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
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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
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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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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 behalf of the PJ, if the subrecipient or contractor is responsible for administering the PJ’s entire HOME-ARP award and the PJ complies with the requirements in the HOME-ARP Notice (e.g., PJ has executed a HOME-ARP written agreement that complies with 24 CFR 92.504 and the PJ describes the subrecipient or contractor’s responsibilities in its HOME-ARP allocation plan).
A PJ may still use non-HOME-ARP funds to pay eligible administration and planning costs incurred by a subrecipient or contractor that is not administering the PJ’s entire HOME-ARP grant and reimburse these costs from HOME-ARP funds after HUD has accepted the HOME-ARP allocation plan.
As the HOME-ARP Notice does not permit the PJ to carry out any other activities other than administration and planning prior to HUD’s acceptance of the HOME-ARP allocation plan, a PJ may not reimburse itself for costs incurred (prior to HUD’s acceptance of the HOME-ARP allocation plan) for activities other than administration and planning.
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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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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 91.401, and imposes the alternative requirements described in the HOME-ARP Notice (pages 67 and 68 of the Appendix). Per the waiver and alternative requirement, a PJ is required to follow its adopted requirements for “reasonable notice and opportunity to comment” for plan amendments in its current citizen participation plan except for where its plan conflicts with the alternative requirements of the Appendix. Consequently, a PJ is not required to amend its current citizen participation plan because the Appendix permit a reduced public comment period of 15 days and requires one public hearing during the development of the HOME-ARP allocation plan prior to submission to HUD.
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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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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 populations.
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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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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, information, or data received from these entities. The optional HOME-ARP Allocation Plan Template includes a suggested table format for demonstrating compliance with the consultation requirements. As described on page 13 of the HOME-ARP Notice, at a minimum, PJs must consult with the following organizations: the CoC(s) serving the PJs geographic area; homeless and domestic violence service providers; veterans’ groups, all public housing agencies (PHAs) serving the PJ’s geographic area; public agencies that address the needs of qualifying populations; and, public or private organizations that address fair housing, civil rights, and the needs of persons with disabilities. Please note that State PJs are not required to consult with every PHA or CoC within its boundaries. However, local PJs must consult with all PHAs (including statewide or regional PHAs) and CoCs serving the jurisdiction.
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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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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 activities
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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 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 submitting the...
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PJs may, but are not required to, set up HOME-ARP action plan projects in the eCon Planning 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 submitting the amendment (i.e., its HOME-ARP allocation plan) for HUD review. If a PJ chooses not to set up a HOME-ARP action plan project, the PJ may set up its HOME-ARP activities under any FY 2021 HOME action plan project. However, only a HOME-ARP administration and planning activity may be set up in IDIS prior to the PJ’s submission of its HOME-ARP allocation plan. Please see the Creating HOME-ARP Projects and Activities in IDIS Fact Sheet for additional details.
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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
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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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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 the use of a project or activity waiting list are on page 11 of the HOME-ARP Notice. If the PJ does not establish preferences in its HOME-ARP allocation plan and uses a project or activity waiting list, individuals and families referred by a Continuum of Care’s coordinated entry process must be placed on the waiting list and admitted in chronological order. In addition, if a PJ has not established preferences in its HOME-ARP allocation plan, the PJ may not limit eligibility to subpopulations of the qualifying populations as described on pages 11-12 of the HOME-ARP Notice.
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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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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 activity or project, the PJ must establish and approve the prioritization applied by the CoC CE or the use of the CoC CE with other referral methods in accordance with the HOME-ARP allocation plan. In addition, the PJ must comply with the requirements for preferences, referral methods, and limiting eligibility to subpopulations, if applicable, in the HOME-ARP Notice (pages 9-12).
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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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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 estimated number of affordable housing rental units, the PJ should consider the following:
- the amount of HOME-ARP funds it plans to allocate to the HOME-ARP rental housing activity
- availability of other funding sources to finance the project(s) and any income or other restrictions associated with those funding sources (e.g., LIHTC)
- the housing characteristics required by qualifying population(s) (e.g., unit sizes, amenities)
- the estimated per unit development costs
- availability and capacity of developers/owners to undertake/complete the project(s) and availability of HOME-ARP sponsors to provide housing or other supportive services (e.g., sublease of units to HOME-ARP households)
- the amount of HOME-ARP funding required for operating assistance reserves to achieve project sustainability and meet the needs of the qualifying populations
When finalizing its affordable rental housing production goal, the PJ must take into consideration the qualifying population(s) the PJ plans to assist, and the priority needs identified during its consultation process and gaps analysis/needs assessment review.
The PJ should keep in mind that:
- the estimated number of units should be reasonable in relation to the amount of HOME-ARP funds allotted for affordable rental housing development. If the PJ anticipates needing to provide a significant amount of HOME-ARP funds for operating assistance reserves to serve qualifying populations, this will reduce the amount of HOME-ARP available to support the development of new affordable rental units.
- the goal should be appropriate, taking into consideration the priority needs of the qualifying population(s)
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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
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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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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 "Amend" and "View" link under the "Action" column.
- Click <Amend> under the "Action" column.
- Click <I Agree> in the "Confirmation of Amendment" window. After a PJ selects the "I Agree" button, the system will reopen the plan for editing and change the status to "Open ñ Amendment."
- On the AD-25 screen, modify the "Title" as needed. Select the substantial amendment type from the "If Amendment" dropdown menu.
- Provide a brief description of the purpose of the amendment in the text box.
- Upload the HOME-ARP allocation plan as an attachment next to the "HOME-ARP allocation plan option" (See note below)
- Click the "Save and Return" button to return to the Consolidated Plan menu screen.
- When the amendment is complete, return to the AD-25 Administration screen and change to plan status to "Submitted for Review." The HOME-ARP allocation plan must be submitted for review by HUD.
Steps to Amend Year 2-5 Annual Action Plan
- Go to Plan/Projects/Activities in the Main Menu. Click <Search> under the "Annual Action Plans" submenu.
- Click <Search> to bring up all existing annual action plans. Locate the approved FY 2021 plan. This plan will have an "Amend" and "View" link under the "Action" column.
- Click <Amend> under the "Action" column.
- Click <I Agree> in the "Confirmation of Amendment" window. After a PJ selects the "I Agree" button, the system will reopen the plan for editing and change the status to "Open ñ Amendment."
- On the AD-26 Administration screen, modify the "Title" as needed. Select the substantial amendment type from the "If Amendment" dropdown menu.
- Provide a brief description of the purpose of the amendment in the text box.
- Upload the HOME-ARP allocation plan as an attachment next to the "HOME-ARP allocation plan option" (See note below)
- Click the <Save and Return> button to return to the Annual Action Plan menu screen.
- When the amendment is complete, return to the AD-26 Administration screen and change to plan status to "Submitted for Review." The HOME-ARP allocation plan must be submitted for review by HUD.
PJs are not required to make any other edits to the FY 2021 annual action plan or applicable consolidated plan screens in the eCon Planning Suite.
Note: The HOME-ARP allocation plan attachment point will be available to PJs in IDIS following the November 2021 IDIS updates release.
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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
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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...
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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.
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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
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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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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 NCS may choose to establish limits on an occupant’s length of stay, subject to local and state codes and ordinances and may develop guidelines for operation of NCS in accordance with the requirements established in section VI.E. of the HOME-ARP Notice.
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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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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 agreement.
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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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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 affordable rental units must meet the requirements in the HOME-ARP Notice. The written agreement must clearly identify and describe the project. Additional guidance will be developed on conducting cost allocation for HOME-ARP NCS units when combined with other non-HOME-ARP sources of funding.
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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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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 are required for every HOME-ARP NCS unit.
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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
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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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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 cost.
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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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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 belongings.” Basic furnishings that are integral to an NCS room or unit include: beds, seating, storage cabinetry, lighting.
However, replacement costs of furnishings once the units are in service are operating costs and HOME-ARP funds cannot be used to pay for these costs.
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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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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 of project (rehabilitation or new construction) and the PJs local code requirements or, in the absence of local codes, the International Residential Code or the International Building Code (as applicable).
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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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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 webpage.
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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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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 nonprofit organizations that will carry out activities with HOME-ARP funds.
A PJ may also use up to an additional 5 percent of its allocation to pay eligible costs related to developing the capacity of eligible nonprofit organizations to successfully carry out HOME-ARP eligible activities. For additional information on non-profit operating and capacity building assistance, see Section VI.F. of the HOME-ARP Notice.
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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
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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
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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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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 amount of HOME-ARP nonprofit operating and capacity building assistance that a nonprofit may receive annually, see Section IV.F. of the HOME-ARP Notice.
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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
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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...
↓ Read More. Administrative Expenses
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 available to commit or drawdown until HUD reviews and accepts the PJ’s HOME-ARP Allocation Plan.
Please see HUD’s Fact Sheet on Accessing Your HOME-ARP Administrative and Planning Funds.
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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
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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...
↓ Read More. Administrative Expenses
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 owner of a housing project or non-congregate shelter is not a subrecipient. Only subrecipients and contractors who are responsible for use of the PJ’s entire HOME-ARP award may incur and expend HOME-ARP funds for eligible administrative and planning costs prior to HUD’s acceptance of the PJ’s HOME-ARP Allocation Plan. The subrecipient or contractor must have an executed HOME-ARP written agreement that complies with 24 CFR 92.504 and the Notice.
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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
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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
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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...
↓ Read More. Eligible Activities
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 used to provide ongoing operating cost assistance or to form a capitalized operating cost assistance reserve. These funds may be used to cover staff salaries. For additional details, please see Section VI.B.5.g. of the HOME-ARP Notice.
PJs may use up to 5% of its allocation to award operating expense assistance to nonprofit organizations if it reasonably expects to provide HOME-ARP funds to the organizations for any of the eligible HOME-ARP activities within 24 months of the award. These funds must be used for "general operating costs" of the nonprofit organization and must not have a particular final cost objective, such as a project or activity, or must not be directly assignable to a HOME-ARP activity or project. For example, the actual costs of implementing a specific activity or project, including staff costs to deliver supportive services or administer HOME-ARP TBRA, are considered HOMEARP project delivery costs or project soft costs and are not eligible costs under Nonprofit Operating Assistance. For additional information on nonprofit operating expenses, see Section VI.F.1.a. of the HOME-ARP Notice.
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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
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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...
↓ Read More. Local Account
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 be separate HOME and HOME-ARP accounts in the PJ’s accounting system and comply with the Financial Management requirements at 2 CFR 200.302.
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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
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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
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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...
↓ Read More. Program Income
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 to the State recipient or subrecipient that retained the program income. The PJ is responsible to report on the use of its program income in IDIS, including program income it allowed a State recipient or subrecipient to retain.
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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
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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...
↓ Read More. Record Keeping
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 retained for five years after the period of rental assistance terminates.
- Written agreements must be retained for five years after the agreement terminates.
- Records covering displacements and acquisition must be retained for five years after the date by which all persons displaced from the property and all persons whose property is acquired for the project have received the final payment to which they are entitled in accordance with 24 CFR 92.353.
- If any litigation, claim, negotiation, audit, monitoring, inspection, or other action has been started before the expiration of the required record retention period records must be retained until completion of the action and resolution of
Please see Section VIII.F. of the HOME-ARP Notice for additional details.
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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...
↓ Read More. Technical Assistance
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 available.
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