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age of the family member (e.g., school records, driver's license if birth year is recorded) and to provide a self-certification.
Age must be verified only once during continuously-assisted occupancy.
FAMILY RELATIONSHIPS
Applicants and program participants are required to identify the relationship of each household member to the head of household. Definitions of the primary household relationships are provided in the Exhibit 1: Definitions of Family and Household Members.
Family relationships are verified only to the extent necessary to determine a family’s eligibility and level of assistance. Certification by the head of household normally is sufficient verification of family relationships.
Marriage
Certification by the head of household is normally sufficient verification. If the TBRA Program Case Manager has reasonable doubts about a marital relationship, the TBRA Program Case Manager will require the family to document the marriage.
A marriage certificate generally isrequired to verify that a couple is married.
In the case of a common law marriage, the couple must demonstrate that they hold themselves to be married (e.g., by telling the community they are married, calling each other husband and wife, using the same last name, filing joint income tax returns).
Separation or Divorce
Certification by the head of household is normally sufficient verification. If the TBRA Program Case Manager has reasonable doubts about a separation or divorce, the TBRA Program Case Manager will require the family to provide documentation of the divorce, or separation.
A certified copy of a divorce decree, signed by a court officer, is required to document that a couple is divorced.
A copy of a court-ordered maintenance or other court record is required to document a separation.
If no court document is available, documentation from a community-based agency will be accepted.
Absence of Adult Member
If an adult member who was formerly a member of the household is reported to be permanently absent, the family must provide evidence to support that the person is no longer a member of the family (e.g., documentation of another address at which the person resides such as a lease or utility bill).
Foster Children and Foster Adults
Third-party verification from the state or local government agency responsible for the placement of the individual with the family is required.
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VERIFICATION OF STUDENT STATUS
General Requirements
The TBRA Program requires families to provide information about the student status of all students who are 18 years of age or older. This information will be verified only if:
The family reports full-time student status for an adult otherthan the head orspouse.
The family reports child care expensesto enable a family memberto further his or her education.
The family includes a student enrolled in an institution of higher education.
DOCUMENTATION OF DISABILITY
The TBRA Program Case Manager must verify the existence of a disability in order to allow certain income disallowances and deductions from income. The TBRA Program Case Manager is not permitted to inquire about the nature or extent of a person’s disability [24 CFR 100.202(c)]. The TBRA Program Case Manager may not inquire about a person’s diagnosis or details of treatment for a disability or medical condition. If the Program Case Manager receives a verification document that provides such information, the TBRA Program Case Manager will not place this information in the tenant file. Under no circumstances will the TBRA Program Case Manager request a participant’s medical record(s). For more information on health care privacy laws, see the Department of Health and Human Services’ website at http://www.hhs.gov/ocr/privacy/.
The above cited regulation does not prohibit the following inquiries, provided these inquiries are made of all applicants, whether or not they are persons with disabilities:
Inquiry into an applicant’s ability to meet the requirements of Ownership or tenancy Inquiry to determine whether an applicant is qualified for a dwelling available only to persons with disabilities or to persons with a particular type of disability Inquiry to determine whether an applicant for a dwelling is qualified for a priority available to persons with disabilities or to persons with a particular type of disability Inquiring whether an applicant for a dwelling is a current illegal abuser or addict of a controlled substance
Inquiring whether an applicant has been convicted of the illegal manufacture or distribution of a controlled substance
FAMILY MEMBERS RECEIVING SSADISABILITY BENEFITS
Verification of the receipt of disability benefits from the Social Security Administration (SSA) is sufficient verification of disability for the purpose of qualifying for waiting list preferences (if applicable) or certain income disallowances and deductions.
If the family is unable to provide the document(s), the TBRA Program Case Manager will ask the family to request a benefit verification letter by either calling SSA at 1-800-772-1213, or by requesting it from www.ssa.gov. Once the applicant or participant receives the benefit verification letter, they will be required to provide it to the TBRA Program Case Manager.
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FAMILY MEMBERS NOT RECEIVING SSA DISABILITY BENEFITS
Receipt of veteran’s disability benefits, worker’s compensation, or other non-SSA benefits based on the individual’s claimed disability are not sufficient verification that the individual meets HUD’s definition of disability in 24 CFR 5.603.
For family members claiming disability who do not receive disability benefits from the SSA, a knowledgeable professional must provide third-party verification that the family member meets the HUD definition of disability. The knowledgeable professional will verify whether the family member does or does not meet the HUD definition.
CITIZENSHIP OR ELIGIBLE IMMIGRATION STATUS
Housing assistance is not available to persons who are not citizens, nationals, or eligible immigrants. [24 CFR 5.508]
The family must provide a certification that identifies each family member as a U.S. citizen, a U.S. national, or an eligible noncitizen and submit the documents discussed below for each family member. Once eligibility to receive assistance has been verified for an individual it need not be collected or verified again during continuously-assisted occupancy [24 CFR 5.508(g)(5)].
U.S. Citizens and Nationals
HUD requires a declaration for each family member who claims to be a U.S. citizen or national. The declaration must be signed personally by any family member 18 or older and by a guardian for minors.
The TBRA Program Case Manager may request verification of the declaration by requiring presentation of a birth certificate, United States passport or other appropriate documentation.
Family members who claim U.S. citizenship or national status will not be required to provide additional documentation unless the TBRA Program Case Manager receives information indicating that an individual’s declaration may not be accurate.
Eligible Immigrants
All family members claiming eligible immigration status must declare theirstatus in the same manner as U.S. citizens and nationals. The documentation required for eligible noncitizens varies depending upon factors such as the date the person entered the U.S., the conditions under which eligible immigration status has been granted, age, and the date on which the family began receiving HUD-funded assistance.
For family members age 62 or older who claim to be eligible immigrants, proof of age is required in the manner described in the ‘documentation of age’ section of this plan. No further verification of eligible immigration status is required.
For family members under the age of 62 who claim to be eligible immigrants, the TBRA Program Case Manager must verify immigration status with the United States Citizenship and Immigration Services (USCIS). The TBRA Program Case Manager will follow all USCIS protocols for verification of eligible immigration status.
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ACCEPTABLE CITIZENSHIP DOCUMENTATION
U.S. Birth Certificate U.S. Certificate of Naturalization U.S. Certificate of Birth abroad issued by the U.S.
State Department
American Indian Card
Certificate of Birth abroad issued Department of
the State
Current DDI or SSDI Award Letter
United States Passport Bureau of Indian Affairs or Tribal Affidavit of Birth A Foreign Passport with a United States VISA A Tribal Certificate of Indian Blood or Native American Census Record
I-97 Form with photographs U.S. Citizen Identification Card Permanent Resident Card Identification Card for Use of Resident Citizen in the United States
Verification from USCIS U.S. Department of Justice Certificate of Citizenship
Refugee Travel Document Identification Card for use of Resident Citizen Northern Mariana ID Alien Registration Receipt Card
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VERIFYING INCOME AND ASSETS
This section describes in detail the types of income that are included and excluded and how assets and income from assets are handled. Any assets and income reported by the family must be verified. This section providesthe TBRA Program policiesthat supplement the general verification procedures specified in this section.
EARNED INCOME
Tips
Unless tip income is included in a family member’s W-2 by the employer, persons who work in industries where tips are standard will be required to sign a certified estimate of tips received for the prior year and tips anticipated to be received in the coming year.
Wages
For wages other than tips, the family must provide originals of the two months of most current, consecutive pay stubs.
Business and Self-Employment Income
Business Owners and self-employed persons will be required to provide:
An audited financial statement for the previous fiscal year if an audit was conducted. If an audit was not conducted, a statement of income and expenses must be submitted and the business Owner or self-employed person must certify to its accuracy.
Allschedules completed for filing federal and local taxes in the preceding year.
If accelerated depreciation was used on the tax return or financial statement, an accountant's calculation of depreciation expense, computed using straight-line depreciation rules.
The TBRA Program Case Manager will provide a format for any person who is unable to provide such a statementto record income and expensesforthe coming year. The business Owner/self-employed person will be required to submit the information requested and to certify to its accuracy at all future reexaminations.
At any reexamination the TBRA Program Case Manager may request documents that support submitted financial statements such as manifests, appointment books, cash books, or bank statements.
If a family member has been self-employed less than three (3) months, the TBRA Program Case Manager will accept the family member's certified estimate of income and schedule an interim reexamination in three (3) months. If the family member has been self-employed for three (3) to twelve (12) months the TBRA Program Case Manager will require the family to provide documentation of income and expenses for this period and use that information to project income.
PERIODIC PAYMENTS ANDPAYMENTS IN LIEU OF EARNINGS
Social Security/SSI Benefits
To verify the SS/SSI benefits of applicants, the TBRA Program Case Manager will request a current (dated within the last 60 days) SSA benefit verification letter from each family member that receives Social Security benefits. If the family is unable to provide the document(s), the TBRA Program Case Manager will help the applicant request a benefit verification letter from SSA’s Website at www.ssa.gov or ask the family to request it by calling SSA at 1-800-772-1213. Once the applicant has received the benefit verification letter, they will be required to provide it to the TBRA Program Case Manager.
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Alimony or Child Support
The methodsthe TBRA Program Case Manager will use to verify alimony and child support payments differ depending on whether the family declares that it receives regular payments.
If the family declares that it receives regular payments, verification will be obtained in the following order of priority:
Copies ofthe receipts and/or paymentstubsforthe 60 days priorto TBRA Program Case Manager request.
Third-party verification form from the state or local child support enforcement agency Third-party verification form from the person paying the support Family’s self-certification of amount received.
Retirement Accounts
The TBRA Program Case Manager will accept written third-party documents supplied by the family as evidence of the status of retirement accounts.
Type of original document that will be accepted depends upon the family member’s retirementstatus:
Before retirement, the TBRA Program Case Manager will accept an original document from the entity holding the account with a date that shows it is the most recently scheduled statement for the account but in no case earlier than 6 months from the effective date of the examination.
Upon retirement, the TBRA Program Case Manager will accept an original document from the entity holding the account that reflects any distributions of the account balance, any lump sums taken and any regular payments.
After retirement, the TBRA Program Case Manager will accept an original document from the entity holding the account dated no earlier than 12 months before that reflects any distributions of the account balance, any lump sums taken and any regular payments.
Zero Annual Income Status
The TBRA Program Case Manager will check UIV sources and/or request information from third-party sourcesto verify that certain forms of income such as unemployment benefits, TANF, SS, SSI, and earnings are not being received by families claiming to have zero annual income.
Student Financial Assistance
Any financial assistance, in excess of amounts received for tuition, that a person attending an institution of higher education receives under the Higher Education Act of 1965, from private sources, or from an institution of higher education must be considered income unless the student is over the age of 23 with dependent children or is residing with parents who are seeking or receiving assistance [24 CFR 5.609(b)(9) and FR 4/10/06].
Forstudents overthe age of 23 with dependent children orstudentsresiding with parents who are seeking or receiving assistance, the full amount ofstudent financial assistance is excluded from annual income [24 CFR 5.609(c)(6)]. The full amount of student financial assistance is also excluded for students attending schoolsthat do not qualify asinstitutions of higher education (as defined in Exhibit 3-2). Excluded amounts are verified only if, without verification, the TBRA PROGRAM would not be able to determine whether or to what extent the income is to be excluded.
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For a student subject to having a portion of his/her student financial assistance included in annual income in accordance with 24 CFR 5.609(b)(9), the TBRA Program Case Manager will request written third-party verification of both the source and the amount. Family provided documents from the educational institution attended by the student will be requested, as well as documents generated by any other person or entity providing such assistance, as reported by the student.
In addition, the TBRA Program Case Manager will request written verification of the student’s tuition amount.
VERIFYING MANDATORY DEDUCTIONS
Dependent and Elderly/Disabled Household Deductions
The dependent and elderly/disabled family deductions require only that the TBRA Program Case Manager verify that the family members identified as dependents or elderly/disabled persons meet the statutory definitions. No further verifications are required.
Dependent Deductions
The TBRA Program Case Manager will verify that:
Any person under the age of 18 for whom the dependent deduction is claimed is not the head or spouse of the family and is not a foster child
Any person age 18 or older for whom the dependent deduction is claimed is not a foster adult or live-in aide, and is a person with a disability or a full-time student Elderly/Disabled Family Deductions
The TBRA Program Case Manager will verify that the head of household or spouse is 62 years of age or older or a person with disabilities.
Medical Expense Deductions
Medical expenses will be verified through:
Written third-party documents provided by the family,such as pharmacy printouts orreceipts.
The TBRA Program Case Manager will make a best effort to determine what expenses from the past are likely to continue to occur in the future. The TBRA Program Case Manager will also accept evidence of monthly payments or total paymentsthat will be due for medical expenses during the upcoming 12 months.
Written third-party verification forms, if the family is unable to provide acceptable documentation.
If third-party or document review is not possible, written family certification as to costs anticipated to be incurred during the upcoming 12 months In addition, the TBRA Program Case Manager must verify that:
The household is eligible for the deduction.
The coststo be deducted are qualified medical expenses.
The expenses are not paid for or reimbursed by any othersource.
Costs incurred in past years are counted only once.
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ELIGIBLE HOUSEHOLD
The medical expense deduction is permitted only for households in which the head or spouse is at least 62 years of age, or is a person with disabilities. The TBRA Program Case Manager will verify that the family meets the definition of an elderly or disabled family provided in the eligibility chapter.
Qualified Expenses
To be eligible for the medical expenses’ deduction, the costs must qualify as medical expenses. See Chapter 6 for the TBRA Program’s policy on what counts as a medical expense.
Unreimbursed Expenses
To be eligible for the medical expenses’ deduction, the costs must not be reimbursed by another source.
The family will be required to certify that the medical expenses are not paid or reimbursed to the family from any source. If expenses are verified through a third party, the third party must certify that the expenses are not paid or reimbursed from any other source.
ExpensesIncurred in Past Years
When anticipated costs are related to on-going payment of medical bills incurred in past years, the TBRA Program Case Manager will verify:
The anticipated repaymentschedules
The amounts paid in the past
Whether the amounts to be repaid have been deducted from the family’s annual income in past years
DISABILITY ASSISTANCE EXPENSES
Attendant Care
The TBRA Program Case Manager will accept written third-party documents provided by the family. If family-provided documents are not available, the TBRA Program Case Manager will provide a third-party verification form directly to the care provider requesting the needed information.
Expensesfor attendant care will be verified through:
Written third-party documents provided by the family,such asreceipts or cancelled checks.
Third-party verification form signed by the provider, if family-provided documents are not available.
If third-party verification is not possible, written family certification as to costs anticipated to be incurred for the upcoming 12 months
Auxiliary Apparatus
Expensesfor auxiliary apparatus will be verified through:
Written third-party documents provided by the family, such as billing statements for purchase of auxiliary apparatus, or other evidence of monthly payments or total payments that will be due for the apparatus during the upcoming 12 months.
Third-party verification form signed by the provider, if family-provided documents are not available.
If third-party verification is not possible, written family certification of estimated apparatus costs for the upcoming 12 months
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In addition, the TBRA Program Case Manager must verify that:
The family member for whom the expense isincurred is a person with disabilities.
The expense permits a family member, or members, to work Family Member is a Person with Disabilities
To be eligible for the disability assistance expense deduction, the costs must be incurred for attendant care or auxiliary apparatus expense associated with a person with disabilities. The TBRA Program Case Manager will verify that the expense is incurred for a person with disabilities.
Family Member(s) Permitted to Work
The TBRA Program Case Manager must verify that the expenses claimed actually enable a family member, or members, (including the person with disabilities) to work.
The TBRA Program Case Manager will request third-party verification from a rehabilitation agency or medical doctor indicating that the person with disabilities requires attendant care or an auxiliary apparatus to be employed, or that the attendant care or auxiliary apparatus enables another family member, or members, to work. This documentation may be provided by the family.
Unreimbursed Expenses
To be eligible forthe disability expenses deduction,the costs must not be reimbursed by anothersource.
The family will be required to certify that attendant care or auxiliary apparatus expenses are not paid by or reimbursed to the family from any source.
CHILD CARE EXPENSES
The amount of the deduction will be verified following the standard verification procedures discussed in this chapter. In addition, the TBRA Program Case Manager must verify that:
• The child is eligible for care (12 or younger).
• The costs claimed are not reimbursed.
• The costs enable a family member to work, actively seek work, or further their education. The costs are for an allowable type of child care. The costs are reasonable.
Eligible Child
To be eligible for the child care deduction, the costs must be incurred for the care of a child under the age of 13. The TBRA Program Case Manager will verify that the child being cared for (including foster children) is under the age of 13.
Unreimbursed Expense
To be eligible forthe child care deduction, the costs must not be reimbursed by anothersource.
The family (and the care provider) will be required to certify that the child care expenses are not paid or reimbursed to the family from any source.
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PURSUING AN ELIGIBLE ACTIVITY
The TBRA Program Case Manager must verify that the family member(s) that the family has identified as being enabled to seek work, pursue education, or be gainfully employed, are actually pursuing those activities.
Information to be Gathered
The TBRA Program Case Manager will verify information about how the schedule for the claimed activity relates to the hours of care provided, the time required for transportation, the time required for study (for students), the relationship of the family member(s) to the child, and any special needs of the child that might help determine which family member is enabled to pursue an eligible activity.
Seeking Work
Whenever possible the TBRA Program Case Manager will use documentation from a state or local agency that monitors work-related requirements (e.g., welfare or unemployment). In such cases the TBRA Program Case Manager will request family-provided verification from the agency of the member’s job seeking efforts to date and require the family to submit to the TBRA Program Case Manager any reports provided to the other agency.
In the event third-party verification is not available, the TBRA Program Case Manager will provide the family with a form on which the family member must record job search efforts. The TBRA Program Case Manager will review this information at each subsequent reexamination for which this deduction is claimed.
Furthering Education
The TBRA Program Case Manager will request third-party documentation to verify that the person permitted to further his or her education by the childcare is enrolled and provide information about the timing of classes for which the person is registered. The documentation may be provided by the family.
Gainful Employment
The TBRA Program Case Manager willseek third-party verification of the work schedule of the person who is permitted to work by the childcare. In cases in which two or more family members could be permitted to work, the work schedules for all relevant family members may be verified. The documentation may be provided by the family.
ALLOWABLE TYPE OF CHILD CARE
The TBRA Program Case Manager will verify that the type of child care selected by the family is allowable.
The TBRA Program Case Manager will verify that the fees paid to the child care provider cover only child care costs (e.g., no housekeeping services or personalservices) and are paid only for the care of an eligible child (e.g., prorate costs if some of the care is provided for ineligible family members).
The TBRA Program Case Manager will verify that the childcare provider is not an assisted family member.
Verification will be made through the head of household’s declaration of family members who are expected to reside in the unit.
Reasonableness of Expenses
Only reasonable childcare costs can be deducted.
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The actual costs the family incurs will be compared with the TBRA Program Case Manager’s established standards of reasonableness for the type of care in the locality to ensure that the costs are reasonable.
If the family presents a justification for costs that exceed typical costs in the area, the TBRA Program Case Manager will request additional documentation, as required, to support a determination that the higher cost is appropriate.
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The TBRA Program Case Manager is required to reexamine each Program Participant’s income and composition at least annually, and to adjust the Program Participant’s level of assistance accordingly.
Interim reexaminations are also needed in certain situations. This chapter discusses both annual and interim reexaminations, and the recalculation of Program Participant’s share and subsidy that occurs as a result.
ANNUAL REEXAMINATIONS
The TBRA Program Case Manager must conduct a reexamination of Program Participant’s income and composition and determine income eligibility at least annually. Income eligibility means not to exceed the low-income limits. This process includes gathering and verifying current information about family composition, income, and expenses. Based on this updated information, the Program Participant’sincome and rent must be recalculated.
If a Program Participant’s income goes above the low-income limit at reexamination, assistance must be terminated after the PHA gives reasonable notice to the tenant.
Scheduling Annual Reexaminations
The TBRA Program Case Manager will begin the annual reexamination process 90-120 days in advance of its scheduled effective date. Generally, the TBRA Program Case Manager will schedule annual reexamination effective dates to coincide with the family’s anniversary date.
Anniversary date is defined as 12 months from the effective date of the Program Participant’s last annual reexamination or, during a Program Participant’s first year in the program, from the effective date of the Program Participant’s initial examination (admission).
If the Program Participant moves to a new unit, the TBRA Program Case Manager will perform a new annual reexamination. The TBRA Program Case Manager also may schedule an annual reexamination for completion prior to the anniversary date for administrative purposes.
Notification of and Participation in the Annual Reexamination Process Program Participant are required to participate in an annual reexamination interview, which must be attended by the head of household or spouse. If participation in an in-person interview poses a hardship because of a Program Participant’s disability, the Program Participant should contact the TBRA Program Case Manager to request a reasonable accommodation.
Notification of annual reexamination interviews will be sent by first-class mail and will contain the date, time, and location of the interview. In addition, it will inform the Program Participant of the information and documentation that must be brought to the interview.
If the Program Participant’s is unable to attend a scheduled interview, the Program Participant’s should contact the TBRA Program Case Manager in advance of the interview to schedule a new appointment. If a Program Participant’s does not attend the scheduled interview, the TBRA Program Case Manager will send a second notification with a new interview date and appointment time.
If a Program Participant fails to attend two scheduled interviews without TBRA Program Case Manager approval, or if the notice isreturned by the post office with no forwarding address, a notice of termination EXHIBIT 4: REEXAMINATIONS
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will be sent to the Program Participant’s address of record, and to any alternate address provided in the Program Participant’s file.
An advocate, interpreter, or other assistant may assist the Program Participant in the interview process.
The Program Participant’s and the TBRA Program Case Manager must execute a certification attesting to the role and assistance provided by any such third party.
Conducting Annual Reexaminations
As part of the annual reexamination process, Program Participants are required to provide updated information to the TBRA Program Case Manager regarding the Program Participant’s income, expenses, and composition.
Program Participants will be asked to bring all required information (as described in the reexamination notice) to the reexamination appointment. The required information will include a TBRA Program Case Manager designated reexamination form, an Authorization for the Release of Information/Privacy Act Notice, as well as supporting documents or forms related to the Program Participant’s income, expenses, and family composition.
Any required documents or information that the Program Participant is unable to provide at the time of the interview must be provided within 10 business days of the interview. If the Program Participant is unable to obtain the information or materials within the required time frame, the family may request an extension.
If the Program Participant does not provide the required documents or information within the required time period (plus any extensions), the Program Participant will be sent a notice of termination.
Program Participants who have extenuating circumstances or are elderly will be permitted to complete their reexamination by mail. A request for an exception must be submitted in writing and will be reviewed and approved by management on a case-by-case basis.
At the annual reexamination, the TBRA Program Case Manager will ask whether the Program Participant, or any member of the Program Participant’s household, is subject to a lifetime sex offender registration requirement in any state. The TBRA Program Case Manager will use the City’s Sex Offender database to verify the information provided by the Program Participant.
If the TBRA Program Case Manager proposes to terminate assistance based on lifetime sex offender registration information, the TBRA Program Case Manager must notify the Program Participant of the proposed action and must provide the subject of the record and the Program Participant a copy of the record and an opportunity to dispute the accuracy and relevance of the information prior to termination.
The information provided by the Program Participant generally must be verified in accordance with the policies in Exhibit 3: Verification. Unless the Program Participant reports a change, or the TBRA Program Case Manager has reason to believe a change has occurred in information previously reported by the Program Participant, certain types of information that are verified at admission typically do not need to be re-verified on an annual basis. These include:
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Legal identity
Age
Socialsecurity numbers
A person’s disability status
Citizenship or immigration status
If adding a new family member to the unit causes overcrowding according to Housing Quality Standards (HQS), TBRA Program Case Manager must conduct a reexamination, and the Program Participant, with assistance from the TBRA Program Case Manager or other navigational resources, must try to find an acceptable unit as soon as possible. If an acceptable unit is available for rental by the Program Participant, the TBRA Program Case Manager must terminate the current Rental Assistance Payments Agreement in accordance with its terms.
Criminal Background Screening
The TBRA Program Case Manager is authorized to perform criminal background checks during the annual recertification/reexamination to determine if a member of a Program Participant’s household is subject to a lifetime registration requirement under any State sex offender registration program. Additionally, the TBRA Program Case Manager must ask whether the Program Participant, or any member of the Program Participant’s household, is subject to a lifetime registered sex offender registration requirement in any state. The TBRA Program Case Manager may not pass along to the Program Participant the costs of a criminal records check.
Each household member age 18 and over will be required to execute a consent form for criminal background check as part of the annual update process
The TBRA Program Case Manager will perform criminal background checks for all adult household members using the following process:
Screen household members for open felony warrants and Penal Code Section 290 status. Screening will take place immediately following application intake. No household members with open felony warrants or individuals validated on the Megan’s Law sex offender registry will be eligible for TBRA assistance.
The Contractor will utilize the following weblinks to screen clients for 290 status and open felony warrants:
https://www.meganslaw.ca.gov
http://public-access.riverside.courts.ca.gov/OpenAccess/ If the recertification screening reveals that the Program Participant has falsified information or otherwise failed to disclose criminal history on his/her full application and/or recertification forms, the TBRA Program Case Manager will pursue termination of assistance.
Effective Dates
In general, an increase in the Program Participant’s share of the rent that results from an annual reexamination will take effect on the Program Participant’s anniversary date, and the Program Participant will be notified at least 30 days in advance. If less than 30 days remain before the scheduled effective date, the increase will take effect on the first of the month following the end of the 30-day notice period.
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If a Program Participant moves to a new unit, the increase will take effect on the effective date of the new lease and Rental Assistance Payments Agreement, and no 30-day notice is required.
If the family causes a delay in processing the annual reexamination, increases in the Program Participant’s share of the rent will be applied retroactively to the scheduled effective date of the annual reexamination.
The Program Participant will be responsible for any overpaid subsidy.
In general, a decrease in the Program Participant’s share of the rent that results from an annual reexamination will take effect on the Program Participant’s anniversary date.
If a Program Participant moves to a new unit, the decrease will take effect on the effective date of the new lease and Rental Assistance Payments Agreement.
If the Program Participant causes a delay in processing the annual reexamination, decreases in the Program Participant share of the rent will be applied prospectively, from the first day of the month following completion of the reexamination processing.
Delaysin reexamination processing are considered to be caused by the Program Participant if the Program Participant fails to provide information requested by the TBRA Program Case Manager by the date specified, and this delay prevents the TBRA Program Case Manager from completing the reexamination as scheduled.
INTERIM REEXAMINATIONS
Family circumstances may change between annual reexaminations. HUD and the TBRA Program Case Manager policies dictate what kinds of information about changes in family circumstances must be reported, and under what circumstances the TBRA Program Case Manager must process interim reexaminations to reflect those changes. HUD regulations also permit the TBRA Program Case Manager to conduct interim reexaminations of income or family composition at any time. When an interim reexamination is conducted, only those factors that have changed are verified and adjusted.
In addition to specifying what information the Program Participant must report, HUD regulations permit the Program Participant to request an interim determination if other aspects of the Program Participant’s income or composition changes. The TBRA Program Case Manager must complete the interim reexamination within a reasonable time after the Program Participant’s request.
Changesin Family and Household Composition
All families must notify the TBRA Program Case Manager of any change within 10 business days of its occurrence (e.g., If the resident or any member of the family became employed, the start date of employment would start the count of 10 business days). The changes must be submitted in writing by using our ‘Change Report Form’. The copy of the form must be time and date stamped by the TBRA Program Case Manager to be considered valid. The copy of the form will be provided to the participant.
The TBRA Program Case Manager will conduct interim reexaminations to account for any changes in household composition that occur between annual reexaminations.
New Family Members Not Requiring TBRA Program Case Manager Approval The addition of minor children as a result of birth, adoption, or court-awarded custody by a current household member does not require TBRA Program Case Manager approval. However, the Program Participantisrequired to notify TBRA Program Case Manager ofthe household addition within 10 business
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days of its occurrence and to provide documentation required by TBRA Program Case Manager, such as birth certificate and Social Security card or other requirement documentation.
New Family and Household Members Requiring Approval
With the exception of minor children who join the family as a result of birth, adoption, or court awarded custody, a Program Participant must request the TBRA Program Case Manager approval to add a new family member or other household member (live-in aide or foster child). [HCV Program, 24 CFR 982.551(h)(4)] When any new family member is added, the TBRA Program Case Manager must conduct a reexamination to determine any new income or deductions associated with the additional family member, and to make appropriate adjustments in the Program Participant share of the rent and the Rental Assistance Payments Agreement payment.
The TBRA Program Case Manager will not approve the addition of a foster child or foster adult if it will cause a violation of HQS space standards.
Other than the addition of a foster child or foster adult, if the approval of a new family member or live-in aide will cause overcrowding according to HQS standards, the approval letter will explain that the Program Participant will be required to move.
If a change in family size causes a violation of Housing Quality Standards (HQS) space standards, the TBRA Program Case Manager must try to find an acceptable unit as soon as possible. If an acceptable unit is available for rental by the Program Participant, the TBRA Program Case Manager must terminate the Program Participant’s Rental Assistance Payments Agreement in accordance with its terms.
Program Participants must request the TBRA Program Case Manager approval to add a new family member, live-in aide, foster child, or foster adult. This includes any person not on the lease who is expected to stay in the unit for longer than a total of 14 days within a 12-month period, and therefore no longer qualifies as a “guest.” Requests must be made in writing and approved by TBRA Program Case Manager prior to the individual moving into the unit. The TBRA Program Case Manager must first be notified of any requests for additions to the household.
The Program Participant will not receive approval to add to the household what constitutes a separate family (two or more persons).
TBRA Program Case Manager will not approve the addition of new household members other than a significant other to the household, by birth, adoption, court-awarded custody, or marriage unless the Program Participant can demonstrate that there are medical needs or other extenuating circumstances, including reasonable accommodation, that should be considered by the TBRA Program Case Manager. A request for an exception must be submitted in writing and will be reviewed and approved by management on a case-by-case basis.
A live-in aide and their family may be approved to be added to the household composition through the reasonable accommodation process. If a live-in aide is approved, only one bedroom will be granted for a live-in aide and their family. All members of the live-in aide’s family must meet eligibility requirements. A live-in aide must be requested through the reasonable accommodation process if a disabled household.
TBRA Program Case Manager will approve the addition of a significant other or legal spouse, as long as the adult meets eligibility requirements.
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TBRA Program Case Manager will approve the addition of a biological minor when a current household member has physical custody of the minor, the adoption or court-awarded custody of a minor, or a minor who has been placed temporarily in the household and a current household member has physical custody of the minor.
Other additions to the household will be reviewed on a case-by-case basisto take into consideration adult relatives returning to the household who need care provided by a household member; relatives who have never lived in the household, but now a household member is responsible for the care of the relative; or in situations where an adult biological or adopted child of a household member needs to live in the household for safety reasons or to attend school. All adult household additions must meet eligibility requirements, regardless of age or familial status.
The TBRA Program Case Manager will not approve the addition of a new family or household member unless the individual meets the TBRA Program Case Manager’s eligibility criteria and documentation requirements.
If the TBRA Program Case Manager determines an individual meets the TBRA Program Case Manager’s eligibility criteria and documentation requirements, the TBRA Program Case Manager will provide written approval to the family.
If the TBRA Program Case Manager determines that an individual does not meet the TBRA Program’s eligibility criteria or documentation requirements, the TBRA Program Case Manager will notify the Program Participant in writing of its decision to deny approval of the new family or household member and the reasons for the denial.
The TBRA Program Case Manager will make its determination within 10 business days of receiving all information required to verify the individual’s eligibility.
Departure of a Family or Household Member
Program Participants must promptly notify the TBRA Program Case Manager if any family member no longer lives in the unit. Because family members are considered when determining the family unit (certificate) size, the TBRA Program Case Manager also needs to know when any live-in aide, foster child, or foster adult ceases to reside in the unit.
If a family member ceases to reside in the unit, the Program Participant must inform the TBRA Program Case Manager in writing within 10 business days of its occurrence and provide the new residential address of the family member who is being removed. This requirement also applies to a family member who has been considered temporarily absent at the point that the family concludes the individual is permanently absent.
If a live-in aide, foster child, or foster adult cease to reside in the unit, the Program Participant must inform the TBRA Program Case Manager within 10 business days.
Changes Affecting Income or Expenses
Interim reexaminations can be scheduled either because the TBRA Program Case Manager has reason to believe that changes in income or expenses may have occurred, or because the Program Participant reports a change. When a Program Participant reports a change, the TBRA Program Case Manager may take different actions depending on whether the family reported the change voluntarily, or because it was required to do so.
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TBRA PROGRAM CASE MANAGER-INITIATEDINTERIM REEXAMINATIONS The TBRA Program Case Manager-initiated interim reexaminations are those that are scheduled based on circumstances or criteria defined by the TBRA Program. They are not scheduled because of changes reported by the Program Participant.
The TBRA Program Case Manager will conduct interim reexaminations in each ofthe following instances:
For Program Participants receiving the Earned Income Disallowance (EID), the TBRA Program Case Manager will conduct an interim reexamination at the start and conclusion of the second 12-month exclusion period (50 percent phase-in period).
If the Program Participant hasreported zero family income, the TBRA Program Case Manager will conduct an interim reexamination every month as long as the Program Participant continues to report that they have no income. The Program Participant will provide a notarized affirmation of zero income, complete a zero-income budgeting worksheet and questionnaire. A review of the checking and saving bank statements will be conducted to observe the cost expenditures and deposits.
If at the time of the annual reexamination, it is not feasible to anticipate a level of income for the next 12 months (e.g., seasonal or cyclic income), the TBRA Program Case Manager will schedule an interim reexamination to coincide with the end of the period for which it is feasible to project income.
If at the time of the annual reexamination, tenant declarations were used on a provisional basis due to the lack of third-party verification, and third-party verification becomes available, the TBRA Program Case Manager will conduct an interim reexamination.
The TBRA Program Case Manager may conduct an interim reexamination at any time in order to correct an error in a previous reexamination, or to investigate a tenant fraud complaint.
FAMILY-INITIATED INTERIM REEXAMINATIONS
The TBRA Program Case Manager must adopt policies prescribing when and under what conditions the family must report changes in family income or expenses.
REQUIRED REPORTING
Program Participants are required to report all increases in earned and unearned income, including new employment within 10 business days of its occurrence. The changes must be submitted in writing by using the ‘Change Report Form’. The copy of the form must be time and date stamped by the TBRA Program Case Manager to be considered valid. The copy of the form will be provided to the Program Participant.
PROCESSING THE INTERIMREEXAMINATION
Method of Reporting
The Program Participant must notify the TBRA Program Case Manager of changes in writing. Generally, the family will not be required to attend an interview for an interim reexamination. However, if the TBRA Program Case Manager determines that an interview is warranted, the Program Participant may be required to attend.
Based on the type of change reported, the TBRA Program Case Manager will determine the documentation the Program Participant will be required to submit. The Program Participant must submit
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any required information or documents within 10 business days of receiving a request from the TBRA Program Case Manager. This time frame may be extended for good cause with TBRA Program Case Manager approval. The TBRA Program Case Manager will accept required documentation by mail, by fax, or in person.
Effective Dates
If the Program Participant share of the rent is to increase:
The increase generally will be effective on the first of the month following 30 days’ notice to the Program Participant.
If a Program Participant failsto report a change within the required time frames, or failsto provide all required information within the required time frames, the increase will be applied retroactively to the date it would have been effective had the information been provided on a timely basis. The Program Participant will be responsible for any overpaid subsidy and may be offered a repayment agreement in accordance with the policies in Chapter 15.
If the Program Participant share of the rent is to decrease:
The decrease will be effective on the first day of the month following the month in which the change was reported and all required documentation was submitted; however, all required documentation must be received by the 20th calendar day of the month to allow adequate time for processing.
In cases where the change cannot be verified until afterthe date the change would have become effective, the change will be made retroactively.
RECALCULATING FAMILY SHARE AND SUBSIDY AMOUNT
After gathering and verifying required information for an annual or interim reexamination, the TBRA Program Case Manager must recalculate the Program Participant’s share of the rent and the subsidy amount, and notify the family and Owner of the changes. While the basic policies that govern these calculations are provided in Exhibit 2: Income and Subsidy Determinations, this part lays out policies that affect these calculations during a reexamination.
Changesin Rent standards and Utility Allowances
In order to calculate the family share of the rent and rental assistance amount correctly, changes in rent standards, subsidy standards, or utility allowances may need to be updated and included in the TBRA Program Case Manager’s calculations.
Rent Standards
The Program Participant’s share of the rent and rental assistance calculations must use the correct rent standard for the family, taking into consideration the family unit size, the size of unit, and the area in which the unit is located.
When the TBRA Program Case Manager changes its rent standards or the family’s situation changes, new rent standards are applied at the first annual reexamination following the effective date of the rent standard change.
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If the Program Participant moves to a new unit, or a new Rental Assistance Payments Agreement is executed due to changes in the lease (even if the Program Participant remains in place) the current rent standard applicable to the Program Participant will be used when the new Rental Assistance Payments Agreement is processed.
SubsidyStandards
If there is a change in the family unit size that would apply to a family during the Rental Assistance Payments Agreement term, either due to a change in family composition, or a change in the TBRA Program’s subsidy standards, the new family unit size must be used to determine the rent standard amount for the family at the Program Participant’s first annual reexamination following the change in family unit size.
UTILITY ALLOWANCES
The Contractor will use the Housing Authority of the County of Riverside’s Utility Allowance charts to determine appropriate utility allowances. These charts may be accessed by clicking the following link:
https://harivco.org/Tenant/UtilityAllowanceChart/tabid/82/Default.aspx The Program Participant share of the rent and rental assistance calculations must reflect any changes in the Program Participant’s utility arrangement with the Owner, or in the TBRA Program’s utility allowance schedule. When there are changes in the utility arrangement with the Owner, the TBRA Program Case Manager must use the utility allowances in effect at the time the new lease and Rental Assistance Payments Agreement are executed.
At reexamination, the TBRA Program Case Managermust use the TBRA Program current utility allowance schedule.
NOTIFICATION OF NEWFAMILY SHARE AND RENTAL ASSISTANCE AMOUNT The TBRA Program Case Manager must notify the Owner and Program Participant of any changes in the amount of the rental assistance payment. The notice will include the following information:
The amount and effective date of the new Rental Assistance Payment Agreement payment The amount and effective date of the new Program Participant share of the rent The amount and effective date of the new tenant rent to Owner The family must be given an opportunity for an informal hearing regarding the TBRA Program Case Manager’s determination of their annual or adjusted income, and the use of such income to compute the rental assistance payment (see Exhibit 2: Income and Subsidy Determinations).
Discrepancies
During an annual or interim reexamination, the TBRA Program Case Manager may discover that information previously reported by the Program Participant was in error, or that the Program Participant intentionally misrepresented information. In addition, the TBRA Program Case Manager may discover errors made by the TBRA Program Case Manager. When errors resulting in the overpayment or underpayment of subsidy are discovered, corrections will be made in accordance with the policies in Exhibit 4: Reexaminations.
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Federal laws require the City of Corona to treat all applicants and participants equally, providing the same quality of services, regardless of family characteristics and background. Federal law prohibits discrimination in housing on the basis of race, color, religion, sex, national origin, age, familial status, and disability. The City of Corona and the Contractor, on behalf of the City of Corona, will comply fully with all federal,state, and local nondiscrimination laws, and with rules and regulations governing fair housing and equal opportunity in housing and employment, including:
Title VI of the Civil Rights Act of 1964
Title VIII of the Civil Rights Act of 1968 (as amended by the Community Development Act of 1974 and the Fair Housing Amendments Act of 1988) Executive Order 11063
Section 504 of the Rehabilitation Act of 1973
The Age Discrimination Act of 1975
Title II of the Americans with Disabilities Act (to the extent that it applies, otherwise Section 504 and the Fair Housing Amendments govern)
The Equal Accessto Housing in HUD Programs Regardless of Sexual Orientation or Gender Identity Final Rule, published in the Federal Register February 3, 2012, and further clarified in Notice PIH 2014-20.
Violence Against Women Reauthorization Act of 2013 (VAWA)
NONDISCRIMINATION
A reasonable accommodation is an adjustment made to a rule, policy, practice, or service that allows a person with a disability to have equal access to the TBRA Program. For example, reasonable accommodations may include making home visits or extending the certificate term in order for a participant to lease an accessible dwelling unit.
Federal regulations prohibit discrimination against certain protected classes. State and local requirements, as well as the City of Corona policies, can prohibit discrimination based on other factors.
The City of Corona shall not discriminate because ofrace, color,sex,religion, familial status, age, disability or national origin (called “protected classes”)
Familial status includes children under the age of 18 living with parents or legal custodians, pregnant women, and people securing custody of children under the age of 18.
The City of Corona will not discriminate on the basis of marital status or sexual orientation. The City of Corona will not use any of these factors to:
Deny to any family the opportunity to apply for housing, nor deny to any qualified applicant the opportunity to participate in the TBRA Program
Provide housing that is different from that provided to others Subject anyone to segregation or disparate treatment
Restrict anyone's accessto any benefit enjoyed by othersin connectionwith the housing program Treat a person differently in determining eligibility or other requirements for admission Steer an applicant or participant toward or away from a particular area based any of these factors Deny anyone access to the same level of services
EXHIBIT 5: FAIR HOUSING & NONDISCRIMINATION
REQUIREMENTS
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Deny anyone the opportunity to participate in a planning or advisory group that is an integral part of the housing program
Discriminate in the provision of residentialreal estate transactions Discriminate against someone because they are related to or associated with a member of a protected class
Publish or cause to be published an advertisement or notice indicating the availability of housing that prefers or excludes persons who are members of a protected class.
Providing Information to Program Participants and Owners The City of Corona will take steps to ensure that Program Participants and Owners are fully aware of all applicable civil rights laws. As part of the briefing process, the City of Corona will provide information to TBRA Program applicants about civil rights requirements and the opportunity to rent in a broad range of neighborhoods [24 CFR 982.301]. The Rental Assistance Payments Agreement informs Owners of the requirement not to discriminate against any person because of race, color, religion, sex, national origin, age, familial status, or disability in connection with the contract.
Discrimination Complaints
If a Program Applicant or Program Participant believes that any family member has been discriminated against by the Contractor or an Owner, the family should advise the City of Corona Community Development Department, Attn: Administrative Services Manager. HUD requires the City of Corona make every reasonable attempt to determine whether the Program Applicant’s or Program Participant’s assertions have merit and take any warranted corrective action. In addition, the City of Corona is required to provide the Program Applicant or Program Participant with information about how to file a discrimination complaint [24 CFR 982.304]. Upon receipt of a housing discrimination complaint, City of Corona is required to:
Provide written notice of the complaint to those alleged and inform the complainant that such notice was made.
Investigate the allegations and provide the complainant and those alleged with findings and either a proposed corrective action or an explanation of why corrective action is not warranted.
Keep records of all complaints, investigations, notices, and corrective action. [Notice PIH 2014- 20]
Program Applicants or Program Participants who believe that they have been subject to unlawful discrimination may notify the City of Corona either orally or in writing. Notification shall be made to the Community Development Department, Attn: Administrative Services Manager. Within 10 business days of receiving the complaint, the City of Corona will provide a written notice to those alleged to have violated the rule. The City of Corona will also send a written notice to the complainant informing them that notice was sent to those alleged to have violated the rule, as well asinformation on how to complete and submit a housing discrimination complaint form to HUD’s Office of Fair Housing and Equal Opportunity (FHEO).
The City of Corona will attempt to remedy discrimination complaints made against the City of Corona and will conduct an investigation into all allegations or discrimination.
Within 10 business days following the conclusion of the City of Corona’s investigation, the City of Corona will provide the complainant and those alleged to have violated the rule with findings and either a proposed corrective action plan or an explanation of why corrective action is not warranted.
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The City of Corona will keep a record of all complaints, investigations, notices and corrective actions.
Policies Related to Persons with Disabilities
One type of disability discrimination prohibited by the Fair Housing Act is the refusal to make reasonable accommodation in rules, policies, practices, or services when such accommodation may be necessary to afford a person with a disability the equal opportunity to use and enjoy a program or dwelling under the program.
Contractor must ensure that persons with disabilities have full access to the TBRA Program. This responsibility begins with the first contact by an interested family and continues through every aspect of the program.
The Contractor shall ask all applicants and participants if they require any type of accommodations, in writing, on the intake application, reexamination documents, and notices of adverse action by the City of Corona, by including the following language:
Any person who believes they need a reasonable accommodation to participate in any program should notify our office at least twenty-four hours prior to the date the accommodation will be required.
Definition of Reasonable Accommodation
A person with a disability may require certain types of accommodations in order to have equal access to the TBRA Program. The types of reasonable accommodationsthe Contractor can provide include changes, exceptions, or adjustmentsto a rule, policy, practice, orservice,subject to approval by the TBRA Oversight Committee.
Federal regulations stipulate that requests for accommodations will be considered reasonable if they do not create an "undue financial and administrative burden”, or result in a “fundamental alteration” in the nature of the program or service offered. A fundamental alteration is a modification that alters the essential nature of a provider’s operations.
Types of Reasonable Accommodations
When needed, the Contractor will modify normal procedures to accommodate the needs of a person with disabilities. Examples include:
Permitting applications and reexaminationsto be completed bymail Providing “large-print” forms
Conducting home visits
Providing time extensions for locating a unit when necessary, because of lack of availability of accessible units or special challenges of the family in seeking a unit Permitting an authorized designee or advocate to participate in the application or certification process and any other meetings with Contractor
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Request for an Accommodation
If a Program Applicant or Program Participant indicatesthat an exception, change, or adjustment to a rule, policy, practice, or service is needed because of a disability, HUD requires that the Contractor treat the information as a request for a reasonable accommodation, even if no formal request is made [Joint Statement of the Departments of HUD and Justice: Reasonable Accommodations under the Fair Housing Act].
The Program Applicant or Program Participant must explain what type of accommodation is needed to provide the person with the disability full access to the TBRA Program.
If the need for the accommodation is not readily apparent or known to the City of Corona, the Program Applicant or Program Participant must explain the relationship between the requested accommodation and the disability. There must be an identifiable connection, or nexus, between the requested accommodation and the individual’s disability.
The Contractor will encourage the Program Applicant or Program Participant to make itsrequest in writing using a reasonable accommodation request form. However, the Contractor will consider the accommodation any time the Program Applicant or Program Participant indicatesthat an accommodation is needed whether or not a formal written request is submitted.
Verification of Disability
The regulatory civil rights definition for persons with disabilities is provided in Exhibit 6: Definition of a Person with a Disability Under Federal Civil Rights Laws. The definition of a person with a disability for the purpose of obtaining a reasonable accommodation is much broader than the HUD definition of disability.
Before providing an accommodation, the Contractor must determine that the person meetsthe definition of a person with a disability, and that the accommodation will enhance the Program Applicant’s or Program Participant’s access to the TBRA Program.
If a Program Applicant’s or Program Participant’s disability is obvious or otherwise known to the Contractor, and if the need for the requested accommodation is also readily apparent or known, no further verification will be required [Joint Statement of the Departments of HUD and Justice: Reasonable Accommodations under the Fair Housing Act].
If a Program Applicant or Program Participant indicates that an accommodation isrequired for a disability that is not obvious or otherwise known to the Contractor, the Contractor must verify that the person meetsthe definition of a person with a disability, and that the limitationsimposed by the disability require the requested accommodation.
When verifying a disability,the following requirements apply when verifying a disability:
Third-party verification must be obtained from an individual identified by the family who is competent to make the determination. A doctor or other medical professional, a peer support group, a non-medical service agency, or a reliable third party who is in a position to know about the individual’s disability may provide verification of a disability [Joint Statement of the Departments of HUD and Justice: Reasonable Accommodations under the Fair Housing Act]
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The Contractor must request only information that is necessary to evaluate the disability-related need for the accommodation. The Contractor will not inquire about the nature or extent of any disability.
Medicalrecords will not be accepted or retained in the participant file.
In the event that the Contractor does receive confidential information about a person’s specific diagnosis, treatment, or the nature or severity of the disability, the Contractor will dispose of it. If the information needs to be disposed, the Contractor will note in the file that the disability and other requested information have been verified, the date the verification was received, and the name and address of the knowledgeable professional who sent the information [Notice PIH 2010- 26].
Approval/Denial of a Requested Accommodation
[Joint Statement of the Departments of HUD and Justice: Reasonable Accommodations under the Fair Housing Act, Notice PIH 2010-26].
The Contractor must approve a request for an accommodation ifthe following three conditions are met:
The request was made by or on behalf of a person with a disability.
There is a disability-related need for the accommodation.
The requested accommodation is reasonable, meaning it would not impose an undue financial and administrative burden on the Contractor, or fundamentally alter the nature of the TBRA Program’s operations (including the obligation to comply with HUD requirements and regulations).
Requests for accommodations must be assessed on a case-by-case basis, taking into account factors such as the cost of the overall size of the program with respect to the number of employees, type of facilities and size of budget, type of operation including composition and structure of workforce, the nature and cost of the requested accommodation, and the availability of alternative accommodations that would effectively meet the family’s disability-related needs.
Before making a determination whether to approve the request, the Contractor may enter into discussion and negotiation with the Program Applicant or Program Participant, request more information from the Program Applicant or Program Participant, or may require the Program Applicant or Program Participant to sign a consent form so that the Contractor may verify the need for the requested accommodation.
After a request for an accommodation is presented, the Contractor will respond, in writing, within 10 business days.
If the Contractor denies a request for an accommodation because it is not reasonable (it would impose an undue financial and administrative burden or fundamentally alter the nature of the Contractor’s operations), the Contractor will discuss with the Program Applicant or Program Participant whether an alternative accommodation could effectively address the family’s disability-related needs without a fundamental alteration to the TBRA Program and without imposing an undue financial and administrative burden.
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If the Contractor believes that the Program Applicant or Program Participant has failed to identify a reasonable alternative accommodation after interactive discussion and negotiation, Contractor will notify the Program Applicant or Program Participant, in writing, of its determination within 10 business days from the date of the most recent discussion or communication with the Program Applicant or Program Participant.
Program Accessibility for Persons with Hearing or Vision Impairments HUD regulations require that persons with disabilities related to hearing and vision have reasonable access to programs and services [24 CFR 8.6].
At the initial point of contact with each applicant, the Contractor shall inform all applicants of alternative forms of communication that can be used other than plain language paperwork.
To meet the needs of persons with hearing impairments, TTD/TTY (text telephone display / teletype) communication will be available.
To meet the needs of persons with vision impairments, large-print and if possible, audio versions of key program documents will be made available upon request. When visual aids are used in public meetings or presentations, or in meetings with the City of Corona staff, one-on-one assistance will be provided upon request.
Additional examples of alternative forms of communication are sign language interpretation; having material explained orally by staff; or having a third-party representative (a friend, relative or advocate, named by the applicant)to receive, interpret and explain housingmaterials and be present at allmeetings.
Physical Accessibility
The City of Corona must comply with a variety of regulations pertaining to physical accessibility, including the following:
Notice PIH 2010-26
Section 504 of the Rehabilitation Act of 1973
The Americans with Disabilities Act of 1990
The Architectural Barriers Act of 1968
The Fair Housing Act of 1988
When approving the participation in the TBRA Program of a family that includes an individual with disabilities who needs an accessible unit, Contractor will provide a current list of available accessible units known to Contractor and will assist the Program Applicant or Program Participant in locating an available accessible unit, if necessary. In general, Owners must permit the family to make reasonable modifications to the unit. However, the Owner is not required to pay for the modification and may require that the unit be restored to its original state at the family’s expense when the family moves.
Improving Accessto Servicesfor Persons with Limited English Proficiency (LEP) Language for Limited English Proficiency Persons (LEP) can be a barrier to accessing important benefits or services, understanding and exercising important rights, complying with applicable responsibilities, or understanding other information provided by the TBRA Program. In certain circumstances, failure to ensure that LEP persons can effectively participate in or benefit from federally-assisted programs and activities may violate the prohibition under Title VI against discrimination on the basis of national origin.
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This part incorporates the Final Guidance to Federal Assistance Recipients Regarding Title VI Prohibition against National Origin Discrimination Affecting Limited English Proficient Persons, published January 22, 2007 in the Federal Register.
In accord with the City of Corona Limited English Proficiency Plan four-factor analysis, the languages requiring translation include: Spanish.
The Contractor will take affirmative steps to communicate with people who need services or information in a language other than English. These persons will be referred to as Persons with Limited English Proficiency (LEP).
LEP is defined as persons who do not speak English as their primary language and who have a limited ability to read, write, speak or understand English. For the purposes of these Program Guidelines, LEP persons are TBRA applicants and participants, and parents and family members of applicants and participants.
Oral Interpretation
The Contractor will offer competent interpretation services free of charge, upon request, to the LEP person.
The Contractor will utilize a language line for telephone interpreter services. Where LEP persons desire, they will be permitted to use, at their own expense, an interpreter of their own choosing, in place of or as a supplement to the free language services offered by the Contractor. The interpreter may be a family member or friend.
The Contractor will analyze the various kinds of contacts it has with the public, to assess language needs and decide what reasonable steps should be taken. “Reasonable steps” may not be reasonable where the costs imposed substantially exceed the benefits.
Where feasible and possible, according to its language assistance plan (LAP), the PHA will train and hire bilingual staff to be available to act as interpreters and translators, will pool resources with other PHAs, and will standardize documents.
Written Translation
Translation is the replacement of a written text from one language into an equivalent written text in another language. According to the City of Corona LEP Plan, languages requiring translation include:
Spanish.
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A person with a disability, as defined under federal civil rights laws, is any person who:
Has a physical or mental impairment that substantially limits one or more of the major life activities of an individual, or
Has a record of such impairment, or
Is regarded as having such impairment
The phrase “physical or mental impairment” includes:
Any physiological disorder or condition, cosmetic or disfigurement, or anatomical loss affecting one or more of the following body systems: neurological; musculoskeletal; special sense organs; respiratory, including speech organs; cardiovascular; reproductive; digestive; genito-urinary; hemic and lymphatic; skin; and endocrine; or
Any mental or psychological disorder, such as mental retardation, organic brain syndrome, emotional or mental illness, and specific learning disabilities. The term “physical or mental impairment” includes, but is not limited to: such diseases and conditions as orthopedic, visual, speech and hearing impairments, cerebral palsy, autism, epilepsy, muscular dystrophy, multiple sclerosis, cancer, heart disease, diabetes, mental retardation, emotional illness, drug addiction and alcoholism.
“Major life activities” includes, but is not limited to, caring for oneself, performing manual tasks, walking, seeing, hearing, breathing, learning, and/or working.
“Has a record of such impairment” means has a history of, or has been misclassified as having, a mental or physical impairment that substantially limits one or more major live activities. “Is regarded as having an impairment” is defined as having a physical or mental impairment that does not substantially limit one or more major life activities but is treated by a public entity (such as The TBRA Program Case Manager) as constituting such a limitation; has none of the impairments defined in this section but is treated by a public entity as having such an impairment; or has a physical or mental impairment that substantially limits one or more major life activities, only as a result of the attitudes of others toward that impairment.
The definition of a person with disabilities does not include:
Current illegal drug users
People whose alcohol use interferes with the rights of others Persons who objectively pose a direct threat orsubstantial risk of harm to others that cannot be controlled with a reasonable accommodation under the TBRA program The above definition of disability determines whether an applicant or participant is entitled to any of the protections of federal disability civil rights laws. Thus, a person who does not meet this disability is not entitled to a reasonable accommodation under federal civil rights and fair housing laws and regulations.
EXHIBIT 6: DEFINITION OF A PERSON
WITH A DISABILITY UNDER FEDERAL CIVIL RIGHTS LAWS
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The definition of a person with a disability for purposes of granting a reasonable accommodation request is much broader than the HUD definition of disability. Many people will not qualify as a disabled person under the TBRA Program, yet an accommodation is needed to provide equal opportunity.
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PERSON WITH DISABILITIES [24 CFR 5.403]
The term person with disabilities means a person who has any of the following types of conditions:
Has a disability, as defined in 42 U.S.C. Section 423(d)(1)(A), which reads: Inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months; or In the case of an individual who has attained the age of 55 and is blind (within the meaning of “blindness” as defined in section 416(i)(1) of this title), inability by reason of such blindness to engage in substantial gainful activity, requiring skills or ability comparable to those of any gainful activity in which he has previously engaged with some regularity and over a substantial period of time.
Has a developmental disability as defined in the Developmental Disabilities Assistance and Bill of Rights Act of 2000 [42 U.S.C. 15002(8)], which defines developmental disability in functional terms as follows:
(A) In General
The term “developmental disability” means a severe, chronic disability of an individual that:
(i) is attributable to a mental or physical impairment or combination of mental and physical impairments;
(ii) is manifested before the individual attains age 22; (iii)is likely to continue indefinitely;
(iv)results in substantial functional limitations in 3 or more of the following areas of major life activity: (I) Self-care, (II) Receptive and expressive language, (III) Learning, (IV) Mobility, (V) Self-direction, (VI) Capacity for independent living, (VII) Economic selfsufficiency; and (v) reflects the individual’s need for a combination and sequence of special, interdisciplinary, or generic services, individualized supports, or other forms of assistance that are of lifelong or extended duration and are individually planned and coordinated. (B) Infants and Young Children
An individual from birth to age 9, inclusive, who has a substantial developmental delay or specific congenital or acquired condition, may be considered to have a developmental disability without meeting 3 or more of the criteria described in clauses (i) through (v) of subparagraph (A) if the individual, without services and supports, has a high probability of meeting those criteria later in life.
Has a physical, mental, or emotional impairment that is expected to be of long-continued and indefinite duration; substantially impedes his or her ability to live independently, and is of such a nature that the ability to live independently could be improved by more suitable housing conditions.
People with the acquired immunodeficiency syndrome (AIDS) or any conditions arising from the etiologic agent for AIDS are not excluded from this definition.
EXHIBIT 7: DETAILED DEFINITIONS RELATED TO DISABILITIES
TBRA Program Guidelines 87 City of Corona
A person whose disability is based solely on any drug or alcohol dependence does not qualify as a person with disabilities for the purposes of this program.
For purposes of reasonable accommodation and program accessibility for persons with disabilities, the term person with disabilities refers to an individual with handicaps.
INDIVIDUAL WITH HANDICAPS [24 CFR 8.3]
Individual with handicaps means any person who has a physical or mental impairment that substantially limits one or more major life activities; has a record of such an impairment; or is regarded as having such an impairment. The term does not include any individual who is an alcoholic or drug abuser whose current use of alcohol or drugs prevents the individual from participating in the program or activity in question, or whose participation, by reason of such current alcohol or drug abuse, would constitute a direct threat to property or the safety of others.
As used in this definition, the phrase:
(1) Physical or mental impairment includes:
(a) Any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems: neurological; musculoskeletal; special sense organs; respiratory, including speech organs; cardiovascular; reproductive; digestive; genito-urinary; hemic and lymphatic; skin; and endocrine; or
(b) Any mental or psychological disorder, such as mental retardation, organic brain syndrome, emotional or mental illness, and specific learning disabilities. The term physical or mental impairment includes, but is not limited to, such diseases and conditions as orthopedic, visual, speech and hearing impairments, cerebral palsy, autism, epilepsy, muscular dystrophy, multiple sclerosis, cancer, heart disease, diabetes, mental retardation, emotional illness, drug addiction and alcoholism.
(2) Major life activities means functions such as caring for one's self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning and working. (3) Has a record of such an impairment means has a history of, or has been misclassified as having, a mental or physical impairment that substantially limits one or more major life activities. (4) Is regarded as having an impairment means:
(a) Has a physical or mental impairment that does not substantially limit one or more major life activities but that is treated by a recipient as constituting such a limitation; (b) Has a physical or mental impairment thatsubstantially limits one ormoremajor life activities only as a result of the attitudes of others toward such impairment; or (5) Has none of the impairments defined in paragraph (1) of this section but is treated by a recipient as having such an impairment.
TBRA Program Guidelines 88 City of Corona
Owners play a majorrole in the TBRA Program by supplying decent,safe, and sanitary housing for Program Participants.
The term “Owner” refers to any person or entity with the legal right to lease or sublease a unit to a participant in the TBRA program. The term “Owner” includes a principal or other interested party, such as a designated agent of the Owner.
Owners have numerous responsibilities under the program, including screening and leasing to families, maintaining the dwelling unit, enforcing the lease, and complying with various contractual obligations.
OWNERS INTHE TBRA PROGRAM
Owner Recruitment
TBRA Program Case Manager is responsible for ensuring that low-income families have access to all types and ranges of affordable housing in the TBRA Program Case Manager’s jurisdiction. A critical element in fulfilling this responsibility is for TBRA Program Case Manager to ensure that a sufficient number of Owners, representing all types and ranges of affordable housing in the TBRA Program Case Manager’s jurisdiction, are willing to participate in the TBRA program.
To accomplish this objective, TBRA Program Case Manager’s may need to identify and recruit new Owners to participate in the program.
Owner Responsibilities
The basic Owner responsibilitiesin the TBRA program are outlined in the regulations as follows:
Compliance with all of the Owner's obligations under the Rental Assistance Payments Agreement and the lease
Performing all management and rental functions for the assisted unit, including selecting a Program Participant to lease the unit, and deciding if the Program Participant is suitable for tenancy of the unit
Maintaining the unit in accordance with the inspection criteria, including performance of ordinary and extraordinary maintenance
Complying with Equal Opportunity requirements
Preparing and furnishing to the TBRA Program Case Manager information required under the Rental Assistance Payments Agreement
Collecting the security deposit, the tenant rent, and any charges for unit damage by the Program Participant.
Enforcing tenant obligations underthe dwelling lease
Paying for utilities and services that are not the responsibility of the Program Participant as specified in the lease
Allow reasonable modificationsto a dwelling unit occupied or to be occupied by a disabled person [24 CFR 100.203]
Complying with the Violence against Women Reauthorization Act of 2013 (VAWA) when screening prospective tenants or terminating the tenancy of a family (see 24 CFR Part 5, Subpart L; 24 CFR 982.310(h)(4); and 24 CFR 982.452(b)(1)).
EXHIBIT 8: OWNERS
TBRA Program Guidelines 89 City of Corona
Owner Qualifications
The TBRA Program Case Manager does not formally approve anOwnerto participate in the TBRA program.
However, there are a number of criteria where the TBRA Program Case Manager may deny approval of an assisted tenancy based on past Owner behavior, conflict of interest, or other Owner-related issues. No Owner has a right to participate in the TBRA program.
Owners Barred from Participation
The TBRA Program Case Manager must not approve the assisted tenancy if the TBRA Program Case Manager has been informed that the Owner has been debarred, suspended, or subject to a limited denial of participation under 24 CFR part 24. HUD may direct the TBRA Program Case Manager not to approve a tenancy request if a court or administrative agency has determined that the Owner violated the Fair Housing Act or other federal equal opportunity requirements, or if such an action is pending.
Leasing to Relatives
The TBRA Program Case Manager will not approve a tenancy if theOwneristhe parent, child, grandparent, grandchild, sister, or brother of any member of the Program Participant’s family. The TBRA Program Case Manager may make an exception as a reasonable accommodation for a family member with a disability.
The Owner is required to certify that no such relationship exists. This restriction applies at the time that the Program Participant receives assistance under the TBRA Program for occupancy of a particular unit.
Current contracts on behalf of Owners and Program Participant that are related may continue, but any new leases or contracts for these Program Participants may not be approved.
Conflict of Interest
The TBRA Program Case Manager will not approve a tenancy in which any of the following classes of persons has any interest, direct or indirect, during tenure or for one year thereafter:
Any present or former member or officer of the TBRA Program Any employee of the TBRA Program, or any contractor, subcontractor or agent of the TBRA Program, who formulates policy or who influences decisions with respect to the programs Any public official, member of a governing body, or State or local legislator, who exercises functions or responsibilities with respect to the programs Any member of the Congress of the United States
HUD may waive the conflict of interest requirements, except for members of Congress, for good cause. The TBRA Program Case Manager must submit a waiver request to the appropriate HUD office for determination.
Where the TBRA Program Case Manager has requested a conflict-of-interest waiver, the TBRA Program Case Manager may not execute the Rental Assistance Payments Agreement until HUD has made a decision on the waiver request.
OWNER ACTIONS THAT MAY RESULT IN DISAPPROVAL OF A TENANCY REQUEST The TBRA Program Case Manager will refuse to approve a request for tenancy if any of the following are true:
TheOwner has violated obligations under a Rental Assistance Payments Agreement under Section 8 of the 1937 Act (42 U.S.C. 1437 (f));
The Owner has committed fraud, bribery or any other corrupt or criminal act in connection with any federal housing program;
TBRA Program Guidelines 90 City of Corona
The Owner has engaged in any drug-related criminal activity or any violent criminal activity; The Owner has a history or practice of non-compliance with the inspection criteria for units leased under the tenant-based programs, or with applicable housing standards for any other federal housing program;
The Owner has a history or practice of failing to terminate tenancy of tenants of units assisted under any other federally assisted housing program for activity engaged in by the tenant, any member of the household, a guest or another person under the control of any member of the household that:
o Threatensthe right to peaceful enjoyment of the premises by otherresidents; o Threatensthe health orsafety of other residents, of employees of the TBRA Program Case Manager, or of Owner employees or other persons engaged in management of the housing;
o Threatens the health or safety of, or the right to peaceful enjoyment of their residences, by persons residing in the immediate vicinity of the premises; or o Is drug-related criminal activity or violent criminal activity The Owner has a history or practice of renting units that fail to meet state or local housing codes; The Owner has not paid state or local real estate taxes, fines, or assessment In considering whether to disapprove Owners for any of the discretionary reasons listed above, the TBRA Program Case Manager will consider any mitigating factors. Such factors may include, but are not limited to, the seriousness of the violation in relation to program requirements, the impact on the ability of families to lease units under the program, health and safety of participating families, among others.
LEGAL OWNERSHIP OF UNIT
The TBRA Program Case Manager will only enter into a contractual relationship with the legal Owner of a qualified unit. No tenancy will be approved without acceptable documentation of legal Ownership (e.g., deed of trust, proof of taxes for most recent year).
NON-DISCRIMINATION
The Owner must not discriminate against any person because of race, color, religion, sex, national origin, age, familialstatus, or disability, in connection with any actions orresponsibilities underthe TBRA Program and the Rental Assistance Payments Agreement with the TBRA Program Case Manager.
The Owner must cooperate with the TBRA Program Case Manager and with HUD in conducting any equal opportunity compliance reviews and complaint investigations in connection with the TBRA Program and the Rental Assistance Payments Agreement with the TBRA Program Case Manager.
See Exhibit 5: Fair Housing and Nondiscrimination Requirements for a more thorough discussion of Fair Housing and Equal Opportunity requirements.
RENTAL ASSISTANCE PAYMENTS AGREEMENT
The Rental Assistance Payments Agreement represents a written agreement between the TBRA Program and the Owner of the dwelling unit occupied by a TBRA-assisted family. The agreement spells out the Owner’s responsibilities under the program, as well as the TBRA Program Case Manager’s obligations.
Under the Rental Assistance Payments Agreement, the TBRA Program Case Manager agrees to make rental assistance payments to the Owner on behalf of the Program Participant approved by the TBRA Program Case Manager to occupy the unit.
TBRA Program Guidelines 91 City of Corona
When the TBRA Program Case Manager has determined that the unit meets program requirements and the tenancy is approvable, the TBRA Program Case Manager and Owner must execute the Rental Assistance Payments Agreement.
Rental Assistance Payments Agreement
During the term of the Rental Assistance Payments Agreement, and subject to the provisions of the Rental Assistance Payments Agreement, the TBRA Program Case Manager must make monthly rental assistance payments to the Owner on behalf of the Program Participant, at the beginning of each month. The rental assistance payments will be processed on the 1st of every month except when there is a holiday or a weekend. The payment will then, in these cases, be processed the next business day. If a lease term begins after the first of the month, the rental assistance payment for the first month is prorated for a partial month.
The amount of the rental assistance payment is determined according to the policies described in Exhibit 2: Income and Subsidy Determinations and is subject to change during the term of the Rental Assistance Payments Agreement. The TBRA Program Case Manager must notify the Owner and the Program Participant in writing of any changes in the rental assistance payment.
Rental assistance payments can be made only during the lease term, and only while the Program Participant is residing in the unit.
The monthly rental assistance payment by the TBRA Program is credited toward the monthly rent to Owner under the Program Participant’s lease. The total of the rent paid by the Program Participant, and the rental assistance payment is equal to the rent to Owner as specified in the lease.
The Program Participant is not responsible for payment of the rental assistance payment, and the TBRA Program Case Manager is not responsible for payment of the family share of rent.
The Program Participant’s share of the rent cannot be more than the difference between the rent to Owner and the rental assistance payment. The Owner may not demand or accept any rent payment from the Program Participant in excess of this maximum. The Owner may not charge the Program Participant extra amounts for items customarily included in rent in the locality, or provided at no additional cost to unsubsidized tenants in the premises.
If the Owner receives any excess rental assistance from the TBRA Program Case Manager, the excess amount must be returned immediately. If the TBRA Program Case Manager determines that the Owner is not entitled to all or a portion of the rental assistance payment, the TBRA Program Case Manager may deduct the amount of overpayment from any amounts due to the Owner, including amounts due under any other contract.
Owner Certification of Compliance
Unless the Owner complies with all provisions of the Rental Assistance Payments Agreement, the Owner is not entitled to receive rental assistance payments under the Rental Assistance Payments Agreement.
By endorsing the monthly check from the TBRA Program Case Manager, the Owner certifiesto compliance with the terms of the Rental Assistance Payments Agreement contract. This includes the following:
TBRA Program Guidelines 92 City of Corona
Certification that the Owner is maintaining the unit and premises in accordance with inspection criteria;
The contract unit is leased to the Program Participant’s family and, to the best of the Owner’s knowledge, the Program Participant resides in the unit as the family’s only residence; The rent to Owner does not exceed rents charged by the Owner for comparable unassisted units on the premises;
The Owner does not receive (other than rent to Owner) any additional payments or other consideration for rent of the contract unit during the Rental Assistance Payments Agreement term.
Late Rental Assistance Payments
The TBRA Program Case Manager is responsible for making rental assistance payments promptly when due to the Owner, in accordance with the terms of the Rental Assistance Payments Agreement. After the first two calendar months of the Rental Assistance Payments Agreement term, the Rental Assistance Payments Agreement provides for late penalties if the TBRA Program Case Manager fails to make the rental assistance payment on time.
Penalties for late rental assistance payments can only be imposed if:
1) the penalties are in accordance with generally accepted localrental market practices and law governing penalties for late payment by tenants;
2) it is the Owner’s normal business practice to charge late payment penalties for both assisted and unassisted families; and
3) the Owner charges the assisted family forlate payment of the family’s share of the rent.
The TBRA Program Case Manager is not required to pay a late payment penalty if HUD determines that the payment is late for reasons beyond the TBRA Program Case Manager’s control. In addition, late payment penalties are not required if the TBRA Program Case Manager intentionally delays or denies payment as a remedy to an Owner’s breach of the Rental Assistance Payments Agreement.
Termination of Rental Assistance Payments
The TBRA Program Case Manager must continue making rental assistance payments to the Owner in accordance with the Rental Assistance Payments Agreement as long as the Program Participant continues to occupy the unit and the Rental Assistance Payments Agreement is not violated.
Rental assistance payments terminate when the Rental Assistance Payments Agreement terminates or when the tenancy is terminated in accordance with the terms of the lease.
If the Owner has initiated eviction proceedings against the Program Participant and the Program Participant continues to reside in the unit, the TBRA Program Case Manager must continue to make rental assistance payments to the Owner until the Owner has obtained a court judgment or other process allowing the Owner to evict the Program Participant.
The Owner must inform the TBRA Program Case Manager when the Owner has initiated eviction proceedings against the family and the family continues to reside in the unit.
TBRA Program Guidelines 93 City of Corona
The Owner must inform the TBRA Program Case Manager when the Owner has obtained a court judgment or other process allowing the Ownerto evict the Program Participant, and provide the TBRA Program Case Manager with a copy of such judgment or determination.
After the Owner has obtained a court judgment or other process allowing the Owner to evict the Program Participant, the TBRA Program Case Manager will continue to make rental assistance payments to the Owner until the Program Participant actually moves from the unit or until the Program Participant is physically evicted from the unit, whichever is earlier. The Owner must inform the TBRA Program Case Manager of the date when the Program Participant actually moves from the unit or the Program Participant is physically evicted from the unit.
Breach of Rental Assistance Payments Agreement
Any of the following actions by the Owner constitutes a breach of the Rental Assistance Payments Agreement:
If the Owner violates any obligations under the Rental Assistance Payments Agreement including failure to maintain the unit in accordance with inspection criteria If the Owner has violated any obligation under any other Rental Assistance Payments Agreement under
TBRA
If the Owner has committed fraud, bribery or any other corrupt or criminal act in connection with any federal housing program
For projects with mortgages insured by HUD or loans made by HUD, if the Owner has failed to comply with the regulation for the applicable program; or if the Owner has committed fraud, bribery or any other corrupt or criminal act in connection with the mortgage or loan If the Owner has engaged in drug-related criminal activity If the Owner has committed any violent criminal activity If the TBRA Program Case Manager determines that a breach of the Rental Assistance Payments Agreement has occurred, it may exercise any of its rights and remedies under the Rental Assistance Payments Agreement.
The TBRA Program Case Manager’s rights and remedies against the Owner under the Rental Assistance Payments Agreement include recovery of any Rental Assistance Payments Agreement overpayment, suspension of rental assistance payments, abatement or reduction of the rental assistance payment, termination of the payment or termination of the Rental Assistance Payments Agreement . The TBRA Program Case Manager may also obtain additional relief by judicial order or action.
The TBRA Program Case Manager must notify the Owner of its determination and provide in writing the reasons for the determination. The notice may require the Owner to take corrective action by an established deadline. The TBRA Program Case Manager must provide the Owner with written notice of any reduction in rental assistance payments or the termination of the Rental Assistance Payments Agreement.
Before the TBRA Program Case Manager invokes a remedy against an Owner, the TBRA Program Case Manager will evaluate all information and documents available to determine if the contract has been breached.
TBRA Program Guidelines 94 City of Corona
If relevant, the TBRA Program Case Manager will conduct an audit of the Owner’s records pertaining to the tenancy or unit.
If it is determined that the Owner has breached the contract, the TBRA Program Case Manager will consider all of the relevant factors including the seriousness of the breach, the effect on the Program Participant, the Owner’s record of compliance and the number and seriousness of any prior Rental Assistance Payments Agreement violations.
Rental Assistance Payments Agreement Term and Terminations The term of the Rental Assistance Payments Agreement runs concurrently with the term of the dwelling lease beginning on the first day of the initial term of the lease and terminating on the last day of the term of the lease, including any lease term extensions.
The Rental Assistance Payments Agreement and the rental assistance payments made under the Rental Assistance Payments Agreement terminate if:
The Owner orthe Program Participant terminatesthe lease The lease expires
The TBRA Program Case Manager terminatesthe Rental Assistance Payments Agreement; The TBRA Program Case Manager terminates assistance for the Program Participant The Program Participant moves from the assisted unit. In this situation, the Owner is entitled to keep the rental assistance payment for the month when the Program Participant moves out of the unit
180 calendar days have elapsed since the TBRA Program Case Manager made the last rental assistance payment to the Owner
The Program Participant is absent from the unit for longer than the maximum period permitted by the TBRA Program
The TBRA Program Case Manager electsto terminate the Rental Assistance Payments Agreement Available program funding is not sufficient to support continued assistance for Program Participants in the program
The unit does not meet HQS size requirements due to change in family composition The unit does not meet inspection criteria
The Program Participant’sfamily breaks up
The Owner breachesthe Rental Assistance Payments Agreement If the TBRA Program Case Manager terminates the Rental Assistance Payments Agreement, the TBRA Program Case Manager will give the Owner and the Program Participant written notice. The notice must specify the reasonsforthe termination and the effective date of the termination. Once a Rental Assistance Payments Agreement is terminated, no further rental assistance payments may be made under that agreement.
In all cases, the Rental Assistance Payments Agreement terminates at the end of the calendar month that follows the calendar month in which the TBRA Program Case Manager gives written notice to the Owner.
The Owner is not entitled to any rental assistance payment after this period, and must return to the TBRA Program Case Manager any rental assistance payment received after this period.
TBRA Program Guidelines 95 City of Corona
If the family moves from the assisted unit into a new unit, even if the new unit is in the same building or complex as the assisted unit, the Rental Assistance Payments Agreement for the assisted unit terminates.
A new Rental Assistance Payments Agreement would be required.
When the Program Participant moves from an assisted unit into a new unit, the term of the Rental Assistance Payments Agreement for the new unit may begin in the same month in which the Program Participant moves out of its old unit. This is not considered a duplicative subsidy.
Change in Ownership / Assignment of the Rental Assistance Payments Agreement The Rental Assistance Payments Agreement cannot be assigned to a new Owner without the prior written consent of the TBRA Program Case Manager.
An Owner under a Rental Assistance Payments Agreement must notify the TBRA Program Case Manager in writing prior to a change in the legal Ownership of the unit. The Owner must supply all information as requested by the TBRA Program Case Manager. The assignment will be approved only if the new Owner is qualified to become an Owner under the TBRA Program according to the policies in this chapter.
Prior to approval of assignment to a new Owner, the new Owner must agree to be bound by and comply with the Rental Assistance Payments Agreement. The agreement between the new Owner and the former Owner must be in writing and in a form that the TBRA Program Case Manager finds acceptable. The new Owner must provide the TBRA Program Case Manager with a copy of the executed agreement.
The TBRA Program Case Manager must receive a signed, written request from the existing Owner stating the name and address of the new Rental Assistance Payments Agreement payee and the effective date of the assignment in order to change the Rental Assistance Payments Agreement payee under an outstanding Rental Assistance Payments Agreement.
Within 10 business days of receiving the Owner’s request, the TBRA Program Case Manager will inform the current Owner in writing whether the assignment may take place.
The new Owner must provide a written certification to the TBRA Program Case Manager that includes:
A copy of the escrow statement or other document showing the transfer of title and recorded deed;
A copy of the Owner’s IRS Form W-9, Request for Taxpayer Identification Number and Certification, or the social security number of the new Owner; The effective date of the Rental Assistance Payments Agreement assignment; A written agreement to comply with the terms of the Rental Assistance Payments Agreement; and
A certification that the new Owner is not a prohibited relative.
If the new Owner does not agree to an assignment of the Rental Assistance Payments Agreement, or fails to provide the necessary documents, the TBRA Program Case Manager will terminate the Rental Assistance Payments Agreement with the old Owner. If the new Owner wants to offer the Program Participant a new lease, and the Program Participant elects to stay with continued assistance, the TBRA Program Case Manager will process the leasing in accordance with the policies in these Program Guidelines.
TBRA Program Guidelines 96 City of Corona
In accordance with 24 CFR 92.356, no employee, agent, consultant, officer, or elected official or appointed official of the City of Corona or Contractor who exercise or have exercised any functions or responsibilities with respect to activities assisted with HOME funds or who are in a position to participate in a decisionmaking process or gain inside information with regard to these activities may obtain a financial interest or financial benefit from a HOME-assisted activity, or have a financial interest in any contract,subcontract, or agreement with respect to the HOME-assisted activity, or the proceeds from such activity, either for themselves or those with whom they have business or immediate family ties, during their tenure or for one year thereafter. Immediate family ties include (whether by blood, marriage or adoption) the spouse, parent (including a stepparent), child (including a stepchild), brother, sister (including a stepbrother or stepsister), grandparent, grandchild, and in-laws of a covered person.
Upon the written request of the City of Corona, HUD may grant an exception to the Conflict of Interest provisions on a case-by-case basis when HUD determines that the exception will serve to further the purposes of the HOME Investment Partnerships Program and the effective and efficient administration of the City’s program or project. HUD will only consider an exception after the City has provided the following:
(1) A 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 (2) An opinion of the participating jurisdiction's or State recipient's attorney that the interest for which the exception is sought would not violate State or local law.
In determining whether to grant a requested exception after the City has satisfactorily met the requirements above, HUD will consider the cumulative effect of the following factors, where applicable:
(1) Whether the exception would provide a significant cost benefit or an essential degree of expertise to the program or project which would otherwise not be available; (2) Whether the person affected is a member of a group or class of low-income persons intended to be the beneficiaries of the assisted activity, and the exception will permitsuch person to receive generally the same interests or benefits as are being made available or provided to the group or class;
(3) Whether the affected person has withdrawn from his or her functions or responsibilities, or the decision-making process with respect to the specific assisted activity in question; (4) Whether the interest or benefit was present before the affected person was in a position as described in paragraph (c) of this section;
(5) Whether undue hardship will result either to the participating jurisdiction or the person affected when weighed against the public interest served by avoiding the prohibited conflict; and (6) Any other relevant considerations.
EXHIBIT 9: CONFLICT OF INTEREST
TBRA Program Guidelines 97 City of Corona
The City and Contractor must act in accordance with the following applicable laws, rules, and regulations for HUD programs:
1. U.S. Department of Housing and Urban Development HOME Investment Partnerships Program Regulations at 24 CFR Part 92.
2. 24 CFR Part 1 and 6, Public Law 90-284, Fair Housing Act, the regulations issued following Title VI of the 1964 Civil Rights Act and Section 109 of the 1975 Housing and Community Development Act that prohibits discrimination in HUD programs based on sex, race, color, national origin, and religion and administer all programs and activities in a manner to affirmatively further the policies of the Fair Housing Act.
3. 24 CFR Part 107 and 108, the regulations issued following Executive Order 11063 and Executive Order 12892 which prohibits discrimination and promotes equal opportunity in housing.
4. 24 CFR Part 24, the regulations that prohibit use of debarred or suspended contractors on federally assisted projects and Drug Free Workplace requirements; issued according to Executive Order 12459.
5. Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, regarding eligibility restrictions for certain resident aliens.
6. 24 CFR Part 58, the regulations prescribing the Environmental Review procedure under the National Environmental Policy Act of 1969.
7. 24 CFR Part 7 and 41 CFR Part 60, regulations on equal employment opportunity without regard to race sex, color, religion, age, national origin, and disability in federally assisted construction contracts.
8. 2 CFR Part 200, Uniform Administrative Requirements.
9. 24 CFR Part 87 and Byrd Anti-Lobbying Amendment (31 U.S.C. 1352), regulations for restrictions on lobbying and required certifications.
10. 36 CFR Part 800, the regulations outlining the procedures for the protection of historic and cultural properties.
11. Age Discrimination Act of 1975 (42 U.S.C. 6101), the regulations that prohibit discrimination on the basis of age.
12. Chapters 81 and 84, of the Health and Safety Code; Title VIII, subtitle D of the CranstonGonzalez National Affordable Act of 1990, and 24 CFR Part 50.
13. Clean Air Act (42 U.S.C. 7401) and the Federal Water Pollution Control Act (33 U.S.C. 1251 et seq.), regulations and provision that requires compliance with all applicable standards, orders, or regulations issued following the rule.
14. Copeland "Anti-Kickback" Act (18 U.S.C. 874 and 40 U.S.C. 276c), the regulations on contracts for construction or repair awarded by Contractors shall include a provision for compliance with the Copeland "Anti-Kickback" Act.
15. Executive Order 13170, regulations on increasing opportunities and access for Disadvantaged Businesses.
16. HUD requirements, all other required reports, circulars, and procedures when applicable.
17. National Affordable Housing Act (NAHA) PL 101-625.
18. National Flood Insurance Act of 1968, 24 CFR Part 55 under Executive Order 11988, the regulations for proposed projects and properties located in a floodplain.
EXHIBIT 10: COMPLIANCE WITH APPLICABLE LAWS, RULES &
REGULATIONS
TBRA Program Guidelines 98 City of Corona
19. 2 CFR 200, regulationsthatidentify federal cost principals.
20. 2 CFR Part 200,regulations concerning annual audits.
21. Residential Lead Based Paint Hazard Reduction Act of 1992, the regulations implemented by 24 CFR Part 35, Subpart B imposes certain requirements on disclosure of lead base paint hazards.
22. Section 3 of the U.S. Housing and Urban Development Act of 1968 providing for economic opportunities for low and very low local residents in connection with assisted projects.
23. Section 504 of the Rehabilitation Act of 1973, 24 CFR Part 40 and 41, the regulations that sets forth policies and procedures for the enforcement of standards and requirements for accessibility for disabled persons. The Architectural Barriers Act of 1968 and the American with Disabilities Act provide additional laws on accessibility and civil rights to individuals with disabilities.
24. Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, policiesthat provide for displacement, relocation assistance, and real property acquisition as defined by 42 U.S.C. 4601 (URA) (42 U.S.C. 4601), and implementing regulations issued by the Department of Transportation at 49 CFR part 24 and section 104(d) of the Housing and Community Development Act of 1974 (42 U.S.C. 5304(d)).
25. Title IV ofthe Personal Responsibility and Work Opportunity Reconciliation Act of 1996.
26. 2 CFR 92.504(a) and 2CFR 92.504(d)(3) Administrative Transparency and Accountability through risk-based monitoring for all HOME funded activities and projects, including on-site monitoring schedules and financial oversight protocols for rental properties.
27. Violence Against Women Act Protections. The program regulations set forth in 24 CFR Part 5, subpart L, apply to all HOME tenant-based rental assistance and rental housing assisted with HOME funds, as supplemented by section 24 CFR 92.359, and the requirements imposed therein.
TBRA Program Guidelines 99 City of Corona
City of Corona
Karen Roper
Homeless Solutions Manager
400 S. Vicentia Avenue
Corona, CA 92882
951-739-4949
[email protected]
Contractor
Mercy House
Patti Long, Associate Director
PO Box 1905
Santa Ana, CA 92702
714-836-7188 X 104
[email protected]
HOME Consultant
LDM Associates, Inc.
Program Monitor
Sara Farrar
909-476-6006
[email protected]
EXHIBIT 11: CONTACT INFORMATION
EXHIBIT “7”
SHELTER OPERATIONS PLAN
[SEE ATTACHED SIXTY-ONE (61) PAGES]
1 EXHIBIT E
Shelter Operations Plan
2 Table of Contents
SECTION I. PURPOSE & INTRODUCTION............................................................................................................................................. 3 SECTION II. SHELTER ADMINISTRATION............................................................................................................................................. 3 A. Program Description......................................................................................................................................................... 3 B. Admission Criteria and Procedures................................................................................................................................. 11 C. Overflow Management .................................................................................................................................................. 15 D. Exit and Re-Admission .................................................................................................................................................... 15 E. Employment and Housing Navigator Services Policy....................................................................................................... 17 F. Daytime Program Policies............................................................................................................................................... 18 G. Navigation Center Program Policies................................................................................................................................ 18 H. Continuum of Care Good Neighbor Community Policy................................................................................................... 20 I. Shelter Advisory Board ................................................................................................................................................... 23 J. Safety Policies................................................................................................................................................................. 25 K. Security Plan................................................................................................................................................................... 28 L. Health Policies................................................................................................................................................................ 32 M. Food Policies.............................................................................................................................................................. 38 N. Transportation Policies ................................................................................................................................................... 39 O. Financial Policies............................................................................................................................................................. 42 Q. Non-Discrimination Policies............................................................................................................................................. 43 R. Confidentiality Policies ................................................................................................................................................... 45 S. Grievance Policies........................................................................................................................................................... 47 SECTION III. STAFFING AND MANAGEMENT PLAN ........................................................................................................................... 48 A. Staff Policies ................................................................................................................................................................... 48 B. Policies for Staff Training ................................................................................................................................................ 49 C. Volunteer Policies........................................................................................................................................................... 52 SECTION V. ATTACHMENTS ............................................................................................................................................................ 55
3 SECTION I. PURPOSE & INTRODUCTION
The purpose of the Shelter Operations Plan (“SOP”) is to ensure that the City of Corona’s selected Operator uses a best practice model for operation of a low-barrier Emergency Shelter Program and Navigation Center.
Establishing a low-barrier Emergency Shelter Program and Navigation Center will meet critical needs of some of the most vulnerable homeless neighbors in the City of Corona, while also addressing a pressing social issue that is deeply impacting local businesses and residents within the City.
The Plan identifies emergency shelter and navigation services for homeless persons and best practices to maintain a safe and healthy environment for homeless clients and the community at large. The ultimate purpose of the program is to connect homeless persons to permanent housing opportunities and resourcesto maintain housing stability and self-sufficiency. Goals and guidelines of the Plan align with HUD’s Standards as well as the City of Corona Homeless Strategic Plan.
As part of the RFP process, Applicants may propose changes to the SOP. Depending upon the nature of the proposed changes and the results of the RFP selection process, the City may accept or reject some or all of any changes proposed by an applicant.
SECTION II. SHELTER ADMINISTRATION
A. Program Description
1. Population Served
Emergency Shelter Program and Navigation Center Services In order to meet the goal of the City of Corona Homeless Strategic Plan to “Develop a lowbarrier emergency shelter and navigation center” the proposed program will initially serve 30 single adult male clients and 5 single adult females while providing access to a wide range of programs and supportive services at an on-site Navigation Center. To ensure that the shelter will meet the needs of the community in serving chronic and vulnerable homeless people, clients will be admitted with minimal, “low-threshold” requirements so that chronic and vulnerable homelessindividuals can easily enter and remain in shelter until they can be connected to permanent housing. The shelter will also offer 5 beds of posthospital recuperative care, in partnership with Corona Regional Medical Center and Centro Medico Community Clinic and have contingency plans to shelter 5 single adult females in the event of severe weather, Corona Police Department needs and other extenuating circumstances. Both the recuperative care and single adult female shelter beds will be provided in the private rooms in the center of the shelter leaving the east and west dorms for single adult males.
4 Navigation Center
All guests of the Emergency Shelter Program will have access to supportive services provided through the Navigation Center. The Navigation Center will be comprised of public and private agencies providing multi-disciplinary services, including Centro Medico Community Clinic.
Initially, accessto Navigation Center and Clinic services will be limited to authorized shelter guests, guests of the pilot transportation/meal service program, or permanently housed clients who are authorized to come to facility for supportive services. After successful program implementation, program analysis, and with written approval from the City of Corona, the Shelter Operator may be allowed to expand Navigation Center and Clinic services.
To manage the impact on the surrounding community,should the City of Corona approve expanded access to the Emergency Shelter/Navigation Center, the following policies will apply:
City must approve any such change in writing
Services will only be accessed by authorized agency referral and appointment only; no walk-ins or walk-outs will be allowed
On-site partner agencies must be responsible for coordination ofservice appointments Depending upon the type of service, on-site partner agencies may be responsible for providing transportation options to and from the shelter for scheduled appointments Services will focus on homeless neighbors with ties to the City of Corona unless otherwise authorized by the City
2. Program Description
The Emergency Shelter/Navigation Center is designed to provide crisis stabilization shelter and multi-disciplinary services to move individuals out of homelessness and into permanent housing opportunities.
Access to safe shelter
The Emergency Shelter/Navigation Center will accommodate overnight sleeping for 30 single adult males per evening, 5 single adult females and 5 post hospital recuperative care beds.
Access to the Emergency Shelter/Navigation Center is to be provided 24 hours a day, seven days a week, 365 days a year. In order to decrease the impact to the surrounding neighborhood, accessto bed availability will be handled through a call center/bed reservation system. No walk-ins/walk-outs for the Emergency Shelter/Navigation Center or services will be permitted. The Shelter Operator will provide on-site staff to track daily bed inventory and communicate daily bed vacancies with authorized referral agencies and City staff.
5 Length of Stay
There is no set minimum and the maximum length of stay will be consistent with the Corona Municipal Code, Section 17.04.244 which states the length of stay in emergency shelter shall be limited to 180 consecutive nights.
Each client will have an Employment and Housing Navigatorsupporting their progress toward stabilization. The program is designed to provide this support until a housing option becomes available. However, at any time, a client may be exited from the shelter for safety or shelter violations as outlined in the “Exit and Readmission Policies”. Consistent with national best practices and trends, the goal for length of stay should be 90 days or less. The Operator will maintain a report to account for clients with lengths of stay exceeding 90 days.
Sleeping Areas
Beds will consist of single and/or bunk beds. Each client will be assigned a bed and bedding for the length of their stay. Additional beds, cots or mats will be available on site to accommodate overflow issues, special needs populations, and recuperative care clients.
Space will be divided to allow for separate sleeping areas for both men and women. Flexible sleeping space will also be provided for transgendered populations, those dealing with illness, in recuperative care, or for other special needs populations.
Meals
Breakfast, lunch, dinner, and snacks will be provided for all clients in the central dining area.
The Shelter Operator will include in their staffing plan, a qualified Cook and kitchen assistantsto prepare on-site meals. The kitchen and dining hall may also serve as vocational training for clients of the program and may offer community volunteer opportunities. In addition, the shelter operator will be required to collaborate with faith agencies that used to serve meals in the parks. The day service meal program will be designed to move meal serving out of City parks and into the shelter facility.
Hygiene Facilities
Hygiene facilities will be provided on-site including toilets, showers, and laundry facilities.
Clients will be encouraged to utilize these facilities as daily resourcesto them. Toiletries will be provided by the Shelter Operator to clients as needed.
6 Transportation
No walk-ins or unauthorized drop-offs will receive shelter or navigation center services.
New clients and returning clients will receive direct transportation to and from the shelter daily. Dates and times for daily pick-ups are outlined in the “Transportation Policies. It is recommended that there be a minimum of two (2) designated locationsthat provide ample geographic range for those seeking shelter services in City of Corona as well as take into consideration community impact and safety considerations. Locations will be determined in collaboration with the Corona Police Department, the City’s Community Services Department, and the City’s Homeless Solutions Manager. Operator will only pick-up and drop-off clients at City’s designated locations.
Security
The Shelter Operator will follow policies and procedures that promote safety for clients, staff, volunteers, and the community and will create an atmosphere that promotes community safety with a goal to resolve issues before they escalate. The security plan will include a multi-faceted approach involving screening for sex offenders and open felony warrants, security searches upon entrance, confiscation of harmful contraband, trained security personnel providing around-the-clock indoor and outdoor coverage, security alarms, cameras, and lighting. Other program elements that will support security efforts include no walk-ins, no walk-outs, no unauthorized drop-offs, and no loitering policies.
Storage
All clients will have access to personal storage space in the exterior lockers. Additionally, a refrigerated storage area will be available to clients with medication needs.
Employment and Housing Navigation Services
Upon entering the shelter, each client will be assigned to an Employment and Housing Navigator. The primary function of the Employment and Housing Navigator is to work sideby- side with the client to create a pathway to employment (or disability income, if applicable) and permanent housing opportunities, with the ultimate goal of ending their homelessness within a 90-day timeframe and up to a 180-day timeframe if there are challenges with the housing market. Additionally, the Employment and Housing Navigator is to provide resources and support to the client during their stay, including encouragement to access any and all services provided at the Navigation Center. The Employment and Housing Navigator will ensure that appropriate clients are entered into the County’s Coordinated Entry System (CES), as the first line of housing engagement. Additionally, all clients will be entered into the County’s Homeless Management Information System (HMIS).
7 Together, the Employment and Housing Navigator and the client will complete a Housing Plan which will guide their efforts toward securing permanent housing opportunities.
Meeting weekly, the Employment and Housing Navigator will document the client’s progress towards actions outlined in the Housing Plan.
Daytime Program Activities
As a 24-hour Emergency Shelter/Navigation Center, the Shelter Operator will encourage all clientsto stay on-site during the day and to take advantage of the on-site services provided to them during the daytime. Daytime program activities include but are not limited to, the following:
Full access to service providers through appointments made at the Navigation Center Life skills classes and workshops
Job training and workforce development
Medical, Behavioral Health and Dental/Oral Care Services provided by Centro Medico Community Clinic
Indoor and outdoorrecreational activitiesincluding exercise classes Time with pets, assistance animals and service animals
Other miscellaneous supportive services
Access to onsite computer lab and study area
3. Services Provided
The Emergency Shelter/Navigation Center should incorporate a combination of multidisciplinary supportive services aimed at crisis stabilization and creation of pathways into permanent housing. The table on the next page will provided an overview of the vision for the services to be provided at the Navigation Center.
8 Service Location Provided by Shelter Operator
or Service Partner(s)
1. Intake/Assessment/Case Management/Employment
and Housing Navigation
Emergency
Shelter/Navigation Center
Shelter Operator
2. Crisis Evaluation and Behavioral Health Services Emergency Shelter/Navigation Center
Centro Medico Community Clinic &
County Partners
3. Recreational Services Emergency
Shelter/Navigation Center
Shelter Operator
4. Domestic Violence Services Emergency
Shelter/Navigation Center
Domestic Violence Partner
5. Shelter Beds on Site Emergency
Shelter/Navigation Center
Shelter Operator
6. Medical Servicesincluding Post-Hospital Recuperative Care
Emergency
Shelter/Navigation Center
Centro Medico Community Clinic
FQHC Partner
7. Transportation Services and Assistance
Emergency
Shelter/Navigation Center Shelter Operator/ Transportation Vendor
8. Computers/Email Emergency
Shelter/Navigation Center Shelter Operator
9. Security Emergency
Shelter/Navigation Center
Shelter Operator/Private Security
Vendor
10. Meals/Food Emergency
Shelter/Navigation Center
Shelter Operator/Faith-Based and
Community Partners
11. Parking Emergency
Shelter/Navigation Center
Shelter Operator
12. Homeless Prevention/Diversion Assessment and
Referrals
Emergency
Shelter/Navigation Center
Shelter Operator
13. Drug and Alcohol Supportive Services/Treatment
(on/off site)
Emergency
Shelter/Navigation Center
Centro Medico Community Clinic and
County Partners
14. Crisis Evaluation – Referral Plan Emergency
Shelter/Navigation Center
Shelter Operator
15. Services for Veterans Emergency
Shelter/Navigation Center
and Off-Site
Shelter Operator Partnership with
County Veterans Service Office and
VA
16. Commissary/Dining Hall Emergency
Shelter/Navigation Center
Shelter Operator
17. Life Skills Classes Emergency
Shelter/Navigation Center
Shelter Operator and Service Partners
18. Housing Assistance (PSH & TBRA) Emergency
Shelter/Navigation Center
City Resources, County & Nonprofit
Partners
19. Laundry Emergency
Shelter/Navigation Center
Shelter Operator
20.Shelter Guest Storage Emergency
Shelter/Navigation Center
Shelter Operator
21. Pet, Service Animal and Assistance Animal Services
Emergency
Shelter/Navigation
Center
ShelterOperator/
Service Partners
9 4. Coordinated Entry System Integration
The Emergency Shelter/Navigation Center will serve as a designated “Entry Point” to Corona’s homeless system of services. The Shelter Operator will include in its staffing plan, designated staff to conduct Diversion screening and prevent those with other resources from entering the homeless shelter system. Additional staff will be trained to complete on-site VI-SPDAT (Vulnerability Index – Service Prioritization Decision Assistance Tool) assessments and referrals to the County’s Coordinated Entry System. Employment and Housing Navigators will also assist Emergency Shelter/Navigation Center clients to obtain the necessary IDs and vital documentation to move forward in their housing connection process.
5. Target Goals/Expected Outcomes
The target goals and expected outcomes for the Emergency Shelter/Navigation Center will adhere to guidelines and expectations set forth by the City of Corona Homeless Strategic Plan.
The Emergency Shelter/Navigation Centershould not be regarded as a singular program rather a complete system of services to reduce the number of persons who experience homelessness in Corona and an increase in permanent housing placements for chronically and situationally homeless individuals.
Indicatorsfor measuring effective system performance include the following key considerations:
Reduction in First Time Homeless
Are fewer people experiencing homelessness for the first-time? Are only persons who have no safe, appropriate housing option being admitted to shelter?
Overall Reduction in Number of Persons Who Experience Homelessness Are overall rates of homelessness declining? Is street homelessness declining? Is chronic homelessness declining?
Reduction in the Length of Time Homeless
Do people stay homelessforshorter periods of time? Are the homeless quickly connected to permanent housing? This can also measure efficiency related to turnover of beds which is essential to meet system demand for the Emergency Shelter/Navigation Center.
Successful Resolution of Housing/Homeless Crisis
Do people resolve their housing/homeless crisis successfully by maintaining/obtaining permanent housing? Are people successfully connected to community-based supports? Reduction in Recidivism (subsequent return to homelessness from permanent housing) Are repeat occurrences of homelessness avoided or declining?
10 6. Program Layout
The following components should be considered in program layout for the Harrison Emergency Shelter and Navigation Center:
Shelter Sleeping Areas
o East and West Dormsfor Single Males
o Recuperative Care Private Rooms in Center of Shelter
o Single Females in Private Rooms in Center of Shelter to address severe weather, PD need or other extenuating circumstances
Medical Wing on East Side of Building
o Medical Services
o Behavioral Health Services
o Dental/Oral Care Services
o Specimen Collection Restroom
o Clinic Check-In Area
o Staff Break Room (to be shared by Operator and Clinic staff) Dining/Commons/Overflow Area
o Dining Room
o Commons/Overflow
Security Offices/Stations
o Main Security Office or Workstations
Site Administration andOperations Offices
o Including Records/Files Room
Intake and Entry Areas
o General Intake & Concierge
o Service Desk
Success Center
o Workforce Development
o Life Skills Training
o Othersupportive services and training
Restroom and Shower Areas
o Client Restrooms/Showers
o Staff Restrooms
Laundry Facilities
o Client (Personal) Laundry
o Staff (Bedding/Linens) Laundry
Kitchen
o Walk-In Freezer
o Walk-In Refrigerator
o Commercial Refrigerators
o Icemaker
o Pantry
11 Offices
o Conference/Meeting Rooms
o Supportive Services
Other Indoor AreasInclude:
o Recreation Room:
o Computer Lab/Study
o Staff Break Room (in clinic wing of building)
In addition, the conceptualsite would also feature the following:
Outdoor Facilities/Areas
o Client Storage Lockers
o Bike Rack Area
o Dog Run
o Outdoor Commons
B. Admission Criteria and Procedures
1. Client Rules and Guidelines
A prospective client must be able to perform all aspects of their care, follow all Harrison Emergency Shelter and Navigation Center rules and maintain appropriate behavior with consideration for all other clients of the shelter. All clients must review and sign a copy of a "Shelter Rules" document prior to entry. Intake staff will assist any and all clients who may have difficulty understanding or reviewing the rules.
The Shelter Operator must structure program rules to serve Corona’s homeless neighbors who have documentable ties to the City of Corona. The Shelter Operator and authorized referral agencies will be required to verify documentable ties to the City of Corona using the following criteria:
Driver’s License or California ID showing last permanent housing address in City City Library Internet Card or Library Book Card plus one other documentable tie Bank Statements
Car Registration
HMIS record of six months of prior services in City
City Net record of six months of prior outreach interactions will confirm documentable tiesto City
Corona PD record of six months of prior callsfor service/outreach, or enforcement will confirm documentable ties to City
Children are enrolled in City schools for six months or more They or a member of the household are employed in the City They or a member of the household graduated from a City high school Other documentation that demonstrates a last permanent address in City • Previous Utility Bill
• Previous Rental Agreement
• Other bills or documents with City Address
12 Faith Based or Community Based Partner verification ofsix months of prior servicesin City County Agency verification of six months of prior services in City Only the City of Corona Police Department or authorized City staff may allow the Shelter Operator to waive the ties to the City requirement.
2. Identification Requirements
A form of official identification is required to verify identity; however, a client will not be denied access to shelter services without one so long as Corona PD can verify identity so Operator can screen for open felony warrants and sex offender status. Employment and Housing Navigators will assist clients in obtaining a California ID, providing each client with a no-cost ID voucher.
Additionally, all Emergency Shelter/Navigation Center clients will receive a shelter-specific identification card upon entering the shelter that will be used for readmission throughout the duration of their stay.
3. Screening Requirements
The Shelter Operator will be required to screen clients for open felony warrants and Penal Code Section 290 status. Screening will take place prior to arrival at the facility as part of the bed reservation system. No potential clients with open felony warrants or individuals validated on the Megan’s Law sex offender registry will be allowed to access the shelter property. The Shelter Operator will utilize the following weblinks to screen clients for 290 status and open felony warrants:
https://www.meganslaw.ca.gov
http://public-access.riverside.courts.ca.gov/OpenAccess/
4. Bed Reservation System
To minimize neighborhood impact, all clients seeking access to the Emergency Shelter/Navigation Center must be referred through the City of Corona Police Department, City of Corona staff, City Net, and the Shelter Operator (hereinafter referred to as authorized referral agencies). To facilitate the referral process, the Shelter Operator will use a designated Intake and Bed Reservation Hotline (hereinafter referred to as “hotline”). The City of Corona may also add additional authorized referral agencies and partners.
A prospective client must be screened through the authorized referral agencies who will contact the hotline and conduct an initial phone intake process. Clients will be screened for diversion and/or homeless prevention services. If they have an alternate, habitable location where they may stay, they will be diverted from occupying a shelter bed until their resources have been exhausted.
Clients meeting eligibility requirements will be assigned a bed reservation number and given instructions on transportation shuttle options and designated arrival time.
13 5. The Shelter Operator will be required to manage and update a designated systemfor capturing bed inventory, reservations, and vacancies
New clients will be screened using the phone intake system and provided a reservation number, bus and/or shuttle pick up time and location.
Beds will be assigned based on availability and eligibility results. As instructed, authorized clients should arrive at the designated bus and/or shuttle pick up location or at the shelter through their own transportation. Those who do not arrive at the designated time without communicating previous arrangements will forfeit their bed for the night.
Security staff will be assigned to the bus and/or shuttle pick up location with a list of eligible clients, which have been prescreened for sex offender or open felony warrants. The bus will transport clients directly to the Emergency Shelter/Navigation Center site.
Clients will not be allowed to loiter in the neighborhood surrounding the Emergency Shelter/Navigation Center facility or the bus and/or shuttle pick up locations at any time. There will be strict enforcement of shelter client contract rules which could result in permanent exit from the facility if not followed. Drop-off/pick-up locations are an extension of the shelter and thus any violation such as loitering constitutes a violation of the shelter rules which will be strictly enforced. Operator/Security will conduct random daily checks of 1 mile radiusto shelter and drop-off/pick-up locations to enforce shelter rules and avoid loitering and homeless congregations.
Upon arrival, clients will go through a security screening process and work with an Intake and Admissions Coordinator to be informed of rules and regulations of the Emergency Shelter/Navigation Center, complete necessary intake paperwork and obtain a shelter ID card.
6. Day Leave and Returning Clients
A morning shuttle will be available to clients who have a desire to leave the facility during the day for employment or personal appointments.
Clients who leave the program during the day may return via the transportation shuttle to ensure that their beds remain claimed.
Clients arriving later due to special circumstances such as employment or discharge from the hospital, must communicate with their Employment and Housing Navigator their anticipated arrival time. No client will be allowed into the shelter after 10:00 PM except for valid reasons requested by Corona PD, Corona City staff, approvals by Employment and Housing Navigators, and/or the shelter bed reservation staff. Failure to comply with protocols could result in client forfeiture of their bed reservation.
14 Clients who are unable to meet the evening shuttle must arrange alternate transportation to the shelter site, no later pickups will be provided. Alternate transportation must be authorized by the shelter operator.
7. Hours of Operation
The Emergency Shelter/Navigation Center will be open 24 hours per day, 7 days per week, 365 days per year. These hours of operation will be in effect seven days per week, every week regardless of holidays or weather. The following is a sample schedule. Operator will submit a final/proposed schedule to the City of Corona for approval. 5:00 AM Early Wake Up Call
5:00 AM-8:00 AM Breakfast served
6:00AM First bus/shuttle for morning drop-offs
7:00 AM Second Wake Up Call
8:00AM-8:00PM Navigation Center open
8:00 AM-10:00 PM Commons Area open
8:00 AM-6:00 PM Recreation Room/Recreation Areas open
8:00 AM- 10:00 PM Pet Kennel and Dog Park/Run open
9:00 AM Sleeping Area closed (until 6:00 PM)
10:00 AM Second (final) bus/shuttle for morning drop-offs and day-service meal pick-ups
10:00 AM – 5:00 PM Centro Medico Community Clinic Services 10:00 AM- 4:00 PM Computer/Technology Lab open (by appt only) 11:00 AM-1:00 PM Lunch served
3:00 PM-4:00 PM Snack served
4:00PM First bus/shuttle for evening pick- ups and day-service meal drop-offs 6:00 PM Sleeping Area open
6:00 PM-9:00 PM Dinner served
7:00 PM Second bus/shuttle for evening pick- ups and day-service meal drop-offs 10:00 PM Lights Out in Sleeping Areas
15 C. Overflow Management
1. Coordinated Service Delivery Plan
It is anticipated that in the early stages of operation, need and demand will outweigh the capacity of the 40 bed Round Emergency Shelter Program. Therefore, it is imperative that a Coordinated Service Delivery Plan be implemented that includes coordination of the following diversion and redirection strategies:
Homeless Diversion
The Shelter Operator will include homeless diversion screening at intake to ensure that those with alternative resources will not be accessing the homeless system. The Shelter Operator will either provide themselves or partner with an agency that can offer successful diversion assistance.
Coordination with Transitional and Bridge Housing providers The Shelter Operator will work with service providers with Transitional and/or Bridge Housing vacancies. Thisform of housing will be utilized by returning clients who have been matched with a housing opportunity and will soon move into permanent housing. This strategy will increase the Emergency Shelter/Navigation Center bed turnover rate as clients are successfully matched to alternate housing opportunities.
2. Overflow Policies
The Bed Reservation System is designed to prevent and minimize overflow and capacity issues for the shelter. A daily bed utilization count will ensure that the 40-bed capacity will be fulfilled each evening, as need for beds persist.
In the event of a community-wide natural disaster or in extreme weather situations deemed so by state, county, or city authority, the shelter will maintain a “no walk-up” policy. However, the following option could be utilized by the Operator:
o Utilize alternative locations (churches) for additional beds that may accommodate homeless without a bed reservation during inclement weather or disaster. Option has budget implications/funding considerations o Work with City to develop shelter bed expansion strategies in compliance with occupancy standards and Fire Codes
D. Exit and Re-Admission
1. Exit and Readmission Policies
Clients will be considered to have exited the program when they voluntarily leave or are exited from the shelter for safety or continual shelter violations or find alternate housing.
16 When a client exits of their own volition or is exited for shelter violations, the client may contact the admission hotline to screen for readmission eligibility after the time designated by staff (on average after 30 days).
Length of exit for safety violations will depend on the severity of the infraction.
The Shelter Operator should be balanced in their approach to program exits and readmission policies as it pertains to rules violations and infractions. Such policies should include considerations to maintain a safe and effective facility, safety for clients, volunteers, staff, and the surrounding neighborhood as well as demonstrate compassion toward homeless individuals who face increasingly vulnerable situations if forced to exit from a sheltersituation to places not suitable for human habitation.
It is recommended that Infractions be subdivided in a Multi-Tiered System based on the perceived impact of the infraction. Consequences for each tier level should be fitting and just for the level of the infraction and its perceived impact on the wellbeing of stakeholders.
As an example, a Tier 1 level may include “Basic Program Guideline Infractions” such as smoking in the bathrooms, not leaving sleeping area on time in the morning, cutting in line, etc. Tier 2 may include “Moderate Infractions” such as possessing marijuana or alcohol on site, client fighting (minor scuffles), disrespect toward volunteers, etc.
For disobedience of rules in Tier 1 or Tier 2 there will be increasing enforcement actions including verbal warnings and write-ups. After a compounded number of infractions in these tier levels, a client may be asked to leave, and staff will determine and give them the designated time line for which they can be readmitted.
Infractions at the Tier 3 level would be “Major Infractions” that include illegal drug use or possession, violent attacks/fights, possession of weapons, etc. The Shelter Operator will maintain a zero-tolerance policy towards violence, sexual misconduct, other criminal activity, and drugs and medications used or possessed beyond the scope permitted in the “Health Polices”. These behaviors, when substantiated, are punishable by immediate expulsion upon first offense and a minimum of 30 days expulsion prior to readmission.
Clients who use the facility, programs, and services in violation of a specific rule will be obliged to adhere to those consequences. The consequences may also be subject to intervention by law enforcement, and if necessary, prosecution up to the limit of the law.
17 2. Exit Procedures
When a client is asked to exit due to disobedience of rules, violence, or criminal activity, security will escort the person off the property and those exited will be transported to a selfdirected location out of the surrounding area.
E. Employment and Housing Navigator Services Policy
Upon entering the shelter, each client will be assigned to an Employment and Housing Navigator. The primary function of the Employment and Housing Navigator isto work side-byside with the client to create a pathway toward permanent housing opportunities, with the ultimate goal of ending their homelessness within a 30-day timeframe. Additionally, the Employment and Housing Navigator is to provide resources and support to the client during their stay, including encouragement to access any and all services provided at the Navigation Center.
The Employment and Housing Navigator will ensure that all clients have a complete assessment and are entered into the Coordinated Entry system, as the first line of housing engagement.
Employment and Housing Navigators will assist Emergency Shelter/Navigation Center clients obtain the necessary documentation to move forward in their housing connection process, once matched to permanent housing opportunities by the Coordinated Entry Module. Shelter Operator will also use City’s HOME funding for Tenant-Based Rental Assistance and the 5th Street Permanent Supportive Housing units to increase housing placements for homeless with documentable ties to Corona.
Together the Employment and Housing Navigator and the client will complete a Housing Plan which will guide their efforts toward securing permanent housing opportunities. Meeting weekly, the Employment and Housing Navigator will document the client's progress towards actions outlined in the Housing Plan. Additionally, Employment and Housing Navigators will work with clients to provide referrals to services in the Navigation Center or any community referrals, as necessary.
1. Documentation of Employment and Housing Navigation Services and Data Security Policies Employment and Housing Navigators will keep case notes in both hard copy paper files and in the HMIS database to track every client’s progress and participation in the Emergency Shelter/Navigation Center. These files are also used to track the resources and referrals given, support rendered, and any infractionsthe client may accrue. Outcomes are recorded at exit and throughout participation in the program. Paper files will be stored in a secure, locked location only accessible by necessary staff.
18 The Shelter Operator will use HMIS as its primary database and ensure that every client completes and signs a Riverside County HMIS Client Consent Form upon entry into the program.
Intake Specialists and Housing and Employment Navigators will ensure collection of all HUD Data standards as required by the HMIS system and well as the City of Corona Homeless Strategic Plan Performance Measures.
The Shelter Operator will have a policy restricting computer access records and client information to authorized staff. All database and HMIS access will require passwords by authorized users.
Disclosure of client information to other social service agencies may be permitted only with the client’s written consent. City Net and City of Corona Homeless Solutions staff should be listed on release of information forms to facilitate case conferencing and support of client Housing Plans.
Disclosure of records relating to clients may be released without client consent in certain circumstances as required by law.
F. Daytime Program Policies
Clients that are participating in the Emergency Shelter/Navigation Center may, but are not required to, leave the facility during the day. The Shelter Operator will make every good-faith effort to encourage all clientsto stay on-site during the day and to take advantage of the on-site services provided to them during the daytime. Access to bed areas will be limited throughout the day to encourage clientsto become active participants of the Emergency Shelter/Navigation Center.
Two morning shuttle times will be available to clients who desire to leave the facility for work or personal appointments, one at AM and one at AM.
If not utilizing the morning transportation services, clients are encouraged to stay at the facility.
Clients will have access to daytime services through the Navigation Center’s partner organizations and will be able to meet with their assigned Employment and Housing Navigator on a weekly basis or as may be needed. They will also have access to activities provided by shelter staff and volunteer organizations. Clients are welcome to use the facility’s recreational areas, lounge, computer lab, and designated outdoor spaces.
G. Navigation Center Program Policies
1. Navigation Center Clients
Access to the Navigation Center will be limited to clients and/or graduates (who stayed at shelter, remained in compliance, and graduated to othershelter/housing). However, if so agreed upon, in writing, by Shelter Operator and City of Corona, access to the Navigation Center may be broadened to include other homeless populations. Clients who are only accessing services through the partner organizations will only be permitted on facility grounds with a set
19 appointment. This includes Corona homeless clients being served by Centro Medico Community Clinic. Navigation Center clients will not be permitted to loiter on the grounds, nor will they be permitted to access shelter areas including the lounge, bed areas, dining halls or recreational areas. With the exception of the day shuttle/meal service program funded by the City of Corona, transportation to and from the Navigation Center for these clients must be provided and coordinated by the service partner organizations.
As with Emergency Shelter/Navigation Center clients, Navigation Center clients are expected to follow all Navigation Center rules and maintain appropriate behavior with consideration for all other clients of the shelter. Rules of the Navigation Center will prominently be displayed in lobby waiting areas. Those in violation of these rules will be exited from the site, suspended, or terminated from receiving services depending on the severity of the offense.
2. Lead Agency Protocols
The role of the Shelter Operator is not to provide all of the supportive services offered at the Navigation Center but to recruit and manage a group of partner agencies specialized in providing an array of supportive services beneficial to Emergency Shelter/Navigation Center clients.
The Shelter Operator will work collaboratively with the City of Corona Homeless Solutions staff to recruit public and private service providers. The Shelter Operator will maintain service provider room reservation schedule and ensure the day-to-day operational functions of the Navigation Center.
The Shelter Operator should ensure that the Navigation Center hasflexible hoursto allow clients to come before or after work, or alternatively, on the weekends. The Shelter Operator will also engage participation in and facilitate quarterly meetings of the Service Partner Advisory Board.
3. Requirementsfor Service Provider Partners
All service providers who desire to offer direct services at the Navigation Center will complete an interest application and will be required to enter into a formal Memorandum of Understanding (MOU) with the Shelter Operator to participate.
Responsibilities of the Service Provider Partners will include, but are not limited to:
Set and maintain their own appointment schedule with clients Provide non-shelter guest clients will accessto transportation to fulfill their scheduled appointments, if needed
Ensure that all clients are aware of Navigation Center rules and enact appropriate enforcement of client shelter rules for their clients if and when necessary Agree to share service output and outcome information
20 Communicate room reservation conflicts with Shelter Operator in advance Respect, maintain and keep clean all areas of the Navigation Center Respect and cooperate with Shelter Operator staff, otherservice providers and clients Participate in quarterly Service Partner Advisory Board meetings and provide input to the improvement of the Emergency Shelter/Navigation Center Screen clientsfor eligibility (no clients with sex offenses or open felony warrants willbe allowed on-site)
H. Continuum of Care Good Neighbor Community Policy
1. Communication and Coordination with Neighborhood Businesses and Public The Shelter Operator is expected to communicate with business neighbors on an ongoing basis.
As part of this commitment, prior to commencement of any services at the Emergency Shelter/Navigation Center, the Shelter Operator will work with City staff to facilitate Community Forums, as needed. These Community Forums will provide opportunities to answer any questions members of the surrounding community might have on the operation of the Emergency Shelter/Navigation Center. The Shelter Operator will provide information to the public including operational design and when services will begin.
A public inquiry phone number and contact information will also be posted. Community stakeholders may call this number for information about the shelter/navigation center or to have any questions answered. The phone number will be retained as a resource for community members while the shelter is up and operational. All community complaints and/or inquiries about the Emergency Shelter/Navigation Center will be recorded and forwarded to the appropriate staff for prompt investigation. The Shelter Operator will be fully committed to an appropriate customer service response and will consider the resolution of community complaints a high priority.
The Shelter Operator will also create and maintain a program website that will include important information for community stakeholders and clients alike. The website will include a “Frequently Asked Questions” section which will help to provide instant answers to community concerns. Additionally, the website will include a digital copy of the Shelter Operator’s “Good Neighbor Community Policy” and “Shelter Operations Plan”.
Visits by members of the community and tours of the facility will be available by scheduling an appointment with Shelter Operator Staff.
The Shelter Operator will have program brochures available on-site as well as disseminate these resourcesto groups throughout the community. Information on the brochures will highlight the various services at the facility as well as criteria for admission and eligibility. Volunteer, in-kind and donation opportunities will also be listed for those who wish to support the program.
21 The Shelter Operator will work directly with the City of Corona Homeless Solutions staff on any media inquiries and allow the City to decide who will take the lead on responses to the media.
2. Communication and Coordination with Local Police and Fire Departments The Shelter Operator will be committed to communicating and working collaboratively with the City of Corona Police and Fire Departments as may be needed. The intention of the Shelter Operator should be to act as self-sufficiently as possible and minimize the shelter’s impact on the City’s Police and Fire Departments. This includes ensuring that program staff and security staff are trained to properly manage and respond to an array of difficult situations that may occur at shelter.
The Shelter Operator will provide an array of services and support that will be beneficial to the City’s Police and Fire departments. These services include, but will not be limited, to:
Security staff stationed both on-site and at bus/shuttlelocations On-site Medical facilitiesto respond to medical needs of the clients Accepting referralsfrom Corona PD 24/7 so long as beds are available Staff Neighbor Patrol will monitorsurrounding area to control issues of loitering, abandoned property, and other blight
Training opportunities on mental illness, homeless sensitivity, or other topics of interest to supplement existing department trainings
Direct referral accessto the Coordinated Entry System to assist Corona PD to connect homeless individuals with housing opportunities
Statistical reports on number of clients served, length of stay and/ordemographic information. All such data requests will be coordinated through the City’s Homeless Solutions staff
Additionally, the Operator will meet with Corona PD Homeless Outreach & Psychological Evaluation (HOPE) Team Officers and other Corona PD representatives as may be needed.
Initially, it is suggested to meet once a month when shelter opens. Corona PD will have the ability to bring forward operator non-performance directly to the City of Corona Homeless Solutions staff in the City Manager’s Office.
22 3. Communication and Coordination with City, County, and Service Providers Operation of the Emergency Shelter/Navigation Center will be for the public good and to move Corona’s system of services forward. As such, successful implementation of the Emergency Shelter/Navigation Center will require the partnership of variousstakeholders including the City, County and other Service Providers.
The Shelter Operator will be committed to working cooperatively with numerous other service providers, community, and government organizations to serve the needs of the homeless population in the City of Corona.
In order to effectively manage and operate a robust Navigation Center that provides an array of services for the shelter clients, the Shelter Operator must demonstrate a strong history of collaboration and willingness to engage other service providers.
Additionally, the Shelter Provider will be responsive to and provide support to City of Corona in relation to the outcomes and operation of the program.
4. Policiesfor Community Involvement
The Shelter Operator will be committed to active participation in City community events. To the extent reasonable and feasible, representatives of the Shelter Operator will attend meetings of the City of Corona Homeless Strategic Plan Working Group, Continuum of Care meetings, Chamber of Commerce meetings, and other community meetings, as requested.
Additionally, the Shelter Operator may sponsor special events,such as community resource fairs, which will include the community and the neighborhood on various occasions.
5. Policiesfor Neighborhood Patrol
A staff led Neighborhood Patrol will assemble weekly to monitor a 1-mile radius around the shelter perimeter. The role of this patrol group is to identify and address issues, to engage with neighbors and enhance safety and cleanliness of the immediate vicinity.
Additionally, they will prevent and control issues of loitering, unauthorized parking of client vehicles in the neighborhood, abandoned property, shopping carts and other blight. A log will be kept of the weekly patrols. The following actions will be completed by the Neighborhood Patrol:
23 All litter and trash items will be removed from the area and properly disposed of Clientsfound loitering will be issued a warning. Violations of this rule may cause a client to be exited from the facility
Unauthorized parking of client vehiclesin the neighborhood are subject to towing Shelter Operator will contact City designated shopping cart retrieval program to collect all shopping carts found that do not contain items of personal property Shelter Operator will follow City codesfor removing personal property foundin surrounding area
Shelter Operator will work with Corona PD and City Net to receive referrals from outreach and engagement activitiesto homelessin surrounding community such as parks, riverbed, etc.
I. Shelter Advisory Board
A Shelter Advisory Board will be established and maintained to provide review of the operations of the Emergency Shelter/Navigation Center, enhance community relations, and bring information of any strengths and concerns from the neighborhood, local businesses, City and County entities, service provider partners and shelter clients about the operation of the Emergency Shelter/Navigation Center.
1. Composition of Board
The Shelter Advisory Board will be comprised of three distinct Boardsrepresenting different stakeholders and interests. The composition of these three boards will include:
Community Advisory Board
Business Representatives
Resident Representatives
Faith-Based Organization Representatives
Nonprofit Representatives
County Representatives
City of Corona Homeless Solutions
Corona PD
24 Client Advisory Board (no membership limits)
Open invitation to current shelter clients and graduates Service Partner Advisory Board (no membership limits)
Open invitation to all Navigation Center partners
Centro Medico Community Clinic
Corona Regional Medical Center
2. Meeting Schedule
All three Shelter Advisory Boards will meet quarterly (at minimum).
Ad Hoc meetings will be convened as necessary and provide a way for any member to agendize issue and provide a mechanism to call a special meeting.
3. Accountability and Grievance Process and Policies
In addition to providing input to the operation of the Emergency Shelter/Navigation Center, the Shelter Advisory Boards are also tasked with the on-going review of the Shelter Providers ability to effectively administer its Operational Plan and Good Neighbor Policies. In the event that a Shelter Advisory Board finds concerns over the Shelter Operator’s implementation of the program, the following processes and policies will be enacted to allow the Shelter Operator to make corrective actions toward such grievances:
1) Once a grievance has been filed, Shelter Operator and Advisory Board will create, at the meeting in which the grievance is filed, an action-plan to resolve the issues by the next regularly scheduled Advisory Board meeting
2) At the next meeting, the action plan’s outcomes will be reviewed to determine if the issue has been resolved
3) If the issue has not been resolved, but the Shelter Operator has provided evidence of a good faith effort to follow the course of actions outlined on the plan, they will begiven an additional 90-days to enact an alternative plan
4) If the issue has not been resolved and the Shelter Operator has not demonstrated or provided evidence of following the course of actions outlined in the plan, a formal complaint will be sent to the City of Corona Homeless Solutions for investigation and possible termination of the Shelter Operator Contract. The City of Corona shall have a plan for operation of the shelter if the shelter operator is terminated by the City of Corona, including failure to enforce plan components such as Good Neighbor Policy, bed reservation requirements, no walki-in/no walk-out policy, etc. The plan may include selecting the next eligible operator from the original operator RFP and/or entering into a sole source with a new operator, based on approval of City Council. 5) Additionally, Corona PD will have the ability to bring forward operator nonperformance directly to the City of Corona Homeless Solutions Office.
25 J. Safety Policies
1. Facility Maintenance
The Shelter Operator will maintain a schedule for regular facility maintenance and cleaning.
The Shelter Operator will contract with a janitorialservice or have staff provide daily cleaning services for all areas utilized by clients and weekly for office space and the Navigation Center.
Shelter Staff will rotate regular maintenance duties and inspections for minor repairs and replacements. Maintenance and cleaning forms are used to track completion of each task and reviewed monthly. The Shelter Operator will be responsible for staff training and performance in these duties.
The outside grounds will be incorporated into the maintenance schedule and rotation including cleaning of parking lot, landscape maintenance, maintenance and cleaning of sidewalks and patio areas, and checking of outside lights and furnishings. Graffiti will be reported to Program Manager for removal within 24 hours.
Need for repairs will be reported promptly by staff to the Program Manager. Minor repairs may be completed by staff as trained. Major repairs are reported to the Program Manager of the Shelter. Difficult repairs will be sent out to an approved list of vendors for bids, approval, and completion. Shelter Operator will comply with the terms and conditions of the lease agreement which will set forth responsibilities of the City and Shelter Operator.
The Shelter Operator will be committed to maintaining a pest free environment throughout the premises. As such, no food will be allowed in living areas of facility. Trash bags will be emptied daily in all areas. Inspection of client spaces and lockers will be conducted for any items that would attract pests. All staff will receive appropriate training for the identification of common pests as well as prevention and control measures. A Pest Control company will be contracted by the Shelter Operator and will come regularly to spray for bugs, check for infestation of pests, and perform other pest prevention or extermination treatments that will be seen on their visits or reported by staff.
2. Fire and Earthquake Safety
Evacuation Plan Clients
Shelter staff will be trained in protecting the safety of everyone in the facility. Staff will respond quickly and safely when an emergency, incident, or natural disaster occurs. Evacuation Routes and Exits will be posted in each major area of facility. An evacuation point outside will be designated.
26 In case of the need for evacuation, the present site lead during the emergency will notify all staff and clients to evacuate, call 911, and direct evacuation plan. Staff will be assigned to oversee the evacuation of clients in each work area. Staff will check client areas, assigns assistance to nonambulatory and disabled persons, and leads clients to safety through the nearest safe evacuation exit. Staff will assemble clients outside at designated evacuation point, read bed list for attendance and search for any missing clients as safety conditions allow.
In case of fire these additional protocols will be completed:
The Program Manager or lead staff member will pull the nearest fire alarm if it is not already sounding.
While evacuating clients,staff will attempt to close all door(s), if safe to do so.
Before exiting a room, the Program Manager or lead staff member will touch back of hand to the door to determine if the door is cool, then open it a crack, smell forsmoke, and if deemed safe, open the door, and leave the building to the evacuation meeting point.
If the door is hot, it is not opened, and staff will lead clientsto leave via the nearest safe exit.
Staff will locate and use appropriate fire extinguishers if safe to do so.
When the Fire Department arrives, a staff person will speak to the officer in chargeand give the officer a set of staff keys.
Staff will contact the Program Manager or his/her delegate as soon as possible, if noton site.
Staff will report incident and procedure in Critical Incident Report and staffshift notesas directed in shelter policy. All Critical Incidents must be immediately reported to City’s Homeless Solutions staff.
If the weather is inclement and if the evacuation will not be short, staff will:
Contact the Program Manager and City Homeless Solutionsto identify evacuation locations and disaster team if assistance is needed for client shelter, meals, or services.
Contact other Homeless Providersfor services as needed.
For a false alarm or other short-term evacuation,staff will direct occupants back into the building once the Fire Department has authorized an “all-clear.”
27 3. Fire Prevention Procedures
The Emergency Shelter/Navigation Center will be approved by the Fire Department for all fire codes, sprinklers, alarms, and exits prior to service implementation. Emergency lighting will be installed both inside the facility and outside on the grounds for safety and in compliance with all codes.
No smoking will be allowed inside or outside the building within 20 feet of doors. A smoking section will be designated, and a sign posted in the enclosed patio area.
4. Fire Drills and Documentation
Fire drills will be conducted at least quarterly. Documentation of fire drills will be kept for three years in Shelter Management Files.
5. Fire Inspections and Extinguishers
The most recent annual fire inspection will be posted in a designated area of the Emergency Shelter/Navigation Center facility and will be included in the Shelter Management files. Fire extinguishers will be hung in each area of the building as shown in facility plans and in evacuation plan. Fire extinguishers will be inspected and maintained per City of Corona Fire Department requirements. A certificate of the last most recent fire inspection will be posted in a visible designated area.
6. Earthquake Safety
Earthquake drills will be conducted quarterly by staff. The evacuation route and procedures may be the same as for other hazards. A client tally and search will be conducted once evacuation is conducted.
In case of an actual earthquake that causes damage to facility or grounds, the City of Corona Building Department will be called to inspect the facility as soon as safety permits. Clients will be evacuated from building and transported to other shelter as needed.
28 K. Security Plan
The Shelter Operator will follow policies and procedures that promote utmost safety for clients, staff, volunteers, and the community and will strive to provide an atmosphere that promotes community, stays alert for signs of conflict, and confronts behaviors before they escalate.
1. Eligibility Screening
No person validated on the sex offender registry (Megan’s Law) will be allowed to access the shelter property. Additionally, no felons with open warrants will be allowed to access the shelter property. Clients may only be referred by Corona PD, City Net or City Homeless Solutions staff.
Clients must have documentable ties to the City of Corona unless a waiver is approved by the Corona Police Department or Homeless Solutions staff.
Operator will use the following screening methods:
a. Screening for Sex Offenders: https://www.meganslaw.ca.gov b. Screening for Open Felony Warrants: http://public-access.riverside.courts.ca.gov/OpenAccess/ c. Methodsto Verify Ties to the City:
Driver’s License or California ID showing last permanent housing address in City City Library Internet Card or Library Book Card plus one other documentable tie Bank Statements
Car Registration
HMIS record of six months of prior services in City
City Net record of six months of prior outreach interactions will confirm documentable tiesto City
Corona PD record of six months of prior callsfor service/outreach, or enforcement will confirm documentable ties to City
Children are enrolled in City schools for six months or more They or a member of the household are employed in the City They or a member of the household graduated from a City high school Other documentation that demonstrates a last permanent address in City • Previous Utility Bill
• Previous Rental Agreement
• Other bills or documents with City Address
Faith Based or Community Based Partner verification ofsix months of prior servicesin City
County Agency verification of six months of prior services in City
29 2. Secured Entrances
All clients will be required to enter the shelter in a coordinated, peaceful fashion. Families will have a separate entrance for entering the shelter as well as separate sleeping areas.
All clients will present identification upon entry. Clients without valid California identification cards will be given supportive services to secure a valid identification card. Clients will also receive a shelter-specific ID to use for admission into the shelter during the duration of their stay.
All clients and their belongings will be checked by security personnel, utilizing security wands each time they enter and exit from the shelter and all contraband will be seized. Contraband items include but are not limited to: weapons, explosives, flammable or volatile substances, illegal drugs, controlled substances or drug paraphernalia, bio-hazardous items or environmentally harmful goods.
Clients will sign in upon entrance and sign out upon exit from the building.
3. On-site Security Personnel
The Shelter Operator will provide a sufficient number of trained security personnel to ensure the safety of clients and the surrounding neighborhood, 24 hours a day.
Security personnel will be on site at all times and will conduct security rounds of the facility, as necessary.
Security personnel will be stationed both inside and outside the shelter to ensure maximum coverage.
Security personnel will be accessible and visible to clients, and survey facility for any potential concerns. Staff and security will have communication with each other via portable electronic equipment.
Security personnel will carry non- lethal weaponssuch as mace, batons, and handcuffs. Security personnel will receive "Homeless Sensitivity Training" through the Shelter Operator’s resources.
30 4. Security Alarms and Cameras
The building will be equipped with security cameras inside and outside, and safety alarms. A staff member will monitor security through cameras at administrative office areas.
5. Security Lighting
Security lighting will be used both inside and outside the facility to highlight entrances and parking lot. A staff person will escort any personsto parking lot or security gate after sunset.
6. Loitering Policy
Clients will not be allowed to loiter in the surrounding neighborhood. Violations of this rule may cause a client to be exited from the facility. The Shelter Operator’s Good Neighbor Community Policy will include regular checks of surrounding area to prevent and control loitering issues.
7. Deescalating Conflicts
All employees will receive training in communication techniquesthat de-escalate confrontations.
8. Entrance and Exit Procedures
All staff and clients will enter and exit through one main entrance and security check point. All areas of the building will be locked when not in use. The building will be zoned so that clients will only have access to the areas which they need. During sleeping hours clients will have restricted access to other areas of the building.
All clients will present identification upon entry and their person and belongings will be searched by security. They will sign in upon entrance and sign out upon exit from the building.
All clients will enter the property by bus/shuttle. Clients will be escorted from the designated parking lot area and bus/shuttle drop off area to the shelter entrance. Navigation Center clients will follow the same entrance procedures.
Clients with vehicles must go through the referral and screening process before they are authorized to drive to the facility and park in the shelter parking lot or on Harrison Street.
31 9. Policy regarding storage of client’s possessions
All shelter residents will have access to limited personal storage space. Each client bed will be assigned a large storage locker for personal valuables.
A client storage log will be signed at each visit to the storage locker area. The storage area may be accessed, with staff supervision and only during assigned hours during the day.
All items will be stored for the length of the client’s stay at the shelter. The right to store items may be revoked based on violation of rules and/or the management’s discretion. Once a client has exited the shelter program, any personal effects may be stored for up to 7 days; after which, the property will be donated or disposed of. Clients who have exited from the shelter program must contact staff to set an appointment to collect their personal belongings.
In the event the client cannot come to retrieve their own property, they may name a proxy of their choosing to pick up their effects by filling out an Authorization for Release of Personal Property form. The client will be responsible for asking their designated contact person to retrieve property, if needed.
No contraband items may be stored at the shelter. Contraband items include but are not limited to: weapons, explosives, flammable or volatile substances, illegal drugs, controlled substances or drug paraphernalia, bio-hazardous items or environmentally harmful goods.
10. Policy pertaining to authorized/unauthorized search of clients’ property by staff The Shelter staff will have the right to inspect all storage areasto ensure compliance with contraband policies. Staff hasthe right to designate a period of time when a client will be ineligible for re-entry to facility if contraband is found. Length of ineligible time will be documented according to the “Exit and Readmission Policies”.
When inspecting a client’s possessions without them present, two staff persons will be responsible for the search. An Authorization Form will be signed by the client at time of entrance into facility when they place items into the storage area. When items are found in the client’s possession that are not suitable for storage, clients can choose to have staff dispose of the item or client may store property off site premises at their own cost.
32 11. Policy on Possession of Weapons On-Site
No weapons or objects which can be used as weapons will be brought into the shelter. All of a client’s belongingsthat they are carrying on-site will be searched upon entry and inspected for weapons and items that could be used as such. Anyone found with a weapon or dangerous material that can be used as a weapon will be asked to immediately leave the premises and neighborhood of the facility. Sharp objects such as tools or scissors will be stored in locked storage areas and not taken into shelter living areas.
All kitchen knives and sharp objects, hazardous materials, and cleaning equipment that could be used as a weapon will be kept in locked areas with only staff accessibility.
12. Procedure for Contacting Police
The intention of the Shelter Operator should be to act as self-sufficiently as possible and minimize the shelter’s impact on the Corona Police Department. This includes ensuring that staff and security will be trained to properly manage and respond to an array of difficult situations that may occur at shelter.
In establishing a procedure for contacting police, the Shelter Operator will work cooperatively with Corona PD and the Homeless Solutionsstaff to establish shelter policies and procedures on how and when to contact police for conflict resolution, trespassing, theft, unruly behaviors, loitering around property, mental health evaluation, and emergencies.
Upon consensus, a 911 protocol will be established and followed. All staff members will be trained in these procedures. 911 may be called for any medical emergencies, violent behaviors that endanger others, and suicidal ideation.
L. Health Policies
1. Housekeeping Policy
The Shelter Operator will commit to and understand the importance of maintaining hygienic, sanitary environments for the well-being of clients, volunteers, and staff. The Shelter Operator will maintain written, standardized housekeeping procedures. Each procedure will be designed for safety of staff and clients and for a consistent, high standard of housekeeping. Staff will be provided with training in these procedures, will be monitored in performance of the procedures, and evaluated in their effective use of them. Training may include education onany hazardous materials with which staff may come into contact when carrying out their assigned work tasks. The complete list of procedures will be included in a Shelter Policy and Procedures Manual and made available to all employees.
33 Outside janitorial staff may be contracted to assist in the maintenance and cleaning of the facility. Thorough daily cleaning of all client areasincluding living quarters, kitchen and dining areas, and common areas will be completed using institution strength anti-bacterial products.
Bathrooms, showers, and eating areas will be given priority attention. The kitchen and dining areas will be cleaned according to strict health standards after each meal. Office space will be cleaned weekly by the janitorial staff and as needed by Shelter staff and partner organizations using the space.
To prevent cross-contamination, clients will be required to store personal toiletries in plastic sealable bags on their beds when not in use. Clients will be assigned a set of linens at intake for their use while in the shelter. The client will be responsible for making and maintaining their bed each morning. Staff will wash bed linens weekly in hot water with bleach unless special circumstances require more regular cleaning.
All staff will practice universal precautionsin handling of laundry, cleaning of facility, and general self – health care. Specifically:
Staff will wear appropriate protective garments (i.e. gloves) while completing tasks Staff will use recommended disinfecting cleaning products for each area of facility Staff will practice required hand-washing procedures
Kitchen staff will be trained in and practice required food-handling procedures All client clothes will be washed upon initial intake and weekly (or as needed) thereafter All laundry will be handled according to safety and washing procedures Staff and volunteers will follow a set of Program Rules and Regulationsfor working when they are sick/contagious
The outside grounds will be included in the housekeeping standards and schedule. The Shelter’s outside spaces, parking lot, and green areas will be cleaned daily from debris and litter. Chairs and tables will be washed according to inside standards. Minor repairs of the facility and grounds will be completed by the Shelter staff. Any major repairs or work requiring specialized training will be completed by approved vendors. Shelter Operator shall refer to the Lease Agreement to understand responsibilities of City and Shelter Operator.
34 The Navigation Center will be included the housekeeping standards and schedule. The Service Partner agencies must adhere to housekeeping procedures as outlined in their respective MOU agreement. Service Provider Partners will be expected to respect and keep their areas clean after usage.
2. Pet, Assistance Animal and Service Animal Policies
Clients will be permitted to bring pets, assistance animals, and service animals to the shelter facility.
Service animals and assistance animals will be permitted to stay with client in the shelter living areas while all other pets must stay in assigned kennels/crates in sleeping quarters and the designated dog run during times of client recreation, or on leashes in outdoor common areas.
In order to qualify as a service animal, a client must produce an official letter from a licensed physician, social worker, therapist, or case worker stating that the animal is needed to ease the effects of mental, emotional, or physical disabilities.
Only registered animalsthat have proof of current rabies vaccinations will be allowed at the shelter facility.
The health and well-being of all pets as well as assistance and service animals brought into the shelter facility will be the responsibility of the owner. Shelter guest pet responsibilities include:
o Compliance with leash policies for safety of othershelter guests, other animals, and shelter staff and volunteers
o Spay/Neuter laws
o Feeding/watering animals
o City Licensing
o Pick-up after pet waste
o Safe Tethering Laws
o Rules against animal cruelty
Clients who are unable to care for or feed their pets or cannot control them while at the shelter will be asked to remove the pets from the facility. Shelter Operator will work with City Animal Services & Enforcement and/or Riverside County Department of Animal Services to determine if temporary boarding options are available for clients with extenuating circumstances.
35 Shelter Operator will work with City Homeless Solutions staff to develop funding and community partnership strategies to assist clients with pet care costs such as rabies shots, licensing, food, or vet bills.
Shelter Operator may deny requestsfor Pet, Assistance Animal, and Service Animal accommodation if:
o Animal poses a threat to other shelter guests, shelter staff, or pets of other shelter clients. Such denials will be based upon
Behavior of animal
Nature, duration, severity of risk and probability that potential injury will actually occur and whether risk can be mitigated through a soft muzzle Undue financial or administrative burden
Accommodation fundamentally alters nature of shelter services
3. Possession and Use of Controlled Substances
The Shelter Operator will have a strict policy prohibiting the possession or use of alcohol or controlled substances at the Emergency Shelter/Navigation Center premises by employees, residents, clients, and general public.
It will be the intent of the Shelter Operator to promote a safe, healthy, and productive environment for everyone. Staff recognizes that the illegal and/or excessive use of drugs and alcohol, or the inappropriate use of prescribed drugs is not conducive to a safe living environment. It will be the objective of the Shelter Operator to have an environment that isfree from the influence of controlled substances and alcohol at all times on premises. The unlawful purchase, possession, transfer, manufacturing, distribution, dispensation, or use of any illegal drug is inconsistent with the objective of operating in a safe and efficient manner and will be strictly prohibited and is contrary to the Emergency Shelter/Navigation Center’s mission.
4. Policy for Drug Possession
Staff will have the right to refuse entrance to any client who is noticeably under the influence, exhibiting behavior that is inappropriate due to influence, or otherwise cannot follow the rules and expected behaviors of a client while participating in shelter activities. If alcohol, illegal substances, or paraphernalia are found in client’s possession after they have completed entry paperwork and necessary security screenings, that client may be asked to exit the facility at the discretion of staff. They may be given a time frame of their next eligible readmission date. The illegal drug or alcohol will be disposed of and documented by two staff following written protocol in a Policy and Procedures Manual.
36 5. Security, Use and Access of Prescription Medications If a client has medications that must be administered throughout the evening/night or will be damaged by extreme heat or cold, they may retrieve them from a designated staff person. If a medication needsto be refrigerated, the medication will be packaged and labeled with person’s name, bed number, and name of medication and placed inside a designated locked refrigerator.
A client who qualifies and requests their medications to be stored in a locked area must sign an Agreement Form and will have access to the medications as soon as possible by their request to the staff on duty. The client will be responsible for requesting and taking their own medications within limits of how they are prescribed. Only the person whose name is on the medications will be able to retrieve them.
6. Client Use of Over-The-Counter Medications
Use and storage of over-the-counter medicationsfollow the same policy and procedures of prescription medications.
7. Client Accessto Emergency and Medical Care
Clients may have access to medical care. Centro Medico Community Clinic is the City’s onsite Federally Qualified Health Center (FQHC) partner. Client should communicate to staff member on duty their need for medical care, if possible. Medical support may be accessed through the onsite Medical Wing and/or through local hospitals if and when access to the Medical Wing is not available.
If a client requires first aid items, they may access them from a shelter staff member at the service desk. The staff member may assist the client in first aid care with client’s permission, as he/she will be trained, and using universal precautions.
In case of a seizure, staff will be trained in appropriate safety precautions and will call support from the Medical Wing staff or 911 if seizure persists or causes bodily harm. If a client needs emergency or serious medical care, the staff on duty will call 911 and follow 911 procedures. In case of an injury, staff will not move the client. They will contact other staff, call 911, and if appropriate, check breathing and pulse and begin CPR if needed. One staff member or trained volunteer will attempt to keep the client comfortable and keep other clients away from immediate scene, while another staff member will wait for medical personnel, give medical personnel information about client, and direct them to client.
The Program Manager will be called as soon as possible. After client emergency or incident has been controlled, the lead staff member will complete a Critical Incident Report form which will be immediately sent to the Program Manager, higher-level staff as needed, and City of Corona Homeless Solutions staff.
37 8. First Aid Equipment, Supplies and Procedures
The Shelter Provider and/or Medical Wing partner will have first aid supplies available at all times. The first aid kit will be inspected monthly, updated as items expire, and re-stocked after each use. Staff members will be trained annually in universal precautions, first aid care, seizure, or Mental Health crisis. Any incident occurring at the Emergency Shelter/Navigation Center requiring first aid will be documented in the daily report and a Critical Incident Report will be prepared and sent to Program Manager, other higher-level staff as necessary, and City of Corona Homeless Solutions staff.
9. Policies & Procedures for Disease Prevention
The Shelter Operator will have protocols for prevention and treatment of certain diseases and conditions such asseizures, diabetic episodes, mental health episodes, lice, bed bugs, influenza, and other communicable and contagious diseases. Universal precautions will be maintained at all times in handling of fluids, client clothing, laundry, and in all cleaning of premises.
When an accident or injury to an employee or client occurs or when there has been damage to Shelter property, staff will follow a set protocol which includes:
Immediately contacting Supervisor aboutthe situation
Dealing with any injuries
Securing the accident scene by obtaining names, addresses, and phone numbers of witnessesif possible, taking photosif possible, and noting any unusual circumstances Recording all necessary information to complete a formal report Not accepting any responsibility on behalf of the Shelter Operator Reporting all accidents or injuries within 24 hoursto insurance carrier Completing and submitting a Critical Incident Report to the City Homeless Solutions staff If a client shows symptoms of a contagious disease or other public health concern that might threaten another person, the client will be sent to the Medical Wing or hospital emergency room for diagnosis and treatment. If a client leaves due to disease, the bedding and client’s clothes will be washed, bed cleaned, and bedding replaced on bed. Clothes and belongings will be stored in designated area and held for the maximum amount of time permitted. The Shelter will operate to conform to best health practices and concerns.
Universal precautions will be used for all handling of client possessions. Staff will follow hand washing techniques recommended by the Riverside County Public Health Department AKA Riverside University Health System – Public Health.
38 M. Food Policies
1. Provision of Nutritional Needs of Clients
The Shelter Operator will provide a breakfast, lunch, and hot dinner to each shelter guest client every day. Meals will be prepared through the on-site kitchen facility. The Shelter Operator’s Food Coordinator will work with the Kitchen staff to coordinate a weekly menu. They will ensure that meals will be nutritious and balanced.
The Shelter Operator will include in its in-kind donation strategies, opportunities for food donations and partnerships with local food banks. The Shelter Operator will also work with community and faith-based partners and existing community meal service programs to offer opportunities to feed homeless individuals at the shelter as part of the City’s pilot transportation shuttle/day meal service program to move homeless meal serving out of City parks and into the shelter. During extenuating circumstances, through in-kind partnerships or as cost-effective strategies are developed, Shelter Operator may also purchase daily food deliveries through a third-party vendor and include such expenses in the operating budget.
Tables will be set up for meals in the dining area of the Shelter at the scheduled meal times. Food will be served at designated times of operation for registered shelter clients or registered transportation shuttle/day meal service program clients only.
2. Meeting Riverside County Environmental Health Department Standards The Shelter Operator, Food Coordinator, and Kitchen Staff will meet all Riverside County Environmental Health Departmentstandards. Thisincludes but is not limited to the Food Facility Operators Guide and Ordinance 492 which governs requirementsfor Food Facilities. Inspections will be completed by the Health Department and any changes will be made if indicated. The certificates for Health Department inspection results will be posted in the Kitchen area of the facility. All cook staff will be required to have completed the ServSafe Food Handler Program.
3. Provisions for the Sanitary Storage and Preparation of Food The Emergency Shelter/Navigation Center will have adequate space for storage of dry foods, refrigerated foods, frozen foods, and supplies. Separate refrigerator/ freezer space should be available for client medications. The Shelter Operator will provide extra refrigeration and freezer appliances as needed to supplement safe storage of food, if space is available. Current certificates of food handling safety will be posted in the kitchen area and in the employee file for each cook. Cooks and volunteers assisting them follow the procedures of the Riverside County Environmental Health Department as taught in the ServSafe Food Handler Program. All volunteers will be supervised by a cook employee. Other employees will only be allowed in kitchen area under supervision of cook.
39 All storage areas will be cleaned on a planned schedule and outdated food will be disposed of.
There will be a rotation schedule for storage and use of food in freezer, refrigerator, and dry goods pantry that maximizes use of food so that it does not become outdated.
N. Transportation Policies
The policiesfor travel to and from the Emergency Shelter/Navigation Center will be designed to support client needs and minimize potential impact on the adjacent neighborhood and surrounding businesses.
The following transportation measures will be implemented:
1. Transportation Flow On and Off Property
The Shelter Provider will create a plan for safe and effective flow of traffic on and off the property based on the schematics of the shelter grounds and surrounding neighborhood.
Considerations should include policy for no-walk-ins/no walk-outs, policy for clients with vehicles and bus/shuttle services.
2. Pedestrian Traffic
The shelter will operate by bed reservation only and no walk-ins or walk-outs will be allowed. The clients will be expected to utilize the transportation options that will be provided to them by the Shelter Operator. The no walk-in and no walk-out policy will be posted and disseminated throughout the community.
Any individual that does walk-up will receive information on how to connect with City Net for a referral in order to be screened for eligibility to make a bed reservation and be provided transportation to a self- directed location out of the surrounding area to return only when the established reservation protocol has been followed.
3. Bicycle Traffic and Parking
A bicycle rack will be provided in a secured outdoor area. Bike locks will be encouraged but are the responsibility of the client to obtain. Bus and shuttle transportation vehicles will be designed to transport bicycles to mitigate foot traffic to the facility.
4. Bus and Shuttle Transportation Services
Access to the shelter will be provided by bus and/or shuttle transportation services. The Shelter Operator will work cooperatively with City and other stakeholdersto provide the most cost-effective means for providing transportation to and from the shelter.
40 It is recommended that there be a minimum of two (2) designated pick up locations that provide ample geographic range for qualified clients seeking shelter services. Locations will be selected by the Corona Police Department and the City’s Community Services Department.
Operator will not drop-off/pick-up other than at agreed upon locations.
Daily bus and/or shuttles will be provided to transport all screened clients to the Shelter Site.
Security personnel will be staffed at each location to ensure only prescreened clients with bed reservationsreceive transportation to the shelter. Operator/Security will also conduct random daily checks of 1 mile radius to shelter and drop-off/pick-up locations to enforce shelter rules and thus avoid loitering and homeless congregations.
To avoid, long term loitering at the bus and/or shuttle pick up areas, clients may arrive at the bus and/or shuttle Stop thirty (30) minutes before the Bus/Shuttle departure time.
Drop-off/pick-up locations are an extension of the shelter and thus any violation such as loitering constitutes a violation of the shelter rules which will be strictly enforced.
In the case of special circumstances, and only if arrangements have been communicated by the client to their Employment and Housing Navigator and/or bed reservation staff the prior evening, returning clients who are unable to return to the shelter at the designated time may work out alternative transportation options so long as the no-walk in or no walk-out policy is not violated.
Shelter Operator may also authorize prescreened clientsto drive their vehicles to the shelter facility after a bed reservation has been confirmed.
Each morning, two bus and/or shuttle services will be provided for clients who desire to leave the shelter for employment and other personal appointments. Suggested times are 6:00AM and 10:00AM.
5. Personal Vehicle Transportation and Parking
The Shelter parking lot will be available to Shelterstaff. Volunteers, vendors, and community visitors may also park their vehicles in the Emergency Shelter/Navigation Center lot while at the facility. The facility’s parking lot can accommodate 11 vehicles.
Vehicles eligible to park in the Harrison Emergency Shelter and Navigation Center lot will be listed on the Vehicle Parking Form by license plate and client name. Vehicles in lot overnight must be registered on this log each night. Security staff will include the parking lot during security rotations.
41 Harrison Street parking restrictions do not allow overnight parking from 8 pm to 8 am with the exception of the 10 spaces in front of the facility as depicted below:
Shelter Operator will be required to develop strategies to manage overnight parking with 21 available spaces. Please note that once the shelter is operational, Operator can work with the City to incrementally change parking restrictions if more than 21 spaces are needed for overnight parking for shelter staff, vendors, and clients with vehicles
6. Staff Transportation of Clients
Shelter staff members will not be permitted to transport clients under any circumstances in their personal vehicles. Only designated staff in shelter owned/operated or contracted vehicles may transport clients.
7. Transportation Policiesfor Navigation Center Clients If Phase II is implemented, transportation to and from the Navigation Center must be arranged by the Service Provider partner.
8. Delivery of Shelter Goods and Community Donations
Deliveriesfor shelter goods and community donations will be dropped off in a designated area.
The planned location for these designated drop-offs will take into consideration pedestrian, bike, and other vehicle traffic routes to minimize safety risks and impact to the shelter site and surrounding area.
It is anticipated that delivery of goods from contracted vendors will occur approximately 3xs weekly. The delivery of community donations by private donors will occur approximately 3xs daily during designated donation drop-off times.
Subject to change as may be needed, all deliveries of goods and/or donations will occur
42 between the hours of 10AM-4PM.
O. Financial Policies
1. Financial Requests from Clients
Financial requests from clients must be requested and received through their Employment and Housing Navigator and/or through Service Provider Partner at the Navigation Center. Clients will sign a designated log when they receive the requested item (bus pass, clothing/food voucher, etc.). All bus passes and/or vouchers must be kept in a locked safe in a locked office or closet at all times when not in use.
The Shelter Operator and/or Service Provider partners may offer financial assistance opportunitiesto clients, when available and must establish priority levels and/or other fair means for distribution. The Shelter Operator and/or Service Provider partners will not be obligated to fulfill all financial requests from clients that they receive.
2. Client Possessions and Funds
No funds of clients will be handled by the Shelter staff. Clients with funds kept in their possession while at the Shelter will be responsible for their security and safety. Staff will encourage clients not to have funds on site, and to store wallet, electronic devices, and any cash in appropriate locked storage. The Shelter Operator will have a policy of not being responsible for lost or stolen items that is included in a Policy and Procedures Manual, listed in the signed Rules agreement, and read nightly when rules will be reviewed before intake.
Clients will not be permitted to give cash to staff at any time, for any reason.
3. Annual Outside Audit
An independent financial audit of the Shelter Operator will be completed on an annual basis. A most current audit will be kept on file at the Shelter Operator’s administration office(s) and may be viewed, as necessary.
The Emergency Shelter/Navigation Center will also be subject to an annual program audit or monitoring. It will be the responsibility of the Shelter Operator to correct any deficiencies reported by the audit within the time limits available to them. Failure to comply may result in the termination of the Shelter Operator contract.
43 4. Financial Reports Review
Financial reports will be produced each month by the accounting department of the Shelter Operator. These reports will be reviewed by the City of Corona Finance Department and Homeless Solutions staff.
The Administration Office of the Shelter Operator will review financialstatements and budgets with Program Manager on a regular basis. To manage programs within authorized budgets, adjustments will be made in spending, if necessary.
P. Legal Policies
1. Policy for Compliance with Local Laws
The Shelter Operator will follow all County Health Department and City Fire Department requirements, and will train staff for food handling, CPR, fire drills and other disaster evacuation procedures. The Shelter Operator and staff will work cooperatively with Corona PD to deal with clients who commit crimes while staying at the shelter. Additionally, Shelter staff and management will cooperate with law enforcement agencies on investigations for persons wanted for crimes as much as is possible while maintaining policies on client confidentiality.
2. Policy for Compliance with Labor Laws
The Shelter Operator will comply with all required labor laws. Occupational Safety and Health Administration (OSHA) training and reviews will be conducted during staff meetings on a quarterly basis. OSHA flyers will be posted in administrative offices.
The Shelter Operator’s wages will be at or above minimum wage. Employee breaks, meals, and overtime will be monitored legally and compensated as needed. The Shelter Operator will be contracted with a company to examine any work injuries. The proper incident reports, Workmen’s Compensation forms, and requirements will be completed.
Q. Non-Discrimination Policies
The Shelter Operator will adhere to a policy of non-discrimination which will be stated in the Shelter Operator’s Policies and Procedures Manual.
The Shelter Operator will not discriminate in the provision of client care based on age, race, color, religion, sex, sexual orientation or gender identity and expression, marital status, geographic, national, or ethnic origin, HIV status, disability, or veteran status.
44 1. Policy for Compliance with Americans with Disabilities Act The Shelter Operator will comply with appropriate standards of The Americans with Disabilities Act (ADA). Staff will be trained to be cognizant of any client physical disability and assist as needed to address any barriers from the structure of the building. Staff will receive training to work appropriately with persons with disabilities. All persons will be treated with dignity, value, and worth.
2. Gender-Specific Programming Policy
Persons accessing the Emergency Shelter/Navigation Center services will be identified by the gender identification for which they choose. Staff will provide beds to persons of gender identity, expression, and sexual orientation with due regard to privacy and client rights.
Bathrooms and showers will be constructed with equal privacy for all clients, regardless of sexual orientation, expression, or identity. All programs and services will be available with the dignity of all clients as highest priority.
3. Sexual Harassment Policy
All clients, volunteers, and employees should be able to coexist at the Emergency Shelter/Navigation Center in a trauma informed care environment, free from sexual harassment and inappropriate sexual behavior.
The Shelter will have a zero-tolerance policy for sexual harassment and inappropriate behavior of a sexual nature. No sexual harassment will be tolerated by anyone on the facility grounds, including staff, volunteers, or clients. Clients, staff, and volunteers will be notified, at the Shelter Operator’s sole discretion, if any of their remarks, advances, gestures, or attire constitutes sexual harassment toward any person in the Harrison Emergency Shelter and Navigation Center facility.
Anyone who believes he or she has been the subject of any such behavior will be urged to report it to the staff or supervisor immediately. A report will be completed and taken to appropriate staff or supervisor for resolution. Reported incidents will be investigated on a confidential basis. Provisions will be instituted to guard the safety and emotional health of persons who have been victims of a reported incident. After proper review, a person found to have engaged in sexual harassment or inappropriate behavior of a sexual nature will be subject to disciplinary action including possible immediate exit from program or termination from employment.
45 4. Policy Regarding Sex Offenders
The Shelter Operator will have strict requirements for the safety staff, service partners, and clients. Staff and volunteers will be trained in sex abuse definitions, sex offender policies, and vulnerable adult abuse. All employees must review thistraining yearly and be certified to have passed its standards.
The Shelter Operator will follow federal law requirements in reporting sex offenders. All clients will be screened for sex offenses through the National Megan’s Law database. Screening will be conducted at the time of reservation; no potential participants with a registered sex offense will be allowed on the bus/shuttle or admitted as clients.
R. Confidentiality Policies
1. Personal Confidentiality
People seek help from emergency shelters at a difficult time in their lives. Their need for service and the help that can be provided is determined through sharing of factual and personal information. For this to be effective, every client must be able to trust that every staff member and volunteer respect client confidentiality.
Therefore, the Shelterstaff and Shelter Operator will maintain strict confidentiality practices as written in Confidentiality Policy. These practices include:
1) Fact of Participation: The fact that an individual is or has been a participant inthe Emergency Shelter/Navigation Center should not be disclosed except as may be specifically defined.
Inquiries by visit, telephone, or letter regarding a participant in the program should be answered with the statement that information as to whether a particular person is or has been in residence cannot be divulged; that if in fact the individual is in residence, they will be advised of the inquiry, and that, at their discretion, they will or will not communicate with the inquirer. 2) Disclosure to Other Agencies: Disclosure of client information to the City Homeless Solutions staff and other social service agencies, whether on a referral to or from the agency, generally may be permitted with the client’s written consent for release of information. Information is to be withheld where enjoined by law and by contract. The Shelter Operator will maintain the confidentiality of client records (as under the Privacy Act). Disclosure of information relating to program participantsshould not be made to employers, credit agencies, unions, or other similar organizations, except at the request, and with the consent of the client. 3) Information to the Client: In some situations, it may be required by law to disclose to the participant information contained in his/her own case record. Information disclosed shouldbe limited to that which is included in the formal case record. The formal case record should contain factual information, not counselor notes and observations. Information provided by other agencies should not be shared.
46 4) Law Enforcement Agencies: All requests for information regarding clients originating from law enforcement agents, should be referred to the Shelter Operator’s acting Legal Department.
Before any action is taken on any legal request, a staff member or program manager should contact their Legal Department as there are boundaries in place to determine the sharing of information with law enforcement personnel according to its policies on client confidentiality(as stated in the Shelter Operator’s Policy Manual) and applicable law.
When an arrest warrant or a search warrant has been issued by a court, if such a warrant is presented to the facility relating to a client in the residence, staff will cooperate with the law enforcement agency in making the arrest or the search, preferably in a manner which will involve the least disruption to the program at the facility.
5) Written Consent: If there is any doubt as to whether client information should be disclosed, the consent of the client should be first obtained, except as otherwise required by law. The consent will be in writing on a Release of Information form and should identify theinformation to be disclosed, the person or agency to whom it will be disclosed, and the purpose of the disclosure, and the period of time during which authorization is granted. 6) Abuse Reporting: The Shelter Operator and Shelter staff will comply with all state and municipal laws requiring reporting to governmental agencies of instances of domestic violence and elder abuse. Staff will report any suspicion or evidence of vulnerable adult abuse. All staff persons at the shelter will be mandatory reporters. A Critical Incident Report will also be completed and submitted to the Program Manager, any higher-level staff as needed, and City Homeless Solutions staff. All staff will be trained at time of hire to identify signs of abuse and to properly document and report it. Training will be repeated annually. 7) Harm to Self or Others: If a client at the shelter program shares with a staff person a viable threat to do harm to self or another, the terms of confidentiality can be revoked, as in thecase of suicidal or homicidal admittance.
2. Database Confidentiality Policies
Only trained Intake staff, Employment and Housing Navigators, and management staff will be authorized to access the Homeless Management Information System (HMIS) Database. Each staff person will have a separate password for entry. Staff is only to use computers that are authorized and HMIS compliant. No persons without a username and password set up by the Shelter Operator’s IT department should have access to staff-only computers.
3. Exceptionsto the Confidentiality Policy
All clients will be informed that staff will comply with the law to disclose client-related information to prevent danger to self or others or to report elderly/vulnerable adult abuse.
47 S. Grievance Policies
The grievance procedure will be applicable for any conflicts or disagreements between clients or between clients and staff. For example, the grievance process may be employed to address disruptive behavior or appeal incorrect formal action. However, in no way does the grievance procedure suspend the rules or consequences established in the Shelter Rules signed upon entering the program. Clients will have the right to file a grievance without the fear of harmful repercussions from staff or other residents.
1. Receiving and Posting
The Grievance Procedure should be clearly posted in the Policy and Procedure Manual and available at the shelter facility. A client will be given a copy of the grievance procedure when a conflict has occurred that cannot be resolved satisfactorily between the client and a staff person or another client, or when the client has a complaint about an event that occurred at the Shelter involving that client. The Grievance Policy Form will be read by the client and signed.
2. Meeting with Staff
Once received, staff will decide at the earliest regular staff meeting which grievances warrant a meeting. If needed, a formal grievance meeting will be called, headed by the Program Manager or their assistant. Prior to this meeting, the client defendant will be given a copy of the grievance so he/she may prepare to respond to the grievance.
At the grievance meeting, the plaintiff will begin stating his/her case. The defendant will then respond. All persons present will be allowed to ask questions of either the plaintiff or defendant. The burden of proof rests with the plaintiff. All decisions will be binding and after the formal grievance procedure has been completed, staff and residents will be expected to regard the matter as settled and in the past.
If a client expresses a concern or makes a complaint concerning their involuntary discharge, he/she may take the following steps:
The client may request to discussthe matter with the Program Manager, who will make a decision on any corrective action required within the boundaries of his/her authority.
When appropriate, the Manager will notify higher-level staff.
If the client is still unsatisfied with the outcome, he may submit a request for intervention to the Shelter Operator’s Executive Director, who will acknowledge receipt within a reasonable time frame. The Executive Director will take any corrective action required within 10 days and inform the client, in writing, of the resolution.
48 Clients have the right to ask assistance of another person to speak on their behalf, or to help fill out a grievance form.
Client grievances will be reported in monthly program reports. The Executive Director or other Shelter Operator executive staff member will review all grievances quarterly and/or annually.
Grievances and resolutions should be documented in client file and incident reports.
3. Whistleblower Policy
Clients should have several ways in which they may share a grievance – verbally or written, anonymous or through a third party. A suggestion and grievance box will be available in the common area and will be checked weekly by staff.
Confidentiality will be strictly kept between the person making the complaint and the Program Manager which will withhold information internally to the extent prudent where a complaint involves a staff member or volunteer. The Grievance Procedure will be clearly posted in the Policy and Procedure Manual and available at the facility.
SECTIONIII. STAFFING AND MANAGEMENT PLAN
A. Staff Policies
1. Hiring Policy
The Shelter Operator must be an equal opportunity employer. A copy of its applicable Equal Opportunity and Affirmative Action Policy will be available in the Employee Handbook and through the Human Resources Department of the Administrative Offices.
2. Screening Procedure
Position openings will be posted on various employment networking websites. Potential applicants will be screened through a two-step interview process.
3. Acceptance Procedure
A completed application packet and staff letter of recommendation will be sent to the head of the Human Resources Department who conducts a thorough background check. Every potential applicant will be screened for active warrants, violent felony convictions, sexual offenses which require registration, and legal ability to work. Staff who will be in direct contact with clients will also be required to complete Tuberculosis screening as well as training for mandated reporting policies. The applicant
49 must successfully complete all screening requirements before they will be able to begin working directly with clients.
Upon hire, the new employee will sign a job agreement form and will be provided a job description informational sheet for their records. They will also attend a general orientation program led by the Head of the Human Resources Department. This orientation will cover important topics, such as but not limited to, sexual harassment policies, and appropriate interactions with co-workers, volunteers, and clients. Training places a heavy emphasis on appropriate conduct between staff and clients. Staff will be expected to adhere to these practices when interacting with clients. Program Managers complete a lengthier program-specific orientation process.
4. Staffing Policiesfor Safe Humane Environment
The Emergency Shelter/Navigation Center will be staffed to provide the safest, most dignified environment for all clients. All staff will be easily identifiable and will be required to wear Shelter Operator- Approved shirts as well as name tags while on site.
It is recommended that a total of full- time staff and up to part-time staff at the Emergency Shelter Program. Staff will be scheduled to optimize safety of staff, volunteers, and clients and to provide optimal coverage during hours of high volume.
B. Policiesfor Staff Training
All Emergency Shelter/Navigation Center staff will be trained in emergency evacuation, first aid procedures, mandated reporting policies, crisis intervention, and CPR procedures. This training will be repeated and updated annually and as needed. Staff may receive additional training on different topics as opportunities arise and are needed.
Each staff member also receives on-going in-service training in crisis management. Staff will also be trained in Strength Based Approaches and positive communication skills. Each staff member will be required to attend annual training to update and improve their knowledge. Documentation of training will be kept in each employee’s file by the Program Manager and provided to the Head of Human Resources for filing, when appropriate.
Security staff will be provided sensitivity training to better equip them to work with homeless clients, and those in crisis.
1. Emergency Procedures - Evacuation, First Aid, and CPR, 911 Reporting Emergency Shelter/Navigation Center staff will be trained in fire, earthquake, and chemical spill evacuation procedures when hired and annually. Evacuation drills with allstaff and clients will be held and recorded quarterly. Evacuation protocols will be recorded at the Service Desk for reference.
Evacuation maps will be posted throughout the facility. All staff will be trained in first aid and CPR
50 procedures annually. 911 reporting will be taught in orientation and reviewed annually. CPR certificates will be kept in staff files. Universal precautions will be followed.
2. Safety Conduct - Prevention of Abuse, CrisisIntervention, Conflict Resolution The Shelter Operator will have a required training program in prevention of vulnerable adult abuse, and sexual harassment. Each staff will complete this training program annually. Certificates of completion will be recorded in Human Resource files.
Emergency Shelter/Navigation Center staff will complete a course in conflict resolution and crisis intervention upon hire and annually. Documentation of completion will be recorded in staff file.
3. Appropriate Behavior for Dignity and Respect
Operations, Program, Administrative, and Management staff will be trained in a Strengths Based Perspective model of client care. They will be trained regularly, including at time of hire, on the best methods of working with, treating, and responding to clients who have had difficult and traumatic life experiences. Each staff member will be expected to put these modelsto use in every interaction they have with clients and potential clients. Staff members will be offered training regularly and expected to participate actively. Notice of completion will be recorded in staff files, and each staff member should have access to this information in the readily available staff handbook.
4. Communication
Clients, Staff, Community
Shelter staff will undergo classes in communication skills – such as handling phone calls, confidentiality policies, crisis management and de-escalation of conflict. The communication skills will be reinforced through practice and reviewed at regular staff meetings as warranted. Courses covering topics such as communication skills with mentally ill persons, receptionist skills, communication with difficult people, and conflict resolution will be completed. This training should be completed at least monthly and will be provided more often, and individually, as needed.
5. Resources and Referrals
Operations, Program, and Employment and Housing Navigator Staff will be oriented to resources, homelessservices, and organizations for collaboration and referral. They will also be highly trained staff to connect clients to the Coordinated Entry System, as a system designated Entry Point. A staff representative will attend the Riverside County Continuum of Care meetings.
Protocols for offering and accepting referralsfrom other agencies will be in place, reviewed by staff, updated, and kept in a manual on-site.
51 6. Mental Health and Addiction Skills
All Program staff will attend mental health training events which include naming of symptoms, cooccurring diseases, de-escalation techniques, and safety protocols. This training will be completed at time of hire and annually, or as necessary. Staff will attend workshops and training on various aspects of mental health diagnoses, symptoms, and care. Staff will be trained in symptoms of drug abuse, and referrals for treatment. Recovery programs will be encouraged, and off-site referrals will be made as appropriate.
Though sobriety will be not a requirement to stay in the shelter or participate in services, clients will be expected to be able to practice self-care, follow all rules and regulations, and behave appropriately and respectfully toward staff, volunteer, and other clients. Drug use while at the shelter will be prohibited and will result in immediate exit from the program.
7. Self - Care
Regular staff meetings will be held for all staff. Part of the purpose of these meetings will be communication and processing of stressors while working in the difficult environment of an Emergency Shelter/Navigation Center. Staff will be welcome to participate in team-building activities throughout the year, including holiday parties, and events with co-workers.
All staff will be trained in effective communication with coworkers and in proper techniquesto address coworker harassment and stressors and will be made aware of the importance in practicing self-care.
Staff will be informed of an open-door policy with supervisors and the Head of the Human Resources Department.
8. Annual Staff Evaluation and Training Plan
All staff will be evaluated by their direct supervisor at 90 daysfrom their hire date and at semi-annual intervals. The evaluation form will be stored in the employee file held at the Human Resource office.
9. Documentation of Staff Training
Attendance of and participation in staff training will be recorded in each staff file by the Program Manager of Emergency and Shelter Services. Training required by all staff members will be also recorded in the Human Resourcesfile to ensure each member’s knowledge and information will be upto-date.
52 C. Volunteer Policies
1. Selection, Screening, and Background Checks
The Emergency Shelter/Navigation Center Volunteer Coordinator will actively recruit through a variety of sources, including schools, faith-based groups, and community programs. Volunteer Coordinators will hold regular Volunteer Recruitment events in order to increase the number of volunteersthatserve at the Emergency Shelter/Navigation Center.
Individuals as well as groups will be invited to volunteer at the shelter. Children 13 and older will be able to volunteer, however they must be accompanied by an adult or legal guardian and both adults and guardians must be registered to volunteer on the day they appear.
All potential volunteers will be screened for sex offenses and criminal background checks before being confirmed for volunteer duty.
2. Orientation and Training
The Shelter Operator will include a Volunteer Coordinator position(s) in itsstaffing plan to support volunteer coordination efforts at the shelter. The Volunteer Coordinator will handle scheduling, orientation, and training of the volunteers.
Before beginning service, volunteers will be provided an Application and Agreement that includes information about volunteer duties, appropriate conduct with clients, staff, and other volunteers. Each volunteer will be required to sign this Agreement before they will be assigned a duty at the shelter.
Volunteers who do not agree with the requirements or refuse to sign will not be assigned a duty and will not be able to volunteer at the shelter.
Volunteers will sign up for an open position, time and date using online volunteerscheduling software.
Volunteer Coordinators will call and confirm volunteer’s date and time and to provide them with the location of the shelter and any necessary important information.
Volunteers will be trained on-site at tasks by the Volunteer Coordinator on duty. Any tasks that require a trained staff member will be supervised by that staff member to ensure accuracy and cleanliness.
Volunteers will be given opportunitiesto attend community forums and eventsto receive more training about community resources and network with other community agencies.
Volunteers will be expected to adhere to a strict code of ethics and standards. Those found in violation of this code will be removed from the facility and may be limited in future volunteer opportunities.
The volunteer code of ethics includes the following:
53 a. Each volunteer must maintain a firm commitment to professional conduct Volunteers of the Emergency Shelter/Navigation Center will be expected to maintain the highest level of moral, ethical, and professional conduct while at the site. Volunteers will not engage in verbal abuse, inappropriate jokes, and stories, and or any type of inappropriate interaction with Emergency Shelter/Navigation Center staff or clients.
b. Limiting Relationships with Clients
Volunteers will be prohibited from developing dual relationships with any clients they meet through their volunteer involvement at the Emergency Shelter/Navigation Center. Examples of dual relationships include (but will be not limited to) a volunteer entering into a business,romantic, or sexual relationship with a client. Soliciting clients for their business will be strictly prohibited.
Volunteers will be not allowed to be named as having authority to make decisions for a client under any type of power of attorney or other legal procedure. c. Food and Other Substances
Volunteers will not consume any food items or drinks supplied by the Emergency Shelter/Navigation Center while volunteering. Food and drinks will be purchased solely for the consumption of the homeless clients. Volunteers must also commit to not consuming any type of illicit drugs on the property while volunteering. Volunteers who appear to be under the influence of any substance that impedes their ability to perform their duties safely and efficiently may be turned away.
d. Discrimination
Volunteers will not discriminate against any client. They will not judge an individual based ontheir race, disability, religious preference, sexual orientation, color, age, veteran status, citizenship, ancestry, national origin, or gender.
e. Volunteer Boundaries
Volunteers will be not permitted to loan or give money to clients, should not meet with clients outside of the Emergency Shelter/Navigation Center without permission from program staff, and will be not allowed to drive clients in their vehicles. f. Commitment
The Emergency Shelter/Navigation Center will be reliant upon the work of volunteers. This commitment should be taken seriously. If a volunteer misses a shift without removing themselves from the schedule and giving notice, the volunteer may be limited or restricted from volunteering.
54 3. Identifiable Lines of Authority
Volunteers will be informed of identifiable lines of authority in their Application Packet.
Volunteers will defer to the Volunteer Coordinator on duty to give resources, referrals, andhandle situations beyond their responsibility and volunteer agreement.
Volunteers will also have access to the Program Manager or lead staff member on site, for questions and grievances.
All volunteers will be provided a name tag identifying them as such.
4. Descriptions of Volunteer Tasks
Volunteers will be needed 7 days per week to help both in the evening up to volunteers(5-8pm), morning hours up to volunteers (5-10am) and mid-day hours up to volunteers (11-4pm).
The Emergency Shelter/Navigation Center Volunteer/Service Provider Coordinator will ensure all volunteers will be provided tasks and descriptions of any dutiesthey might perform. Tasks and duties include, but will be not limited to:
Assisting the Intake Specialist in registering and signing in clients at time of entry Setting up and breaking down tables for dinners and breakfasts Distributing donations and hygiene items
Organizing and setting up donations of clothing
Helping direct lines to donations and food
Serving meals,setting up snacks and drinks for clients
Organizing recreational activities for clients
55 SECTION V. ATTACHMENTS
A. Shelter Client Rules
B. Volunteer Policies
56 ATTACHMENT A
SHELTER CLIENT RULES
57 EMERGENCY SHELTER
Client RULES
Welcome to the emergency shelter program. The Shelter Staff and Volunteers are working very hard to make your stay safe and comfortable. As a client of the program, you must agree in writing to follow these rules at all times:
1. Sign-in at the Shelter begins at and ends at . Clients will NOT be allowed entry into the Sleeping Area before . Clients will NOT be allowed entry into the Sleeping Area after .
Clients may not leave the Sleeping Area after signing in for any reason. If you leave, you will forfeit your bed. No exceptions. (This policy includes but is not limited to going outside to retrieve personal belongings, cigarettes, etc.)
2. No Walk-In/Walk-Out Policy Compliance is required for all clients who must take the transportation shuttle to and from the Shelter each day. The only exception to this rule is for clients who have received approval to drive and park their vehicle at the shelter facility.
3. Alcohol and drugs are NOT permitted in or around the Shelter Property and they will be confiscated if found. At the discretion of the Site Leader or Management, you may be excluded from the program for that night, or possibly terminated.
4. No weapons or objects that may be perceived as weapons are permitted. If found, they will be tagged by security and kept until you leave. Anyone with a concealed weapon will be immediately exited from the program.
5. We reserve the right to search all applicants for weapons (or items that could be used as weapons), alcohol, and illegal drugs.
6. All prescription medication must be checked in with security personnel upon entering the shelter building in its original container.
7. Photo ID’s are required of all registered clients. Shelter Staff will take photos and thumbprintsto produce program ID’s for clients, and for security reasons, if necessary. By entering this program, you give your consent to this.
8. All Clients must complete intake and check in as well as complete all appropriate paperwork with Shelter Staff.
9. Showers are strongly recommended for all shelter clients. Showers may be required if lack of personal hygiene becomes a risk to the health & safety of the other shelter guests and staff.
58 10. No smoking inside the shelter. There is a designated smoking area outside the shelter. Smoking is only permitted in the designated area while staff or security is present.
11. Lights go out at or around 10:00 PM. Clients must remain at their beds after lights out.
12. The early wakeup call is at . Coffee and breakfast is provided to clients between and AM. Clients are expected to be out of bed by am unlessspecial arrangements have been made due to overnight work or illness. No one is allowed in the Sleeping Area from AM to PM.
13. In public areas, shirts, pants are mandatory for men and women at all times; socks and shoes are strongly encouraged.
14. The evening meal is served from PM to PM. Please clean up around your area after you eat, and wear shoes when in the meal line. Should you have a spill, please notify staff immediately.
15. A Cell Phone charging Station will be available for clientsto use during designated hours. Clients are NOT allowed to use ANY unauthorized electrical outlets for any reason.
16. Any undesignated parking either on or off the property is subject to tow at the owner’sexpense.
17. Large storage lockers will be available for each shelter guest. Shopping carts will not be allowed in the shelter.
18. No clients under 18 years of age will be admitted into the shelter.
19. There is a women’s section and a men’s section for sleeping. Women are not allowed in the men’s section, and men are not allowed in women’s section.
20. Only the Site Leader or Manager on duty can expel / prevent any clients from staying at the shelter. Any conflicts between clients should be brought to the attention of the staff immediately. If you are asked to leave and you do not, it is a trespass on City of Corona property.
21. Clients can only reserve beds for themselves. Do not place any of your items on another bed to reserve a space.
22. Donations will be handed out in an orderly fashion by the staff & volunteers. Clients will not interfere with donations being brought in or the distribution of donations.
59 23. The Shelter Program operates as clients of the City of Corona. As a result, all clients are expected to be Good Neighbors and have an obligation to comply with all state and local laws and/or ordinances and shelter rules and behave in a courteous manner at all times. Complaints from residents, business owners, or public officials may result in warnings to the clients and expulsion from the Shelter program.
24. Any threats or acts of violence such as loud and disruptive behaviors, threats, fighting, etc. towards staff, volunteers, security, or other clients will result in immediate expulsion.
25. Neither Shelter, nor any of its vendor/partners are in any way responsible or liable for lost, stolen, or damaged items that clients bring onto premises. IT IS THE CLIENTS’ RESPONSIBILITY TO TAKE ALL
PERSONAL BELONGINGS WITH THEM UPON EXITING THE PROGRAM, AND TO CLAIM THEIR ITEMS FROM THE SECURITY CHECK-IN WHEN THEY LEAVE THE PROPERTY. ANY ITEMS LEFT BEHIND MAY BE DISCARDED.
26. Pet Crates are available for client use on a first come, first served basis, dog run space permitting. All Animals will be permitted ONLY with appropriate documentation (including up-to-date rabies vaccination and dog license from the City of Corona) and approval by site-leader or management. Any animal may be asked to leave at any time due to aggressive or disruptive behavior, or if owner does not properly cleanup after the animal.
27. Cash is never to be given to Staff, Volunteers, or Interns at ANY time.
As a result of signing thisform, I have read and do understand that neither Shelter, any of its volunteers,service providers, Security, or any of the vendors providing services for the Emergency Shelter/Navigation Center will be responsible for any loss, theft, or damage to personal property including, but not limited to, Bicycles, Carts, Luggage, Cell Phones, and other itemsthat are brought onto the program property. I understand that program rules may change as necessary and that I am required to abide by any amended rules and protocols as they are created.
I have read the above and agree to follow the Shelter rules.
Name (please print):
Signature: Date:
60 ATTACHMENT B
VOLUNTEER POLICIES
61 Emergency Shelter/Navigation Center Volunteer Policies
1. Each volunteer must maintain a firm commitment to professional conduct Volunteers of the Emergency Shelter/Navigation Center are expected to maintain the highest level of moral, ethical, and professional conduct while at the site. Volunteers will not engage in verbal abuse, inappropriate jokes, and stories, and or any type of inappropriate interaction with Emergency Shelter/Navigation Center staff or clients.
2. Relationships with Clients
Volunteers are prohibited from developing dual relationships with any clients they meet through their volunteer involvement at the Emergency Shelter/Navigation Centre. Examples of dual relationships include (but are not limited to) a volunteer entering into a business, romantic, or sexual relationship with a client. Soliciting clientsfor your business is strictly prohibited. Volunteers are not allowed to be named as having authority to make decisions for a client under any type of power of attorney or other legal procedure.
3. Food and Other Substances
Volunteers will not consume any food items or drinks supplied by the Emergency Shelter/Navigation Center while volunteering. Food and drinks are purchased solely for the consumption of the homeless clients. Volunteers must also commit to not consuming any type of illicit drugs on the property while volunteering. Volunteers who appear to be under the influence of any substance that impedes their ability to perform their duties safely and efficiently may be turned away.
4. Discrimination
Volunteers will not discriminate against any client. They will not judge an individual based on their race, disability, religious preference, sexual orientation, color, age, veteran status, citizenship, ancestry, national origin, or gender.
5. Volunteer Boundaries
Volunteers are not permitted to loan or give money to clients and should not meet with clients outside of the Emergency Shelter/Navigation Center without permission from program staff.
6. Commitment
The Emergency Shelter/Navigation Center is reliant upon the work of volunteers. This commitment should be taken seriously. If a volunteer misses a shift without removing themselves from the schedule and giving notice, the volunteer may be limited or restricted from volunteering in the future.
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GRANT AGREEMENT FOR THE USE OF
AMERICAN RESCUE PLAN ACT (ARPA) FUNDS
This GRANT AGREEMENT FOR THE USE OF AMERICAN RESCUE PLAN ACT FUNDS (“Agreement”) by and between the COUNTY OF RIVERSIDE, a political subdivision of the State of California (“COUNTY”) and CITY OF CORONA, a general law city (“GRANTEE”). The COUNTY and GRANTEE may be individually referred to herein as a “Party” and collectively as the “Parties”. This Agreement, for the use of U.S. Department of the Treasury (“U.S. Treasury”) Coronavirus State and Local Fiscal Recovery Funds (“SLFRF”) under the American Rescue Plan Act of 2021 (Pub. L. 117-2), amending Title VI of the Social Security Act (42 U.S.C. 801 et seq.), hereinafter “ARPA” or the “Act”, is made and entered into as of the Effective Date (defined herein).
RECITALS
WHEREAS, on March 11, 2021, to address the negative economic impacts of the COVID19 pandemic, President Joseph R. Biden signed into law the Act, and on January 6, 2022, the U.S. Treasury adopted a Final Rule implementing the “SLFRF”; and WHEREAS, state, territorial, local and tribal governments must comply with the Final Rule by April 1, 2022 when the Final Rule takes effect; and WHEREAS, the Act, the regulations promulgated in 31 CFR Part 35, and the Final Rule (collectively, the “ARPA Rules”) provide that SLFRF may be used to cover costs that are necessary expenditures incurred due to the public health emergency of the COVID-19 pandemic; and
WHEREAS, on October 19, 2021, via Minute Order 3.5, the Board of Supervisors of the County of Riverside approved allocating $50,000,000 in ARPA funds to increase shelter capacity, permanent supportive housing units and affordable housing to help address homelessness; and
WHEREAS, on October 4, 2022 (Minute Order 3.44), the Board approved the second installment allocation of APRA funds to focus on projects and/or programs that serve as a
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pathway to create affordable housing with necessary supporting infrastructure to assist lowincome communities disproportionately affected by the COVID-19 pandemic; and WHEREAS, GRANTEE is proposing to utilize SLFRF funds to pay a portion of the costs to reimburse the City of Corona for the renovation work completed at the Harrison HOPE Center (“Project”). The City of Corona invested $3 million in Phase I and Phase II renovations. The renovations were recently completed in May 2023 with the Center opening in June 2023. The County will reimburse the City of Corona for $1 million of the $3 million costs for the renovation of the Harrison Hope Center. The $1 million grant will be used to fund the operation of the Harrison Hope Center System of Services. The scope of the project resulted in the replacement and/or addition of new roof shingles and sheathing, addition of new facility components including but not limited to an onsite clinic in the west wing of the building, a dog run shelter, security system enhancements, mandated Americans with Disabilities ACT (ADA) improvements in bathrooms, showers, kitchen and other places in the facility and replacement of all 4 exterior ADA access ramps, interior and exterior paint, new floor coverings, fencing, landscaping, storage lockers, parking lot slurry seal, interior murals, new appliances for the kitchen and laundry room, new countertops in the bathrooms, new HVAC systems, commercial generator installation, enhanced fire safety and protection system and other renovations that transformed the functionality and life of the facility. The newly renovated Harrison HOPE Center is a 40-bed low-barrier emergency shelter/navigation center that has an onsite Federally Qualified Health Center (FQHC) clinic providing medical, behavioral health, and oral care services as well as a success center for computer learning, job development and other services, plus many other amenities including accommodations for pets, client storage, and a full-service kitchen for meals. The City of Corona developed the Harrison HOPE Center as part of an overall Homeless System of Services that includes: Permanent supportive housing, tenant based rental assistance, post hospital recuperative care, and a transportation/meal program that provides day services to non-shelter guests, all which make up this comprehensive system of services. The Project is located at 420 West Harrison Street, Corona CA, more specifically known as Assessor’s Parcel Number 119-290-049
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(“Property”), and as more specifically described in the legal description attached hereto and incorporated herein as Exhibit A; and
WHEREAS, the purpose of this Agreement is for COUNTY to provide financial assistance to GRANTEE in the maximum amount of One Million Dollars ($1,000,000) consisting of SLFRF funds, to reimburse a portion of the City of Corona Harrison HOPE Center renovation costs that were completed on the Property, as more fully described herein; and consisting of SLFRF funds, to fund the City of Corona Harrison HOPE Center renovation costs to the Property, as more fully described herein.
WHEREAS, the 2023 Budget Act, Section 19.561 (a) (5) states that designated state entity administering an allocation may provide the allocation as an advance lump sum payment, and the allocation may be used to pay for costs incurred prior to the effective date of 2023 Budget Act; WHEREAS, pursuant to 31 CFR Part 35.6, one of the Eligible Uses (as defined under ARPA Rules) of the SLFRF funds is to respond to the public health emergency or its negative economic impacts for the purpose of assisting low-income households and individuals disproportionately impacted by the COVID-19 pandemic through the development, repair and operation of affordable housing and services or programs to increase long-term housing security; WHEREAS, the ARPA-assisted activities described herein comply with the Eligible Uses under ARPA Rules in that they are necessary to assist populations experiencing food and housing insecurity as a result of impacts due do to the COVID-19 public health emergency.
NOW, THEREFORE, based upon the foregoing Recitals and for good and valuable consideration, the receipt and sufficiency of which is acknowledged by all Parties, the COUNTY and GRANTEE hereby agree as follows:
1. PURPOSE. The aforementioned Recitals are true and correct and incorporated herein by this reference. COUNTY has agreed provide a grant in the maximum total of One Million Dollars ($1,000,000) in ARPA funds (“ARPA Grant”) to GRANTEE upon the satisfaction of the terms and conditions set forth herein, including but not limited to the conditions precedent to distribution of the ARPA Grant set forth in Section 11 below. Subject
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also to Sections 48 below, GRANTEE shall undertake and complete the ARPA activities required herein and as set forth in Exhibits A, B and C, and shall utilize the ARPA Grant, as required herein and pursuant to the ARPA Rules. GRANTEE shall serve people that are experiencing homelessness or are chronically homeless as defined in Title 24 CFR Part 578.3 (“Qualified Population(s)”).
2. GRANTEE’S OBLIGATIONS. Upon the commencement of the Effective Date (defined in Section 55 below), GRANTEE hereby agrees to undertake and complete the following activities within the time period(s) set forth herein and in Exhibit B:
a. Satisfy the conditions precedent to distribution of the ARPA Grant set forth in Section 11 below.
b. Fund the Project in accordance with the timeline set forth in Exhibit B and C. c. Operate the Project in such a manner so that it will remain available to the Qualified Population for the Affordability Period as defined in Section 14 below.
d. Maintain the Project in compliance with applicable local, state, federal laws, codes and regulations, including but not limited to the ARPA rules, as further described in Section 17 below until the expiration of the Term of this Agreement set forth in Section 6 below, and the Affordability Period set forth in Section 14 below.
e. The ARPA Grant funds shall be used for only Eligible Uses under the ARPA Rules and GRANTEE shall expend the ARPA Grant funds by December 31, 2026. GRANTEE shall demonstrate to the COUNTY, in the COUNTY’s sole and absolute discretion, that the ARPA Grant funds are deemed fully expended in compliance with the ARPA Rules.
3. RESERVED.
4. ARPA GRANT. Subject to GRANTEE’s satisfaction of the conditions precedent to disbursement of the ARPA Grant set forth in Section 11 below, COUNTY shall distribute the
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ARPA Grant to GRANTEE.
5. PRIOR COUNTY APPROVAL.
a. Except as otherwise expressly provided in this Agreement, approvals required of the COUNTY shall be deemed granted by the written approval of the Director of Housing and Workforce Solutions (“HWS”), or designee.
Notwithstanding the foregoing, the Director may, in their sole discretion, refer to the governing body of the COUNTY any item requiring COUNTY approval; otherwise, “COUNTY approval” means and refers to approval by the Director of HWS, or designee.
b. The Director of HWS, or designee, shall have the right to make changes to the attachments to this Agreement in order to ensure that all such attachments are consistent with the terms and provisions of this Agreement.
6. TERM OF AGREEMENT. This Agreement shall become effective upon the Effective Date, as defined in Section 55 below, and unless terminated earlier pursuant to the terms hereof, shall continue in full force and effect until the later to occur of (i) December 1, 2038 or (ii) fifteen (15) years from April 9, 2024, which is the date of the recordation of the notice of completion for Phase II of the construction work on the Project in the Official Records (“Term of Agreement”).
7. GRANTEE’S REPRESENTATIONS. GRANTEE represents and warrants to COUNTY as follows:
a. Authority. GRANTEE has full right, power, and lawful authority to enter into this Agreement and accept the ARPA Grant and undertake all obligations as provided herein. The execution, performance, and delivery of this Agreement by GRANTEE have been fully authorized by all requisite actions on the part of GRANTEE.
b. No Conflict. To the best of GRANTEE’s knowledge, GRANTEE’s execution, delivery and performance of its obligations under this Agreement will not
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constitute a default or a breach under contract, agreement or order to which GRANTEE is a party or by which it is bound.
c. No Bankruptcy. GRANTEE is not the subject of a bankruptcy proceeding. d. Prior to Effective Date. GRANTEE shall, during the term of this agreement, upon learning of any fact or condition which would cause any of the warranties and representations in this Section 7 not to be true as of the Effective Date of this Agreement, immediately give written notice of such fact or condition to COUNTY. Such exception(s) to a representation shall not be deemed a breach by GRANTEE hereunder but shall constitute an exception which COUNTY shall have the right to approve or disapprove if such exception would have an effect on the value and/or operation of the Project.
e. Prior to Closing. GRANTEE shall, upon learning of any fact or condition which would cause any of the warranties and representations in this Section 7 not to be true as of close of escrow, immediately give written notice of such fact or condition to COUNTY. Such exception(s) to a representation shall not be deemed a breach by GRANTEE hereunder but shall constitute an exception which COUNTY shall have the right to approve or disapprove if such exception would have an effect on the value and/or operation of the Project.
8. COMPLETION SCHEDULE. GRANTEE shall proceed consistent with the Schedule of Performance set forth in Exhibit B, as such schedule may be amended, in COUNTY’s sole and absolute discretion, pursuant to Section 10, and subject to Force Majeure Delays as defined in Section 9.
9. FORCE MAJEURE DELAYS. “Force Majeure” means event(s) beyond the reasonable control of GRANTEE, and which could not have been reasonably anticipated, which prevent(s) GRANTEE from complying with any of its obligations under this Agreement, including, but not limited to: acts of God, acts of war, acts or threats of terrorism, civil disorders, strikes, labor disputes, flood, fire, explosion, earthquake or other similar acts.
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“Force Majeure Delay” is delay due to Force Majeure that, in each case, (i) materially adversely affects the performance by GRANTEE of its obligations hereunder, (ii) is not reasonably foreseeable and is beyond GRANTEE's reasonable control, (iii) despite the exercise of reasonable diligence, cannot be prevented, avoided or removed by GRANTEE and is not attributable to the negligence, willful misconduct or bad faith of GRANTEE, and (iv) is not the result of the failure of GRANTEE to perform any of its obligations under this Agreement.
Notwithstanding the foregoing, a Force Majeure Delay shall not be deemed to have occurred unless GRANTEE has notified COUNTY in writing of such occurrence within fifteen (15) days after such occurrence, and has provided COUNTY with the details of such event and the length of the anticipated delay within an additional fifteen (15) days thereafter. GRANTEE shall diligently attempt to remove, resolve, or otherwise eliminate such event, keep COUNTY advised with respect thereto, and shall commence performance of its obligations hereunder immediately upon such removal, resolution or elimination. During the occurrence and continuance of a Force Majeure Delay, GRANTEE shall be excused from performance of its obligations under this Agreement to the extent the Force Majeure prevents GRANTEE from performing such obligations.
10. EXTENSION OF TIME. Subject to Section 2(e) above, COUNTY may, in its sole and absolute discretion and subject to ARPA Rules, grant an extension to the Implementation Schedule set forth in Exhibit B for the purpose of completing GRANTEE's activities which cannot be completed as outlined in Exhibit B. GRANTEE shall request said extension in writing, stating the reasons therefore, which extension must be first approved in writing by the COUNTY in its sole and absolute discretion. The Director of HWS, or designee, may extend all pending deadlines in the Implementation Schedule on two (2) or fewer occasions, so long as the aggregate duration of such administrative time extensions is no greater than three hundred sixty five (365) days and complies with all ARPA Rules. Every term, condition, covenant, and requirement of this Agreement shall continue in full force and effect during the period of any such extension.
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11. CONDITIONS PRECEDENT TO DISTRIBUTION OF ARPA GRANT FUNDS.
COUNTY, through its Department of HWS, shall disburse the ARPA Grant funds directly to GRANTEE, subject to the conditions precedent set forth below. COUNTY shall not disburse any ARPA Grant funds pursuant to this Agreement until the following conditions precedent have been satisfied:
a. GRANTEE executes this Agreement and delivers to COUNTY; b. GRANTEE provides COUNTY with evidence of insurance as required herein; c. GRANTEE provides evidence it has obtain the necessary building permits to develop improvements to the property that are being proposed as outlined in Exhibit B;
d. GRANTEE executes the Covenant Agreement, substantially conforming in form and substance to the Covenant Agreement attached hereto and incorporated herein as Exhibit J, and delivers to the County of Riverside; e. RESERVED;
f. RESERVED;
g. GRANTEE is not in default under the terms of this Agreement or any other agreement related to the financing of the Project;
h. If Davis Bacon and/or prevailing wages are required to be paid, GRANTEE shall demonstrate that it hired a qualified professional firm to review and monitor Davis Bacon and/or prevailing wage compliance for all submissions of contractors certified payrolls to COUNTY. In the event that the Project required prevailing wages, GRANTEE shall demonstrate that it complied with, and required its contractors and subcontractors performing work on the Project, to pay prevailing wages, use a skilled and trained workforce, and adhere to any applicable labor regulations and all State laws in connection with the construction of the Project, including but not limited to Article 1 (commencing with Section 1720) of Part 7 of Division 2 of the Labor Code,
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and Chapter 2.9 (commencing with Section 2600) of Part 1 of Division 2 of the Public Contract Code. GRANTEE agrees and acknowledges that it is the responsibility of GRANTEE to obtain a legal determination, at GRANTEE’s sole cost and expense, as to whether prevailing wages must be paid during the construction of the Project. If the Project was subject to prevailing wages, then GRANTEE shall be solely responsible to pay its contractors and subcontractors the required prevailing wage rates. GRANTEE agrees to indemnify, defend, and hold COUNTY harmless from and against any and all liability arising out of and related to GRANTEE’s failure to comply with any and all applicable Davis Bacon and/or prevailing wage requirements; i. GRANTEE represents that GRANTEE, and its principals, or any/all persons, contractors, consultants, businesses, etc. are conducting business with, are not presently debarred, proposed for debarment, suspended, declared ineligible, or voluntarily excluded from participation or from receiving federal contracts or federally approved subcontracts or from certain types of federal financial and nonfinancial assistance and benefits with the Excluded Parties Listing System (“EPLS”). EPLS records are located at www.sam.gov; and
j. GRANTEE shall provide documentation demonstrating that a competitive bid process was used to select the qualified contractors that completed Phase I and Phase II construction work on the Project.
GRANTEE agrees to submit the following documentation to COUNTY, 180 days from execution of this Agreement:
The fully executed Professional Services and Funding Agreement between the City and Mercy House Living Centers, which outlines the Harrison Hope Center service plan, the Harrison Hope Center Shelter operations plan and the funding sources that were used to complete Phase I and Phase II construction work for the Project.
12. REALLOCATION OF FUNDS. If GRANTEE fails to accept the funds by
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December 31, 2024, then GRANTEE will not be eligible for reimbursement for construction renovation work already completed on the Project, unless a written extension is granted by County pursuant to section 13. If GRANTEE fails to meet the acceptance deadline, the COUNTY will reallocate the ARPA Grant Funds. Upon such reallocation of ARPA Grant funds, this Agreement shall be terminated and be of no further force and effect and GRANTEE shall be released and discharged from any obligations hereunder, except as to those obligations which by their terms survive termination of this Agreement.
13. DISTRIBUTION OF FUNDS. COUNTY'S Board of Supervisors shall determine the final disbursement and distribution of all ARPA Grant funds received by COUNTY under ARPA. Disbursement of ARPA Grant shall occur upon the satisfaction of conditions set forth in Section 11. COUNTY shall pay GRANTEE in the form of funding draw requests with supporting documents which specifically state how such ARPA Grant funds will be expended.
COUNTY shall promptly review the funding draw request and supporting documentation, but in no event later than thirty (30) days. COUNTY may require additional information from GRANTEE as may be necessary and appropriate for COUNTY to make its determination as to allowable costs. COUNTY shall deposit the sum specified in the funding draw requests into GRANTEE’S bank account upon receipt of wire instructions.
14. TERMS OF AFFORDABILITY. The City of Corona Harrison HOPE Centershall remain occupied and available to Qualified Populations, pursuant to Section 18 below, Exhibit A, and the Covenant Agreement attached hereto as Exhibit J, until the later of (i) fifteen (15) years from the recordation of the Notice of Completion in the Official Records for which when construction was completed for the Project, or (ii) December 1, 2038 (“Affordability Period”).
15. INSURANCE. Without limiting or diminishing GRANTEE’S obligation to indemnify or hold COUNTY harmless, GRANTEE represents and acknowledges that it required the general contractor for the Project (“General Contractor”) to procure and maintain, at its sole cost and expense, the following insurance coverages during the course of renovation work that was completed on the Project.
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a. Builder’s All Risk (Course of Construction) Insurance. GRANTEE required General Contractor to provide a policy of Builder’s All Risk (Course of Construction) insurance. Such policy was written on an all risk basis and a completed value form. Such policy covered the full insurable value. Such policy also provided coverage for temporary structures (on-site offices, etc.), fixtures, machinery and equipment being installed as part of the work. Upon request by COUNTY, GRANTEE shall declare all terms, conditions, coverages and limits of such policy.
b. Workers’ Compensation Insurance. GRANTEE required to maintain statutory Workers' Compensation Insurance (Coverage A) as prescribed by the laws of the State of California. Policy shall include Employers’ Liability (Coverage B) including Occupational Disease with limits not less than $1,000,000 per person per accident.
c. Commercial General Liability Insurance. GRANTEE required General Contractor to maintain Commercial General Liability insurance coverage, including but not limited to, premises liability, unmodified contractual liability, products and completed operations liability, personal and advertising injury, and cross liability coverage, covering claims which may arise from or out of CONTRACTOR’S performance of its obligations hereunder. Policy’s limit of liability were not be less than $2,000,000 per occurrence combined single limit. If such insurance contained a general aggregate limit, it applied separately or was no less than two (2) times the occurrence limit. d. Vehicle Liability Insurance. GRANTEE required General Contractor to maintain liability insurance for all owned, non-owned or hired vehicles so used in an amount not less than $1,000,000 per occurrence combined single limit.
If such insurance contains a general aggregate limit, it applied separately or was no less than two (2) times the occurrence limit.
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e. General Insurance Provisions – All Lines.
(i) GRANTEE’S General Contractor used an insurance carrier with an A M BEST rating of not less than A: VII (A:7).
(ii) Project work is already completed; therefore, GRANTEE, or GRANTEE on behalf of General Contractor, does not need to declare its insurance self-insured retentions.
(iii)GRANTEE shall furnish the County of Riverside with copies of the Certificate(s) of Insurance and Endorsements confirming coverage was in effect during construction thus effecting coverage as required herein. (iv)It is understood and agreed to by the parties hereto that GRANTEE’s insurance shall be construed as primary insurance, and COUNTY's insurance and/or deductibles and/or self-insured retentions or selfinsured programs shall not be construed as contributory. (v) GRANTEE agrees to notify COUNTY of any claim by a third party or any incident or event that may give rise to a claim arising from the performance of this Agreement.
16. FINANCIAL AND PROJECT RECORDS. GRANTEE shall maintain financial, programmatic, statistical, and other supporting records of its operations and financial activities sufficient to establish compliance with subsection 601(d) of the Social Security Act, as amended, (42 U.S.C. 801(d)), in accordance with the requirements of the ARPA Rules, which records shall be open to inspection and audit by authorized representatives of COUNTY, the California Department of Finance, and the United States Department of the Treasury Office of Inspector General, during regular working hours. COUNTY, state, and federal representatives have the right of access, with at least forty-eight (48) hours prior notice, to any pertinent books, documents, papers, or other records of GRANTEE, in order to make audits, examinations, excerpts, and transcripts. Said records shall be retained for such time as may be required by the ARPA Rules, but in no event no less than five (5) years after the Project completion date as evidenced by
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recordation of the Notice of Completion, or after final payment is made, whichever is later, to support reported expenditures and to participate in COUNTY, state, and federal audits; except that records of individual income verifications, project rents, and project inspections must be retained for the most recent five (5) year period, until five (5) years after the Affordability Period terminates. If any litigation, claim, negotiation, audit, or other action has been started before the expiration of the regular period specified, the records must be retained until completion of the action and resolution of all issues which arise from it, or until the end of the regular period, whichever is later.
17. COMPLIANCE WITH LAWS AND REGULATIONS. By executing this Agreement, GRANTEE hereby certifies that it will adhere to and comply with all federal, state and local laws, regulations and ordinances. In particular, GRANTEE shall comply with the ARPA Rules and the following as they may be applicable to GRANTEE in connection with the ARPA Grant:
a. Compliance with Executive Order 11246 of September 24, 1965, entitled "Equal Employment Opportunity", as amended by Executive Order 11375 of October 13, 1967, and as supplemented in Department of Labor Regulations (41 CFR Part 60).The GRANTEE will not discriminate against any employee or applicant for employment because of race, color, religion, sex, or national origin. GRANTEE shall ensure that all qualified applicants will receive consideration for employment without regard to race, color, religion, sex or national origin. The GRANTEE will take affirmative action to ensure that applicants are employed and the employees are treated during employment, without regard to their race color, religion, sex, or national origin. Such actions shall include, but are not limited to, the following: employment, up-grading, demotion, or transfer; recruitment or recruitment advertising; rates of pay or other forms of compensation; and selection for training, including apprenticeship. The GRANTEE agrees to post in a conspicuous place, available
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to employees and applicants for employment, notices to be provided by the County setting forth the provisions of this non-discrimination clause; b. Executive Order 11063, as amended by Executive Order 12259, and implementing regulations at 24 CFR Part 107;
c. Section 504 of the Rehabilitation Act of 1973 (Pub. L. 93-112), as amended, and implementing regulations;
d. The Age Discrimination Act of 1975 (Pub. L.94-135), as amended, and implementing regulations;
e. The regulations, policies, guidelines and requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards(2 CFR Part 200) as they relate to the acceptance and use of federal funds under the federally-assigned program;
f. Title VI of the Civil Rights Act of 1964 (Pub. L. 88-352) and implementing regulations issued at 24 CFR Part 1;
g. Title VIII of the Civil Rights Act of 1968 (Pub. L. 90-284) as amended; h. Rights to Data and Copyrights: Contractors and consultants of GRANTEE providing services or work under this Agreement agree to comply with all applicable provisions pertaining to the use of data and copyrights pursuant to 48 CFR Part 27.404-3, Federal Acquisition Regulations (FAR). i. Air Pollution Prevention and Control (formally known as the Clean Air Act) (42 U.S.C. 7401 et seq.) and the Federal Water Pollution Control Act (33 U.S.C. Section 1251 et seq.), as amended: Contracts and subgrants of amounts in excess of $100,000 shall contain a provision that requires the recipient to agree to comply with all applicable standards, orders or regulations issued pursuant to the Clean Air Act (42 U.S.C. 7401 et seq.) and the Federal Water Pollution Control Act as amended (33 U.S.C. Section 1251 et seq.). Violations
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shall be reported to the Federal awarding agency and the Regional Office of the Environmental Protection Agency (EPA).
j. Anti-Lobbying Certification (31 U.S.C. 1352): The language of the certification set forth below shall be required in all contracts or subcontracts entered into in connection with this grant activity and all GRANTEES shall certify and disclose accordingly. This certification is a material representation of fact upon which reliance was placed when this transaction was made or entered into.
Submission of this certification is a prerequisite for making or entering into this transaction imposed by. Section 1352, Title 31, U.S. Code. Any person who fails to file the required certification shall be subject to a civil penalty of not less than $10,000 and no more than $100,000 for such failure. “The undersigned certifies, to the best of his or her knowledge or belief, that:
No Federal appropriated funds have been paid or will be paid, by or on behalf of it, to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement;
If any funds other than Federal appropriated funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with this Federal contract, grant loan or cooperative agreement, he/she will complete and submit Standard Form – LLL, “Disclosure Form to Report Lobbying,” in accordance with its instructions.”
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k. Debarment and Suspension (Executive Orders (E.O.) 12549 and 12689): No contract award shall be made to parties listed on the government wide exclusions in the System for Award Management (SAM), in accordance with OMB guidelines at 2 CFR 180 that implement Executive Orders (E.O.s) 12549 and 12689, “Debarment and Suspension.” SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than E.O. 12549. Contractors with awards that exceed the small purchase threshold shall provide the required certification regarding its exclusion status and that of its principal employees.
l. Drug-Free Workplace Requirements: The Anti-Drug Abuse Act of 1988 (Pub.
L. 100-690) requires grantees (including individuals) of federal agencies, as a prior condition of being awarded a grant, to certify that they will provide drugfree workplaces. Each potential recipient must certify that it will comply with drug-free workplace requirements.
m. Access to Records and Records Retention: The GRANTEE, and/or any subconsultants or sub-contractors, shall allow all duly authorized Federal, State, and/or County officials or authorized representatives access to the work area, as well as all books, documents, materials, papers, and records of the GRANTEE, and any sub-consultants or sub-contractors, that are directly pertinent to a specific program for the purpose of making audits, examinations, excerpts, and transcriptions. The GRANTEE or any sub-consultants or subcontractors, further agree to maintain and keep such books, documents, materials, papers, and records, on a current basis, recording all transactions pertaining to this Agreement in a form in accordance with generally acceptable accounting principles. All such books and records shall be retained for such periods of time as required by law, provided, however, notwithstanding any
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shorter periods of retention, all books, records, and supporting detail shall be retained for a period of at least five (5) years after the expiration of the term of this Agreement, or final payment is made, whichever is later. n. Federal Employee Benefit Clause: No member of or delegate to the Congress of the United States, and no Resident Commissioner shall be admitted to any share or part of this Agreement or to any benefit to arise from the same. o. Energy Efficiency: Mandatory standards and policies relating to energy efficiency which are contained in the State energy conservation plan issued in compliance with the Energy Policy and Conservation Act (Pub. L. 94 - 163, Dec. 22, 1975; 42 U.S.C. Section 6201, et. seq., 89 Stat.871). p. Procurement of Recovered Materials (2 CFR 200.322.): A non-Federal entity that is a state agency or agency of a political subdivision of a state and its contractors must comply with 42 U.S.C. 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 preceding 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. The requirements of 2 CFR 200.322, as amended effective November 12, 2020, are hereby included in this Agreement as appropriate and to the extent consistent with law.
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q. Contract Work Hours and Safety Standards Act (CWHSA) (30 U.S.C. 3701- 3708): GRANTEE shall comply with all applicable provisions of the CWHSA. r. Displacement, relocation, and acquisition. The relocation requirements of Title II and the acquisition requirements of Title III of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, and the implementing regulations at 24 CFR Part 42. GRANTEE must ensure that it has taken all reasonable steps to minimize the displacement of persons as a result of this Project.
s. Lead-based paint. The ARPA-Assisted Units, as defined in the Covenant Agreement, are subject to the lead-based paint requirements of 24 CFR Part 35 issued pursuant to the Lead-Based Paint Poisoning Prevention Act (42 U.S.C. 4821, et seq.). The lead-based paint provisions of 24 CFR 982.401 (j), except 24 CFR 982.401 (j)(1)(i), also apply, irrespective of the applicable property standard under §92.251.
t. Labor. GRANTEE represents that it complied with any applicable labor regulations and all other State and Federal laws in connection with the construction of the improvements which comprise the Project, including if applicable, requirements relating to Davis Bacon. GRANTEE agrees and acknowledges that it is the responsivity of GRANTEE to obtain a legal determination, at GRANTEES sole cost and expenses as to whether Davis Bacon wages must be paid for during the construction of the Project.
GRANTEE agrees to indemnify, defend, and hold COUNTY harmless from and against any and all liability arising out of a related to GRANTEE’s failure to comply with any and applicable prevailing wage requirements. u. Model Energy Code published by the Council of American Building Officials.