2 - CoC Policies
Section 1: Bridge Housing Policy
Purpose: The purpose of this policy is to establish guidelines to determine who is considered for bridge housing and prioritization for available housing.
Bridge Housing- Model used as short-term stay when eligible participant has been offered and accepted a permanent housing intervention, but access to that permanent housing is still being arranged.
The IA BoS CoC understands once a household/individual has been determined eligible and accepted into a PSH program, a unit is not always immediately available. During this time, unless they have other options such as temporarily living with friends or family, the household/individual will generally continue to reside in an emergency shelter or on the streets, prolonging their period of homelessness. After a household/individual has been accepted into a program, but before an appropriate unit has been identified, the household/individual may
Stay with a friend or family in a hotel or motel without losing their eligibility for the PSH program in which they have already been accepted.
OR
The household/individual may be temporarily housing in an available RRH unit while a PSH unit is identified.
Bridge Housing acts as a safety net and/or creates increased housing flow by ensuring housing stability for those who may not be successful in housing programs or who may not need housing case management/subsidy assistance and can be transferred to appropriate interventions that ensure housing stability.
Bridge Housing options are not exclusive to the Continuum of Care or Coordinated Entry, meaning that any successful Bridge Housing intervention should be considered and pursued. Generally, Bridge Housing is used to move clients from Rapid Rehousing programs to other, longer-term housing programs including Permanent Supportive Housing, Housing Choice Vouchers, Mainstream Vouchers, subsidized units, group homes, assisted living and other housing options. A CoC Bridge Housing opportunity is always Permanent Supportive Housing.
Bridge Housing should be considered to support clients who:
Will not be able to maintain rental/utility payments when program subsidy ends;
No longer require case management and/or subsidy support to maintain housing; or
Do not have the supports necessary to thrive in the current housing program and require more or different support not able to be provided by the current housing program.
While working with participants in the Bridge Housing process, providers must follow:
Housing First- Since the participant has been accepted into a PSH program, the current housing provider cannot place any requirements on the participant, including requiring a program participant to participate in additional services as a condition of occupancy or requiring the program participant to meet sobriety requirements.
Active Housing Search- The PSH providers must be actively assisting the participant to identify a unit as quickly as possible and must be able to document attempts at locating a unit in the participants case file. Under no circumstance should the placement in RRH slow down placement into permanent housing. This means placing a program participant into a permanent housing unit should not take any longer than the time it would normally take to place someone in permanent housing who is residing on the streets or in an emergency shelter.
No duplication of services- There cannot be duplication in billing for the participant. For example, both programs cannot provide and then seek reimbursement from HUD for housing search or other services. The PSH provider and the RRH provider must coordinate to ensure that the appropriate services are provided, and the same services are not being paid for out of both grants.
Who should be considered for Bridge Housing:
Rapid Rehousing case managers should review every participant who is matched to their program to determine if they will qualify for a CoC Bridge Housing opportunity. Participants must have proof of homelessness before lease signing in the Rapid Rehousing program to ensure qualification for additional programs, and specifically Permanent Supportive Housing programs.
Case Managers will inform the Coordinated Entry Specialist for the region or the Designation Lead Agency (DLA) when they have participants in need of PSH Bridge Housing opportunities. The Coordinated Entry Specialist or DLA will track and manage CoC housing matches for all qualified and potential bridge housing candidates and will also review all Rapid Rehousing matches for Bridge Housing eligibility.
Prioritization for Available Housing:
When a PSH program has openings, determining who is prioritized for those openings will be conducted in the following way:
When a PSH Project Based Voucher is available: those currently experiencing literal homelessness will be matched.
When a PSH Scattered Site/Tenant-Based Voucher is available: Clients verified as qualified for CoC Bridge Housing will be matched and will take priority over those experiencing literal homelessness.
The housing opportunity the person bridged from will then be assigned another client, based on dynamic prioritization.
In the event of multiple qualified clients needing bridge at the same time, the Continuum of Care will determine who is matched in the following way:
The qualified bridge participant who will be exiting the current housing program/subsidy support soonest will receive bridge priority.
In the instance of a tie when current housing program/subsidy support ends for participants, case managers of the participants will engage in the CoC Coordinated Entry Tie breaker process to determine which participant receives priority for available housing.
Tie breakers are used for identical scores and are as follows: Chronic Status, Length of Time Homeless or on the Streets, currently fleeing DV, Veterans, Youth.
Section 2: Education Policy for Children & Youth Experiencing Homelessness
The purpose of this policy is to ensure agencies awarded Continuum of Care (CoC) funding within the Iowa Balance of State CoC (IA BoS CoC) inform program participants of eligibility for education services and ensure access to those services.
Agencies within the IA BoS CoC that receive CoC funds must:
Demonstrate collaboration with local school districts to identify families experiencing homelessness and inform families and youth experiencing homelessness of their eligibility for McKinney-Vento education services.
Ensure their programs are establishing policies and practices that are consistent with, and do not restrict the exercise of rights provided by the education subtitle of the McKinney-Vento Act, and other laws relating to the provision of education and related services to individual and families experiencing homelessness.
Identify ways to support youth in school activities and allow flexibility for these activities.
Ensure their programs providing housing or services to families has a designated staff person to ensure that children are enrolled in school and connected to the appropriate services within the community, including early childhood programs such as Head Start, as noted in Part C of the Individuals with Disabilities Education Act and McKinney-Vento education services.
Assign at least one employee (1 FTE) as the designated contact for local district liaisons. This must be included in the job description and staff designated will be the contact for school districts/early childhood education programs if any issues, concerns, or changes occur. Designated staff will provide the school districts/early childhood education program with contact information and connection to coordinated entry.
Implement policies and procedures for client enrollment into educational opportunities. This will include:
Identify and implement strategies for successfully enrolling persons in educational opportunities.
Identify and implement methods for providing information and education on educational opportunities to those experiencing homelessness in a clear, concise, culturally competent manner.
Identify and describe the agency's role in assisting clients to make appointments, arrange for transportation and access to appropriate educational opportunities.
Record and document progress with participants and to abide by assurance and create policies and procedures that align with this policy.
Project Intake/Enrollment: Agencies must collect information regarding children in the household including:
Name and age of child(ren);
Grade of the child(ren);
School the child(ren) is attending or last attended;
Transportation method to get to and from school;
Identify needs to participate in school appropriately (i.e., school supplies, clothing, etc.);
Determine whether the child(ren) are currently a part of the school’s McKinney-Vento program;
Indication that school-based services were discussed.
Connection with Education System: Agencies must ensure that information is provided to families explaining their rights under McKinney-Vento and ensure collaboration between the school(s) and the homeless response system. The agency can obtain a release of information with the participant with the school of origin and/or school in the district of the family and/or youth’s situation. Agencies must also notify families/youth that:
Child(ren) may attend the school of their choosing in coordination with school district/early education program policies.
Ability of school districts to provide transportation to keep the child(ren) in their school of origin and assist in coordinating this service for the child(ren) as appropriate.
Section 3: Emergency Transfer Plan
This plan identifies tenants who are eligible for an emergency transfer, the documentation needed to request an emergency transfer, confidentiality protections, how an emergency transfer may occur, and guidance to tenants on safety and security. This plan is based on a model emergency transfer plan published by the U.S. Department of Housing and Urban Development (HUD), the Federal agency that oversees that IA BoS CoC Housing Providers (HPs) are in compliance with VAWA.
A tenant who is a victim of domestic violence, dating violence, sexual assault, or stalking, as provided in HUD’s regulations at 24 CFR part 5, subpart L is eligible for an emergency transfer, if: the tenant reasonably believes that there is a threat of imminent harm from further violence if the tenant remains within the same unit. If the tenant is a victim of sexual assault, the tenant may also be eligible to transfer if the sexual assault occurred on the premises within the 90- calendar-day period preceding a request for an emergency transfer.
A tenant requesting an emergency transfer must expressly request the transfer in accordance with the procedures described in this plan.
Tenants who are not in good standing may still request an emergency transfer if they meet the eligibility requirements in this section.
To request an emergency transfer, the tenant shall notify HP’s management office and submit a written request for a transfer to the HP office mailing address, which will be provided with intake paperwork and as requested by tenants. HP will provide reasonable accommodations to this policy for individuals with disabilities. The tenant’s written request for an emergency transfer should include either:
1. A statement expressing that the tenant reasonably believes that there is a threat of imminent harm from further violence if the tenant were to remain in the same dwelling unit assisted under HP’s program;
OR
2. A statement that the tenant was a sexual assault victim and that the sexual assault occurred on the premises during the 90-calendar-day period preceding the tenant’s request for an emergency transfer.
HP will keep confidential any information that the tenant submits in requesting an emergency transfer, and information about the emergency transfer, unless the tenant gives HP written permission to release the information on a time limited basis, or disclosure of the information is required by law or required for use in an eviction proceeding or hearing regarding termination of assistance from the covered program. This includes keeping confidential the new location of the dwelling unit of the tenant, if one is provided, from the person(s) that committed an act(s) of domestic violence, dating violence, sexual assault, or stalking against the tenant. See the Notice of Occupancy Rights under the Violence Against Women Act For All Tenants for more information about HP’s responsibility to maintain the confidentiality of information related to incidents of domestic violence, dating violence, sexual assault, or stalking.
HPs cannot guarantee that a transfer request will be approved or how long it will take to process a transfer request. HP will, however, act as quickly as possible to move a tenant who is a victim of domestic violence, dating violence, sexual assault, or stalking to another unit, subject to availability and safety of a unit. If a tenant reasonably believes a proposed transfer would not be safe, the tenant may request a transfer to a different unit. If a unit is available, the transferred tenant must agree to abide by the terms and conditions that govern occupancy in the unit to which the tenant has been transferred. HP may be unable to transfer a tenant to a particular unit if the tenant has not or cannot establish eligibility for that unit.
If HPs have no safe and available units for which a tenant who needs an emergency is eligible, HP will assist the tenant in identifying other housing providers who may have safe and available units to which the tenant could move. At the tenant’s request, HP will also assist tenants in contacting the local organizations offering assistance to victims of domestic violence, dating violence, sexual assault, or stalking that are attached to this plan.
Section 4: Involuntary Family Separation & Non-Discrimination Policy
The purpose of this policy is to serve a family, or any group of persons identifying as a family (with or without children under the age of 18) without discrimination or involuntary separation. This policy is intended to supplement, but not replace, any applicable state and federal laws governing conflicts of interest relevant to nonprofit and charitable organizations. All CoC-funded housing projects that serve families must adhere to this policy.
As defined in Rule FR-5359 Equal Access Rule family includes, but is not limited to the following, regardless of actual or perceived sexual orientation, gender identity, or marital status as the following:
A family with or without children (a child who is temporarily away from the home because of placement in foster care is considered a member of the family).
An elderly family.
A near-elderly family.
A disabled family.
A displaced family.
The remaining member of a tenant family.
To comply with Rule FR-5359, a project shall not discriminate based on family composition.
In compliance with CoC Program Interim Rule 24 CFR 578.93(e) involuntary separation is prohibited in projects funded through CoC dollars. CoC funded projects may not deny admission to any household on the basis of:
Age or gender of children under 18,
Gender of a parent or parents.
Marital status of the parent or parents.
Agencies within the IA BoS CoC that receive CoC funds must demonstrate the following:
There can be no inquiry, documentation required, or “proof” related to family status, gender identification and/or sexual orientation. The prohibition on inquiries or documentation does not prohibit inquiries related to individuals gender identity for the limited purpose of determining placement in temporary, singles-only emergency shelters which are limited to one sex because they have shared bedrooms or bathrooms, or for determining the number of bedrooms to which a household may be entitled.
Projects that serve individuals must follow the Rule FR-5359 Equal Access Rule. The only time a CoC-funded project is permitted to serve a single sex is when they are serving adults only (no minors) and/or have a physical configuration such that privacy is a concern, such as shared living space.
Prohibition against involuntary family separation. The age of a child under age 18 must not be used as a basis for denying any family's admission to an emergency shelter that uses Emergency Solutions Grant (ESG) funding or services and provides shelter to families with children under age 18.
The age of a child under 18 must not be used as a basis for denying any family’s admission to a program which uses CoC dollars if those programs serve families with children under the age of 18.
Agencies must allow for a grievance process for families who feel they have been involuntarily separated or have experienced discrimination
Section 5: Mainstream Benefits Policy
The purpose of this policy is to reiterate already existing HUD requirements for CoC-funded projects to provide assistance to program participants in accessing and how to use mainstream benefits for which they are eligible and to ensure CoC-funded projects are:
Educating and assisting all people experiencing homelessness with access to and use of mainstream benefits (i.e. Social Security, Disability, Health Insurance, etc.).
Ensuring all CoC-funded projects working with people experiencing homelessness have written policies and procedures addressing access to and education on mainstream benefits.
Agencies within the IA BoS CoC that receive CoC funds will implement policies and procedures for client enrollment into mainstream benefits. This will include:
Identify and describe the agency’s role and function in assessing household mainstream benefit enrollment.
Identify and implement strategies for successfully enrolling persons in mainstream benefits.
Identify and implement methods for providing information and education on mainstream benefits to those experiencing homelessness in a clear, concise, culturally competent manner to promote client understanding, motivation, empowerment, and positive health behavior change.
Identify and describe the agency's role in assisting clients to make appointments, arrange for transportation, and access to appropriate mainstream benefits.