Substantial Amendment to the Consolidated Plan 2008 Action Plan for the Homelessness Prevention and Rapid Re-Housing Program (HPRP)

Grantees eligible to receive funds under the Homelessness Prevention and Rapid Re-Housing Program (HPRP) are required to complete a substantial amendment to their Consolidated Plan 2008 Action Plan.  This form sets forth the required format for this substantial amendment.  A completed form is due to HUD within 60 days of the publication of the HUD HPRP notice. 

To aid grantees in meeting this submission deadline, the HPRP Notice reduces the requirement for a 30-day public comment period to no less than 12 calendar days for this substantial amendment. With this exception, HPRP grantees are required to follow their Consolidated Plan’s citizen participation process, including consultation with the Continuum of Care (CoC) in the appropriate jurisdiction(s). Grantees are also required to coordinate HPRP activities with the CoC’s strategies for homeless prevention and ending homelessness. To maximize transparency, HUD strongly recommends that each grantee post its substantial amendment materials on the grantee’s official website as the materials are developed.

A complete submission contains the following three documents:

1)      A signed and dated SF-424,

2)      A completed form HUD-40119 (this form), and

3)      Signed and dated General Consolidated Plan and HPRP certifications.

For additional information regarding the HPRP program, visit the HUD Homelessness Resource Exchange (www.hudhre.info).  This site will be regularly updated to include HPRP resources developed by HUD and its technical assistance providers.

The information collection requirements contained in this application have been submitted to the Office of Management and Budget (OMB) for review under the Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520).  This agency may not collect this information, and you are not required to complete this form, unless it displays a currently valid OMB control number.

Information is submitted in accordance with the regulatory authority contained in each program rule.  The information will be used to rate applications, determine eligibility, and establish grant amounts.

Public reporting burden for this collection of information is estimated to be 16 hours, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.  This information is required to obtain benefits. To the extent that any information collected is of a confidential nature, there will be compliance with Privacy Act requirements.  However, the substantial amendment to the Consolidated Plan 2008 Action Plan does not request the submission of such information.

Warning:  HUD will prosecute false claims and statements.  Conviction may result in criminal and/or civil penalties. (18 U.S.C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802)

A.  General Information

*Amounts are available at http://www.hud.gov/recovery/homelesspreventrecov.xls

B.   Citizen Participation and Public Comment

1.      Briefly describe how the grantee followed its citizen participation plan regarding this proposed substantial amendment (limit 250 words).

Response:

The Community Development conducted three meetings to receive input for the 2009 Action Plan on March 20, 2009.  At these meetings, held throughout Berwyn, the CDD also provided an outline of the HPRP requirements and solicited responses.  All participants were also invited to a follow up meeting held at the Senior Center on April 9.

In addition to interested citizens, representatives of Cook County, The Alliance to End Homelessness in Suburban Cook County, Sarah’s Inn, Solutions for Care, Catholic Charities, West Suburban Pads, CEDA, Town of Cicero, Village of Oak Park and the Senior Advocate for Berwyn participated in the April 9 meeting.   Participants in the meeting provided feedback on program design, eligible activities for HPRP funding, and began the development of a coordinated approach among the HPRP recipients in the western suburbs.

The draft Substantial Amendment was made available to citizens, homeless service providers, affected local governments, and other interested parties on April 29, 2009.  A legal notice (attached) was published in the April 29 edition of Berwyn Life newspaper, informed citizens of the Substantial Amendments availability at both the Community Development Department and the City Hall.  A copy of the Substantial Meeting was also posted on the City’s web site (http://www.berwyn-il.gov).  The Draft Substantial Amendment (was) presented to the City Council at a Public Meeting held on April 28.  The official public examination and comment period for the Substantial Amendment (is) April 29 –May 11.

2.      Provide the appropriate response regarding this substantial amendment by checking one of the following options:

                   Grantee did not receive public comments.

                   Grantee received and accepted all public comments.

 Grantee received public comments and did not accept one or more of the comments.

[to be completed after comment period]

3.      Provide a summary of the public comments regarding this substantial amendment. Include a summary of any comments or views not accepted and the reasons for non-acceptance.

Response:

[to be completed after comment period]

C.  Distribution and Administration of Funds

Reminder: The HPRP grant will be made by means of a grant agreement executed by HUD and the grantee. The three-year deadline to expend funds begins when HUD signs the grant agreement.  Grantees should ensure that sufficient planning is in place to begin to expend funds shortly after grant agreement.

1.      Check the process(es) that the grantee plans to use to select subgrantees. Note that a subgrantee is defined as the organization to which the grantee provides HPRP funds.

 Competitive Process  

 Formula Allocation

 Other (Specify: Designation in cooperation with the local continuum of care and an RFQ process.  

2.      Briefly describe the process(es) indicated in question 1 above (limit 250 words).

Response:

Berwyn’s developed its proposed approach to administering the HPRP jointly with the Alliance to End Homelessness in Suburban Cook County, and the Town of Cicero and Village of Oak Park, two neighboring jurisdictions receiving HPRP funds.  To foster a coordinated approach, minimize overhead and simplify reporting and fiscal management, the group will identify three lead organizations with proven capacity in administering homeless prevention programs. 

Beyond the three organization’s that will serve as leads to each of the three HPRP Cities, additional organizations will be identified to provide needed services through an RFQ process.  Through this process, Berwyn will identify organizations that currently provide homeless prevention and re-housing services, and are active continuum members that participate in the areas Homeless Management Information System (HMIS). 

3.      Briefly describe the process the grantee plans to use, once HUD signs the grant agreement, to allocate funds available to subgrantees by September 30, 2009, as required by the HPRP Notice (limit 250 words).

Response:

Berwyn will work together with the Alliance and the other west suburban HPRP grantees to designate subgrantees and to develop memorandum of understandings that contain common program design elements and reporting standards.  Berwyn will designate a lead agency that will serve as a portal to the local network of nonprofit organizations homeless prevention organizations.  Once the agreement between HUD and the City is fully signed, Berwyn will execute memorandums of understanding (subcontract agreements?) with each organization that will provide services in Berwyn.  Berwyn will complete all subcontracting agreements by September 30, 2009.

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4.      Describe the grantee’s plan for ensuring the effective and timely use of HPRP grant funds on eligible activities, as outlined in the HPRP Notice.  Include a description of how the grantee plans to oversee and monitor the administration and use of its own HPRP funds, as well as those used by its subgrantees (limit 500 words).

Response:

Berwyn will execute subgrantee agreements that clearly define performance expectations and implement a monitoring plan that emphasizes accountability in performance, meeting of expenditure milestones, record keeping and reporting.    The City intends to execute [one/two] year agreements with subgrantees with the goal of expending the vast majority of HPRP funds within two years.  Remaining funds, or funds that are not being expended in a timely fashion, will be reallocated to ensure that 100% of funds are expended within three years. 

The City will work closely with its subgrantees to ensure that their efforts remain targeted on reaching program objectives and that they remain in compliance with program requirements.   Subgrantees will be instructed to invoice monthly using financial request forms that will be provided. 

The City will meet with each subgrantee at start up, and at least quarterly during the initial year to ensure that the program is on track.  Monitoring visits include review of client files for proper documentation for all eligible services received as well as a financial review.  The City will also monitor expenditure rates monthly and will recapture funds that do not meet expenditure milestones.  Invoices will be reviewed for proper documentation and that they are consistent with both the requirements of the Integrated Disbursement Information System (IDIS) and quarterly and annual HPRP reports.

D.  Collaboration

1.      Briefly describe how the grantee plans to collaborate with the local agencies that can serve similar target populations, which received funds under the American Recovery and Reinvestment Act of 2009 from other Federal agencies, including the U.S. Departments of Education, Health and Human Services, HohOMHomeland Security, and Labor (limit 250 words).

Response:        

As municipalities working together, Berwyn, Cicero, and Oak Park will ensure that local agencies and our subgrantees work with ARRA-funded agencies serving similar populations to ensure that resources are targeted collaboratively.  The coordinated intake and database management process will provide up-to-date information to ascertain client eligibility to access these resources, and case managers will refer individuals to available resources as appropriate. 

The referral process will include such public benefit programs as TANF, food stamps, LIHEAP assistance, medical and disability assistance, and local EITC, IDA, and education tax credit programs.  The grantees will coordinate with federal and state agencies receiving ARRA funds or facilitating their delivery.

2.      Briefly describe how the grantee plans to collaborate with appropriate Continuum(s) of Care and mainstream resources regarding HPRP activities (limit 250 words).

Response:

The Continuum serves as a primary information and communication link regarding homeless and its prevention in Cook County.  The grantees will attend Continuum meetings and provide periodic HPRP program updates, including the numbers served and types of assistance provided.  The grantees will also confer with individual Continuum members to discuss such matters as referrals, case management, and service delivery.  Berwyn and the other grantees will also work closely with the continuum to ensure that subgrantees enter beneficiary and accomplishment information directly into HMIS.   The grantees will also work with the State of Illinois and the Alliance to End Homeless in Suburban Cook County to address barriers that may arise in accessing mainstream services and implement the HPRP program effectively in each community.

3.      Briefly describe how HPRP grant funds for financial assistance and housing relocation/stabilization services will be used in a manner that is consistent with the grantee’s Consolidated Plan (limit 250 words). 

Response:

Berwyn’s consolidated plan recognizes that the prevention of homelessness is a critical element of community and household stabilization.  HPRP adds an important component to the consolidated plan’s comprehensive approach to homelessness and its prevention.  HPRP will bolster existing efforts to provide public services and employment opportunities to special at-risk populations, such as the elderly, youth, and the disabled.  HPRP funds will also expand the scarce resources that have been available for financial assistance and stabilization services under the City’s consolidated and action plans.  These additional resources will reduce the stress on the City’s housing stock and ameliorate the need for emergency shelters. 

E.  Estimated Budget Summary

HUD requires the grantee to complete the following table so that participants in the citizen participation process may see the grantee’s preliminary estimated amounts for various HPRP activities. Enter the estimated budget amounts for each activity in the appropriate column and row. The grantee will be required to report actual amounts in subsequent reporting.

¹Financial assistance includes the following activities as detailed in the HPRP Notice: short-term rental assistance, medium-term rental assistance, security deposits, utility deposits, utility payments, moving cost assistance, and motel or hotel vouchers.       

²Housing relocation and stabilization services include the following activities as detailed in the HPRP Notice: case management, outreach, housing search and placement, legal services, mediation, and credit repair.

³Data collection and evaluation includes costs associated with operating HUD-approved homeless management information systems for purposes of collecting unduplicated counts of homeless persons and analyzing patterns of use of HPRP funds.  

⁴This amount must match the amount entered in the cell on the table in Section A titled “Amount Grantee is Requesting.”

F.  Authorized Signature

By signing this application, I certify (1) to the statements contained in the list of certifications and (2) that the statements herein are true, complete, and accurate to the best of my knowledge. I also provide the required assurances and agree to comply with any resulting terms if I accept an award. I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties. (U.S. Code, Title 218, Section 1001)

___________________________________________________     ___________________ Signature/Authorized Official                                                             Date

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