Lead-Based Paint Compliance for COC Grantees, March 2017
This message is sent to COC Primary Contacts for the Fort Worth HUD Office:
Recipients of funds under the COC are responsible for ensuring compliance with the program requirements to include the Lead-Based Paint provisions at 24 CFR Part 35. In order to assist your COC members in complying with these requirements we have compiled a list of resources that you and your members should find useful.
There are numerous tools available to assist COCs in achieving compliant and protecting their clients from lead paint hazards in pre-1978 units.
One tool is the Lead Rule Compliance Advisor located at: https://portalapps.hud.gov/CORVID/HUDLBPAdvisor/welcome2.html
This Advisor was designed to present the requirements of the Lead Safe Housing Rule (LSHR). By analyzing your responses to a short number of questions, the Advisor generates a report of project-specific requirements that can be saved on your computer in a word-processing program or printed for the file. Along the way, the Advisor provides links to related resources including a glossary, related regulations, guidance, and sample forms used by many programs and field staff to implement the LSHR’s requirements. By using the Advisor, HUD field staff will be better able to provide accurate and consistent guidance to HUD grantees and program participants, and to monitor their lead-related activities.
COC staff conducting housing inspections must be able to document that they have been trained in how to properly conduct unit inspections. When the units being inspected were constructed prior to 1978 the staff member must also demonstrate that they have completed training in how to complete a Visual Assessment of paint. Visual Assessment training can be found here: https://www.hud.gov/offices/lead/training/visualassessment/h00101.htm
Information on the Lead-Based Paint Disclosure Rule and its documentation requirements can be found here: https://portal.hud.gov/hudportal/HUD?src=/program_offices/healthy_homes/enforcement/disclosure
Copies of HUD’s monitoring checklists for CPD programs to include COC and lead-based paint can be found here: https://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/handbooks/cpd/6509.2
Making It Work slides and modules https://www.hudexchange.info/resources/documents/MakingItWorkModules.pdf
Making It Work Reference Manual https://www.hudexchange.info/resources/documents/MakingItWorkReferenceManual.pdf
Making It Work Sample Forms https://www.hudexchange.info/resources/documents/MakingItWorkSampleForms.pdf
Summary of the Lead-Based Paint requirements by activity: https://www.hudexchange.info/resources/documents/Summary-of-Lead-Based-Paint-Requirements-By-Activity.pdf (A,L,SS,O under Subpart K is Acquisition, Leasing, Supportive Services, Operating)
Lead Requirements Worksheet https://www.hudexchange.info/resources/documents/LeadRequirementsWorksheet.pdf
HUD Secure Systems, February 2017
HUD officials are reminding grantees to be vigilant with security and management controls related to HUD Secure Systems, including the internet version of the Line of Credit Control System, or, “eLOCCS”. Grantees are reminded to: adhere to the rules of behavior; follow security policies; never share passwords; and, maintain up-to-date accounts for Users and Approving Officials. As a supplement to the resources available on the HUD website, the Fort Worth Field Office has provided the following guidance:
Rules of Behavior for HUD Systems_Jan25_2017
REAC PasswdReset_April_2016 and other facts
eLOCCS Getting Started Guide_June 2014
eLOCCS Registration Guide 2014-06June_2014
Notary Language NEWLOCCS Access Form 27054
Instructions for Recertification in eLOCCS
HQ Dec 2014 Registering for eLOCCS Step by Step Guide
WASS REQUEST INSTRUCTIONS – USER UPGRADES DOWNGRADES-9-4-2012
User Log on_eLOCCS
Homelessness Definition, January 2013
To assist recipients and subrecipients understand the updated definition of homeless, and administer their programs in compliance with the amended regulations, HUD is developing guidance and training materials. The following materials are currently available:
- Determining Homeless and At-Risk Status, Income and Disability Webinar – This webinar provides a comprehensive introduction to HUD’s Homeless Definition Final rule. After reviewing this webinar, viewers should be able to apply the criteria under the homeless definition and understand the basic documentation requirements.
- At-a-Glance – Criteria and Recordkeeping Requirements for Definition of Homeless– This two-page document, to be posted on the HRE shortly and attached to this listserv, provides a high-level overview of the criteria for each category of homelessness (page 1) as well as the corresponding recordkeeping requirements for each category (page 2). This document does not contain the same level of detail that can be found in the regulation.
- At-a-Glance – Criteria for Definition of At Risk of Homelessness– This one-page document, to be posted on the HRE shortly and attached to this listserv, provides a high-level overview of the criteria for each category of at risk of homelessness. This document applies to recipients of Emergency Solutions Grants funds only. This document does not contain the same level of detail that can be found in the regulation.
HUD is continuing to prepare additional documents to create a comprehensive library of guidance documents and training materials on the definition of homeless. The following materials are anticipated in the near future:
- Notice on Limitation on Use of Funds to Serve Persons Defined as Homeless Under Other Federal Laws-This Notice provides guidance to Continuums of Care (CoCs) and recipients of Supportive Housing Program (SHP) and Shelter Plus Care (S+C) program competitive grant funds in FY2011, regarding the limitations imposed in Section 422(j) of the McKinney-Vento Act, as amended by the HEARTH Act. This Notice provides further clarification on information in the Notice of Funding Availability (NOFA) Questions and Answers: A Supplement to the FY2011 CoC Homeless Assistance NOFA and Application. The subject Notice is only applicable to those recipients whose approved FY2011 applications (new or renewal) proposed to serve families with children and/or unaccompanied youth.
- Recordkeeping Requirements for Homeless, At Risk of Homelessness, Income, and Disability Webinar – This webinar will provide a comprehensive introduction to the recordkeeping requirements established in HUD’s Homeless Definition Final rule.
- Determining and Documenting Homeless and At-Risk Status, Income, and Disability User Guide-this document will assist readers in understanding the definition of homeless, at risk of homelessness, income, and disability, as well as provide templates and tools to assist case managers and intake workers document homeless status, at risk of homeless status, income, and disability status.
- Frequently Asked Questions-this document will provide answers to frequently asked questions that are being received, and answered, through the Help Desk. At the end of this listserv, SNAPS will provide a few of the frequently asked questions, along with the answers, that are being received, and their answers, to assist readers until this document is posted.
HUD appreciates your patience as these are being completed – many of your questions will be answered once these documents are published.
For questions on the requirements set forth in this regulation, please visit the Virtual Help Desk on the HUD HRE. HUD has taken great care to anticipate questions and include as much detail in the regulations and notice as possible. Therefore, please make sure to read both documents, in their entirety, prior to submitting a question to the Help Desk, as this will reduce the duplicative questions and responses and increase the response time for questions that are not addressed in the regulation.
What Questions Has HUD Received On the Homeless Definition?
HUD has received many questions on the definition. Below are a few of the most frequently asked questions and the response we have provided. Please remember to submit questions that you may have to the Virtual Help Desk on the HRE located at: http://www.hudhre.info/index.cfm?do=viewHelpdesk. Select “CoC Policy” under the program/system dropdown and “Homeless Definition” under the Topic dropdown to be routed most quickly to the appropriate person who can answer your question.
Is an individual or family who qualifies as homeless under Category 2 (imminent risk of homelessness) or Category 3 (homeless under other federal statutes) eligible for permanent supportive housing under the SHP or S+C program?
While persons who meet the criteria of Category 2 or Category 3 of the homeless definition are defined as homeless, they are not eligible for permanent supportive housing through the SHP or S+C programs because they are not coming from the streets, emergency shelter, safe havens or transitional housing as required in the FY 2011 NOFA. All permanent housing projects funded in the FY 2011 CoC Competition must continue to abide by the limitation on permanent supportive housing set forth in the NOFA in Section III.E.2.d(3).
My SHP/S+C project received funding in FY 2011 CoC Competition and has an operating start date of January 1, 2011. Since the definition does not go into effect until January 4, 2011 can I use the new definition in my project?
SHP and S+C projects that received funding in FY2011 CoC Competition must use the revised definition when administering their projects. The definition published in the Federal Register on December 5, 2011 applies to all SHP and S+C projects funded in the FY 2011 CoC Competition, including those with an operating start date between January 1, 2012 and January 3, 2012.
Are SHP and S+C projects funded in the FY 2011 CoC Competition expected to use the amended definition ofchronically homeless that was published in the amendments to the Consolidated Plan rule on December 5, 2011 in the Federal Register?
No, the amended definition of chronically homeless does not apply to projects funded in the FY 2011 CoC Competition. Projects funded in the FY 2011 CoC Competition should continue to use the definition of chronically homeless found in Section I.D.3 of the 2011 Continuum of Care NOFA.