OMB Approved No.: 1505-0266 

Exp.: 11/30/2021

EMERGENCY RENTAL ASSISTANCE PROGRAM

U.S. DEPARTMENT OF THE TREASURY

Program Improvement Plan

This form of Program Improvement Plan has been developed to improve the delivery of 

emergency rental assistance (ERA) funds under the Consolidated Appropriations Act, 2021 and 

the American Rescue Plan Act of 2021. The assistance authorized by the Consolidated 

Appropriations Act, 2021 is referred to as “ERA1.” The assistance authorized by the American 

Rescue Plan Act of 2021 is referred to as “ERA2.” 

The Consolidated Appropriations Act, 2021 requires the U.S. Treasury Department to begin 

reallocating “excess” ERA1 funds beginning on September 30, 2021. Treasury issued 

Reallocation Guidance, available on Treasury’s website, under which grantees that obligated 

less than 65% of their ERA1 allocations by September 30, 2021, or that do not provide an 

Obligated Funds Certification as described in the guidance, must submit for Treasury’s approval 

a Program Improvement Plan no later than November 15, 2021 in order to avoid an excess 

funds determination equal to 10% of the grantee’s initial allocation. A grantee may also submit 

a Program Improvement Plan to mitigate an excess funds determination that would result from 

an insufficient expenditure ratio based on the grantee’s reported expenditures through 

September 30, 2021. 

In this Program Improvement Plan, the undersigned grantee (Grantee) will:

1. Assess the Grantee’s ERA1 program by identifying (i) policies and practices

recommended by Treasury that the Grantee has already implemented; (ii) whether the

Grantee has adopted any policies or practices that Treasury has discouraged; and (iii)

key obstacles to delivering ERA assistance to eligible households in the Grantee’s

jurisdiction;

2. Document actions the Grantee will take to improve program performance; and

3. Project the Grantee’s ERA1 expenditures through February 2022.

1. Assess the Grantee’s ERA1 Program

A. Identify policies and practices implemented by the Grantee

Please indicate which of the following recommended policies or practices that the Grantee has 

already implemented. Note that the policies and practices that Treasury most strongly 

encourages are listed in bold type. 

Application, Accessibility, and Prioritization

The Grantee’s application process: 

 Provides the opportunity to apply in-person 
2

 Provides the opportunity to apply over the phone 

 Provides the opportunity to apply online

 Includes a mobile-friendly option to facilitate submitting an application with a smartphone

 Applies user-friendly website and application design practices

 Partners with community-based organizations, tenant organizations or trusted community 

leaders to provide tenants with application assistance

 Ensures all application methods adopted by the Grantee are equally available and accessible by 

individuals with disabilities 

 Ensures all application methods adopted by the Grantee are available in languages other than

English 

 If so, please list the languages

______________________________________________________

 Prioritizes applications from households at high risk of eviction or facing other immediate 

threats to housing stability 

 Provides applicants a way to check on their application status

Determination of Household Eligibility

The Grantee: 

 Does not create additional eligibility requirements beyond those required by the statute 

 Partners with a neighboring jurisdiction on application policies, program terms and intake

procedures to ensure regional consistency 

 Relies on a tenant’s self-attestation for purposes of determining whether an applicant has 

experienced a qualifying financial hardship (see sample application screen: COVID-19 

Pandemic Impact) 

 Allows for self-attestation to establish that a tenant is at risk of housing instability or 

homelessness (see sample application screen: Risk of Housing Instability or Homelessness) 

 Accepts a self-attestation of income when determining an applicant’s income eligibility

 Has defined a fact-specific proxy for purposes of supporting the determination of applicants’ 

income eligibility (see sample application screen: Income-Fact Specific Proxy) 

 Uses categorical eligibility when available to confirm an applicant’s income eligibility (see 

sample application screen: Income-Categorical Eligibility) 

 Combines self-attestation with other reasonable policies and procedures to document where 

the applicant resides and the applicant’s monthly rent payment in cases where the lease is 

either unwritten or there is no available copy (see application screen: Residence and Monthly 

Rent) 

 Allows tenants of public housing and other federally assisted housing to apply

Eviction Diversion, Housing Stability Services, and Legal Services

The Grantee: 

 Has an eviction-diversion partnership with one or more courts that hear eviction cases from 

the grantee’s jurisdiction

If applicable, check any components of the diversion program: 

 Provides tenants access to an advocate or other legal assistance

 Made available before the filing of an eviction complaint or pleading
3

 Provides alternative(s) to formal court process (e.g., alternative dispute 

resolution) 

 Provides opportunity to apply for ERA and housing stability services

 Participation is mandatory

 Supported by policies that direct parties to apply for ERA before filing and that 

halt the eviction process where an application is initiated

 Court-based or otherwise implemented through formal collaboration with the 

court

 Provides information to judges, magistrates, court clerks, and other relevant court officials and 

sheriffs or law enforcement about the availability of ERA funds for tenant assistance and 

housing stability services and the importance of offering these services as early as possible in, or 

prior to the initiation of, the eviction process

 Works with eviction court(s) to provide information about ERA program assistance to tenants 

and landlords as early in the adjudication process as possible

 Refers ERA applicants to non-profit organizations for legal assistance

 Expends funds to support legal assistance to tenants at risk of eviction 

 Refers ERA applicants to non-profit organizations for housing stability services

 Expends funds on housing stability services provided by community-based and nonprofit 

organizations to keep people housed and meet essential household needs

 Refers ERA applicants to non-profit organizations for culturally and linguistically relevant

housing stability services

 Expends funds to support housing stability services or legal assistance that are culturally and 

linguistically relevant to populations with limited English proficiency

 Provides tenants with information about non-profit organizations that provide housing stability 

services on the ERA website and in the application

 As a condition to receiving ERA funds paid on a tenant’s behalf, requires a landlord’s agreement

not to evict the tenant for nonpayment of rent for 30 to 90 days longer than the period covered 

by the rental assistance

 Requires landlords and utility companies receiving funds for rental or utility payment arrears to 

terminate any debt collection actions and inform credit reporting agencies of the matter’s

resolution 

Marketing and Outreach

The Grantee: 

 Advertises the ERA program in print, television, radio, or online media specifically targeted to 

groups that may experience barriers to accessing ERA resources

 Advertises the ERA program in print, television, radio, or online media in languages other than 

English 

 If so, please list the languages

______________________________________________________

 Includes measures specially targeted to landlords that own or operate fewer than 10 units in 

its program outreach efforts

 Conducts outreach to landlords through landlord and real-estate associations
4 

 Provides funding to community-based organizations, promotoras, tenant organizations, or 

trusted community leaders to support ERA outreach efforts, application assistance or 

navigation services

 Coordinates with other health and social service providers serving low-income communities to 

identify and reach individuals who may qualify for the ERA program 

 Engages utility companies or agencies that administer the Low Income Home Energy Assistance 

Program (LIHEAP) to inform low-income tenants about the ERA program

 Targets its outreach practices based on social vulnerability index scores, risk of evictions, or 

other data-driven measures of housing insecurity

 Markets the ERA program through community institutions such as libraries, public schools, 

grocery stores, community centers, and health clinics

Payments

The Grantee: 

 Makes bundled payment arrangements with landlord or utility providers that serve more than 

10 eligible tenants

 Provides the tenant and landlord notice immediately upon approval of an application and prior 

to payment processing

 Offers electronic payments to tenants and landlords

 On average, makes payments less than two weeks after application approval

Program Design

The Grantee:

 Provides tenants the opportunity to apply and receive funds directly when landlords decline

to participate in the application process

 Collaborates with another ERA grantee to achieve administrative efficiencies or to prevent 

duplication of assistance

 Notifies one or more utility companies about ERA applications in process to secure a payment 

grace period or service restoration for the applicant households

 Will accept technical assistance when offered to strengthen the ERA program

 Has created a publicly viewable data dashboard or program progress report

 Has developed a risk-mitigation plan for fraud

 Protects personally identifiable information (PII) of tenants, including by not collecting Social 

Security numbers
5 

B. Discouraged Practices

In the box below, please identify any practices or policies expressly discouraged by Treasury’s 

FAQ guidance the Grantee believes are warranted for its ERA program and intends to continue. 

Examples include failing to allow tenants to apply directly when landlords do not participate; 

prohibiting applications from residents of federally assisted housing; establishing eligibility 

requirements beyond those required by statute or Treasury’s FAQs; and collecting Social 

Security numbers or other unnecessary personally identifiable information (PII) from applicants. 

At its option, the Grantee may provide further details and explanation under separate cover. 

Discouraged Practices
6 

C. Identify key obstacles

In the boxes below, please identify the key obstacles to increasing the amount of ERA1 funds 

the Grantee expends on assistance to eligible households and increasing the number of 

households served by the Grantee’s ERA1 program on a monthly basis. 

Obstacle # 1

Obstacle # 2

Obstacle #3
7 

2. Actions for Program Improvement 

In the boxes below, please list at least three specific actions that the Grantee will take to 

improve the performance of its ERA1 program, including to increase the amount of ERA1 funds 

the Grantee expends on assistance to eligible households and increase the number of 

households served by the Grantee’s ERA1 program on a monthly basis. To the maximum extent 

possible, the Grantee’s improvements should include policies and practices identified in bold in 

Section A above as those that Treasury most strongly encourages.

Improvement Action # 1

Improvement Action # 2

Improvement Action #3

Improvement Action #4

Improvement Action #5
8 

3. Projected ERA1 expenditures

Please provide reasonable monthly projections of the Grantee’s ERA1 program’s expenditures 

and activities over the next four months. 

November 2021

Number of unique households that will be assisted

Amount of assistance to eligible households 

expended

$

Number of applications submitted

December 2021

Number of unique households that will be assisted

Amount of assistance to eligible households 

expended

$

Number of applications submitted

January 2022

Number of unique households that will be assisted

Amount of assistance to eligible households 

expended

$

Number of applications submitted

February 2022

Number of unique households that will be assisted

Amount of assistance to eligible households 

expended

$

Number of applications submitted

Do you anticipate providing rental assistance between November 2021 and February 2022 

funded with a source other than ERA1 (e.g. ERA2, State and Local Fiscal Recovery Funds, other 

funds made available by a state or local entity)?

 Yes

 No

If yes, please describe in the box below the sources of funding other than ERA1 that you 

anticipate will support the Grantee’s provision of rental assistance, and provide a projection for 

the next four months of the number of households that will receive such assistance and the 

amount to be expended. 
9 

Other Funding Sources

Projection

Month* Number of Households Amount

1. , 20 $

2. , 20 $

3. , 20 $

4. , 20 $

*The projection should begin with the first full month following plan submission.
10

Contact Information for Program Administrator:

For questions related to implementation of this plan, please list a program administrator contact: 

Name: ____________________________________

Title: ____________________________________

Email: ____________________________________

Office phone: ____________________________________

Mobile phone: ____________________________________ 

Signature

[ERA GRANTEE]

By:

[Official’s Name] 

[Official’s Title]

Date: , 20

PAPERWORK REDUCTION ACT NOTICE: The information collected will be used for the U.S. Government to determine the 

reallocation of emergency rental assistance funds. The estimated burden associated with this collection of information is 120 

minutes per response. Comments concerning the accuracy of this burden estimate and suggestions for reducing this burden 

should be directed to the Office of Privacy, Transparency and Records, Department of the Treasury, 1500 Pennsylvania Ave., 

N.W., Washington, D.C. 20220. DO NOT send the form to this address. An agency may not conduct or sponsor, and a person is

not required to respond to, a collection of information unless it displays a valid control number assigned by OMB.

PRIVACY ACT STATEMENT

AUTHORITY: Solicitation of this information is authorized by section 501 of division N of the Consolidated Appropriations Act, 

2021 (the “Act”)

PURPOSE: The Act requires Treasury to allocate funds to eligible grantees for the delivery of emergency rental assistance to

eligible households. Eligible grantees include states, local governments, U.S. territories, Tribes or Tribally Designated Housing 

Entities (TDHEs), as applicable, and the Department of Hawaiian Home Lands. Treasury maintains contact information for 

authorized representatives and contact persons of the ERA grantees for the purpose of communicating with ERA grantees 

regarding the administration of their award under the Act. 

ROUTINE USES: The information you furnish may be shared in accordance with the routine uses outlined in the Treasury’s 

system of records notice, Treasury .017 – Correspondence and Contact Information, which can be found at 81 FR 78266 (Nov. 7, 

2016). 

DISCLOSURE: Disclosure of this information is voluntary. However, grantees/recipients that do not disclose contact 

information will be unable to communicate with Treasury on issues related to their obligations under the Act which may affect 

the status of their award.