Topic Question
Allocation Plan

Are PJs required to make changes to the most recently approved consolidated plan to ensure "consistency with the plan"?

No, PJs are not required to make changes to the most recently approved consolidated plan. Further, the HOME-ARP Notice does not require PJs to submit a certification that its HOME-ARP allocation plan is consistent with the consolidated plan. The required certifications are listed in the HOME-ARP Notice (page16).

Allocation Plan
Allocation Plan

How can I access the optional HOME-ARP allocation plan template?

The optional HOME-ARP allocation plan template can be accessed on the HOME-ARP webpage on HUD.gov, under "Fact Sheets" or on the HUD Exchange under "Resources".

Allocation Plan
Allocation Plan

May a PJ use HOME-ARP funds prior to HUD’s acceptance of the HOME-ARP allocation plan to pay a contractor to prepare the PJ’s HOME-ARP allocation plan where the contractor is not responsible for administering the PJ’s entire HOME-ARP grant?

No. While PJs are permitted to use up to 5% of their HOME-ARP award for eligible administration and planning costs prior to HUD’s acceptance of the PJ’s HOME-ARP allocation plan, from the obligation date of the HOME-ARP grant and prior to HUD’s acceptance of the PJ’s HOME-ARP allocation plan, a subrecipient or contractor to the PJ may only incur and expend HOME-ARP funds for eligible administration and planning costs on...
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Citizen Participation Plan

Are PJs required to amend their citizen participation plans to take advantage of the reduced public comment period permitted in the Notice?

No, a PJ is not required to amend its citizen participation plan to change the public comment period to a 15-day public comment period, as permitted by the HOME-ARP Notice (page 13). The HOME-ARP Notice Appendix includes a waiver and alternative requirement to waives Section 105 and 107 of the Cranston-Gonzales National Affordable Housing Act (42 USC 12705 and 12707) and the citizen participation plan requirements at 24 CFR 91.105, 91.115, and...
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Consultation

If a PJ consulted with the required organizations during the development of its FY 2021 consolidated plan or annual action plan, must the PJ consult again?

Yes, prior to the development of its plan, a PJ must consult with the required agencies and service providers described in the HOME-ARP Notice (page 13) to identify unmet needs and gaps in housing or service delivery systems. These consultations enable the PJ to specifically discuss the unmet needs and identify gaps in the housing, shelter, and service system for the HOME-ARP qualifying...
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Consultation

How does a PJ demonstrate consultation?

A PJ must consult with agencies and service providers as described in the HOME-ARP Notice (page 13). Then in its allocation plan, a PJ must provide a list of the organizations consulted, identify the type(s) of each organization (e.g., CoC, public housing agency (PHA), homeless service provider, etc.), describe the method(s) of consultation (e.g., virtual meeting, stakeholder session, survey, or questionnaire, etc.), and summarize the feedback,...
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Consultation-Agencies/Service Providers

Can one organization or agency qualify as more than one type of organization listed under required consultations in the Notice?

Yes, one organization may be categorized as more than one type of organization identified in HOME-ARP Notice (page 13). However, PJs are encouraged, whenever possible, to exceed the minimum consultation requirements and consult with additional organizations to secure broad and sufficient input for the needs assessment and gap analysis in the design of the PJ’s strategy for distributing HOME-ARP funds for eligible...
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eCon Planning Suite

Is a PJ required to set up action plan projects in the eCon Planning Suite for HOME-ARP?

PJs may, but are not required to, set up HOME-ARP action plan projects in the eCon Planning Suite in the Integrated Disbursement and Information System (IDIS). If a PJ opts to set up a HOME-ARP action plan project, the PJ must amend its FY 2021 annual action plan to do so. A PJ may then set up a HOME-ARP administration and planning activity, but not any other HOME-ARP eligible activities, in IDIS under the new HOME-ARP project prior to...
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Needs Assessment

How recent must data be to be considered "current data" as described in the Notice?

Current data are the most recent data sources available to the PJ. As of the October 2021, the most current data include but are not limited to:

  • 2019 American Community Survey (ACS) 5-year estimates
  • 2014-2018 Comprehensive Housing Affordability Strategy (CHAS) data
  • 2020 Point-in-Time Count
  • 2020 Housing Inventory Count
Needs Assessment
Preferences

Is a PJ required to establish preferences for qualifying populations?

No, PJs are not required to establish preferences among qualifying populations. However, if a PJ does not establish preferences or a method of prioritization in the allocation plan, then the PJ must admit individuals and families from any qualifying population to rental housing or non-congregate shelter and provide TBRA or supportive services in chronological order based on a written waiting list insofar as is practicable. The requirements for...
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Preferences

If a PJ intends to use the CoC’s coordinated entry process to admit qualifying populations to HOME-ARP projects and activities, what is the PJ required to include in its HOME-ARP allocation plan?

The HOME-ARP Notice (page 10) requires that a PJ may only permit a Continuum of Care’s coordinated entry process (CE) to determine the eligibility of HOME-ARP qualifying populations and rank individuals and families for HOME-ARP assistance based on the preferences and/or method of prioritization specified by the PJ. Consequently, if the PJ intends to use the CoC CE or use the CoC CE with other referral methods for any HOME-ARP eligible...
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Production Goals

How should a PJ determine its HOME-ARP production goals in the HOME-ARP allocation plan? How should a PJ determine its HOME-ARP production goals in the HOME-ARP allocation plan?

Section V.C.3 of CPD Notice 21-10 requires on page 15 that a PJ must: 1) estimate the number of affordable rental housing units for qualifying populations it expects to produce or support with its HOME-ARP allocation; 2) specify the affordable housing goal it plans to achieve, and 3) describe how this goal and the affordable rental housing estimate will address the priority needs described earlier in its HOME-ARP allocation plan. To derive an...
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Submission and Review Requirements

Is there a deadline for submission of the HOME-ARP allocation plan?

No, there is not a deadline for submitting the HOME-ARP allocation plan. PJs should make best efforts to plan for the use of HOME-ARP funds expeditiously and deliberately while ensuring compliance with the consultation and public participation requirements in the HOME-ARP Notice (page 13). However, if the PJ does not submit a HOME-ARP allocation plan or if the PJ’s plan is not accepted within a reasonable period of time, as determined by...
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Submission and Review Requirements

Can a PJ submit its HOME-ARP allocation plan as an amendment to a different fiscal year’s annual action plan (other than FY 2021)?

No, The HOME-ARP Notice (pages 16-17) requires that PJs submit the HOME-ARP allocation plan to HUD in the eCon Planning Suite in the Integrated Disbursement and Information System (IDIS) as an amendment to the PJ’s FY 2021 annual action plan. PJs are not permitted to submit the allocation plan as an amendment to a different fiscal year’s action plan.

Submission and Review Requirements
Submission and Review Requirements

How does a PJ upload the HOME-ARP allocation plan in the eCon Planning Suite in the IDIS?

To submit the HOME-ARP allocation plan, PJs must take the following steps in Integrated Disbursement and Information System (IDIS) to make an amendment to their plan: Steps to Amend a Year 1 Annual Action Plan Go to Plan/Projects/Activities in the Main Menu. Click under the "Consolidated Plans" submenu. Click <Search> to bring up all existing consolidated plans. Locate the FY 2021 plan. This plan will have an...
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Submission and Review Requirements

Where are the required HOME-ARP certifications posted?

The HOME-ARP certifications can be accessed on the HOME-ARP webpage on HUD.gov, under "Fact Sheets" or on the HUD Exchange under "Resources".

Submission and Review Requirements
Activities

Are there any instructions on how to set-up a HOME-ARP Administration Activity in IDIS? Do we need to amend our 2021 Annual Action Plan (AAP) in order to do this?

Yes, please see HUD’s Fact Sheet on Accessing HOME-ARP Funds . PJs may, but are not required to, set up HOME-ARP action plan projects in the eCon Planning Suite by amending the FY 2021 annual action plan. If a PJ does not set up a HOME-ARP action plan project, the PJ may associate its HOME-ARP Administration activity with a FY 2021 HOME project. All HOME-ARP activities must be associated with a 2021 Program Year "Annual Action Plan...
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Activities

What Plan Year and Project do I use for setting up my HOME-ARP activities?

A PJ must associate its HOME-ARP activities with a Project from its 2021 Annual Action Plan (AAP) year. The PJ can choose from three options for setting up a HOME-ARP Project or Projects: Option 1: Create one new HOME-ARP Project and associate all HOME-ARP activities under the single HOME-ARP Project. This option requires amending the 2021 AAP. Option 2: Create multiple HOME-ARP Projects (according to whatever standard convention or system the...
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Reports

Will there be separate HOME-ARP reporting requirements in IDIS? When will these be available?

Yes, there will be reports unique to HOME-ARP in IDIS. You can find the existing guidance on reporting requirements in the HOME-ARP Notice Section VIII.G. Several reports will become available in Fall 2021, but most will become available in Spring 2022.

Reports
Admission and Occupancy Requirements

Does HOME-ARP require a PJ to limit occupancy of HOME-ARP NCS units to a defined length of stay because the HOME-ARP Notice defines NCS as temporary shelter?

No. HOME-ARP does not require PJs to establish limits on the length of stay by occupants of HOME-ARP NCS units though HOME-ARP NCS is subject to local and state building codes or ordinances which may require owners or operators of NCS to do so. NCS is not intended as permanent housing as its purpose is to provide temporary shelter until an individual or household can obtain transitional or permanent housing. PJs and owner/operators of HOME-ARP...
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Admission and Occupancy Requirements

Are programmatic agreements for occupancy in an NCS unit considered to be a lease or occupancy agreement?

The HOME-ARP Notice (page 55) states that NCS is temporary shelter that does not require occupants to sign a lease or occupancy agreement. Programmatic agreements that do not qualify as a lease or occupancy agreement under state or local law and do not set terms for tenancy or occupancy, including but not limited to specifying a length of stay or requiring payment of fees or charges for occupancy, are not considered a lease or occupancy...
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Eligible Activities

Can a PJ provide HOME-ARP funds for the development of a multifamily project with both NCS and permanent affordable rental housing units?

Yes, PJs can use HOME-ARP funds on a project with a mix of unit designations. However, if a PJ intends to fund a development that contains both HOME-ARP NCS and HOME-ARP rental units, the PJ must set the property up in IDIS as two separate activities and conduct cost allocation in accordance with 24 CFR 92.205(d)(1) to ensure that the costs of the two activities are separately identified, tracked, and documented. Both the HOME-ARP NCS and...
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Property and Habitability Standards

Are tiny house villages, defined as a community of small self-contained dwelling units co-located on a shared property, eligible for HOME-ARP funds as a form of NCS?

Yes, if such units meet the requirements for HOME-ARP NCS in the HOME-ARP Notice. Any NCS unit developed with HOME-ARP funding, including those developed as part of a tiny house village must meet the requirements in the HOME ARP Notice. Please note that units that lack in-unit sanitary facilities and rely on centralized facilities do not meet HOME-ARP NCS property standards and are not eligible for HOME-ARP funds. In-unit sanitary facilities...
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Property and Habitability Standards

Can PJs acquire and rehabilitate single family homes into NCS with multiple self-contained units with in-unit sanitary facilities?

Yes, if such units comply with the HOME-ARP NCS requirements, including local codes, and ordinances. HOME-ARP NCS permits one or more buildings that provide private units or rooms as temporary shelter to individuals and families. PJs may acquire and/or rehab single-family homes into NCS to serve multiple households in compliance with all the requirements in the HOME ARP Notice.

Property and Habitability Standards
Property and Habitability Standards

Can a PJ develop NCS units that share sanitary facilities (i.e. dormitory style in which more than one unit has access to the same bathroom)?

No. The minimum HOME-ARP property standards found in Section VI.E.7.a of the HOME-ARP Notice require in-unit sanitary facilities that are in proper operating condition and are adequate for personal cleanliness and the disposal of human waste. The costs of rehabilitating or constructing a building to meet these standards is an eligible HOME-ARP...
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Property and Habitability Standards

Can HOME-ARP funds be used to furnish NCS units as part of its new construction or rehabilitation?

Yes. The costs associated with meeting the Minimum Home-ARP NCS Property Standards established in Section VI.E.7 of the HOME-ARP Notice (page 60) are eligible if they are part of a development or rehabilitation budget and are a one-time cost to place the units into service. This may include basic furnishings to create, “…an acceptable, individual room to sleep which includes space and security for themselves and their...
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Property and Habitability Standards

Do the HOME-ARP Property and Habitability Standards in section VI.E.7. of the HOME-ARP Notice establish a minimum square footage or required configuration for a NCS "room" or "unit"?

No. The HOME-ARP Property and Habitability Standards in section VI.E.7. of the HOME-ARP Notice do not specify room size or a required configuration for NCS units. All HOME-ARP NCS projects must meet the minimum HOME-ARP property standards at section VI.E.7.a of the HOME-ARP Notice (page 60) prior to occupancy and the ongoing property standards throughout the restricted use period. Specific requirements for NCS units are determined by the type...
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Non-profit Subgrantees

I am a non-profit and would like to apply for funding for eligible activities. How do I do this?

Participating Jurisdictions will lay out their funding priorities and application process in their HOME-ARP Allocation Plan. Non-profits and other eligible organizations may reach out to their local PJ for more information. You can find information regarding PJ allocations and contact information on the HOME-ARP...
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Program Requirements

What is the difference between the CHDO set-aside in the HOME program and the non-profit operating and capacity building assistance allowable in HOME-ARP?

PJs are not required to set aside any of their HOME-ARP allocation for community partners, such as Community Housing Development Organizations (CHDOs), or for any specific eligible activity. This is a key difference from the HOME Program, which requires PJs to set aside 15% of their HOME grant for CHDOs to use for specific activities. However, a PJ may use up to 5 percent of its HOME-ARP allocation to pay operating expenses of CHDOs and other...
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Program Requirements

Do non-profits receiving operating or capacity building assistance need to be CHDOs? Is there any other sort of certification they must meet?

No, non-profits do not need to be CHDOs in order to receive non-profit operating and/or capacity building assistance. The HOME-ARP Notice only specifies that the PJ must reasonably expect to provide HOME-ARP funds to the organization for any of the eligible HOME-ARP activities within 24 months of the award.

Program Requirements
Program Requirements

For annual limitations on the amount of nonprofit operating assistance, is the fiscal year that of the nonprofit, the PJ, or HUD?

Annual limitations are based on the non-profit's fiscal year.

Program Requirements
Program Requirements

Can a PJ give a CHDO HOME operating assistance and HOME-ARP operating assistance? If so, are the funds aggregated for the threshold of 50% operating costs or $50,000? Can a PJ give a CHDO HOME operating assistance and HOME-ARP operating assistance? If so, are the funds aggregated for the threshold of 50% operating costs or $50,000?

Yes, a nonprofit may receive both HOME CHDO operating assistance and HOME-ARP operating assistance, and each program’s regulations limiting the amount of assistance would apply separately. Note that unlike the HOME program, the HOME-ARP program does not require PJs to set aside funding for CHDOs. However, PJs may give capacity building and/or operating assistance to CHDOs and nonprofit organizations. For additional information on the...
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Administrative Expenses

PJs are permitted to use 5% of their grant allocation for eligible administrative planning costs prior to approval of the Allocation Plan. Is this 5% in addition to the 15% allowable for administrative and planning costs or part of the 15%?

No, the 5% available before approval of the Allocation plan is not in addition; it is included in the total 15% of the grant allowable for administrative and planning costs. Please see Section VI.A. of the HOME-ARP Notice for additional details.

Administrative Expenses
Administrative Expenses

How does our PJ access the 5% administrative funds for planning?

After HUD receives the executed HOME-ARP grant agreement, PJs will have access to the 5% administrative funds in IDIS. PJs must then create an Administration and Planning Activity in IDIS and associate it with a 2021 Annual Action Plan project. It can fund the activity and drawdown funds for eligible expenses. Note that the remaining grant amount, including the remaining 10 percent administrative and planning set-aside funds, will not be...
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Administrative Expenses

Can HOME administrative funds be used to cover the administrative costs, such as salary, for staff working on HOME-ARP?

No. HOME and HOME-ARP administrative funds cannot be used interchangeably. HOME-ARP administrative costs must be charged to HOME-ARP.

Administrative Expenses
Administrative Expenses

Are subgrantees allowed to receive administrative funds for their use to administer their activity/project, even if they are not administering the entire HOME-ARP grant for the PJ?

PJs may provide all or a portion of its HOME-ARP administrative funds to subrecipients and contractors that are administering activities on behalf of the PJ (e.g., CoC entity, other non-Federal entity), in accordance with the requirements in the Notice. However, note that subrecipients are public agencies or nonprofits that administer all or some of the PJ's programs. A public agency or nonprofit that receives HOME-ARP to be the developer or...
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Administrative Expenses

Are bank charges associated with opening the HOME -ARP local account eligible as an administrative cost?

Yes, if they are reasonable and necessary costs under 2 CFR part 200.404.

Administrative Expenses
CFDA Number

What is the CFDA number for HOME-ARP?

The CFDA number for HOME-ARP is 14.239: HOME Investment Partnerships Program.

CFDA Number
Eligible Activities

What is the difference between "general" nonprofit operating expenses and operating expenses for a project? Specifically, does paying the salary of staff people working on putting together an ARP project considered general? Can you provide an example?

HOME-ARP can be used to pay for two distinct types of operating assistance: 1. operating assistance in HOME-ARP rental housing, and 2. non-profit operating assistance. Operating assistance in HOME-ARP rental housing is specific to a project to address rental income shortfalls of the HOME-ARP units restricted for qualifying households during the compliance period. It must be included in the project’s underwriting. These funds can either be...
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FFATA Reporting

Are HOME-ARP funds subject to FFATA reporting? Are HOME-ARP funds subject to FFATA reporting?

Yes, HOME-ARP funds are subject to FFATA reporting requirements. Please see additional detail on the Federal Funding Accountability and Transparency Act (FFATA) webpage.

FFATA Reporting
Local Account

What sort of bank account should the PJ use for its HOME-ARP funds?

The HOME-ARP Notice specifies that the PJ must establish a HOME-ARP Investment Trust Fund local account (local account) that is interest bearing. PJs may not use their local HOME local account for the HOME-ARP local account. The HOME-ARP local account may be either a separate account or a subsidiary or sub-account account within its general fund (or other appropriate fund). While the bank account itself does not have to be separate, there must...
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Local Account

What steps should a PJ take after creating a new HOME-ARP local account so the draws can be received? What steps should a PJ take after creating a new HOME-ARP local account so the draws can be received?

If the PJ creates a new bank account, it must send a completed SF1199a to the local HUD field office.

Local Account
Program Income

The HOME-ARP Notice states that HOME-ARP Program Income (PI) is HOME PI and must be used in accordance with HOME program requirements. Should HOME-ARP PI be deposited in the HOME-ARP local account or HOME local account? How is it marked in IDIS? What are the eligible expenses and populations?

Program income generated from HOME-ARP should be deposited in the HOME-ARP local account and recorded in IDIS as HOME program income. The PJ must expend these funds for HOME eligible activities. For additional information about eligible HOME activities, please visit the HOME page

Program Income
Program Income

Under what circumstances can a subrecipient or State recipient retain PI? What must be included in the written agreement and how is this documented in IDIS?

The PJ may allow a State recipient or subrecipient to retain the program income for additional HOME projects (if this is specified in the written agreement in accordance with the terms and conditions specified in Section VIII.B. of the HOME-ARP Notice and 24 CFR 92.504). In this case, the PJ must enter HOME-ARP program income retained by the State recipient or subrecipient as a HOME program income receipt in IDIS and subgrant the program income...
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Program Income

Are funds remaining in an operating reserve at the end of the compliance period considered PI? What happens to these funds?

Any HOME-ARP funds remaining in a rental project's operating cost assistance reserve must be returned to the PJ if at the end of the HOME-ARP budget period (Sept 30, 2030), the project will not continue to operate in accordance with the HOME-ARP requirements. The returned funds are considered HOME program income and can be used in accordance with the HOME program requirements.

Program Income
Record Keeping

How long should records be kept?

All records must be kept for five years, however there are some exceptions: For HOME-ARP rental housing projects, records may be retained for five years after the project completion date; except that records of individual tenant income verifications, project rents and project inspections must be retained for the most recent five-year period, until five years after the affordability period terminates. For HOME-ARP TBRA projects, records must be...
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Technical Assistance

Will technical assistance (TA) be available from HUD to help PJs with different aspects of the HOME-ARP grant? What sorts and how do we request it?

Yes, technical assistance is available for recipients of HOME-ARP funding. To request in-depth assistance, see the Request Program Assistance page on HUD Exchange. Before requesting TA, review the HOME-ARP page on HUD-Exchange to view Fact Sheets, recorded trainings, and other resources. Sign up for the HOME-ARP Mailing List to find out about additional TA, training, and publications as they become...
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Content current as of July 21, 2022.