2/18/22, 9:13 PM [EXTERNAL] Fwd: ERA Questions for The Auditor to Hays CC - Donith, Jamil A

[EXTERNAL] Fwd: ERA Questions for The Auditor to Hays CC

Ben Martin <ben@texashousing.org>

Thu 2/17/2022 1:47 PM

To: Donith, Jamil A <Jamil.Donith@charter.com>;

 1 attachment

Hays County PIP.pdf;

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Letter to Hays County Commissioners outlining the ways that Hays County is not following Treasury best practices, even practices that the
Commissioners have already signed off on.

---------- Forwarded message ---------

From: Eric Martinez <eric@manoamigasm.org>

Date: Mon, Feb 14, 2022 at 6:45 PM

Subject: ERA Questions for The Auditor to Hays CC

To: Eric Martinez <eric@manoamigasm.org>

Cc: Karen Paup <Karen@texashousing.org>, Ben Martin <Ben@texashousing.org>, Erin Hahn <erin@texashousing.org>

Dear Commissioners: 

Mano Amiga serves residents of Hays County that are impacted by criminalization, immigration or are otherwise low-income. To this end,
fellow community advocates have asked us to get involved recently to help raise awareness on the administration of the ERA program.
Since then, we have connected with folks from Texas Housers to help guide us through best practices. Ben Martin, Senior Research
Analyst, Erin Hahn, Research Analyst, and Karen Paup, Co-director with Texas Housers, are CC'd on this email. 

The thoughts below are the culmination of Texas Housers, Mano Amiga, & other local Hays County advocates. Time is pressing, so I'm
unable to get their consent in time to credit them appropriately. They are BCC'd and are welcome to claim credit where it's due. 

~~~~~~
Hays is acting outside of its program guidelines, which appear to allow self-attestation and categorical eligibility, yet the county does not
execute these in practice: Hays County has committed to at least allowing self-attestation (of all 3 eligibility factors: income, risk of housing
instability, and COVID-related hardship) in the Program Improvement Plan (PIP) it submitted to Treasury in November (attached). 

Below are a few examples of where the PIP does not align with practice. 

Provides tenants the opportunity to apply and receive funds directly when landlords decline to participate in the
application process

Not happening. We know somebody that has had an ERA ticket that has been open since October. Members of our group
later found out from County staff that the application was missing the W9 from the landlord when in fact, it had been sent
months prior. 

Relies on a tenant's self-attestation for purposes of determining whether an applicant has experienced a qualifying
financial hardship (see sample application screen: COVID-19 Pandemic Impact)

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2/18/22, 9:13 PM [EXTERNAL] Fwd: ERA Questions for The Auditor to Hays CC - Donith, Jamil A

Not happening. The auditor requires pre-Covid income documentation and Proof of Income Loss Due to COVID-19.

Allows for self-attestation to establish that a tenant is at risk of housing instability or homelessness (see sample
application screen: Risk of Housing Instability or Homelessness)

Not happening. The auditor requires notice of past-due rent, past-due utilities, or notice to evict.

Largely, the flow of the overall process is hampered or stopped by the County Auditor's guidelines which go above & beyond that of the
U.S. Treasury. The questions below are geared towards the auditor & each is backed by evidence of submitted cases and email
correspondence, on hand or accessible through an information request.  

1. Why hasn't the auditor directed administrators to utilize categorical eligibility (or the determination of a household's eligibility
based on their participation in another government assistance program), a practice already stated in the Hays County ERA program
guidelines?

2. Why hasn't the auditor directed administrators to accept applicants' self-attestation of income eligibility, a practice that is both
strongly recommended by the Treasury and already stated in the Hays County ERA program guidelines?

3. Why hasn't the auditor directed administrators to accept applicants' self-attestation of financial hardship, which is both strongly
recommended by the Treasury and already stated in the Hays County ERA program guidelines?

4. Why hasn't the auditor directed administrators to accept applicants' self-attestation of housing instability or risk of
homelessness, which is both strongly recommended by the Treasury and already stated in the Hays County ERA program
guidelines?

5. Why hasn't the auditor authorized administrators to utilize fact-specific proxies (which determine eligibility based on geographic
location through zip codes, neighborhoods, apartment complexes, etc.), which the Treasury strongly recommends?

6. Why has the auditor authorized additional documentation requirements beyond those that the Treasury requires? Only
the minimum required documents as established by Treasury should be requested so as not to burden applicants with
providing unnecessary documents and administrators with processing them.

7. Why hasn't the auditor authorized administrators to accept the ID of only one household member (as opposed to the ID of every
individual over 18 in the household), which is already stated in the Hays County ERA program guidelines?

8. Why hasn't the auditor authorized funding up to 12 months rental arrears and up to 3 months current and future rent on a
tenant's initial application?

9. Why hasn't the auditor authorized or requested the hiring of more caseworkers and requested a wage range based on
experience, education, and skills to attract qualified caseworkers and accelerate distribution?

Respectfully, 

Eric Martinez
Policy Director
Mano Amiga 

--

Ben Martin | Senior Researcher

Texas Housers
Phone: (720) 224-1041
Web: texashousers.org

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