##  U.S. Department of Housing and Urban Development

**Community Planning and Development**

+-----------------------------------+-----------------------------------+
| **Special Attention of:**         | **Notice:** CPD 06-07             |
+-----------------------------------+-----------------------------------+
| #### All HOPWA Formula Grantees   | Issued: August 3, 2006            |
|                                   |                                   |
| **All HOPWA Competitive           |                                   |
| Grantees**                        |                                   |
|                                   |                                   |
| **All CPD Field Office            |                                   |
| Directors**                       |                                   |
+-----------------------------------+-----------------------------------+
|                                   | Expires: August 3, 2007           |
+-----------------------------------+-----------------------------------+
|                                   | Cross References                  |
+-----------------------------------+-----------------------------------+
|                                   | 24 CFR Part 574 \-- Housing       |
|                                   | Opportunities for Persons With    |
|                                   | AIDS (HOPWA)                      |
+-----------------------------------+-----------------------------------+

**Subject:** Standards for HOPWA Short-term Rent, Mortgage, and Utility
(STRMU) Payments and Connections to Permanent Housing

# TABLE OF CONTENTS-- (with correction II (h)

\(I\) Overview:

(a) Authority

(b) Purpose

(c) Generalized Statement of Eligible Activities to Prevent Homelessness

\(II\) Standards for STRMU Payments:

(a) Confidentiality of Client Information

(b) Connection to Permanent Housing

(c) Eligibility for STRMU---HIV and Low-income Status

(d) Eligibility for STRMU---Current Resident

(e) Eligibility for STRMU---Risks of Homelessness

(f) Capped Payments

(g) Suitable Housing Units

(h) \[removed\]

\(III\) The Eligible STRMU Period---Standard Methods to Track:

(a) Limit of 21 Weeks

(b) Methods for Calculating the Annual Eligible Period

\(IV\) Performance Objectives:

(a) Performance Output and Outcome Goals

(b) Housing Outputs on Number of Households Assisted

(c) Client Outcomes on Housing Stability and Reduced Risks of
    Homelessness

(d) Outcomes on Access to Health Care, Case Management Services, and
    Employment Assistance and Training

\(V\) Connections to Permanent Housing Placement:

(a) Individual Housing Service Plan

(b) Permanent Housing Placement Assistance

(c) Related Use of Rental Assistance

(d) Related Use of Facilities

\(VI\) Waiver of Time Limitations for Short-term Rent, Mortgage, and
Utility Payments:

\(VII\) Waiver Request Process:

(a) Field Office Actions

(b) Necessary Elements

\(VIII\) Field Office and Grantee Oversight:

(a) Oversight Actions

(b) Continued Appropriate Housing

\(IX\) Frequent Questions and Answers (FAQ)

  ----------------------------------- -----------------------------------
  **Distribution: W-3-1,\             
  **                                  

  Previous editions are obsolete      form HUD-21-B (3/80)
  ----------------------------------- -----------------------------------

**I. Overview:**

**(a) Authority**. Section 858 of the AIDS Housing Opportunity Act
("Act"), 42 U.S.C. 12907, authorizes the use of Housing Opportunities
for Persons With AIDS (HOPWA) funds for short-term rent, mortgage, and
utility payments (STRMU) to prevent the homelessness of the tenant or
mortgagor of the dwelling*.* Regulations implementing STRMU are found at
24 CFR 574.300(b) and 574.330. This part of the HOPWA program is often
referred to as \"Short-term\" or \"Limited Housing Assistance\" since
clients are households who are facing the loss of their current housing
arrangements through pending eviction, foreclosure, or the termination
of utilities due to non-payment of these expenses. Clients can solicit
help in paying some or all of these eligible expenses when they are in
arrears in order to eliminate the threat of homelessness of the HOPWA
client.

The objective of the HOPWA program is to address the housing needs of
eligible persons associated with the challenges of living with HIV/AIDS.
STRMU payments are for eligible individuals and their household family
members who are already in housing and who are at risk of losing that
housing. STRMU should **not** be used to assist a client with locating a
housing unit or with other move-in support, as the household should
already have a housing arrangement. Other sections of the Act provide
for assistance with these other types of housing needs, such as: (i)
shelter for persons who are homeless in a short-term supported housing
facility; (ii) tenant-based or project-based rental assistance to secure
permanent, affordable housing units for on-going support; (iii)
residency in a community residence or other housing facilities which
provide other forms of on-site support and care; and (iv) housing
information services on other housing options, such as public or private
housing assistance or homeownership opportunities and support (see the
permanent housing placement discussion in section V(b)).

**(b) Purpose**. This Notice provides guidance in operating short-term
rent, mortgage and utility payments (STRMU) projects under the Housing
Opportunities for Persons With AIDS (HOPWA) program. STRMU payments are
used to prevent homelessness of individuals and families by helping them
remain in their own dwellings. This Notice updates and replaces CPD
Notice 02-09, issued November 5, 2002, on this subject and related
supportive services. Grantees must implement this Notice as soon as
practicable. The target date should be the start of the next operating
year under their Consolidated Plan schedule or competitive grant
agreement, which occurs after this publication date. However, as a
program-wide standard, grantees must implement this Notice no later than
October 1, 2006.

The goal of STRMU assistance under the HOPWA program is to provide
short-term interventions that help maintain stable living environments
for households who are experiencing a financial crisis as a result of
issues arising from their HIV/AIDS condition. STRMU assistance is a type
of prevention that is intended to reduce the risks of homelessness, and,
along with other HOPWA efforts, to improve access to health care and
other needed support. As a reasonable HOPWA program goal, this Notice
seeks to foster long-term solutions to housing problems for clients
receiving this time-limited housing assistance. This can be done by the
creation and use of individual housing service plans that include an
assessment of current resources and establish long-term goals for
recipient households along with access to other support, where needed.
These goals should involve efforts to restore client self-sufficiency
and future independence from the need for housing support. On-going
assessments of the housing assistance and supportive services requested
by participants, as required under 24 CFR 574.500, may be evidenced by
the development of a housing service plan for every client of the agency
approving the expenditure of STRMU payments. Stand alone STRMU payments
are likely to create only a temporary solution for an unstable living
arrangement unless connected to a long-term housing service plan for
maintaining the household.

This Notice will assist grantees in determining the eligible payment
period for STRMU benefits. Grantees and Project Sponsors must verify
tenancy and the household's short-term housing needs. Grantees are
encouraged to coordinate related housing efforts to assess the on-going
housing needs of these households, establish an individual housing
service plan for each household, and provide access to other permanent
housing options for HOPWA eligible persons and their families. In some
situations, the household may be helped to secure other forms of housing
support, such as residency in a community residence or in another
housing facility that provides on-site support or qualify for another
public housing program. In other situations, the eligible person and his
family may be able to transition out of public support in cases where
the household is appropriately housed and capable of independent living
with private resources. For some, the plan may establish that the
household was assisted in addressing a temporary housing crisis, and
that, with STRMU assistance, the matter was resolved to allow for
continued self-sufficiency of the household.

**(c) Generalized statement of eligible activities to prevent
homelessness.**

This chart is intended to clarify how STRMU payments and other HOPWA
eligible housing activities can be used to help households achieve more
stable housing arrangements. Rows 1-7 are eligible housing activities
under HOPWA-funded programs. Short-term rent, mortgage and utility
payments to prevent homelessness of eligible persons is listed in column
A, and other related HOPWA eligible activities in columns B-E, as found
at 24 CFR 574.300(b).

+-----------+---------+------------+---------+-------------+---------+
| *         | **A.    | ###### B.  | **C.    | **D.        | **E.    |
| *Eligible | Sho     | Tenant-bas | Housing | Permanent   | Housing |
| HOPWA     | rt-term | ed Rental  | Info    | Housing     | Case    |
| Activity  | Rent,   | Assistance | rmation | (PH)        | Man     |
| (right)   | M       |            | Ser     | Placement   | agement |
| and type  | ortgage |            | vices** | as a        | as a    |
| of        | and     |            |         | Supportive  | Sup     |
| benefit   | Utility |            |         | Service**   | portive |
| (below)** | pay     |            |         |             | Se      |
|           | ments** |            |         |             | rvice** |
+-----------+---------+------------+---------+-------------+---------+
| **1. Rent | Yes, if | Yes, if    | No      | No          | No      |
| payments  | within  | done with  |         |             |         |
| (for      | 21 week | i          |         |             |         |
| h         | limit   | nspections |         |             |         |
| ouseholds |         | for        |         |             |         |
| with a    |         | Housing    |         |             |         |
| lease)**  |         | Quality    |         |             |         |
|           |         | Standards  |         |             |         |
|           |         | and with   |         |             |         |
|           |         | resident   |         |             |         |
|           |         | rent       |         |             |         |
|           |         | payments   |         |             |         |
+-----------+---------+------------+---------+-------------+---------+
| **2.      | Yes, if | No         | No, but | No          | No      |
| Mortgage  | within  |            | can be  |             |         |
| payments  | 21 week |            | related |             |         |
| (but not  | limit   |            | support |             |         |
| dow       | (for    |            | through |             |         |
| n-payment | costs   |            | info    |             |         |
| support   | within  |            | rmation |             |         |
| for new   | the     |            | on      |             |         |
| units)**  | m       |            | homeow  |             |         |
|           | ortgage |            | nership |             |         |
|           | agr     |            | p       |             |         |
|           | eement) |            | rograms |             |         |
+-----------+---------+------------+---------+-------------+---------+
| **3.      | No      | No         | No      | Yes, for    | No      |
| First     |         |            |         | reasonable  |         |
| month's   |         |            |         | costs to    |         |
| rent and  |         |            |         | move        |         |
| security  |         |            |         | persons to  |         |
| deposits; |         |            |         | permanent   |         |
| credit    |         |            |         | housing,    |         |
| checks**  |         |            |         | not to      |         |
|           |         |            |         | exceed 2    |         |
|           |         |            |         | months of   |         |
|           |         |            |         | rent costs, |         |
|           |         |            |         | including   |         |
|           |         |            |         | security    |         |
|           |         |            |         | deposits    |         |
|           |         |            |         | and fees    |         |
|           |         |            |         | for credit  |         |
|           |         |            |         | checks      |         |
+-----------+---------+------------+---------+-------------+---------+
| **4.      | Yes, if | Yes, if    | No      | Yes, but    | No      |
| Utility   | within  | part of    |         | only for    |         |
| payments  | 21 week | the rental |         | one-time    |         |
| (gas,     | limit   | payment    |         | utility     |         |
| electric, |         |            |         | hookup and  |         |
| water and |         |            |         | processing  |         |
| sewer)**  |         |            |         | costs       |         |
+-----------+---------+------------+---------+-------------+---------+
| **5.      | No      | No         | Yes,    | Yes, as     | Yes,    |
| In        |         |            | for     | support and | such as |
| formation |         |            | costs   | help to     | cou     |
| and/or    |         |            | for     | complete PH | nseling |
| support   |         |            | pr      | ap          | and     |
| to locate |         |            | oviding | plications, | help to |
| and apply |         |            | info    | and         | develop |
| for       |         |            | rmation | eligibility | a       |
| housing   |         |            | and     | screenings  | housing |
| ass       |         |            | ma      | for tenancy | service |
| istance** |         |            | terials | or          | plan to |
|           |         |            | that    | utilities   | es      |
|           |         |            | inform  | for these   | tablish |
|           |         |            | clients | units       | stable  |
|           |         |            | of      |             | pe      |
|           |         |            | av      |             | rmanent |
|           |         |            | ailable |             | housing |
|           |         |            | housing |             |         |
+-----------+---------+------------+---------+-------------+---------+
| **6.      | No      | No         | No      | No, however | No      |
| Move-in   |         |            |         | programs    |         |
| support,  |         |            |         | may         |         |
| such as   |         |            |         | coordinate  |         |
| supplies, |         |            |         | with        |         |
| fur       |         |            |         | leveraged   |         |
| nishings, |         |            |         | resources   |         |
| i         |         |            |         | and         |         |
| ncidental |         |            |         | donations   |         |
| costs,    |         |            |         | for these   |         |
| and minor |         |            |         | purposes    |         |
| repairs   |         |            |         |             |         |
| of        |         |            |         |             |         |
| housing   |         |            |         |             |         |
| units**   |         |            |         |             |         |
+-----------+---------+------------+---------+-------------+---------+
| **7.      | No      | No         | No      | Life skills | Help to |
| Other     |         |            |         | and housing | access  |
| e         |         |            |         | counseling  | other   |
| lements** |         |            |         | on unit     | be      |
|           |         |            |         | cleaning,   | nefits, |
|           |         |            |         | maintenance | such as |
|           |         |            |         | and         | heal    |
|           |         |            |         | household   | th-care |
|           |         |            |         | budgeting   | and     |
|           |         |            |         |             | other   |
|           |         |            |         |             | sup     |
|           |         |            |         |             | portive |
|           |         |            |         |             | s       |
|           |         |            |         |             | ervices |
+-----------+---------+------------+---------+-------------+---------+

> *NOTE: STRMU projects should consider how to access other housing, as
> needed, including permanent housing programs. STRMU costs are direct
> housing and utility costs and do not include personal items such as
> grooming, clothing, home and personal furnishings, supplies, care for
> pets, financial assistance, consumer credit payments, entertainment
> activities, vehicle maintenance and repairs, phone service, and other
> non-housing-related costs. See additional HOPWA standards at 24 CFR
> part 574.*

**II. [Standards for STRMU Payments]{.underline}:**

**(a) Confidentiality of Client Information**. The provision of HOPWA
funding involves information on the HIV/AIDS status of individuals for
the purpose of determining eligibility for program support. Such
information is subject to confidentiality requirements, as mandated by
Section 856 of the AIDS Housing Opportunity Act. The implementing HOPWA
regulation, as set forth at 574.440, states: "*The grantee shall agree,
and shall ensure that each project sponsor agrees, to ensure the
confidentiality of the name of any individual assisted under this part
and any other information regarding individuals receiving assistance*."
Consistent with statutory and regulatory requirements, grantees and
project sponsors must ensure that information is used for the limited
purpose of establishing program eligibility. HIV/AIDS status, along with
related client eligibility documentation, should only be accessible by
qualified individuals who determine eligibility or provide support, or
who oversee the provision of this federal assistance. Grantees must have
written procedures and training efforts in place to maintain
confidentiality. Precautions may include, but are not limited to,
maintaining paper files in locked cabinets accessible only by designated
individuals, and installing security software for electronic files.
Grantees should conduct periodic monitoring of these procedures and
undertake related training efforts. As in other areas involving
sensitive or protected client information, questions should only be
asked and recorded when a program or project has adequate data
confidentiality protections in place. However, such actions shall not
limit the collection of non-personal data necessary to demonstrate sound
management of program resources, such as aggregated non-identifying
information collected for program performance reports, or controlled
access by an authorized governmental official to adequately conduct a
program management monitoring or financial audit. Failure to comply with
this section shall be considered a default of grant responsibilities,
which, after notice, may give rise to suspension and/or loss of grant
funds, as well as other potential actions or liability.

**(b) Connection to Permanent Housing**. As a short-term intervention
tool, STRMU assistance is not intended to provide continuous or
perpetual assistance. Other types of HOPWA assistance, such as rental
assistance (see 574.300(b)(5)), residency in community residences or
other housing facilities (see 574.300(b)(3), (4) and (8)), or assistance
with access to other housing programs should be employed when client
assessments indicate that little or no improvement of the \"conditions\"
that caused this financial burden are likely during or after the 21-week
benefit period. STRMU assistance is "needs-based" and intended to
benefit clients who are temporarily unable to meet their monthly housing
and utility expenses due to unexpected situations. STRMU assistance
should be consistent with an assessment of the family's housing or
utility needs and connected to the establishment of a related individual
housing service plan to address those on-going needs.

**(c) Eligibility for STRMU---HIV and Low-income Status**. To receive
STRMU assistance, the client must be eligible for HOPWA assistance.
Pursuant to 24 CFR 574.3, an eligible person means "a person with
acquired immunodeficiency syndrome or related diseases who is a low
income individual ... and the person's family." The project sponsor must
maintain documentation that the assisted person is HIV positive or has a
diagnosis of AIDS, as determined by a health professional competent to
make such a determination. Sufficient determinations include
documentation resulting from appropriate HIV tests administered by a
physician's office, HIV counseling center or community health center.
Documentation must also confirm that the eligible person and his family
are low-income, as measured as 80 percent of area median income, and
provide for periodic updating of income information, such as annual
re-determinations (see: HUD income limit information for Fiscal Year
2006 income limits at

http://www.huduser.org/datasets/il/il06/index.html).

**(d) Eligibility for STRMU---Current Resident**. In order to receive
STRMU assistance, there must be evidence of client tenancy or ownership
and residency. To receive rental payments, the eligible person or a
member of the resident household must present evidence that he is a
named tenant under a valid lease or that he is a legal resident of the
premises. To receive a mortgage payment, the eligible person must
demonstrate that he is the resident owner of mortgaged real property.
For utility assistance, the eligible person must have an account in his
name with a utility company **or** proof of responsibility to make
utility payments, such as cancelled checks or receipts in their name
from a utility company. Individuals who have prior criminal histories,
poor credit or lack of rental history often do not have leases or
utility accounts in their name; however, they are responsible for paying
the housing expenses. Satisfactory evidence of tenancy includes the
lease naming them as leaseholder or eligible household occupant, or a
default/late payment notice that identifies the eligible person or a
resident member of the family as a named tenant under the lease.
Satisfactory evidence of ownership of encumbered property includes: (i)
a deed accompanied by a mortgage or deed of trust; (ii) a mortgage or
deed of trust default/late payment notice which identifies the eligible
person or a resident member of the family as the property owner/debtor;
and (iii) a valid, current dated title insurance policy identifying the
eligible person or a resident member of the family as property
owner/debtor.

**(e) Eligibility for STRMU---Risks of Homelessness.** HOPWA is a
\"needs-based\" program; therefore, clients must demonstrate the level
of benefits needed through verifiable documentation. Federal assistance
covers actual costs, which are not covered or reimbursed from other
available resources when the household is unable to make payments for
monthly housing costs. Program staff are responsible for verifying and
documenting the client's inability to make required payments. The
housing service provider should assess that the household's needs are
(i) for actual costs, (ii) that other resources, such as household
income, are not reasonably available to address the unmet housing need,
(iii) that the STRMU payment will alleviate the payment delinquency so
as to avoid the eviction and result in, at least, temporary stability
for that household, and (iv) that the household's on-going housing needs
were assessed or will be assessed in connection with the development of
an individual housing service plan for the household. STRMU payments
cannot be made to an eligible person and their family for the same
period of time or housing costs if assistance is also being provided for
those costs and period of time through HOPWA or another federal, state
or local housing subsidy program.

Although STRMU assistance does not require the client to pay a portion
of the rent or utility bill, STRMU payments must not be used to relieve
the household responsibility for their rent, mortgage, or utility
payments in the absence of inability to pay. If a client is capable of
paying some of their required payments, program staff may negotiate an
appropriate amount for the household's contribution to ensure these
partial payments are made by the client, thereby limiting STRMU payments
to the difference between the amounts due and the amount the client is
able to pay. If clients know that they could save some weeks of
assistance for future emergencies by paying at least a portion of the
debt and having the assisted portion count as only a portion of the
month, it fosters more incentive and accountability with that client.
For example, program staff might determine through the assessment
process that the client is able to pay \$100 of their \$400 rent (equal
to ¼ of the total). For the purposes of tracking, the amount of weeks or
period of assistance used would be only for the part of the monthly
housing costs paid by STRMU, which in this case is ¾ of the month or
three weeks of assistance (see section IV). In providing STRMU
assistance, program staff must document that the client has no other
means to cover the payment(s) during the 21-week period and that the
grantee is making efforts to develop a permanent solution to this
housing affordability problem. Included in this Notice is a table
demonstrating how these payments can be tracked to help assure adherence
to the 21-week payment limitation.

**(f) Capped Payments**. For STRMU assistance a grantee may authorize a
project sponsor to establish a capped amount for the individual or
family's housing or utility assistance payment for a given period of
time. In establishing a capped amount, grantees must consider the area's
Fair Market Rent, rent reasonableness or other measure of the area's
housing market with a goal that the level of support is sufficient to
avoid any continuing household housing crisis. Should a grantee apply
caps or limitations on the amount of assistance, the use of these limits
must be applied in a uniform, consistent and non-discriminatory manner.
In the case that a household receives the maximum subsidy for that
period, HUD will consider the assistance to have been attributable to
the entire 21-week period allowed by the regulations. If the grantee
allows a provider to establish a program limit or schedule of support
available as STRMU payments, the use of the limit must be established as
an expressed element of the grantee's annual action plan under the
Consolidated Plan, or as a specific element in an approved competitive
application. The use of this schedule must be assessed for its
appropriateness in assistance provided to eligible persons and monitored
for consistency by the grantee. The grantee should report its assessment
to HUD as an expressed element of the grantee's annual report to ensure
that the use of any schedule results in adequate and appropriate housing
support of the households assisted. The assessment must cover the four
items found in paragraph (e) on actual need.

**(g) Suitable Housing Units**. As STRMU is used to support households
in their current housing, it is required that projects assess whether
the housing is safe, decent and sanitary as part of their required
on-going assessment of the housing assistance provided through this
federal program. A housing quality standard inspection is not required
initially for the use of these time-limited STRMU payments, if needed to
prevent the homelessness of the household and the unit is safe and
decent. However, it is strongly recommended that continued occupancy of
any HOPWA-supported housing be shown to meet HUD's habitability
standards found at 24 CFR 574.310(b)(2), and that any observed
deficiencies noted in an individual housing service plan are addressed
appropriately, consistent at a minimum with state and local standards.

**(h)** \[removed\]

**III. [The Eligible STRMU Period---Standard Methods to
Track]{.underline}:**

**(a) Limit of 21 Weeks**. The statute and related regulations place
limitations on the length of time clients may receive STRMU assistance.
Beneficiaries should be prompted to make at least a partial payment for
their housing costs. Assistance may not be provided for costs accruing
over a period of more than 21 weeks in any 52-week period. Therefore,
program staff are required to examine the periods of time covered by
rental, mortgage and utility bills to assure that payments are not made
in excess of amounts incurring over 21 weeks. Note that short-term
support should be connected to helping households with more long-term
needs with other forms of support. All STRMU costs may be equated to the
actual calendar days of assistance provided; however, HOPWA allows other
acceptable methods for equating and tracking the "benefits period" as
most costs relate to monthly billing cycles for rent, mortgage or
utility payments. Once a grantee selects the method it intends to use
for calculating the maximum allowable period of benefits, the grantee
must use that particular method for every project sponsor. The purpose
of allowing these three methods is to help grantees establish clear
procedures for tracking the application of this 21-week limit on such
monthly costs. The four standard methods are as follows:

\(1\) **CALENDAR DAYS OF ASSISTANCE**. This method would be equal to the
actual days for which housing and/or utility payments are made on behalf
of the client household. The limit of 21 weeks is equated to 147 days of
assistance in the year. [Example #1]{.underline}: If a total utility
bill was paid and the service period was April 17-May 16, 14 days would
be attributed to April and 16 days to May. [Example #2]{.underline}: If
a portion of the utility bill was paid, the days would be counted based
on the amount that was paid by STRMU (e.g. total bill for April 17-May
16 (30 days)) is \$148.00. Agency agrees to pay \$100. Divide \$148 by
30 days, which equals \$4.93 per day. The \$100 payment divided by
\$4.93 per day equals 20.3 days (rounded to 20 days) assisted by STRMU.

\(2\) **ROUNDING A MONTH TO FOUR WEEKS**. This method rounds each month
to four weeks, allowing for up to 21 weeks in the benefits period.
Rental and mortgage costs generally cover a calendar month period
consisting of slightly more than four full weeks. This method allows for
5 months and one week of assistance as the limit, regardless of the
number of days in those months. [Example]{.underline}: A rental period
of June 1-June 30 is rounded down to 4 weeks. If payment was made for
75% of a month's rent it would be tracked as 3 weeks; 50% of a month's
rent would be tracked as 2 weeks, and 25% of a months rent would be
tracked as 1 week.

Monthly utility service periods generally do not coincide with rent or
mortgage periods, rather they likely span parts of 2 calendar months
(e.g. May 7-June 6). When assisting **only** the utility costs, the
monthly assistance period is rounded down to 4 weeks of STRMU support.
[Example:]{.underline} A utility period of May 7-June 6 is rounded down
to 4 weeks. If payment was made for 75% of a utility bill it would be
tracked as 3 weeks; 50% of a utility bill would be tracked as 2 weeks,
and 25% of a utility bill would be tracked as 1 week.

If **both** a housing bill and utility bill are paid to address the
household's STRMU need, but the dates of service do not coincide, the
benefit period would be calculated as follows: Count this overall
assistance as one month (4 weeks) if at least 14 days of the utility
period coincide with the rent/mortgage period. In situations where less
than 14 days coincide, the remaining portion of the utility period will
be attributed to the next month for tracking purposes. [Example
#1]{.underline}: A rental period of May 1-31 is rounded down to 4 weeks.
The utility period of May 7-June 6 results in 25 days coinciding with
the rental period; therefore, a total of 4 weeks is counted in May for
the payment of both rent and utilities. [Example #2]{.underline}: If the
utility bill had coincided with the May rental period for less than 14
days (e.g., May 20-June 19, equaling 12 days rounded up to 2 weeks in
May), part of this assistance (19 days) would be attributed to June, as
3 additional weeks of assistance added to the 4 weeks attributed to May
for rent assistance.

\(3\) **COUNTING FULL AND PARTIAL WEEKS**. This method tracks twenty-one
weeks of assistance based on 52 weeks per year, divided by 12 months,
rounded to 4.3 weeks per month. A full month's rent would be tracked as
4.3 weeks; 75% of a month's rent would be tracked at 3.2 weeks, 50% of a
month's rent would be tracked as 2.2 weeks, and 25% of a month's rent
would be tracked at 1.1 weeks of assistance.

**(b) Methods for Calculating the Annual Eligible Period.** The grantee
must ensure that all project sponsors use the same method each year to
determine the period for STRMU assistance. The period may be calculated
by using any of the acceptable methods; however, the grantee must select
one method and require project sponsors to consistently apply it for all
of its clients. (i) The first method is to use a set standard annual
period for all clients. This can be either the grantee\'s operating year
under their HUD-approved Consolidated Plan, which is used for plan
approval and for annual reporting to HUD or the calendar year, which
begins January 1 and ends on December 31; or for a competitive grant,
the operating year established under the grant agreement with HUD. (ii)
The second method is for grantees to establish a separate period of
eligibility for each client. This is based on the beginning service date
in which a STRMU payment is made on behalf of the client (e.g., the
monthly period in which the first housing and/or utility assistance
payment is made, including any overdue bills, prior to the date the
client made the request). The client\'s period of eligibility would end
52 weeks after the first STRMU benefit started accruing. At the end of
the 52-week period, the next period of eligibility would begin.

**IV. Performance Objectives**:

**(a) Performance Output and Outcome Goals**. STRMU assistance is used
to help stabilize clients who are already housed and to provide time to
develop a permanent housing stabilization plan for long-term support.
Continued reliance on short-term assistance for the same household does
not represent a stable living situation although a temporary result
shows a reduced risk of homelessness.

HUD tracks established performance goals for the use of STRMU assistance
through annual grantee performance reports. At the beginning of each
operating year, grantees must estimate the number of households expected
to benefit from STRMU payments. Formula grantees must estimate these
output goals in their Consolidated Plan annual action plan proposals
(and related IDIS elements), while competitive grantees must establish
housing output goals on the logic model form of their application to
HUD. On February 9, 2006, regulations on this matter were updated in a
final rule, entitled Consolidated Plan Revisions and Updates (71 FR
6950). The new rule provides, which is codified at 24 CFR 91.220(l)(3)
provides that HOPWA EMSA grantees must establish one-year goals for the
number of households to be provided housing through the use of STRMU
payments. A similar provision applies to state grantees under
91.320(k)(4). Grantees are responsible for carrying out planned
activities consistent with the HUD-approved grant agreement for their
award. Pursuant to section 91.520, grantees are required to provide a
report on the comparison of actual to planned outcomes under Section
91.520. Annual output goals are established in grant agreements as the
required HOPWA program housing outputs for the expected use of funds to
help provide short-term support to eligible persons. At the end of each
operating year, the grantee will report to HUD on the total number of
different households that benefited from STRMU payments by remaining
stably or temporarily housed in their own dwelling. (Note: this is not
the number of such payments, as eligible households may receive more
than one payment during that year, based on assessed need and consistent
with the time limitations).

HUD has established required program outcome measures to determine how
assistance helps recipient households establish or maintain stable
housing, reduce their risks of homelessness, and improve their access to
healthcare and other support. These outcome measures will enable
grantees and HUD to better assess the effectiveness of activities in
addressing the housing needs of recipients and to increase the number of
eligible persons in stable housing situations over time. By design, the
intended purpose of short-term assistance is to address immediate
housing needs and provide support to prevent or reduce the pressing
risks of homelessness for recipients. Projects should not rely solely on
short-term assistance. STRMU payments are intended to resolve a housing
crisis to help recipients to become self-sufficient. Efforts must
involve on-going assessment of housing needs that can be shown by use of
an individual housing service plan for recipients, with a focus on how
the household will have access to on-going permanent housing assistance.

This new outcome measure will identify HOPWA-assisted households that
have been assisted in maintaining their current housing. The outcome
goal of a short-term program is to reduce the risks of homelessness and
improve access to health care and other support through other public and
private resources. At the end of each year of assistance, HOPWA grantees
are asked to consider the effects of their efforts and report to HUD
under this general client outcome (see updated HOPWA reporting forms).
These assessments will help the community, as well as HUD, in assessing
past performance and directing future efforts to increase the percentage
of clients in stable housing situations under the HOPWA outcome measure.
Additionally, programs can utilize the information to consider
alternatives or program enhancements if activities do not result in
adequate and appropriate benefits for eligible persons. In their annual
performance reports, grantees identify:

**(b) Housing Outputs on Number of Households Assisted**: Grantees must
compare the estimated number of households to be supported with HOPWA
housing assistance funds during this year (as approved in the grant
agreement) and the actual number supported by project activities. For
STRMU, the report covers the number of households who were assisted
during the program year*. (Note: revised HOPWA annual performance
reports have deleted the previous requirement to track the size of the
unit being supported, categorized by the number of bedrooms per unit.
Regardless of the number of months the program sponsor made payments for
a household, the report will count only once each household that
received assistance during the program year.)*

**(c) Client Outcomes on Housing Stability and Reduced Risks of
Homelessness**: Grantees must provide current year outcomes on the
housing status of their recipients. This annual result will be compared
with a baseline of the grantee's prior number of HOPWA-assisted
households who were enabled to establish and/or better maintain stable
housing and improve their access to healthcare and other support.
Grantees will be asked to provide the housing status of their clients,
such as clients continuing in a HOPWA housing program or leaving HOPWA
housing assistance for other forms of housing support, at the end of
each program year. In some cases, the household becomes self-sufficient,
or qualifies for another housing program that helps them maintain a
stable living arrangement. For others, additional short-term or
transitional housing support will be required, and these households are
reported under a temporary arrangement. However, some clients leave
programs for compliance reasons, other failures, or unknown causes that
evidence an unstable arrangement or result. To complete HUD reports on
STRMU activities, grantees will be asked to use charts similar to those
depicted below.

**Examples for Reporting on HOPWA Housing Stability Outcomes** -- Status
of Clients at the end of the grantee operating year.

-   In column 1, provide the total number of eligible households that
    received STRMU housing assistance.

```{=html}
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```
-   In column 2, out of the total number of households receiving STRMU
    assistance this operating year, indicate what number of those
    households also received STRMU assistance in the prior operating
    year (covering 2 years of STRMU assistance), and what number of
    these households further received STRMU assistance in both of the
    prior two operating years (covering 3 years of STRMU assistance).

-   In column 3, report the status of each household at the end of the
    operating year, regardless of the number of weeks of STRMU
    assistance accessed. If members of a household had different
    outcomes during the operating year, report only on the destination
    of the eligible person living with HIV/AIDS.

+------------+-----------------+---------------+---------------------+
| **         | **1.**          | **2.**        | **3.**              |
| Short-term |                 |               |                     |
| Housing    | **Total Number  | **Of the      | **Housing Stability |
| Subsidy    | of Households   | Total number  | Status of STRMU     |
| As         | Receiving HOPWA | Households    | Assisted Households |
| sistance** | STRMU           | Receiving     | at the End of       |
|            | Assistance**    | STRMU         | Operating Year**    |
|            |                 | Assistance    |                     |
|            |                 | this          |                     |
|            |                 | operating     |                     |
|            |                 | year**        |                     |
+------------+-----------------+---------------+---------------------+
| **         |                 | **What number | 1 (Emergency        |
| Short-term |                 | of those      | Shelter) =          |
| Rent,      |                 | households    |                     |
| Mortgage,  |                 | received      |                     |
| and        |                 | STRMU         |                     |
| Utility    |                 | Assistance in |                     |
| As         |                 | the prior     |                     |
| sistance** |                 | operating     |                     |
|            |                 | year:**       |                     |
|            |                 |               |                     |
|            |                 |               |                     |
|            |                 |               |                     |
|            |                 | **What number |                     |
|            |                 | of those      |                     |
|            |                 | households    |                     |
|            |                 | received      |                     |
|            |                 | STRMU         |                     |
|            |                 | Assistance in |                     |
|            |                 | the two (2)   |                     |
|            |                 | prior         |                     |
|            |                 | operating     |                     |
|            |                 | years         |                     |
|            |                 | (ago):**      |                     |
|            |                 |               |                     |
|            |                 |               |                     |
+------------+-----------------+---------------+---------------------+
|            |                 |               | 2 (Temporary        |
|            |                 |               | Housing) =          |
+------------+-----------------+---------------+---------------------+
|            |                 |               | 3 (Private          |
|            |                 |               | Housing)\* =        |
+------------+-----------------+---------------+---------------------+
|            |                 |               | 4 (Other HOPWA) =   |
|            |                 |               |                     |
+------------+-----------------+---------------+---------------------+
|            |                 |               | 5 (Other Subsidy) = |
|            |                 |               |                     |
+------------+-----------------+---------------+---------------------+
|            |                 |               | 6 (Institution) =   |
|            |                 |               |                     |
+------------+-----------------+---------------+---------------------+
|            |                 |               | 7 (Jail/Prison) =   |
|            |                 |               |                     |
+------------+-----------------+---------------+---------------------+
|            |                 |               | 8 (Disconnected) =  |
|            |                 |               |                     |
+------------+-----------------+---------------+---------------------+
|            |                 |               | 9 (Death) =         |
+------------+-----------------+---------------+---------------------+

**Background on HOPWA Housing Stability Codes**

**Unstable Emergency or Homeless status**

1 = Emergency shelter or no housing destination due to habitation in
places not intended for occupancy (e.g., a vehicle, an abandoned
building, bus/train/subway station, or anywhere outside).

**Short-term and Temporary Housing Arrangements**

2 = Temporary housing and other short-term arrangements, such as moving
in with family/friends, continued STRMU assistance, Ryan White subsidy,
transitional housing for homeless, and temporary placement in
institution (e.g., hospital, psychiatric hospital or other psychiatric
facility, substance abuse treatment facility or detox center).\*

\* *NOTE:* *STRMU is considered a temporary arrangement that reduces the
risk of homelessness for a tenant or resident owner, and should be
reported as category #2, if there is a reasonable expectation that
additional STRMU support is needed or likely to continue into the next
program year in order to assist the household in avoiding homelessness.*

**Stable Permanent Housing/Ongoing Participation**

3 = Private Housing in the private rental or homeownership market
(without known subsidy other than STRMU, including permanent placement
with families or other self-sufficient arrangements) with reasonable
expectation that additional support is not needed.

4 = Other HOPWA-funded housing assistance that is not STRMU assistance
(e.g. TBRA or facility-based assistance).

*NOTE: For some households, STRMU may address the temporary housing need
for a tenant or resident owner, and should be reported as category #3 if
there is an assessment and reasonable expectation that additional STRMU
support will NOT be needed or is unlikely to continue into the next
program year and the household will likely maintain its private housing
arrangement.*

5 = Other subsidized housing assistance from non-HOPWA sources (e.g.,
Section 8, HOME, public housing).

6 = Institutional setting with greater support and continued residence
expected (e.g., residential or long -term care facility, hospital).

**Life Events**

7 = Jail or prison.

8 = Disconnected or disappeared from project support, unknown
destination or no assessments of housing needs were undertaken.

9 = Death (i.e., remained in housing until death). This life event is
not factored into determining or assessing the housing stability outcome
for beneficiaries.

**Assessments for STRMU assistance:**

**Stable Housing** is the sum of the number of households reported under
categories 3, 4, 5, and 6 who received STRMU assistance for some portion
of the permitted 21-week period and there is reasonable expectation that
additional STRMU support is **not** needed in order to maintain private
housing arrangements (as STRMU is a time-limited form of housing
support)**.**

**Temporary Housing** reported under category 2 should be used to
reflect on-going short-term or temporary efforts that help prevent or
reduce risks of homelessness. Include households that received STRMU
assistance for some portion of the permitted 21-week period and who will
most likely continue to receive this assistance in the next program
year, based on a reasonable understanding or assessment of their housing
arrangements.

**Unstable Situations** is the sum of the number of households reported
under categories 1, 7, and 8 that accessed assistance for some portion
of the permitted 21-week period during the program year, and the
household is maintaining a temporary housing arrangement that is likely
to rely on STRMU assistance into the next year.

Note: In some situations, a household may utilize STRMU only once or
twice during the program year and remain stably housed for long periods
of time. There are other households who access assistance more often and
are not stably housed after 21 weeks, but remain in their unstable
housing situations because of limited affordable housing options in
their community. It will be important to note in the required on-going
program assessment the number who return for STRMU assistance in the
next program year. In such cases, the assessment for use of a STRMU-only
approach to their needs may show that this type of support is temporary
in avoiding homelessness and that the household requires a more
appropriate level of permanent housing support. HUD is interested in
reviewing the performance data to be collected in evaluating this aspect
of program support to note if such temporary help with STRMU can
stabilize households in an appropriate and cost effective manner.
Additionally, grantee comments on this performance result and efforts
conducted consistent with the individual housing service plan would also
be useful to understanding the challenges facing this special needs
population.

**(d) Outcomes on Access to Health Care, Case Management Services and
Employment Assistance and Training:** As required for the on-going
assessment of the housing assistance and supportive services provided to
beneficiaries, grantees are asked to consider how beneficiaries of STRMU
payments can improve their access to other support to establish a more
stable housing situation, as needed. For example, eligible persons who
need to relocate from inadequate housing could benefit from the use of
housing information services, permanent housing placement services, or
other supportive services by the project sponsor, to find and establish
a new residency in an appropriate housing unit. Case management support
in connection with housing information services and housing placement
support can enable STRMU households to receive support to develop
housing plans to better establish and maintain stable living
arrangements by accessing other housing support along with healthcare
and mainstream human services. Such efforts may be shown in changes in
the household incomes, through access to other public benefits or
employment. Other types of support interventions are also available.

##### To measure the effectiveness of this support, the grantee's annual report should indicate the number of households in the STRMU program who had an assessment of their connection to supportive services which demonstrated the following service involvements prior to entry into the program and/or newly established this connection to support during the program year: (i) has a housing plan for maintaining or establishing stable on-going residency; (ii) had contact with a case manager/benefit counselor at least once in the last three months (or consistent with the schedule specified in their individualized service plan); (iii) had contact with a primary health care provider at least once in the last three months (or consistent with the schedule specified in their individualized service plan); (iv) had medical insurance coverage or medical assistance; (v) obtained an income-producing job created by this project sponsor during the year; and (vi) obtained an income-producing job outside this agency during the year.

Example: Reporting access to services prior to and during HOPWA STRMU
assistance. Please indicate the number of STRMU participants who had the
following service, accessed prior to entry into the STRMU program and/or
during the operating year:

  ----------------------------------------- -------------- ------------ ------------
  **Category of Services Accessed**         **Number of                 **Number of
                                            Households                  jobs that
                                            receiving                   included
                                            HOPWA Housing               health
                                            Assistance**                benefits**

                                            **At Entry or  **At Exit or 
                                            Continuing     Continuing   
                                            from prior     in the       
                                            year**         program      
                                                           (into next   
                                                           year)**      

  i\. Has a housing plan for maintaining or                             
  establishing stable on-going residency.                               

  ii\. Had contact with a case                                          
  manager/benefit counselor at least once                               
  in the last three months (or consistent                               
  with the schedule specified in their                                  
  individualized service plan).                                         

  iii\. Had contact with a primary health                               
  care provider at least once in the last                               
  three months (or consistent with the                                  
  schedule specified in their                                           
  individualized service plan).                                         

  iv\. Had medical insurance coverage or                                
  medical assistance.                                                   

  v\. Obtained an income-producing job                                  
  created by this project sponsor during                                
  the year.                                                             

  vi\. Obtained an income-producing job                                 
  outside this agency during the year.                                  
  ----------------------------------------- -------------- ------------ ------------

*Note: This chart is provided to illustrate the information to be
reported on client outcomes from the use of STRMU payments and related
program activities to support permanent housing placements for
beneficiaries of HOPWA assistance. Please use the appropriate HOPWA
report forms provided through the CAPER, APR, and IDIS reporting and not
through these examples when providing annual information to HUD.*

**V. [Connections to Permanent Housing]{.underline}:**

STRMU support is limited to helping the household maintain a current
residence on a temporary basis. Other forms of HOPWA support may be used
to compliment the use of short-term assistance, such as housing case
management, housing information counseling, permanent housing placement
support, and the costs for on-going housing support through rental
assistance programs, or residence in housing facilities.

**(a) Individual Housing Service Plan.** Along with client eligibility,
the project sponsor must document the appropriateness of the STRMU
payment in each client's file. Grantees are required to conduct an
ongoing assessment of the housing assistance and supportive services
required by participants in the program at 24 CFR 574.500. Grantees can
satisfy this requirement by directing their sponsors to develop
individual housing service plans for all beneficiaries. HOPWA housing
information services at 574.300(b)(1), or housing case management funds
at 574.300(b)(7), may be used to help the client understand available
housing resources and develop and follow their individual housing
service plan with connections to other support. The plan should identify
the household's on-going housing stability needs and likely options for
providing related assistance, including the use of other housing
programs and mainstream health and human welfare programs. In providing
STRMU assistance, the provider's qualified staff should assess the
client's housing needs and related resources, along with the reasons or
causes of the housing need. The plan should address budget and money
management issues, if the cause for housing debt is related to the
household's poor money management practices, such as the use of credit
cards or cash for non-essential items, or entertainment activities. The
assessment should help determine how to best use short-term or
transitional support in connecting the on-going permanent housing
arrangements, including forms of supportive housing or more independent
living arrangements reasonably associated with the assessment of the
client's needs. STRMU assistance must be provided in a manner that has a
sufficient or clear beneficial effect on addressing the client's
assessed immediate or short-term housing needs and only be provided in
connection with the client's demonstrated compliance with the plan.
Plans should establish the on-going housing stability goals for clients
in connection with their need to access medical treatment and supportive
services associated with HIV/AIDS issues.

**(b) Permanent Housing Placement Assistance.** Permanent housing
placement services at 574.300(b)(7) may be used to help eligible persons
establish a new residence where on-going occupancy is expected to
continue. It may be used to compliment other forms of HOPWA housing
assistance. For example, it may be used to assist STRMU clients who have
exceeded the 21-weeks of allowable assistance.

\(i\) Costs may include fees for housing services or activities designed
to assist individuals or families in locating suitable housing, which at
a minimum would be referral to housing that is decent, safe and
sanitary, subject to requirements covering other assistance programs.
These costs may include tenant counseling, assisting individuals and
families to understand leases, secure utilities, make moving
arrangements, pay for representative payee services for persons who use
such services to better manage their own finances, and mediation
services related to neighbor/landlord issues that may rise.

\(ii\) Costs may include placement costs such as application fees,
related credit checks, and reasonable security deposits necessary to
move persons into permanent housing, provided such deposits do not to
exceed two months of rent, and such funds would be designated to be
returned to the program.

\(iii\) However, some items are [not]{.underline} eligible as HOPWA
permanent housing placement costs, such as costs for housing supplies,
smoke alarms, standard furnishings, minor repairs to the unit associated
with the move-in, and other incidental costs for occupancy of the
housing unit. *Note: while these items are not eligible as HOPWA costs
for permanent housing placement assistance, grantees may make use of
leveraged funds or donations to address the related needs for other
move-in support for HOPWA beneficiaries.*

**(c) Related Use of Rental Assistance.** If it is determined that STRMU
clients needs ongoing rental assistance beyond the 21-weeks or the
program cap to address immediate housing needs, HOPWA project-based or
tenant-based rental assistance, or other forms of tenant-based rental
assistance such as HUD's Section 8 Voucher or HOME programs may be used.
(However, many of the available housing programs are targeted to rental
housing assistance and may not be available to homeowners or to pay for
mortgages). These rental assistance programs may also address monthly
housing costs, but do not allow for the use of security deposits such as
first and last month's rent and utility deposits. Other categories of
HOPWA funding may be used for this purpose (see permanent housing
placement above). Rental assistance programs must conduct housing
quality inspections to determine the suitability and habitability of the
rental unit, and have requirements for resident rent. For example, a
portion of rental costs paid from household income, which is set to
limits such as 30 percent of adjusted gross monthly income. HOPWA
regulations have additional standards for resident rent payments and
housing quality inspections at 574.320.

**(d) Related Use of Facilities.** Clients who previously received STRMU
assistance may also later in the year be placed in a housing facility in
which the household benefits from residency through the use of
project-based rental assistance or through the costs to operate those
facilities. In addition to rental assistance for households who are
homeless, the program may offer shelter or residency in community
residences or other housing facilities for which the costs of facility
development, leasing or operating cost for the housing facility is
eligible under 574.300(b)(3), (4) and (8), along with related supportive
services for residents under 574.300(b)(7). A facility could operate to
address emergency, transitional and/or permanent housing needs of
beneficiaries.

**VI. [Wavier of Time Limits for Short-term Rent, Mortgage and Utility
Payments]{.underline}:**

Waivers of the STRMU 21-week time limitations may be granted by HUD for
a period of one year on an individual basis, subject to approval by the
Assistant Secretary for Community Planning and Development (CPD) and the
concurrence of the Office of General Counsel (OGC). Although other forms
of HOPWA or other program assistance may be available to grantees or
sponsors to address the on-going housing needs, in certain situations it
will be necessary to obtain a waiver of the STRMU time limitation*.*
Waiver requirements are found in the regulations at 24 CFR
574.330(a)(2): *Waiver of time limitations.* HUD may waive, as it
determines appropriate, time limitations based on the good faith effort
of the grantee or project sponsor to provide permanent housing or
housing in a living environment appropriate to the client\'s health or
social needs. However, since grantees can make use of rental assistance
under 24 CFR 574.300(b)(5) in lieu of continuing short-term assistance,
a waiver of the short-term limit should only be requested in special
circumstances and not for reasons of administrative convenience. HUD
will require that the suitability for continued use of STRMU payments be
shown in an individual housing service plan for the household to
evidence good faith effort.

Waiver requests must address the client's housing quality standards. For
clients receiving rental assistance in excess of 574.320(a), waiver
requests must also address the maximum subsidy limit. Housing that does
not meet the housing quality standards found at 574.310(b) is not, in
CPD\'s determination, appropriate to any client\'s health or social
needs. Similarly, CPD has determined that clients living in rental
housing receiving STRMU assistance in excess of the maximum, monthly
subsidy under 574.320(a) are not appropriately housed. The request
should demonstrate that the household's on-going housing needs were
assessed in connection with efforts to access other support, such as the
development of an individual housing service plan for the household, and
how support to access other forms of needed support were undertaken.

**VII. [Waiver Request Process]{.underline}:**

**(a) Field Office Actions**. HUD\'s CPD Directors are *not* authorized
to approve waivers but may recommend such actions. Field Offices must
follow the standard procedures used when the waiver of a regulation
provision is requested. To expedite waivers so that they may be obtained
before payments for a 22nd week or sixth month of assistance are needed,
the CPD Director should send a concurring or nonconcurring statement,
together with the grantee\'s written request for a waiver of the
regulation to the Assistant Secretary for Community Planning and
Development. Given the short period of STRMU assistance, please also
alert the Director, Office of HIV/AIDS Housing, at HUD Headquarters, as
soon as practical, that this type of request is underway to provide
support for preparing this time sensitive matter. Grantees should seek
to process any needed waiver for the individual or family at least four
weeks prior to the 21-week limit, as these actions require review
actions by a number of HUD offices.

**(b) Necessary Elements.** The Office of HIV/AIDS Housing will provide
support for the Assistant Secretary's consideration of the STRMU waiver
request and will help process all requests with concurrence by OGC. In
granting waiver requests, HUD will consider the appropriateness of the
housing to the needs of the individual client, such that the current
level of housing support will maintain the individual in an independent
living situation in a reasonable manner. HUD will also consider the
grantee\'s good faith effort to access and/or provide permanent housing.
For example, housing case management efforts or housing information
services to secure alternate housing solutions, housing counseling
efforts, as well as placing the client on wait lists for mainstream
permanent types of housing assistance, such as HOPWA rental assistance,
Section 8 vouchers or various other affordable housing resources. Each
client for whom a waiver is sought must attest that the conditions that
caused the original financial burden and need continue to exist, and
without this assistance the client would be at risk of homelessness.
Prior to soliciting HUD\'s approval of a waiver, each property inspector
or case manager shall document the client\'s capacity to live
independently and that the level of benefits received is sufficient to
satisfactorily sustain the client in their dwelling.

**VIII. [Field Office and Grantee Oversight]{.underline}:**

**(a) Oversight Actions**. After HUD approves a waiver of the time
limitation, the grantee and HUD staff should provide adequate grants
management oversight, including on-site monitoring, to inspect a
sampling of client files for the clients for whom waivers were issued.
An effort should be made to determine if these clients have been moved
to permanent housing or continue to receive assistance, and that the
type of housing assistance is appropriate to their needs. Grantees must
ensure that project sponsors maintain in each client file, adequate
documentation for a HUD review. Waiver of the time limit for STRMU
assistance may extend a client\'s benefits for a defined period of time
specified in the request, such as the remainder of the year, if it is
determined and documented that no other appropriate housing options are
available that would maintain an adequate and stable living arrangement
during this period. Waivers would not be approved for indefinite or
unrealistic periods.

Clients receiving STRMU assistance are eligible to receive supportive
services, as provided by 574.310(a)(1). Supportive services may continue
to be provided to eligible persons while they remain in their residences
after the 21-week period for STRMU if such residence is appropriate to
the housing needs of the eligible persons and the assistance is
consistent with the housing service plan for the household. A mortgage,
rent and utility program assisted under this part shall provide, when
reasonable, supportive services specifically designed to maintain the
individual in such residence.

**(b) Continued Appropriate Housing**. The grantee and/or project
sponsor must evaluate each client\'s level of need and care to determine
if it is appropriate to maintain the individual in an *independent
living environment,* prior to requesting a waiver of the time
limitations that would pertain to continuing assistance during the
remainder of this grantee operating year (i.e. potentially extending its
eligibility period to 52 weeks). An approved waiver would serve to
extend each client\'s benefits for an increased period of time, but
clients may not be able to regain independence in their current housing
situations. A good faith effort to provide long-term housing solutions
*must* be pursued for each client. Under certain circumstances, the
client's *current* living environment may be the most appropriate for
\"his or her health and social needs,\" and is deemed more appropriate
than relocating an already adequately housed client, if that housing is
deemed to be safe, decent and sanitary as determined by a housing
quality inspection. Persons in substandard living environments shall not
be continued under this short-term program and must be referred to
organizations that can provide the appropriate level of care and housing
needed by this individual.

### 

### IX. [Frequent Questions and Answers (FAQ) About STRMU Assistance]{.underline}:

**(a) Is there a specific date by which STRMU guidance needs to be
implemented?**

Grantees must implement this Notice as soon as practicable. The target
date should be the start of the next operating year under their
Consolidated Plan schedule or competitive grant agreement, which occurs
after this publication date. However, all grantees must implement this
notice no later than October 1, 2006. A grantee that determines
corrective action is needed to fully comply with the Notice should take
all necessary steps to correct the matter as soon as practical and may
seek HOPWA technical assistance, as needed. If contract amendments are
deemed necessary, a reasonable action plan and timeline should be put in
place by the grantee for amending its contracts and making the necessary
changes, based on this HUD Notice.

**(b)** **Can STRMU payments pay for telephone service?**

NO, not as a housing cost reported as STRMU. However, in some
situations, a grantee may determine that their HOPWA programs will allow
for supportive services that include reasonable costs for basic phone
services that are determined to be needed to assist the beneficiary in
accessing services, such as maintaining consistent and accurate
participation with medical treatment protocols, care or other essential
supportive services. As an additional consideration for rural or small
population areas, these supportive service cost may involve reasonable
costs for long-distance services, if needed, for connecting clients to
this available support.

**(c) To document need, is a default notice or eviction action required,
as these can add late fees to our costs?**

This notice does not require documentation in the form of a default/late
payment notice to demonstrate housing need. A late payment notice is
only one of the methods that can be used to verify the debt; there may
be a variety of other ways to verify amounts owed, including calling the
utility company, landlord, or mortgage company directly prior to a late
payment notice being issued, and thereby avoiding adding late fees as
additional costs.

HOPWA is a \"needs-based\" program and clients must demonstrate a need
for benefits through some form of verifiable documentation, noting such
as \"inability to make their monthly payment.\" A grantee can establish
a reasonable basis to quantify and verify the need for a STRMU payment.
This could involve a record of actual monthly bills for reoccurring
cost, and evidence of the limited nature of household income along with
limited available financial resources (i.e. balance on bank accounts).
This could involve a case manager\'s assessment of \"need\" which
includes a variety of elements such as current, previous and future
month\'s financial situation/forecast, employment/benefits
circumstances, and HIV/AIDS health-related conditions. A household
budget review of these costs, and assessment of inability to meet such
costs, could be done by a housing case manager as part of this
documentation of this record. As STRMU payments are a form of time
limited interventions, the solution may rest with a need to develop a
individual housing service plan that provides a plan for the more
long-term housing needs of these households.

This document was issued by HUD's Office of Community Planning and
Development to provide for the management of HOPWA activities consistent
with program requirements. Please address any questions to the State or
Area CPD Offices in your community, or to the Office of HIV/AIDS
Housing, at HUD Headquarters, at HOPWA@hud.gov.