Substantial Amendment to the FY 2011 Annual Action Plan for the Second Allocation of Emergency Solutions Grants (ESG

) Program Funds 1. SF-424 2. Consultation Process
• Consult with the Continuum(s) of Care within the geographic area on: o Determining how to allocate ESG funds for eligible activities The jurisdiction collaborates with the Human Services Advisory Council (HSAC) to coordinate efforts and programs serving people who are homeless as well as the allocation of ESG funds for eligible activities. Comprehensive Emergency Assistance Systems/Continuum of Care (CEAS/CoC) falls under the HSAC umbrella. Every year the opportunity to compete for ESG funds is made available to agencies. County staff review the applications for completeness, eligibility and compliance with needs addressed in the 5 Year Consolidated Plan, the Homeless Plan and the Continuum of Care. In response to the new ESG, applications must now meet a need serving the homeless population in one of these core areas: homeless prevention and rapid re-housing, street outreach, emergency shelters or HMIS. The County’s (HSAC) Program Review Committee reviews, hears presentations by the applicants, ranks and makes funding recommendations of the applications, according to the following criteria: 1. Compliance with regulations regarding eligibility 2. Meeting a County goal as defined in the Homeless Plan1 3. Consistency with the Consolidated Plan 4. Having a designated match 5. Providing a direct service to the homeless with priority given to prevention and rapid re-housing 6. Financial need 7. Timeliness Program Year 2011 was atypical; the HUD award amount was not firm until late in the year. Because there were hints of increased funding to be made available, this jurisdiction allowed applicants to submit 2 applications: 1 at the original amount, 1 at the increased amount. They
1

The County's Homeless Plan was developed by the Department of Human Services and this Division of Community Development in response to the needs and concerns identified in the Continuum of Care. The plan addresses the need for more permanent supportive housing as well as affordable rental properties and it emphasizes the need for financial resources for supportive services.

were briefed on the changes proposed for ESG and the new emphases shifting from emergency shelters to prevention and rapid re-housing. Most reflected this change in their amended applications. Four providers were recommended for funding, as outlined in the charts on pages 3, 4, and 5. o Developing the performance standards for activities funded under ESG Presently, performance standards, or outcomes, are requested to be defined in the ESG grant application. In compliance with 576.400, the jurisdiction is working with the CoC to collaborate on revised standards reflecting the HEARTH Act. Standards listed in #9 were derived from previous CoC submissions as well as provider outcomes identified in ESG applications. The jurisdiction will consult with CEAS on proposed performance standards. o Developing funding, policies, and procedures for the operation and administration of the HMIS. The County of Morris Continuum of Care (CoC), serving the Morris County jurisdiction, submitted a “Declaration of Intent” to NJHMFA to participate in the NJ Statewide HMIS Collaborative. The CoC committed to work with NJHMFA and other state agency staff to facilitate implementation of the HMIS Collaborative with appropriate provider agencies in the CoC. In addition, the CoC committed to: 1. Represent and participate in the Advisory Committee for the Statewide HMIS Collaborative and workgroups as needed 2. Participate in cost sharing 3. Work with NJHMFA and other State agency staff to support implementation activities 4. Work with NJHMFA as project sponsor for the HMIS Supportive Housing Program Application. Currently, the jurisdiction’s ESG grant application states the requirement of entering data into HMIS. Because ESG includes HMIS related expenses as an eligible activity, the rules outlined in the Interim Rule will be included in the jurisdiction’s grant applications and agreements with subgrantees.

3. Summary of Citizen Participation Process
• Summarize citizen participation process used: The County of Morris has developed the following criteria for “what constitutes a substantial change” to the approved Consolidated Plan requiring an amendment: a.A project is cancelled and deleted from the program; b.A new project, not previously described, is proposed; c.A change to its allocation priorities or a change in the method of distribution of funds. The County of Morris will formally amend an annual Action Plan when: a. An activity is cancelled and deleted from the program; b. A new activity, not previously described, is proposed; c. A change of purpose, scope or location necessitates a new environmental assessment; d. More than 50% of the original beneficiaries of an activity have changed.

2

Notification of a substantial amendment will be published and note a 30 day comment period. Notification of an Action Plan amendment will also be published and note a 7 day comment period. The County of Morris will consider any comments received in writing, or orally at public hearings in preparing amendments. A summary of comments, accepted or not accepted, will be attached to the amendments. • Summarize the public comments or views received: • Summarize the comments or views not accepted and include the reasons for not accepting those comments or views. There were no comments or views that were not accepted. Revisions to the Citizen Participation Plan will be proposed to comply with the ESG regulations.

4. Match
• Describe: o types of cash and/or non-cash resources used as match o specific amounts of resources used as match o proposed uses of match resources Homeless Solutions, Inc. SSH Volunteer Hours In-Kind Donations Foundations Proposed Uses of Match Resources Interfaith Council Jersey Battered for Homeless Women Families in Morris Services, Inc. County 5,000 17,368 16,777 Family Shelter Program Case Management/PSH Nights of Shelter Homeless Prevention Services Morris County Office of Temporary Assistance 16,777

5. Proposed Activities and Overall Budget
a. Proposed Activities • All recipients must include the following details for each proposed activity: 1) corresponding priority needs from recipient’s Annual Action Plan 2) concise description of the activity, including the number and types of persons to be served 3) corresponding standard objective and outcome categories 4) start date and completion date 5) ESG and other funding amounts • Local governments must include the following details for each proposed activity: 6) one or more performance indicators 7) projected accomplishments, in accordance with each indicator, to be made within one year

3

8) projected accomplishments, in accordance with each performance indicator, to be made over the period for which the grant will be used for that activity Project sheets from CPMP tool have been attached. b. Discussion of Funding Priorities • Explain funding the proposed activities at the amounts specified (use locally-relevant data to support the funding priorities, and explain how the funding priorities will support the national priorities established in Opening Doors: Federal Strategic Plan to Prevent and End Homelessness) Applicant Funding Proposed New ESG Rationale Recommendation Activity
Interfaith Council for Homeless Families Jersey Battered Women Services Morris County Office of Temporary Assistance Homeless Solutions $17,368 $5,000 Case Management/PSH Nights of Shelter Homelessness Prevention Emergency Shelter Identified as High Priority Need Provides safety for women and children fleeing domestic violence Identified as High Priority in ending homelessness Preventing families from living on the streets is a priority.

$16,777

Housing stabilization Family Shelter Program

Homelessness Prevention Emergency Shelter

$16,777

Each of the proposed activities is consistent with “Opening Doors: Federal Strategic Plan to Prevent and End Homelessness” which identifies four overarching goals: o Finish the job of ending chronic homelessness in 5 years o Prevent and end homelessness among Veterans in 5 years o Prevent and end homelessness for families, youth, and children in 10 years o Set a path to ending all types of homelessness • Identify any obstacles to addressing underserved needs in the community. The highest ranking factors that Point in Time respondents stated conributed to their homelessness, in order of importance, were: o Lost job/cannot find work o Alcohol or drug abuse problems o Housing costs too high o Relationship/family breakup/death o Mental illness/emotional problems o Medical problems/phsicalor developmental disability o Eviction

4

Juxtaposed are the following identifed obstacles to providing associated services to address the previously listed causes for homelessness: “lack of supportive service dollars for Housing First2, for payee services and for case management services.”3 Additionally, there are “increasing needs for families, particularly those with complex medical, mental health and housing needs. Families with a high-need parent and/or child who should probably not be housed without intense support are most difficult to place permanently outside our shelter system.”4 The gaps in services and housing for the sheltered and unsheltered chronic homeless are addressed in the county's Continuum of Care. These obstacles include: o serious shortage of affordable housing o lack of programs with adequate resources to reduce excessive rent or mortgage burdens to qualified persons o community resistance to siting special-needs housing programs o lack of sufficient job training and supportive employment opportunities for disabled individuals who would like to return to work, and o nearly non-existent shelter and residential options for active substance abusers o high recidivism in the criminal justice system for individuals dually diagnosed with chronic mental illness and substance abuse o individuals with serious and persistent mental illnesses can be very difficult to engage in treatment, making it especially challenging to provide them with permanent supportive housing.

c. Detailed Budget
• Include detailed budget of planned activities and funding levels accounting for entire second allocation and any reprogrammed funds from the first allocation (may use Table 3 in this Notice). Applicant 1st Round Eligible Activity 2nd Round Eligible Activity Type Type
Interfaith Council for Homeless Families Jersey Battered Women Services Office of Temporary Assistance Homeless Solutions $29,952 $10,000 $29,905 $29,560 Essential Services Operations Prevention Operations $17,368 $5,000 $16,777 $16,777 Prevention Emergency Shelter Prevention Emergency Shelter

2

Housing First is also known as rapid re-housing; it is an alternative to the current system of emergency shelter/transitional housing, BeyondShelter.org. 3 From Homelessness to Housing: A Blueprint to Eliminate Homelessness, 2009. 4 From Homelessness to Housing

5

Total for homeless assistance activities using funds from the first allocation ($69,512) is less than the expenditure limit for emergency shelter and street outreach activities ($93,203) as illustrated below. Full Award 60% Essential Services & Operations 1st Round Emergency Shelter and Street Outreach 2nd Round Balance $155,339 $93,208 $69,512 $21,777 $1,914

6. Written Standards for Provision of ESG Assistance
• If the recipient is a metropolitan city, urban county, or territory: include written standards for providing the proposed assistance. a. Standard policies and procedures for evaluating individuals’ and families’ eligibility for assistance under ESG. Standards and policies will vary slightly to reflect agencies’ targeted populations. The CoC will build on standards and procedures established when HPRP went into effect, to reflect the new regulations and its required use of a coordinated assessment tool. Individuals and families may access the program through multiple entry points: At whichever point a household (single individual or family) contacts the program, they will receive an initial screening to determine potential eligibility and, if preliminarily determined eligible, a more in-depth assessment to both confirm eligibility and begin to develop a housing stabilization plan. The initial screening will determine: o That the program participant does not have an annual income that exceeds 30 percent of median family income for the area, as determined by HUD o When determining the annual income of an individual or family, the standard for calculating annual income under 24 CFR 5.609 will be used o If the household's living situation qualifies as either literally homeless or at imminent risk of homelessness o For those reporting to be imminently at risk, if the household has one or more additional risk factors established which make shelter entry more likely if not assisted. These factors include living currently in a place in which they do not hold a lease, such as doubled up with family or friends, in a hotel/motel or in an institutional setting. Persons holding a lease who have received pay or quit notices will be referred to other programs that offer more traditional prevention services. Person with evictions notices will be referred to legal services. o If the program participant lacks sufficient resources and support networks necessary to retain housing without ESG assistance.

6

1 The initial screening also collects basic demographic information on the household (HMIS universal data elements) and is used to help qualify the household for other services if appropriate and to gather information on those seeking assistance for analysis and program refinement. 2 Households determined initially eligible will receive a full assessment of housing barriers and household resources. Households may be screened out at this point if: o The household appears to have other resources/housing opportunities that it can access to avoid homelessness or become re-housed without ESG Assistance, or o The household has very high or multiple barriers to re-housing and another more appropriate placement or referral can be made. b. Policies and procedures for coordination among emergency shelter providers, essential service providers, homelessness prevention and rapid re-housing assistance providers, other homeless assistance providers, and mainstream service and housing providers. The Morris County CEAS is a sub-committee of the Human Service Advisory Council that is charged with developing and planning a full continuum of care for the homeless. The CoC coordinates housing and services funded for homeless families and individuals. The mission is to meet the specific needs of people who are homeless as they move to stable housing and maximize self-sufficiency. The CEAS Providers group provides a forum for providers of services to share information, resources, skills, contacts and knowledge with one another with the goal of better accessing services and mainstream benefits for clients. If gaps in service are identified in this process, they are reported to the CEAS/COC Committee for review and action. The Division of Human Services coordinates Homeless Management Information System (HMIS) users sessions, which provides an opportunity to discuss common issues and finding ways to collect data uniformly. The county also has a cross systems review committee comprised of homeless service providers, hospital Emergency Room staff, representatives from the department of corrections, and professionals specializing in substance abuse. This review committee will identify gaps in services for homeless substance abusers. c. Policies and procedures for determining and prioritizing which eligible families and individuals will receive homelessness prevention assistance and which eligible families and individuals will receive rapid re-housing assistance. The Office of Temporary Assistance, developed the Services Face Sheet, modeled after the fields identified by HMIS. This tool, originally referred to as the Universal Assessment Tool, was meant to enable multiple points of entry for any client seeking services. It will serve as the foundation for a Coordinated Assessment System.

7

Through the intake process, using the Services Face Sheet, a basic needs assessment is conducted, enabling a determination to be made regarding the provision of homelessness prevention assistance versus rapid re-housing assistance. Eligible households that are literally homeless, as per the HUD definition, at the time of contacting the program, will receive rapid re-housing services. Households seeking shelter entry will qualify for prevention assistance if they are in a housing situation which local data indicates are most likely to lead to a shelter entry -- doubled up with family or friends, in a hotel/motel using their own resources, or leaving an institutional setting. Persons holding a lease with pay or quit notices will be referred to other programs that offer more traditional prevention services. Person with evictions notices may also be referred to legal services Diversion households may receive support to maintain their current housing if that situation is safe and sustainable. It is anticipated that it many cases these diversion households will need similar services to those receiving rapid re-housing, including housing search assistance, deposit and initial rental assistance. d. Standards for determining the share of rent and utilities costs that each program participant must pay, if any, while receiving homelessness prevention or rapid re-housing assistance. Rental assistance will only be provided for housing units, for which the total rent for the unit does not exceed the fair market rent established by HUD, as provided under 24 CFR 982.503, and complies with HUD’s standard of rent reasonableness, as established under 24 CFR 982.507. See attachment for determining rent reasonableness. e. Standards for determining how long a particular program participant will be provided with rental assistance and whether and how the amount of that assistance will be adjusted over time. In order to conserve resources the CoC provides enough support to divert or re-house households quickly, reserving resources for other households, while allowing for increased assistance if needed. Household's entering will receive either 1) deposit only 2) a full or partial deposit and one month rent, intended for household's with a source of income, employment or disability or retirement benefits, sufficient to cover rent after re-housing but with need for initial support to securely transition to housing, 3) full or partial deposit and a short-term subsidy to temporarily bridge the income gap, typically restricted to six months but with extensions permitted with authority approval; 4) services to locate suitable housing with no or low rent. Household's entering at one level needing more assistance can be transferred to a higher level or out of the program to more intensive support.

8

f. Standards for determining the type, amount, and duration of housing stabilization and/or relocation services to provide a program participant, including the limits, if any, on the homelessness prevention or rapid re-housing assistance that each program participant may receive, such as the maximum amount of assistance, maximum number of months the program participants receives assistance; or the maximum number of times the program participants may receive assistance. The objective is to provide enough service to divert or re-house households quickly and reserve resources as much as possible for other households, while leaving the door open for increased assistance if needed. All household's will receive an initial assessment and referrals to appropriate community- based services. Money management/budgeting training will be provided for any household receiving more than one-time assistance. Providers are expected to work with households to obtain benefits, including income and health coverage, or make referrals to agencies that can assist with this. Households in need of housing search assistance will receive help identifying units and making applications to landlords. Households receiving (6 months) rental assistance will receive housing and income-focused support services, ensuring that the household has the support needed to make progress on the housing stabilization plan and that the landlord is satisfied that the household is receiving support for housing related needs. Households may be extended for an additional three months, during which time they may transition off of subsidy but continue to receive services or may receive both services and subsidy. Written standards for recipients who are eligible and decide to use part of the second allocation of FY 2011 funds for emergency shelter and street outreach activities Using the HUD established formula for determining eligible costs within the 60% cap for street outreach and emergency shelter, the jurisdiction is able to fund two shelters (Homeless Solutions and Jersey Battered Women Services), which have provided standards as included below. a. If funding any emergency shelter activities with second allocation: policies and procedures for admission Homeless Solutions, Inc. (HSI): Morris County individuals and families are referred to the shelter through several means including self referral, agency referral, Drug Court, Intensive Supervision Program (ISP), Mental Health Association, etc. They must complete a phone screen and submit to a criminal background check. If they are deemed eligible and a bed is available they must pass drug and alcohol tests. If they are successful they will be admitted. Anyone not meeting the requirements is referred to County Services, the Homeless Hotline and/or out of County agencies. Jersey Battered Women Services: Intake Procedures PURPOSE: The purpose of the intake procedure is: 1. To make the woman and her children feel welcome, comfortable and safe. 2. To give the woman an opportunity to discuss the abuse that she experienced. 3. To give the woman information regarding Safe House services. 4. To give the woman information regarding Safe House guidelines. 5. To obtain the necessary information from the woman for statistical purposes.

9

6. To give the woman the opportunity to begin to set goals for her Safe House stay. 7. To begin to give the woman the tools to accomplish her goals. PROCEDURE: In order to accomplish the above, the following must be completed: The worker prepares for the woman's arrival at Safe House. The worker confirms that an arrival plan has been discussed with the woman. This plan should include a discussion of a safety plan for the woman, if necessary, and an estimated time when the woman will arrive at Safe House. The worker chooses an appropriate room for the woman and her family. The worker reviews the woman's hotline call(s) and her completed assessment form. The worker attends to the woman when she arrives at Safe House. The worker assesses the woman's needs for physical and emotional comfort. The worker explains the purpose of the intake and schedules a time to complete the intake. The worker completes the intake forms with the woman: The worker reviews Safe House information with the woman. The worker completes the intake interview with the woman. The worker documents the interview on a Supervision Record Form. JBWS: Criteria for Safe House Extensions PURPOSE: 1. To continue to help a client who may be at risk if she left Safe House. 2. To validate that a 60 day stay at Safe House may not be sufficient for all clients to make the changes they are trying to make. 3. To validate the difficulty in finding housing with the limited income available to battered women within a 60 day stay. 4. To validate that legal or health problems may interfere with a client's capacity to leave the Safe House within 60 days. IMPORTANT: Most Safe House residents would benefit from a longer Safe House stay. However, JBWS is a crisis setting. Staff needs to remember that there are Help Line callers in need of emergency Safe House when making extension decisions. If the resident's problems need long term solutions, the client should be referred to Homeless Solutions for continued follow up. Extensions beyond the original 60 day Safe House stay will be given to a resident if: 1. There continues to be a safety concern that prohibits the resident from leaving Safe House. OR 2. All alternative housing arrangements have been explored including family, friends, etc. and are unavailable or inappropriate. AND 3. There are extraordinary factors present which have prohibited the resident from finding an alternative housing arrangement. Diversion HSI: Homeless Solutions has a Skills Curriculum which all guests are required to attend to reduce the possibility of them returning to homelessness. Some of the Core Courses include Budgeting, Credit Counseling, Job Search Skills, Home Hunting, Parenting and Healthy Self.

10

Homeless Solutions also works with Drug Court, ISP and refer guests to Intensive Outpatient Programs (IOP) when necessary. The CoC will work on developing a system-wide diversion policy and procedure. Referral and discharge by emergency shelters assisted under ESG HSI: See Diversion above. In addition Homeless Solutions links guests with the various services in the County including Office of Temporary Assistance, Norwescap, JBWS, Dress for Success, Zufall Clinic, etc. Standards regarding length of stay: Single Men and Single Women may stay up to 3 months. Families are allowed to stay up to 6 months. Safe Haven guests are allowed to stay up to 18 months. JBWS: The Safe House exit should be part of the counseling and advocacy process of a resident's Safe House stay. The exit procedure provides closure to the work of termination with the client. PURPOSE: The purpose of the Safe House exit procedure is: 1. To assist the client and her family in making the transition from Safe House to their new living situation. 2. To assist the client in preparing a safety plan for dealing with potentially abusive situations in the future. 3. To provide the information about other services offered by JBWS, which she and her family might be interested in. 4. To help the client identify resources in the community which she might be interested in. 5. To provide the opportunity for the client to review the accomplishments she has made and the goals which she has achieved during her stay at Safe House. 6. To offer opportunities for the client and her children to remain connected to JBWS through participation in various outreach programs. 7. To obtain necessary data to contact the client and to gather statistical information. PROCEDURE: 1. The primary worker will schedule an appointment with the client to complete the exit interview. 2. The primary worker will complete the Exit Form and provide an Exit Questionnaire for the client to complete. 3. The primary worker will arrange for the return of medication and obtain the room key from the client. JBWS- Referrals PURPOSE: Due to the lack of affordable housing in the area, Safe House residents are usually not able to move from the Safe House to their own apartment. Many times women must be transferred to the homeless Shelters in the area after their exit date. The homeless shelters in Morris County include Homeless Solutions and Family Promise. 11

PROCEDURE: In order to be consistent with our clients who will exit JBWS and go to a homeless Safe House, the following procedure should be followed: 1. All JBWS Safe House residents receive a letter approximately 30 days after they enter Safe House. This "30 day letter" states their scheduled exit date and their exit plan as understood by staff. 2. If a JBWS resident does not have an exit plan, the Daytime Advocate will discuss a referral to a homeless Safe House. If the resident wants to consider these options, the Daytime Advocate will obtain consent to release information to the Shelters that is appropriate to that client. This discussion should take place 2 weeks prior to the resident's exit date. 3. The primary worker should help the client prepare for this transfer by visiting the Shelter (if available) and assisting the resident to get any questions answered that she may have. 4. The client should contact the homeless shelters and inform them of their exit date and put their name on the waiting list. The Daytime Advocate should confirm this information with the homeless shelter. 5. The client may request an extension at JBWS until a bed is open at the homeless shelter by presenting the need in writing to their primary worker. The primary worker must be clear that if the resident's plan is to go to a homeless shelter, an extension will only be considered until a bed is available there. 6. The primary worker should provide this information to all staff by writing it in the briefing book and presenting it at case review. If the primary worker will not be at case review, inform the Client Services Manager. If the resident is requesting an extension, this information must be presented in writing. 7. When an opening exists for a JBWS resident at Homeless Solutions or Family Promise Shelters, their staff will contact both the client and the JBWS daytime worker. Both Shelters will try to complete these calls 2-3 days prior to the exit date so that the resident and her children may be prepared for the transfer. 8. The primary worker will contact a Homeless Solutions or Family Promise caseworker and describe the community agencies with whom the client is involved. 9. Homeless Solutions will determine the resident's room at their shelter. JBWS may advocate based on special conditions for a resident to be placed in their second floor program. The decision will ultimately be up to the Homeless Solutions staff. 10. JBWS staff will try to help the resident to move her possessions with the assistance of volunteers. A resident may not leave her possessions at JBWS after her exit date. If the resident is receiving help from TANF and needs additional storage space, she should discuss this with her Office of Temporary Assistance worker.

12

Safeguards to meet the safety and shelter needs of special populations and persons with the highest barriers to housing. HSI: All guests are drug and alcohol tested during admission and randomly thereafter. Monthly fire drills are performed. Security checks “walk through” of the entire building and outside are performed during each shift. The security camera is monitored between checks to ensure safety and compliance of the facility. When guests returns to the building they and their belongings are inspected for contraband. Random dorm checks for contraband are performed. JBWS Diversity Values Statement JBWS affirms its commitment to diversity and inclusion and will foster and develop our cultural competency* to ensure that commitment. We believe that diversity enhances our ability to accomplish our mission and facilitates our growth as an organization. We are committed to creating and maintaining an environment where every individual is respected, welcomed and appreciated. We value safety and justice for all individuals. We recognize that oppression and the abuse of power foster violence. We will seek to identify and remove barriers to services. We will serve victims and survivors of domestic violence, persons using abusive behavior, and each of their families in a manner that embraces the richness of our differences and does not discriminate on the basis of gender, ethnicity, race, age, immigration or citizenship status, sexual orientation, economic status, religion, national origin, culture, disability, health status or intellectual perspective. We commit to foster a respectful, inclusive work environment that provides support and encouragement, nurtures leadership, and emphasizes the effective use of the talents and abilities of all staff and volunteers. We strive to maintain an atmosphere of respect and trust in which we feel safe to explore and discuss our attitudes, beliefs, values, and behaviors in relation to others who are similar to and different from ourselves, regardless of our position within the organization. We recognize that in order to do this, that we continually need to educate ourselves, examine our personal prejudices and cultivate positive behavioral change in one another. This means challenging ourselves and others in the broader community in an ongoing, mutually respectful dialogue. Because we believe that every individual is important in a unique way and adds to the overall quality of the organization, we will strive to recruit and retain qualified diverse staff on every level of the agency and to foster an environment that draws strength from, celebrates, and honors diversity. We strive to embody these values within the organization and in our work throughout the community. *Cultural competence means that organizations have a defined set of values and principles, and demonstrate behaviors, policies and structures that enable them to work effectively crossculturally in all types of culture, not just national origin.

13

7. Describe Process for Making Sub-awards
The process is a competitive process whereby the community is able to submit a grant application seeking ESG funds. County staff review the applications for completeness, eligibility and compliance with needs addressed in the 5 Year Consolidated Plan and the Continuum of Care. Applications must meet a need serving the homeless population in one of these core areas: homeless prevention and rapid re-housing, street outreach, emergency shelters or HMIS. The County’s Human Services Advisory Committee (HSAC) Program Review Committee (PRC) reviews, hears presentations by the applicants, ranks and makes funding recommendations of the applications, according to the following criteria: 1. Compliance with regulations regarding eligibility 2. Meeting a County priority need as defined in the Homeless Plan 3. Consistency with the Consolidated Plan 4. Having a designated match 5. Providing a direct service to the homeless 6. Financial need 7. Timeliness o The PRC submits its funding recommendations to the HSAC for its approval. o HSAC funding recommendations are submitted to the County’s Community Development Revenue Sharing Advisory Committee (CDRS) for its approval. o The CDRS submits its funding recommendations to the Board of Chosen Freeholders for its approval. o At this point the sub-award recommendations are sent to HUD for final approval.

8. Homeless Participation Requirement
• For those recipients who cannot meet the participation requirement in § 576.405(a), the substantial amendment must include a plan that meets the requirements under § 576.405(b). Homeless participation has traditionally been encouraged by the CoC but efforts will be enhanced to comply with the new ESG regulations. The Division will approach homeless providers and recipients of ESG funds to provide opportunities to obtain feedback on services and needs from individuals who are homeless. A CoC Homeless Plan subcommittee has established a questionnaire to be used at focus group settings, to solicit input from people who are homeless in preparation for the “10 Year Plan to End Homelessness Planning Retreat.” This questionnaire is suitable for use in various situations in order to pursue regular input, e.g. soup kitchen and drop-in center. People who are known to be homeless have been invited to participate at CoC meetings, make a presentation at a HSAC meeting and participate in the retreat referred to in the paragraph above.

14

9. Performance Standards
• The recipient must describe the performance standards for evaluating ESG activities, which must be developed in consultation with the Continuum(s) of Care. PS: Using targeting criteria to maximize chances that assistance is given to those who are already homeless or are at risk of becoming homeless. How: Updated by way of review of HMIS data PS: Reducing number of people living on streets and in emergency shelters How: track where people enter the program; compare information to PIT count data. PS: Shorten time people spend homeless How: rapid re-house within 45 days of homelessness and prevention assistance with 14 days for households who are not moving, and 45 days for households who are. PS: Ensure assistance provided is effective at reducing barriers. How: the greatest barrier to housing for most clients is lack of income. Measure: Percent of households leaving with employment income Percent of households entering with no income but leave with an income PS: Increase the percent of participants in all CoC funded projects that are employed at program exit to 20% or more PS: <10% of households assisted return to the homeless system within 12 months. PS: Create new permanent housing beds for chronically homeless persons PS: Increase the percent of participants remaining in CoC funded permanent housing projects for at least six months to 77 % or more.

PS: Increase the percent of participants in CoC funded transitional housing that move into permanent housing to 65% or more.

PS: Decrease the number of homeless households with children.

10. Requirements for recipients who plan to use the risk factor under paragraph (1)(iii)(G) of the “at risk of homelessness” definition

15

• If recipient plans to serve persons “at risk of homelessness,” based on the risk factor “otherwise lives in housing that has characteristics associated with instability and an increased risk of homelessness:” describe specific characteristics associated with instability and increased risk of homelessness. Prevention activities will be recommended for funding and these subrecipients will use HUD’s definition of “At risk of homelessness” as outlined in 576.2 of the Interim Rule: An individual or family who: (i) Has an annual income below 30 percent of median family income for the area, as determined by HUD; (ii) Does not have sufficient resources or support networks, e.g., family, friends, faith-based or other social networks, immediately available to prevent them from moving to an emergency shelter or another place described in paragraph (1) of the ‘‘homeless’’ definition in this section; and (iii) Meets one of the following conditions: (A) Has moved because of economic reasons two or more times during the 60 days immediately preceding the application for homelessness prevention assistance; (B) Is living in the home of another because of economic hardship; (C) Has been notified in writing that their right to occupy their current housing or living situation will be terminated within 21 days after the date of application for assistance; (D) Lives in a hotel or motel and the cost of the hotel or motel stay is not paid by charitable organizations or by Federal, State, or local government programs for low-income individuals; (E) Lives in a single-room occupancy or efficiency apartment unit in which there reside more than two persons or lives in a larger housing unit in which there reside more than 1.5 persons reside per room, as defined by the U.S. Census Bureau; (F) Is exiting a publicly funded institution, or system of care (such as a health-care facility, a mental health facility, foster care or other youth facility, or correction program or institution); or (G) Otherwise lives in housing that has characteristics associated with instability and an increased risk of homelessness, as identified in the recipient’s approved consolidated plan; (2) A child or youth who does not qualify as ‘‘homeless’’ under this section, but qualifies as ‘‘homeless’’ under section 387(3) of the Runaway and Homeless Youth Act (42 U.S.C. 5732a(3)), section 637(11) of the Head Start Act (42 U.S.C. 9832(11)), section 41403(6) of the Violence Against Women Act of 1994 (42 U.S.C. 14043e– 2(6)), section 330(h)(5)(A) of the Public Health Service Act (42 U.S.C. 254b(h)(5)(A)), section 3(m) of the Food and Nutrition Act of 2008 (7 U.S.C. 2012(m)), or section 17(b)(15) of the Child Nutrition Act of 1966 (42 U.S.C.1786(b)(15)); or (3) A child or youth who does not qualify as ‘‘homeless’’ under this section, but qualifies as ‘‘homeless’’ under section 725(2) of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11434a(2)), and the parent(s) or guardian(s) of that child or youth if living with her or him.

11. Requirements for Optional Changes to the FY 2011 Annual Action Plan Centralized or Coordinated Assessment System
• If the recipient’s jurisdiction, or a portion of the recipient’s jurisdiction, currently has a centralized or coordinated assessment system and the recipient or subrecipients utilize the centralized or coordinated assessment system, the recipient should describe the assessment system in the substantial amendment.

16

The CoC is planning to develop a coordinated assessment system by building on the ‘Universal Assessment Tool’ developed for HPRP, revising this tool to incorporate updates in the Office of Temporary Assistance ‘Face Sheet’ as well as providers’ specific clientele’s characteristics.

12. Monitoring
• If existing monitoring procedures are not sufficient to allow recipients to monitor compliance with the new requirements, HUD encourages recipients to update their monitoring standards and procedures in the process of submitting this substantial amendment. This should address appropriate levels of staffing. The three basic goals for monitoring progress and performance of ESG subgrantees include: o Ensuring that ESG funds are used effectively to assist homeless individuals and families and that the basic ESG program goals are met; o Ensuring compliance with ESG regulations and program requirements in the usage of funds and in carrying out program activities; and o Enhancing and develop the management capacity of subgrantees. Areas for Monitoring The areas for monitoring and oversight include the following: o Eligible Activities Requirements - Ensure those subgrantees are using ESG funds as originally planned and for eligible activities. Determine if costs are properly classified and if spending limits on certain activities have been properly adhered to. Ensure that the activities funded by ESG benefit homeless persons and that they are provided at a reasonable cost. o Financial Regulations - Ensure those subgrantees are appropriately following financial management requirements. o Program Disbursements - Ensure that subgrantee draw down funds in compliance with requirements. o Procurement and Audits - Ensure that subgrantee comply with such requirements. o Conflict of Interest, Environmental Compliance, and Other Federal Requirements - Ensure that subgrantee comply with these requirements. There will be annual: o Physical site inspections of the subgrantee activity locations to observe and insure compliance with the current grant agreements. o Review of subgrantee site client files. o Interview with staff. o Review of job titles and job descriptions for all ESG funded positions, insuring that the disbursed ESG funds are being utilized while fulfilling all program policy guidelines. Monitoring Process: o Formal and advance notification of the visit; o Coverage of the areas outlined; and o Clear conclusions and recommendations provided to the grantee following the visit. 17

10. Certifications
Attached

18