Changes to HUD CoC Policies that affect Rapid Re-housing programs
Understanding the New CoC Policy Waivers
In light of the COVID-19 pandemic, Rapid Re-housing programs must adjust their policies and protocols in order to accommodate new social distancing measures. HUD released waivers to Rapid Re-housing program requirements on Wednesday, April 1 to ensure that youth, landlords, and service providers can all maintain social distance while still continuing with Rapid Re-housing programs. These waivers aim to lessen the burdens the pandemic has created for service providers and ensure that youth experiencing homelessness can still access housing.
Key Takeaways:
Service Providers can now place clients in Rapid Re-housing units that are higher than Fair Market Rate (FMR), but not greater than the reasonable rent.
To place clients more quickly, service providers can now use CoC funding to pay for up to 6 months of rental and utility debts. This waiver is in place for 1 year.
Case management is no longer required monthly and can be offered on an as-needed basis for the next 2 months.
Housing inspections are no longer required to be completed in person, but should be done via videoconferencing. Once the shelter in place is lifted, the unit should be physically re-inspected.
New rapid re-housing leases don’t need to be yearly for the next 6 months, leases can be less than a year now as long as they are longer than 1 month.
In-Depth Analysis:
On April 1st, in response to the COVID-19 pandemic, HUD waived several restrictions on rapid re-housing policy that required service providers, landlords and/or clients to meet face-to-face. These waivers have been implemented to stop the spread of COVID-19 while still continuing rapid re-housing services:
In order to more rapidly house clients, service providers can now place clients in rapid re-housing units that are more costly than the Fair Market Rate, but not greater than the reasonable rent. This policy will remain in effect for 6 months.
This is especially beneficial for service providers in high-cost markets.
There is no information yet on whether or not CoC’s can continue to pay a higher rate than the FMR after 6 months have passed.
CoC funding for housing search and counseling services can now be used on for up to 6 months worth of client arrears for rent and utilities.
Service providers can now place clients who have up to 6 months in debts on rent or utilities.
They can use housing search and counseling services funding to settle these debts.
This waiver is in effect for 1 year.
Monthly case management is no longer required.
Service providers can now offer case management on an as-needed basis.
This is in effect for 2 months.
In-person unit inspections are no longer required.
Rapid re-housing staff are now required to use videoconferencing technology to virtually inspect potential rapid re-housing units.
Staff need to create a plan to physically inspect within 3 months after shelter in place orders are lifted.
This new policy is in place for 6 months.
Rapid re-housing leases are not required to be for the duration of 1 year.
This allows service providers to broaden their ability to find units.
Leases no longer have to be yearly, but they should be at least longer than 1 month.
This is in effect for 6 months.
Actions to Take Now:
To use any of these waivers, service providers need to notify their HUD Field Office’s Community Planning and Development Director via email or mail.
The notification must be sent 2 days before the service provider intends to use the waiver.
The waiver should include:
Name, Title, & Contact Info for service provider
Service area(s) affected by the disaster
When the waiver will start to be used
Which waivers will be used (official waiver names listed here)
Assess current unit inspection protocols and adjust them so that they can now be completed via videoconference.
Work with clients to determine if they will want case management for the next two months. For clients who decline, consider bringing awareness to services via email/text on a regular basis.
Important Links: