225 Program Guide (24-444-22-3139-01)

Housing is Recovery Pilot Program

Purpose
Eligible Grantees
Program Participant Eligibility Requirements
Referral Process
Eligible Costs
Rent and Utility Payment Standards
Data Reporting
1. Monthly Participant Data Reporting:
2. Quarterly Performance and Financial Reporting:

Purpose

The triple aim of the Housing is Recovery pilot program is:

Preventing institutionalization and overdose deaths;
Improving health outcomes and access to recovery support services; and
Reducing State costs.

DMH will evaluate this pilot program over the pilot period and may make changes to program policies and procedures as necessary to ensure that the triple aim above is achieved.

Eligible Grantees

Eligible grantees must:

Be a certified Community Mental Health Center (CMHC) providing Rule 132 services or have a contract/memorandum of understanding (MOU) with a CMHC to provide mental health or substance use disorder engagement and treatment services for all participants in this program.
Be able to administer housing subsidies or have a contract/MOU with a partner who can administer housing subsidies for all participants in this program.
Be able to complete Housing Quality Standards (HQS) inspections of potential housing units or have a contract/MOU with a partner who can complete these inspections timely.
Have staff trained to provide SSI/SSDI Outreach, Access, and Recovery (SOAR) services or have a contract/MOU with a partner to provide these services to all eligible participants in this program.
Be qualified/authorized to provide services to people with serious mental illness or people with substance use disorder at high risk of overdose.
Secure and provide housing units for purposes of immediate temporary housing following hospital discharge or release from a correctional facility while a long-term rental unit is secured.

Grantees must meet all other eligibility and prequalification requirements required by the Grant Accountability and Transparency Act (GATA) as outlined on the IDHS Grant Application Information & Instructions page.

Program Participant Eligibility Requirements

Eligible consumers must be at least 21 years of age or aging out of guardianship under the Department of Children and Family Services, and eligible to enroll in, or enrolled in, Medicaid, and fall into one of the two eligibility categories below. For this program, "homeless" is defined in 59 Ill. Adm. Code 145.20.

Individual at high risk of unnecessary institutionalization: a person who has a serious mental illness (as defined in 59 Ill. Adm. Code 145.20) who is homeless (or will be homeless upon hospital discharge or correctional facility release) and who has:

Had three or more psychiatric inpatient hospital admissions within the most recent 12-month period;
Had three or more stays in a State or county correctional facility in the State of Illinois within the most recent 12-month period;
Been incarcerated in a State or county correctional facility in Illinois for the most recent 12 consecutive months; or
A disability determination due to a serious mental illness and has been incarcerated at least once in a State or county correctional facility in Illinois within the most recent 12 consecutive months.

Individual at high risk of overdose: a person with a substance use disorder who is homeless (or who will be homeless upon hospital discharge or correctional facility release) and who has:

Had three or more hospital inpatient or inpatient withdrawal management or community-based withdrawal management stays for a substance use disorder within the most recent 12-month period;
Had three or more stays in a State or county correctional facility in the State of Illinois within the most recent 12-month period;
Been incarcerated in a State or county correctional facility in Illinois for the most recent 12 consecutive months; or
Had one or more drug overdoses in the last 12 months.

Eligible consumers must also meet all the following additional criteria:

This program is open to single-person households, except for participants with a medically necessary live-in aide.
Participants must have income at or below 30% of the area median income (AMI) as defined by the federal Department of Housing and Urban Development (HUD).
Participants must not currently be receiving rental assistance under another local, State, or federal housing program.
Participants must be placed on, or agree to register for, the Illinois Housing Development Authority (IHDA) Statewide Referral Network (SRN) and Section 811 waiting lists.
Participants must be on a current Public Housing Authority waiting list for a Housing Choice Voucher (HCV) or agree to register or apply for an HCV or comparable permanent rental subsidy when registration or application opportunity becomes available.

Referral Process

Grantees in this pilot program should build relationships with various settings, including hospitals, county jails, prisons, homeless shelters, and inpatient detoxification facilities. Grantees should develop a process for identifying eligible individuals before hospital discharge, correctional system release, or other appropriate referral places, including homeless shelters. Grantees must provide DMH with a description of their referral process and information on any limitations they provide on their ability to serve all eligible individuals. Grantees' referral and intake process should facilitate rapid housing to the greatest practical extent possible.

DMH can provide grantees with technical assistance in building relationships with correctional settings, including the Illinois Department of Corrections. DMH may also facilitate referrals between pilot program grantees where appropriate.

Eligible Costs

Rental Application Fees:

Funds may pay for a reasonable rental housing application fee that the owner charges to all applicants according to their regular business practices. These costs typically range from $25 to $80 in Illinois but are not regulated or limited under Illinois law.

Inspection Costs:

HUD Housing Quality Standards (HQS, 24 CFR 982.401) will apply to all assisted units. An HQS inspection must be completed before any assistance is provided for a unit and must also be conducted annually (within 12 months after the previous inspection). Grantees may use the HUD inspection form (HUD-52580A (pdf)) and inspection checklist (HUD-52580 (pdf)) to ensure that a property meets HQS guidelines. If a unit fails initial inspection, the owner or designated agent must be informed of the deficiencies and agree to remediate noted deficiencies promptly, and a follow-up inspection must be completed within 14 days. If the owner or designated agent refuses to remediate noted deficiencies or if the unit fails the follow-up inspection, the unit will be ineligible for any financial assistance. Extensions beyond 14 days may be granted if the owner or designated agent demonstrates a good faith effort to remediate the deficiencies within a mutually agreed upon timeframe. Program funds may be used for the following activities:

Staff time necessary to perform and document inspections;
Reasonable per inspection fees charged by a third-party vendor to conduct HQS inspections, with a contract or MOU in place; and/or
HQS certification fees, including any recertification or CEU fees for maintaining third-party certification, for grantee staff. Certification fees for the staff of third-party vendors are not an eligible cost.

Security Deposits: Funds may pay for a security deposit on behalf of a program participant that is equal to no more than two months' rent and will be refunded to the program participant as stipulated in the lease agreement as an incentive for the program participant to care for the property. Additionally, the following conditions apply:

Program funds may not be used to pay security deposits for subsequent moves beyond the initial move-in while a participant remains in the program without approval in advance in writing by authorized DMH staff.
Non-refundable move-in fees charged by a property may be paid instead of security deposits (not in addition to) if those fees total no more than 75% of one month's rent. Fees for subsequent moves beyond the initial move-in require approval in advance in writing by authorized DMH staff.

Utility Deposits:

Funds may pay for a standard utility deposit, and/or standard connection fees, required by the utility company for all customers of the utility services eligible for Utility Allowances/Payments under this program. Grantees are responsible for ensuring that all program participants complete applications for the Low-Income Home Energy Assistance Program (LIHEAP) on an ongoing basis. Utility arrearages are not an eligible cost under Utility Deposits or Utility Allowances/Payments for this program.

Landlord Incentives:

If necessary, to obtain a housing unit for a program participant or to secure temporary housing units for immediate housing, grantees may pay the following incentives on behalf of the program participant:

The security deposit may be increased by an additional (third) month's rent as long as it is still refundable to the program participant as stipulated in the lease agreement, as an additional incentive for the program participant to care for the property;
A one-time, non-refundable signing bonus that is equal to no more than two months' rent; and/or
Paying the cost to repair damages or remediate conditions (such as infestations incurred or caused by the program participant) that are clearly documented and not covered by the security deposit, and/or that are incurred while the program participant is still residing in the unit.

Program funds may not be used to pay for landlord incentives for subsequent moves while a participant remains in the program without approval in advance in writing by DMH staff. Grantees are also strongly encouraged to "negotiate up" when offering incentives to owners or their designated agents to minimize the cost necessary to secure a housing unit and maximize the number of program participants that each grantee can serve.

Transition Assistance Funds:

Funds may pay for other necessary and reasonable costs associated with placement into an assisted unit under this program. These funds are one-time and capped at $3,000 total. Funds must be paid for directly by the grantee (not given to the program participant) and may only be offered at the initial program move-in (subsequent moves while remaining in the program are ineligible). A list of pre-approved expenses will be provided by the DMH Program Contact. These expense may include (but are not necessarily limited to):

Moving costs, such as truck rental or hiring a moving company;
Basic living and storage furniture;
Window air conditioner units (required purchase when not provided under the lease for housing units with no central air conditioning);
Basic kitchenware, dishes, and utensils necessary for food preparation, storage, and consumption;
Linens necessary for bedding and hygiene; and/or
Other basic supplies needed for hygiene, garbage disposal, and cleaning/disinfecting.

Any use of funds outside the pre-approved expense list must be approved in advance in writing by the DMH Program Contact. Grantees must make a good faith effort to minimize these costs or acquire necessary furnishings through other resources, and they should describe those efforts or lack of other resources in their request to authorized DMH staff to fund these costs.

Rental Assistance/Leasing Payments:

Contract rent may be paid directly to a property owner or their designated agent as stipulated in the lease agreement, in accordance with the Rent and Utility Payment Standards for this program.

Utility Allowances/Payments:

In cases where utility costs are not included in the contract rent, meaning utilities are tenant-paid, grantees must provide program participants with a Utility Allowance using program funds, or Utility Payments must be made directly in accordance with the Rent and Utility Payment Standards for this program. Utility arrearages are not an eligible cost under Utility Deposits or Utility Allowances/Payments for this program.

Subsistence Allowances:

Funds may be payable directly to program participants who have no income (or their representative payee) in the maximum amount of $300 per month for basic expenses only under the following conditions:

Participants must meet one of the following requirements:
- Currently enrolled and engaged in documented SSI/SSDI Outreach, Access, and Recovery (SOAR) services and participating in at least 4 hours of vocational activity per month (as documented for the previous month) with an Individual Placement and Support (IPS) Supported Employment Provider or a Community Rehabilitation Provider (CRP); or
- Participating in at least 8 hours of vocational activity per month (as documented for the previous month) with an Individual Placement and Support (IPS) Supported Employment Provider or a Community Rehabilitation Provider (CRP).
For both vocational service options, the number of vocational activity hours must be documented by the supporting IPS/CRP provider monthly via progress notes submitted with monthly billing.
Eligible vocational activities include:
Discovery
Visual résumé
Job club
Job shadow
Volunteering
Informational interviews
Financial counseling
Transitional jobs (i.e., agency enterprises)
Work trials
Internships
Other activities approved in advance and in writing by DMH staff
Participants are eligible for allowances only after they have moved into and remain living in a unit assisted by this program.
Participants receiving SSI/SSDI benefits are not eligible to receive Subsistence Allowances. The allowance must be terminated after payment is made the month following the first or lump sum payment received from the Social Security Administration.
Participants obtaining employment must have their allowance terminated after payment is made the month following the first full month of employment. Participants working at least 6 hours/week at $13/hour will earn more by working than by receiving the allowance.
Program participants are eligible for the Subsistence Allowance for a maximum of 24 months ($7,200 total). Extensions may be requested of and authorized by DMH program staff in writing and will only be granted where considerable efforts to secure benefits and/or employment are evident and documented.

Temporary/Immediate

Housing: Grantees should secure temporary housing units to provide immediate housing to individuals who are discharging from hospitals or being released from a correctional facility. These temporary housing units may be used for immediate temporary housing, not to exceed 90 days, to prevent consumers from reentering homelessness or unstable housing, or avoiding unnecessary institutionalization. Temporary housing units must meet HQS standards, but may be single-room occupancy units or other non-permanent supportive housing settings.

Engagement and Support Services:

Funds can be used to pay for engagement services that assist the consumer with maintaining their housing, and wraparound support, including linkage to mental health or substance use recovery support services if the consumer is open to receiving such linkage. These engagement services must be provided at least twice per month, with at least one of the visits being a home visit. Engagement services must be provided in a home- or community-based setting and do not require a clinic visit. Services that are reimbursable by Medicaid or any other source are ineligible for the Housing is Recovery pilot program funds. Additional support services that can be paid for by this grant include:

Determining and documenting program eligibility for participants;
Housing search and placement activities;
Arranging inspections, although conducting inspections falls under Inspection Costs above;
Negotiating and communicating with property owners or designated agents;
Determining, documenting, and arranging payments for costs eligible under this program;
Any other activities necessary to ensure compliance with this program that are not reimbursable billable to other sources, including Medicaid.

Rent and Utility Payment Standards

Income Eligibility:

Calculations for program eligibility and any financial assistance under this program will be in accordance with HUD regulations for Assisted Housing for Annual income (24 CFR 5.609), and grantees must retain written documentation of the specific sources of income included in the gross income calculation. Calculation summaries must also include signatures by both the grantee and program participant to certify that the calculation is inclusive of all applicable sources of income or that the program participant has no income from any applicable sources at the time of calculation. Program participants must have an income at or below 30% of the Area Median Income (AMI) as calculated by HUD.

Fair Market Rent:

In general, Payment Standards for Rental Assistance Payments and Utility Allowances/Payments will be at or below the Fair Market Rent (FMR) for the unit size and the geographical area in which the unit is located. Metropolitan and Small Area FMRs apply where applicable, and the updated FMRs for each Federal fiscal year by geographical area can be found at huduser. Where justified by the lack of available affordable housing in the local housing market, DMH may allow a grantee to apply a subsidy to rent up to 120% of FMR. This approval must be requested and granted in writing in advance.

Rent Reasonableness:

The contract rent charged for a unit must be reasonable in relation to rents currently being charged for comparable units in the private unassisted market and must not be in excess of rents currently being charged by the owner for comparable unassisted units. Grantees must complete and retain documentation of a rent comparison for that unit and no less than 3 other units in the private unassisted market that take into consideration:

The location, quality, size, unit type, and age of the contract unit; and
Any amenities, housing services, maintenance and utilities to be provided by the owner in accordance with the lease.

Unit Size:

Since this program is limited to single-person households, Payment Standards for units larger than one bedroom may be assigned only for program participants requiring a live-in aide or who need additional room to store medical equipment. The grantee must retain documentation of the medical necessity for the live-in aide or medical equipment from a professional that is licensed or certified to make such a determination. All units must still pass the required HQS inspection(s). The number of bedrooms needed for an individual must be used for the calculation of Payment Standards but is not intended to restrict program participants from moving into available units with additional bedrooms if the total rent and utility costs for the units meet the Payment Standards for the allowed unit size, and smaller units are not readily available in the market where the program participant chooses to reside. For example, a program participant assigned a Payment Standard for a one-bedroom unit may move into a two-bedroom unit if the rent and utility costs do not exceed the FMR for a one-bedroom unit and no appropriate one-bedroom units are readily available.

Leasing Requirements:

Grantees will have two options for leasing arrangements: the Rental Assistance Option or the Master Lease Option. Grantees can make this determination individually for each program participant based on their needs, unit availability in the housing market, and conditions necessary for grantees to establish relationships with property owners or their designated agents to secure units.

Rental Assistance Option: Grantees will need to have two agreements in place: a lease and a Housing Assistance Payment (HAP) contract under the following conditions:

The program participant will be the sole liable party to the lease, requiring the program participant to pay rent directly to the owner or designated agent.
The grantee must have a Housing Assistance Payment (HAP) contract with the owner or designated agent governing the payment of rental assistance.
The grantee must make rental assistance payments to the owner or designated agent based on the difference between the Contract Rent and the Total Tenant Payment less the Utility Allowance.
The grantee is not responsible for the portion of rent paid by the program participant if the program participant misses a rent payment in any given month.
The grantee cannot make rental assistance payments on a vacant unit except:
- If a unit assisted under this program is vacated before the expiration of the lease, the assistance for the unit may continue for a maximum of 30 days from the end of the month in which the unit was vacated, unless occupied by another eligible participant;
- No additional assistance will be paid until the unit is occupied by another eligible participant; and
- Stays in long-term care facilities, specialized mental health rehabilitation facilities (SMHRFs), or correctional facilities of less than six months are not considered vacancies, and the grantee will continue to make rental assistance payments during such stays.
HAP contract templates can be provided to grantees but are not intended to be used by grantees without revision. Grantees should consult with legal counsel and use a form that complies with state and local law in addition to the requirements of this program. The Illinois Department of Human Services assumes no liability for the use or content of HAP agreements between grantees and property owners/agents.

Master Lease Option: Grantees will need to either have one or two agreements in place: a Lease and Sublease Agreement (combined), or a Lease Agreement and either a Sublease Agreement or an Occupancy Agreement under the following conditions:

The grantee will be the sole liable party to the lease, or the lease must clearly indicate that the tenant will have no liability of any kind with respect to any amounts which may be payable under the Lease and Sublease Agreement.
Program funds may not be used to lease units or structures owned by the grantee, their parent organization(s), their subsidiary organization(s), any other related organization(s), or organizations that are members of a partnership, where the partnership owns the structure, unless authorized DMH staff have granted an exception in writing for good cause.
The grantee is responsible for paying the full Contract Rent regardless of whether the program participant pays their portion of rent.
The grantee may make leasing payments on vacant units under the following limitations:
- When a unit is newly leased by a grantee, rent can be paid out of program funds for up to 90 days prior to occupancy by a program participant.
- If a unit leased under this program is vacated before the expiration of the lease, the leasing payments for the unit may continue for a maximum of 30 days from the end of the month in which the unit was vacated, unless:
  - The unit is occupied by another eligible program participant; or
  - Another eligible program participant has been identified for occupancy in the unit and will occupy the unit within 90 days of when a program participant moves out of the unit.
- Stays in long-term care facilities, specialized mental health rehabilitation facilities (SMHRFs), or correctional facilities of less than six months are not considered vacancies.

Total Tenant Payment (TTP):

The monthly amount a program participant will have to contribute toward their rent and utilities will be the highest of the following amounts, rounded to the nearest dollar:

30 percent of the participant's monthly adjusted income, calculated by dividing the adjusted income (24 CFR 5.611) by 12 months; or
10 percent of the participant's monthly income, calculated by dividing the annual income (24 CFR 5.609) by 12 months.

The following conditions also apply to Total Tenant Payments:

Any lost or terminated income sources can be immediately discounted upon documentation of termination being provided by the program participant and a new income calculation may be made to determine the subsequent TTP.
Any increase in income can be discounted until the next Income Eligibility calculation is required (minimally every twelve months, or when a new lease is executed, whichever comes first).
Subsistence Allowances provided through this program are exempt and will not be included in any income or rent/utility payment calculations for program participants.
TTP must be applied first towards Utility Allowances before being applied to Contract Rent. Where a utility allowance exceeds a program participant's monthly rental contribution, a utility reimbursement may be paid to the program participant or their representative payee.
The remaining portion of the TTP after Utility Allowances are subtracted will be the amount of Contract Rent that the program participant will be responsible for paying (Tenant Rent Payment or TRP).
Grantees must require program participants to make their Tenant Rent Payments:
- Directly to the property owner or designated agent when the program participant is sole liable party to the lease, under the Rental Assistance Option; or
- Directly to the grantee when the grantee is sole liable party to the lease, under the Master Lease Option.

Utility Allowances/Payments:

For any tenant-paid utilities, not included in the lease and paid for by the owner or designated agent, grantees must either provide a Utility Allowance to program participants when the program participant is sole liable party to the lease (Rental Assistance Option) or must make full payments for the actual costs of utilities when the grantee is sole liable party to the lease (Master Lease Option). Utility Allowances are meant to cover the approximate cost of tenant-paid utilities, not the actual cost, and must be based on the utility allowance schedule developed by the Public Housing Authority (PHA) covering the geographic location of the property. Utility allowances must be deducted from a program participant's Total Tenant Payment, or if the utility allowance exceeds the program participant's monthly rental contribution, a utility reimbursement must be paid directly to the program participant or their representative payee. In addition, providers are responsible for ensuring that all program participants complete an application for the Low-Income Home Energy Assistance Program (LIHEAP). Eligible utilities are only those that are included in the PHA's utility allowance schedule and are required for:

Heating;
Cooking;
Water heating;
Electricity;
Water supply;
Sewer waste;
Trash collection; and/or
Air conditioning.

Data Reporting

Monthly Participant Data Reporting:

IDHS will provide grantees with an Excel spreadsheet template that must be completed monthly with information on all participants referred to and/or enrolled in the Housing is Recovery pilot program. This template will capture data on consumer demographics, outcomes, and service delivery. Data elements to be reported monthly are listed in Exhibit E and must be reported using the prescribed template. This spreadsheet must be completed correctly and submitted to the DMH Program Contact no later than the 5th business day of each month, containing information on all consumers referred or served during the prior month.

Quarterly Performance and Financial Reporting:

Grantees are required to submit the Periodic Performance Report Template by Program (PRTP) and Periodic Performance Report (PPR) to

DHS.DMHQuarterlyReports@illinois.gov

no later than 30 days after the end of each quarter. Periodic Financial Reports (PFRs) must also be submitted quarterly. The PRTP template will be provided by the DMH Program Contact, and the PPR and PFR templates are available on the Provider section of the DHS website. Data elements to be tracked and reported on the PRTP are listed in Exhibits E & F.