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CHAPTER 2. KEY PROGRAM COMPONENTS

2.1 OVERVIEW

The CHSP provides assistance in the form of supportive services

for participants in eligible housing projects. The supportive

services are provided to frail or temporarily disabled elderly

persons and non-elderly persons with disabilities for the purpose

of promoting independence, preventing unnecessary

institutionalization and encouraging deinstitutionalization.

This chapter describes key program components, beginning with key

definitions.

The key program components addressed in this chapter include:

o service coordination;

o participant eligibility, admission and termination;

o the professional assessment committee (PAC);

o types of qualifying supportive services;

o participant fees;

o funding and cost sharing; and

o program costs.

2.2 KEY DEFINITIONS

The following definitions are the definitions that a user of this

handbook is most likely to need. For a complete list of terms

used in the CHSP regulations, see the CHSP Common Rule at 24 CFR

700.105 or 7 CFR 1944.252 (Appendix 2).

a\. Activity of Daily Living (ADL)

An activity of daily living (ADL) is an activity regularly

necessary for personal care, including eating, bathing,

grooming, dressing, transferring and performing household

management activities.

To be eligible to participate in the CHSP, an elderly

resident of an eligible project must need assistance with at

least 3 of these activities but still be able to perform at

a minimum level as described below:

\(1\) Eating: May need assistance with cooking, preparing or

serving food, but must be able to feed self;

\(2\) Bathing: May need assistance with getting in and out of

the shower or tub, but, must be able to wash self;

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\(3\) Grooming: May need assistance with washing hair, but must

be able to take care of personal appearance;

\(4\) Dressing: May need occasional assistance but must be able

to dress self;

\(5\) Transferring: May need assistance in getting in and out

of bed and chairs, walking, going outdoors, using the

toilet, and

\(6\) Household Management Activities: May need assistance in

doing housework, grocery shopping or laundry. Assistance

in getting to and from one location to another for

activities such as going to the doctor and shopping may

also be provided. In either case, individuals must be

mobile. The mobility requirement does not exclude

persons using wheelchairs or those requiring other

mobility devices.

b\. Adjusted Income

Adjusted income is adjusted gross income, as defined for the

Public Housing Program and for the Section 8 program (24 CFR

Part 813 or Part 913).

c\. Area Agency on Aging (AAA)

The Area Agency on Aging (AAA) is an agency designated by a

State Agency on Aging to administer the program described in

Title III of the Older Americans Act of 1965 (45 CFR Chapter

XIII).

d\. Case Management

Case management is evaluation of health, psychological and

social needs, development of an individually tailored case

plan for services and periodic reassessment of the residents

needs in coordination with the PAC and;

o making decisions about the way resources are allocated to

an individual.

o developing and monitoring of case plans in coordination

with a formal assessment of services needed.

Case management for the CHSP is provided by the service

coordinator.

e\. Excess Residual Receipts

Residual receipts are the project funds that remain at the end

of a year after all expenses are paid in limited dividend

projects. Residual receipts of more than \$500 per unit are

referred to as \"excess\" residual receipts for the CHSP.

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Excess residual receipts can be used as cash match for CHSP

grants to the extent that they are available and not committed

to other uses. All eligible housing under the Multifamily

Housing Program can use their residual receipts as match for

the CHSP grant.

f\. Frail Elderly Person

A frail elderly person is a person at least 62 years old who

needs assistance with three or more ADLs, as defined above.

g\. Person with Disabilities

A person with disabilities is a household comprised of one or

more persons, at least one of whom is an adult who has a

disability. A person is considered to have a disability if

such person is determined under regulations issued by HUD or

by RHS to have a physical, mental, or emotional impairment

that is characterized as follows:

o It is expected to be of long-continued and indefinite

duration;

o It substantially impedes his or her ability to live

independently, and

o It is of such a nature that the person\'s ability could be

improved by more suitable housing conditions.

A person is also considered to have a disability if the person

has a developmental disability as defined in Section 102 (7)

of the Developmental Disabilities Assistance and Bill of

Rights Act (42 U.S.C. 6001-7).

The term \"person with disabilities\" includes the following:

o two or more persons with disabilities living together,

o one or more such persons living with another person who

is determined (under regulations promulgated by HUD or by

RHS) to be important to their care and their well-being,

and

o the surviving member or members of any household, where

at least one or more persons was an adult with a

disability, who was living with the deceased member of

the household at the time of his or her death, in a unit

assisted under the CHSP.

h\. Professional Assessment Committee (PAC)

The PAC is a group of at least three individuals whose purpose

is to appraise the functional disabilities of residents in

relationship to performing ADLS. They are appointed by the

officials responsible for the CHSP in an eligible housing

project. (See Paragraph 2.8 for more information on PACs.)

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i\. Service Coordinator

The service coordinator is a social service staff person

responsible for assuring that program participants are linked

to the supportive services they need to continue independent

living. The service coordinator is hired by an eligible

owner, grantee or management company, or another third party

contractor such as a local case management agency. (See

Paragraph 2.4 below for a, description of the functions of a

service coordinator.)

j\. Service Plan

Each CHSP Grantee develops a plan for supportive services,

which estimates the type and nature of services to be provided

and the cost for each unit of service, This plan is developed

in consultation with the Area Agency on Aging and the

appropriate state or local agency and is submitted with the

grant application.

k\. Service Provider

The service provider is a person or organization licensed or

otherwise approved in writing by a state or local agency

(e.g., Department of Health, Department of Human Services or

Welfare) to provide supportive services. The service provider

may provide the service on either a for-profit or not-for-profit

basis.

l\. State Unit on Aging

The State Unit on Aging is an agency designated by the

governor to administer the program in Title III of the Aging

Act of 1965 (45 CFR Chapter VIII).

m\. Temporarily Disabled

Temporarily disabled means having an impairment that is

expected to be of no more than six months duration and that

impedes the ability of the individual to live independently,

unless the individual receives supportive services.

2.3 OVERVIEW OF SERVICES COORDINATION UNDER THE CHSP

Services coordination primarily refers to the activity of linking

a CHSP participant to needed supportive services or medical

services, which are provided by private practitioners or agencies

in the general community. Additionally, service coordination can

include case management, both formal and informal. Case managers

are responsible for decisions about the way resources are

allocated to individuals, based on their needs; the appropriate

services needed to assist them; and their eligibility for public

services.

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a\. The Service Coordinator

\(1\) Service coordination may be performed by a staff person

hired by the project or a third party that contracts

with the project to provide the services.

\(2\) Service coordinators may be provided by a third party

agency along with a supportive services package to

assist project residents.

\(3\) Service coordinators may be shared among projects in

the same immediate geographic area, and they may be

based on or off-site.

b\. Existing Service Coordination in Eligible Projects

Many projects currently provide service coordination. These

projects are primarily older Section 202s, Section 202,/8 or

other Section 8/221 (d)/236 projects, public/Indian housing

projects and Section 202/8 projects that are generally group

homes for non-elderly persons with disabilities.

It service coordination is currently in place and paid for

by HUD or other resources, the costs are not permitted to be

shifted to the CHSP.

Indicators or examples of existing coordination arrangements

are:

\(1\) SSI and/or Medicaid payments going directly to the

project\'s management for rent and service costs;

\(2\) the coordination of the services (and possibly their

payment) through the management or management agent of

the project;

\(3\) social work staff or equivalent approved in the budget

by HUD.

\(4\) placement of third party staff persons on the premises

without charge to the current HUD budget of the

project; and

\(5\) any combination of the above.

These arrangements may be with case managers, social

workers, or service coordinators, either with the

owner/borrower\'s management company or a state/local

government agency. For purposes of the CHSP, service

coordination is operative if the major functions of a

service coordinator, as stated below, are currently in place

for project residents.

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2.4 FUNCTIONS OF A SERVICE COORDINATOR UNDER THE CHSP

a\. Allowable Service Coordinator Functions

The service coordinator has the following major functions:

\(1\) Provides general case management (including intake) and

referral services to CHSP participants needing such

assistance;

\(2\) Provides formal case management. This involves an

evaluation of health, psychological, and social needs,

performed with a commonly accepted assessment tool.

The service coordinator may evaluate any apparently

frail elderly or non-elderly disabled resident to

determine if he/she is eligible for the CHSP. If the

resident is eligible, the service coordinator refers

the individual to the PAC;

\(3\) Establishes linkages with all agencies and service

providers in the community. Creates a directory of

service providers for use by both project staff and

residents;

\(4\) Refers and links the participants to service providers

in the general community, or those of the grantee or

eligible owner;

\(5\) Serves as staff to the PAC. Completes all paperwork

needed by the PAC for the assessment, referral, case

monitoring and reassessment processes. May develop

case plans in coordination with assessment services in

the community, or the PAC.

Implements the case plans made by the PAC and agreed to

by the program participants. Maintains necessary case

files on each program participant, containing such

material as described in Section 4.6(b)(2)(B) and

Figure 4-1.

\(6\) Monitors the ongoing provision of services from

community agencies and keeps the PAC and the provider

agency current with the progress of the program

participants.

\(7\) Educates participants on service availability,

application procedures, client rights, etc., and

provides advocacy as appropriate.

\(8\) Sets up volunteer support programs with service

organizations in the community.

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\(9\) Helps participants build informal support networks with

other residents, family and friends.

\(10\) Educates staff on the management team on issues related

to \"aging-in-place\" and services coordination, in order

to help them more effectively assist other persons

receiving housing assistance through the grantee or

eligible owner.

b\. Non-Allowable Service Coordinator Functions

\(1\) CHSP funds cannot be used to support the time of a

coordinator who performs other project activities such

as serving as the project\'s recreational or activities

director or assisting with administrative activities

normally associated with project management.

However, a coordinator may perform non-allowed duties d

the portion of the coordinator\'s time spent on these

duties is paid by resources other than CHSP.

\(2\) A service coordinator is not permitted to provide

supportive services directly.

\(3\) The service coordinator or the case management agency

may not have a financial interest in a service provider

agency that intends to provide services under the CHSP

(24 CFR 700.130 (c) or 7 CFR 1944.257 (c)).

2.5 SERVICE COORDINATOR AND AIDE QUALIFICATIONS

a\. Service Coordinator Minimum Qualifications

A service coordinator\'s work and educational experiences

should meet the following minimum guidelines:

\(1\) A Bachelor of Social Work or degree in a related field

such as gerontology, psychology, or counseling is

preferable; a college degree is fully acceptable.

However, an individual without a degree, but with

appropriate work experience may be hired as a service

coordinator. Such situations must NOT be rejected out

of hand.

\(2\) Training in the aging process, elder services,

disability services, eligibility for and procedures of

federal and applicable state entitlement programs,

legal liability issues relating to providing service

coordination, drug and alcohol abuse by the elderly,

and mental health issues. (24 CFR 700.130 (b) or 7 CFR

1944.257 (b)). A service coordinator who cannot

provide evidence of this type of training when he or

she is hired must meet this requirement within a year

of the effective date of hire.

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\(3\) Two to three years of experience in social services

delivery with senior citizens and/or non-elderly persons

with disabilities, as appropriate.

\(4\) Demonstrated working knowledge of supportive services

and other resources for senior citizens and non-elderly

persons with disabilities in the area served by the

project.

\(5\) Demonstrated ability to advocate, problem-solve, and

provide results for those served.

\(6\) In situations where the management of a building(s)

wants to create a services \"learn\" in which a service

coordinator supervises one or more aides, the

coordinator should have appropriate professional staff

experience AND prior management or supervisory

experience.

b\. Qualifications for Aides Working with a Service Coordinator

It is desirable, but not required, that aides have a college

degree. They should, however, have appropriate experience

in working with the elderly and/or persons with

disabilities.

Another option for management is to set up an internship or

work-study program with local colleges and universities.

Students could assist in carrying out some of the service

coordination functions noted above; provide planning

guidance to project staff; or provide program

evaluation/assessment functions.

2.6 PARTICIPANT ELIGIBILITY

a\. Persons eligible to receive CHSP subsidized services must:

\(1\) be persons:

o who are 62 years or older and deficient in at

least three Activities of Daily Living (ADLs); OR

o with permanent disabilities, regardless of age; OR

o who are temporarily disabled and 62 years or

older.

\(2\) live in housing assisted by HUD or RHS that has

received CHSP funds.

In providing services under CHSP, priority shall be given to

eligible residents who have very low incomes (24 CFR 700.125

\(b\) or 7 CFR 1944.256 (b)). \"Very low income\" is defined by

HUD as having an income that is at or below 50 percent of

the area median income.

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b\. Activities of Daily Living (ADLs)

To be eligible for the CHSP, an elderly person must need

assistance with at least 3 ADLs but be able to perform at

the minimum level, as described in Paragraph 2.2. The ADL

assessment is relevant only with regard to determining a

person\'s eligibility to receive supportive services; it is

not a basis for eligibility for occupancy.

The determination of whether an elderly person meets this

minimal level of performance also includes consideration of

those services that will be performed by a person\'s spouse,

relative, or other attendants that will be provided to the

individual. For example, a participant who needs assistance

in feeding him/herself will meet the minimum requirements of

the eating ADL only if assisted by a spouse, relative, or

attendant. If such assistance were to become unavailable to

that participant, the eligible owner or grantee is not

obligated to replace this aid or to provide other

individualized services.

c\. Non-Eligible Residents of Eligible Housing

Under certain circumstances, elderly persons who are not

deficient in at least three ADLs may receive services

provided by CHSP. These residents must live in either HUD

or RHS assisted housing that is receiving CHSP funds. In

order for non-eligible project residents to receive CHSP

services, the housing managers, service coordinator and PAC

must jointly determine that they need supportive services

and that their participation will not negatively affect the

provision of services to program participants. Also, the

non-eligible residents must agree to pay the full cost of

providing the services. (24 CFR 700.150 (f) or 7 CFR

1944.261 (f)).

d\. Nonresidents

CHSP managers, in consultation with project residents, may

elect to offer services to elderly persons or persons with

permanent or temporary disabilities living in the

surrounding community under certain circumstances.

Nonresidents who receive meals and other services from a

CHSP must agree to pay full cost of providing the services.

(24 CFR 700.150 (f) or 7 CFR 1944.261 (f). Project managers

may serve these persons, as long as their participation does

not adversely affect the cost-effectiveness or operation of

the program. (24 CFR 700.135 (f) or 7 CFR 1944.258 (b)).

2.7 PARTICIPANT ADMISSIONS AND TERMINATION PROCEDURES

a\. Supportive Service Application

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Each grantee, with the assistance of the service coordinator

and the PAC, shall develop a supportive service application

for residents to use. The application must include an

intake form that contains personal information about the

applicant, and is to be filled out by the service

coordinator. The application should also contain a

preliminary ADL assessment (including an informal support

network review) by the service coordinator and have attached

comments from the applicant\'s physician or the service

coordinator.

b\. PAC Assessment

The PAC will complete a formal assessment, as appropriate

and necessary, to determine the individual\'s need for

assistance in activities associated with daily living. The

information in the supportive services application is

crucial to the PAC\'s determination of the need for further

physical and/or psychological evaluation of any individual

who wishes to receive supportive services.

c\. Case Plan

Following assessment by the PAC and negotiation between the

PAC (or the service coordinator, if this responsibility is

delegated) and the involved individual, the case plan is

created for each individual. It contains the services

approved for that individual, the provider agency, the cost

of the service and the fees, and any notes associated with

service monitoring and delivery, change of condition of the

individual over time and both follow-up case notes and

reassessments, as appropriate. The case plan is updated by

the service coordinator and the PAC, in consultation with

the participant, at least semi-annually.

d\. Participatory Agreement

Once agreement between the participant and the PAC or

service coordinator is reached on the case plan, each

participant in the CHSP must sign a participatory agreement

(24 CFR 700.140 or 7 CFR 1944.259). The agreement is

inserted in the participant\'s file.

The participatory agreement must include:

\(1\) Period covered,

\(2\) Services to be provided,

\(4\) Fees to be charged, and

\(5\) A clear statement that the fees may no longer be

collected during that 12-month period once they are

equivalent to 20 percent of adjusted income, as

calculated in 24 CFR Part 91 3 (24 CFR 700.1 50 (a) or

7 CFR 1944.261 (9)). See Paragraph 2.13 below for

further discussion of program participant fees.

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HUD/RHS requires that the agreement be reviewed and updated

at the time of annual income recertification by the

project/PHA/IHA\'s occupancy specialist. The agreement must

also be adjusted whenever the service program is modified by

the PAC.

e\. Transition Out of the CHSP

\(1\) Cause for Transition Out. A program participant can be

transitioned out of the CHSP if he/she:

\- regains physical and mental health, and is able to

function without supportive services, even if only

for a short period of time.

\- requires a higher level of care than that which can

be provided under CHSP and needs to be transferred

to another setting; or,

\- refuses to pay services fees.

\(2\) Continuation of Service. Once terminated from the

program, former participants may retain CHSP supportive

services d they continue living in an eligible project

and pay full service costs.

\(3\) Reinstatement. It is possible for a former CHSP

participant to be reinstated. The individual may be

readmitted based on a reassessment by the PAC.

2.8 THE PROFESSIONAL ASSESSMENT COMMITTEE (PAC)

Each grantee must appoint a professional assessment committee (PAC)

that will evaluate and determine the eligibility of potential

program participants and determine the services to be provided to

each participant (24 CFR 700.135 (a) or 7 CFR 1944.258 (a)).

a\. Membership of the PAC

Each PAC must be composed of at least three individuals who

are professionally competent to appraise the functional

abilities of frail or temporarily disabled elderly persons

and/or non-elderly persons with disabilities in relation to

the performance of the normal tasks of daily living. PAC

members shall be appointed by eligible housing project

officials who are responsible for the congregate services

program.

1 . The statute requires that the PAC members must include at

least one qualified medical professional (Title VIII

Section 802 (e)(3)(B)). The regulations add that the PAC

should also

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include at least one individual who does not have any

direct or indirect relationship to the project (24 CFR

700.135 (c) or 7 CFR 1944.258 (c)).

2\. Other individuals who may be considered for membership on

the PAC are:

\(A\) the manager of the housing project;

\(B\) one or more representatives from local social

service or health agencies, who have experience

with the elderly and/or persons with disabilities;

\(C\) a representative from a local organization

representing resident concerns (such as the local

chapter of a group for the elderly or disabled) or

an official representative of a resident

organization, if one exists; and

\(D\) other persons professionally competent to appraise

an individual\'s functional ability.

3\. The following individuals are not permitted to serve as

PAC members:

\(A\) staff or board members of service providers

expected to be paid from the CHSP;

\(B\) project residents, other than a representative of

a resident organization, because they generally

will lack professional qualifications to assess

individuals; and, because the privacy of

participating residents should be protected.

\(C\) the Service Coordinator. The service coordinator

advises the PAC but does not vote on accepting

individuals into the CHSP.

b\. Duties of the PAC

According to the regulations at 24 CFR 700.135 (b) or 7 CFR

1944.258 (b), the PAC is required to:

\(1\) perform a formal assessment of each potential elderly

program participant\'s deficiencies in performing the

ADLs. This assessment shall be based on the screening

done by the service coordinator. It shall include a

review of the adequacy of the applicants\' informal

support network (i.e., family and friends), in meeting

the ADL needs of the potential participants;

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\(2\) determine that each elderly applicant needs assistance

in at least three ADLs; or that applicants qualify

under either the definition of elderly who are

temporarily disabled or the definition of non-elderly

persons with disabilities.

\(3\) authorize or perform a medical evaluation, if

necessary. These evaluations may be performed by a PAC

medical professional, or applicants to the CHSP may be

referred to another agency in the community that will

perform the evaluation without charge;

\(4\) perform a regular reassessment and updating of the

supportive services plan of all participants at least

semi-annually;

\(5\) replace members within 30 calendar days after a current

member resigns.

NOTE: Formal assessments should not be done if

membership falls below three persons or if the qualified

medical professional leaves the PAC and has yet to be

replaced. In such cases the service coordinator may

accept new program participants only on an emergency

basis.

\(6\) notify program participants and the grantee of any

proposed modifications to PAC procedures. These parties

and a resident\'s legal representative should be provided

with a process and a reasonable time period to review and

comment on all proposed PAC procedures prior to their

adoption. This should be done both at the time of

initial program development and for any changes during

the term of the CHSP grant;

\(7\) provide assurance of nondiscrimination in selection of

CHSP participants, with respect to race, religion, color,

sex, national origin, familial status or type of

disability; and

\(8\) provide complete confidentiality of information related

to any individual examined, in accordance with the

Privacy Act of 1974.

2.9 PAC OPERATING PROCEDURES

The PAC must establish operating procedures to accomplish the

assessment and to assure fair treatment and due process for the

residents (24 CFR 700.135(a) or 7 CFR 1944.258(a)). Operating

procedures should be in written form and available for review by

the project owner, grantees or residents. Operating procedures

should cover:

a\. Administrative Organization of the PAC

The PAC operating procedures should set:

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\(1\) the length of time members shall participate;

\(2\) the minimum number of meetings to be held annually; and

\(3\) establishment of chairperson, secretary and other

officers, as appropriate.

b\. Application and Assessment Procedures

The PAC operating procedures should describe:

\(1\) application taking and eligibility determination

procedures;

\(2\) the assessment and re-evaluation process;

\(3\) how fees are determined and the current fee schedules;

\(4\) termination policies.

C. Appeal Procedures

The PAC operating procedures should allow for residents to

appeal PAC decisions related to entrance to, extent of

participation in, or transition out of the CHSP. (See

paragraph 2.10 below.)

2.10 PROCEDURAL RIGHTS OF APPLICANTS AND PARTICIPANTS

The PAC must provide an informal process that recognizes the

rights of individuals receiving assistance to due process of law.

a\. Application Rejection or Termination of Services

At a minimum, the PAC must:

\(1\) serve the participant with a written notice containing

a clear statement of the reasons for rejection or

termination;

\(2\) upon appeal, review the decision. The participant must

be given the opportunity to present written or oral

objections before an individual other than the person

(or that person\'s subordinate) who made or approved the

rejection or termination decision. A description of

the appeals process, including both informal settlement

and hearing procedures, is presented in Appendix 2,

Sample Appeals Procedure.

\(3\) provide prompt written notification of the PAC\'s final

decision.

b\. Option to Refuse Services

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PAC procedures must ensure that, as part of the case planning

process, any participant has the option of declining offered

services and requesting other supportive services.

c\. Additional Services

In situations where individuals request additional services

not initially recommended by the PAC, the PAC must determine

whether the request is for a legitimately needs-based

service that can be covered by CHSP funds. Individuals can

purchase at cost for additional services not recommended by

the PAC, as long as those services do not interfere with the

efficient operation of the program.

2.11 RESOURCES IN THE COMMUNITY FOR EVALUATIONS

Grantees may use existing community programs that perform

functional evaluations of the applicants. These evaluations

would then be submitted to and evaluated by the PAC. For persons

without a doctor or who cannot afford a medical evaluation, HUD

encourages the use of the following community programs and

facilities:

o City/County Health and Social Service Departments;

o Geriatric Evaluation Services;

o Community Mental Health Centers;

o Vocational Rehabilitation Centers;

o Public Health and Veterans Administration facilities; or

o Developmental Disabilities Assistance Centers authorized

under the 1970 Act, as amended.

2.12 ELIGIBLE SUPPORTIVE SERVICES

Supportive services are the means by which the frail elderly

residents of eligible housing and non-elderly residents with

disabilities are able to continue living independently. Both

eligible owners and grantees can provide supportive services

directly or may, by contract or lease, provide such services

through other appropriate agencies or providers.

The CHSP allows for a variety of services to be funded under Its

auspices. These include meals, housekeeping, personal

assistance, transportation and health-related services. Services

other than meals may be provided off-site, if appropriate.

Eligible services include:

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a\. Meal Service

\(1\) Each grantee is required to make available to program

participants a full meal service adequate to meet

nutritional needs, defined administratively as a

minimum of at least one hot meal a day served in a

group setting. Meals must be provided to program

participants on site (24 CFR 700.120 (c)(1) or 7 CFR

1944.255 (c)(1)).

While a meal service Is a mandatory component of the

CHSP, not all CHSP participants are required to take

meals from the CHSP. Participants will be offered

meals service by the PAC, depending on the outcome of

their assessments. Meal programs must conform to CHSP

guidelines described in Exhibit 2-1.

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Exhibit 2-1

CHSP MEAL SERVICE GUIDELINES

1\. Hot Meals

The daily meal made available by the grantee must be served hot.

A CHSP hot meal is one in which the principal food item of the

meal is hot at the time of serving (24 CFR 700.120 (c)(2) or 7

CFR 1944.255(c)(2).

2\. Special Menus

Special meals shall be provided as necessary, to meet the dietary

needs related to the health requirements of such conditions as

diabetes and hypertension. HUD also strongly encourages grantees

to meet the dietary needs of religious and ethnic groups (24 CFR

700.120 (c)(3) or 7 CFR 1944.255(c)(3)).

3\. Type of Service

At least one daily meal made available by the grantee must be

served in a group setting. Grantees have the option, if providing

more than one meal daily, of serving all meals in a group setting

or providing a combination of group and carry-out meals. In most

cases, however, in order to encourage socialization, grantees

should encourage residents to partake of the meals in a group or

\"congregate\" arrangement (24 CFR 700.120 (c)(1)(1) or 7 CFR

1944.255(c)(1)).

A meals program in which 100 percent of the meals are delivered

to the apartment of the resident is INELIGIBLE.

Meals may be provided using one or several of the following

methods:

\- provision of meals on-site by project management;

\- contracting for catered meals to be brought in;

\- contracting for meals, with the contractor using an on-site

facility for preparation;

\- provision of and assistance in the preparation of in-unit

meals for participants who are temporarily ill or disabled.

4\. Meals Service Standards

Meals provided through CHSP must be wholesome and nutritious.

They must be appropriate for the low-energy intake characteristic

of the elderly or the special needs of non-elderly persons with

disabilities; be suitable for, and adaptable to, the limitations

of elderly or disabled people in preparing their food, and be

compatible with dietary and drug therapies.

Each meal must meet a minimum of one-third of the minimum daily

dietary allowance as established by the Food and Nutrition Board

of the National Academy of Sciences-National Research Council.

If state or local nutrition standards are stricter, these must be

followed instead (24 CFR 700.120 (c)(4) or 7 CFR 1944.255

(c)(4)).

5\. Dietician Certification

Grantees must obtain a certification which states that the one

daily meal provided under CHSP meets the minimum daily dietary

allowances and is hot at the time of serving. This certification

must be prepared and signed by a registered dietician, and

submitted to the grantee annually (24 CFR 700.120 (c)(4) or 7 CFR

1944.255 (c)(4)).

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\(2\) In contracting for or otherwise providing for meal

services, preference shall be given to any provider of

meal services who:

\(A\) receives assistance under Title III of the Older

Americans Act (24 CFR 700.120 (c)(6) or 7 CFR

1944.255 (c)(6)), or

\(B\) delivers meals as a part of a regular, on-going

program to elderly individuals and non-elderly

persons with disabilities.

These preferences do not preclude an eligible owner or

grantee from directly cooking and providing meals under

its own auspices.

\(3\) Eligible owners or grantees have the option of extending

meal services to noneligible residents or nonresidents,

as described in Paragraph 2.6 above. These individuals

shall be charged the actual cost of providing the meal.

\(4\) Each eligible owner and grantee must apply for approval

as a retail food store under Section 9 of the Food Stamp

Act of 1977 (42 U.S.C. 2018)(24 CFR 700.120 (c)(6) or 7

CFR 1944.255 (c)(6)).

\(5\) Eligible owners and grantees must also request

agricultural commodities made available without charge

by the Department of Agriculture, for use in meal

services, subject to regulations at 7 CFR Section 250.

The procedures for both applying for retail food store

approval and requesting agricultural commodities are

described in Paragraph 4.5 below.

b\. Housekeeping Aid

Many frail elderly and non-elderly persons with disabilities

may have difficulty in doing everyday housework and

household maintenance. Light housekeeping services may be

offered to such residents, including making beds, washing

clothes, vacuuming, dusting and bathroom cleaning. Laundry

facilities should be made available for housekeepers to

provide this service for those who do it themselves. The

number of service hours provided will depend on residents\'

functional abilities. Normally, a participant will need

approximately two hours a week of housekeeping service.

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4640.1 REV-1

c\. Personal Assistance

Personal care services (as illustrated in Figure 2-2) are

often pivotal in meeting participants daily living needs.

This assistance includes a variety of tasks that maintain

personal appearance and hygiene, based on an individual\'s

personal impairments and needs.

Figure 2-2

EXAMPLES OF PERSONAL CARE SERVICES

1\. grooming

2\. dressing

3\. using the toilet (getting to the toilet, cleaning

self, arranging clothing)

4\. bathing and personal hygiene

5\. hair, skin and foot care

6\. clothes care

7\. cooking, preparing or serving food

8\. getting in and out of bed and chairs

9\. walking

10\. going outdoors

d\. Transportation Services

Transportation services such as those in Figure 2-3, enable

those lacking a car or the ability to drive to remain

independent, to maintain necessary links with the community,

and to obtain the services and goods needed on a regular

basis.

Figure 2-3

EXAMPLES OF TRANSPORTATION SERVICES

1\. Project owns and operates a car or one or more

vans, or shares a van/car(s) with other nearby

project(s);

2\. Project contracts with a taxi service for specific

routes or for set-cost subsidized vouchers for the

project participants.

3\. Project arranges with local senior citizen (or

city/county) bus service to be included on its

regular route(s). Sometimes this may include fare

agreements.

Projects most often use car, taxi, van, or bus service.

Transportation services can make such places as medical

clinics, social service agencies, shopping areas, grocery

stores, religious institutions, and libraries accessible and

readily available to program participants.

Volunteer arrangements for transporting CHSP participants

are discouraged, unless the liability insurance covers the

actions of volunteers.

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a\. Health-Related Services

Figure 2-4 illustrates health-related services that

encourage and promote good health and active living for

program participants.

Figure 2-4

EXAMPLES OF HEALTH-RELATED SERVICES

1\. Wellness programs;

2\. Preventive health screening; and,

3\. Monitoring of medication, consistent with state

law.

f\. Personal Emergency Response Systems

These are systems that will allow residents to call for

emergency aid through the use of hand-held units or devices

worn around the neck. Such a system serves to ensure the

safety of program participants at all times.

g\. Other Requested Services

Applicants and grantees can request approval from the

Secretary of HUD or the Secretary of the Department of

Agriculture for funding for other appropriate services (NOT

including recreational activities) at the time of initial

application, or later, as appropriate. These should be

designed to enhance and promote the independence, good

physical and mental health and safety of program

participants. If approved, these services will be

authorized through amendments to the original grant award,

if not part of that award.

An example of a requested service that could be approved is

counseling. Counseling services, as illustrated in Figure

2-5, may be provided to enhance the quality of life for CHSP

participants.

Figure 2-5

EXAMPLES OF COUNSELING SERVICES

1\. Social work counseling (such as short-term

assistance with personal, religious or family

problems);

2\. Legal and financial counseling (including help in

applying for entitlement programs); and

3\. Legal advocacy.

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4640.1 REV-1

2.13 PROGRAM PARTICIPANT FEES

Each grantee is required to establish fees for meals and may set

fees for other provided services. Grantees must collect fees

that are equal to at least 10 percent of the costs of the

services provided by the program (24 CFR 700.150(e) or 7 CFR

1944.261 (e)). See Paragraph 2.14 for an explanation of cost

sharing.

a\. General Requirements

\(1\) The fees must ensure that no participating resident

pays more than the cost of the services that he/she

actually receives (24 CFR 700.1 50 (c) or 7 CFR

1944.261 (a)).

\(2\) Fees may NOT be charged for meals or any supportive

service funded under the Older Americans Act (24 CFR

700.150 (c) or 7 CFR 1944.261(c)). Participants may

make voluntary donations for these services, which must

be counted toward the required fees.

\(3\) Grantees must charge a percentage of adjusted income as

the meals fee. Fees for other services are optional

for the grantee to charge (24 CFR 700.150 (d) and (a)

or 7 CFR 1944.261 (d) and (e)).

b\. Limitations on Fees Charged to Program Participants

\(1\) A participant shall not pay more than 20 percent of

his/her adjusted income for fees within any annual

period.

\(2\) If a program participant has no adjusted income, or d

20 percent of the person\'s adjusted income does not

cover all fees, the grantee may totally or partially

waive the fee requirement for that participant. (See

Paragraph 2.14 regarding HUD/grantee cost sharing of

the shortfall.)

\(3\) For services other than meals, grantees must charge

flat fees. CHSP rules do not permit the use of sliding

fee scales.

c\. Meal Service Fees

Under CHSP, a participant\'s income is first applied to

covering the cost of meal services.

\(1\) Full Meals Service

The fee for participants receiving full meal services

(more than one meal a day, seven days a week) must be

reasonable and shall be: at least 10 and no more than

20 percent of the

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adjusted income of the participant, or the cost of

providing the service, whichever is less (24 CFR

700.150 (d)(1) or 7 CFR 1944.261 (d)(1)).

\(2\) Less Than Full Meals Service

The fee for participants receiving less than full meal

service, i.e., one meal a day, seven days a week or

less) shall be the lesser of 10 percent of that

individual\'s adjusted income, or the cost of providing

the service (24 CFR 700.150 (d)(2) or 7 CFR 1944.261

(d)(2)).

Figure 2-6 illustrates the process of calculating meals fees

for program participants.

Figure 2-6

CALCULATION OF MEALS FEES

(Using Average Incomes)

The fees that CHSP participants are charged for meals are

based on the cost of meals received and the participants\'

adjusted incomes.

Example: A CHSP project has ten participants with an

average income of \$6,000. Each of them receives

two meals a day, seven day a week. The total

annual meals cost for the program is \$36,400.

1\. The first step is to calculate the cost of each meal that an

individual receives.

10 participants X 2 meals/week X 7 days/week = 140

meals/week.

140 meals/week X 52 weeks/year = 7,280 meals/year.

\$36,500 total meals cost divided by 7,280 meals =

\$5.00/meal.

2\. The second step is to calculate the annual meals cost for

one person:

\$5.00/meal X 14 meals/week X 52 weeks/year = \$3,640/year.

3\. The third step is to determine a participant\'s annual meals

fee based on income.

Because two meals per day are provided in this CHSP, the

participants must be charged more than 10% and less than 20%

of their adjusted incomes. Assume that the percentage of

income is set at 13%.

13% of \$6000/year (annual average adjusted income) =

\$780/year

4\. An individual must pay a fee that is the lesser of a set

percentage of income and the cost of the meals. Therefore,

the fourth step is to compare 13% of the annual average

income (\$780) to the annual cost of meals for one

participant (\$3,640).

\$780 is less than one person\'s annual meals cost (\$3,640).

Therefore, each participant is charged \$780/year for the

meals program. The total meals fees to collected are:

\$780/participant/year X 10 participants = \$7,800/year

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4640.1 REV-1

d\. Fees for Services Other Than Meals

For services other than meals, a participant is charged a

fee per unit of service for each of the services he or she

receives. Figure 2-7 presents one example of setting fees

for meals and other services in a CHSP.

Total fees charged for meals and other services are limited

to 20 percent of each participant\'s income or the cost of

providing the services, whichever is less (24 CFR 700.1 50

\(e\) or 7 CFR 1944.261 (e)). If the meals fee alone for an

individual equals 20 percent of his or her adjusted income,

no fee may be charged for any other service.

e\. Fees for Other Residents and Nonresidents

Project residents who do not qualify for CHSP assistance and

non-residents may receive services as long as the fee equals

the cost of providing the service(s) (24 CFR 700.150(f) or 7

CFR 1944.261 (f)). The cost of providing these services and

the fees paid are off-budget. The fees are not counted in

the 10% of program cost that must be collected from program

participants.

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Figure 2-7

SETTING PARTICIPANT FEES FOR MEALS AND OTHER SERVICES

A CHSP provides 7 meals a week, personal care and transportation.

Participant A has an annual income of \$10,000 and receives 7

meals per week and 10 hours of personal care. Participant B has

an income of \$5,000 per year and receives 7 meals, 5 hours of

personal care, and 10 rides per week. The costs of providing

each meal and each unit of service are: \$5.00 per meal; \$5.00 per

hour of personal care, and .50 per ride.

1\. To determine what fees each of these participants will pay, the

first stop is to determine the annual cost of providing these

services:

Participant A

Meals: 7 meals/week X \$5.00/meal = \$35/week

\$35/week X 52 = \$1,820

Personal Care: 10 hours/week X \$5.00/hour = \$50/Week

\$50/week X 52 = \$2,600

Total Cost of Other Services = \$2,600

Participant B

Meals: 7 meals/Week X \$5.00/meal = \$35/week

\$35/Week X 52 = \$1,820

Personal Care: 5 hours/week X \$5.00/hour = \$25/week

\$25/week X 52 = \$1,300

Transportation:10 rides/Week X \$0.50/ride = \$5/week

\$5/week X 52 - \$260

Total Costs of other services = \$1,300 + \$260 = \$1,560

2\. The next step is to determine the limit to each participant\'s

meals fee, based on income. For less than full meals service,

participants are charged the lesser of the cost of providing the

meals (\$1,820/person) and 10% of income. Participant A, then,

can pay up to \$1,000 for meals, and Participant B can pay up to

\$500 for meals.

3\. Finally, the fees that each participant is charged for services

other than meals is determined. Total fees charged for meals and

other services are limited to 20% of each participant\'s income,

or the cost of providing the services whichever is less.

Participant A\'s fees for other services are limited to:

20% of \$10,000 - \$2,000

\$2,000 - \$1,000 (meals fee) - \$1,000

Participant B\'s fees for other services are limited to:

20% of \$5,000 - \$1,000

\$1,000 - \$500 (meals fee) - \$500

Therefore, Participant A will be charged \$1,000 annually for the

personal care services that he receives, and Participant B will

be charged \$500 annually for the personal care and transportation

that she receives.

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4640.1 REV-1

2.14 COST SHARING

a\. General (24 CFR 700-145 (a) or 7 CFR 1944.260 (a))

\(1\) The CHSP grant covers up to 40% of total program costs.

\(2\) Eligible owners or grantees are required to provide

matching funds that account for AT LEAST 50 percent of

total program costs. In cases in which a state is a

grantee, a local government\'s contribution cannot

exceed 10 percent of the amount required from the

state. (See Paragraph 2.15 below for a discussion of

what a grantee may include as matching funds.)

\(3\) Participants generally must contribute fees in such an

amount that accounts for AT LEAST 10 percent of total

program costs. Exhibit 2-2 provides an example of this

fee match requirement.

If fees collected from program participants do not add

up to 10 percent of costs because participants have

either no income or very-low income, HUD will share the

cost of the deficit amount with the owner or grantee on

a 50/50 percent basis.

b\. Prohibition on Substitution of Funds (24 CFR 700.145 (b) or

7 CFR 1944.260 (b))

Grantees must certify to HUD that CHSP funds will not be

substituted for funds that the grantee or other third party

was providing before the date of application for assistance

under CHSP. Activities funded by CHSP funds must be in

addition to, and must not replace, activities or services

funded by the grantee prior to the time of application to

the CHSP.

c\. Maintenance of Existing Supportive Services (24 CFR 700.145

\(b\) or 7 CFR 1944.260 (b))

Grantees must certify that they will maintain any existing

supportive services already received by frail elderly

residents and non-elderly residents with disabilities, if

the PAC determines that the existing services are needed to

maintain independence. Such supportive services cannot be

used as matching funds. They must be maintained throughout

the time participants remain in the CHSP, unless the PAC or

another entity that has performed an assessment determines

that the participants no longer need them.

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Grantees must provide this certification annually, as part

of the annual program and budget review. Certification is

required for any program participant who was receiving

eligible supportive services at the time of his/her

application to the CHSP.

EXHIBIT 2-2

4640.1

REV-1

EXHIBIT 2-2

FEE REQUIREMENT

In calculation of fees, applicants must keep in mind that the

fees collected need to meet at least the 10 percent requirement

as stated in Sections 700.150(a) and 1944.261(e) of the Common

Rule.

For example: two CHSP programs, Program A and Program B, each

have 30 participants. Program B provides more extensive services

and is more expensive than Program A. In addition to a daily CHSP

meal, Program A provides housekeeping and transportation

services. In addition to a daily CHSP meal, Program B provides

personal care, housekeeping and extensive transportation

services. The monthly average adjusted income of participants in

each program is \$400.00.

1\. The total annual program costs:

Program 1 Annual Costs Program 2 Annual

Costs

Service Service

Coordinator \$20,000 Coordinator \$25,000

Meals 65,700 Meals

65,700

Housekeeping 12,480 Housekeeping

19,500

Transportation 10,000 Personal Care

31,000

Administration 11,000 Transportation

12,480

Total Cost \$119,180 Administration

17,000

Total Cost of Program:

\$170,680

2\. Fee Match Required

For each program, the minimum fee match requirement of 10% of

total program costs is:

Program 1: Program 2:

10% of \$119,180 = \$11,918 10% of \$170,680 =

\$17,006

3\. Collectible meals fees

Meals fees for each project are limited to 10% of the adjusted

incomes of the program participants:

30 participants x \$400/mo. x 12 months = \$144,000

10% of \$144,000 = \$14,400

4\. Comparison of amount that may be collected as meals fees with the

10% match requirement.

In Program 1, if participants are charged 10 percent of their

adjusted monthly income for the meal, and no fee for services,

participant fees collected would total \$14,400. The minimum

requirement of \$11,918 is met. Actual fees collected are 12% of

total costs.

In Program 2, a ten percent fee (i.e., for the meal only), would

produce only \$14,400, and this would not be enough to meet the

requirement of ten percent of total program costs. In addition

to a fee for the meal, a fee (or fees) for other services would

have to be set high enough to collect an additional \$2,600 of the

total of at least \$17,000, needed to meet the minimum

requirement.

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4640.1 REV-1

2.15 ELIGIBLE MATCHING FUNDS

Matching funds are the 50 percent of program costs that grantees

must provide to supplement CHSP support. These funds must be new

funds or resources directed specifically for new CHSP support, NOT

existing services funds or resources in place.

a Cash (24 CFR 700.145 (c)(2)(i) or 7 CFR 1944.260 (c)(2)(i))

\(1\) Cash - this includes funds from federal, state, and local

governments, third party contributions, available

payments authorized under Medicaid for specific

individuals in CHSP, Community Development Block Grants,

Community Services Block Grants and Older American\'s Act

Programs.

\(2\) Excess residual receipts (amounts in excess of

\$500/unit) in Sections 8, 202 or 202/8, 221 (d), or 236

projects may also be used ff they are not committed to

other uses, and, the HUD state or area office/RHS state

office approves their availability.

\(3\) INELIGIBLE cash contributions include (24 CFR 700.145

\(d\) or 7 CFR 1944.260 (d)):

\(A\) CHSP funds,

\(B\) PHA operating funds,

\(C\) PHA\'s Section 8 administrative fee,

\(D\) Section 8 funds other than excess residual

receipts,

\(E\) Comprehensive Improvement Assistance Program CIAP

funds other than for a service coordinator, and

\(F\) Comprehensive grant funds, unless used for a

service coordinator.

b\. In-Kind Resources

The value of in-kind resources may account for a MAXIMUM of 1 0

percent of the grantee\'s required matching amount. In-kind

resources, as defined at 24 CFR 700.145 (c)(2)(iii) or 7 CFR

1944.260 (c)(2)(iii), include the current market value of donated

common and office space, furniture, utilities, material,

supplies, equipment, and food used in direct provision of

services or program administration. Stock on hand that is

contributed for use in the CHSP is considered an in-kind

resource.

CHSP applications (and annual renewals) must contain explanations

of how the estimated donated value for items was obtained. An

example of computing the value of an in-kind resource is

presented in Figure 2-8.

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4640.1

REV-1

Figure 2-8

EXAMPLE OF VALUE OF IN-KIND RESOURCE

Situation:

A 1,225 sq. ft. area is donated for use by the CHSP as a dining

facility 25 percent of the time. The current rental value of the

facility is \$2/sq. ft./month.

Calculation of Value:

1\. Sq. Ft. X Rent/Sq. Ft./Month = Total Cost Per Month

2\. Total Cost Per Month X % Used by CHSP = CHSP Value Per Month

3\. CHSP Value Per Month X 12 = CHSP Value Per Year

Type of Facility

Dining 1,225 sq. ft. X \$2/sq.ft./mo. = \$2,450/month

\$2,450/month X 25% = \$612.50

\$612.50/month X 12 = \$7,350/year

c\. Value of Services

The imputed value of other agency or third-party provided

direct services or staff who will work with or provide

services to program participants. These services must be

necessary to keep program participants independent. Imputed

value may include any salary paid to staff from other

sources to carry out the CHSP or any salary paid to

residents employed by CHSP from other sources.

This means that if the applicant or another third party

agency allocates staff time to CHSP, the actual value of

such staff time may be directly contributed to the program

as match. The cost of the staff time should include fringe

benefits.

Figure 2-9 illustrates the imputed value of staff time. A

letter on organization letterhead must clearly spell out

this amount including staff position, time, amounts, units

of service provided, and dollar value of service.

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4640.1 REV-1

Figure 2-9

EXAMPLE OF IMPUTED VALUE OF STAFF

A CHSP applicant assigns a bus driver, a bookkeeper and an executive

director to the CHSP, as follows:

Job Category Percent of Time Hours per Week

Bus Driver 15% 6

Bookkeeper 10% 4

Executive Director 5% 2

Each worker has the following hourly rates:

Job Category Hourly Rate

Bus Driver \$10

Bookkeeper \$12

Executive Director \$40

The imputed annual value of each worker would then be calculated, as

follows:

1 . Hours/Week X Hourly Rate = Dollar Value per Week

2\. Dollar Value Per Week X 52 = Dollar Value per Year

Job Category

Bus Driver:

6 hrs./week X \$10/hour = \$60/week

\$60/week X 52 = \$3,120/yr

Bookkeeper:

4 hrs/week X \$12/hour = \$48/week

\$48/week X 52 = \$2,496/yr

Executive Director:

2 hours/week X \$40/hour: \$80/week

\$80/week X 52 = \$4,160/yr

Total Imputed Value: \$9,776

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d\. Volunteer Services

Services performed by volunteers including PAC members are

valued at a rate of \$5 an hour. The value of PAC members\'

time cannot be counted for any time period during which

initial assessments of individuals are made prior to their

entry into the CHSP. However, all PAC time for

reassessments and other follow-up after entrance to the

program may be counted.

Volunteers may also provide some supportive services such as

serving as meals service aides or helpers. However, if

project residents are used to provide these services, they

must be persons who are not eligible to receive CHSP

services and must be remunerated as indicated in e below.

e\. Employment/Services of Project Residents

Section 802 (j)(1) of the National Affordable Housing Act

states that each project receiving assistance under this

section shall, to the maximum extent practicable, utilize

the elderly and persons with disabilities who are residents

of the project, but who are not eligible to receive CHSP

services, to participate in providing CHSP services;

however, such non-eligible persons may not volunteer their

services.

Section 802(j) states that residents providing such services

\"must be paid wages that are not lower than the higher of-

\(a\) the minimum wage that would be applicable to the

employee under the Fair Labor Standards Act of 1938

\...;

\(b\) the State or local minimum wage for the most nearly

comparable covered employment; or

\(c\) the prevailing rates of pay for persons employed in

similar public occupations by the same employer.\"

f\. Annual Review of Matching Funds (24 CFR 700.145 (a) or 7 CFR

1944.260 (f)

Matching funds will be reviewed annually as part of the

program/budget review. If matching funds are found to be

insufficient to meet program requirements at any time during

the term of the grant, HUD may decrease the federal grant

share of supportive service funds accordingly. This

adjustment will be done in the year following the year with

the shortfall, so that the required ratio of federal grant

to matching funds is maintained.

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4640.1 REV-1

2.16 PROGRAM COSTS

a\. Allowable Costs (24 CFR 700.115 (a) or 7 CFR 1944.256 (a))

Allowable costs must be reasonable, necessary, and must be

in compliance with OMB\'s cost policies, as delineated in OMB

Circulars A-87 and A-128. Allowable costs are as follows:

\(1\) direct hiring of staff, including a service

coordinator;

\(2\) supportive service contracts with third parties;

\(3\) equipment and supplies (including food), necessary to

provide services;

\(4\) operational costs of a transportation service (e.g.

mileage, insurance, gasoline and maintenance, driver

wages, taxi or bus waivers;

\(5\) purchasing or leasing of vehicles; and,

\(6\) direct and indirect administrative expenses for

administrative costs such as annual fiscal review and

audit, telephones, postage, travel, professional

education, furniture and equipment, and costs

associated with self evaluation or assessment.

(Allowable expenses for self-assessment may not exceed

one percent of the total CHSP budget.)

b\. Non-Allowable Costs (24 CFR 700.115(b) or 7 CFR 1944.254

(b))

Costs are nonallowable if they are related to any program,

service or activity provided by a grantee and which existed

prior to the time of application to CHSP. Such costs are as

follows:

\(1\) Capital funding (such as purchases of buildings, related

facilities and land, and major kitchen items such as

stoves, refrigerators, freezers, dishwashers, trash

compactors or sinks).

\(2\) Disproportionate administrative costs charged to CHSP for

payment of rents/leases, utilities or staff salaries.

\(3\) Payments to PAC members or any other outside

professionals assisting in the assessment process with

HUD CHSP funds (other than the Service Coordinator).

\(4\) Pre-existing supportive services or administrative

(e.g. security) programs.

\(5\) Costs of supportive services other than those approved

by HUD.

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\(6\) Modernization, renovation or new construction of a

building or facility, including kitchens.

\(7\) Costs associated with the development of the

application and service plans before the effective date

of the CHSP grant award.

\(8\) Overnight emergency nursing services and ongoing and

regular care from doctors and nurses, including skilled

nursing care, administering of medicine, purchases of

medical supplies, equipment or medication. Included

also is overnight nursing services and other

institutional forms of service, care or support.

\(9\) Occupational therapy and vocational rehabilitation

services.

\(10\) Costs of service coordination already in place and paid

for by HUD or through resources of an agency other than

HUD or RHS. (See Paragraph 2.4 for more on existing

service coordination.)

\(11\) Other items defined as unallowable in OMB Circulars A-87 or

A-122.

c\. Administrative Cost Limitation ((24 CFR 700.115(c) or 7 CFR

1944.254 (c)) Administrative costs cannot exceed 10 percent

of a program\'s total budget.

2.17 OTHER FEDERAL REQUIREMENTS

In addition to the administrative requirements in 24 CFR Parts 84

and 85, the cost principles in OMB Circulars A-87 and A-122, and

the audit requirements in OMB Circulars A-128 and A-133 (see

Exhibit 1-1), CHSP grants are subject to the following federal

requirements, in accordance with 24 CFR 700.175 and 7 CFR

1944.266:

a\. Drug-Free Workplace

Grantees must certify that they will provide a drug-free

workplace, in accordance with the Drug-Free Workplace Act of

1988, implemented by 24 CFR Part 24, subpart F.

b\. Nondiscrimination and Equal Opportunity

Recipients must comply with the following requirements to

ensure nondiscrimination. (A partial listing of HUD

implementing regulations are contained in appendices 21-27).

\(1\) Fair housing requirements of the Fair Housing Act and

HUD Fair Housing Regulations (24 CFR Part 100)

(Appendix 21);

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4640.1 REV-1

Equal Opportunity in Housing (Executive Order 10063 and

24 CFR Part 107) (Appendix 22); the fair housing

advertising and poster guidelines (24 CFR Parts 109 and

110\) (Appendix 23).

\(2\) Nondiscrimination in housing (Title VI of the Civil

Rights Act of 1964 and HUD regulations at 24 CFR Part

1\) (Appendix 24).

\(3\) Prohibitions against discrimination on the basis of age

or disability (Age Discrimination Act of 1975, Section

504 of the Rehabilitation Act of 1973, and HUD

regulations at 24 CFR Parts 146 (Appendix 25) and 8

(Appendix 26).

\(4\) Encouragement of the use of minority and women\'s

business enterprises, consistent with HUD\'s

responsibilities under various Executive Orders.

\(a\) Executive Order 11246

Requires all federal government contracting agencies to

assure contract compliance for nondiscrimination in

government employment; and, nondiscrimination in

employment by government contractors and

subcontractors.

\(b\) Executive Orders 11625 and 12432:

The Minority Business Enterprise Program (OSDBU) is

required to oversee the implementation of voluntary

compliance programs to stimulate minority business

participation in procurement and grant programs.

\(c\) Executive Order 12138:

Directs all Federal agencies to facilitate and

strengthen women-owned business enterprises to assure

full participation by women in the free enterprise

system.

\(5\) Affirmative Fair Housing Marketing requirements at 24

CFR Part 200 and compliance procedures at 24 CFR Part

108 (Appendix 27).

\(6\) Maintenance of data on the race, ethnicity and gender

of program applicants and participants, as the

Secretary may require under 24 CFR Part 121.

c\. Anti-Lobbying Certification

Grantees with assistance of more than \$100,000 must certify

that no federal funds have been or will be spent on lobbying

activities in connection with the assistance, according to

the Common Rule at 7 CFR Part 3018 and 24 CFR Part 87.

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REV-1

d\. Debarred or suspended contractors

Grantees are subject to provisions applying to the

employment, engagement of services, awarding of contracts or

funding of any contractors or subcontractors during

debarment, suspension or placement in ineligibility status,

according to 24 CFR Part 24 and 7 CFR Part 3017.

e\. Conflict of Interest

No one who is associated with an applicant and has any

responsibilities related to the activities supported by CHSP

grant funds, or participates in decision-making activities

or is in a position to gain inside information may obtain a

personal or financial interest or benefit from the activity,

or have an interest in any contract, subcontract or

agreement for himself or herself either during his or her

tenure or for one year thereafter. This requirement is in

addition to the requirements in OMB Circular A-87 and 24 CFR

Part 85.

2-33 10/96