IV. Homeless Prevention Program (Statute: 310 ILCS 70/1)

1. A. Purpose and Terminology
2. B. Policies and Procedures
3. C. Contracts and Amendment Procedures
4. D. Program Budget
5. E. Supportive Services
6. F. Provider Responsibilities
7. G. Homeless Prevention Program Deliverables
8. H. Allowable/Unallowable Costs
9. I. Payments on Behalf of Participants
10. J. Time Limitation for Accessing Program Funding
11. K. Funding Caps and Other Eligibility Criteria
12. L. Program Monitoring

A. Purpose and Terminology

The Homeless Prevention Program provides rental/mortgage assistance, security deposit assistance, utility assistance, approved case management, and approved supportive services to individuals and families who are in imminent danger of eviction, foreclosure or are currently homeless. Supportive services must directly relate to the prevention of homelessness. These services are provided in an effort to stabilize families in their existing homes, shorten the amount of time that individuals and families stay in shelters, and assist individuals and families with securing affordable housing. The households must document to the provider a temporary economic crisis beyond household control, by giving evidence of at least one of the following conditions:

• loss of employment
• medical disability or emergency
• loss or delay of some form of public benefit
• natural disaster
• substantial change in household composition
• victimization by criminal activity
• illegal action by a landlord
• displacement by a government or private action, or
• some other condition which constitutes a hardship comparable to the other conditions enumerated above.

The households must also be able to demonstrate an ability to meet prospective rental/utility obligations or mortgage payments after assistance has been granted based on current or anticipated income. Payments for Homeless Prevention services must be made to a landlord, utility company or other vendor who provides housing or other services on behalf of an applicant for assistance. Payments cannot be made directly to an applicant. The following terminology is used in the Homeless Prevention Program:

• Case Management:  Coordinating the acquisition, delivery and use of supportive services. Case management must include individual assessments that are used to develop individual service plans. There is up to a maximum of 10% allowed for case management.
• Continuum of Care:  A Continuum of Care system provides multi-point access and linkages to services by service providers. The main functions of the Continua are outreach and assessment, emergency shelter, transitional housing, permanent housing, and supportive services.
• Financial Counseling: Budgeting/financial planning to ensure that participating households have the ability to maintain their rental/mortgage or utility obligations after assistance has been granted to reduce the probability of a recurrence of the crisis situation.
• Follow-up: Contacting each program participant or family assisted during the fiscal year to assess their housing status and provide the results to IDHS.
• Supplemental Nutrition Assistance Program (SNAP) Screening/Coordination (formerly known as Food Stamps) and Low Income Home Program Energy Assistance Program (LIHEAP) Screening Coordination: Screening every household that receives Homeless Prevention Program assistance to determine the need and eligibility for assistance and based on that determination, assist the participant with the application process or referral.
• Housing Location/Inspection:  Locating and/or the initial inspection of rental property on behalf of participants to ensure the housing is generally decent and adequate for the household and meets the general health and safety standards prior to tenant occupancy.
• Outreach:  Locating and contacting at risk persons in the community and informing them of available services. Informing community partner organizations about the availability of services.
• Rental/Mortgage Assistance: Payment of rent/mortgage and/or arrears in the amount established as necessary to defeat eviction/foreclosure, prevent homelessness, or shorten the amount of time spent homeless.
• Security Deposit:  Payment of a rent or security deposit.
• Supportive Services:  Supportive Services, where appropriate, to prevent homelessness or repeated episodes of homelessness.
• Utility Assistance:  Payment of utility bills and arrears.

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B. Policies and Procedures

1. Grant Funding Application For Homeless Prevention:  Funding for the Homeless Prevention Program is provided annually by IDHS. The funding announcement is directed to the local Continuum of Care (CoC) with the availability of funds. Those groups, in turn, solicit proposals from local agencies that serve homeless families and individuals. The CoC then recommends projects for funding to IDHS. IDHS determines which applications will be funded and the funding amounts. Upon execution of the contract, Homeless Prevention providers will receive payments as prescribed by IDHS.  IDHS reserves the right to advance additional funds to an agency beyond the prescribed method when it is in the best interest of the provider and/or the Homeless Prevention Program.
2. Reporting Requirements:  Each recipient agency is required to report quarterly on fiscal expenditures and participant services. Quarterly reports are due on October 20, January 20, April 20, and July 20.
3. Board of Directors:  Each provider is required to submit names of board members and chief officers who oversee the agency. The provider must maintain a current list of the board members and their terms of office and a list of phone numbers and email addresses of the board members. The board must meet at least quarterly and maintain meeting minutes. The provider must maintain a policy on conflict of interest for board of director's members.
4. 501(c)(3):  If the provider is not a governmental entity, the provider must be a federally tax exempt, non-profit agency legally authorized to operate in the State of Illinois with a Not-for-Profit Corporation Charter from the Illinois Secretary of State and verification from the Internal Revenue Service of exemption from federal income tax liability under the applicable Section 501(c)(3) or 501(c)(4) of the Internal Revenue Code. Each provider must submit documentation of not-for-profit status and their 501(c)(3) status. Each provider must certify that it complies with all provisions of the Federal Internal Revenue Code, the Illinois Revenue Act, and all rules promulgated thereunder, including withholding provisions and timely deposits of employee taxes and unemployment insurance taxes. Also, an annual report must be on file with the Secretary of State that the provider is a not-for-profit provider. This report will be sent by the Secretary of State to each provider's registered agent 45 to 60 days in advance of the date of the provider's incorporation. A provider can contact the Secretary of State, Office/Annual Report Section at (217) 782-6961 with any questions or conflict resolutions.
5. Records:  The provider must maintain written policies and procedures regarding its fiscal activities, including but not limited to, payroll, purchasing, cash management, relevant fee schedules, contracts and risk management. The provider must submit and have on file a copy of their Annual Report to the Internal Revenue Service Form 990 and an Annual Report to the Attorney General Form AG 990. The provider must show proof that its governing body has approved a budget at least annually. All fiscal records are to be maintained for at least five years after the end of the fiscal year to which they relate. Failure to maintain adequate records to document the expenditure of IDHS funds creates a presumption in favor of the Department for recovery of the funds. The provider must have on file the by-laws, policies and procedures and a current organization chart. The provider must maintain policies concerning the hiring, termination, evaluation, and discipline of staff. Also, the provider must have policies on non-discrimination in hiring, employment, sexual harassment as well as written job descriptions of employees' duties and responsibilities.
6. Participant Information and Data:  Each provider must report quarterly on the number and characteristics of households served and the supportive services provided. IDHS provides a web-based reporting system for the Homeless Prevention Program. Quarterly reports should include information on household composition and household income. Reasons for particular services being utilized include: maintaining a current residence, move from a current residence to other permanent housing, or move from a shelter to other permanent housing.
7. Participant Files:  Each Homeless Prevention provider is required, at a minimum, to keep participant files with regard to rental/mortgage assistance, utility assistance, security deposits, supportive services, case management, participant intake forms, assessment forms, participant outcomes/follow-up, life skills data and other information involving the participants for a five-year period.
8. Follow-up:  The Homeless Prevention Program requires submission of a follow-up report after the end of each fiscal year.  The follow-up report is conducted to help determine if participants are maintaining independent living and self-sufficiency. Three months (90 days) after receiving Homeless Prevention assistance, each household must be contacted, and their current living situation assessed by the provider. Contact attempt(s) must be made in at least one of the following ways: the household is contacted by phone, the landlord is contacted by phone, or a letter is sent to the household with a self-addressed, stamped postcard requesting a response as to their current housing status. All of these options should be exhausted before concluding that a household is unable to be located.
   Based on the results of that contact attempt, each household should then be placed into one of four follow-up categories: contact was made and the household is still living in the same location, contact was made and the household is living in a different location, contact was made and the household is now homeless, or a contact attempt was made and the household was unable to be located. 

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C. Contracts and Amendment Procedures 

1. Contract Procedures and Approvals:  Providers to be awarded funding will be notified, in writing, of annual contract award submittal dates and procedures for contracting.
   
2. Amendment, Submittals and Approvals:  If necessary, a provider may file a modification to the Funding Application. Modifications or amendments to the funding and services plan must be submitted by the provider, in writing, and are subject to approval by the Illinois Department of Human Services, Bureau of Basic Supports. All sub-contracts or pass-through funding agreements must meet all terms and conditions of the IDHS Community Services Agreement and must be approved by IDHS prior to entering into any sub-contractual or pass-through funding arrangement.

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D. Program Budget

1. Homeless Prevention Program Budget:  The Homeless Prevention Program budget establishes how funds will be used in program implementation during the fiscal year. Agencies are required to track all IDHS funds by program and budget line item.
2. Financial Management System:  Providers must have an established financial management system which provides complete, separate, and accurate accountability of funds. The provider's accounting system must be well-maintained, up to date, and provide the following original documentation:
   1. Bank reconciliations;
   2. Trial balance;
   3. Separate identification of program expenses in a general ledger;
   4. Complete accountability of all obligations, payments, and reimbursements;
   5. Justification of allocations;
   6. Written administrative and accounting procedures;
   7. Segregation of duties for internal control; and
   8. Maintain an accounting system that isolates IDHS funds and allows tracking of IDHS expenditures.
3. Budget Revisions - Amendment Process:
   All budget revisions and amendments for the Emergency Food Program must be made within the parameters of and in accordance with the federal grant awarded by USDA. The budget revision/amendment process may include:
   1. Letters of increase or decrease; A letter is sent to the provider stating the intent to increase or decrease dollars to a contract. There is no need for the provider to sign and return this document.
   2. Formal amendments; An agreement executed by the provider and IDHS constitutes a formal amendment. The following is required for a formal amendment to be processed:
      1. Adding new program services: An amendment to add a new program service must contain a detailed summary of services to be provided under the amended contract and the method of payment
      2. Extending the service date of the contract: An amendment to extend the service date of the contract must contain the following information: Agreement number as it appears on the original contract; provider name; clause stating the new term; signatures of the provider and the Secretary of the Illinois Department of Human Services.
      3. Extending the service dates of an existing program: An amendment to extend the dates of a specific program in the existing contract must contain the following information: Agreement number as it appears on the original contract; provider name; clause stating the new term of the agreement; signatures of the provider and the Secretary of the Illinois Department of Human Services.
      4. Changing the language within an existing program attachment only: An amendment to change the language of a specific program attachment of an existing contract must contain the following information: Agreement number as it appears on the original contract; provider name; clause(s) stating the new language of the agreement; signatures of the provider and the Secretary of the Illinois Department of Human Services.
4. Fiscal Audits:  If deemed necessary, a program and fiscal audit will be conducted by the IDHS Office of Contract Administration.
5. Match Requirements: The Homeless Prevention Program does not require matching funds.
6. Recovery:  The Office of Contract Administration (OCA) is responsible for financial reconciliation and financial recovery of unspent funds. As part of the funds recovery procedure, the Office of Contract Administration will send to each provider an "Informal Notice" letter containing the state fiscal year, the provider's name and FEIN number, and the amount of IDHS funds provided to each provider. The letter will also include a Grant Reconciliation Report to be completed by each provider. The provider will have fifteen days from the receipt of the informal notice to request, in writing, an informal hearing on lapsed funds or a plan of correction dealing with other violations. If the informal hearing does not result in a resolution of the lapsed funds, a "Formal Notice to Recover Lapsed Funds" letter will be sent by registered mail to the provider. The provider will then have thirty-five days to request, in writing, a Formal Hearing. At the end of thirty-five days, if no request has been received, the OCA may proceed to recover the amount of funds. If the provider does not have an upcoming fiscal year contract from which to deduct the lapsed funds owed, the Bureau of Collections will establish a collection account in the name of the provider. The Bureau of Collections will generate an invoice and mail it to the provider for payment. The provider will then receive monthly billing statements. The debt may also be referred by the IDHS to the Attorney General's Office if the debt remains unpaid for one year.
7. Program Payments: Upon execution of a contract, providers will receive payments as prescribed by IDHS. IDHS reserves the right to advance additional funds to the agency beyond the prescribed method when it is in the best interest of the provider to do so.

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E. Supportive Services 

The supportive services provided through the Homeless Prevention Program are those deemed necessary to move people to self-sufficiency. Homeless Prevention providers should be aware that supportive services can only be offered to the extent that they directly relate to the prevention of homelessness or repeated episodes of homelessness. There are two categories of supportive services:

1. Required Services - Supportive services that are built into the scope of the Homeless Prevention Program and are part of the service plan that every participating household receives. The required supportive services provided by the Homeless Prevention Program are limited to the following:
   1. Case Management
   2. Financial Counseling
   3. Food Stamp Service Coordination/Screening
   4. LIHEAP Service Coordination/Screening
   5. Follow-Up
2. Supplemental Supportive Services provided with other funding - Supportive services not funded directly through the Homeless Prevention Program, but still offered to participating households (through other in-house service programs or referrals to partnering agencies in the network) as a supplement to housing assistance. These services include, but are not limited to, the following:
   1. Outreach
   2. Advocacy
   3. Counseling
   4. Mental Health Services
   5. Alcohol Abuse Services
   6. Substance Abuse Services
   7. Health/Dental Services
   8. Education
   9. Transportation
   10. Employment Services
   11. Child Care
   12. Children's Services
   13. Housing Placement/Inspection
   14. HIV/AIDS Related Services
   15. English as a Second Language
   16. Legal Services (as requested)

F. Provider Responsibilities

All providers must provide open access to the program for everyone on a non-discriminatory basis. Also, the provider must submit, on a quarterly basis, an accurate participant services and fiscal report. Providers must report supportive services in addition to participant assistance data. In addition, the service facility must be accessible and meet ADA requirements. The provider must operate during normal business hours, at a minimum. All Providers will also adhere to an appeal process developed with the local Continuum of Care when assistance is deemed ineligible but challenged by the prospective participant.  The Appeal Process for denial of services must be submitted annually with the Funding Plan.

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G. Homeless Prevention Program Deliverables

All deliverables will be verified by on-site monitoring visits, through review of data in the required web-based reporting system or by other means as the Department deems necessary.

• All providers will have a referral process that assists program participants with enrollment into public benefit programs such as TANF, Supplemental Nutrition Assistance Program (SNAP, formerly known as Food Stamps), All Kids, medical assistance, disability assistance, as well as other resources that address the needs of the population targeted for service. The outcome will be verified through on-site field monitoring, and/or through web-based reporting or submission of this information in the Annual Funding Plan.
• All providers will attend local Continuum of Care homeless network meetings and report on progress and distribution of funds from the Illinois Department of Human Services (IDHS). The outcome will be verified through on-site field monitoring, the web-based reporting system, or submission of this information in the Annual Funding Plan.
• All providers will have a community outreach plan which includes a detailed description for notifying the community of the program, hours of operation, and admittance/eligibility requirements into the program(s) they administer for IDHS. This plan must include outreach to other community service agencies, court and sheriff's personnel involved with eviction matters, and other outreach entities. IDHS must be advised of any publications and distribution of flyers, printed materials, and brochures that are part of the IDHS funded program. The outcome will be verified by on-site field monitoring, or submission of this information in the Annual Funding Plan.
• All providers will document participant need and eligibility, and will maintain documentation in the participant files for a minimum of five years. All providers must use the "Homeless Prevention Documentation Checklist" tool to assure completeness of the participants files. The outcome will be verified by on-site field monitoring, or submission of this information as part of the required documentation in the Annual Funding Plan.
• All providers will expend program funds under any of the allowable cost categories: prevention rental/mortgage assistance, security deposit assistance, utility assistance, approved case management, and approved legal services according to program rules and consistent with the purposes of the Homeless Prevention Act. The outcome will be verified by on-site field monitoring, and/or quarterly reporting.
• All providers will adhere to IDHS program requirements including non-discrimination and community-wide access to Homeless Prevention program services. The outcome will be verified by on-site field monitoring, review of the Centralized Repository Vault (CRV) or submission of this information as part of the documentation in the Annual Funding Plan.
• All providers will conduct a follow-up report. The follow-up report is due as determined by IDHS. 
• All providers will have the ability to download the IDHS SNAP (formerly Food Stamps) application and distribute it to households to determine their need, and based on that determination, assist with a Low-Income Home Energy Assistance Program (LIHEAP) application or referral. The outcomes will be verified by on-site field monitoring, and/or quarterly reporting.
• All providers must assess each household to determine their eligibility for the Low-Income Home Energy Assistance Program (LIHEAP), and based on the determination assist the participant with the application process or referral, if applicable.
• All participants will have a complete intake and assessment done upon entry into the program.  Providers must submit all intake and assessment forms to IDHS annually for approval. Intake and assessment will be verified by on-site field monitoring, and through annual submission with Funding Plans.
• All providers will have a written agreement or Memorandum of Understanding for referrals to other social service providers.  The agreement or Memorandum at a minimum must include:
  • type(s) of service(s) to be provided; and
  • how referrals will be handled by each entity; and
  • follow-up actions.
• All providers will report deliverables and outcomes using the Homeless Prevention web-based reporting system.
• The following projected data are also included in the provider's Grant Funding Application:
  • the projected total number of households served; and
  • the projected number of households receiving rental/mortgage assistance; and
  • the projected number of households receiving utility assistance; and
  • the projected number of households receiving security deposit assistance.

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H. Allowable/Unallowable Costs

The Homeless Prevention Program costs are limited to specific categories. The following are allowable and unallowable costs under the Homeless Prevention Program:

1. Allowable Costs: Direct Costs
   1. Payment of rent or mortgage on behalf of clients
   2. Payment of rent or mortgage arrears on behalf of clients
   3. Payment of utilities and utility arrears on behalf of clients
   4. Payment of a security deposit on behalf of clients
   5. Supportive services (including approved legal services)
      • The total of the above services for each household may not exceed the dollar value of six months' worth of the client's rent or mortgage amount.
      • The total of the above services must comprise 85% - 100% of the total grant award
   6. Case management (staff salaries and fringe benefits)
   7. g. Direct administrative costs (direct administrative salaries and fringe benefits, telecommunications, and program supplies)
      • The total of F and G cannot exceed 15% of the total grant award
2. Unallowable Costs:  Any costs other than client rent or mortgage assistance, client utility assistance, client security deposit assistance, case management, approved supportive services, and limited direct administrative costs are not allowed.

I. Payments on Behalf of Participants

Payments for Homeless Prevention services must be made to a landlord, utility company or other vendor who provides housing or other services to an applicant for assistance. Payments cannot be made directly to a participant. Providers must have the capacity to issue payments on behalf of participants within five days of approval for assistance.

J. Time Limitation for Accessing Program Funding

1. All eligible Homeless Prevention participants are able to access assistance once every two years.
2. In the event a participant requires additional Homeless Prevention assistance within the 2-year period, exceptions will be considered. The exception will need to be submitted to and approved by IDHS Homeless Prevention Program staff.
   

K. Funding Caps and Other Eligibility Criteria

Continuum of Care organizations that establish funding or eligibility limitations must submit a description of these activities in the annual funding plan to IDHS, accompanied by a description of the appeal process utilized by the Continuum of Care organization.

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L. Program Monitoring

Representatives of the IDHS may perform periodic monitoring reviews, during normal business hours to review the management practices, fiscal procedures or other aspects of the provider's operations to ensure compliance with IDHS, State and Federal rules, regulations and policies. Providers must maintain all participant and fiscal records on site to facilitate program monitoring by IDHS.

1. Notification:  The IDHS will send a written notification at least thirty days prior to visiting a provider if at all possible. Official notice will include a monitoring review sheet that must be completed before the IDHS representative arrives.
2. Initial Site Visit:  Once a new grant is awarded by the IDHS, a representative from or designated by the IDHS may conduct a site visit to advise the provider of the IDHS program standards and reporting documents. The visit is to help the provider understand and follow IDHS rules and regulations. The initial visit to the site is also to make sure all State rules and regulations are followed. The IDHS, when doing a site visit, will review a sampling of all case files to determine service availability and utilization. Included in the case files for example are: intake forms, assessment forms, case management, short and long-term goals, referrals, and medical information.
3. Program Review:  Whenever problems or issues are identified during monitoring, the IDHS will issue a Corrective Action Plan. Technical assistance may be provided by appropriate staff from the IDHS. The IDHS may also make recommendations to the provider.
4. Corrective Action Plans:  Problems of continuing or serious nature may result in a Corrective Action Response from the IDHS. If a site has a serious violation, the provider will be notified in writing within ten days. The provider will then have thirty days to respond with a mandatory written plan of action to the violation. If necessary, the IDHS will conduct a follow-up visit to the provider to ensure implementation of the approved corrective action plan.
5. Technical Assistance:  The IDHS will provide technical assistance to the providers if needed. Upon request, the IDHS will respond to questions pertaining to fiscal reports, policy and procedures, rules and regulations and Federal and State laws.
6. Fiscal Reporting:  Throughout the year, the IDHS will be available to help with questions pertaining to fiscal reporting that is required by the IDHS.  Quarterly fiscal reporting is required.
7. Program:  The IDHS is available to advise the provider, if needed, on the policy and procedures of the program.
8. Training:  The IDHS may conduct mandatory training sessions throughout the year. If feasible, and to the extent possible, the IDHS will notify providers at least 30 days in advance of a mandatory meeting. These training seminars will cover areas such as fiscal reporting, participant reports and other areas designed to help agencies meet State and Federal guidelines and requirements. The agencies are required to attend mandatory training sessions.

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