Glendale Rental Assistance
Stabilization Program
(GRASP)
Policies & Procedures Manual
Effective Date: XX/XX/XX
Funding/Compliance: Developed to align with LACAHSA RPHP terms and applicable federal, state, and local laws. If a conflict exists, funder terms and law control.
Table of Contents
1. Purpose, Authority, and Program Governance.............................................................3
2. Definitions.....................................................................................................................4
3. Civil Rights, Equal Access, ADA/Section 504 & Language Assistance........................5
3.1 Reasonable Accommodation (RA)..........................................................................5
3.2 Language Assistance (LEP) ...................................................................................6
3.3 Complaints & Appeals.............................................................................................6
4. Application Process & Intake Model .............................................................................6
4.1 Pre-Opening Outreach (Prep Phase)......................................................................7
4.2 Serving the initial pool.............................................................................................7
4.3 Serving the initial pool.............................................................................................8
4.4 Applicant experience...............................................................................................8
4.5 Supplemental intake (referrals and walk-ins)..........................................................9
4.6 Future Openings .....................................................................................................9
5. Eligibility Policy ...........................................................................................................10
5.1 Baseline Criteria - Must meet all criteria ...............................................................10
5.2 Qualifying Risk/Hardship - At least one must be true ...........................................11
5.3 Non-Duplication of Benefits...................................................................................12
5.4 Liquid-Asset Screen..............................................................................................12
6. Prioritization Policy: Grouping Step + Points ..............................................................12
6.1 Grouping Step.......................................................................................................12
6.2 Points ....................................................................................................................13
6.3 Points rubric ..........................................................................................................13
6.4 Worked Scoring Examples....................................................................................13
6.5 Lottery & Tie-Break Protocols ...............................................................................14
7. Verification & Documentation Standards....................................................................14
7.1 Hierarchy of evidence (use the highest available). ...............................................14
7.2 Minimum eligibility that must be verified for every case........................................15
7.3 Two-source standard. ...........................................................................................15
7.4 Director authority...................................................................................................15
8. Benefit Determination .................................................................................................15
8.1 Foundational rules (apply to all arms)...................................................................16
8.2 Emergency Assistance..........................................................................................16
8.3 Income-Support Assistance ..................................................................................17
8.4 Special Assistance................................................................................................18
9. Case Management Standards....................................................................................19
9.1 Policy.....................................................................................................................19
9.2 Minimum workflow.................................................................................................19
9.3 Required records (must appear in the case file) ...................................................20
10. Funding Allocation, Service Targets & Set-Asides ...................................................20
10.1 Cohorts and annual targets.................................................................................20
10.2 Budget set-asides (time-limited reserves)...........................................................21
10.3 Operating rules....................................................................................................21
11. Appeals & Grievances ..............................................................................................21
11.1 Grounds & Filing .................................................................................................21
12. Fraud, Waste & Abuse (FWA) ..................................................................................22
12.1 Prevention...........................................................................................................22
12.2 Detection (screening & flags)..............................................................................23
12.3 Investigation & Case Handling............................................................................23
12.4 Overpayments & Recovery .................................................................................23
12.5 Sanctions & Referrals .........................................................................................23
13. Monitoring, Reporting, and Accountability ................................................................24
14. Policy Maintenance & Change Control.....................................................................24
1. Purpose, Authority, and Program Governance
a.Policy. GRASP is designed to prevent eviction and housing loss among Glendale renters by delivering targeted, time-limited assistance through three arms: Emergency Assistance, Income-Support Assistance, and Special Assistance.
b.Governance. Council sets policy objectives and approves budgets. The Housing Director maintains this Manual. Material policy changes require Council notice.
The Housing Director is authorized to issue and update these Policies & Procedures consistent with Council direction, funding terms, and applicable laws. c.Program integrity. Decisions must be consistent, auditable, and equitable.
Every approved assistance decision will be reproducible from the case record.
2. Definitions
a.Applicant -Head of household who submits a GRASP application. b.Arms of assistance -Emergency (avert eviction/shutoff or health/safety displacement); Income-Support (time-limited bridge for income drop/extreme burden); Special (one-time payment to remove a discrete housing barrier). c.Arrears -Unpaid rent or mandatory utility charges that have come due. d.Basic eligibility -In order for a household to be eligible or consideration for GRASP, all of the following must be true: their rents and occupies a dwelling in the City of Glendale as their primary residence; their gross household income is at or below 80% of AMI for its household size; they can provide the required proofs (or approved alternatives) to document residency/tenancy, income, and the months/expenses to be covered; and they show either an immediate housing risk or a recent hardship within the past twelve months with a clear housing nexus.
e.Community Based Organization (CBO) -Local nonprofit/public-benefit organization that serves residents (outreach, services, referrals). f.Critical -Immediate housing threat: nonpayment eviction/UD, utility shutoff/imminent shutoff, or verified health/safety condition affecting habitability. g.Duplication of benefits (DOB) -GRASP paying a month/expense already paid or to be paid by another source for the same period and purpose. h.Glendale residency -Assisted unit is within the City of Glendale and is the household’s primary residence.
i.Household -All persons who occupy the same rental dwelling unit as their primary residence and will reside there during the assisted months. One household per unit (even if finances/taxes are separate). j.Housing nexus -Direct link between the expense and the ability to remain housed/pay rent (e.g., car repair required to keep the job that pays rent).
k.Immediate family -Parent, stepparent, child, stepchild, spouse/registered partner, sibling, grandparent, grandchild, and in-laws in those categories. l.Landlord/authorized agent -Owner of record or written designee authorized to manage and accept rent.
m.Mandatory utilities -Electricity, gas, water/sewer, or trash the tenant must pay to keep the unit habitable.
n.Non-Critical -Eligible recent-hardship cases with no immediate housing threat. o.Primary residence -The unit the household lives in and intends to remain; short absences don’t change this if the unit is maintained and rent remains due. p.Rent burden -(Contract rent + tenant-paid mandatory utilities) ÷ gross monthly income.
q.Tenancy -Lawful rental arrangement for the assisted unit (lease, month-to- month, or recognized subtenancy).
3. Civil Rights, Equal Access, ADA/Section 504 &
Language Assistance
a.Policy. GRASP is administered in compliance with applicable federal, state, and local civil-rights laws. The City provides equal access to the program regardless of protected class and offers reasonable accommodations and language assistance as needed to ensure effective participation. Survivors of domestic violence, dating violence, sexual assault, or stalking will not be denied assistance or penalized based on violence experienced. Glendale staff will not request or retain documentation related to immigration status for any GRASP activity.
3.1 Reasonable Accommodation (RA)
a.Purpose. Ensure applicants with disabilities have equal opportunity to apply, provide documents, communicate with staff, and receive assistance. b.How to request. Applicants may request RA in any channel (portal checkbox, phone, email, in person). Staff must assist if asked.
c.Timelines.
i. Acknowledge within 3 business days; decide within 10 business days (or sooner if time-sensitive), unless additional information is needed. ii. Extensions to application deadlines or document windows must be issued in writing and noted in the system.
d.Examples the program will grant, as appropriate:
i. Alternate formats (large print; accessible PDFs).
ii. Alternative submission methods (staff-assisted upload; in-home verification in rare cases).
iii. Modified timelines for document collection.
iv. Acceptance of alternative documentation where a disability limits access to standard proofs.
e.Documentation. Use the RA form; record the request, decision, effective dates, and any follow-up.
3.2 Language Assistance (LEP)
a.Policy. GRASP provides meaningful access for Limited English Proficiency (LEP) applicants. Interpreters are available at no cost. Minors may not serve as interpreters. Bilingual staff may interpret only if qualified. b.Interpreters.
i. Offer in-person or telephonic/video interpreters for all appointments; schedule when the case is opened or when the appointment is set. ii. Staff record the language tag and interpreter confirmation in the case file. c.Public communications. Website and flyers clearly state that free interpreters are available; application pages show language toggles or contact info to request assistance.
3.3 Complaints & Appeals
a. Complaints alleging discrimination or failure to provide language access/RA are acknowledged within 3 business days and resolved within 15 business days when practicable.
4. Application Process & Intake Model
a.Policy. GRASP will use an initial, time-limited opening to build the first applicant pool, and then will operate on a rolling, staff-discretion basis until the pool needs to be replenished.
4.1 Pre-Opening Outreach (Prep Phase)
a.Pre-Opening. Before GRASP’s initial 2-week opening, the City will perform a targeted pre-launch push so that renters, landlords, CBOs, and internal City programs know the dates, know who the program is for, and are ready to help applicants submit during the window.
a.Partner notice. At least 30-45 days before opening, notify internal City programs (Housing/RRP, GWP, Code, Homeless Services, Senior Services, Libraries/Community Centers) and community-based organizations (CBOs) serving renters (e.g., legal aid, immigrant- and senior-serving groups, faith-based providers).
b.Public notice. Post the opening dates and how to apply no later than 14 days before opening on (a) the City housing site and GlendaleRentalRights.com, (b) official social channels, (c) physical postings at City sites and participating CBOs, and (d) the Affordable Housing Interest List.
4.2 Serving the initial pool
a. The City of Glendale will open GRASP to the public for an initial intake period of 2 weeks.
b. During this period, all applications received are logged, time-stamped, and screened for basic eligibility.
c. One-application rule (duplicates). Only one active GRASP application per rental unit at a time. If multiple applications are received from the same unit, the City will merge them, verify total occupants, and proceed as one case. d. If outreach shows low participation from a priority group (for example, ELI seniors with disabilities), staff may extend the window or run targeted clinics during the same opening or processing period.
e. After screening, each application is labeled as:
i. Critical - imminent housing threat (nonpayment UD/eviction, shutoff/imminent shutoff, verified health-safety); or
ii. Non-Critical - recent 12-month hardship (good-cause job loss/reduction, medical/wage-loss with housing nexus, essential unavoidable expense with housing nexus).
f.Scoring. The program then creates two ranked queues from that opening: a Critical queue and a Non-Critical queue, using the GRASP points rubric. g.Selection. Staff will start at the top of Critical and move down, and then do the same for Non-Critical
h. Critical households are always served before Non-Critical households, regardless of when they applied.
4.3 Serving the initial pool
a. After the 2-week window closes, staff will begin serving the pool from the top of the Critical list using the three-arm test:
i. Emergency now (if there is a payable threat);
ii. Income-Support profile/placeholder (if the household is still rent-burdened or in temporary income loss after Emergency);
iii. Special (if there is a small, clear housing-nexus cost to remove). b. Staff may begin serving Non-Critical in score order only when all Critical cases from the initial opening have been either:
i. funded/encumbered,
ii. denied for ineligibility or non-response, or
iii. referred to another program,
c. As Emergency/Income/Special encumbrances time out or are not used, those dollars return to the main pot and can be used for the remaining applicants.
4.4 Applicant experience
a.Step 1 - Apply. The applicant submits online, or in person at a City office. b.Step 2 - Confirmation. The applicant immediately receives a confirmation with the date/time and a short explanation: “Your application has been received. The City will conduct an initial review to determine preliminary eligibility. If selected for participation, you will receive a separate document request that lists exactly what to provide and the timeframe for submission. If you are determined ineligible, you will receive a written notice explaining the reasons and how to appeal. No action is required from you at this stage.”
c.Step 3 - Outcome message. After staff screen the file, the applicant gets one of three outcomes:
i. Eligible – Meets basic eligibility criteria/placed in queue. ii. Conditional approval– documents needed/pending verification. iii. Not eligible – does not meet basic criteria.
d.Step 4 - Document pull (only if selected). Only applicants we are prepared to fund are asked for full proof (ledger, notice, income, medical letter, utility bill, proof of Glendale tenancy). They get a 7-day deadline, with extensions for disability/LEP/good cause.
e.Step 5 - Verification and final decision. When the documents arrive, staff match them to what was claimed. If it matches, staff issues final approval and sends to payment. If it does not match, or no documents arrive, staff issues a denial/closure and selects the next case in rank.
4.5 Supplemental intake (referrals and walk-ins)
c. While the City is working through the initial pool, staff may accept additional applications on a case-by-case basis from:
i. internal referrals (e.g. RRP, homeless prevention, GWP); ii. walk-ins or hotline calls reporting an imminent eviction; iii. other public agencies or CBOs serving Glendale residents. d.These discretionary applications are screened the same way (eligibility → Critical/Non-Critical → scoring) and are inserted into the appropriate queue based on their score, even if the original 2-week opening is closed. e. Staff should use discretion for walk-ins only when:
i. the household is clearly Critical; or
ii. the current pool of eligible cases is low and more applicants are needed to meet Council priorities.
4.6 Future Openings
a.When used. If, after serving down the initial pool and ongoing referrals/walk-ins (§4.5), the number or mix of eligible applicants is insufficient to meet program goals or Council priorities, the City may schedule a new opening. b.Notice. Future openings follow the same public-notice standards in §4.5 (Pre- Opening Outreach) and §4.1(a)–(b): post dates, how to apply (online/in-person), languages, and access supports. Future openings may be shorter (for example, 5–7 business days) and may target specific groups through outreach and CBO clinics.
c. Messaging. Notices must state that Critical cases are reviewed first and that application does not guarantee assistance (see §4.1(h)). d.Processing. Applications from future openings use the same screening, Critical/Non-Critical labeling, scoring, and selection rules in §§4.1(e)–(h), 4.2, and
6.
5. Eligibility Policy
Policy. To be eligible for GRASP, a household must meet all baseline criteria and at least one qualifying risk/hardship condition. Assistance may not duplicate payment for the same month/expense from any source.
5.1 Baseline Criteria - Must meet all criteria
a.Residency & Tenancy. At the time of application, award and participation, the household’s primary residence must be within the City of Glendale. i. Emergency Assistance (unit-tied). Covered months/charges must relate to the current Glendale tenancy (e.g., rent arrears/prospective rent for the Glendale unit, Glendale utility account). Payee and payment method are governed by §10.
ii. Income-Support Assistance (household-tied). Benefit supports housing stability while the household continues to reside in Glendale. Moves within Glendale may continue after updating address/lease; moves outside Glendale end future payments effective the move date. Monthly attestation, if used, is governed by §10.
iii. Special Assistance (expense-tied). The cost must have a documented housing nexus for a Glendale resident, or tie to move-in costs for a Glendale unit with a signed lease/approval to move within 30 days.Income.
b.Income ceiling. Gross household income is less than 80% of Area Median Income (AMI) for household size, using the GRASP Annual Income rules and the most current AMI limits applicable to Glendale.
c.Documentation readiness. The household can provide required documents or approved alternatives.
d.Explicit Exclusions. Not eligible:
i. people currently experiencing homelessness;
ii. homeowners or mortgage holders;
e. Related-Party Tenancies (Immediate Family). GRASP will not fund a tenancy where the owner/landlord (or the payee entity) is an immediate family member of any household member, or an entity they own/control greater then10%, unless an exception is approved:
i. Reasonable accommodation (disability). A brief provider note (no diagnosis) shows the arrangement is necessary for a person with disabilities.
5.2 Qualifying Risk/Hardship - At least one must be true a.Imminent risk of displacement:
i.Nonpayment-of-rent eviction (only). Eligible when the eviction/UD is solely for nonpayment of rent for the assisted unit. Mixed-cause notices (e.g., nonpayment + nuisance) are ineligible unless the landlord withdraws all at-fault causes via amended notice/pleading or written settlement.
No-fault termination (with risk test). A 30- or 60-day no-fault notice (for example, owner move-in or withdrawal/Ellis) qualifies only if both conditions are met: (1) the household shows elevated risk of homelessness-income at or below 50% of AMI, or rent burden above 60%, or another City-accepted risk indicator; and (2) the household has no secured alternative housing (no executed new lease). Where the law requires landlord-paid relocation, GRASP may fund only the documented gap after that payment is applied.
ii.Utility shutoff or imminent shutoff . Provide disconnection notice or utility confirmation tied to the assisted unit/account. iii.Verified health/safety condition. Resident must provide an inspection order, red-tag, or qualified provider letter showing the condition jeopardizes continued occupancy. If the condition triggers landlord-paid relocation (e.g., code-cited or intentional disrepair), staff must confirm those payments and apply them first. GRASP funds the gap only and may support Glendale re-housing costs when appropriate. Temporary relocation does not apply.
b.Recent hardship (within the prior 12 months):
i.Job loss or reduction in work hours/income (involuntary or good- cause only). Eligible when due to layoff, employer-cut hours, workplace closure, verified medical restrictions, school/childcare closure, documented safety/harassment/retaliation, or other good-cause reason supported by third-party evidence. Exclusions: voluntary quit without good cause; termination for cause; elective schedule reductions; leaving a job or gig by choice absent safety/mechanical or medical documentation. ii.Major medical expense or temporary disability with wage-loss or uncovered-costs nexus. Eligible when either the condition reduces wages (e.g., partial pay, unpaid leave, waiting periods); OR the household has documented, medically necessary out-of-pocket costs that create a rent shortfall.
iii.Essential, unavoidable expense with housing nexus. Must be necessary, time-sensitive, causally linked to the month(s) of shortfall, and third-party documented (e.g., essential car repair to keep employment; emergency childcare to maintain shifts; deposits/fees to secure a Glendale unit). Non-eligible: elective purchases, consumer debt without housing nexus, discretionary travel.
5.3 Non-Duplication of Benefits
a. GRASP funds may not duplicate payment for the same month or expense covered by any other source. Staff will conduct internal and reasonable external checks; if duplication is discovered, assistance will be adjusted, denied, or recovered per Section 15.
5.4 Liquid-Asset Screen
a.At any time during program eligibility or participation, if household liquid assets (cash, checking/savings, readily sellable securities/crypto) exceed the lesser of $35,000 or six (6) months of contract rent, the household is ineligible GRASP.
Special Assistance may be considered only if funds are temporarily inaccessible (e.g., frozen/probate) and an immediate risk exists; a Director waiver with documentation is required.
6. Prioritization Policy: Grouping Step + Points
a.Policy. Application prioritization under GRASP happens in two steps so that the most urgent housing threats are reviewed ahead of general hardship cases.
Applications are first labeled as either critical or non-critical, after that label is assigned, each group is scored separately using the GRASP points rubric.
6.1 Grouping Step
a.Policy. Every complete application is screened to see whether it meets the program’s definition of immediate or imminent housing risk. An application is labeled Critical when the documentation shows one of the following: an eviction or unlawful detainer for nonpayment of rent; a utility shutoff or an official notice that shutoff is imminent for the assisted household; or a verified health or safety condition that makes the current unit temporarily uninhabitable or unsafe.
Applications that do not show one of these urgent conditions, but still meet the program’s recent-hardship test (job loss/reduction for good cause, major medical expense with a housing nexus, or another essential expense that undermines rent), are labeled Non-Critical.
6.2 Points
a.Policy. After the application is assigned a Critical or Non-Critical label, each group is scored separately using the GRASP points rubric (income level, rent burden, vulnerability factors like disability or age, and recent instability). Higher- scoring cases are placed ahead of lower-scoring cases for each respective group.
6.3 Points rubric
Category Criteria Points
Income
≤ 30% AMI +6
31–50% AMI +4
51–80% AMI +2
Rent Burden (contract rent
+ required utilities ÷ gross
monthly income)
≥ 91% +5
81–90% +4
71–80% +3
61–70% +2
51–60% +1
≤ 50% +0
Vulnerability
Disability +3
Senior 62+ +2
Single-member household +1
Children under 18 in
household
+1
Instability (last 12 months)
Job loss/reduction (good-
cause/involuntary)
+2
Major medical expense or
temporary disability (wage-
loss OR uncovered-costs
nexus)
+2
For scoring, percentages are rounded to the nearest whole percent; decimals of
0.5 or higher round up (e.g., 59.6% → 60%).
6.4 Worked Scoring Examples
a. Case A - Critical
Why Critical: Documented nonpayment eviction.
Score:
Income: ≤30% AMI = +6
Rent burden: 95% = +5
Vulnerability: Disability +3, Senior 62+ +2, Single-member household +1 = +6 Instability Job loss/reduction = +2
Total: 6 + 5 + 6 + 2 = 19
6.5 Lottery & Tie-Break Protocols
a.Purpose. When more eligible applications exist than funds, GRASP applies a clear, fair, and auditable order.
Run this process separately for the Critical queue first, then for the Non-Critical queue.
i. Tie-break order (in this exact sequence)
1. Higher point score comes first.
2. If scores are equal: Earlier complete-submission timestamp comes first.
3. If both score and timestamp are identical: run a micro-lottery among those tied applications.
Complete-submission timestamp = the moment the application first met the “complete” standard (all required fields + minimum docs). Later uploads do not change this timestamp.
7. Verification & Documentation Standards
a.Policy. GRASP verifies facts that drive eligibility, prioritization, and payment using the highest reasonably available evidence. Staff apply a verification hierarchy, a two-proof minimum for arrears, and anti-duplication checks before authorizing any payment. Detailed evidentiary lists and workflows are maintained in the GRASP Verification SOPs and Appendices.
7.1 Hierarchy of evidence (use the highest available).
a. Official/administrative data (City/utility/court/assessor); b. Written third-party records (landlord ledgers, employer/benefit letters, utility bills); c. Documented oral third-party confirmation;
d. Applicant-provided documents (receipts, bank statements, screenshots);
e. Self-certification only when higher levels are unavailable in time and housing would be jeopardized. Staff must note the reason.
7.2 Minimum eligibility that must be verified for every case. a. If any of these four cannot be verified at some level, do not approve benefits. b. Residency/tenancy in Glendale for the assisted household; c. Household income at or below 80% AMI (per §5 rules); d. A qualifying risk or recent hardship (per §5);
e. No duplication of benefits for the same month/expense (per §5.3).
7.3 Two-source standard.
a. For any fact used to determine eligibility, prioritization, or payment, staff must obtain two independent sources of verification before approval. b.Emergency exception. If waiting for a second source would likely cause loss of housing or essential utility service, staff may proceed with one source, record a short justification in the case file, and obtain the second source as soon as practicable.
c.Items that require verification. Apply the two-source standard to: identity and residency; income; rent and arrears; utilities; qualifying hardship and housing nexus; household composition and any live-in aide; payee authority and payee setup; and duplication-of-benefits checks. Operational examples are set out in the Verification SOP.
7.4 Director authority.
a. The Housing Director may update Verification SOPs and Appendices (document matrices, checklists, sample letters) to reflect funder guidance and lessons learned, without changing adopted eligibility rules.
8. Benefit Determination
a.Purpose. After an application is selected, staff authorize benefits to achieve the least-cost, fastest stabilization while respecting all eligibility rules. Benefits are structured under one of three arms-Emergency, Income-Support, or Special-and may transition across arms as circumstances change (no duplication of benefits).
8.1 Foundational rules (apply to all arms).
a.No duplication of benefits (DOB). Do not pay a month or expense already paid by another source; offset any later reimbursements.
b.Direct pay is preferred. Pay landlords, utilities, or vendors directly whenever feasible. If a payee refuses or cannot accept, pay the household with proof of obligation and a clear memo of covered months/charges.
c.Documentation. A Benefit Sizing Worksheet is completed for each authorization; exceptions require supervisor approval.
d.No concurrent financial assistance across categories. Households may not receive any more than one type of assistance at the same time. e.Total cap & cooling-off. Total financial assistance from any combination of eligible activities must not exceed $36,000 in any 24-month period; after reaching the cap or 24 months, a 6-month cooling-off applies before new aid
8.2 Emergency Assistance
a. Purpose. Prevent eviction or utility shutoff and stabilize the tenancy as fast as possible, to resolve the verified threat.
b. Coverage limits. Emergency Assistance may cover up to six total months per household within the applicable LACAHSA program rules and overall funding caps. Prospective months are permitted within those limits and must be authorized one month at a time with a current tenancy check before each release. Emergency Assistance may not run concurrently with any LACAHSA category that prohibits overlap.
c. Authorization standard (situation-based). Staff authorize payments in the sequence most likely to stop the immediate threat (e.g., UD dismissal terms, utility hold-off requirements, habitability resolution), based on documents in the file and landlord/utility confirmations.
d. Prospective payments. Future rent/utility payments may be authorized one month at a time as needed to prevent eviction or shutoff, counted toward the applicable 6-month assistance limit and the $36,000/24-month cap; continuation requires confirmation of occupancy, need and no duplication of benefits. e. Payment practice. For Emergency Assistance, the City pays the landlord directly for rent (and the utility directly for shutoff prevention). Tenant payments are used only if a payee cannot accept City payment and require proof of obligation and a receipt. The City will release funds only when there is reasonable assurance the payment will resolve the stated housing threat and not be followed by eviction, shutoff, or continued displacement.
f. Emergency Sizing Standard. For each approved month, the City may pay up to the full contract rent and required tenant-paid utilities when documentation shows that doing so is the least-cost, fastest way to resolve the nonpayment eviction or utility shutoff. Where a smaller amount will resolve the threat (e.g., balance to dismiss, amount to prevent shutoff), authorize only that amount. Emergency authorizations follow funder rules: payments count toward the 6-month ERFFA limit, must be authorized one month at a time (arrears excepted), cannot overlap with Short-Term Income Support for the same months, and count toward the $36,000/24-month household cap. File must include a short note explaining why the authorized amount is the least necessary to resolve the crisis. g.Transitions to other arms. Emergency Assistance frequently triggers follow-on support; handle as follows:
i.Emergency → Income-Support. If the tenancy is intact after Emergency but the household still faces a temporary income shortfall or extreme rent burden, create/activate an Income-Support schedule (up to the allowed duration) starting the month after the Emergency coverage ends. Do not overlap months with a prohibited LACAHSA category. Re-check eligibility before each Income-Support release.
ii.Emergency → Special Assistance. If a one-time bill (e.g., essential car repair, deposit, medically necessary expense) is the actual barrier to staying housed or working, authorize Special Assistance instead of additional Emergency months. Document the housing nexus. iii. Encumbrances. Use encumbrances/hold notes to reserve expected future months under the new arm; release or reduce them promptly if eligibility changes or the household stabilizes.
h.Closure. Close Emergency when (1) the verified threat is cured or credibly held off by documented terms, (2) authorized months have been issued, or (3) the case transitions to another arm. Release any unused encumbrances back to the pool and record the disposition.
8.3 Income-Support Assistance
a.Purpose. Provide short-term, declining monthly support to keep rent/essential housing costs affordable while the household restores income-without creating a benefits cliff.
b.Eligibility link. Income-Support may be authorized only after the household meets §5 (baseline + qualifying risk/hardship) and either:
i. has stabilized the immediate emergency (or had no emergency) but remains rent-burdened due to a documented temporary income drop, or ii. faces a near-term income gap that would otherwise trigger nonpayment or re-entry into crisis.
c.Duration & caps. Income-Support Assistance may be provided for up to 18 months, authorized one month at a time, with a maximum of $2,000 per month paid directly to the household. Across all RPHP financial-assistance activities combined (any mix of Emergency/Temporary Rental Assistance and Income- Support), a household may receive no more than $36,000 within any 24-month period; after reaching either the $36,000 cap or 24 months of assistance, the household must wait 6 months before any new assistance. Income-Support may not run concurrently with other assistance.
d.Sizing principle. The monthly amount is determined with the GRASP Income- Support Worksheet to close a documented affordability gap toward a reasonable target housing burden set in the Admin Bulletin. The worksheet considers contract rent, required tenant-paid utilities, verified current income, and confirmed third-party aid; amounts may step down over time. The detailed method and any numeric parameters are set in the Income-Support Sizing SOP and may be updated administratively within LACAHSA rules.
e.Payment practice. Pay the household by default with a monthly attestation that funds are used for rent, required utilities, essential transportation to work, or essential child care.
f.Monthly release check. Before each month is released, staff confirm: continued Glendale residency, no duplication of benefits, any income/rent/utility changes, and continued need per the sizing SOP.
g.Transitions with other arms.
i.From Emergency → Income-Support when the immediate threat is cleared and a temporary income gap persists.
ii.From Income-Support → Emergency if a UD/shutoff arises (pause future IS months, address Emergency, then re-assess IS need).
iii. Special Assistance may be paired for one-time barriers with a clear housing nexus (no duplication).
8.4 Special Assistance
a. Remove a one-time barrier with a clear housing nexus so the household can secure or keep housing.
b. Eligible uses (examples).
i. Utility arrears or deposit to restore or maintain service for the assisted unit.
ii. Medically necessary out-of-pocket costs that caused the rent shortfall (vendor pay preferred).
iii. Security deposit, application fees, or key move-in costs to secure a Glendale unit.
iv. Essential car repair required to keep a job that pays the rent (with employer schedule/commute confirmation).
c. Not eligible (examples).
i. Cosmetic or elective medical care
ii. Consumer debt without housing nexus
iii. Discretionary purchases,
iv. or costs already covered by another source.
d. Amount, duration, and caps. Special Assistance is one-time per barrier and must fit within the household’s remaining funder cap(s).
e. Payment practice.
i. Pay the vendor directly when feasible. If paying the household, collect proof of payment and keep a clear memo of the covered expense and date.
9. Case Management Standards
a. Purpose. Case management converts eligible applications into timely, compliant payments; documents decisions; and monitors ongoing need to prevent duplication of benefits and misuse.
9.1 Policy
a. Apply the least-burdensome process that still meets verification, funder, and audit requirements.
b. Follow the two-source verification standard in Section 7 for facts that drive eligibility, prioritization, or payment.
c. Use the Benefit Determination rules in Section 10; record any exceptions with supervisor approval.
d. Maintain clear, reproducible records so any award decision can be independently reconstructed.
9.2 Minimum workflow
a. Assignment: Assign each approved application to a caseworker; note assignment date.
b. Conditional approval & doc request (if selected): Issue a conditional approval listing the arm(s) under consideration, the specific documents required, and the response window (extensions per RA/LEP policy).
c. Verification check: Confirm residency/tenancy, income, and the month(s)/expense(s) to be paid per Section 7.
d. Benefit note: Before payment, enter a short note stating arm, months/expenses, sizing basis, any future placeholder, and required landlord/utility cooperation. e. Payment packet: Assemble the documents Finance needs and mark “ready to pay.”
f. Disposition: Close the case (served/ineligible/no response).
9.3 Required records (must appear in the case file)
a. Eligibility evidence: residency/tenancy, income, qualifying risk/hardship. b. Arm decision: one-line rationale (e.g., “Emergency: 3 months to resolve UD”). c. Payment trail: request, approval, payee, covered months/expenses, amounts. d. Communications: attempts, extensions, landlord/utility contacts, referrals. e. Final disposition and date (closed, follow-up, referred).
10. Funding Allocation, Service Targets & Set-
Asides
a.Policy. Within overall funder limits and Council-approved budgets, GRASP will (1) reserve funds for defined cohorts through time-limited set-asides and (2) track annual service targets (soft floors) for priority populations. All applicants must still meet §5 eligibility; Critical-first processing and points scoring in §6 apply within each cohort.
10.1 Cohorts and annual targets
a. Seniors (62+) – Service target: At least 20% of total households served annually are senior-headed.
b. GCC student households – Service target: Serve 10 eligible student-headed households referred by Glendale Community College (GCC) during the program year.
10.2 Budget set-asides (time-limited reserves)
a.Senior set-aside. Reserve up to 20% of the combined Emergency + Income- Support annual allocation for senior-headed households. Unused senior set- aside automatically reverts to the general pool on October 1. b. GCC student access. Maintain at least 10 case “slots” (encumbrance capacity) for eligible GCC referrals on a rolling basis.
10.3 Operating rules
a. Critical-first still governs. Within each cohort, process Critical cases before Non- Critical (§6).
b. Points still decide order. Use the §6 points rubric to order cases inside each cohort.
c. No hard quotas. Targets guide outreach and allocation; they are not caps or grounds to deny a higher-need non-cohort household.
d. Verification. Cohort status (age/enrollment) is verified per §7 using the two- source standard where practicable (e.g., government ID + benefits/tax record for age; GCC enrollment letter/portal + student ID).
e. Anti-duplication & benefits. All DOB checks (§5.3) and benefit rules (§8) apply equally to cohort and non-cohort cases.
f. Reallocation safety valve. The Housing Director may re-balance set-asides mid- year by Administrative Bulletin when demand patterns risk leaving funds idle or when needed to satisfy funder requirements (§15).
11. Appeals & Grievances
a. Policy. Applicants may appeal eligibility or scoring decisions and may submit grievances about process or access. Appeals are reviewed by a staff member uninvolved in the original decision.
11.1 Grounds & Filing
a. Appeal grounds: error of fact or policy application; new evidence previously unavailable; procedural error.
i. Deadline: 14 calendar days from notice.
b. Review & Timelines
i. Acknowledge within 5 business days; decision within 14 business days of complete appeal.
c. Evidence & Standards
i. Accept additional documents or statements. Reviewer applies program policy as written and explains determinations citing case record and rules.
d. Grievances
i. Process complaints unrelated to eligibility (staff conduct, access, timeliness). Acknowledge within 5 business days; resolve within 14 business days when practicable.
e. Records
i. Maintain an appeal/grievance log with outcomes.
12. Fraud, Waste & Abuse (FWA)
a. Policy. This section protects GRASP funds from intentional misuse by applicants, landlords, vendors, and staff. FWA controls apply to all arms of GRASP (Emergency, Income-Support, Special), to all intake channels (public opening, referrals, walk-ins), and to all payees (landlords, utilities, hotels, storage, other vendors).
12.1 Prevention
a.Attestations. Applicant and payee attest that information is true, GRASP may verify with third parties, and false/duplicate claims may lead to denial, termination, or recovery.
b.Two-source verification. For facts that drive eligibility, prioritization, or payment, use the two-source standard in §7 (emergency exception per §7). c.Duplication of benefits checks. Check GRASP and reasonable external sources for overlapping months/expenses before approval. d.Payee validation. Confirm owner/agent/vendor authority to accept payment and tax/EFT details before disbursement.
e.Segregation of duties. Casework, approval, and payment processing functions are separated.
f.Conflicts of interest. Staff disclose/recuse per City policy.
12.2 Detection (screening & flags)
a.System/desk reviews. Screen for overlapping months/expenses, repeated or altered documents, identity mismatches, and patterns suggesting multi-filing. b.Sampling. Conduct periodic post-payment quality reviews; sampling rate set in the SOP.
12.3 Investigation & Case Handling
a.Pause authority. If there is material doubt about eligibility, amount, or payee, staff may place payment on hold and document the reason. b.Clarification & checks. Request clarifying documents and, where needed, perform independent third-party checks (e.g., landlord, utility, employer, court/Code).
c.Applicant response. Provide the applicant an opportunity to respond before an adverse action.
d.Determination & record. Document outcome:
i. No FWA-proceed;
ii. Error-correct and pay the correct amount;
iii. Likely FWA-deny/terminate and proceed to recovery/sanctions.
12.4 Overpayments & Recovery
a. Overpayment includes wrong month(s), amounts above verified arrears, payment to an ineligible payee, or payment to a household later found ineligible at the time of payment.
b.Stop loss. Halt future scheduled payments on the case. c.Recovery order.
i. seek voluntary return or permissible offset with landlords/vendors; ii. tenant repayment plans when the tenant received funds directly; iii. refer to Finance/collections when required.
12.5 Sanctions & Referrals
a. Good-faith/low-impact errors. Correct and continue; no sanction. b. Careless/repeat issues. Written warning; future submissions may require higher- level verification.
c. Intentional fraud. Deny/terminate; flag in system; refer to City Attorney/law enforcement/funder when required.
d. Staff cases. Suspected staff misconduct or conflicts go to the department director/HR; reassign the case.
13. Monitoring, Reporting, and Accountability
a.Reporting. Staff will provide a quarterly program summary to the Housing Director and an annual report consistent with funder and City requirements. b.Record Retention. Maintain complete case and payment records for seven (7) years after final disbursement or grant close-out, whichever is later; extend for legal holds.
c.Data. GRASP will collect and report household-level program data using the current LACAHSA tools and timelines. At minimum, the City will track and be able to report:
i. household composition and demographics;
ii. eligibility information, including income band, housing status at entry, and qualifying event(s);
iii. prioritization factors applied;
iv. expenditure categories, payees, and amounts;
v. time in program; and
vi. destination at exit.
The City will submit biannual programmatic/financial reports to LACAHSA by the prescribed deadlines and will use any regional database/shared data methods designated by LACAHSA once available. Records will be maintained to support LACAHSA monitoring and audit.
d.Monitoring & Audit. Conduct quarterly file reviews and reconcile approvals/encumbrances/disbursements; implement written corrective actions within 60 days of any finding. Cooperate with external audits.
14. Policy Maintenance & Change Control
a.Policy. This Manual is a living document. The Housing Director may issue administrative updates and takes material changes to Council or the City Manager as required.
b. Change Types
i. Administrative: typos, clarifications, SOP/form updates, minor rubric tuning within authorized bounds.
ii. Material: eligibility thresholds, point weights beyond authorized bounds, new set-asides, or changes affecting applicant rights. c. Variances & Staff Discretion (case-by-case). Staff may depart from a process requirement in this Manual only when necessary to prevent imminent housing loss, ensure meaningful access (ADA/LEP), or when a stricter requirement is impracticable for reasons outside the household’s control. d. Staff may depart from a procedural requirement only to prevent imminent housing loss or material abuse (anti-circumvention), and only where consistent with law and funder terms.