-threatening conditions that relate to violence against the individual or a family member, including a child, that has either taken place within the individual’s or family’s primary nighttime residence or has made the individual or family afraid to return to their primary nighttime residence;
(ii) Has no other residence; and
(iii) Lacks the resources or support networks, e.g., family, friends, faith- based or other social networks, to obtain other permanent housing.

Homeless Management Information System (HMIS) means the information system designated by the Continuum of Care to comply with the HUD’s data collection, management, and reporting standards and used to collect client- level data and data on the provision of housing and services to homeless individuals and families and persons at- risk of homelessness.

Metropolitan city means a city that was classified as a metropolitan cit y under 42 U.S.C. 5302(a) for the fiscal year immediately preceding the fiscal year for which ESG funds are made available. This term includes the District of Columbia.

Private nonprofit organization means a private nonprofit organization that is a secular or religious organization described in section 501(c) of the Internal Revenue Code of 1986 and which is exempt from taxation under subtitle A of the Code, has an accounting system and a voluntary board, and practices nondiscrimination in the provision of assistance. A private nonprofit organization does not include a governmental organization, such as a public housing agency or housing finance agency.

Program income shall have the meaning provided in 24 CFR 85.25. Program income includes any a mount of a security or utility deposit returned to the recipient or subrecipient.

Program participant means an individual or family who is assisted under ESG program.

City of Berkeley ESG Policies and Procedures
May 12, 2020

Program year means the consolidated program year established by the recipient under 24 CFR part 91.

Recipient means any State, territory, metropolitan city, or urban county, or in the case of reallocation, any unit of general purpose local government that is approved by HUD to assume financial responsibility and enters into a grant agreement with HUD to administer assistance under this part.

State means each of the several States and the Commonwealth of Puerto Rico.

Subrecipient means a unit of general purpose local government or private nonprofit organization to which a recipient makes available ESG funds.

Unit of general purpose local government means any city, county, town, township, parish, village, or other general purpose political subdivision of a State.

Urban county means a county that was classified as an urban county under 42 U.S.C. 5302(a) for the fiscal year immediately preceding the fiscal year for which ESG funds are made available.

Victim service provider means 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.

Subpart B— Program Components and Eligible Activities

§ 576.100 General provisions and expenditure limits.
(a) ESG funds may be used for five program components: street outreach, emergency shelter, homelessness prevention, rapid re-housing assistance, and HMIS; as well as administrative activities. The five program components and the eligible activities that may be funded under each are set forth in § 576.101 through § 576.107. Eligible administrative activities are set forth in § 576.108.
(b) The total amount of the recipient’s fiscal year grant that may be used for street outreach and emergency shelter activities cannot exceed the greater of:
(1) 60 percent of the recipient’s fiscal year grant; or (2) The amount of Fiscal Year 2010 grant funds committed for homeless assistance activities. (c) The total amount of ESG funds that may be used for administrative activities cannot exceed 7.5 percent of the recipient’s fiscal year grant.
(d) Subject to the cost principles in OMB Circulars A– 87 (2 CFR 225) and A–122 (2 CFR 230) and other requirements in this part, employee compensation and other overhead costs directly related to carrying out street outreach, emergency shelter, homelessness prevention, rapid re- housing, and HMIS are eligible costs of those program components. These costs are not subject to the expenditure limit in paragraph (c) of this section.

§ 576.101 Street outreach component.
(a) Eligible costs. Subject to the expenditure limit in § 576.100(b), ESG funds may be used for costs of providing essential services necessary to reach out to unsheltered homeless people; connect them with emergency shelter, housing, or critical services; and provide urgent, non-facility-based care to unsheltered homeless people who are unwilling or unable to access emergency shelter, housing, or an appropriate health facility. For the purposes of this section, the term ‘‘unsheltered homeless people’’ means individuals and families who qualify as homeless under paragraph (1)(i) of the ‘‘homeless’’ definition under § 576.2. The eligible costs and requirements for essential services consist of:
(1) Engagement. The costs of activities to locate, identify, and build relationships with unsheltered homeless people and engage them for the purpose of providing immediate support, intervention, and connections with homeless assistance programs and/or mainstream social services and housing programs. These activities consist of making an initial assessment of needs and eligibility; providing crisis counseling; addressing urgent physical needs, such as providing meals, blankets, clothes, or toiletries; and actively connecting and providing information and referrals to programs targeted to homeless people and mainstream social services and housing programs, including emergency shelter, transitional housing, community-based services, permanent supportive housing, and rapid re -housing programs. Eligible costs include the cell phone costs of outreach workers during the performance of these activities. (2) Case management. The cost of assessing housing and service needs, arranging, coordinating, and monitoring the delivery of individualized services to meet the needs of the program participant. Eligible services and activities are as follows: using the centralized or coordinated assessment system as required under § 576.400(d); conducting the initial evaluation required under § 576.401(a), including verifying and documenting eligibility; counseling; developing, securing and coordinating services; obtaining Federal, State, and local benefits; monitoring and evaluating program participant

City of Berkeley ESG Policies and Procedures
May 12, 2020

progress; providing information and referrals to other providers; and developing an individualized housing and service plan, including planning a path to permanent housing stability. (3) Emergency health services. (i) Eligible costs are for the direct outpatient treatment of medical conditions and are provided by licensed medical professionals operating in community-based settings, including streets, parks, and other places where unsheltered homeless people are living.
(ii) ESG funds may be used only for these services to the extent that other appropriate health services are inaccessible or unavailable within the area.
(iii) Eligible treatment consists of assessing a program participant’s health problems and developing a treatment plan; assisting program participants to understand their health needs; providing directly or assisting program participants to obtain appropriate emergency medical treatment; and providing medication and follow-up services. (4) Emergency mental health services.
(i) Eligible costs are the direct outpatient treatment by licensed professionals of mental health conditions operating in community-based settings, including streets, parks, and other places where unsheltered people are living. (ii) ESG funds may be used only for these services to the extent that other appropriate mental health services are inaccessible or unavailable within the community.
(iii) Mental health services are the application of therapeutic processes to personal, family, situational, or occupational problems in order to bring about positive resolution of the problem or improved individual or family functioning or circumstances.
(iv) Eligible treatment consists of crisis interventions, the prescription of psychotropic medications, explanation about the use and management of medications, and combinations of therapeutic approaches to address multiple problems. (5) Transportation. The transportation costs of travel by outreach workers, social workers, medical professionals, or other service providers are eligible, provided that this travel takes place during the provision of services eligible under this section. The costs of transporting unsheltered people to emergency shelters or other service facilities are also eligible.

These costs include the following:
(i) The cost of a program participant’s travel on public transportation; (ii) If service workers use their own vehicles, mileage allowance for service workers to visit program participants; (iii) The cost of purchasing or leasing a vehicle for the recipient or subrecipient in which staff transports program participants and/or staff serving program participants, and the cost of gas, insurance, taxes and maintenance for the vehicle; and
(iv) The travel costs of recipient or subrecipient staff to accompany or assist program participants to use public transportation.
(6) Services for special populations.

ESG funds may be used to provide services for homeless youth, victim services, and services for people living with HIV/AIDS, so long as the costs of providing these services are eligible under paragraphs (a)(1) through (a)(5) of this section. The ter m victim services means services that assist program participants who are victims of domestic violence, dating violence, sexual assault, or stalking, including services offered by rape crisis centers and domestic violence shelters, and other organizatio ns with a documented history of effective work concerning domestic violence, dating violence, sexual assault, or stalking. (b) Minimum period of use. The recipient or subrecipient must provide services to homeless individuals and families for at least the period during which ESG funds are provided. (c) Maintenance of effort. (1) If the recipient or subrecipient is a unit of general purpose local government, its ESG funds cannot be used to replace funds the local government provided for street outreach and emergency shelter services during the immediately preceding 12-month period, unless HUD determines that the unit of general purpose local government is in a severe financial deficit.
(2) Upon the recipient’s request, HUD will determine whether the unit of general purpose local government is in a severe financial deficit, based on the recipient’s demonstration of each of the following:
(i) The average poverty rate in the unit of general purpose local government’s jurisdiction was equal to or greater than 125 percent of the average national poverty rate, during the calendar year for which the most recent data are available, as determined according to information from the U.S. Census Bureau. (ii) The average per-capita income in the unit of general purpose local government’s jurisdiction was less than 75 percent of the average national per- capita income, during the calendar year for which the most recent data are available, as determined according to information from the Census Bureau. (iii) The unit of general purpose local government has a current annual budget deficit that requires a reduction in funding for services for homeless people.

City of Berkeley ESG Policies and Procedures
May 12, 2020

(iv) The unit of general-purpose local government has taken all reasonable steps to prevent a reduction in funding of services for homeless people. Reasonable steps may include steps to increase revenue generation, steps to maximize cost savings, or steps to reduce expenditures in areas other than services for homeless people.

§ 576.103 Homelessness prevention component.

ESG funds may be used to provide housing relocation and stabilization services and short - and/or medium-term rental assistance necessary to prevent an individual or family from moving into an emergency shelter or another place described in paragraph (1) of the ‘‘homeless’’ definition in § 576.2. This assistance, referred to as homelessness prevention, may be provided to individuals and families who meet the criteria under the ‘‘at risk of homelessness’’ definition, or who meet the criteria in paragraph (2), (3), or (4) of the ‘‘homeless’’ definition in § 576.2 and have an annual income below 30 percent of median family income for the area, as determined by HUD. The costs of homelessness prevention are only eligible to the extent that the assistance is necessary to help the program participant regain stability in the program participant’s current permanent housing or move into other permanent housing and achieve stability in that housing. Homelessness prevention must be provided in accordance with the housing relocation and stabilization services requirements in § 576.105, the short - term and medium-term rental assistance requirements in § 576.106, and the written standards and procedures established under § 576.400.

§ 576.104 Rapid re-housing assistance component.

ESG funds may be used to provide housing relocation and stabilization services and short - and/or medium-term rental assistance as necessary to help a homeless individual or family move as quickly as possible into permanent housing and achieve stability in that housing. This assistance, referred to as rapid re -housing assistance, may be provided to program participants who meet the criteria under paragraph (1) of the ‘‘homeless’’ definition in § 576.2 or who meet the criteria under paragraph 4 of the ‘‘homeless’’ definition and live in an emergency shelter or other place described in paragraph (1) of the ‘‘homeless’’ definition. The rapid re- housing assistance must be provided in accordance with the housing relo cation and stabilization services requirements in § 576.105, the short- and medium- term rental assistance requirements in § 576.106, and the written standards and procedures established under § 576.400.

§ 576.105 Housing relocation and stabilization services. (a) Financial assistance costs. Subject to the general conditions under § 576.103 and § 576.104, ESG funds may be used to pay housing owners, utility companies, and other third parties for the following costs:
(1) Rental application fees. ESG funds may pay for the rental housing application fee that is charged by the owner to all applicants.
(2) Security deposits. ESG funds may pay for a security deposit that is equal to no more than 2 months’ rent. (3) Last month’s rent. If necessary to obtain housing for a program participant, the last month’s rent may be paid from ESG funds to the owner of that housing at the time the owner is paid the security deposit and the first month’s rent. This assistance must not exceed one month’s rent and must be included in calculating the program participant’s total rental assistance, which cannot exceed 24 months during any 3-yearperiod. (4) Utility deposits. ESG funds may pay for a standard utility deposit required by the utility company for all customers for the utilities listed in paragraph (5) of this section. (5) Utility payments. ESG funds may pay for up to 24 months of utility payments per program participant , per service, including up to 6 months of utility payments in arrears, per service. A partial payment of a utility bill counts as one month.

This assistance may only be provided if the program participant or a member of the same household has an account in his or her name with a utility company or proof of responsibility to make utility payments. Eligible utility services a re gas, electric, water, and sewage. No program participant shall receive more than 24 months of utility assistance within any 3-year period. (6) Moving costs. ESG funds may pay for moving costs, such as truck rental or hiring a moving company. This assistance may include payment of temporary storage fees for up to 3 months, provided that the fees are accrued after the date the program participant begins receiving assistance under paragraph (b) of this section and before the program participant moves into permanent housing. Payment of temporary storage fees in arrears is not eligible. (b) Services costs. Subject to the general restrictions under § 576.103 and § 576.104, ESG funds may be used to pay the costs of providing the following services:
(1) Housing search and placement.

Services or activities necessary to assist program participants in locating, obtaining, and retaining suitable permanent

City of Berkeley ESG Policies and Procedures
May 12, 2020

housing, include the following:
(i) Assessment of housing barriers, needs, and preferences; (ii) Development of an action plan for locating housing; (iii) Housing search;
(iv) Outreach to and negotiation with owners;
(v) Assistance with submitting rental applications and understanding leases; (vi) Assessment of housing for compliance with Emergency Solutions Grant (ESG) requirements for habitability, lead- based paint, and rent reasonableness;
(vii) Assistance with obtaining utilities and making moving arrangements; and (viii) Tenant counseling.
(2) Housing stability case management. ESG funds may be used to pay cost of assessing, arranging, coordinating, and monitoring the delivery of individualized services to facilitate housing stability for a program participant who resides in permanent housing or to assist a program participant in overcoming immediate barriers to obtaining housing. This assistance cannot exceed 30 days during the period the program participant is seeking permanent housing and cannot exceed 24 months during the period the program participant is living in permanent housing. Component services and activities consist of:
(A) Using the centralized or coordinated assessment system as required under § 576.400(d), to evaluate individuals and families applying for or receiving homelessness prevention or rapid re-housing assistance; (B) Conducting the initial evaluation required under § 576.401(a), including verifying and documenting eligibility, for individuals and families applying for homelessness prevention or rapid re- housing assistance; (C) Counseling;
(D) Developing, securing, and coordinating services and obtaining Federal, State, and local benefits; (E) Monitoring and evaluating program participant progress; (F) Providing information and referrals to other providers; (G) Developing an individualized housing and service plan, including planning a path to permanent housing stability; and
(H) Conducting re-evaluations required under § 576.401(b). (3) Mediation. ESG funds may pay for mediation between the program participant and the owner or person(s) with whom the program participant is living, provided that the mediation is necessary to prevent the program participant from losing permanent housing in which the program participant currentlyresides. (4) Legal services. ESG funds may pay for legal services, as set forth in § 576.102(a)(1)(vi), except that the eligible subject matters also include landlord/tenant matters, and the services must be necessary to resolve a legal problem that prohibits the program participant from obtaining permanent housing or will likel y result in the program participant losing the permanent housing in which the program participant currently resides. (5) Credit repair. ESG funds may pay for credit counseling and other services necessary to assist program participants with critical skills related to household budgeting, managing money, accessing a free personal credit report, and resolving personal credit problems. This assistance does not include the payment or modification of a debt. (c) Maximum amounts and periods of assistance. The recipient may set a maximum dollar amount that a program participant may receive for each type of financial assistance under paragraph (a) of this section. The recipient may also set a maximum period for which a program participant may receive any of the types of assistance or services under this section.

However, except for housing stability case management, the total period for which any program participant may receive the services under paragraph (b) of this section must not exceed 24 months during any 3 -year period. The limits on the assistance under this section apply to the total assistance an individual receives, either as an individual or as part of a family.
(d) Use with other subsidies. Financial assistance under paragraph (a) of this section cannot be provided to a program participant who is receiving the same type of assistance through other public sources or to a program participant who has been provided with replacement housing payments under the URA, during the period of time covered by the URA payments.

§ 576.106 Short-term and medium-term rental assistance. (a) General provisions. Subject to the general conditions under § 576.103 and § 576.104, the recipient or subrecipient may provide a program participant with up to 24 months of rental assistance during any 3 -year period. This assistance may be short-term rental assistance, medium-term rental assistance, payment of rental arrears, or any combination of this

City of Berkeley ESG Policies and Procedures
May 12, 2020

assistance.
(1) Short-term rental assistance is assistance for up to 3 months of rent. (2) Medium-term rental assistance is assistance for more than 3 months but not more than 24 months of rent. (3) Payment of rental arrears consists of a one-time payment for up to 6 months of rent in arrears, including any late fees on those arrears.
(4) Rental assistance may be tenant-based or project-based, as set forth in paragraphs (h) and (i) of this section. (b) Discretion to set caps and conditions. Subject to the requirements of this section, the recipient may set a maximum amount or percentage of rental assistance that a program participant may receive, a maximum number of months that a program participant may receive rental assistance, or a maximum number of times that a program participant may receive rental assistance. The recipient may also require program participants to share in the costs of rent. (c) Use with other subsidies. Except for a one-time payment of rental arrears on the tenant’s portion of the rental payment, rental assistance cannot be provided to a program participant who is receiving tenant -based rental assistance, or living in a housing unit receiving project-based rental assistance or operating assistance, through other public sources .

Rental assistance may not be provided to a program participant who has been provided with replacement housing payments under the URA during the period of time covered by the URApayments. (d) Rent restrictions. (1) Rental assistance cannot be provided unless the rent does not exceed the Fair Market Rent established by HUD, as provided under 24 CFR part 888, and complies with HUD’s standard of rent reasonableness, as established under 24 CFR 982.507.
(2) For purposes of calculating rent under this section, the rent shall equal the sum of the total monthly rent for the unit, any fees required for occupancy under the lease (other than late fees and pet fees) and, if the tenant pays separately for utilities, the monthly allowance for utilities (excluding telephone) established by the public housing author ity for the area in which the housing is located.
(e) Rental assistance agreement. The recipient or subrecipient may make rental assistance payments only to an owner with whom the recipient or subrecipient has entered into a rental assistance agreement. The rental assistance agreement must set forth the terms under which rental assistance will be provided, including the requirements that apply under this section. The rental assistance agreement must provide that, during the term of the agreement, the owner mu st give the recipient or subrecipient a copy of any notice to the program participant to vacate the housing unit, or any complaint used under state or local law to commence an eviction action against the programparticipant. (f) Late payments. The recipient or subrecipient must make timely payments to each owner in accordance with the rental assistance agreement. The rental assistance agreement must contain the same payment due date, grace period, and late payment penalty requirements as the program participant’s lease. The recipient or subrecipient is solely responsible for paying late payment penalties that it incurs with non-ESG funds.

(g) Lease. Each program participant receiving rental assistance must have a legally binding, written lease for the rental unit, unless the assistance is solely for rental arrears. The lease must be between the owner and the program participant.

Where the assistance is solely for rental arrears, an oral agreement may be accepted in place of a written lease, if the agreement gives the program participant an enforceable leasehold interest under state law and the agreement and rent owed are sufficiently documented by the owner’s financial records, rent ledgers, or canceled checks. For program participants living in housing with project-based rental assistance under paragraph (i) of this section, the lease must have an initial term of one year.

(h) Tenant-based rental assistance.
(1) A program participant who receives tenant -based rental assistance may select a housing unit in which to live and may move to another unit or building and continue to receive rental assistance, as long as the program participant continues to meet the program requirements.
(2) The recipient may requirethat all program participants live within a particular area for the period in which the rental assistance is provided.
(3) The rental assistance agreement with the owner must terminate and no further rental assistance payments under that agreement may be made if:
(i) The program participant moves out of the housing unit for which the program participant has a lease; (ii) The lease terminates and is not renewed; or
(iii) The program participant becomes ineligible to receive ESG rental assistance. (i) Project-based rental assistance. If the recipient or subrecipient identifies a permanent housing unit that meets ESG requirements and becomes available before a program participant is identified to lease the unit, the recipient or subrecipient may enter into a rental assistance agreement with the owner to reserve the unit and

City of Berkeley ESG Policies and Procedures
May 12, 2020

subsidize its rent in accordance with the following requirements:

1. The rental assistance agreement may cover one or more permanent housing units in the same building. Each unit covered by the rental assistance agreement (‘‘assisted unit’’) may only be occupied by program participants, except as provided under paragraph (i)(4) of this section.

2. The recipient or subrecipient may pay up to 100 percent of the first month’s rent, provided that a program participant signs a lease and moves into the unit before the end of the month for which the first month’s rent is paid. The rent paid before a program participant moves into the unit must not exceed the rent to be charged under the program participant’s lease and must be included when determining that program participant’s total rental assistance.

3. The recipient or subrecipient may make monthly rental assistance payment s only for each whole or partial month an assisted unit is leased to a program participant. When a program participant moves out of an assisted unit, the recipient or subrecipient may pay the next month’s rent, i.e., the first month’s rent for a new program participant, as provided in paragraph (i)(2) of this section.

4. The program participant’s lease must not condition the term of occupancy to the provision of rental assistance payments.

If the program participant is determined ineligible or reaches the maximum number of months over which rental assistance can be provided, the recipient or subrecipient must suspend or terminate the rental assistance payments for the unit. If the payments are suspended, the individual or family may remain in the assisted unit as permitted under the lease, and the recipient or subrecipient may resume payments if the individual or family again becomes eligible and needs further rental assistance. If the payments are terminated, the rental assistance may be transferred to another available unit in the same building, provided that the other unit meets all ESG requirements. (1) The rental assistance agreement must have an initial term of one year. When a new program participant moves into an assisted unit, the term of the rental assistance agreement may be extended to cover the initial term of the program participant’s lease. If the program participant’s lease is renewed, the rental assistance agreement may be renewed or extended, as needed, up to the maximum number of months for which the program participant remains eligible. However, under no circumstances may the recipient or subrecipient commit ESG funds to be expended beyond the expenditure deadline in § 576.203 or commit funds for a future ESG grant before the grant is awarded. (j) Changes in household composition.

The limits on the assistance under this section apply to the total assistance an individual receives, either as an individual or as part of a family.

§ 576.107 HMIS component.
(a) Eligible costs.
(1) The recipient or subrecipient may use ESG funds to pay the costs of contributing data to the HMIS designated by the Continuum of Care for the area, including the costs of:
(i) Purchasing or leasing computer hardware;
(ii) Purchasing software or software licenses;
(iii) Purchasing or leasing equipment, including telephones, fax machines, and furniture; (iv) Obtaining technical support; Leasing office space; (v) Paying charges for electricity, gas, water, phone service, and high-speed data transmission necessary to operate or contribute data to the HMIS;
(vi) Paying salaries for operating HMIS, including:
(A) Completing data entry;
(B) Monitoring and reviewing data quality;
(C) Completing data analysis;
(D) Reporting to the HMIS Lead;
(F) Training staff on using the HMIS or comparable database; and (G) Implementing and complying with HMIS requirements;
(vii) Paying costs of staff to travel to and attend HUD-sponsored and HUD- approved training on HMIS and programs authorized by Title IV of the McKinney-Vento Homeless Assistance Act; (viii) Paying staff travel costs to conduct intake; and (ix) Paying participation fees charged by the HMIS Lead, if the recipient or subrecipient is not the HMIS Lead. The HMIS Lead is the entity designated by the Continuum of Care to operate the area’s HMIS. (2) If the recipient is the HMIS lead agency, as designated by the Continuum of Care in the most recent fiscal year Continuum of Care Homeless Assistance Grants Competition, it may also use ESG funds to pay the costs of:

City of Berkeley ESG Policies and Procedures
May 12, 2020

(i) Hosting and maintaining HMIS software or data;
(ii) Backing up, recovering, or repairing HMIS software or data; (iii) Upgrading, customizing, and enhancing the HMIS;
(iv) Integrating and warehousing data, including development of a data warehouse for use in aggregating data from subrecipients using multiple software systems;
(v) Administering the system;
(vi) Reporting to providers, the Continuum of Care, and HUD; and (vii) Conducting training on using the system or a comparable database, including traveling to the training. (3) If the subrecipient is a victim services provider or a legal services provider, it may use ESG funds to establish and operate a comparable database that collects client-level data over time (i.e., longitudinal data) and generates unduplicated aggregate reports based on the data. Information entered into a comparable database must not be entered directly into or provided to an HMIS.
(b) General restrictions. Activities funded under this section must comply with HUD’s standards on participation, data collection, and reporting under a local HMIS.

§ 576.108 Administrative activities.
(a) Eligible costs. The recipient may use up to 7.5 percent of its ESG grant for the payment of administrative costs related to the planning and execution of ESG activities. This does not include staff and overhead costs directly related to carrying out activities eligible under § 576.101 through § 576.107, because those costs are eligible as part of those activities. Eligible administrative costs include:
(1) General management, oversight and coordination. Costs of overall program management, coordination, monitoring, and evaluation. These costs include, but are not limited to, necessary expenditures for the following:
(i) Salaries, wages, and related costs of the recipient’s staff, the staff of subrecipients, or other staff engaged in program administration. In charging costs to this category, the recipient may either include the entire salary, wages, and related costs allocable to the program of each person whose primary responsibilities with regard to the program involve program administration assignments, or the pro rata share of the salary, wages, and related costs of each person whose job includes any program administration assignments. The recipient may use only one of these methods for each fiscal year grant. Program administration assignments include the following:
(A) Preparing program budgets and schedules, and amendments to those budgets and schedules; (B) Developing systems for assuring compliance with program requirements; (C) Developing interagency agreements and agreements with subrecipients and contractors to carry out program activities;
(D) Monitoring program activities for progress and compliance with program requirements; (E) Preparing reports and other documents directly related to the program for submission to HUD; (F) Coordinating the resolution of audit and monitoring findings; (G) Evaluating program results against stated objectives; and (H) Managing or supervising persons whose primary responsibilities with regard to the program include such assignments as those described in paragraph (a)(1)(i)(A) through (G) of this section. (ii) Travel costs incurred for monitoring of subrecipients; (iii) Administrative services performed under third-party contracts or agreements, including general legal services, accounting services, and audit services; and
(iv) Other costs for goods and services required for administration of the program, including rental or purchase of equipment, insurance, utilities, office supplies, and rental and maintenance (but not purchase) of office space. (2) Training on ESG requirements. Costs of providing training on ESG requirements and attending HUD- sponsored ESG trainings.
(3) Consolidated plan. Costs of preparing and amending the ESG and homelessness-related sections of the consolidated plan in accordance with ESG requirements and 24 CFR part 91. (4) Environmental review. Costs of carrying out the environmental review responsibilities under § 576.407. (b) Sharing requirement. (1) States. If the recipient is a State, the recipient must share its funds for administrative costs with its subrecipients that are units of general-purpose local government. The amount shared must be reasonable under the circumstances. The recipient may share its funds for administrative costs with its subrecipients that are private nonprofit organizations.
(2) Territories, metropolitan cities, and urban counties. If the recipient is a territory, metropolitan city, or urban

City of Berkeley ESG Policies and Procedures
May 12, 2020

county, the recipient may share its funds for administrative costs with its subrecipients.

Subpart C— Award and Use of Funds

§ 576.201 Matching requirement.
(a) Required amount of matching contributions. (1) Except as provided under paragraphs (a)(2) and (a)(3) of this section, the recipient must make matching contributions to supplement the recipient’s ESG program in an amount that equals the amount of ESG funds provided by HUD.
(b) Eligible sources of matching contributions. (1) Subject to the requirement for States under paragraph (a)(2) of this section, the recipient may require its subrecipients to make matching contributions consistent with this section to help meet the recipient’s matching requirement.
(2) Matching contributions may be obtained from any source, including any Federal source other than the ESG program, as well as state, local, and private sources. However, the following requirements apply to matching contributions from a Federal source of funds:
(i) The recipient must ensure the laws governing any funds to be used as matching contributions do not prohibit those funds from being used to match Emergency Solutions Grant (ESG) funds. (ii) If ESG funds are used to satisfy the matching requirements of another Federal program, then funding from that program may not be used to satisfy the matching requirements under this section. (c) Recognition of matching contributions. (1) In order to meet the matching requirement, the matching contributions must meet all requirements that apply to the ESG funds provided by HUD, except for the expenditure limits in § 576.100. (2) The matching contributions must be provided after the date that HUD signs the grant agreement. (3) To count toward the required match for the recipient’s fiscal year grant, cash contributions must be expended within the expenditure deadline in § 576.203, and noncash contributions must be made within the expenditure deadline in § 576.203.
(4) Contributions used to match a previous ESG grant may not be used to match a subsequent ESG grant. (5) Contributions that have been or will be counted as satisfying a matching requirement of another Federal grant or award may not count as satisfying the matching requirement of this section. (d) Eligible types of matching contributions. The matching requirement may be met by one or both of the following:
(1) Cash contributions. Cash expended for allowable costs, as defined in OMB Circulars A –87 (2 CFR part 225) and A– 122 (2 CFR part 230), of the recipient or subrecipient. (2) Noncash contributions. The value of any real property, equipment, goods, or services contributed to the recipient’s or subrecipient’s ESG program, provided that if the recipient or subrecipient had to pay for them with grant funds, the costs would have been allowable. Noncash contributions may also include the purchase value of any donated building. (e) Calculating the amount of noncash contributions. (1) To determine the value of any donated material or building, or of any lease, the recipient must use a method reasonably calculated to establish the fair market value. (2) Services provided by individuals must be valued at rates consistent with those ordinarily paid for similar work in the recipient’s or subrecipient’s organization. If the recipient or subrecipient does not have employees performing similar work, the rates must be consistent with those ordinarily paid by other employers for similar work in the same labor market. (3) Some noncash contributions are real property, equipment, goods, or services that, if the recipient or subrecipient had to pay for them with grant funds, the payments would have been indirect costs. Matching credit for these contributions must be given only if the recipient or subrecipient has established, along with its regular indirect cost rate, a special rat e for allocating to individual projects or programs the value of those contributions. (f) Costs paid by program income.

Costs paid by program income shall count toward meeting the recipient’s matching requirements, provided the costs are eligible ESG costs that supplement the recipient’s ESG program.

Subpart E— Program Requirements

§ 576.400 Area-wide systems coordination requirements.
(a) Consultation with Continuums of Care. The recipient must consult with each Continuum of Care that serves the recipient’s jurisdiction in determining how to allocate ESG funds each program year; developing the performance standards for, and evaluating the outcomes of, projects and activities assisted by ESG funds; and developing funding, policies, and procedures for the administration and operation of the HMIS.

City of Berkeley ESG Policies and Procedures
May 12, 2020

(b) Coordination with other targeted homeless services. The recipient and its subrecipients must coordinate and integrate, to the maximum extent practicable, ESG-funded activities with other programs targeted to homeless people in the area covered by the Continuum of Care or area over which the services are coordinated to provide a strategic, community-wide system to prevent and end homelessness for that area. These programs include:
(1) Shelter Plus Care Program (24 CFR part 582);
(2) Supportive Housing Program (24 CFR part 583);
(3) Section 8 Moderate Rehabilitation Program for Single Room Occupancy Program for Homeless Individuals (24 CFR part 882);
(4) HUD— Veterans Affairs Supportive Housing (HUD–VASH) (division K, title II, Consolidated Appropriations Act, 2008, Pub. L. 110–161 (2007), 73 FR 25026 (May 6, 2008));
(5) Education for Homeless Children and Youth Grants for State and Local Activities (title VII –B of the McKinney- Vento Homeless Assistance Act (42 U.S.C. 11431 et seq.));
(6) Grants for the Benefit of Homeless Individuals (section 506 of the Public Health Services Act (42 U.S.C. 290aa– 5)); (7) Healthcare for the Homeless (42 CFR part 51c);
(8) Programs for Runaway and Homeless Youth (Runaway and Homeless Youth Act (42 U.S.C. 5701 et seq.)); (9) Projects for Assistance in Transition from Homelessness (part C of title V of the Public Health Service Act (42 U.S.C. 290cc–21 et seq.));
(10) Services in Supportive Housing Grants (section 520A of the Public Health Service Act); (11) Emergency Food and Shelter Program (title III of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11331 et seq.));
(12) Transitional Housing Assistance Grants for Victims of Sexual Assault, Domestic Violence, Dating Violence, and Stalking Program (section 40299 of the Violent Crime Control and Law Enforcement Act (42 U.S.C. 13975)); (13) Homeless Veterans Reintegration Program (section 5(a)(1)) of the Homeless Veterans Comprehensive Assistance Act (38 U.S.C. 2021);
(14) Domiciliary Care for Homeless Veterans Program (38 U.S.C.2043); (15) VA Homeless Providers Grant and Per Diem Program (38 CFR part 61); (16) Health Care for Homeless Veterans Program (38 U.S.C. 2031); (17) Homeless Veterans Dental Program (38 U.S.C. 2062); (18) Supportive Services for Veteran Families Program (38 CFR part 62);and (19) Veteran Justice Outreach Initiative (38 U.S.C. 2031). (c) System and program coordination with mainstream resources. The recipient and its subrecipients must coordinate and integrate, to the maximum extent practicable, ESG- funded activities with mainstream housing, health, social services, employment, education, and youth programs for which families and individuals at risk of homelessness and homeless individuals and families may be eligible. Examples of these programsinclude:
(1) Public housing programs assisted under section 9 of the U.S. Housing Act of 1937 (42 U.S.C. 1437g) (24 CFR parts 905, 968, and 990);
(2) Housing programs receiving tenant-based or project-based assistance under section 8 of the U.S. Housing Act of 1937 (42 U.S.C. 1437f) (respectively 24 CFR parts 982 and 983); (3) Supportive Housing for Persons with Disabilities (Section 811) (24 CFR part 891); (4) HOME Investment Partnerships Program (24 CFR part92); (5) Temporary Assistance for Needy Families (TANF) (45 CFR parts260–265); (6) Health Center Program (42 CFR part 51c);
(7) State Children’s Health Insurance Program (42 CFR part457):
(8) Head Start (45 CFR chapter XIII, subchapter B);
(9) Mental Health and Substance Abuse Block Grants (45 CFR part 96);and (10) Services funded under the Workforce Investment Act (29 U.S.C. 2801 etseq.).

§ 576.401 Evaluation of program participant eligibility and needs. (a) Evaluations. The recipient or its subrecipient must conduct an initial evaluation to determine the eligibility of each individual or family’s eligibility for ESG assistance and the amount and types of assistance the individual or family needs to regain stability in permanent housing. These evaluations must be conducted in accordance with the centralized or coordinated assessment requirements set forth under § 576.400(d) and the written standards established under § 576.400(e).

City of Berkeley ESG Policies and Procedures
May 12, 2020

(b) Re-evaluations for homelessness prevention and rapid re-housing assistance. (1) The recipient or subrecipient must re-evaluate the program participant’s eligibility and the types and amounts of assistance the program participant needs not less than once every 3 months for program participants receiving homelessness prevention assis tance, and not less than once annually for program participants receiving rapid re-housing assistance. At a minimum, each re-evaluation of eligibility must establish that:
(i) The program participant does not have an annual income that exceeds 30 percent of me dian family income for the area, as determined by HUD; and
(ii) The program participant lacks sufficient resources and support networks necessary to retain housing without ESG assistance.
(2) The recipient or subrecipient may require each program participant receiving homelessness prevention or rapid re - housing assistance to notify the recipient or subrecipient regarding changes in the program participant’s income or other circumstances (e.g., changes in household composition) that affect the program participant’s need for assistance under ESG. When notified of a relevant change, the recipient or subrecipient must re -evaluate the program participant’s eligibility and the amount and types of assistance the program participant needs. (c) Annual income. When determining the annual income of an individual or family, the recipient or subrecipient must use the standard for calculating annual income under 24 CFR 5.609. (d) Connecting program participants to mainstream and other resources. The recipient and its subrecipients must assist each program participant, as needed, to obtain:
(1) Appropriate supportive services, including assistance in obtaining permanent housing, medical health treatment, mental health treatment, counseling, supervision, and other services essential for achieving independent living; and Other Federal, State, local, and private assistance available to assist the program participant in obtaining housing stability, including:
(i) Medicaid (42 CFR chapter IV, subchapter C):
(ii) Supplemental Nutrition Assistance Program (7 CFR parts 271– 283); (iii) Women, Infants and Children (WIC) (7 CFR part 246); (iv) Federal-State Unemployment Insurance Program (20 CFR parts 601– 603, 606, 609, 614–617, 625, 640, (v) Social Security Disability Insurance (SSDI) (20 CFR part 404); (vi) Supplemental Security Income (SSI) (20 CFR part 416); (vii) Child and Adult Care Food Program (42 U.S.C. 1766(t) (7 CFR part 226)); (viii) Other assistance available under the programs listed in § 576.400(c). (e) Housing stability case management. (1) While providing homelessness prevention or rapid re - housing assistance to a program participant, the recipient or subrecipient must:
(i) Require the program participant to meet with a case manager not less than once per month to assist the program participant in ensuring long-term housing stability; and (ii) Develop a plan to assist the program participant to retain permanent housing after the ESG assistance ends, taking into account all relevant considerations, such as the program participant’s current or expected income and expenses; other public or private assistance for which the program participant will be eligible and likely to receive; and the relative affordability of available housing in the area.
(2) The recipient or subrecipient is exempt from the requirement under parag raph (e)(1)(i) of this section if the Violence Against Women Act of 1994 (42 U.S.C. 13701 et seq.) or the Family Violence Prevention and Services Act (42 U.S.C. 10401 et seq.) prohibits that recipient or subrecipient from making its shelter or housing conditional on the participant’s acceptance of services.

§ 576.402 Terminating assistance.
(a) In general, If a program participant violates program requirements, the recipient or subrecipient may terminate the assistance in accordance with a formal process established by the recipient or subrecipient that recognizes the rights of individuals affected. The recipient or subrecipient must exercise judgment and examine all extenuating circumstances in determining when violations warrant termination so that a program participant’s assistance is terminated only in the most severe cases.
(b) Program participants receiving rental assistance or housing relocation and stabilization services. To terminate rental assistance or housing relocation and stabilization services to a program participant, the required formal process, at a minimum, must consist of:
(1) Written notice to the program participant containing a clear statement of the reasons for termination;

City of Berkeley ESG Policies and Procedures
May 12, 2020

(2) A review of the decision, in which the program participant is given the opportunity to present written or oral objections before a person other than the person (or a subordinate of that person) who made or approved the termination decision; and
(3) Prompt written notice of the final decision to the program participant. (c) Ability to provide further assistance. Termination under this section does not bar the recipient or subrecipient from providing further assistance at a later date to the same family or individual.

§ 576.403 Shelter and housing standards.
(a) Lead-based paint remediation and disclosure. The Lead-Based Paint Poisoning Prevention Act (42 U.S.C. 4821– 4846), the Residential Lead-Based Paint Hazard Reduction Act of 1992 (42 U.S.C. 4851–4856), and implementing regulations in 24 CFR part 35, subparts A, B, H, J, K, M, and R apply to all shelters assisted under ESG program and all housing occupied by program participants.
(b) Minimum standards for emergency shelters. Any building for which Emergency Solutions Grant (ESG) funds are used for conversion, major rehabilitation, or other renovation, must meet state or local government safety and sanitation standards, as applicable, and the following minimum safety, sanitation, and privacy standards. Any emergency shelter that receives assistance for shelter operations must also meet the following minimum safety, sanitation, and privacy standards.

The recipient may also establish standards that exceed or add to these minimum standards. (1) Structure and materials. The shelter building must be structurally sound to protect residents from the elements and not pose any threat to health and safety of the residents. Any renovation (including major rehabilitation and conversion) carried out with ESG assistance must use Energy Star and Water Sense products and appliances. (2) Access. The shelter must be accessible in accordance with Section 504 of the Rehabilitation Act (29 U.S.C. 794) and implementing regulations at 24 CFR part 8; the Fair Housing Act (42 U.S.C. 3601 et seq.) and implementing regulations at 24 CFR part 100; and Title II of the Americans with Disabilities Act (42 U.S.C. 12131 et seq. ) and 28 CFR part 35; where applicable.
(3) Space and security. Except where the shelter is intended for day use only, the shelter must provide each program participant in the shelter with an acceptable place to sleep and adequate space and security for themselves and their belongings.
(4) Interior air quality. Each room or space within the shelter must have a natural or mechanical means of ventilation.

The interior air must be free of pollutants at a level that might threaten or harm the health of residents. (5) Water supply. The shelter’s water supply must be free of contamination. (6) Sanitary facilities. Each program participant in the shelter must have access to sanitary facilities that are in proper operating condition, are private, and are adequate for personal cleanliness and the disposal of human waste. (7) Thermal environment. The shelter must have any necessary heating/ cooling facilities in proper operating condition.
(8) Illumination and electricity. The shelter must have adequate natural or artificial illumination to permit normal indoor activities and support health and safety. There must be sufficient electrical sources to permit the safe use of electrical appliances in the shelter.
(9) Food preparation. Food preparation areas, if any, must contain suitable space and equipment to store, prepare, and serve food in a safe and sanitary manner.
(10) Sanitary conditions. The shelter must be maintained in a sanitary condition. (11) Fire safety. There must be at least one working smoke detector in each occupied unit of the shelter. Where possible, smoke detectors must be located near sleeping areas. The fire alarm system must be designed for hearing - impaired residents. All public areas of the shelter must have at least one working smoke detector. There must also be a second means of exiting the building in the event of fire or other emergency. (c) Minimum standards for permanent housing. The recipient or subrecipient cannot use ESG funds to help a program participant remain or move into housing that does not meet the minimum habitability standards provided in this paragraph (c). The recipient may also establish standards that exceed or add to these minimum standards. (1) Structure and materials. The structures must be structurally sound to protect residents from the elements and not pose any threat to the health and safety of the residents. (2) Space and security. Each resident must be provided adequate space and security for themselves and their belongings. Each resident must be provided an acceptable place to sleep. (3) Interior air quality. Each room or space must have a natural or mechanical means of ventilation. The interior air must be free of pollutants at a level that might threaten or harm the health of residents.

City of Berkeley ESG Policies and Procedures
May 12, 2020

(4) Water supply. The water supply must be free from contamination. (5) Sanitary facilities. Residents must have access to sufficient sanitary facilities that are in proper operating condition, are private, and are adequate for personal cleanliness and the disposal of human waste. (6) Thermal environment. The housing must have any necessary heating/cooling facilities in proper operating condition.
(7) Illumination and electricity. The structure must have adequate natural or artificial illumination to permit normal indoor activities and support health and safety. There must be sufficient electrical sources to permit the safe use of electrical appliances in the structure.
(8) Food preparation. All food preparation areas must contain suitable space and equipment to store, prepare, and serve food in a safe and sanitary manner.
(9) Sanitary conditions. The housing must be maintained in a sanitary condition. (10) Fire safety. (i) There must be a second means of exiting the building in the event of fire or other emergency. (ii) Each unit must include at least one battery-operated or hard-wired smoke detector, in proper working condition, on each occupied level of the unit. Smoke detectors must be located, to the extent practicable, in a hallway adjacent to a bedroom. If the unit is occupied by hearing impaired persons, smoke detectors must have an alarm system designed for hearing-impaired persons in each bedroom occupied by a hearing-impaired person. (iii) The public areas of all housing must be equipped with a sufficient number, but not less than one for each area, of battery-operated or hard-wired smoke detectors. Public areas include, but are not limited to, laundry rooms, community rooms, day care centers, hallways, stairwells, and other common areas.

§ 576.404 Conflicts of interest.
(a) Organizational conflicts of interest. The provision of any type or amount 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 subrecipient, or a parent or subsidiary of the subrecipient. No subrecipient may, with respect to individuals or families occupying housing owned by the subrecipient, or any parent or subsidiary of the subrecipient, carry out the initial evaluation required under § 576.401 or administer homelessness prevention assistance under § 576.103. (b) Individual conflicts of interest. For the procurement of goods and services, the recipient and its subrecipients must comply with the codes of conduct and conflict of interest requirements under 24 CFR 85.36 (for governments) and 24 CFR

84.42 (for private nonprofit organizations). For all other transactions and activities, the following restrictions apply:
(1) Conflicts prohibited. No person described in paragraph (b)(2) of this section who exercises or has exercised any functions or responsibilities with respect to activities assisted under the ESG program, or who is in a position to participate in a decision-making process or gain inside information with regard to activities assisted under the program, may obtain a financial interest or benefit from an assisted activity; have a financial interest in any contract, subcontract, or agreement with respect to an assisted activity; or have a financial interest in the proceeds derived from an assisted activity, either for him or herself or for those with whom he or she has family or business ties, during his or her tenure or during the one -year period following his or her tenure.
(2) Persons covered. The conflict-of- interest provisions of paragraph (b)(1) of this section apply to any person who is an employee, agent, consultant, officer, or elected or appointed official of the recipient or its subrecipients. (3) Exceptions. Upon the written request of the recipient, HUD may grant an exception to the provisions of this subsection on a case-by-case basis, taking into account the cumulative effects of the criteria in paragraph (b)(3)(ii) of this section, provided that the recipient has satisfactorily met the threshold requirements of paragraph (b)(3)(i) of this section. (i) Threshold requirements. HUD will consider an exception only after the recipient has provided the following documentation:
(A) If the recipient or subrecipient is a government, disclosure of the nature of the conflict, accompanied by an assurance that there has been public disclosure of the conflict and a description of how the public disclosure was made; and (B) An opinion exception is sought would not violate state or local law. (ii) Factors to be considered for exceptions. In determining whether to grant a requested exception after the recipient has satisfactorily met the threshold requirements under paragraph (b)(3)(i) of this section, HUD must conclude that the exception will serve to further the purposes of the ESG program and the effective and efficient administration of the recipient’s or subrecipient’s program or project, taking into account the cumulative effect of the following factors, as applicable:
(A) Whether the exception would provide a significant cost benefit or an essential degree of expertise to the program or project that would otherwise not be available;

City of Berkeley ESG Policies and Procedures
May 12, 2020

(B) Whether an opportunity was provided for open competitive bidding or negotiation; (C) Whether the affected person has withdrawn from his or her functions, responsibilities or the decision-making process with respect to the specific activity in question; (D) Whether the interest or benefit was present before the affected person was in the position described in paragraph (b)(1) of this section;
(E) Whether undue hardship results to the recipient, the subrecipient, or the person affected, when weighed against the public interest served by avoiding the prohibited conflict; and (F) Any other relevant considerations.
(c) Contractors. All contractors of the recipient or subrecipient must comply with the same requirements that apply to subrecipients under this section.

§ 576.405 Homeless participation.
(a) Unless the recipient is a State, the recipient must provide for the participation of not less than one homeless individual or formerly homeless individual on the board of directors or other equivalent policy- making entity of the recipient, to the extent that the entity considers and makes policies and decisions regarding any facilities, services, or ot her assistance that receive funding under Emergency Solutions Grant (ESG). (b) If the recipient is unable to meet requirement under paragraph (a), it must instead develop and implement a plan to consult with homeless or formerly homeless individuals in considering and making policies and decisions regarding any facilities, services, or other assistance that receive funding under Emergency Solutions Grant (ESG). The plan must be included in the annual action plan required under 24 CFR 91.220. (c) To the maximum extent practicable, the recipient or subrecipient must involve homeless individuals and families in constructing, renovating, maintaining, and operating facilities assisted under ESG, in providing services assisted under ESG, and in providing services for occupants of facilities assisted under ESG. This involvement may include employment or volunteer services.

§ 576.406 Faith-based activities.
(a) Organizations that are religious or faith-based are eligible, on the same basis as any other organization, to receive ESG funds. Neither the Federal Government nor a State or local government receiving funds under ESG shall discriminate against an organization on the basis of the organization’s religious character or affiliation. (b) Organizations that are directly funded under the ESG program may not engage in inherently religious activities, such as worship, religious instruction, or proselytization as part of the programs or services funded under ESG . If an organization conducts these activities, the activities must be offered separately, in time or location, from the programs or services funded under ESG, and participation must be voluntary for program participants. (c) Any religious organization that receives ESG funds retains 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 the religious organization does not use direct ESG funds to support any inherently religious activitie s, such as worship, religious instruction, or proselytization. Among other things, faith -based organizations may use space in their facilities to provide ESG-funded services, without removing religious art, icons, scriptures, or other religious symbols.

In addition, an ESG-funded religious organization retains its authority over its internal governance, and the organization 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. (d) An organization that receives ESG funds shall not, in providing ESG assistance, discriminate against a program participant or prospective program participant on the basis of religion or religious belief. (e) ESG funds may not be used for the rehabilitation of structures to the extent that those structures are used for inherently religious activities. Solutions ESG funds may be used for the rehabilitation of structures only to the extent that those structures are used for conducting eligible activities under the ESG program. Where a structure is used for both eligible and inherently religious activities, ESG funds may not exceed the cost of those portions of the rehabilitation that are attributable to eligible activities in accordance with the cost accounting requirements applicable to ESG funds.

Sanctuaries, chapels, or other rooms that an ESG-funded religious congregation uses as its principal place of worship, however, are ineligible for funded improvements under the program. Disposition of real property after the term of the grant, or any change in use of the property during the term of the grant, is subject to government -wide regulations governing real property disposition (see 24 CFR parts 84 and 85). (f) If the recipient or a subrecipient that is a local government voluntarily contributes its own funds to supplement

City of Berkeley ESG Policies and Procedures
May 12, 2020

federally funded activities, the recipient or subrecipient has the option to segregate the Federal funds or commingle them.

However, if the funds are commingled, this section applies to all of the commingled funds.

§ 576.407 Other Federal requirements.
(a) General. The requirements in 24 CFR part 5, subpart A are applicable, including the nondiscrimination and equal opportunity requirements at 24 CFR 5.105(a). Section 3 of the Housing and Urban Development Act of 1968, 12 U.S.C. 1701u, and implementing regulations at 24 CFR part 135 apply, except that homeless individuals have priority over other Section 3 residents in accordance with § 576.405(c).
(b) Affirmative outreach. The recipient or subrecipient must make known that use of the facilities, assistance, and services are available to all on a nondiscriminatory basis. If it is unlikely that the procedures that the recipient or subrecipient intends to use to make known the availability of the facilities, assistance, and services will to reach persons of any particular race, color, religion, sex, age, national origin, familial status, or disability who may qualify for those facilities and services, the recipient or subrecipient must establish additional procedures that ensure that those persons are made aware of the facilities, assistance, and services. The recipient and its subrecipients must take appropriate steps to ensure effective communication with persons with disabilities including, but not limited to, adopting procedures that will make available to interested persons information concerning the location of assistance, services, and facilities that are accessible to persons with disabilities. Consistent with Title VI and Executive Order 13166, recipients and subrecipients are also required to take reasonable steps to ensure meaningful access to pr ograms and activities for limited English proficiency (LEP) persons.
(c) Uniform Administrative Requirements. The requirements of 24 CFR part 85 apply to the recipient and subrecipients that are units of general purpose local government, except that 24 CFR 85.24 and 85.42 do not apply, and program income is to be used as match under 24 CFR 85.25(g). The requirements of 24 CFR part 84 apply to subrecipients that are private nonprofit organizations, except that 24 CFR 84.23 and 84.53 do not apply, and program income is to be used as the nonfederal share under 24 CFR 84.24(b). These regulations include allowable costs and non-Federal audit requirements. (d) Environmental review responsibilities. (1) Activities under this part are subject to environmental review by H UD under 24 CFR part 50. The recipient shall supply all available, relevant information necessary for HUD to perform for each property any environmental review required by 24 CFR part 50. The recipient also shall carry out mitigating measures required by HUD or select alternate eligible property. HUD may eliminate from consideration any application that would require an Environmental Impact Statement (EIS).
(2) The recipient or subrecipient, or any contractor of the recipient or subrecipient, may not acqui re, rehabilitate, convert, lease, repair, dispose of, demolish, or construct property for a project under this part, or commit or expend HUD or local funds for eligible activities under this part, until HUD has performed an environmental review under 24 CFR part 50 and the recipient has received HUD approval of the property.
(e) Davis-Bacon Act. The provisions of the Davis-Bacon Act (40 U.S.C. 276a to 276a–5) do not apply to the ESG program.
(f) Procurement of Recovered Materials. The recipient and its contractors must comply with Section 6002 of the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act. The requirements of Section 6002 include procuring only items designated in guidelines of the Environmental Protection Agency (EPA) at 40 CFR part 247 that contain the highest percentage of recovered materials practicable, consistent with maintaining a satisfactory level of competition, where the purchase price of the item exceeds $10,000 or the value of the quantity acquired by the prece ding fiscal year exceeded $10,000; procuring solid waste management services in a manner that maximizes energy and resource recovery; and establishing an affirmative procurement program for procurement of recovered materials identified in the EPA guidelines.

Subpart F— Grant Administration
§ 576.500 Recordkeeping and reporting requirements.
(a) In general. The recipient must have policies and procedures to ensure the requirements of this part are met. The policies and procedures must be established in writing and implemented by the recipient and its subrecipients to ensure that ESG funds are used in accordance with the requirements. In addition, sufficient records must be established and maintained to enable the recipient and HUD to determine whether ESG requirements are being met. (b) Homeless status. The recipient must maintain and follow written intake procedures to ensure compliance with the homeless definition in § 576.2. The procedures must require documentation at intake of the evidence relied upon to establish and verify homeless status. The procedures must establish the order of priority for obtaining evidence as third-

City of Berkeley ESG Policies and Procedures
May 12, 2020

party documentation first, intake worker observations second, and certification from the person seeking assistance third.

However, lack of third- party documentation must not prevent an individual or family from being immediately admitted to emergency shelter, receiving street outreach services, or being immediately admitted to shelter or receiving services provided by a victim service provider. Records contained in an HMIS or comparable database used by victim service or legal service providers are acceptable evidence of third-party documentation and intake worker observations if the HMIS retains an auditable history of all entries, including the person who entered the data, the date of entry, and the change made; and if the HMIS prevents overrides or changes of the dates on which entries are made. (1) If the individual or family qualifies as homeless under paragraph (1)(i) or (ii) of the homeless definition in § 576.2, acceptable evidence includes a written observation by an outreach worker of the conditions where the individual or family was living, a written referral by another housing or service provider, or a certification by the individual or head of household seeking assistance. (2) If the individual qualifies as homeless under paragraph (1)(iii) of the homeless definition in § 576.2, because he or she resided in an emergency shelter or place not meant for human habitation and is exiting an institution where he or she resided for 90 days or less, acceptable evidence includes the evidence described in paragraph (b)(1) of this section and one of the following:
(i) Discharge paperwork or a written or oral referral from a social worker, case manager, or other appropriate official of the institution, stating the beginning and end dates of the time residing in the institution. All oral statements must be recorded by the intake worker; or
(ii) Where the evidence in paragraph (b)(2)(i) of this section is not obtainable, a written record of the intake worker’s due diligence in attempting to obtain the evidence described in paragraph (b)(2)(i) and a certification by the individual seeking assistance that states he or she is exiting or has just exited an institution where he or she resided for 90 days or less.
(3) If the individual or family qualifies as homeless under paragraph (2) of the homeless definition in § 576.2, because the individual or family will imminently lose their housing, the evidence must include:
(i)(A) A court order resulting from an eviction action that requires the individual or family to leave their residence within 14 days after the date of their application for homeless assistance; or the equivalent notice under applicable state law, a Notice to Quit, or a Notice to Terminate issued under state law; (B) For individuals and families whose primary nighttime residence is a hotel or motel room not paid for by charitable organizations or federal, state, or local government programs for low- income individuals, evidence that the individual or family lacks the resources necessary to reside there for more than 14 days after the date of application for homeless assistance; or
(C) An oral statement by the individual or head of household that the owner or renter of the housing in which they currently reside will not allow them to stay for more than 14 days after the date of application for homeless assistance. The intake worker must record the statement and certify that it was found credible. To be found credible, the oral statement must either:
(I) be verified by the owner or renter of the housing in which the individual or family resides at the time of application fo r ho
meless assistance and documented by a written certification by the owner or renter or by the intake worker’s recording of the owner or renter’s oral statement; or (II) if the intake worker is unable to contact the owner or renter, be documented by a written certification by the intake worker of his or her due diligence in attempting to obtain the owner or renter’s verification and the written certification by the individual or head of household seeking assistance that his or her statement was true and complete;
(ii) Certification by the individual or head of household that no subsequent residence has been identified; and (iii) Certification or other written documentation that the individual or family lacks the resources and support networks needed to obtain other permanent housing.
(4) If the individual or family qualifies as homeless under paragraph (3) of the homeless definition in § 576.2, because the individual or family does not otherwise qualify as homeless under the homeless definition but is an unaccompanied youth under 25 years of age, or homeless family with one or more children or youth, and is defined as homeless under another Federal statute or section 725(2) of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11434a(2)), the evidence must include:
(i) For paragraph (3)(i) of the homeless definition in § 576.2, certification of homeless status by the local private nonprofit organization or state or local governmental entity responsible for administering assistance under the Runaway and Homeless Youth Act (42 U.S.C. 5701 et seq.), the Head Start Act (42 U.S.C. 9831 et seq.), subtitle N of the Violence Against Women Act of 1994 (42 U.S.C. 14043e et seq.), section 330 of the Public Health Service Act (42 U.S.C. 254b), the

City of Berkeley ESG Policies and Procedures
May 12, 2020

Food and Nutrition Act of 2008 (7 U.S.C. 2011 et seq.), section 17 of the Child Nutrition Act of 1966 (42 U.S.C. 1786), or subtitle B of title VII of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11431 et seq.), as applicable; (ii) For paragraph (3)(ii) of the homeless definition in § 576.2, referral by a housing or service provider, written observation by an outreach worker, or certification by the homeless individual or head of household seeking assistance; (iii) For paragraph (3)(iii) of the homeless definition in § 576.2, certification by the individual or head of household and any available supporting documentation that the individual or family moved two or more times during the 60- day period immediately preceding the date of application for homeless assistance, including: recorded statements or records obtained from each owner or renter of housing, provider of shelter or housing, or social worker, case worker, or other appropriate official of a hospital or institution in which the individual or family resided; or, where these statements or records are unobtainable, a written record of the intake worker’s due diligence in attempting to obtain these statements or records.

Where a move was due to the individual or family fleeing domestic violence, dating violence, sexual assault, or stalking, then the intake worker may alternatively obtain a written certification from the individual or head of household seeking assistance that they were fleeing that situation and that they resided at that address; and (iv) For paragraph (3)(iv) of the homeless definition in § 576.2, written diagnosis from a professional who is licensed by the state to diagnose and treat that condition (or intake staff- recorded observation of disability that within 45 days of date of the application for assistance is confirmed by a professional who is licensed by the state to diagnose and treat that condition); employment records; department of corrections records; literacy, English proficiency tests; or other reasonable documentation of the conditions required under paragraph (3)(iv) of the homeless definition. (5) If the individual or family qualifies under paragraph (4) of the homeless definition in § 576.2, because the individual or family is fleeing domestic violence, dating violence, sexual assault, stalking, or other dangerous or life - threatening conditions related to violence, then acceptable evidence includes an oral statement by the individual or head of household seeking assistance that they are fleeing that situation, that no subsequent residence has been identified and that they lack the resources or support networks, e.g., family, friends, faith-based or other social networks, needed to obtain other housing. If the individual or family is receiving shelter or services provided by a victim service provider, the oral statement must be documented by either a certification by the individual or head of household; or a certification by the intake worker. Otherwise, the oral statement that the individual or head of household seeking assistance has not identified a subsequent residence and lacks the resources or support networks, e.g., family, friends, faith-based or other social networks, needed to obtain housing must be documented by a certification by the individual or head of household that the oral statement is true and complete, and, where the safety of the individual or family would not be jeopardized, the domestic violence, dating violence, sexual assault, stalking, or other dangerous or life-threatening condition must be verified by a written observation by the intake worker or a written referral by a housing or service provider, social worker, legal assistance provider, health-care provider, law enforcement agency, legal assistance provider, pastoral counselor, or any other organization from whom the individual or head of household has sought assistance for domestic violence, dating violence, sexual assault, or stalking. The written referral or obser vation need only include the minimum amount of information necessary to document that the individual or family is fleeing, or attempting to flee domestic violence, dating violence, sexual assault, and stalking.
(c) At risk of homelessness status. For each individual or family who receives Emergency Solutions Grant (ESG) homelessness prevention assistance, the records must include the evidence relied upon to establish and verify the individual or family’s ‘‘at risk of homelessness’’ status. This evidence must include an intake and certification form that meets HUD specifications and is completed by the recipient or subrecipient. The evidence must also include:
(1) If the program participant meets the criteria under paragraph (1) of the ‘‘at risk of homelessness’’ definition in § 576.2:
(i) The documentation specified under this section for determining annual income; (ii) The program participant’s certification on a form specified by HUD that the program participant has insufficient financial resources and support networks; e.g., family, friends, faith-based or other social networks, immediately available to attain housing stability and meets one or more of the conditions under paragraph (1)(iii) of the definition of ‘‘at risk of homelessness’’ in § 576.2;
(iii) The most reliable evidence available to show that the program participant does not have sufficient resources or support networks; e.g., family, friends, faith-based or other social networks, immediately available to prevent them from moving to an emergency shelter or another place described in paragraph (1) of the ‘‘homeless’’ definition. Acceptable evidence includes:
(A) Source documents (e.g., notice of termination from employment, unemployment compensation statement, bank statement, health-care bill showing arrears, utility bill showing arrears);

City of Berkeley ESG Policies and Procedures
May 12, 2020

(B) To the extent that source documents are unobtainable, a written statement by the relevant third party ( e.g., former employer, public administrator, relative) or the written certification by the recipient’s or subrecipient’s intake staff of the oral verification by the relevant third party that the applicant meets one or both of the criteria under paragraph (1)(ii) of the definition of ‘‘at risk of homelessness’’ in § 576.2; or (C) To the extent that source documents and third-party verification are unobtainable, a written statement by the recipient’s or subrecipient’s intake staff describing the efforts taken to obtain the required evidence; and (iv) The most reliable evidence available to show that the program participant meets one or more of the conditions under paragraph (1)(iii) of the definition of ‘‘at risk of homelessness’’ in § 576.2. Acceptable evidence includes:
(A) Source documents that evidence one or more of the conditions under paragraph (1)(iii) of the definition (e.g., eviction notice, notice of termination from employment, bank statement); (B) To the extent that source documents are unobtainable, a written statement by the relevant third party ( e.g., former employer, owner, primary leaseholder, public administrator, hotel or motel manager) or the written certification by the recipient’s or subrecipient’s intake staff of the oral verification by the relevant third party that the applicant meets one or more of the criteria under paragraph (1)(iii) of the definition of ‘‘at risk of homelessness’’; or To the extent that source documents and third-party verification are unobtainable, a written statement by the recipient’s or subrecipient’s intake staff that the staff person has visited the applicant’s residence and determined that the applicant meets one or more of the criteria under paragraph (1)(iii) of the definition or, if a visit is not practicable or relevant to the determination, a wri tten statement by the recipient’s or subrecipient’s intake staff describing the efforts taken to obtain the required evidence; or (2) If the program participant meets the criteria under paragraph (2) or (3) of the ‘‘at risk of homelessness’’ definition in § 576.2, certification of the child or youth’s homeless status by the agency or organization responsible for administering assistance under the Runaway and Homeless Youth Act (42 U.S.C. 5701 et seq. ), the Head Start Act (42 U.S.C. 9831 et seq.), subtitle N of the Violence Against Women Act of 1994 (42 U.S.C. 14043e et seq.), section 330 of the Public Health Service Act (42U.S.C. 254b), the Food and Nutrition Act of 2008 (7 U.S.C. 2011 et seq.), section 17 of the Child Nutrition Act of 1966 (42 U.S.C. 1786) or subtitle B of title VII of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11431 et seq.), as applicable.
(d) Determinations of ineligibility. For each individual and family determined ineligible to receive Emergency Solutions Grant (ESG) assistance, the record must include documentation of the reason for that determination. (e) Annual income. For each program participant who receives homelessness prevention assistance, or who receives rapid re-housing assistance longer than one year, the following documentation of annual income must be maintained:
(1) Income evaluation form containing the minimum requirements specified by HUD and completed by the recipient or subrecipient; and
(2) Source documents for the assets held by the program participant and income received over the most recent period for which representative data is available before the date of the evaluation ( e.g., wage statement, unemployment compensation statement, public benefits statement, bank statement); (3) To the extent that source documents are unobtainable, a written statement by the relevant third party ( e.g., employer, government benefits administrator) or the written certification by the recipient’s or subrecipient’s intake staff of the oral verification by the relevant third party of the income the program participant received over the most recent period for which representative data is available; or
(4) To the extent that source documents and third party verification are unobtainable, the written certification by the program participant of the amount of income the program participant received for the most recent period representative of the income that the program participant is reasonably expected to receive over the 3 -month period following the evaluation.
(f) Program participant records. In addition to evidence of homeless status or ‘‘at risk of homelessness’’ status, as applicable, records must be kept for each program participant that document:
(1) The services and assistance provided to that program participant, including, as applicable, the security deposit, rental assistance, and utility payments made on behalf of the program participant; (2) Compliance with the applicable requirements for providing services and assistance to that program participant under the program components and eligible activities provisions at § 576.101 through § 576.106, the provision on determining eligibility and amount and type of assistance at § 576.401(a) and (b), and the provision on using appropriate assistance and services at § 576.401(d) and (e); and
(3) Where applicable, compliance with the termination of assistance requirement in §576.402. (g) Centralized or coordinated assessment systems and procedures. The recipient and its subrecipients must keep documentation evidencing the use of, and written intake procedures for, the centralized or coordinated assessment

City of Berkeley ESG Policies and Procedures
May 12, 2020

system(s) developed by the Continuum of Care(s) in accordance with the requirements established by HUD. (h) Rental assistance agreements and payments. The records must include copies of all leases and rental assistance agreements for the provision of rental assistance, documentation of payments made to owners for the provision of rental assistance, and supporting documentation for these payments, including dates of occupancy by program participants. (i) Utility allowance. The records must document the monthly allowance for utilities (excluding telephone) used to determine compliance with the rent restriction.
(j) Shelter and housing standards. The records must include documentation of compliance with the shelter and housing standards in § 576.403, including inspection reports. (k) Emergency shelter facilities. The recipient must keep records of the emergency shelters assisted under the ESG program, including the amount and type of assistance provided to each emergency shelter. As applicable, the recipient’s records must also include documentation of the value of the building before the rehabilitation of an existing emergency shelter or after the conversion of a building into an emergency shelter and copies of the recorded deed or use restrictions. (l) Services and assistance provided. The recipient must keep records of the types of essential services, ren tal assistance, and housing stabilization and relocation services provided under the recipient’s program and the amounts spent on these services and assistance. The recipient and its subrecipients that are units of general purpose local government must keep records to demonstrate compliance with the maintenance of effort requirement, including records of the unit of the general purpose local government’s annual budgets and sources of funding for street outreach and emergency shelter services.
(m) Coordination with Continuum(s) of Care and other programs. The recipient and its subrecipients must document their compliance with the requirements of § 576.400 for consulting with the Continuum(s) of Care and coordinating and integrating ESG assistance with programs targeted toward homeless people and mainstream service and assistance programs.
(n) HMIS. The recipient must keep records of the participation in HMIS or a comparable database by all projects of the recipient and its subrecipients.
(o) Matching. The recipient must keep records of the source and use of contributions made to satisfy the matching requirement in § 576.201. The records must indicate the particular fiscal year grant for which each matching contribution is counted. The records must show how the value placed on third- party, noncash contributions was derived. To the extent feasible, volunteer services must be supported by the same methods that the organization uses to support the allocation of regular personnel costs.
(p) Conflicts of interest. The recipient and its subrecipients must keep records to show compliance with the organizational conflicts-of-interest requirements in § 576.404(a), a copy of the personal conflicts of interest policy or codes of conduct developed and implemented to comply with the requirements in § 576.404(b), and records supporting exceptions to the personal conflicts of interest prohibitions. (q) Homeless participation. The recipient must document its compliance with the homeless participation requirements under § 576.405.
(r) Faith-based activities. The recipient and its subrecipients must document their compliance with the faith- based activities requirements under § 576.406.
(s) Other Federal requirements. The recipient and its subrecipients must document their compliance with the Federal requirements in § 576.407, as applicable, including:
(1) Records demonstrating compliance with the nondiscrimination and equal opportunity requirements under § 576.407(a), including data concerning race, ethnicity, disability status, sex, and family characteristics of persons and households who are applicants for, or program participants in, any program or activity funded in whole or in part with ESG funds and the affirmative outreach requirements in §576.407(b). (2) Records demonstrating compliance with the uniform administrative requirements in 24 CFR part 85(for governments) and 24 CFR part 84 (for nonprofit organizations). (3) Records demonstrating compliance with the environmental review requirements, including flood insurance requirements.
(4) Certifications and disclosure forms required under the lobbying and disclosure requirements in 24 CFR part 87. (t) Relocation. The records must include documentation of compliance with the displacement, relocation, and acquisition requirements in § 576.408.
(u) Financial records. (1) The recipient must retain supporting documentation for all costs charged to the ESG grant. (2) The recipient and its subrecipients must keep documentation showing that ESG grant funds were spent on allowable costs in accordance with the requirements for eligible activities under § 576.101-§ 576.109 and thecost

City of Berkeley ESG Policies and Procedures
May 12, 2020

principles in OMB Circulars A–87 (2 CFR part 225) and A–122 (2 CFR part 230). (3) The recipient and its subrecipients must retain records of the receipt and use of program income. (4) The recipient must keep documentation of compliance with the expenditure limits in § 576.100 and the expenditure deadline in § 576.203.
(v) Subrecipients and contractors. (1) The recipient must retain copies of all solicitations of and agreements with subrecipients, records of all payment requests by and dates of payments made to subrecipients, and documentation of all monitoring and sanctions of subrecipients, as applicable. If the recipient is a State, the recipient must keep records of each recapture and distribution of recaptured funds under §576.501. (2) The recipient and its subrecipients must retain copies of all procurement contracts and documentation of compliance with the procurement requirements in 24 CFR 85.36 and 24 CFR 84.40–84.48. (3) The recipient must ensure that its subrecipients comply with the recordkeeping requirements specified by the recipient and HUD notice or regulations.
(w) Other records specified by HUD. The recipient must keep other records specified by HUD. (x) Confidentiality. (1) The recipient and its subrecipients must develop and implement written procedures to ensure:
(i) All records containing personally identifying information (as defined in HUD’s standards for participation, data collection, and reporting in a local HMIS) of any individual or family who applies for and/or receives ESG assistance will be kept secure and confidential;
(ii) The address or location of any domestic violence, dating violence, sexual assault, or stalking shelter project assisted under the ESG will not be made public, except with written authorization of the person responsible for the operation of the shelter; and
(iii) The address or location of any housing of a program participant will not be made public, except as provided under a preexisting privacy policy of the recipient or subrecipient and consistent with state and local laws regarding privacy and obligations of confidentiality.
(2) The confidentiality procedures of the recipient and its subrecipients must be in writing and must be maintained in accordance with this section.
(y) Period of record retention. All records pertaining to each fiscal year of ESG funds must be retained for the greater of 5 years or the period specified below. Copies made by microfilming, photocopying, or similar methods may be substituted for the original records.
(1) Documentation of each program participant’s qualification as a family or individual at risk of homelessness or as a homeless family or individual and other program participant records must be retained for 5 years after the expenditure of all funds from the grant under which the program participant was served; (2) Where ESG funds are used for the renovation of an emergency shelter involves costs charged to the ESG grant that exceed 75 percent of the value of the building before renovation, records must be retained until 10 years after the date that ESG funds are first obligated for the renovation; and (3) Where ESG funds are used to convert a building into an emergency shelter and the costs charged to the ESG grant for the conversion exceed 75 percent of the value of the building after conversion, records must be retained until 10 years after the date that ESG funds are first obligated for the conversion. (z) Access to records. (1) Federal government rights. Notwithstanding the confidentiality procedures established under paragraph (w) of this section, HUD, the HUD Office of the Inspector General, and the Comptroller General of the United States, or any of their authorized representatives, must have the right of access to all books, documents, papers, or other records of the recipient and its subrecipients that are pertinent to the ESG grant, in order to make audits, examinations, excerpts, and transcripts. These rights of access are not limited to the required retention period but last as long as the records are retained.

Alameda County
Priority Home Partnership
(PHP)
City of Berkeley

Emergency Solutions Grant
Rapid Rehousing and Prevention
Assistance
Policies and Procedures Manual

Version 2
January 2014

ii

Priority Home ESG
Policies and Procedures Manual

Table of Contents

Introduction ................................................................................................................... 3 Program Purpose......................................................................................................... 3 Interim Guidelines ........................................................................................................ 3 Structure of the Manual ............................................................................................... 4 1: Participant Eligibility ................................................................................................ 5 Eligibility Determination ............................................................................................... 6 2: Enrollment ................................................................................................................ 7 Budget and Housing Stability Plan............................................................................... 7 3: Financial Assistance for Housing ........................................................................... 7 Eligible Financial Assistance Expenses ....................................................................... 7 Determining the Amount of Financial Assistance ........................................................ 8 4: Supportive Services and Connection to Mainstream Resources ........................ 9 Links to Mainstream Services .................................................................................... 10 Legal Services ........................................................................................................... 11 5: Housing Unit Requirements ................................................................................... 11 A. Rent Reasonableness and Compliance with Fair Market Rent ............................ 12 B. Housing Inspection ................................................................................................ 13 C. Rental Assistance Agreement ............................................................................... 13 6: Three Month Reassessment of Eligibility ............................................................. 14 7: Termination of Housing Assistance or Program Participation ........................... 14 Grievances and Appeals ............................................................................................ 15 8: Program Exit ............................................................................................................ 15 Appendix of Forms and Documents .......................................................................... 17 ESG Client File Document Check List .................................................................... 18 ESG Application for Assistance and Eligibility Determination Form ....................... 19 ESG Program Participation Agreement .................................................................. 27 Sample Budgeting Worksheet ................................................................................ 28 ESG Housing Stability Plan ...................................... Error! Bookmark not defined.

ESG Financial Assistance Calculation Form .......................................................... 30 Rent Reasonableness and FMR Certification ........................................................ 33 Habitability Standards Inspection Form .................................................................. 34 Rental Assistance Agreement Letter ...................................................................... 41 Three Month Reassessment of Eligibility ............................................................... 42 Notification of Termination of ESG Assistance ....................................................... 46 ESG Income Eligibility Calculation Worksheet ....................................................... 42

3 COB ESG Manual and Forms - Ver 2 Jan. 2014
Introduction

The Emergency Solutions Grant (ESG) is a federal program that provides funding to states and local governments for emergency services and housing supports for homeless and at-risk households. Under the 2009 HEARTH Act, eligible activities under ESG were expanded from traditional shelter and outreach services to also include rapid rehousing and targeted homeless prevention. Per the ESG regulations (§576.400) ESG recipients must consult with the Continuum of Care entity in their region to determine how to allocate ESG funds, develop performance standards and evaluate the outcomes of projects and activities funded with ESG. They also must develop written policies and procedures for determining which households will receive assistance and for determining the type, amount, and length of assistance to be offered to eligible households.

Program Purpose
The primary purpose of local ESG-funding for prevention and/or rapid rehousing is to serve households as close to the “front door” of homelessness as possible – either by diverting them from entry into homelessness, and particularly to shelter, through prevention assistance, or assisting persons as soon as possible after becoming homeless, including after entering shelter, to end their homelessness quickly and shorten lengths of stay in shelter and time spent homeless. In some cases, particular subpopulations may be targeted for this assistance, consistent with plans to end homelessness.

This manual of policies and procedures covers all ESG recipients and subrecipients operating prevention and/or rapid rehousing programs in Alameda County, as these areas are all contained in HUD-recognized Continuum of Care 502. ESG entitlement recipients in Alameda County currently include the Cities of Berkeley and Oakland and the County of Alameda on behalf of the Urban County. Additional ESG subrecipients within the County may be selected by the State of California or, from time to time, additional cities may become entitlement for ESG. This manual was developed collaboratively by the CoC Entity, EveryOne Home, and all current entitlement recipients and State ESG subrecipients.

Interim Guidelines
The ESG and CoC regulations require that the Continuum of Care develop and implement a centralized or coordinated assessment system, and a set of written standards for CoC funded activities. Once coordinated assessment is established, each ESG-funded program or project must use the assessment system, and recipients and subrecipients must work with the Continuum of Care to ensure that screening, assessment and referral of program participants are consistent with the written standards required for ESG programs. This manual and the written standards contained herein for prevention and rapid rehousing are considered interim for the period until a broader coordinated assessment system and written standards for assistance have been developed and adopted across the Continuum.

4 COB ESG Manual and Forms - Ver 2 Jan. 2014

A complete version of the ESG Interim Regulations can be found here:
https://www.onecpd.info/resources/documents/HEARTH_ESGInterimRule&ConPlanCon formingAmendments.pdf
Structure of the Manual
This manual is for ESG rec ipients, subrecipients, and interest ed parties. It provides a
detailed description of the steps that will be taken to determine eligibility, calculate financial assistance, recertify for eligibility, provide support and terminate ESG assistance for rapid rehousing and prevention. Required and/or recommended forms and documents are provided in an Appendix of Forms and Documents at the end of the manual. In some cases, recipients or subrecipients may target their programs more specifically to subpopulations, such as survivors of domestic violence or seniors who are otherwise eligible.

Items in bold italics that are highlighted in grey, are changes to the manual specific to how the City of Berkeley will implement the program.

A document icon appears by every form that is referred to and clicking on the highlighted hyperlinks on the names of the form will take the reader directly to the referenced documents in the Appendix.

 Some key forms and information are entered into the county-wide InHOUSE Homeless Management Information System. Forms that are provided by InHOUSE are not included in this manual but are indicated by a computer icon.

Ac
knowledgments: The development of the ESG Manual was supported by Alameda County EveryOne Home and t
he City of Berkeley. For more information related to the ESG Manual or about the Priority Home Partnership, please contact Elaine DeColigny, EveryOne Home Director, at (510) 670-5944 or email [email protected]. The manual was prepared by Katharine Gale Consulting with input from local government and community agency staff including the following persons: Kerry Abbot, Erika Bernheimer, Elaine DeColigny, Geoff Green, Kristin Lee, Susan Shelton, Liz Varela, Jennifer Vasquez, and Riley Wilkerson.

5 COB ESG Manual and Forms - Ver 2 Jan. 2014
1: Participant Eligibility

As stated above, the primary purpose of ESG-funded rapid rehousing and prevention is to reduce entries into homelessness and/or shorten stays in homelessness to the greatest extent feasible.

To be eligible to receive ESG prevention or rapid rehousing assistance, participant households in Alameda County must meet both national and local requirements, and this eligibility must be documented with an application and supporting documentation kept in a client file. These requirements include:
• Participants must be homeless or at imminent risk of homelessness, per the applicable HUD definitions in the ESG regulation (§576.2) supported by documentation;
• P articipants must be one of the locally targeted populations for the program, as specified on the application and eligibility determination form; • P articipants must be willing to participate in the program and to meet the terms of a self-developed Housing Stability Plan;
• Participants may not have already received 24 months of ESG assistance during the past 36 months (§576.105(c));
• Participants must meet the local asset policy, including having cash or equivalent assets of less than $2,000 per single individual and $3,000 per couple;

In addition:
• Participants receiving prevention assistance must have incomes at or below 30% of the Area Median Income (§576.103).

Eligibility for Rapid Rehousing

Rapid rehousing provides financial assistance and supportive services to individuals or families that are literally homeless, staying in shelter or transitional housing or on the streets or other places not suitable for human habitation, or exiting institutions and having entered from one of these locations. Eligibility for rapid rehousing includes those fleeing domestic violence who are living in one of the places named above.

In keeping with the intentions of the program, rapid rehousing assistance will be used primarily to serve households that are:
1) Adults or family households able to be rehoused rapidly without anticipation of an ongoing subsidy, with ESG financial assistance anticipated to be of six months or less duration;
2) Adults or family households able to be rehoused rapidly with an ongoing subsidy from another source anticipated within six months of ESG program participation
3) Transition-age youth, especially those recently discharged from foster care, who are able to be rehoused rapidly without anticipation of an ongoing subsidy, with ESG assistance of eighteen months or less duration.

6 COB ESG Manual and Forms - Ver 2 Jan. 2014
Eligibility for Prevention Assistance

Prevention assistance will be directed to persons who are not literally homeless but are at imminent risk of homelessness per the HUD Homeless definition (Category 2).

Prevention assistance may include support to a household to retain its current housing or to move to other housing without having to become literally homeless. While the ESG regulations allow for ESG prevention to be provided to those categorized as “at- risk” but not necessarily at “imminent risk”, Alameda County ESG programs will target prevention services specifically to those that are at “immediate risk” defined as:
“An individual or family who will imminently lose their primary nighttime residence, provided that:
- the primary nighttime residences will be lost within 14 days of the day of application for homeless assistance;
- no subsequent residence has been identified; and,
- the individual or family lacks the resources of support networks, e.g., family, friends, faith-based or other social networks, needed to obtain other permanent housing.”

Within the category of “imminent risk” special attention and outreach will be done to target those households that are:
1) doubled up with family and friends, must move within 14 days and are seeking to enter shelter;
2) living in a hotel or motel using their own resources , must leave within 14 days, and are seeking to enter shelter;
3) living in their own housing, are being evicted for non-payment of rent, must leave within 14 days, and are seeking shelter; Not eligible under the City of Berkeley Priority Home Partnership (PHP). These households may be eligible for the Housing Retention Program (HRP).
4) fleeing domestic violence;
5) imminently leaving foster care, or have recently left foster care and are at imminent risk of losing their current housing.

Eligibility Determination
Program operators must determine that potential participants are eligible for assistance, and document this eligibility, including verifying income and housing status. The Program Application and Eligibility Determination Form contains key questions and documentation requirements.

A copy of the ESG Program Application and Eligibility Determination Form can be found in the Appendix. This document and all supporting documentation should be placed in the Participant’s File.
A cover sheet for participant files with a list of all of the program documents can be found here.

7 COB ESG Manual and Forms - Ver 2 Jan. 2014
Ineligible applicants: If a household is assessed and determined to be ineligible, the program operator must notify the household that they have been determined to be ineligible, provide them with appropriate referrals which should be noted on the application form, and create a client file documenting the assessment process and determination.
2: Enrollment

Once found eligible, to enroll the head of household must sign the ESG Participation Agreement complete the HMIS ROI and staff must complete an HMIS Standard Intake Form (SIF) for all household members.

A copy of the ESG Program Participation Agreement can be found in the appendix, immediately following the Application form.

 The HMIS Release of Information (ROI), and the Standardized Intake Form (SIF) are developed and updated by the InHOUSE staff at Alameda County Housing and Community Development Department, in accordance with HUD regulations. Housing Agency staff must ensure that the forms in use are the most recent ones, as HUD and local requirements change periodically. If you are unsure that the forms are the most recent, email [email protected]
.

Budget and Housing Stability Plan

Th
e purpose of ESG Prevention and/or Rapid Rehousing assistance is to provide the support
necessary to help the household retain or gain housing in the shortest period of time possible. Critical to being able to retain the housing is a budget and a housing plan. The budget is also needed to determine the amount of financial assistance to be provided.

The Housing Stability Plan should be updated as frequently as necessary to reflect changing situations. Once a participant has moved into housing, the housing specialist and participant should prepare a new Housing Stability Plan that emphasizes those steps or actions needed to retain housing.

A Sample Budgeting Worksheet and a sample Housing Stability Plan format can be found in the Appendix of Forms. ESG-funded programs may use another version of these forms if approved by the recipient. Be sure to make a copy of the Budget and Housing Plan for the participant and insert a signed copy in the participant’s file. 3: Financial Assistance for Housing
Eligible Financial Assistance Expenses

8 COB ESG Manual and Forms - Ver 2 Jan. 2014
The ESG program has the ability to provide temporary financial assistance to participants on a short or medium-term basis. This assistance may include:

Security Deposits: The housing agency may provide a maximum of two times the monthly rent for a unit as a security deposit to assist a participant to secure housing. At such time as the participant may leave the unit and the landlord return all or part of the deposit to the participant, the participant may retain any balance to use toward a new housing situation.

Utility Deposits: If, in order to begin utility service, the household must provide a deposit to a utility company, the program may assist with this deposit.

Rental Assistance payments: If the participant cannot currently afford to rent a unit in the community but is reasonably anticipated to have sufficient income, either through employment or benefits, within approximately six months the program may provide a rental subsidy for the participant. Such subsidies will be as low as possible:
 If the participant has an income he/she is expected to contribute at least 50% of his/her income toward the rent, unless the participant is expect to receive a permanent housing subsidy within approximately six months, in which case the participant may pay only 30% of their income. Documentation of the expectation of a permanent subsidy should be included in the file.
 If the participant has no income, the program may subsidize the entire rent for the first three months.

Rental assistance may be conditioned on the participant fulfilling his or her agreements as part of the Housing Stability Plan and is never offered for more than three months at a time. To continue rental assistance after three months, the program must recertify the participant. See Section 6: Three Month Reassessment of Eligibility

Past due rent arrears: If in order for a household to retain their housing they must pay past due rent the program will cover up to three months of rent arrears not to exceed $3,000 Not eligible under the City of Berkeley PHP.

Past due utility arrears: In r
are cases, the ESG program will provide funding for past due utilities. The program will only provide such funding for prevention clients if failure to do so will result in the loss of utilities and under the terms of the p articipants lease
this would be grounds for eviction. The program will only provide utility arrears assistance to rapid rehousing clients if utility arrears mean that then household will be unable to establish utility service in their new housing.

In addition, ESG funds may be used to cover the costs of rental applications provided this is a fee that is charge by the owner to all applicants.

Determining the Amount of Financial Assistance

9 COB ESG Manual and Forms - Ver 2 Jan. 2014
The amount of financial assistance is determined by the amount needed to secure the housing and by the amount of contribution the household is able to make toward the housing costs.

For one-time costs, such as security deposits, and rent and utility arrears, the program will pay the entire amount if the household will have less than 50% of income available after paying rent, the household’s budget does not contain any disposable income, and the household assets are less than $500.00. If the household has assets greater than $500, and/or the household budget indicates income is available to make a portion of the payment, the household should be required to provide a portion of the deposit and/or arrears. The household’s payment may be made through a payment plan with the landlord or utility company if that is possible.

For rental assistance payments, households with any income are expected to contribute either 50% of their income, or 50% of the rent, whichever is lower. An exception to this rule may be made for persons with disabilities who are anticipated to receive a permanent subsidy within six months of their ESG program enrollment.

With agency supervisor approval, households may be permitted to contribute less toward the rent for a brief period to cover other extraordinary costs. The program may pay the entire rent on behalf of households that have no income.

The ESG Financial Assistance Calculation Form can be found in the appendix.

The program should complete the form with the participant and the participant should sign it. This calculation needs to be prepared every three months for households receiving medium-term rental assistance.

 All financial assistance provided must be recorded in HMIS. 4: Supportive Services and Connection to Mainstream Resources Whether covered by ESG funds or other sources, ESG programs are expected to assist clients with housing stability case management and with housing search and placement services as needed.

Housing stability case management includes:
• conduct ing the official evaluation of eligibility and need, including verifying and documenting eligibility
• counseling
• developing, securing, and coordinating services and assistance in obtaining Federal, state and local benefits
• monitoring and evaluating participant progress;
• providing information and referral to other providers; • developing an individualized housing plan to permanent housing stability; and • conducting reevaluations.

10 COB ESG Manual and Forms - Ver 2 Jan. 2014
These services may not exceed 30 days during the period the program participant is seeking permanent housing, and may be provided for up to a total of 24 months within a 36 month period.

While providing prevention or rapid rehousing financial assistance, the program must ensure that the participant meets with a case manager not less than once per month to assist the participant in ensuring long-term housing stability. Case management should be provided more frequently if needed.

Housing search assistance are those services intended to assist program participants in locating, obtaining, and retaining suitable permanent housing, and are expected to be offered to all participants receiving rapid rehousing assistance or prevention assistance that includes moving to another unit. These include:
• assessment of housing barriers, needs, and preferences; • development of a plan for locating housing;
• housing search;
• outreach and negotiations with landlords; and
• assistance with submitting rental applications and understanding leases.

Links to Mainstream Services

As part of the stability case management, each participant is expected to be assisted, as needed to obtain other services and mainstream benefits including:
• appropriate supportive services including assistance in obtaining permanent housing, medical health treatment, mental health treatment, counseling, supervision, and other services essential for achieving independent living, and • other federal, state, local, and private assistance available to assist the program participant in obtaining housing stability, including
o Medi-Cal or other medical insurance
o TANF
o Food stamps/Supplemental nutrition assistance (SNAPS) o WIC
o U nemployment insurance
o SSI/SSDI
o Child and adult care food program
o O ther mainstream benefit programs from which the participant household could benefit.

While no specific form is provided for this documentation, all case management meetings must be documented in the participant file, and/or in the HMIS case management module. Documentation should include evidence of assistance provided to obtain mainstream resources and the results of that assistance. Subrecipients are encouraged to check with the recipient for approval of documentation.

11 COB ESG Manual and Forms - Ver 2 Jan. 2014
Legal Services

ESG funds may be used for legal services that are necessary to resolve a legal problem that prohibits the program participant from obtaining permanent housing or will likely result in the program participant losing the permanent housing in which the program participant currently resides. More detail on eligible legal services activities can be found at (§576.102 (a)(1)(vi)) and (§576.105(b)(4)).

While legal services providers that do not provide financial assistance are not required to complete the financial assistance calculation form, they must ensure that all households assisted meet program eligibility (Section 1 above) including completing the
application for assistance to document participant eligibility, and must ensure that the units assisted meet the habitability standards in Section 5 below. 5: Housing Unit Requirements
In addition to the household being eligible, the unit to be assisted must also meet eligibility requirements. These include that the rent is both reasonable and at or below the Fair Market Rent market rent, and that the unit meets habitability standards.

12 COB ESG Manual and Forms - Ver 2 Jan. 2014
A. Rent Reasonableness and Compliance with Fair Market Rent

ESG programs must perform both a rent reasonableness determination and document that the rent falls at or below the Fair Market Rent on every unit assisted, whether for prevention or rehousing.

“Rent reasonableness” means that the total rent charged for a unit must be reasonable in relation to the rents being charged during the same time period for comparable units in the private unassisted market and must not be in excess of rents being charged by the owner during the same time period for comparable non-luxury unassisted units.

To make this determination, the recipient or subrecipients should consider (a) the location, quality, size, type, and age of the unit; and (b) 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 charged rents to other units owned (for example, the landlord would document the rents paid in other units). NOTE that not every element in the suggested list of nine things to check for must be known to establish a comparable unit. See more guidance at http://portal.hud.gov/hudportal/documents/huddoc?id=DOC_11753.pdf

The Fair Market Rent (FMR) is a benchmark established by HUD for regions. For ESG, the FMR is the maximum rent permitted even if other similar units rent for more.

Final FY 2013 FMRs By Unit Bedrooms
Oakland-Fremont, CA HUD Metro FMR Area (Alameda and Contra Costa Counties) SRO Studio/Efficiency 1-bedroom 2-bedroom 3-bedroom 4-
bedroom
$776 $1,035 $1,255 $1,578 $2,204 $2,704
Source: http://www.huduser.org/portal/datasets/fmr.html

The above chart displays the Fair Market Rents applicable during FY2013. Fair Market Rents are updated and published by HUD every year. Programs must ensure that they are using the FMR’s in effect at the time of their determination.

A copy of a Rent Reasonableness and FMR Certification form can be found in the forms appendix. Subrecipients may use an alternative rent reasonableness determination form meets the requirements of the ESG regulations §576.106 and has been approved by the ESG recipient.

13 COB ESG Manual and Forms - Ver 2 Jan. 2014
B. Housing Inspection

In order to ensure that ESG funds are used in housing that meets minimum habitability standards, an inspection must be performed on every unit assisted, whether for prevention or rehousing. This inspection includes compliance with the Lead Paint Poisoning Prevention Act.

A copy of a suggested Habitability Standards Inspection Form can be found in the forms appendix. Subrecipients may use an alternative inspection form as long as it covers all of topic areas required under ESG regulations §576.403 and has been approved by the ESG recipient.

C. Rental Assistance Agreement

Rel
ationships with landlords are a central component of the program. The housing specialist assists both the participant and the landlord to make the housing successful.

Once a unit has been identified and inspected, the housing agency must ensure that:
a) The tenant receives a written lease or rental agreement from the landlord which clearly outlines the terms of tenancy and conforms with applicable California and local law; and
b) The landlord is apprised of the nature of the program, the anticipated support to the participant, the obligations of the landlord, and the manner in which the landlord may contact the program if there are concerns.

At a minimum, the housing ag
ency will provide the landlord with a copy of the Rental Assistance Agreement Letter describing the program and outlining the basic support the participant is anticipated to receive. The landlord must sign the letter and return it to the agency. Some agencies may prefer to use a contract or housing assistance payments (HAP) agreement that outlines in greater detail the rights and obligations of the parties.

Use of such an agreement is fine if it covers all requirements in the ESG regulations §576.106 and has been approved in advance by the ESG recipient.

In order to determine that the landlord named on the lease is the legitimate owner of the property, the housing agency will use a database service, such as Realquest, or another manner to verify and document the ownership. In addition, the housing agency shall collect a W-9 from the landlord or property management agency and follow all IRS reporting requirements.

A copy of the Rental Assistance Agreement Letter is included in the appendix. A copy of this letter or an acceptable substitute agreement should be kept in the participants file, along with a copy of the tenant’s lease and printout from the database used to verify the ownership of the unit and a copy of the W-9. The original W-9 must be given to the housing agency’s finance division the City of Berkeley. The City of Berkeley will verify property ownership.

14 COB ESG Manual and Forms - Ver 2 Jan. 2014
6: Three Month Reassessment of Eligibility

Any participant who receives more than three months of assistance from the program needs to be formally reassessed. This is distinguished from the more frequent check- ins and meetings with the client, which should occur frequently and as needed, and are recorded in case notes.

During the reassessment process, the program is, at a minimum, confirming:
• The participant has not received more than 24 months of assistance, including any arrears coverage.
• The participant’s income level is such that there is still a need to provide financial assistance in order to maintain housing stability.
o Income is not greater than 30%of the Area Median Income (AMI) o Rent is more than 50% of participant income (unless the participant is awaiting a permanent subsidy and is currently paying 30% of income.) • The participant is making documented progress on their housing plan and taking the steps needed towards housing stability without program financial assistance. • The participant lacks the financial resources or support networks to secure their housing without continued assistance.

The three month reassessment is also used to update the participant’s HMIS record with current information about housing and income.

Once the three month reassessment of eligibility is completed, the household should be notified whether they will continue to receive assistance or not, including signing the reassessment form. If continuing to receive assistance, new documents, including an updated housing stability plan, budget and financial assistance calculation should be prepared and discussed with the client.

A copy of the Three Month Reassessment of Eligibility is included in the appendix.

The Reassessment requires updated documentation of income, which should be attached to the form and included in the file.
 Key pieces of information from the Three Month Reassessment Form, including any change in income or address is to be entered into HMIS. (In the future, the Three Month Reassessment may be an HMIS provided form.)
7: Termination of Housing Assistance or Program Participation

H
ousing assistance under this program is intended to be temporary and to help participants secure housing that they can remain in without long-t erm financial support.

Any housing assistance is contingent on the participant’s active participation in carrying out the terms of his/her Housing Stability Plan. Failure to take steps agreed to in the plan, such as seeking work, applying for benefits, looking for housing or accepting housing that meets the participant’s criteria are a reasonable basis for recommending termination of financial assistance.

15 COB ESG Manual and Forms - Ver 2 Jan. 2014

If a program participant is found to be violating the participation agreement, reasonable efforts will be made and documented by staff to assist the participant to address the issue or correct the violation prior to terminating services. Violations that endanger staff, any other participant, any other person, or the viability of the program as a whole will be acted upon immediately.

If a participant is determined to be in continued or grave violation of the program rules, a written Notice of Termination of Assistance will be provided to the program participant containing a clear statement of the reasons for termination, the date on which the termination will become effective, and the process for appealing the decision.

Participants receiving a Notice may request that the decision to terminate participation be reviewed by making a request to the designated supervisor within the agency. This request must be made in writing and must be reviewed within 14 calendar days. A written notice of the final decision will be issued to the participant.

The program may also resume assistance to a program participant whose assistance was previously terminated with the approval of the agency supervisor.

A sample Notification of Termination of ESG Assistance is provided in the Appendix of Forms. Subrecipients may use an alternative Termination form as long as it covers all of topic areas required under ESG regulations §576.402 and has been approved by the ESG recipient, the City of Berkeley.

Grievances and Appeals

Agencies ESG subrecipients must notify participants of the agency’s grievance policy at the time of program enrollment, including providing them with a written copy of the policy and keeping a copy of a signed version of the policy or other notification in the participant file. Housing agencies will follow their agency grievance and appeals process, through to the level of the highest ranking staff member of the agency or as may be otherwise specified in the agency’s approved policy and procedures.

If there is a grievance specific to the ESG which has not been resolved through the agency grievance process, ESG program participants may appeal to the local recipient, the City of Berkeley. Recipients will follow their appeal process.

8: Program Exit
Upon completion of the program, or upon termination prior to completion, all members of the household should be exited from the program in HMIS. At this time all information including household income, final address and housing status are recorded and updated.

16 COB ESG Manual and Forms - Ver 2 Jan. 2014
 The Exit Form is an HMIS-provided form. A printed copy of the form(s) should be kept in the participant file and all data entered into HMIS.

17 COB ESG Manual and Forms - Ver 2 Jan. 2014

City of Berkeley
ESG Rapid Rehousing and
Prevention

Appendix of Forms and Documents

(click here to return to the main section of manual)

18 COB ESG Manual and Forms - Ver 2 Jan. 2014
City of Berkeley
ESG Client File Document Check List
(click here to return to relevant section of manual)

Last Name: ____________________ First Name: ________________ HMIS ID: ________

I. Eligibility Documentation (check or indicate date completed in blank to left) _____ Application for Assistance and Eligibility Screening Form ____ Homeless Status/At-Risk Housing Status and Back up Documentation ____ Income Eligibility Determination and Back up Documentation ____ Asset Verification Documentation
_____ Intake on Head of Household (HMIS SIF form)
_____ Intake(s) on other household members (if applicable) (HMIS SIF form) Intake on other adult ___________ Intake on other adult ____________ Intake on child: _______________ Intake on child:_________________ _____ Other: __________________________
_____ Current ROI ___________ Date:____________

II. Documentation on the Housing Unit and/or Utilities (check or indicate date completed in blank to left)
_____ Documentation of rent or utility arrears (if applicable) _____ Rent Reasonableness and Payment Standard determination for rental unit _____ Habitability Inspection (includes Lead Assessment) _____ Lease between Participant and Landlord
_____ Rental Assistance Agreement with Landlord
_____ W- 9 Form
_____ Other: __________________________
_____ RealQuest or other owner verification documentation

III. Documentation of Assistance/Ongoing Services (check or indicate date completed in blank to left)
_____ Household Budget
_____ Housing Stability Plan
_____ Financial Assistance Calculation Form
_____ Links to Mainstream Resources
_____ Case Management Notes
Three Month Reassessment(s) (if applicable, insert dates)

1. _____________ 2. ______________ 3.____________ 4.______________ _____ Exit Form (HMIS form)
_____ Termination of Housing Assistance Form (if applicable) _____ Other: __________________________

19 COB ESG Manual and Forms - Ver 1.1 2/20/13

City of Berkeley
ESG Application for Assistance and Eligibility Determination Form (click here to return to relevant section of the manual)

Complete this form and have the head of household sign it. This form will determine eligibility and act as an application by the household for assistance.

Assessment Date: __ __ / __ __ / __ __ __ __

Staff: ___________________________________ Agency: ______________________________

A. General Information

1. Head of Household:

First: ___________________ Middle: ____________ Last: __________________ Suffix:____

Complete ROI for Head of Household or check here _________if current ROI on file

2. Other Members of Household

First Name Last Name Age Relationship to Head
of Household

Total number of persons in household: ________

If
applicant is determined to be eligible for assistance, you must complete an HMIS Standard Intake Form (SIF) for every household member.

3. Why are you seeking assistance? Please choose an option, then describe below.

I am living on
the streets, or a
place not meant
for human
habitation

I am in a shelter or TH
housing program and have
been referred for rapid re-
housing
 I am applying for
shelter because I
must leave where I
am currently staying
I want to keep the
housing I have and
am at imminent risk of
losing it Not eligible
under the City of
Berkeley PHP

Explanation:
______________________________________________________________________________

I understand that I am applying for assistance from the federally-funded Emergency Solutions Grant Program. I understand that I am required to certify that all information in this application is true and to provide all required documents to determine eligibility and to enter into a housing stability plan if I am eligible for assistance. I also understand that financial assistance is not guaranteed, is time-limited, and may be terminated or adjusted at any time. I declare that all information I have provided in this application is true to the best of my knowledge.

Head of Household Signature: _________________________ Date: _________________

20 COB ESG Manual and Forms - Ver 1.1 2/20/13

B . Rapid Rehousing Assessment (Cross through and skip this section if applicant household is applying for prevention assistance)
Homeless Status Documentation: To receive rapid rehousing assistance, clients must be homeless by the HUD Homeless Definition and eligible for assistance under certain categories. Use this portion of the form if the applicant clien t household is Literally Homeless (Category 1), or is fleeing/attempting to flee domestic violence (Category 4) and also meets the category of Literally Homeless. Otherwise, complete Section B. of this form for Homeless Prevention.

1. Is household among the eligible target population for this program?  Living/staying in a shelter.
 Living on the streets, a car, an encampment or a place not meant for human habitation.  Living/staying in transitional housing.
 Exiting an institution where s(he) resided for 90 days or less and previously resided in a shelter or the streets of place not mean for human habitation.
 Fleeing or attempting to flee domestic violence and also meets one of the above conditions.

Documentation
Literally Homeless – on the streets or
in a shelter
(in order of preference for documentation)
 Written observation by an outreach worker (attached), or  Written referral by another housing or service provider (attached) HMIS intake for shelter/TH, or
 Self- certification that s(he) was living on the streets or in a shelter (attached)

Exiting an institution and entered from
literal homelessness
One of the forms of evidence above and
 Discharge paperwork or written/ or documented oral referral (attached), or  Written report of intake workers due diligence to obtain above evidence and certification by the individual that they exited institution (attached) Be sure to attach the supporting documentation to the application in file.

2. This household is a candidate for ESG rapid rehousing because:
 They
are homeless but have adequate income to afford a place if assisted to obtain one with short-term assistance (deposit and up to one to three month’s rent subsidy).  They are homeless and don’t currently have adequate income for housing but have potential to increase income to be self sustainable within approximately 6 months and are willing to commit to a housing stability plan.
 They are currently homeless but with assistance can move into a stable situation with friends or family or another situation that doesn’t require an increase in income and will be included on a lease.  They are currently homeless and are expected to receive a housing subsidy within six months from another source but need financial assistance to gain housing and/or support services

Subs
idy anticipated:
 OP
RI  VASH  Shelter Plus Care  Other: __________________________

 Benefit anticipated: SSI Date expected: __________Verified by 3rd Party: _______________

Note: ESG funds may not be used to cover any cost covered by another subsidy source. For rapid rehous ing
candidates with a subsidy, ESG may only be used to pay security deposit and utility deposits if needed to secure housing.

 Current Subsidy ______________ pays for:
___________________________________________________________

 No other subsidy currently
Proceed to Part D: Income Verification Section

21 COB ESG Manual and Forms - Ver 1.1 2/20/13

C. Homelessness Prevention (Cross through and skip this section if applicant household is applying for Rapid Rehousing)

To receive Prevention assistance, clients may either be homeless under certain categories of the HUD Homeless Definition or At risk of Homelessness under any category of that definition. Use this portion of the form if the applicant client household is at Imminent Risk of Homelessness (Category 2), fleeing/attempting to flee domestic violence but does not meet the category of Literally Homeless (Category 4) or is At Risk of Homelessness. Households who do not qualify for rapid rehousing or prevention assistance under these definitions are not eligible for ESG assistance under this program.

1. This household is a candidate for prevention assistance because:
 They are currently seeking shelter, and have been staying with family or friends who will no longer let them remain there. (Must be required to leave within 14 days.)  They are staying in a hotel or motel using their own resources, have no other residence and lack the resource and support networks to obtain other permanent housing.  They are fleeing or attempting to flee domestic violence, have no other residence and lack the resource and support networks to obtain other permanent housing.
 They have a place to live with their name on the lease from which they are being evicted (must be required to leave within 14 days.) Not eligible under the City of Berkeley PHP.  The are about to be discharged from foster care, or have recently been discharged from foster care, and the residence where they are currently living will be lost within 14 days

Documentation
Imminent Risk of Homelessness  A court order resulting from an eviction action notifying the individual or family that they must leave (attached), or  Leaving a hotel or motel – evidence that household has been staying in hotel/ motel (attached), and this application documents lack of resources
 A documented and verified oral statement that residence will be lost within 14 days of the date of this application (attached), and this application documents lack of resources.

Leaving an institution, including
foster care
One of the forms of evidence above and
 Discharge paperwork or written/oral referral (attached), or  Written report of intake workers due diligence to obtain above evidence and certification by the individual that they exited an institution or foster care (attached)
Fleeing domestic violence For victim services providers:
 An oral statement, by the individual or head of household self- certified or certified by the intake worker, which states they are fleeing and have no subsequent resident or resources.

For non-victim services providers:
An oral statement, by the individual or head of household self which states they are fleeing and have no subsequent resident or resources. Where the safety of the individual or family is not jeopardized, the oral statement must be verified.

22 COB ESG Manual and Forms - Ver 1.1 2/20/13

2. Housing Assessment (Prevention Only) Households with a lease in their name are not eligible for the City of Berkeley PHP assistance. Please go to section II of this page.

I. If household intends to keep current housing, what is the monthly rent? _____________

If the household intends to remain in their current unit, does the rent amount exceed the FMR payment standard (based on the chart below)?
No: Proceed to next page.
Yes: Client is not eligible to be subsidized in their current unit. Ask the client if they are interested in relocating to less expensive housing and if so, proceed with assessment. Otherwise, stop here; client is not eligible. Proceed to end of form

Final FY 2013 FMRs By Unit Bedrooms
Oakland-Fremont, CA HUD Metro FMR Area
SRO Studio/Efficiency 1-bedroom 2-bedroom 3-bedroom 4-bedroom $776 $1,035 $1,255 $1,578 $2,204 $2,704
Source: http://www.huduser.org/portal/datasets/fmr.html 2/5/12 Is your name on a rental agreement?
No Yes

If you owe back rent, how much do you owe? __________ Not eligible under the City of Berkeley PHP.

How many month’s rent is that?
One Two Three Four Five Six or more Don’t Know

Is your landlord willing to accept rent from you?
No Yes Don’t Know Does Not Apply

If you are at risk of eviction, where are you in the eviction process? Have not been
served formal
notice
Served a 3-day
notice to pay rent or
quit
Served an Unlawful
Detainer summons
Eviction judgment has
been issued
Does not apply
--------------------------------------------------------------------------------------------------------------------------------------------------- II. If your name is not on a rental agreement, are you living with someone who has a rental agreement and who has
notified you in writing that you must leave?
No Yes

Do you currently receive any type of housing or utility subsidy or assistance from any other source? No Yes
Subsidy pays for: ____________________________________________________________

Note: ESG funds cannot be used to cover any cost covered by another subsidy source. For prevention candidates with a housing subsidy, ESG may only be used to pay the tenant portion of overdue back rent.

Be sure to attach housing status verification form and supporting documentation in file. Proceed to Part D: Income Verification Section

D. Income Verification

What is the combined income of this applicant household? ______________

Household size: __________

23 COB ESG Manual and Forms - Ver 1.1 2/20/13

Alameda County, California
FY2013 Income Limits
Household Size 1
Person
2 Person
3 Person
4 Person
5 Person
6 Person
7 Person
8 Person
Extremely Low Income
(30% of AMI) $18,750 $21,400 $24,100 $26,750 $28,900 $31,050 $33,200 $35,350 Source: http://www.huduser.org/portal/datasets/il/il2013/2013summary.odn 12/11/12

 At or below 30% AMI for household size

 Above 30% AMI for household size and seeking rapid rehousing assistance. The City of Berkeley authorization of recipient may be is required to proceed.

Required Authorization: ____________________________ (if applicable)

 Above 30% AMI for household size and seeking prevention assistance– INELIGIBLE: Proceed to end of form.

You may use the ESG Income Eligibility Calculation Form or another similar form to determine income. Be sure to include income verification form and supporting documentation for determination in file.

E. Resources, Networks and Asset Determination

In addition to meeting the housing status and income requirements, applicants must demonstrate that they do not have sufficient support or resources to retain or gain housing on their own.

ii. Asset Assessment

To determine whether the applicant household has resources that could be used to prevent or end their homelessness, and to determine the amount of financial assistance to be provided, the program must review their assets. This portion of the form applies to all adults in the household listed on page 1.

 No Bank accounts

Bank Accounts (attach appropriate third party documentation for all accounts listed below)

1. Name of Financial Institution: _______________________ Type of account:_____________ Name(s) on Account: __________________________________________________________ Acct #:______________ Acct. Balance:_______________________ as of ____/_____/_____

2. Name of Financial Institution: _______________________ Type of account:_____________ Name(s) on Account: __________________________________________________________ Acct #:______________ Acct. Balance:_______________________ as of ____/_____/_____

24 COB ESG Manual and Forms - Ver 1.1 2/20/13

Investment Accounts (obtain appropriate third party documentation for all accounts listed below)

1. Name of Financial Institution: _______________________ Type of account:_____________ Name(s) on Account: __________________________________________________________ Acct #:______________ Acct. Balance:_______________________ as of ____/_____/_____ Other Assets
# of Vehicles:_____  No Vehicles

Make: ______________________ Model: ________________Year:________

Make: ______________________ Model: ________________Year:________

For cars that are 2007 or newer, note blue book value: ____________________________

Property (describe and note value): ___________________________________________

Other (describe):
____________________________________________________________________________

Be sure to attached copies of bank statements or other asset verification If assets exceed $2,000 per individual or $3,000 per couple, if any vehicle is worth more than $10,000, or if household has more working cars than adult drivers, the household is ineligible.

 No  Yes: ineligible. Proceed to end of form

ii. Personal Resource and Networks

Other subsequent housing options

What steps have you taken to identify other appropriate housing options that you can afford without any assistance from this program?

Summary of assessment:

Does the household have any other appropriate housing options?  Yes  No

2) Financial Resources

Do you have any other resources that you could use to help your household gain housing or remain in your housing? (See asset assessment; discuss use of participants personal resources to resolve situation.)

Summary of assessment:

25 COB ESG Manual and Forms - Ver 1.1 2/20/13

Does the household have other financial resources sufficient to obtain other appropriate subsequent housing or remain in their existing housing?  Yes  No

3) Support Networks

Do you have any other support networks that could help you gain housing or remain in your housing? (This would include family or friends who can lend or give money, a faith-based organization that can assist you, someone with whom you can live, etc.)?

Summary of assessment:

Does the household have support networks needed to obtain other appropriate subsequent housing or remain in t
heir existing housing?  Yes
 No

F. Approach to housing stability
How did your current situation of homelessness or housing instability come about?

Describe:

Are you currently doing anything to increase your household income or decrease your costs?

No Yes Does Not Apply

Describe:

If you are to be assisted, are you willing to participate in services to increase your income or decrease your costs?
No Yes Does Not Apply

If household is not currently working toward increasing income or decreasing costs and is unwilling to do so, the household may be determined as ineligible. (Note that households with a fixed income may not need to increase income to remain stable.)

Please add any other information pertinent to eligibility determination: