In Attendance: Tammie Butler, Marcia Crutchfield, Joanne Glier, Toni Hochstadt, Fran LeMay, Jim Reis, Tom Salter, Pamela Schwartz
The goal of this meeting was to determine processes for administering and distributing ICHH funds.
The group agreed:
- on a uniform release form: Joanne will adapt the RAFT release for regional use, including privacy notice, and distribute via email;
- that each agency will use its own client application form to best suit its program and administrative needs and share their application with the group via email for exchange and learning purposes;
- that each agency will use its own landlord and client agreement forms and each agency will offer to the group via email its form;
- that each agency will use the ICHH assessment tool to collect data while pursuing clarity from ICHH about how to minimize duplication of forms across programs;
- that the group will agree on uniform criteria for eligibility for funds. Pamela will relay questions raised to ICHH and responses will inform the final criteria. Once responses are received, Jim Reis will adapt the criteria and distribute for final review.
Questions for ICHH and their responses (thanks to Liz Curtis, executive director, and Laila Bernstein, coordinator, for their extremely timely reply!):
1. Is ICHH putting out income eligibility guidelines?
No. The money was intentionally left to be flexible for agencies to decide what they should do to achieve outcomes. If the case is “diversion” that means a family is EA eligible and diverted from shelter, which has income guidelines. If it is prevention, that is up to the agencies to determine who is being effectively prevented from becoming homeless.
2. If the agency has discretion, does that include the ability to analyze income based on net income as opposed to gross. Providers would love to do that but in view of RAFT guidelines (and every other program) that only consider gross, they are concerned that that would not be allowable. Is it?
Yes.
3. The providers are looking at the RAFT program in general for documentation requirements. Is that appropriate? Are there other guidelines they should use? While looking for guidelines, they are also concerned about creating a “Raft Jr.” program and don’t want that to happen either. They want the flexibility but they want clarity about how that is administered.
Liz spoke with Metro-Boston about the fact that they used RAFT but now are finding it too restrictive and are looking at revising it. The ICHH does not want to set any additional restrictions around the use of the flexible funds and highly encourage every network to limit the restrictions unless those rules are helping the providers reach their target population and outcomes.
4. Can assistance include helping to pay for car repairs, for instance, if that will enable them to get to their job and keep their home? Again, checking the definition of “flexible.”
Flexibility is meant to give leeway to pay for the minimum that will achieve the outcome. If it is the car repair that is keeping someone from being stable, than that would be the best use of the money.
6. Is there any “appeal process” ICHH would like providers to follow? Without further guidance, they are prepared to adopt the RAFT standard of a “file review” standard. Any thoughts?
That sounds reasonable. The appeal process is to be developed by each network, as per the RFR.
7. How much flexibility is there with Tiers? There is some concern over the vagueness of the categories, especially how it it relates to the contracts with the fiscal agency.
That is part of what we are learning through this pilot. We have been using the definitions in the Commission Report to guide us, but they are open to interpretation and we would like to learn more through this to figure out how to get the right resources to the right people. The point of the tiers is to have flexible responses to homelessness depending on need. We’re more interested in funds being utilized to provide solutions rather than conform to the tier system precisely.
2 Remaining Questions:
1. Integration of ICHH assessment tool with DHCD, HPRP city and state fund reporting requirements — Providers are very concerned about the loss of real service in the face of administrative demand and duplication — how will this be addressed?
2. Doubledipping: Providers recognize the issue, but at the same time don’t want to get mired in the complexity of exchanging info on every consumer in the face of confidentiality requirements and time limitations (wanting to make sure consumers who need timely service are getting it instead of awaiting regionwide “clearance”). Is it ok to be less formal about this piece?
Next meeting: Tuesday, October 13, 1-3 pm, DTA Office, 100 Front Street, Holyoke
