IX. Shelter Diversion

  1. Purpose and Terminology
  2. Policies and Procedures
  3. Program Deliverables and Outcomes
  4. Contracts and Amendment Procedures
  5. Program Budget
  6. Supportive Services
  7. Program Monitoring

A. Purpose and Terminology

The Shelter Diversion program prevents homelessness at the front door of the homelessness response system by helping people identify immediate alternative housing arrangements and, if necessary, connecting them with services and financial assistance to help them remain in or return to permanent housing. Every effort should be made to divert program participants to other housing solutions at their first contact with the homelessness response system. This program's intent is to limit the trauma of homelessness on the individual or family and keep limited shelter beds available for those most in need. Shelter diversion does not act as a barrier to shelter.

Program Participant Eligibility Requirements

  1. Eligible program participants are individuals and families who are seeking emergency shelter by accessing Coordinated Entry for a Continuum of Care OR the 'front door' of the homeless response system; AND
  2. Meet the criteria under the HUD definition of "at risk of homelessness" (24 CFR § 576.2); OR
  3. Meet the criteria under Categories 2, 3, or 4 of the HUD definition of homelessness (76 FR 75994)
  4. Program participants may stay up to 14 days/nights in an emergency shelter while diversion services are being provided but must have entered the diversion program prior to (or at the same time as) their admittance into a shelter. Those who stay more than 14 days/nights will not count as successfully being diverted from shelter admission.

The following terminology is used in the Shelter Diversion Program:

Advocacy: Intervening on behalf of program participants to assist in the receipt and use of services.

Alcohol Abuse Services: Providing or arranging services for participants to AA (Alcoholics Anonymous) or other programs that address alcohol abuse issues.

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.

Child Care: Providing or arranging child-care services.

Children's Services: Providing or arranging services for child-specific services, such as child abuse counseling or preschool programs.

Counseling: Providing or arranging for individual or group counseling to alleviate physical abuse, mental health issues, substance abuse, and/or familial obstacles that are preventing a return to self-sufficiency.

Domestic Violence: Providing or arranging services for victims of domestic violence.

Education: Providing or arranging services for participants to complete a course of study leading to a diploma or specific skill certificate.

Employment Services: Providing or arranging services for participants to complete job preparation and/or to secure job interviews or employment. This may include acquiring special tools or clothing to perform the job in which the participant is placed or receiving training.

English as a Second Language: English language services available to persons who seek to improve their English language skills.

Follow up: Assessing the need and providing additional services upon completion of, and discharge from the program.

Health/Dental Services: Providing or arranging services for participants and assuring use of needed medical and dental services.

HIV/AIDS Related Services: Supportive services related to the needs of participants diagnosed with HIV (Human immunodeficiency Virus - is a virus that attacks cells that help the body fight infection, making a person more vulnerable to other infections and diseases) and AIDS (Acquired Immunodeficiency Syndrome - the late stage of HIV infection that occurs when the body's immune system is badly damaged because of the virus).

Housing/Location Inspection: Locating and/or initial inspection of rental property on behalf of participants to ensure that the housing is decent and adequate for the household and meets general health and safety standards prior to tenant occupancy.

Legal Services Referral: Referrals to any legal services which may be needed by participants.

Mental Health Services: Providing or arranging services that address serious and persistent mental disabilities.

Outreach: Locating and contacting homeless persons in the community and informing them of available services.

Overnight/Emergency Shelter: Providing overnight sleeping accommodations for 12 or fewer hours that provides access to at least one meal and provides supportive services. Maximum length of stay to be determined by Provider.

Substance Abuse Services: Providing or arranging services for participants to attend NA (Narcotics Anonymous) or other programs to address substance abuse issues.

Transitional Shelter: Providing shelter, food, and supportive services for up to 24 months.

Transportation: Transporting or purchasing transportation services, such as bus tokens or taxi fares, for participants to obtain medical care, public assistance, education, training, and other services not provided on site.

Voucher Shelter: Providing emergency shelter on a per diem basis at a nearby hotel or motel when other overnight shelter is not available. And also provides supportive services and may provide food.

B. Policies and Procedures

  1. Funding: All funds awarded to a provider must be obligated by the end of the agreement period and expended by the end of the lapse period. Funding is based on the submission and approval of an annual Funding Application. Plans for funding are evaluated on the basis of provider experience, administrative capacity, need in the geographic area, program service plans and budget. Program funding typically runs from July 1 to June 30. The Illinois Department of Human Services determines which plans will be funded, the funding amounts, and has final approval on all funding amounts distributed to providers.
  2. 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.
  3. 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 employee's duties and responsibilities.
  4. Participant Information and Data: Each provider is required to submit quarterly participant outcome data regarding demographics, population and services using the Periodic Performance Report (PPR). Providers report quarterly on the number and characteristics of the people served and the services provided. The reports include information on the demographic characteristics of the participants, the causes of homelessness and conditions or problems of each participant such as substance abuse.
  5. Participant Intake and Assessment Forms: Each provider is required to submit annually for review by IDHS all participant intake forms and assessment forms. Each provider is required to have completed intake and assessments for each participant upon entry into the program.
  6. Participant Files: Each provider is required at a minimum to keep participant files with regard to supportive services, case management, participant intake forms, assessment forms, participant outcomes, life skills data and other information involving the participants for a five-year period.
  7. Centralized Repository Vault (CRV): Each provider is required to upload appropriate documents to the CRV.

C. Program Deliverables and Outcomes

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

Performance Measures

  • Number of persons assessed for diversion (by household type)
  • Number of persons enrolled in diversion services (by household type)
  • Number of persons safely diverted from shelter admission (by household type)
  • Number of persons initially diverted from shelter admission that subsequently return for diversion within 6 months (by household type)
  • Number of households assessed for diversion (by household type)
  • Number of households enrolled in diversion services (by household type)
  • Number of households safely diverted from shelter admission (by household type)
  • Number of households initially diverted from shelter admission that subsequently return for diversion within 6 months (by household type)
  • Living situation (prior to program entry, by household type)
  • Exit destination (by household type)

Performance Standards

100% of households entering program will meet HUD's definition of "at-risk of homelessness" or Categories 2, 3, or 4 of HUD's definition of "homelessness."

30% of households enrolled in diversion services will be safely diverted from shelter admission.

30% of households diverted from shelter admission will exit to a permanent destination (by household type).

50% or less of households initially diverted from shelter admission subsequently return for diversion within 6 months (by household type).

Reporting

  • This program was designed for compatibility with HUD's Annual Performance Report (APR) data reporting standards that are required by HUD to be exported from HMIS (or a comparable database for victim service providers). Grantees are strongly encouraged to utilize HMIS for the reporting burden of this program (not required by IDHS) and for systems-level evaluations by CoCs but must be utilized if the CoC has a policy in place that requires shelter diversion providers to record program and client level data into HMIS. When required, grantees are responsible for ensuring the completion and maintenance of all data fields required by their local Continuum of Care's HMIS and Coordinated Entry policies, procedures, processes, and/or standards. IDHS may require submission of exported APR reports or their equivalent to verify compliance, performance measures, and demographic information for those served through this program.
  • Periodic Financial Reports will be required on a monthly basis and must be submitted no later than 20 days after the end of the reporting month.
  • Periodic Performance Reports will be required on a quarterly basis and must be submitted no later than 20 days after the quarter ends.
  • Other Unique Programmatic Reporting Requirements: Additional annual performance data may be collected as directed by the Department and in a format prescribed by the Department.

D. 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 Housing and Supportive Services. All sub-contracts or pass-through funding agreements must meet all terms and conditions of the Uniform Grant Agreement (UGA) and must be approved by IDHS prior to entering into any sub-contractual or pass-through funding arrangement.
  3. Contract Budget Line-Item Transfers: Providers are allowed to transfer up to a total of $500 among any Direct Service line items without having to obtain written permission from IDHS. The provider should keep a record of the transfer in the event that a monitoring review is conducted.

Program Standards

Diversion is an intervention designed to immediately address the needs of someone who is at imminent risk of losing their housing or someone who has just lost their housing and become homeless. Diversion is a client-driven approach; its goal is to help the person or household find safe alternative housing immediately, rather than entering shelter or experiencing unsheltered homelessness. It is intended to ensure that the homelessness experience is as brief as possible, to prevent unsheltered homelessness, and to avert stays in shelter. Diversion should not be a mechanism for denying access to available shelter, but rather one for finding a better alternative than shelter or the street.

The core components of a Diversion program are a Rapid Resolution problem-solving approach to conversations with individuals experiencing a housing crisis paired with access to flexible funding that supports creative solutions to keep people housed or create new housing options.

E. Program Budget

  1. Annual Program Budget: The annual Program budget establishes how funding is utilized for program implementation during the fiscal year. Several categories are defined within the Program budget including direct cost, direct program cost and payments on behalf of participants. Providers are required to identify the relevant funding sources and the percent of funding used in each budget category. Providers 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, payment, 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: 
    1. Letters of increase or decrease; A computer-generated e-mail is sent to the provider stating the intent to increase or decrease dollars to a contract.
    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 service 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 service 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. 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.
  6. Program Payments:  Payments for the Program will be made as prescribed by the 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.
  7. Provider Responsibilities: The provider must submit, on a timely basis, complete and accurate fiscal and participant service reports. Access to a computer is required for electronic reporting to IDHS. Providers are required to submit quarterly participant service and monthly fiscal reports on the IDHS web-based reporting system. Each is due no later than 20 days after the end of each reporting period. The State of Illinois' fiscal year operates from July 1 to June 30 each year. Participant service reports provide details as to the number and characteristics of the people served and the services provided. Fiscal reports provide detailed line-item expenditures documented for each period. The participant service reports must be submitted quarterly and are due on October 20, January 20, April 20, and July 20. Fiscal reports must be submitted on or before the 20th of each month.

F. Supportive Services

Supportive Services - All eligible supportive services provided must help program participants identify immediate alternative housing arrangements and, if necessary, connect them with services and financial assistance to help them remain in or return to stable housing. Funds may be used to pay the salary and benefits of grantee staff who directly deliver eligible supportive services. It can also cover eligible services contracted with and performed by another agency.  Additionally, any overhead costs directly related to providing supportive services are eligible. Eligible supportive services are:

  • Moving costs - reasonable one-time costs are eligible and include truck rental and hiring a moving company. Up to 90 days of storage costs may also be included if necessary to prevent loss of personal belongings.
  • Case management - costs of assessing, arranging, coordinating, and monitoring the delivery of individualized services to meet the needs of the program participant(s) are eligible costs. Component services and activities consist of:
    • Conflict resolution/mediation;
    • Connections to family or natural supports;
    • Counseling;
    • Developing, securing, and coordinating services - especially with local Homeless Prevention, Rapid Re-housing, LIHEAP, and other local rent and/or utility assistance programs;
    • Using the centralized or coordinated assessment system as required;
    • Obtaining federal, State, and local benefits;
    • Monitoring and evaluating program participant progress;
    • Providing information and referrals to other providers;
    • Providing ongoing risk assessment and safety planning with victims of domestic violence, dating violence, sexual assault, and stalking; and
    • Developing an individualized housing and service plan, including planning a path to permanent housing stability.
  • Housing search and placement services - costs of assisting eligible program participants to locate, obtain, and retain suitable housing are eligible:
    • Component services or activities are tenant counseling; assisting individuals and families to understand leases; physically inspecting units to ensure compliance with housing quality standards; securing utilities; and making moving arrangements.
    • Other eligible costs are:
      • Mediation with property owners and landlords on behalf of eligible program participants;
      • Credit counseling, accessing a free personal credit report, and resolving personal credit issues; and
      • The payment of rental application fees.
  • Legal services - eligible costs are the fees charged by licensed attorneys and by person(s) under the supervision of licensed attorneys, for advice and representation in matters that interfere with the individual or family's ability to obtain and retain housing.
    • Eligible subject matters are child support; guardianship; paternity; emancipation; legal separation; orders of protection and other civil remedies for victims of domestic violence, dating violence, sexual assault, and stalking; appeal of veterans and public benefit claim denials; landlord tenant disputes; and the resolution of outstanding criminal warrants.
    • Component services or activities may include receiving and preparing cases for trial, provision of legal advice, representation at hearings, and counseling.
    • Fees based on the actual service performed (i.e., fee for service) are also eligible, but only if the cost would be less than the cost of hourly fees. Filing fees and other necessary court costs are also eligible. If the grantee is a legal services provider and performs the services itself, the eligible costs are the grantee's employees' salaries and other costs necessary to perform the services.
    • Legal services for immigration and citizenship matters and issues related to mortgages and homeownership are ineligible. Retainer fee arrangements and contingency fee arrangements are ineligible.
  • Mental health services - eligible costs are the direct outpatient treatment of mental health conditions that are provided by licensed professionals. Component services are crisis interventions; counseling; individual, family, or group therapy sessions; the prescription of psychotropic medications or explanations about the use and management of medications; and combinations of therapeutic approaches to address multiple problems.
  • Outpatient health services - eligible costs are the direct outpatient treatment of medical conditions when provided by licensed medical professionals including:
    • Providing an analysis or assessment of an individual's health problems and the development of a treatment plan;
    • Assisting individuals to understand their health needs;
    • Providing directly or assisting individuals to obtain and utilize appropriate medical treatment;
    • Preventive medical care and health maintenance services, including in-home health services and emergency medical services;
    • Provision of appropriate medication;
    • Providing follow-up services; and
    • Preventive and non-cosmetic dental care.
  • Substance use treatment services - costs of program participant intake and assessment, outpatient treatment, group and individual counseling, and drug testing are eligible. Inpatient detoxification and other inpatient drug or alcohol treatment are ineligible.
  • Transportation - Eligible costs are:
    • The costs of arranging and providing program participant's travel on public transportation, through ride share services (such as Uber, Lyft, etc.), or in a vehicle provided by and operated by the grantee to and from services eligible under this section or to access the program's participants natural supports for the purposes of diversion.
    • Gas cards/vouchers may be provided to program participants operating their own vehicles under the stipulation that that the cards/vouchers being utilized can only be used for gas and are not general gas station gift cards or vouchers that would allow people to buy other items from gas station convenience stores (must be clearly documented).
    • Mileage allowance for service workers to visit program participants;
    • The cost of gas, insurance, taxes, and maintenance for a vehicle in which staff transports program participants and/or staff serving program participants;
    • The costs of grantee staff to accompany or assist program participants to utilize public transportation; and
    • If public transportation options are not sufficient within the area, the grantee may make a one-time payment on behalf of a program participant needing car repairs or maintenance required to operate a personal vehicle, subject to the following:
      • Payments for car repairs or maintenance on behalf of the program participant may not exceed 10 percent of the Blue Book value of the vehicle (Blue Book refers to the guidebook that compiles and quotes prices for new and used automobiles and other vehicles of all makes, models, and types);
      • Payments for car repairs or maintenance must be paid by the grantee directly to the third party that repairs or maintains the car; and
      • The grantee may require program participants to share in the cost of car repairs or maintenance as a condition of receiving assistance with car repairs or maintenance.
  • Direct provision of services - if the supportive service described in this section is being directly delivered by the grantee, eligible costs for those services also include:
    • The costs of labor or supplies, and materials incurred by the grantee in directly providing supportive services to program participants; and
    • The salary and benefit packages of the grantee staff who directly deliver the services.

Relocation Assistance - Separate from transportation assistance, relocation assistance is financial assistance that will help an individual or family travel longer distance when there is a safe and appropriate host within the individual or family's support system which will agree to host them for at least 30 days. They can be diverted through assistance with travel and logistics that include:

  • Charter bus tickets (i.e., Greyhound);
  • Train tickets (i.e., Amtrak or Metra);
  • Airline tickets (when bus or train travel is not practical);
  • Gas cards; and
  • Necessary provisions for travel (care packages, gift cards for grocery/convenience stores or restaurants, etc.)

Basic Housing Costs - security deposits, rent, application fees, utility payments, utility deposits, and utility arrears are eligible as one-time costs each, totaling no more than $2000 per household every 12 months as needed for permanent housing placement. Program participants needing additional assistance with these costs should be connected with other local programs offering this type of assistance.

HMIS - costs directly related to contributing and maintaining data in HMIS or a comparable database (for victim service providers) are eligible. Utilizing HMIS is strongly encouraged for the reporting burden of this program (not required by IDHS) and for systems-level evaluations by CoCs but must be utilized if the CoC has a policy in place that requires shelter diversion providers to record program and client level data into HMIS. Eligible HMIS costs include:

  • Obtaining technical support
  • Paying for travel to, and attending, CoC-required or CoC-approved trainings
  • Paying for HMIS licenses and/or participation fees charged by the HMIS Lead

G. 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, regulation, 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 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 regulation 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 may 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 quarterly fiscal reporting that is required by the IDHS.
  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 agencies at least 30 days in advance of a mandatory training. 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.
  9. Desk Reviews: In addition to on-site reviews, IDHS staff will likely conduct at least one off-site Desk Review during the grant year. Grantees will be given at least 30 days notice if at all possible. A Desk Review entails the Grantee providing IDHS with records such as case files, financial records, intake forms, and referrals, but does not involve a site visit. A Desk Review helps IDHS staff assess the provider's program standards and to ensure that rules and regulations are being followed.