EXECUTIVE OFFICE

600 E Boulevard Ave Dept 325 | Bismarck ND 58505-0250 | 701.328.2538 | 711 (TTY)

www.nd.gov/dhs

DATE: December 3, 2021 (revised January 19, 2022)

TO: Deputy Assistant Secretary Noel Poyo

U.S. Department of Treasury

Delivered via Upload to Treasury Portal

FROM: Jessica Thomasson, Executive Policy Director

ND Department of Human Services

RE: Response to Request for Feedback – North Dakota HAF Plan (HAFP-0110)

This memo is being submitted in response to the request for additional information related to North 

Dakota’s Housing Assistance Fund Plan (HAFP-0110). The plan responses have been updated in the 

portal as noted below.

Completeness

Your plan lists Christopher Jones as the Authorized Official, while the original application for HAF 

payments was signed by Jessica Thomasson. To ensure prompt payment upon approval, the Authorized

Official needs to be the same as the signatory on the original application for HAF payments. If you need

to establish a new authorized representative for HAF payments, please submit a request by email to

HAF@treasury.gov.

Chris Jones is the authorized official who typically signs documents on behalf of the Department 

of Human Services. Jessica Thomasson is the person authorized to prepare and submit 

documents for HAF. Chris will not be accessing the Treasury portal. We will reach out to the 

Treasury Help Desk to make sure appropriate authorizing officials are listed in the Treasury 

system. 

Homeowner Needs and Community Engagement

Data

In two places (delinquency data and property tax/utility data) you have referenced the narrative 

version of your HAF plan. Could you please upload this narrative with your resubmission?

I will attempt to re-upload; the document was included with the first submission. I will verify 

that file size is not an issue with re-submission.

 Please explain how the plan targeting and outreach reflect the data referenced in your plan.
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U.S. Census Bureau data was paired with mortgage servicer data, and utility and property tax 

delinquency data. This data was the foundation to measure the number of homeowners 

financially impacted by the ongoing pandemic. The majority of homeowners that fall within the 

income limits have mortgages serviced in-state, which will expedite administration of HAF funds 

to reinstate mortgage payments and provide future payments to ensure financial stability and 

housing security. 

Where applicable through internal reporting systems, minorities and households with the lowest 

incomes will be targeted first in outreach efforts to enroll them and deliver the assistance they 

need. 

Through the administration of the Emergency Rental Assistance, the ND Dept. of Human Services 

streamlined the application and enrollment process for residents and utility companies. Housing 

facilitators have been hired throughout the state to assist participating households in navigating 

any housing challenges they are experiencing. Partnerships with community agencies provide 

application counseling services so households who do not have the internet access or who may 

otherwise struggle to complete their application can successfully apply. 

It will be a challenge to educate households who do not self-identify as qualifying for HAF that 

assistance is available. Informal networks have been developed in rural communities and with 

minority communities that foster open dialog to reach every North Dakotan that needs 

assistance and prioritize households that have experienced the most hardship first.

Community Engagement and Public Participation

Your plan did not indicate input from any service provider or community organization that as a 

primary purpose addressesthe impact of housing discrimination in one part of your application but

not in others. Can you confirm that this is correct? If not, can you explain how the program is

confident in its ability to reach targeted populations without engaging such organizationsin planning

and implementation?

Community action agencies, housing authorities and one-on-one consultation has taken 

place in the development of the HAF plan and will continue throughout the implementation 

process. These entities are actively involved in outreach and enrollment efforts for the states’ 

emergency rental assistance program. Their partnerships will be critical in reaching impacted 

households including minorities and those experiencing housing cost-burdens.

It is important to note that the ND Dept. of Human Services has long-standing relationships 

with service providers and community agencies across the state, and everyone is focused on 

providing immediate assistance to relieve economic instability and provide the on-going 

services households need to remain in their homes and be able to move forward from 

hardships.

Please describe any coordination you intend with Tribes or Tribal entities.
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Our goal with the program is to ensure maximum access for all North Dakota residents who need 

assistance stabilizing their homeownership situation. The North Dakota HAF program is open to 

both tribal members and non-tribal members, regardless of where their home is located. We are 

making efforts to stay connected with leadership of each tribal housing authority as they are the 

agencies designated to delivery housing related services on behalf of each tribal nation.

Please provide an update indicating any public comments you have received since you 

submitted your HAF Plan, from which organization you received any such comment, and 

whether you have responded to the comments.

The majority of the comments received were inquires asking when HAF would be 

available to reinstate mortgages, utilities and property taxes. 

Ongoing Assessment of Homeowner Need

 No questions

Program Design

Please explain how the sources of data listed in the section on Homeowner Needs informed the

Program Design Elements included in your plan.

Data was collected for local and national servicers to determine how many income qualified 

homeowners were impacted by the pandemic. Additional information was gathered from utility 

companies and county auditors to further understand how many households were delinquent. 

This information was combined with U.S. Census Bureau data and Federal Home Loan Bank of 

Atlanta data to identify the threshold of North Dakotans that may have experienced hardships 

prior to the pandemic and the number of homeowners with mortgages that are delinquent or 

in forebearance.

Funding levels for each program were designed based on the total number of households within 

the data samples experiencing mortgage distress, the average monthly payment and the total 

payments for one-year. 

Will there be a method in your HAF program, early in the process of engaging with a household, 

to evaluate immediate threats to the housing stability of applicants, which may need to be 

addressed under an expedited or prioritized timeline (e.g. HOA liens, tax delinquencies, utility 

shut off)?

Yes. Early in the initial application process we ask for a comprehensive summary of needs and 

issues facing the homeowner. Our system establishes a processing preference for imminent 

risks of instability (ex. utility shutoff, dates indicating further action on foreclosure or tax 

proceedings, etc). In addition to prioritized processing, we also connect these households with 

housing facilitators who work with them to make a plan for how to address the immediate 

crisis they are facing while at the same time working toward a new post-crisis normal.
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Please confirm your exclusion of reverse mortgages and explain what steps you have taken to 

assess the needs of homeowners with this type of mortgage. Please summarize any community 

feedback or data on which you have based this decision.

For impacted homeowners who have reverse mortgages, our plan will reinstate past due 

property taxes and insurance to ensure housing stability. 

Please describe how your program will utilize housing counselors or legal servicesto assist 

homeownersin evaluating loss mitigation options available for their mortgage. Your description 

should include: whether your program will connect homeowners with housing counseling or legal 

services early in the process and the role housing counseling or legal services providers will play in 

supporting homeowners’ efforts at engaging in loss mitigation.

ND Dept. of Human Services is contracting with community agencies to provide application 

counseling services so that households that do not have internet access or who may 

otherwise struggle to complete their application can successfully apply for HAF. Housing 

facilitator services are offered to assist participating households navigate other housing 

challenges they may be experiencing due to the pandemic or may be ongoing issues 

creating economic or housing instability. This work is supplemented with financial planning 

and other community programs and resources that promote long-term financial stability.

We recognize that each homeowner’s situation is unique. For applications that are 

particularly complex, and/or situations where a homeowner is at imminent risk of housing 

loss, the program case review team will make a connection to a contracted housing 

counselor / housing facilitator very early in the process (i.e., as soon as the risk is 

identified). Their work happens in parallel with the review of the application for payment 

eligibility. Also of note, while we do not require that 100% of our applicants work with a 

housing counselor, we do make the service available to 100% of people who participate in 

the program.

In situations where the HAF assistance includes or will be limited to payments for mortgage 

reinstatement, please explain whether and how your will assess whether a similar or more 

appropriate alternative loss mitigation option is available through the servicer.

As part of the application we will ask if the homeowner has been offered other loss 

mitigation options by their servicer. Throughout the application process we work to 

ensure that duplication of benefits does not occur; however, in North Dakota, HAF is 

NOT requiring that a homeowner utilize another option that may be available to 

them BEFORE coming to HAF.

How will your program leverage resources available through a loss mitigation process to benefit 

eligible homeowners and how will your program avoid using HAF funds in ways that duplicate 

relief that available loss mitigation options might provide?
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ND and its housing counseling partners will work with loan servicers to determine loss 

mitigation options for homeowners that could create sustainable monthly payments or allow 

for sale of homes that could be better options than HAF. For ND HAF reinstatement and 

payment assistance will likely be the best options for homeowners with other loss mitigation 

options through the servicers possibly being the option to create sustainable payments.

Please explain what steps, if any, your program will take to assist the homeownerin determining 

whether a HAF-resolution will result in a sustainable monthly payment?

The housing facilitators and housing counselors working with the applicants will utilize 

thresholds established by ND Housing Finance Agency when assessing the financial 

sustainability of ongoing housing obligations. This assessment of housing stability will also 

include the option of identifying alternative housing (i.e., selling the home). A homeowner will 

have overlapping considerations that factor in to their decision making, including the condition 

of their home, their earning potential and regularity of projected income, their family’s health 

status, etc. Our overarching goal is long term housing stability, which includes protection and 

maintenance of the applicant’s credit (by avoiding future foreclosures/delinquencies).

In addition to the numerical analysis described above, to help facilitate this conversation we will 

also include a question on our application for assistance that asks if the homeowner will be able 

to make their normal mortgage payment after receiving assistance. If the answer is no, the 

application will be flagged and referred to a housing counselor for follow up discussion. 

Our intent would be to make sure that the homeowner has evaluated their options before 

proceeding with HAF assistance. For some households, other loss mitigation options should 

perhaps be considered before proceeding with HAF payment of past due/forbearance amounts. 

In other cases, the more immediate resolution provided by HAF, along with access to a limited 

number of prospective payments, may be the most prudent course.

Are you anticipating increased winter home energy costs and their potential impact on the 

homeownersthat HAF will serve?

North Dakota leverages numerous federal and state winter heating programs that are 

already being promoted to income qualified households. Additionally, utility companies 

are actively communicating with customers, encouraging them to apply for assistance as

energy costs are anticipated to increase this winter. 

Based on the information received on utility delinquencies, the HAF program budget was 

developed to acknowledge needs related to utility assistance. North Dakota’s goal is to 

route applicants to the most appropriate source of utility assistance, based on their 

needs, and on fund availability. 

The Department of Human Services administers the emergency rent and homeowner 

assistance programs, as well as the regular and COVID-funded Low Income Home Energy 
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Assistance Program; the department is working on a combined marketing effort for 

utility assistance options. 

Your programsset $40,000 as the maximum amount of assistance per homeowner. Please 

explain how you determined this amount will be sufficient to resolve housing-related 

delinquencies and whether the cap will be sufficient in areas with higher housing costs?

This was based on the highest single payment known to us tempered by the average 

payments we gathered from NDHFA and other servicers information.

Please provide an overview of your Home Repair Program’s policies and procedures and steps, 

including measuresto ensure quality control, and address the risk of fraud.

ND’s HAF Home Repair program will borrow from HUD housing rehab operating practices 

where practical. The homeowner will, upon application, indicate their biggest concerns 

relative to the condition of their home. The application will guide them through a selfassessed scope of work by asking questions about each of the core systems that are eligible 

for inclusion in a HAF home repair project. During application review, the case reviewer will 

assess level of need as defined by the program and, if indicated, will flag the application for 

further processing either as high, medium or low priority relative to their home repair needs.

After initial review, the homeowner will be asked for further information, including 

information related to project readiness. This will include information related to availability 

of contractors in their area. Given the large distances that the ND HAF program covers, we 

will ask the homeowner to submit pictures to help communicate current conditions, until 

such time as an on-site visit is scheduled.

ND HAF will contract with specialized home repair case reviewers whose focus will be to 

establish a formal scope of work for each HAF Home repair project and to identify additional 

funding sources to help further support the home repair work needed (ex. LIHEAP for 

weatherization, Medicaid for disability-related modifications). They will work with incommunity partners to facilitate walk throughs and inspections of each property as needed. 

When accessibility improvements are included as an identified homeowner need, the 

program will include review/assessment by individuals who can appropriately assess and 

define the scope that would be needed to accomplish the desired outcome. 

ND HAF will, through ND Housing Finance Agency and the Department of Human Services, 

offer training and support to these case reviewers to ensure appropriate cross-program 

subject matter knowledge. 

All payments for home repair projects will be made directly to contractors upon verification 

that work has met pre-defined milestones and/or been completed. Scopes of work will be 

drafted to align with generally accepted practices as outlined in state or local building codes. 

Each applicant’s case file will include documentation (written and photographic) related to 

various project milestones described above.
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Eligibility

No questions.

Outreach

Please explain how the program will target outreach and provide access to homeowners with 

limited English proficiency.

The program will ensure that base information is available in English, French and Spanish, 

with additional translation and interpretation available as needed. Relative to outreach, the 

program has established contracts with several community-based organizations who have 

deep and authentic connections to communities of people most likely to have limited English 

proficiency. 

Our experience suggests that personal connection is more effective than formal marketing in 

engaging individuals whose experience and/or circumstances cause them to feel marginalized 

and/or disconnected from traditional mainstream resources. We will continue to recruit and 

support additional organizations as advisors and outreach partners in this effort throughout 

the life of the program. This work will only truly be successful with ongoing, grass-roots 

efforts to connect.

Please explain how the program will provide culturally relevant marketing.

All of our marketing efforts will be developed with representation in mind. The goal of our 

programmatic marketing is to establish affinity – to help the viewer/consumer of the content 

“see themselves” in the messaging. 

Our language is intended to normalize the idea that everyone struggles from time to time, and 

that seeking assistance can help your family stabilize and be ready for whatever the future 

holds. We believe this is a universally appropriate message and work hard to assure that any 

imagery/methods we use support the campaign’s underlying goal of establishing affinity.

Prioritization

If your program intends to serve households who are over the 100% AMI threshold, how will your

program prioritize Socially Disadvantaged Individuals (SDIs)? Please also provide the specific definition

of SDIs that North Dakota will be using for their HAF program?

The ND HAF program has limited availability to households whose income exceeds 100% AMI 

(i.e., eligible to receive mortgage reinstatement assistance). North Dakota’s definition of a 

“socially disadvantaged individual” will include any homeowner with limited English proficiency, 

who has a disability, and/or is a racial or ethnic minority. 

Performance Goals
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Please explain how you intend to communicate your progress towards performance to the 

public. 

We will work towards having a public facing dashboard on our website to communicate 

core statistics related to program utilization and reach, including number of payments to 

ND households by type of payment with some indicators related to geography as well 

(subject to confidentiality considerations). 

We will take the opportunity presented by HAF to broaden understanding of housing 

stability supports by highlighting the various elements of the HAF program (mortgage 

assistance, tax/insurance assistance, home repairs for habitability and accessibility, 

housing counseling and financial planning for economic wellbeing). Our plan includes 

dollars to measure the impact of housing stability services on overall household 

economic well being. Our sincere hope is that we are also able to communicate how 

investments in housing stability have benefits that go beyond housing.

Please indicate which three metrics will serve as the best indicators of the success of your 

program. 

1. Number of borrowers reinstated to a current mortgage status

2. Geographic distribution of assistance

3. Housing stability retained as a result of stabilization supports (home repair, housing 

counseling) 

Please indicate whether you intend to disaggregate metrics by income, race, gender, etc.

Yes. All program metrics will be disaggregated by income, race, gender and geography.

Please consider including as an additional metric the number of homeowners

assisted/foreclosures prevented solely through counseling or legal services without payment of 

HAF funds to resolve the homeowner’s defaults or delinquencies.

We will track this in the system and will include the as part of our report-out related to 

stability supports.

Your performance chart indicates that you expect to assist 200 homeownersthrough the

Home Repair Program. However, given that the maximum amount of Home Repair assistance

is $30,000, assisting 200 homeowners would result in disbursements no greater than

$6,000,000, less than the $10,000,000 budgeted for this program. Do you anticipate assisting

more than 200 homeowners within this program, and if not, do you plan to reduce the

allocation of the Home Repair Program in favor of programs with greater demand? 

Volume of home repair assistance will depend not only on applications/need but also on 

availability of resources in community to complete the required work. If our experience 

indicates greater demand for mortgage reinstatement, for example, we will adjust allocation 

of funds to accommodate that need. Our program goal is to stabilize the housing situation of 
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homeowners in our state; we are committed to monitoring program utilization to align 

resources as demand indicates. 

Readiness 

In your application, you noted that some key operational components needed to implement and govern

the HAF program were still in development. Please update us on your progress in relation to:

o Hiring additionalstaff

o Information technology system updates

o Developing internal policies and procedures

We have 20 trained case reviewers currently working with emergency rent assistance. Their skill 

set will translate to the front-end eligibility determinations needed for HAF. In December/

January we will onboard staff who will develop expertise specific to HAF, including knowledge 

relevant to mortgage servicing, costs/fees associated with homeownership, and home repairs.

We are working to add HAF functionality to the base system ND implemented to support 

emergency rental assistance. The anticipated implementation timeline projects that online 

applications will be available by January 15, 2022 with full system implementation by mid-March 

2022.

Internal policies and procedures will be further refined during the system requirements process in 

December and January to assure alignment between documents.

Is your program prepared to launch upon approval and, if not, by what date will you be ready to launch

following approval?

We anticipate being ready to begin accepting and adjudicating applications by January 15, 

2022. This includes readiness of marketing and outreach materials associated with the go live.

Please provide updated information about your progress in spending the initial 10% payment from

your jurisdiction’s full allocation and the status of any pilot assistance already offered or made

available to homeowners.

ND has been planning for launch but has not yet expended funds. In 2021 Q4 we will be 

obligating some of the funds associated with program infrastructure, including the technology 

platform and outreach partnerships. 

Budget 

According to the HAF Guidance, Administrative Expenses may not exceed 15% of overall allocation, or

$7,500,000 for North Dakota. Your plan indicates an Administrative Expense budget of $7,508,000

exceeds the program cap by $8,000. Please revise your budget to reflect the maximum allocation

amount.
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We have revised the Administrative Expense budget line to $7,500,000.

According to HAF Guidance, 5% of your HAF allocation may be used to cover counseling or education

efforts by housing counseling agencies approved by HUD or a Tribal government, or legal services. Your

plan indicates a Counseling or Legal services Expense budget of $2,509,200 which exceeds 5% of your

allocation ($2,500,000). Please revise your budget to reflect the maximum allocation amount. Please

note, that to the extent that counseling services from legal services provider is providing services

related to planning, community engagement, needs assessment, or administrative expenses, these

amounts may count towards the 15% limit on Administrative Expenses.

We will revise the Housing Counseling related budget line to $2,500,000.