Date: December 21, 2021
To: HOME-ARP Recipients within the LA CoC
From: Molly Rysman, Chief Programs Officer
cc: Gateway Cities Council of Governments
Las Virgenes/Malibu Council of Governments
North Los Angeles County Council of Governments
San Gabriel Valley Council of Governments
South Bay Cities Council of Governments
Westside Cities Council of Governments
RE: 2021 HOME-ARP Funding Recommendations from the LA CoC This memorandum provides a summary of the HOME Investment Partnerships – American Rescue Plan (HOME-ARP) program requirements as it relates to collaboration with a local Continuum of Care (CoC) and use of coordinated entry (CE). This memorandum also provides recommendations from LAHSA, lead agency for the Los Angeles CoC, to jurisdictions being allocated funds from the HOME-ARP. Below is what is included in this memo:
Overview of HOME-ARP Grant Funding
HOME-ARP Project Referral Methods – Use of Coordinated Entry (CE) Application Requirements – HOME-ARP Allocation Plan
Overview of Eligible Uses
LAHSA Recommendations for Use of HOME-ARP Funding
Appendix A. HOME-ARP Allocations by Jurisdiction
The following information is in accordance with the U.S. Department of Housing and Urban Development (HUD) Notice regarding Requirements for the Use of Funds in the HOME Investment Partnerships – American Rescue Plan (HOME-ARP) program, released in September 2021. A total of $197 million is being allocated to 30 jurisdictions in Los Angeles County, 27 of which are located in the LA CoC.
Overview of HOME-ARP Grant Funding
The $1.5 trillion American Rescue Plan, approved by Congress and signed by President Biden on March 11, 2021, contains $5 billion for affordable rental housing and homelessness assistance through HOMEARP. These formula block grants provide states and local jurisdictions (“participating jurisdictions”) with flexible funding to reach populations experiencing homelessness or currently at risk of homelessness and address local affordable housing, non-congregate shelter, and supportive service needs within their respective communities. These funds are not intended to be thought of as traditional HOME program
funds but are intended to address homelessness. HOME-ARP funds are reserved for the following key uses:
Development and support of affordable rental housing
Tenant-based rental assistance (TBRA)
Supportive services for qualifying populations
Acquisition and development of non-congregate shelter (NCS) o HOME-ARP grants may not be used for operating costs for non-congregate shelter or costs associated with converting non-congregate shelter to permanent housing Non-profit operating expenses and capacity building
o Funding for this use is limited to five percent (5%) for supporting operating expenses for non-profit entities carrying out HOME-ARP projects and services, with the option to increase funding by an additional five percent (5%) for costs related to capacity building Qualifying Populations: HOME-ARP funded projects and supportive services must serve individuals or families from the following qualifying populations:
Homeless, as defined by federal law:
1) An individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning:
i. An individual or family with a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings, including a car, park, abandoned building, bus or train station, airport, or camping ground;
ii. An individual or family living in a supervised publicly or privately operated shelter designated to provide temporary living arrangements (including congregate shelters, transitional housing, and hotels and motels paid for by charitable organizations or by federal, state, or local government programs for low-income individuals); or
iii. An individual who is exiting an institution where he or she resided for 90 days or less and who resided in an emergency shelter or place not meant for human habitation immediately before entering that institution; 2) An individual or family who will imminently lose their primary nighttime residence, provided that:
i. The primary nighttime residence will be lost within 14 days of the date of application for homeless assistance;
ii. No subsequent residence has been identified; and
iii. The individual or family lacks the resources or support networks, e.g., family, friends, faith-based or other social networks needed to obtain other permanent housing;
3) Unaccompanied youth under 25 years of age, or families with children and youth, who do not otherwise qualify as homeless under this definition, but who:
i. Are defined as homeless under section 387 of the Runaway and Homeless Youth Act (42 U.S.C. 5732a), section 637 of the Head Start Act (42 U.S.C. 9832), section 41403 of the Violence Against Women Act of 1994 (42 U.S.C. 14043e-2), section
330(h) of the Public Health Service Act (42 U.S.C. 254b(h)), section 3 of the Food and Nutrition Act of 2008 (7 U.S.C. 2012), section 17(b) of the Child Nutrition Act of 1966 (42 U.S.C. 1786(b)), or section 725 of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11434a);
ii. Have not had a lease, ownership interest, or occupancy agreement in permanent housing at any time during the 60 days immediately preceding the date of application for homeless assistance;
iii. Have experienced persistent instability as measured by two moves or more during the 60-day period immediately preceding the date of applying for homeless assistance; and
iv. Can be expected to continue in such status for an extended period of time because of chronic disabilities, chronic physical health or mental health conditions, substance addiction, histories of domestic violence or childhood abuse (including neglect), the presence of a child or youth with a disability, or two or more barriers to employment, which include the lack of a high school degree or General Education Development (GED), illiteracy, low English proficiency, a history of incarceration or detention for criminal activity, and a history of unstable employment; or
4) Any individual or family who:
i. Is fleeing, or is attempting to flee, domestic violence, dating violence, sexual assault, stalking, or other dangerous or life-threatening conditions that relate to violence against the individual or a family member, including a child, that has either taken place within the individual's or family's primary nighttime residence or has made the individual or family afraid to return to their primary nighttime residence;
ii. Has no other residence; and
iii. Lacks the resources or support networks, e.g., family, friends, faith-based or other social networks, to obtain other permanent housing. At-Risk of Homelessness, as defined by federal law:
1) An individual or family who:
i. Has an annual income below 30 percent of median family income for the area, as determined by HUD;
ii. Does not have sufficient resources or support networks, e.g., family, friends, faith-based or other social networks, immediately available to prevent them from moving to an emergency shelter or another place described in paragraph (1) of the “Homeless” definition in this section; and
iii. Meets one of the following conditions:
A. Has moved because of economic reasons two or more times during the 60 days immediately preceding the application for homelessness prevention assistance;
B. Is living in the home of another because of economic hardship; C. Has been notified in writing that their right to occupy their current housing or living situation will be terminated within 21 days after the date of application for assistance;
D. Lives in a hotel or motel and the cost of the hotel or motel stay is not paid by charitable organizations or by federal, State, or local government programs for low-income individuals;
E. Lives in a single-room occupancy or efficiency apartment unit in which there reside more than two persons or lives in a larger housing unit in which there reside more than 1.5 people per room, as defined by the U.S. Census Bureau;
F. Is exiting a publicly funded institution, or system of care (such as a health-care facility, a mental health facility, foster care or other youth facility, or correction program or institution); or
G. Otherwise lives in housing that has characteristics associated with instability and an increased risk of homelessness, as identified in the recipient's approved consolidated plan;
2) A child or youth who does not qualify as “homeless” under this section, but qualifies as “homeless” under section 387(3) of the Runaway and Homeless Youth Act (42 U.S.C. 5732a(3)), section 637(11) of the Head Start Act (42 U.S.C. 9832(11)), section 41403(6) of the Violence Against Women Act of 1994 (42 U.S.C. 14043e-2(6)), section 330(h)(5)(A) of the Public Health Service Act (42 U.S.C. 254b(h)(5)(A)), section 3(m) of the Food and Nutrition Act of 2008 (7 U.S.C. 2012(m)), or section 17(b)(15) of the Child Nutrition Act of 1966 (42 U.S.C. 1786(b)(15)); or
3) A child or youth who does not qualify as “homeless” under this section, but qualifies as “homeless” under section 725(2) of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11434a(2)), and the parent(s) or guardian(s) of that child or youth if living with her or him.
Fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, and human trafficking
Part of populations where providing supportive services would prevent homelessness, including formerly homeless households using temporary assistance and/or households identified as being at greatest risk of homelessness
Veterans and families that include veteran family members that meet above criteria For HOME-ARP Rental Housing projects, at least 70% of units must be reserved for households from qualifying populations with the remaining units to be reserved for low-income populations. All funds used for the remaining uses, including TBRA, supportive services, and NCS, must assist qualifying individuals and families.
HOME-ARP Project Referral Methods - Use of Coordinated Entry (CE) Participating jurisdictions (PJ) may, but are not required to, use the coordinated entry system (CES) for HOME-ARP project and service referrals. If the PJ elects to use a CoC’s CES, all HOME-ARP qualifying populations must be included and accepted.
CES and Other Referral Methods: Outside referral methods and project waiting lists may be used in conjunction with CES; however, prioritization criteria must be approved by the PJ.
Application Requirements – HOME-ARP Allocation Plan
To receive the balance of its HOME-ARP funding, each PJ must submit a HOME-ARP allocation plan, developed in consultation with the local Continuum of Care (CoC) and other public stakeholders.
LAHSA will provide a webinar on at 1:00PM on Wednesday, February 9th, for participating jurisdictions to review the content of this memo. LAHSA will also host forums to follow up on the allocation plans created by each PJ, provide consultation on allocation plans, and identify opportunities for collaboration and technical assistance with implementation. Forums will be held for each region and will include lead Coordinated Entry System (CES) providers as well as local Councils of Government (COG). Participation in this webinar following forums will serve as the consultation process for the Los Angeles Continuum of Care. PJs are welcome to consult further with the LA CoC if they choose and want to have a more indepth consultation with LAHSA staff.
CoC Participation: HOME-ARP allocation plans must be developed in consultation with the local CoC and other service agencies that assist qualifying populations including, but not limited to, local homeless and domestic violence service providers, veterans’ groups, and public housing agencies. Note that while participating jurisdictions are required to consult with each CoC operating within their jurisdiction, state participants do not have the same requirement. Submitted plans must describe the consultation process, participating agencies, and include summary of feedback.
In addition to CoC and service provider engagement, PJs are required to provide opportunities for public participation.
Additional Plan Requirements: Additionally, each HOME-ARP allocation plan must include a local Gaps Analysis, a description of HOME-ARP activities and distribution methods, affordable housing production goals, preferences, and refinancing guidelines, when applicable.
Gaps Analysis/Needs Assessment: The mandatory Gaps Analysis/Needs Assessment must describe the scale of unmet housing and service need within the participating jurisdiction, using recent Point in Time Count data and other data available through the local CoC. More specifically, assessments must give insight into the size and demographic composition of the qualifying populations, unmet needs within each qualifying population, and gaps within the local shelter and housing inventory and across the service delivery system.
Overview of Eligible Uses
The budget period for HOME-ARP grants begins on the Federal Award date and ends on September 30, 2030. The performance of each PJ regarding the use of HOME-ARP funds will be reviewed by HUD and may include, but not be limited to the following forms: remote or on-site monitoring, assessment of documents, and inquiries from sources of relevant information (e.g. audit reports, media reports, citizen complaints).
Rental Housing: HOME-ARP funds can support the acquisition, rehabilitation, and development of affordable rental housing, which includes single room occupancy (SRO) units and permanent supportive housing (PSH). Though funding reserved for this category may not be used for development of temporary housing, such as shelter or non-congregate shelters in hotel and motel settings, HOME-ARP may be used to fund the acquisition of those sites for more permanent housing use.
Tenant-Based Rental Assistance: HOME-ARP can also be used to provide tenant-based rental assistance to qualifying households, which may be used to cover rental costs in a HOME-ARP project or other eligible rental unit. Rental assistance, as well as security and utility deposits are all eligible costs under HOME-ARP TBRA. In contrast with the established HOME program, the maximum term for a rental assistance contract is at the discretion of the PJ or active until the end of the lease, after which assistance can be renewed should funding be available. PJs additionally have the discretion to set maximum amount for HOME-ARP TBRA, which may cover up to 100% of eligible costs.
Supportive Services: Additionally, HOME-ARP can fund a broad range of supportive services including supportive services as defined by McKinney Vento, homeless prevention programs, and housing counseling services. PJs are responsible for ensuring that individuals and families are only receiving HOME-ARP services as needed, and that there is no duplication of services received by the participant.
The notice states that this may request use of HMIS and coordination with CoCs and other service providers.
Non-Congregate Shelter (NCS): HOME-ARP grant funds may be used for the acquisition and development of non-congregate shelter (NCS). Operating expenses are not an eligible cost under HOMEARP. PJs are encouraged to use CE for referrals to HOME-ARP NCS to ensure that all HOME-ARP services can be coordinated effectively. Depending on the type of project and funding amount, there is a minimum period of time that the site must operate as a NCS.
The law authorizes HOME-ARP-funded NCS to be converted into permanent affordable housing or CoC PSH after the minimum use period. During the restricted use period, HOME-ARP funding may not be used to cover the cost of housing conversions.
The restricted use period varies based on the eligible activity that is being funded by HOME-ARP. More details are available in the HUD notice.
Recommendations for Use of HOME-ARP Funding
A balance of resources within the homeless services system is critical to ensure effective operations, with people experiencing homelessness able to swiftly access interim housing resources, and once accessed, move quickly from interim housing into permanent housing. As such, an appropriate balance between outreach, services, interim housing, and permanent housing is necessary to ensure that there are not significant ‘bottlenecks’ in the system that hamper a participants’ access to any one of these resources. When inadequate resources are dedicated to permanent housing, for example, participants may linger in shelter for long periods of time, which in turn blocks access to shelter for people experiencing unsheltered homelessness. LAHSA’s Homeless Services Systems Analysis recommends a ratio of five (5) permanent housing resources for every one (1) interim housing bed to ensure effective flow of the homeless services system. This need for system ‘balance’ is what underpins the recommendations put forth below.
Additionally, these recommendations are put forth in the context of an array of other resources from federal, state, and local partners, and ensuring that new resources are working in concert with each other. At the current moment, the federal government has recently allocated a total of 7,411 Emergency Housing Vouchers (EHV) and Housing Choice Vouchers (HCV) across jurisdictions within LA County (as of
November 11, 2021), which represents an unprecedented influx of tenant-based subsidies. 1 The
following recommendations emphasize the need for investments in housing resources that will leverage these existing subsidies, increasing the number of units available to utilize these subsidies. LAHSA presents the following recommendations, in descending order, with the first recommendation being the most critical to deliver a balanced homeless service system.
Acquisition
While acquisition of permanent housing resources is limited based on available funds, LAHSA highly recommends this eligible use, particularly if jurisdictions are also able to leverage other funds for purchases of multi-unit buildings, scattered site properties, or even individual units that can then serve people experiencing homelessness Because of an influx of rental subsidies within the homeless services system, units acquired by cities will be able to be quickly matched to prospective tenants that are paired with a rental subsidy.
Master Leasing
Master leasing represents another option to quickly bring housing units into the homeless system, and a way to bring more housing units to be able to be utilized by prospective tenants that have a rental subsidy matched to them. It also presents a potentially lower cost option than the acquisition of property and may be appropriate for jurisdictions with smaller awards. More information related to this recommendation will be shared at the forthcoming webinar hosted by LAHSA, as details on eligible costs for master leasing are being determined through ongoing discussions between LAHSA and HUD.
Supportive Services
LAHSA recommends funds used for supportive services as outlined in the Overview of Eligible Uses.
Supportive Services to Support Emergency Housing Vouchers: While an array of emergency housing vouchers have been allocated to public housing authorities within Los Angeles County, these vouchers do not cover costs for supportive services, highlighting a gap. To ensure effective utilization and success of EHVs, there are a number of supportive service needs. These include housing navigation services to assist with locating and securing a housing unit for people experiencing homelessness, as well as tenant retention services to support the success of tenants and landlords once they are housed using an EHV. In alignment with the information above regarding the availability of subsidies, this recommendation encourages the use of funds to pair supportive services with EHVs, namely Navigators.
Problem-Solving: It is estimated that problem-solving, prevention, and diversion could prevent 20% of households from having need of interim housing or accessing the homeless services system.2 With consideration of that estimate, LAHSA supports the utilization of problem-solving (also known as diversion), which is a crisis response strategy to identify and access alternative housing resources outside of the homeless services system. This person-centered, short-term housing intervention focuses
1 Jurisdictions that have received Emergency Housing Vouchers include: Los Angeles County Development Authority (LACDA), Housing Authority of the City of Los Angeles (HACLA), Baldwin Park, Burbank, Compton, Hawthorne, Inglewood, Norwalk, Pomona, Pasadena, Redondo Beach, Santa Monica, South Gate, and Torrance.
LACDA is also a recipient of Housing Choice Vouchers.
2 Los Angeles Homeless Services Authority. (2019). Homeless Services System Analysis: Envisioning an Optimal System in Los Angeles. https://www.lahsa.org/documents?id=4311-homeless-services-system-analysis-envisioningan-optimal-system-in-los-angeles
on maintaining current housing or identifying options within an existing social network.3This approach could include flexible, one-time financial assistance. LAHSA also encourages the use of Homelessness Prevention, which provides programmatic support to prevent individuals and families from entering the homeless services system.
Appendix A. HOME-ARP Allocations by Jurisdiction
American Rescue Plan Act HOME Allocations
Alhambra $2,063,172 Lynwood $1,967,319
Baldwin Park $1,128,365 Montebello $1,088,774
Bellflower $1,301,749 Monterey Park $1,175,039
Burbank $1,896,632 Norwalk $1,231,940
Compton $1,988,847 Palmdale $2,093,968
Downey $1,593,133 Paramount $1,087,336
El Monte $2,413,008 Pasadena $3,042,435
Gardena $1,040,280 Pomona $3,190,091
Glendale $5,109,346 Rosemead $1,222,084
Hawthorne $2,166,698 Santa Clarita $1,913,298
Huntington
Park
$2,180,103 Santa Monica $2,220,124
Inglewood $3,108,579 South Gate $2,584,579
Lancaster $2,450,524 Torrance $1,710,939
Long Beach $10,240,858 Whittier $1,265,320
Los Angeles $99,891,031 Total $196,980,351
Los Angeles
County
$32,614,780
3 Los Angeles Homeless Services Authority. (2019). Problem-Solving: A Humanistic Approach to Ending Homelessness. https://www.lahsa.org/news?article=586-problem-solving-a-humanistic-approach-to-endinghomelessness