Topic Question
General

When conducting resident rent calculation, sometimes beneficiaries receive a credit instead of owing an amount payable for rent. When this occurs, may I collect the credit for payment towards the beneficiary’s utilities?

Yes, but only if the beneficiary consents. A refund/reimbursement to a HOPWA beneficiary is required when the beneficiary makes a rent payment that exceeds the applicable 30% or 10% rent cap in 24 CFR § 574.310(d). For example, this may occur when: Utilities are not included in the rent, The HOPWA beneficiary pays utilities out of his or her pocket, The amount of utilities paid by the beneficiary exceeds the PHA utility allowance, and The payme...
Read More. General
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

Can grantees place caps on the amount of STRMU assistance provided?

Grantees may establish a dollar limit or caps on the total amount of assistance provided to clients during the 52-week period selected, if applied consistently and in a non-discriminatory manner. Caps should be reasonable enough to assist clients in overcoming the pressing need and move to residential stability as soon as possible. Some communities may use the public housing authority Section 8 rent and utility standards as caps and others place ...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

How is the 21-week period calculated and tracked?

Section 858(b)(3)(B) of the AIDS Housing Opportunity Act, as amended, specifically states that assistance may not be provided to "any individual for rent, mortgage, or utilities costs accruing over a period of more than 21 weeks of an 52-week period." This publication provides guidance on ways to track STRMU assistance, thereby allowing for a period of STRMU support that is consistent with the statutory limitation. Grantees are allowed to establi...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

Is a household eligible for STRMU assistance whose sole member living with HIV/AIDS is a minor?

Yes. Written verification must be obtained and maintained in the file indicating that an adult member of the household has legal custody of the minor child, and the entire household income must be taken into consideration for purposes of income eligibility. The child must reside in the household at least 51% of the time. In this situation the adult would be considered the head of household as an affected member of the family, but the minor child ...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

What actions are needed if a client is suspected of fraud?

The HOPWA regulations (24 CFR 574.310 (e)(2)) provide guidance on terminating a client's assistance. It is unlawful to provide false information to the government when applying for "federal public benefit programs" (see Program Fraud Civil Remedies Act of 1986, 31 U.S.C. 3801-3812). Grantees are encouraged to contact their legal counsel and local HUD Field Office for guidance in addressing potential fraud by a HOPWA client. It is recommended that...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

How do requirements for lead-based paint inspections apply for STRMU?

A lead-based paint inspection is not required in all cases of STRMU assistance. Housing built before 1978 that is assisted with HOPWA dollars, where a pregnant woman or a child under six years resides or is expected to reside, generally must have potential lead exposures evaluated and controlled; how these are done depends on the type of assistance. Zero-bedroom units are exempt from the Lead Safe Housing Rule. HOPWA clients are considered disabl...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

Can STRMU payments pay for telephone service?

CORRECTED RESPONSE in CPD Notice 06-07, issued 8/3/06 NO, not as a housing cost reported as STRMU. However, in some situations, a grantee may determine that their HOPWA programs will allow for supportive services that include reasonable costs for basic phone services that are determined to be needed to assist the beneficiary in accessing services, such as maintaining consistent and accurate participation with medical treatment protocols, care or ...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

Can we provide assistance to clients who live in mobile homes, trailers, and motor homes?

Yes, but only in some situations. A rent, mortgage, or utility payment must be the basis for the assistance, and if an applicant presents such documentation and the need is assessed, then STRMU payments for up to 21 weeks of assistance could be permitted under the following circumstances: HOPWA can follow guidance established for the HOME Affordable Housing program in HUD Notice CPD 03-05 for conducting STRMU assistance in these circumstances. Mo...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

Can STRMU be used to assist clients who rent a separate and discreet residence from a family member naming them as tenant?

Yes, but only with reasonable accommodation approval as stated in (g) above. HOPWA regulations follow 24 CFR 982.306(d) prohibits assistance to clients if the owner is the parent, child, grandparent, grandchild, sister, or brother of any member of the family, unless it is determined by a physician that living with the family member is important to the client's overall health and well being. In such situations because of this reasonable accommodat...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

How can STRMU be used to assist clients who have a lease or rental agreement naming them as a tenant, but who live with an adult family member?

STRMU can assist in this scenario under two conditions: Where a client lives with an adult family member and the entire household is assisted and total household income is taken into consideration to meet HOPWA low-income eligibility guidelines, or If the client is renting the unit from the adult family member and a "reasonable accommodation" is determined necessary for the client. HUD regulation 24 CFR 82.306 (d) does not allow housing assista...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

Can STRMU assistance be used for a second mortgage?

Generally yes. As a general matter, a second mortgage represents a lien on real property. Defaults on mortgages (e.g., nonpayment of loan(s), lapsed insurance, unpaid property taxes, or the commission of waste, among others) may lead residents to foreclosures and evictions from their homes. STRMU benefits provide short-term mortgage payments regardless of priority (i.e. the first or second mortgages) to eliminate the threat of homelessness for an...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

Can STRMU payments for mortgages include property taxes, insurance, and condo fees?

Yes in some situations. Most homeowners are required to pay property taxes, mortgage insurance premiums, fire and hazard insurance premiums as part of their monthly mortgage payment. For example, the Federal Housing Administration (FHA) requires a homeowner's monthly payment to include property taxes, special assessments (if applicable), and flood insurance (if applicable) in addition to principal and interest (see 24 CFR 203.22-203.24). These ad...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

Can we assist clients who do not have a rental agreement/lease, mortgage, or utility bill in their name due to criminal history, poor credit, or lack of rental history?

Yes, but only under certain conditions. Eligible STRMU recipients must have a legal right to reside in the unit and prove responsibility for paying the rent, mortgage or utility costs. As a general matter, if the eligible person is not named on a valid lease/rental agreement either as a tenant or an authorized occupant, the person has no legal right to reside in the unit and is therefore not eligible for STRMU assistance. However, if a STRMU appl...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

Are HQS Inspections required in units eligible for STRMU assistance payments?

No. However, HUD requires grantees and project sponsors administering HOPWA funding to provide safe and sanitary housing that is in compliance with all applicable State and local housing codes. If program staff assesses that a STRMU applicant is residing in substandard housing, it is expected that the permanent housing stability plan will address measures to correct unit deficiencies, or to move the client to housing that meets HUD's habitability...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

Can I use STRMU to help an eligible person who is homeless? What are the standards for receiving STRMU payments to prevent homelessness?

No. STRMU can only be used to assist someone currently in housing as an intervention to prevent homelessness. Other HOPWA components can be used to assist someone who is homeless in obtaining housing and other support. HOPWA funds may only be used for eligible activities as cited in 24 CFR 574.300. These "uses" are intended to address unmet housing needs, including costs when no other funding or insurance is available, and assistance must be cons...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments

How does STRMU assistance fit with other HOPWA activities?

STRMU is one type of the three main types of HOPWA housing activities, along with Tenant-Based Rental Assistance (TBRA) and residency in a housing facility, such as a community residence. The use of funds annually to provide these three types of housing support are considered the housing outputs of HOPWA programs, as reported in annual performance reports. HOPWA activities can involve other costs in addition to the direct housing costs for STRMU ...
Read More. Short-term Rent, Mortgage,
and Utility Assistance (STRMU) Payments
Administrative and Planning Costs/Cap

Can administrative costs pay for costs related to displacement and relocation assistance for displaced persons?

No. Costs related to displacement and relocation assistance for displaced persons are considered direct costs, as provided at 24 C.F.R. § 574.630(e)(2), and chargeable to the approved budget line item for the direct activity, which is limited to acquisition, rehabilitation and demolition of the HOPWA-funded project.

Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

Can administrative costs pay for staff recruitment and security clearances?

Yes, administrative costs can be used to pay for staff recruitment and related security clearance if reasonable and associated with management and delivery of HOPWA activities. Where the recruitment and related expenses are necessary to fill a vacancy that occurs during project implementation, such personnel administrative expenses could be eligible. Also, charges to HOPWA for this purpose must be consistent with the allocation of such personnel ...
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

Can HOPWA funds be used for costs to conduct comprehensive planning, coordination and integration of services with local planning bodies and other community resources, including community advisory groups, to develop and enhance housing assistance resources?

Yes. HOPWA grantees and project sponsors can use HOPWA funds for comprehensive planning, community meetings, and other activities to plan, establish, coordinate and develop HIV/AIDS housing assistance and services for eligible persons (including conducting preliminary research and making expenditures necessary to determine the feasibility of specific housing-related initiatives (see 24 C.F.R. § 574.300 (b)(2)). HUD encourages grantees to collabo...
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

Is the seven percent limitation on project sponsor administrative costs applicable to contracted services for carrying out eligible program activities (e.g. contracts with sub-recipients performing specialized services such as mental health services)?

No. There are no specific administrative limits on contracted services to provide benefits to eligible persons. Purchase orders, contracts, or other similar agreements with subcontractors generally include overhead costs or amounts required to cover the cost of carrying out the contracted services, which are specified within the scope and cost provision of the contract. Rates approved for contracted services must comply with the procurement requi...
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

What is the administrative cost limit for a HOPWA competitive grantee that both provides eligible direct service activities to beneficiaries and also contracts with other entities as project sponsors?

When a competitive grantee provides direct service activities to beneficiaries and also contracts with other organizations as project sponsors, that entity is considered a grantee and is eligible to use not more than three percent of the total grant amount for both functions.

Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

How does a HOPWA grantee using another organization for some or all administrative functions allocate administrative amounts?

In some instances, grantees may select another entity to carry out administrative activities on behalf of the grantee. Examples of administrative functions include the distribution of HOPWA awards, coordination and oversight of HOPWA programs and project sponsors, and development and preparation of HOPWA performance reports. A grantee may select a government entity within the grantee's organizational structure, an external governmental entity, or...
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

Is there a limit on the use of HOPWA funds charged to the Housing Information Services category for HMIS or HMIS-compliant systems?

HUD would consider reasonable and allow for up to three percent of the HOPWA grant to be used for HMIS or HMIS-compliant systems to track client access and utilization and enhance housing access.  These costs are separate from the three percent grantee administrative cost cap and may be billed under Housing Information Services, provided that such information systems comply with requirements for confidentiality of personal information. ...
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

Can a grantee or sponsor use HOPWA funds to build upon or integrate with Ryan White CARE Act data systems, and are these activities billable as administrative costs or eligible Housing Information Services costs?

Yes, HOPWA funds can be used to build upon or integrate with Ryan White CARE Act data systems (or other systems), provided that the system meets HMIS program specific data elements/standards and protects client confidentiality. When the systems are developed or used to facilitate data reporting, the costs are considered administrative costs and are subject to the administrative cost limit. These costs may be eligible Housing Information Services ...
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

Can a grantee use HOPWA funds to pay for a Homeless Management Information System (HMIS) or a similar management information system that complies with HOPWA program reporting requirements, including those incorporated into HMIS, and protects client confidentiality?

Yes, costs of including HOPWA in community HMIS and/or implementing HMIS or HMIS-compliant systems are eligible HOPWA costs, provided that such systems comply with HOPWA reporting requirements (as incorporated into HMIS) and protect client confidentiality.  HOPWA funds may be used for HMIS costs incurred by grantees and project sponsors that are required to participate in their community HMIS (i.e., projects that target and serve persons who...
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

What is the distinction between administrative and eligible program activity costs? Some activities, such as bookkeeping, often are administrative but also can be directly related to an eligible program activity.

Program costs are costs for carrying out and delivering eligible program activities, as identified at 24 C.F.R. § 574.300(b).  These costs include housing assistance activities (i.e., tenant- and project-based rental assistance; operating costs for housing; acquisition, rehabilitation, lease, and repair of facilities; new construction of SROs and community residences only; short-term rent, mortgage and utility assistance; and permanent hous...
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

Can a HOPWA grantee or a project sponsor take 1/12 of their allowable administrative costs (three percent or seven percent, respectively) each month throughout the program year to use for administrative costs?

Yes, but only if the costs are based on documented eligible activities incurred for administering the grant award during that monthly period.  Under no circumstances can the allowable administrative percentage be exceeded at the end of the grant term, and the allowable three percent or seven percent must be based on actual grant administrative expenditures.

Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

Can a grantee incur and be reimbursed for the full three percent off the top of their total HOPWA award, and can a project sponsor take seven percent off the top of their total HOPWA award, for administrative costs incurred at the beginning of the grant period?

Yes, but only in special situations, such as when the costs are documented and based on  eligible activities incurred for grant administration after the grant agreement was signed and executed (e.g., startup costs for that project's operations).  More likely, such costs would be incurred during the operation of the project and would be reimbursable as incurred.  Administrative costs may only be reimbursed after the administrative a...
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

Can a HOPWA grantee or project sponsor exceed administrative cost limits?

No.  The limits on administrative costs, as set forth at 24 C.F.R. § 574.300(b), are derived from Section 856 of the AIDS Housing Opportunity Act and cannot be waived.  Even in situations where all incurred administrative costs are reasonable and properly documented for the HOPWA program, if they exceed the applicable three or seven percent statutory administrative limits, they are unallowable and must be paid from other sources, such ...
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

Can a HOPWA grantee deny administrative costs to a sponsor?

No.  Sponsors must undertake the grant administration activities established at 24 C.F.R. § 574.500, including project management, recordkeeping, performance reporting and evaluation of HOPWA efforts.  Carrying out these activities ensures that awards are being administered in compliance with all applicable laws.  To ensure a reasonable level of funding is available to carry out administrative responsibilities, HOPWA grantees shou...
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

What are the administrative cost limits for HOPWA grantees and project sponsors?

Section 856 of the AIDS Housing Opportunity Act and the implementing regulation at 24 C.F.R. § 574.300(b)(10) establish that a grantee can use not more than three percent of the grant amount for  its administrative expenses and that a project sponsor may use not more than seven percent of its HOPWA grant for administrative costs.  As an example, please refer to the Grantee Award vs. Sponsor Award chart on Page 1....
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

Are the costs associated with developing or using HMIS or other management information systems that comply with HOPWA reporting requirements and protect client confidentiality considered administrative or eligible program activity costs?

The purpose and use of the HMIS or other management information system determines the cost category under which such activity may be billed.  As detailed below, when the HMIS is used for tracking and collecting data for purposes of grant reporting, the costs are administrative costs.  When the HMIS is developed or used to improve linkages to community services and resources or to enhance beneficiary access to other community programs, t...
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

Under what category of funds (administrative or programmatic) should a grantee or project sponsor charge staff time and costs related to reporting on monthly or quarterly grant and project activities and APR/CAPER and IDIS reporting to HUD?

Staff costs related to preparation and execution of reports to the grantee or to HUD are charged against administrative costs under the applicable three percent limit for grantees and seven percent limit for project sponsors.  As discussed below, a portion of the costs of operating the management information system that both generates the data and also is used for coordination and other purposes may be allocated to Housing Information Services.

Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

Is the project sponsor administrative cost limit calculated based on 7% of the sponsor’s grant award or 7% of the grant funds expended by the sponsor for project activities during the grant project period (when less than the award)? How can administrative expenses be tracked?

The seven percent limitation is based on the award amount established in the grantee agreement with the project sponsor. Nonetheless, HUD expects grantees to monitor administrative costs throughout the grant period to ensure that they do not exceed the statutory limit. As a method for maintaining costs within the administrative limit, grantees may establish procedures that limit draws for administrative costs to the limitation of seven percent of...
Read More. Administrative and Planning Costs/Cap
Administrative and Planning Costs/Cap

What is the administrative cost limit when a HOPWA grantee awards grant funds to an organization both for program management and as a sponsor to carry out one or more program activities?

In some instances, grantees may select other entities to carry out administrative activities on behalf of the grantee and to deliver direct program services to HOPWA eligible clients.  A grantee may select a governmental entity within the grantee's organizational structure, an external governmental entity, or a nonprofit organization or governmental housing agency to provide both grantee administrative and program activities.  In such i...
Read More. Administrative and Planning Costs/Cap
Confidentiality Requirements

Does HMIS collect information related to HOPWA CAPER reports?

The HOPWA CAPER utilizes the same universal data elements that HMIS uses for collecting client demographic information, and will be useful for determining unduplicated client and household counts. HMIS does not track HOPWA financial information, nor does it create a report in the exact format that the CAPER utilizes to report program information.

Confidentiality Requirements
Confidentiality Requirements

As a HOPWA provider, can we enter data into HMIS under a “Doing Business As” (DBA) name?

In order to maintain client confidentiality, some HIV/AIDS service providers must create a distinct legal trade name without HIV or AIDS in the title, referred to as a "DBA" (doing business as) name. For example, an agency that provides HOPWA tenant-based rental assistance might need to establish a separate entity with a separate name (e.g., Springfield Supportive Housing Program), designate a separate phone line for landlords to call, and/or set...
Read More. Confidentiality Requirements
Confidentiality Requirements

Is there a specific HMIS data system to use for HOPWA?

HMIS software providers vary across the country. To find the local HMIS administrator for your area, look up the HMIS Lead contact listed within your local Continuum of Care. Because HOPWA reporting utilizes the same universal data elements for client demographics that the HMIS uses, it should be feasible to add HOPWA, and possibly customize the program to best meet your HOPWA program tracking and reporting needs. Grantees may also use HOPWA...
Read More. Confidentiality Requirements
Confidentiality Requirements

If a client refuses to sign the HMIS Release of Information, can they be denied services?

No. Potential program participants are not required to sign an HMIS Release of Information in order to receive services. An individual or family can refuse to participate in HMIS, and the provider must still offer all the same services to that household. However, some information may be required by projects to determine eligibility for housing or services, or to assess needed services. Therefore, although program participants are not required to ...
Read More. Confidentiality Requirements
Confidentiality Requirements

Are HOPWA grantees required to enter data into HMIS?

The HOPWA program only requires participation in a local Homeless Management Information System (HMIS) if a grantee is renewing an expiring Competitive HOPWA permanent supportive housing grant, and/or if grantees are specifically targeting their HOPWA services to serve people who are homeless. However, HUD encourages all projects, regardless of target population, to participate in the local HMIS. HMIS systems can be invaluable in coordinating ava...
Read More. Confidentiality Requirements
Confidentiality Requirements

What happens when a client revokes consent he/she had previously given to a provider of HOPWA housing assistance?

Program participants should be advised that revocation of consent to release information or verify certain information required by law for program eligibility may result in termination of housing assistance. Explain the regulatory requirements for HIV and income verification for HOPWA eligibility, as well as the requirements for annual income re-certification and obtaining needed supportive services. It is also important to clarify the additional...
Read More. Confidentiality Requirements
Confidentiality Requirements

Do we need to add funders to our Release of Information in order for them to conduct audits? Is there language that can be included in our privacy rights and responsibilities document provided to clients who receive our services?

Releases of Information are not required in order for funders to do program monitoring including random client file reviews; however, it is important to state this in your privacy rights and responsibilities materials. For example: “XYZ Agency is required to send reports to funders, but no personal participant information is provided; only numbers in aggregate with other participants and general information about program accomplishments. Progra...
Read More. Confidentiality Requirements
Confidentiality Requirements

My agency has an open floor plan. I am the only HOPWA worker. Do you have any suggestions for me?

In service agencies where this situation is present it is recommended to provide at least one case conference room where case managers can meet privately with clients for the purpose of discussing confidential information. Additional methods of protection include locked file cabinets to store client files when you are away from your desk, password protected computers, utilizing unique identifier codes in place of client names on files or written ...
Read More. Confidentiality Requirements
Confidentiality Requirements

If someone contacts our agency based on information listed in a resource guide, how should we explain that we cannot assist them if they are not living with HIV/AIDS?

If your agency resource materials do not state HIV/AIDS services in particular, an effective response is to ask the caller to tell you about their current health and financial situation, and provide more details about their reason for calling. That should provide sufficient information for you to determine if they are HIV positive. If they are not, provide them with other emergency housing and service resource numbers.

Confidentiality Requirements
Confidentiality Requirements

If someone is referred to our agency by another client, how should we respond to their inquiry about eligibility for assistance while maintaining the confidentiality of the person who provided the referral?

Regardless of what a caller might know or suspect about the health status of someone who provided them with information about your agency services, an effective response is to ask the caller to provide you with information about their current health and financial situation, and their reason for calling. This diverts the conversation from any discussion or acknowledgement about the person that referred the caller. If the caller inquires about the ...
Read More. Confidentiality Requirements
Confidentiality Requirements

Is it allowable to refer to HIV/AIDS status on the confidentiality agreement? What if a client were to leave this document where others might see it?

Yes, it is allowable to indicate HIV/AIDS status on the client Release of Information or consent form. Once client data is collected, including the release of information, agencies must safely store and protect both hard copy and electronic records to minimize the risk of an information breach. Agencies must provide copies of signed releases of information to clients at their request and may also consider establishing it as a standard practi...
Read More. Confidentiality Requirements
Confidentiality Requirements

Could you share an example Release of Information?

View an example Release of Information

Confidentiality Requirements
Confidentiality Requirements

What if a data breach is caused by a resident and not a staff person?

Confidentiality can be breached by other clients. It is the responsibility of each agency to educate clients to be respectful of others by not revealing information about specific residential locations, service programs, and other clients. Program service agreements should include language around maintaining confidentiality of other program participants and specific program locations that would identify the HIV/AIDS status of other residents or c...
Read More. Confidentiality Requirements
Confidentiality Requirements

Can we write client names on housing vouchers that go to our agency’s accounting department?

Each organization is different and should evaluate which staff members have a need to know sensitive information. Agencies should ask the question: why does our finance staff need access to personal identifying information? Housing programs should consider using unit numbers only or unique identifiers on checks and housing vouchers. This practice may be particularly suitable if additional precautions are warranted as it provides a method to shiel...
Read More. Confidentiality Requirements
Confidentiality Requirements

How can we run a HOPWA rental assistance program while protecting the confidentiality of the clients we serve? For example, can we write client names on rental checks?

The AIDS Housing Opportunity Act of 1992 and the HOPWA regulations 24 CFR 574.440 require that grantees and project sponsors protect the privacy of those receiving HOPWA assistance. HOPWA grantees should include provisions within each project sponsor agreement or contract outlining the confidentiality requirements for any recipient of HOPWA funds. Examples of best practices include: Establishing a separate entity with non-HIV/AIDS specific names...
Read More. Confidentiality Requirements
Confidentiality Requirements

A simple google search can connect our program name to the fact that we serve people living with HIV/AIDS. Given that, how can we ensure confidentiality of the people we serve?

The availability and easy accessibility of information that the internet provides is an opportunity and a challenge. Providers will need to make individual agency-level decisions about what and how to present information in developing and managing their online presence. These decisions will be driven by the nature and history of an organization along with their goals and mission. Agencies that serve a diverse population should generally describe ...
Read More. Confidentiality Requirements
Housing Counseling

Is “case management” that is commonly conducted to help households find stable housing under HOPWA, considered “housing counseling” for purposes of this rule?

When grantees provide housing services to eligible persons (including persons undergoing relocation) that are incidental to a larger set of holistic case management services, these services do not meet the definition of housing counseling, as defined in 24 CFR § 5.100, and therefore are not required to be carried out in accordance with the certification requirements of § 5.111. However, there may be instances where housing counseling, as define...
Read More. Housing Counseling
Housing Counseling

HOPWA is listed in the certification rule as a “HUD Program where housing counseling is funded under the HUD program.” How is HOPWA affected by the Final Rule on housing counselor certification?

Housing counseling is an eligible activity under HOPWA. If a grantee chooses to fund housing counseling activities under their program, the housing counseling must be provided by a HUD certified housing counselor working for an agency approved to participate in HUD’s Housing Counseling program, by the Final Compliance Date. Please see FAQ 3147 regarding case management....
Read More. Housing Counseling
FFATA

What are the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements and how do I report the required information?

The Federal Funding Accountability and Transparency Act (FFATA) was signed into law on September 26, 2006. This legislation’s intent was to empower every American with the ability to hold the government accountable for each spending decision. The legislation requires information on federal grants and contracts to be made available to the public via a searchable website which is at https://usaspending.gov/.  In order to fulfill report...
Read More. FFATA
FFATA

The HOPWA grant for my agency is not showing up in my work list. What should I do?

The HOPWA grant award information is sent monthly from HUD financial systems to the FSRS website. The awards that populate an agency’s work list are tied to the DUNS Number for the agency. If the agency’s DUNS Number that appears in the Department’s Line of Credit Control System (LOCCS) is incorrect, the system will assign the award to the wrong agency in the system. If a HOPWA grantee does not see their award in the system or is having iss...
Read More. FFATA
FFATA

Are there technical assistance resources available for HOPWA grantees in using the FSRS website?

A FSRS User Guide is available for HOPWA grantees to assist in the use of this system. The user guide provides instructions for grantees on how to access the site, how to query all grants received into the grantee’s work list, and how to finish reporting into the system. If grantees are having any problems with accessing information in the system or need assistance with completing their reporting, they may contact the Federal Service Desk. ...
Read More. FFATA
FFATA

How do I create an account with the FFATA Subaward Reporting System website?

HOPWA grantees should visit FSRS Login page to create an account with the website. The grantee will need to know their DUNS Number in order to create their account.

FFATA
FFATA

Where can I find more guidance on the FFATA Subaward and Executive Compensation Reporting?

HOPWA grantees may view this Open Government Directive – Federal Spending Transparency Memo to discover more information about the FFATA reporting requirements.

FFATA
FFATA

What are the executive compensation reporting requirements and does the project sponsor have to do the reporting in the system?

The executive compensation reporting requirements are applicable to the grantee and project sponsors. Grantees are required to report the names and total compensation of the five most highly compensated officers of the grantee or project sponsor if: If the grantee or project sponsor in the previous fiscal year received 80% or more of its annual gross revenues from federal awards and $25,000,000 or more in annual gross revenues from federal award...
Read More. FFATA
FFATA

For FFATA reporting purposes, what is the definition of a grant? What is the definition of a subaward?

OMB guidance designates the operational definitions of grants and subawards for the FFATA reporting requirements. OMB defines a grant as “an award of financial assistance from a federal agency to a recipient to carry out a public purpose of support or stimulation authorized by a law of the United States”. A subaward is defined as “a legal instrument to provide support for the performance of any portion of the substantive project or program ...
Read More. FFATA
FFATA

Are there any exceptions that would not require a HOPWA grantee to report on their project sponsors?

The Office of Management and Budget (OMB) has published the guidelines applicable to HOPWA grantees in regards to the FFATA reporting requirements.  HOPWA grantees that receive awards less than or equal to $25,000 or awards received prior to October 1, 2010 are not subject to the FFATA reporting requirements. HOPWA grantees whose cumulative gross income was less than $300,000 in the grantee’s last tax year are not subject to the FFATA...
Read More. FFATA

 
 

Content current as of October 18, 2021.