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Home My WebLink AboutFINAL August 2018 FMCoC Bylaws1 (Revised Version approved August 28, 2018) FRESNO MADERA CONTINUUM OF CARE BYLAWS Article I. Name & Purpose Section 1. Name. The name of the organization shall be Fresno Madera Continuum of Care (FMCoC). Section 2. Purpose. The FMCoC is organized, meeting the requirements of the United States Department of Housing and Urban Development (HUD), to provide a comprehensive coordinated homeless housing and services delivery system called a Continuum of Care (CoC). The CoC assists homeless persons to make the critical transition from homelessness to independent or supportive permanent housing; accessing education, health and mental health services, employment training, and life skills development. We are dedicated to increasing community awareness of homeless people and their problems; and the development and implementation of strategies to create permanent solutions to homelessness in the community. The fundamental components of a Continuum of Care are to facilitate the coordinated effort dedicated to ending homelessness and work of Fresno & Madera’s regional 10-year plans to end homelessness, through: • Outreach – efforts to educate and engage the community regarding available services or service locations. Including the process of building a personal connection that may play a role in helping a person improve his/her health status, housing situation, or social support network. • Coordinated Entry – centralized process designed to coordinate intake, assessment, and provision of referrals in order to better match individuals with services. • Homeless Prevention Activities - activities or programs designed to prevent the incidence of homelessness. • Rapid Re-Housing – housing focused towards moving homeless people into housing quickly. • Rental Assistance – short-term (up to 3 months), medium-term (for 3 to 24 months), or long-term (longer than 24 months) housing payments in the form of either tenant- based, project-based, or sponsor-based support. 2 (Revised Version approved August 28, 2018) • Transitional Housing – housing, in which all program participants have a signed lease or occupancy agreement to facilitate the movement of homeless individuals/families into permanent housing within 24 months. • Mental Health & Health Services - services designed to improve individual’s health and mental health, and enhance their ability to remain stable, housed, and community- integrated. • Supportive Services - services that assist a client in the transition from the streets or shelters into permanent or permanent supportive housing, and that assist persons with living successfully in housing. • Permanent Housing– community-based housing without a designated length of stay. • Permanent Supportive Housing – housing and services that will allow homeless persons with disabilities to live as independently as possible. Section 3. Responsibilities. The responsibilities of the FMCoC include the following: Operating, Coordinating and Overseeing the CoC • Develop, follow, and annually update this governing charter/policies and procedures. • Implement FMCoC’s 10-year Plan to End Homelessness. • In consultation with recipients of ESG funds within the CoC, establish and consistently follow written standards for providing CoC assistance. • Monitor performance of CoC and ESG recipients and subrecipients. • In consultation with CoC Program and ESG recipients and subrecipients, develop and implement performance measures appropriate to the CoC’s homeless populations and program types. • Evaluate the outcomes of projects funded under ESG and CoC programs. • Report the outcomes of ESG and CoC projects to HUD annually. • Work with underperforming programs to improve outcomes and, if necessary, take action against ESG and CoC projects that continue to perform poorly. • In consultation with recipients of ESG funds within the CoC, plan, establish and operate a centralized or coordinated assessment system that complies with HUD’s requirements and VAWA restrictions regarding comprehensive assessments and referrals. • Identify homeless housing and service programs that are best practices, which can be adapted and implemented in the CoC. Designating and Operating an HMIS 3 (Revised Version approved August 28, 2018) • Designate a single HMIS for FMCoC and an eligible applicant to serve as the CoC's HMIS lead agency. • Review, revise, and approve a CoC HMIS data privacy plan, data security plan, and data quality plan. • Ensure that the HMIS is administered in compliance with HUD requirements. • Ensure consistent participation by HUD Homeless Assistance Grants projects in the HMIS, and actively encourage non-HUD funded programs to participate. • Ensure compliance with VAWA and required HMIS-parallel data collection by domestic violence providers maintain appropriate, isolated data, and report congregate information as required and allowed within law. CoC Planning • Create and carry out a plan to address gaps in homeless services identified based on data collected annually in the Point in Time count, and to coordinate the implementation of a housing and service system that meets the needs of homeless individuals and families. • Plan for and conduct an annual Point-in-Time count of sheltered homeless persons, including a housing inventory of shelters, transitional housing, and permanent housing reserved for homeless individuals and families, as HUD requires. • Plan for and conduct, at least biennially (every other year), a Point-in-Time count of unsheltered homeless persons within the FMCoC that meets HUD requirements, including a housing inventory of shelters, transitional housing, and permanent housing reserved for homeless persons, in general, and chronically homeless persons and veterans, specifically, as HUD requires. • Conduct an annual gaps analysis of the needs of homeless people, as compared to available housing and services within the FMCoC. • Provide information required to complete the Consolidated Plan(s) within the FMCoC. • Consult with State and local government ESG recipients within the FMCoC on the plan for allocating ESG funds and reporting on and evaluating the performance of ESG recipients and subrecipients. 4 (Revised Version approved August 28, 2018) • Encourage and develop public understanding and education on homeless and housing issues. • Provide information and make recommendations on homeless concerns to the County Boards of Supervisors and cities located in the county. • Provide information about and help guide decisions regarding long-range planning and policy formulation to the County Boards of Supervisors and cities located in the county. Preparing an Application for Funds • Coordinate a collaborative process for the development of a CoC Program grant application to HUD. • Establish priorities that align with local needs and federal policies for recommending projects for HUD CoC Program grant funding. • Designate an eligible collaborative applicant to collect and combine the required application information from all applicants. • Approve the final submission of applications in response to the CoC Notice of Funding Availability. 5 (Revised Version approved August 28, 2018) Section 4. Composition of the CoC. While the CoC as a whole is ultimately responsible for satisfying its obligations, it delegates a large amount of the work to the various bodies that comprise its formal structure, including: • General Members • Board of Directors • Collaborative Applicant • HMIS Lead • Committees The roles and responsibilities of these bodies are set forth in greater detail below. Section 5. Bylaws Statement of Purpose. These Bylaws identify the goals, purpose, composition, responsibilities and governance structure of the FMCoC. 6 (Revised Version approved August 28, 2018) Article II. Membership Section 1. General Membership. General Members will include Continuum of Care constituents and representatives from relevant organizations (as defined by Article II, Section 2), including those who are Continuum of Care participants through legitimate consortia recognized by the FMCoC Board as a regional/formal organized group addressing homelessness. General Members will share information; receive notices of CoC activities, trainings, HUD homeless funding; give input as needed; and will be eligible to receive FMCoC participant letters confirming their role in the CoC-coordinated regional efforts. An FMCoC Agency membership application must be completed and submitted. Applicants must pay membership fees as set annually by the FMCoC Board of Directors, adhere to these bylaws, maintain good standing as defined in Article II, Section 7 (Membership Dues), and meet attendance requirements as defined in Article II, Section 8. An agency must designate one (1) primary agency representative and may add one (1) alternate person as a representative with the authority to vote on their behalf in the absence of the primary person. The designated organization representatives will receive FMCoC official Board notices and communications, which may occur verbally or via teleconference, fax, or email. [Section 1a on Associate Membership has been deleted] Section 2. Identity. Members shall be either a member of, or a representative of agencies serving the following Continuum of Care constituents: (a) Nonprofit homeless assistance providers (b) Victim service providers (c) Faith-based organizations (d) Governments (e) Businesses (f) Advocates (g) Public housing agencies (h) School districts (i) County Offices of Education (j) Social service providers (k) Mental health agencies (l) Hospitals (m) Universities (n) Affordable housing developers (o) Law enforcement (p) Organizations that serve veterans and homeless and formerly homeless individuals (q) ESG agency recipients within the FMCoC’s geographical area (r) HMIS lead agency 7 (Revised Version approved August 28, 2018) (s) Homeless or formerly homeless persons In addition to the above requirements, membership should, as much as possible, include representation from organizations or agencies who serve various homeless subpopulations such as: • Persons with chronic substance abuse issues • Persons with HIV/AIDS • Veterans • Persons experiencing chronic homelessness • Families with children • Unaccompanied youth • Persons with serious mental illness • Victims of domestic violence, dating violence, sexual assault, and stalking • Human Trafficking Section 3. Invitation and Enrollment of New Members. New members may enroll throughout the year. The FMCoC will provide public invitations at least annually for new members and conduct outreach to engage representatives from relevant organizations within its geographic area. Section 4. Diversity and Inclusion. The FMCoC is broadly representative of the public and private homeless service sectors, including homeless client/consumer interests. The FMCoC encourages and will invite all members of the community to participate in discussions, committees and working groups. The FMCoC works to ensure a diverse population contributes to CoC deliberations and decision-making, including consumers and community members, as well as representation across diverse gender, ethnic, cultural and geographical identifications. All interested persons are encouraged to attend meetings, provide input and voice concerns. Section 5. Notice. The 12-month calendar of meeting dates, times, and locations shall be posted on the FMCoC website at least one month in advance of the first meeting of the year. An agenda and meeting site confirmation will be posted to the FMCoC website and distributed via e-mail or fax prior to the meeting. Meeting minutes and any supporting documents shall be posted to the FMCoC website and distributed via e-mail or fax following each meeting. Section 6. Voting. Members’ rights to vote shall include, but are not limited to, the right to elect members to the Board of Directors, to recommend submission of applications in the name of the FMCoC, to recommend publication and/or release of information by the FMCoC, and to approve and authorize changes to the bylaws. The affirmative vote of a majority shall be required for the approval of any matter. Voting rights of members shall not be limited to only those rights expressed in this section. The membership of the FMCoC and FMCoC Board of 8 (Revised Version approved August 28, 2018) Directors may elect to delegate any of its voting authority to another entity within the FMCoC at its discretion (see Article V, CoC Committees). Section 7. Membership Dues. General Membership dues serve to demonstrate a level of commitment and credibility to the FMCoC. Membership dues and application of membership shall be submitted each year in January, but no later than the scheduled Annual Planning Meeting. If an agency is represented in the membership by more than one individual, they shall be required to pay only one membership fee (and maintain only one vote by their designated agency rep as indicated on their application). Individual memberships, however, shall only consist of one person. The membership dues shall be set and approved by the Board of Directors and reviewed once a year. Potential Members can make a hardship appeal on an individual basis to the Board, requesting waiver of dues. The Board of Directors may set up an in-kind membership rate which is uniform for those individuals and/or agencies that may not have the ability to pay a cash membership fee. Section 8. Attendance. FMCoC meetings are held monthly and are open to all members and the public. The Annual Planning Meeting calendar will identify the date, time, and place of all monthly meetings. The calendar of meetings will be set by the Board of Directors. a) General Member - A voting member (or their designated Alternate) of the FMCoC cannot miss more than three (3) FMCoC meetings in a calendar year. b) Board of Directors Attendance - A Director shall be dropped from the Board if s/he misses more than three (3) Board meetings in a year. Extreme circumstances for absences may be presented and approved as a non-absence by the Board. Section 9. Alternates and Vacancies. Each Member Agency should designate one person to serve as Primary Agency Representative and one to serve as Alternate Agency Representative. Although an unlimited number of people may attend FMCoC meetings, only the Primary Agency Representative or Alternate Agency Representative (where the Primary Agency Representative is not present) may register their attendance at CoC meetings and vote on CoC business. Each Member Agency is entitled to only one vote, even if both the Primary Agency Representative and the Alternate Agency Representative attend the same meeting. Individuals who have not been designated as the Primary Agency Representative or Alternate Agency Representative may not attend on the Member Agency’s behalf or vote on the Member Agency’s behalf. To verify that meetings are being attended by the correct Representatives, the Chair (or Secretary if the Chair is not present) of each meeting will ask Alternates to state their full name when calling attendance. If a Member Agency wants to change either its Primary Agency Representative or Alternate Agency Representative, the current Primary Agency Representative 9 (Revised Version approved August 28, 2018) must do so in writing 24 hours in advance of any vote or meeting. If the Primary Agency Representative is unavailable because of an emergency, then the agency may be permitted to select a new Primary Representative immediately after receiving permission to do so via a majority vote of the FMCoC or the Board of Directors. When Membership is affected by non- emergency staffing changes, Members will give notice to the Secretary within seven (7) days of the change. Section 10. Quorum. A quorum, defined as 51 percent of the active FMCoC membership, must be present before business can be transacted or motions made or passed. If a quorum is present, then 51 percent of the FMCoC members who are present may conduct all business. When some members must recuse themselves due to a conflict of interest, the quorum will be calculated based on the proportion of non-conflicted member agencies who are present. Section 11. Applicability. All current recipients of ESG funds in the Fresno County / Madera County region are considered to be “CoC-funded agencies” for purposes of this Governance Charter. Except as otherwise specified, all policies described herein shall apply in full force to all such ESG recipients, regardless of whether they receive any CoC funding. Section 12. Special Meetings. Special meetings of the General Membership shall be called upon the request of the Chair or one-third of the Members. Notices of special meetings shall be sent out by the Secretary to the Membership at least 24 hours in advance. Members may attend and record votes at special meetings by phone and/or videoconference. Members may submit votes by e-mail on business raised at a special meeting if the votes are received by the Secretary within a time period to be set by the Chair. The quorum for a special meeting will be calculated based upon the number of member agencies who attend the meeting by any means and/or cast a valid vote by any means. 10 (Revised Version approved August 28, 2018) Article III. Formation of the CoC Board Section 1. Purpose of the Board. The Board of Directors is the final decision-making body of the FMCoC. The Board approves or vetoes all matters related to the FMCoC. Section 2. Officers. The Officers shall comprise the Board. There shall be eleven (11) Officers of the Board consisting of: • Chair • Immediate Past-Chair • Vice Chair • Secretary • Treasurer • Two (2) Officers at Large, at least one of which must be homeless or formerly homeless • The Collaborative Applicant • Representative from the Regional Homeless Planning Committee of Fresno County/ESG Recipient • Representative from the Regional Homeless Planning Committee of the City of Fresno • Representative from the Regional Homeless Planning Committee of Madera County The number is to be an uneven number for the purposes of voting. Section 3. Election. Following the opening of a Board position(s), each potential Board Member will submit an application to the FMCoC membership for review. The FMCoC will discuss the applications at an open meeting. Following that meeting, the FMCoC will have the opportunity to vote electronically by secret ballot. Elections will be held in a staggered manner for the eleven (11) officers. The selection process shall be reviewed at least every five years. Section 4. Term of Office. Officers shall be elected for a term of twenty-four (24) months. Section 5. Number. The Board of Directors shall have not less than eleven (11) Directors and collectively they shall be known as the FMCoC Board of Directors. The number should be uneven and may be changed by amendment of this bylaw, or by repeal of this bylaw and adoption of a new bylaw, as detailed in these bylaws. Section 6. Conflicts of Interest. A conflict of interest is a breach of an obligation that has the effect or intention of advancing one's own interest in a way detrimental to the organization. Conflicts of interest, and even the appearance of a conflict of interest, must be avoided. Directors are to conduct themselves at all times with the highest ethical standards in a manner, which will bear the closest scrutiny. Directors shall report possible conflicts of interest 11 (Revised Version approved August 28, 2018) at such time as reasonably possible after the conflict arises and receive guidance from the Board on the issue, including, if necessary, recusal from participating in discussion or voting on a particular matter in which a conflict of interest exists. For any matter that involves a decision on funding for which a Director is a recipient, that member must recuse him/herself. A Director, employee, agent or consultant of the Board may not: • Participate in or influence discussions or decisions concerning the selection or award of a grant or other financial benefit to an organization that he/she has a financial or other interest in or represents, except for the Board itself • Solicit and/or accept gifts or gratuities by anyone for their personal benefit in excess of minimal value • Engage in any behavior demonstrating an actual conflict of interest or giving the appearance of any such conflict Each FMCoC Board member, employee, agent or consultant of the FMCoC Board must sign a personal conflicts of interest policy to demonstrate that the individual is aware of and agrees to abide by this policy. Section 7. Voting. Each Director receives one vote, and a simple majority vote is required for all business. Section 8. Quorum. A quorum, defined as 51 percent of the Board of Directors, must be present before business can be transacted or motions made or passed. If a quorum is present, then 51 percent of the Board members who are present may conduct all business. When some Board members must recuse themselves due to a conflict of interest, the quorum will be calculated based on the proportion of non-conflicted Board members who are present. Section 9. Notice. Notice of each calendared meeting agenda shall be posted on the website and/or given to each Director, by mail, e-mail, fax, or verbally prior to the meeting. Section 10. Resignation, Termination, and Absences. Resignation from the Board must be in writing and received by the Secretary within seven (7) days of the change. A Director shall be dropped from the Board if s/he misses more than three (3) Board and/or general meetings in a calendar year. If a Director’s designated Alternate is present, it shall not be counted as an unexcused absence for the Director. Extreme circumstances for absences may be presented and approved as a non-absence by the Board of Directors. A Director may be removed for other reasons by a three-fourths vote of the remaining Directors. 12 (Revised Version approved August 28, 2018) Section 11. Special Meetings. Special meetings of the Board shall be called upon the request of the Chair or one-third of the Directors. Notices of special meetings shall be sent out by the Secretary to the Board 24 hours in advance. 13 (Revised Version approved August 28, 2018) Article IV. Duties of the CoC Board Section 1. The Chair. The Chair shall convene regularly scheduled FMCoC and Board of Directors meetings and shall preside or arrange for other members of the Board to preside at each meeting in the following order: Vice-Chair, Secretary, Treasurer, Officer at Large, Regional Representative, and Collaborative Applicant. Section 2. The Vice-Chair. The Vice-Chair will maintain a list of the membership, chairs, and meeting times of each Standing Committee and will ensure that each Standing Committee meets at least as often as required by these Bylaws. Section 3. The Secretary. The Secretary shall be responsible for keeping records of FMCoC and Board actions, including overseeing the taking of minutes at all Board meetings, sending out meeting announcements, distributing copies of minutes and the agenda to each Director, and assuring that all records are maintained. Section 4. The Treasurer. The Treasurer shall give a report at each Board meeting. The Treasurer shall chair the Finance Committee, assist in preparation of the budget, and make financial information available to the Directors and to the public. Section 5. The Officers at Large. The Officers at Large shall assist the other Directors in carrying out their duties. Section 6. The Immediate Past Chair. The Immediate Past Chair shall provide continuity during the transition of the Board of Directors. Section 7. The Representatives. The Regional and Homeless or Formerly Homeless Representatives shall assist with the Point-in-Time Count for their region and participate in the Board of Directors. Section 8. The Collaborative Applicant. The Collaborative Applicant shall be responsible for submitting the Consolidated Application for the CoC Program Competition; planning and administering the biennial unsheltered Point-In-Time count and annual sheltered Point-In-Time count; submitting the Point-In-Time count(s) and the Housing Inventory Chart to HUD in a timely manner; and submitting requests for technical assistance, if appropriate, to HUD or other technical assistance-granting agency. Section 9. The Board as a Whole. It shall be the duty of the Board of Directors to: 1) Perform any and all duties imposed on them collectively or individually by law, or by these bylaws. 14 (Revised Version approved August 28, 2018) 2) Appoint and remove, employ and discharge, and, except as otherwise provided in these bylaws, prescribe the duties and fix the compensation, if any, of all officers, agents, and employees of the Continuum. 3) Supervise all officers, agents, and employees of the organization to assure that their duties are performed properly. 4) Meet at such times and places as required by these bylaws and adhere to attendance requirements (Article II, Section 6). 5) Register their addresses with the secretary of the Continuum, and notices of meetings mailed or emailed to them at such address shall be valid notices thereof. 6) Attend meetings and contribute to informed dialogue on actions the Board of Directors undertakes. 7) Serve on committee(s) as relevant. 8) Participate in the activities of the Board, including the Point-in-Time count, HMIS oversight, strategic planning, advocacy and public education efforts, project and systems performance reviews, and the application processes for CoC homeless Assistance Grants and other funding proposals. 9) Seek input from and report back to the constituency they represent on key issues and strategies and otherwise keep abreast of needs and gaps in the CoC. Section 10. Duty to Hold Meetings. The Board of Directors shall meet at least bimonthly, at an agreed upon time and place set by the Board. The Board of Directors meetings are public and all Members are invited to attend. The schedule of meetings for each calendar year will be posted on the FMCoC website and/or distributed to the CoC membership. 15 (Revised Version approved August 28, 2018) Article V. CoC Committees Section 1. Formation of Committees. The Standing Committees include the Finance Committee, Evaluation Committee, Homeless Management Information System (HMIS) Committee, and Coordinated Assessment Committee. All other committees, subcommittees, and workgroups are considered Ad Hoc Committees and will be convened and dissolved as necessary. The Board Chair appoints the chairs of all standing committees and all ad hoc committees. Each Committee Chair must be an FMCoC Member, but committee members do not need to be FMCoC Members. Section 2. Conduct of Committees. The time for meetings of committees may be established by the workgroup or coincide with bimonthly FMCoC meetings during the designated time. The Board of Directors may also adopt rules and regulations pertaining to the conduct of meetings of committees if deemed necessary or if the practices of those groups are not consistent with the provisions of these bylaws. Committees will develop recommendations, which will be presented at Board of Directors meetings for review and/or revision. All Standing Committees must submit resolutions to the Board of Directors to be placed on the agenda for the next FMCoC meeting at least one week prior to the next scheduled FMCoC meeting. Section 3. Finance Committee. The Treasurer is chair of the Finance Committee (who reports directly to the Board of Directors). The Finance Committee is responsible for the development and review of fiscal procedures, and annual budget with staff and other Board members. The FMCoC must approve the budget, and all expenditures must be within the budget. Any major change in the budget must be approved by the FMCoC or the Board. The fiscal year shall be the calendar year. Annual reports are required to be submitted to the FMCoC showing income, expenditures, and pending income. The financial records of the organization are public information and shall be made available to the membership, Board members and the public. The Finance Committee shall meet at least twice per year unless otherwise resolved by a formal decision of that Committee or of the Board. Section 4. Evaluation Committee. The Evaluation Committee is responsible for the outlining and coordination for evaluation of member agency housing programs, and coordinating the Notice of Funding Availability (NOFA) competition evaluation of applications, by utilizing members of the committee that are not representatives of competing agencies. Additionally, the Evaluation Committee shall ensure ESG providers in Fresno and Madera Counties are not discharging clients into homelessness. The Evaluation Committee shall meet at least quarterly unless otherwise resolved by a formal decision of that Committee or of the Board. Section 5. Homeless Management Information System (HMIS) Committee. The HMIS Committee is responsible for management of data collected and/or published by the FMCoC, the tracking of subpopulations as listed in Article III, Section 4, and the assessment of 16 (Revised Version approved August 28, 2018) member agencies participation. This committee is also responsible for establishing the Regional CoC data collection policies and procedures, as applies to the HMIS, and conducting an annual review and update of (as applicable): the HMIS Governance Charter between the FMCoC and the HMIS Lead; the Standard Operating Procedure HMIS Data Quality Monitoring, which incorporate Privacy, Security, and Data Quality Plans; and the HMIS Policies & Procedures Manual(s), for compliance with HUD requirements and consistency with current HUD and FMCoC goals. The HMIS Lead shall work closely with the HMIS Committee to maintain and operate the FMCoC’s HMIS, submit HMIS-generated reports to HUD such as the AHAR, and otherwise ensure that the HMIS is administered in compliance with all HUD requirements. The HMIS Committee shall meet at least bimonthly unless otherwise resolved by a formal decision of that Committee or of the Board. Section 6. Coordinated Assessment Committee. The Coordinated Assessment Committee organizes and evaluates the effectiveness of Fresno and Madera's Coordinated Assessment/Coordinated Entry process. The Coordinated Assessment Committee has also inherited the work of the Rapid Results Committee and the Outreach Committee. The Coordinated Assessment Committee shall meet at least monthly unless otherwise resolved by a formal decision of that Committee or of the Board. 17 (Revised Version approved August 28, 2018) Article VI. Operations Section 1. Education Policies. All CoC and ESG projects assisting households with children or unaccompanied youth must comply with the requirements of CoC Program Interim Rule 24 CFR §578.23 including ensuring that individuals and families who become or remain homeless are informed of their eligibility for McKinney-Vento educational services. Consistent with the CoC Program Interim Rule 24 CFR §578.23, it is important that all CoC and ESG programs collaborate with local education authorities in identifying and serving families that become homeless. All CoC and ESG programs assisting families with children or unaccompanied youth must: • Take the educational needs of children into account when placing families in housing and will, to the maximum extent practicable, place families with children as close as possible to their school of origin so as not to disrupt such children's education • Inform families with children and unaccompanied youth of their educational rights, including providing written materials, help with enrollment and linkage to McKinney Vento Liaisons as part of intake procedures. • Not require children and unaccompanied youth to enroll in a new school as a condition of receiving services. • Allow parents or the youth (if unaccompanied) to make decisions about school placement. • Not require children and unaccompanied youth to attend after-school or educational programs that would replace/interfere with regular day school or prohibit them from staying enrolled in their original school. • Post notices of student’s rights at each program site that serves homeless children and families in appropriate languages. • Designate staff that will be responsible for ensuring that homeless children and youth in their programs are in school and are receiving all educational services they are entitled to. • Designate staff that will be responsible for coordinating with the CoC, the Department of Social Services, the County Office of Education, the McKinney Vento Coordinator, the McKinney Vento Educational Liaisons, and other mainstream providers as needed. In order to ensure compliance and to assist providers in meeting these requirements, the CoC will provide training on these issues at least annually and will include compliance with these procedures these in their monitoring processes. Section 2. Family Intake and Separation Policies. CoC- and ESG-funded programs may not deny admission to any household on the basis that there is a child under the age of 18, deny admission to any member of the family, or otherwise separate family members, with the following exceptions: 18 (Revised Version approved August 28, 2018) • Projects that serve a limited demographic approved by HUD or HCD will not be required to expand their client base as a result of this policy. The age and gender of a child under age 18 must not be used as a basis for denying any family's admission to a project that receives CoC or ESG funds. The gender and marital status of a parent or parents may also not be used as a basis for denying any family’s admission to a project that receives CoC or ESG funds. The CoC will work closely with providers to ensure that placement efforts are coordinated to avoid involuntary family separation, including referring clients for the most appropriate services and housing to match their needs. A form is available on the CoC website, www.fresnomaderahomeless.org, for any client who believes that they or a family member have experienced involuntary separation to report it to the CoC. Section 3. Unaccompanied and Parenting Youth. In compliance with orders of priority for ESG-funded and CoC-funded housing and services, and using an assessment protocol, the CoC will prioritize housing and services for unaccompanied youth under age 18 and 18 to 24 based on factors such as vulnerability to victimization, length of time homeless, severity of service needs, high risk of continued trauma or harm, unsheltered homelessness history, and lack of access to family and community support networks. Unaccompanied youth under age 18 may be referred to the local child welfare agency; youth over age 18 will be referred to local youth housing/services providers and also will have access to the full range of CoC/ESG resources for which they are eligible. Section 4. Coordination with Local School Districts. All CoC- and ESG-funded programs are required to coordinate with local education authorities and school districts to ensure all children are enrolled in early childhood programs or in school and connected to appropriate educational services in the community and so that children and families at risk of homelessness may be connected to appropriate intervention. Section 5. Domestic Violence Policies. The privacy and safety of families and individuals fleeing domestic violence situations is of utmost concern to the FMCoC. As such, all efforts shall be made to ensure protection of the privacy and safety of domestic violence survivors. Providers of housing and/or services to domestic violence survivors are prohibited from entering client-level data into the HMIS. A comparable database may be used if it is internal and does not compromise the privacy and safety of the client. The location of Domestic Violence housing and/or services shall be private and shall not be made public. 19 (Revised Version approved August 28, 2018) All efforts shall be made to protect the privacy and safety of domestic violence survivors and to uphold client choice by presenting a range of housing and service options. The following procedures are in place to do that. Privacy and Safety Programs which are primarily for survivors of violence are prohibited from contributing client- level data into the HMIS. However, these programs must record client-level data within a comparable internal database and be able to generate aggregate data for inclusion in reports. Non-victim service providers shall protect the privacy of individuals and families who are fleeing, or attempting to flee violence, by not including intake/treatment data in HMIS. The location of Domestic Violence shelters/programs shall not be made public. Staff responsible for coordinated intake/assessment shall receive training on protecting the safety and privacy of individuals who are fleeing or attempting to flee violence. For each program participant who moved to a different Continuum of Care due to imminent threat of further violence under § 578.51(c)(3), the CoC program must retain: 1. Documentation of the original incidence of violence. This may be written observation of the housing or service provider; a letter or other documentation from a victim service provider, social worker, legal assistance provider, pastoral counselor, mental health provider, or other professional from whom the victim has sought assistance; medical or dental records; court records or law enforcement records; or written certification by the program participant to whom the violence occurred or by the head of household. 2. Documentation of the reasonable belief of imminent threat of further violence, which would include threats from a third-party, such as a friend or family member of the perpetrator of the violence. This may be written observation by the housing or service provider; a letter or other documentation from a victim service provider, social worker, legal assistance provider, pastoral counselor, mental health provider, or other professional from whom the victim has sought assistance; current restraining order; recent court order or other court records; law enforcement report or records; communication records from the perpetrator of the violence or family members or friends of the perpetrator of the violence, including emails, voicemails, text messages, and social media posts; or a written certification by the program participant to whom the violence occurred or the head of household. Certification of Homelessness: For victim service providers: 1. An oral statement by the individual or head of household seeking assistance which states: they are fleeing; they have no subsequent residence; and they lack resources. 20 (Revised Version approved August 28, 2018) Statement must be documented by a self-certification or a certification by the intake worker. For non-victim service providers: 1. Oral statement by the individual or head of household seeking assistance that they are fleeing. This statement is documented by a self-certification or by the caseworker. Where the safety of the individual or family is not jeopardized, the oral statement must be verified; and 2. Certification by the individual or head of household that no subsequent residence has been identified; and 3. Self-certification, or other written documentation, that the individual or family lacks the financial resources and support networks to obtain other permanent housing. Emergency Transfer Plans: 1. A tenant who is a victim of domestic violence, dating violence, sexual assault, or stalking, as provided in HUD’s regulations at 24 CFR part 5, subpart L is eligible for an emergency transfer, if: the tenant reasonably believes that there is a threat of imminent harm from further violence if the tenant remains within the same unit. If the tenant is a victim of sexual assault, the tenant may also be eligible to transfer if the sexual assault occurred on the premises within the 90-calendar-day period preceding a request for an emergency transfer. A tenant requesting an emergency transfer must expressly request the transfer in accordance with the procedures described in this plan. The ability to request an emergency transfer is available regardless of sex, gender identity, or sexual orientation and regardless of whether the tenant is in good standing. 2. To request an emergency transfer, the tenant shall notify the CoC’s coordinated entry system by submitting a written request for a transfer to any designated entry point. The CoC will provide reasonable accommodations to this policy for individuals with disabilities. The tenant’s written request for an emergency transfer should include either: (a) a statement expressing that the tenant reasonably believes that there is a threat of imminent harm from further violence if the tenant were to remain in the same dwelling unit assisted under HP’s program; OR (b) a statement that the tenant was a sexual assault victim and that the sexual assault occurred on the premises during the 90- calendar-day period preceding the tenant’s request for an emergency transfer. 3. The CoC cannot guarantee that a transfer request will be approved or how long it will take to process a transfer request. The CoC will, however, act as quickly as possible to move a tenant who is a victim of domestic violence, dating violence, sexual assault, or stalking to another unit, subject to availability and safety of a unit. If a tenant reasonably believes a proposed transfer would not be safe, the tenant may request a transfer to a different unit. If a unit is available, the transferred tenant must agree to 21 (Revised Version approved August 28, 2018) abide by the terms and conditions that govern occupancy in the unit to which the tenant has been transferred. The CoC may be unable to transfer a tenant to a particular unit if the tenant has not or cannot establish eligibility for that unit. If the CoC has no safe and available units for which a tenant who needs an emergency is eligible, the CoC will assist the tenant in identifying other housing providers who may have safe and available units to which the tenant could move. At the tenant’s request, the CoC will also assist tenants in contacting the local organizations offering assistance to victims of domestic violence, dating violence, sexual assault, or stalking that are attached to this plan. 4. Pending processing of the transfer and the actual transfer, if it is approved and occurs, the tenant is urged to take all reasonable precautions to be safe. Tenants who are or have been victims of domestic violence are encouraged to contact the National Domestic Violence Hotline at 1-800-799-7233, or a local domestic violence shelter, for assistance in creating a safety plan. For persons with hearing impairments, that hotline can be accessed by calling 1-800-787-3224 (TTY). Tenants who have been victims of sexual assault may call the Rape, Abuse & Incest National Network’s National Sexual Assault Hotline at 800-656-HOPE, or visit the online hotline at https://ohl.rainn.org/online/. Tenants who are or have been victims of stalking seeking help may visit the National Center for Victims of Crime’s Stalking Resource Center at https://www.victimsofcrime.org/our-programs/stalking-resource-center. 5. The CoC will keep confidential any information that the tenant submits in requesting an emergency transfer, and information about the emergency transfer, unless the tenant gives the CoC written permission to release the information on a time limited basis, or disclosure of the information is required by law or required for use in an eviction proceeding or hearing regarding termination of assistance from the covered program. This includes keeping confidential the new location of the dwelling unit of the tenant, if one is provided, from the person(s) that committed an act(s) of domestic violence, dating violence, sexual assault, or stalking against the tenant. 6. A tenant who is currently living in CoC-funded housing who qualifies for and requests an emergency transfer to avoid domestic violence, dating violence, sexual assault, or stalking will be given the highest priority in the Coordinated Entry System. Because moving a household from one CoC-funded home to another CoC-funded home does not result in a net decrease in the availability of CoC services, giving the highest priority to these emergency requests helps address the emergency nature of the tenant’s needs without materially compromising the ability of other high-vulnerability clients to promptly receive housing opportunities. Section 6. Coordination with Local School Districts. All CoC- and ESG-funded programs are required to coordinate with local education authorities and school districts to ensure all children are enrolled in early childhood programs or in school and connected to 22 (Revised Version approved August 28, 2018) appropriate educational services in the community and so that children and families at risk of homelessness may be connected to appropriate intervention. Section 7. Safeguards for Special Populations. For providers serving special populations, such as survivors of domestic violence, families, seniors, mentally ill and disabled individuals, and veterans, safety and shelter safeguards shall be described in the service provider’s policies and clearly communicated to program participants. The FMCoC is committed to ensuring safe access to shelter, housing and services for survivors of domestic violence and works with local domestic violence providers to ensure safety planning and appropriate referrals. Per the Violence Against Women Reauthorization Act (VAWA) 2013, no survivor will be evicted, or assistance denied or terminated by a CoC-funded program because he/she is a survivor of domestic violence. Nor shall any survivor be denied tenancy or occupancy rights due to adverse factors caused by being a survivor. The CoC has an Emergency Transfer Plan (as required by 24 CFR 5.2005 and 24 CFR 578.99(j)(6)) to protect victims of domestic violence, dating violence, sexual assault or stalking serviced by the CoC. This plan is being implemented through the Coordinated Entry System and all CoC- and ESG-funded agencies and related staff. Agencies will provide emergency transfers for domestic violence survivors receiving rental assistance or otherwise residing in CoC- or ESG-funded units. To exercise their rights under VAWA, a survivor need only to self-certify. Lease provisions will also include protections required under VAWA. Households with children will be prioritized for services based on need, as indicated by factors such as vulnerability to victimization, number of previous homeless episodes, unsheltered homeless, criminal history, and bad credit or rental history. Veterans determined to be ineligible for federal Department of Veterans Affairs services will be eligible for CoC- and ESG- funded resources as appropriate. Providers shall make every effort to ensure that their services are accessible and appropriate for individuals and families with the highest barriers to housing and who are likely to be homeless the longest. Section 8. Coordinated Entry Policies. The CoC has established a Coordinated Entry System in compliance with HCD ESG regulations, 25 CCR 8409; HUD Coordinated Entry Notices CPD-17-01 and CPD-16-11; VAWA Reauthorization Act of 2013; and the CoC Program Interim Rule, 24 CFR Part 578. All CoC- and ESG-funded programs are committed to implementing this system. The Coordinated Entry System promotes comprehensive and coordinated access to assistance regardless of where an individual or family is located in the CoC service area, and uses the VI-SPDAT, a standardized assessment tool that ensures that the community prioritizes assistance for people with the most urgent and severe needs and to those who have been homeless for the longest period of time. Section 9. Participation in HMIS. All CoC- and ESG- funded projects must ensure that data on all persons served and all activities provided under these federally funded programs are 23 (Revised Version approved August 28, 2018) entered into the HMIS, in accordance with HUD's standards on participation, data collection, and reporting under a local HMIS. Victim service providers may use a comparable database, independent from the HMIS. All CoC- and ESG-funded projects must comply with the requirements in the Fresno-Madera CoC HMIS Policies and Procedures Manual. Section 10. Housing First. All CoC- and ESG-funded programs are committed to adopting a Housing First approach and reducing barriers for accessing their services. Section 11. Discharge Policies. The FMCoC shall work with community partners to ensure that individuals discharged from the foster care system, the health care system, the mental health system, and the corrections system are not discharged into homelessness. Section 12. CoC-Wide Anti-Discrimination Policy. The Fresno / Madera Continuum of Care, the agencies funded by the CoC and/or ESG, the CoC’s Coordinated Entry system, and their staff, volunteers, and interns are all committed to complying with all requirements regarding the HUD Equal Access Rule and all other all federal, state and local non-discrimination and privacy laws. Policy CoC and ESG-funded providers shall not discriminate on the basis of any protected characteristic, including race, color, national origin, religion, sex, familial status, disability, or age. CoC-funded housing shall be made available to all otherwise eligible individuals regardless of actual or perceived sexual orientation, gender identity, or marital status. The CoC and CoC agencies will: 1) Ensure equal access to programs for all individuals and their families; 2) Provide housing, services, and/or accommodations in accordance with each client’s gender identity, i.e., people who identify as men will be treated as men, and people who identify as women will be treated as women; and 3) Determine eligibility without regard to actual or perceived sexual orientation, gender identity, or marital status. Procedures to Ensure Equal Access • The CoC will provide training annually (and as needed) to CoC agencies and agency staff regarding the Equal Access Rule and related requirements. • The CoC and CoC agencies will use appropriate, inclusive language in communications, publications, trainings, personnel handbooks and other policy documents that affirms 24 (Revised Version approved August 28, 2018) the CoC’s commitment to serving all eligible clients in adherence with the HUD Equal Access Rule. • Gender identity is not required to match the gender listed on the ID or documents. • Agency intake materials will allow for clients to indicate their legal name and the name they prefer to be called. • CoC agencies will support clients who need assistance in changing gender markers on identification cards or benefit applications. • Clients with prescribed hormones or other medications as part of their gender-affirming healthcare regime will have access to those medications. Procedures to Ensure Privacy • CoC agencies will ensure all staff, volunteers and contractors (a) maintain the confidentiality of a client's legal name and gender at birth, and (b) understand the potential impact that disclosure can have on a client's progress to self-sufficiency. • Agency staff will keep a client's transgender status confidential unless the client gives permission to share this information. Similarly, a client's legal name (when different from the client’s preferred name) will be treated as confidential information. • When possible, CoC agencies will ensure that construction or property rehabilitation includes and promotes privacy and safety in sleeping areas, bathrooms, and showers. • If a CoC program only offers congregate bathrooms or showers, that program will provide an appropriate number of individual stalls (at least one of each) for toilets and shower heads. • Where feasible, CoC agencies will offer individual gender-neutral bathrooms and gender-neutral shower rooms. • Agency staff shall not ask questions or seek information concerning a person's anatomy or medical history beyond elements necessary for the purpose of providing services. • Agency staff will honor the request of an individual for a private space to complete intake and data collection. Procedures to Prevent and Correct Discrimination • CoC agencies will ensure that their staff, volunteers and contractors understand that a client may appear to have a gender or orientation that is different from the way the client identifies. • CoC agencies will take immediate action to resolve inappropriate behavior, harassment, or equal access issues by any person (staff, volunteers, contractors or clients). • Agency staff shall not consider a client or potential client ineligible because their appearance or behavior does not conform to gender stereotypes and will serve all individuals that are eligible for the project/program. • If a client needs to be moved for harassment and safety concerns, agency staff will have a preference to move the client with a bias (e.g. move the individual who is having 25 (Revised Version approved August 28, 2018) concerns towards the person who may not conform to mainstream gender expression/identity.) • Agency staff will honor the request of an individual for accommodations based on their personal safety and privacy concerns, whenever feasible. Staff will not impose artificial requirements on transgender clients to force them to "accommodate" the prejudices of other residents. • Agency staff and clients will use each client's preferred gender and pronoun and support each client’s gender identity. • When discussing levels of risk, agency staff will be alert to and correct any misinformation or inaccurate conclusions that transgender clients threaten the health or safety of other clients solely based on their non-conforming gender identity or expression. Section 13. Written Process for Termination of Assistance. All programs that offer housing assistance to individuals or families funded by the Continuum of Care must provide a written explanation of a tenant’s rights and responsibilities that includes an explanation of program requirements and the consequences and appeal rights should a violation occur. The violation notification must be provided in writing to the participant with an accompanying right to an independent hearing (where the review officer is not directly involved in the program administration and is not subordinate to the person who made the original termination decision) to review the program’s decision to terminate assistance to the recipient. Written notification of the outcome of the hearing/final decision will be provided within thirty (30) days of the conclusion of the hearing. Section 14. Obligations for Programs that are De-Funded or Reallocated. When a project’s funding is reallocated, the agency that was operating that project has certain responsibilities to the rest of the community and HUD, even if that agency is no longer operating any CoC Program- funded projects. Beginning with FY 2017 CoC Program grants, all agencies that wish to continue to receive CoC funding must agree to fulfill these responsibilities if their projects are defunded. These responsibilities, below, apply regardless of whether a project’s funding was voluntarily reallocated, involuntarily reallocated, or denied by HUD as part of the national CoC Program competition. • Finding Housing for Clients Who Exit the Project: all project participants must be notified in writing at least 30 days prior to a project’s closure. The project must plan to ensure project participants do not exit into homelessness, and to identify alternative, permanent housing for them. This includes if the project is closing or reducing its size; changing program models so that current project participants cannot remain in the project; or otherwise transitioning in any way so that at least some project participants must leave the project temporarily or permanently. The agency should seek FMCoC assistance as needed at the earliest opportunity if the agency needs help in securing housing for its clients. 26 (Revised Version approved August 28, 2018) • Available Beds: the project must provide the FMCoC with details about any unused beds or those that are expected to be unfilled as the project winds down so the FMCoC can assess the beds’ appropriateness for interim or bridge housing. The project must work with the FMCoC as much as possible so that they can be used for interim or bridge housing as needed. The project also must provide relevant project details (e.g., changes in available beds, target population, and eligibility criteria; expected dates when these will change; expected closure dates) to the FMCoC’s coordinated entry staff so the project’s bed availability and eligibility information in the coordinated entry system is accurate. • Managing Data for Clients Who Exit the Project and Completing Required Reporting: the project must complete HMIS/comparable database data entry and data clean-up for all project participants, including all persons served over the past project term and who already may have exited the project. A final Annual Performance Report (APR) is due to HUD via the Sage HMIS Repository within 90 days of the project’s CoC Program grant end date. The project must provide the names and contact information of its staff responsible for these activities to the FMCoC’s HMIS Lead/System Administrator; and communicate with them to ensure the project is on track to meet its data entry and reporting tasks and deadlines. • Closing Out the Project’s Finances and CoC Program Grant(s): the project must provide information on estimated unspent funding to the FMCoC within 60 days after the project is aware its funding is or will be reduced; and consult with the FMCoC about alternative, permissible uses. In addition, HUD has a formal close-out process for its grants when a project is completed, terminated, no longer HUD-funded; or when recipients discontinue a project. HUD’s grant closeout requirements are in the CoC Program Interim Rule (24 CFR §578.109) and the Uniform Administrative Requirements (2 CFR §§200.16, 200.343); and the additional requirements that apply, even after close- out (2 CFR §200.344-200.345). • Planning and Communication: the project must communicate its plans to the FMCoC at the earliest opportunity, including at least the basic summary information within 20 days of learning the project has lost its funding. The project must also keep the FMCoC informed about available beds for other possible interim housing uses, and project information for coordinated entry system accuracy (see Available Beds above). In addition, the agency may need to identify alternate uses of any property the project owns or leases if the project will close, reduce its size, or change its program model in such a way that its property needs to change. The agency should determine whether any covenants, use restrictions, or other property conditions apply (e.g., 15- or 20-year use restrictions if the 27 (Revised Version approved August 28, 2018) project received CoC Program or Supportive Housing Program capital funding). The agency should discuss these with the FMCoC and HUD Field Office as needed if it needs assistance. 28 (Revised Version approved August 28, 2018) Article VII. Prioritization Section 1. Referral through Coordinated Entry. Per the CoC and ESG Program Interim Rules, 24 CFR § 578 and 24 CFR §§ 91 and 576 respectively, enrollment info CoC and/or ESG- funded programs shall follow the CoC’s Coordinated Entry Policies and Procedures with respect to assessment prioritization, matching, referral, and placement. The FMCoC Continuum of Care prioritizes chronically homeless individuals and families and has committed to adopting a Housing First approach in CoC/ESG programs. The Housing First approach is characterized by progressive engagement and assistance practices including: 1) Ensuring low-barrier, easily accessible assistance to all people, including, but not limited to, people with no income or income history, and people with active substance abuse or mental health issues; 2) Helping participants quickly identify and resolve barriers to obtaining and maintaining housing; 3) Seeking to quickly resolve the housing crisis before focusing on other non-housing related services; 4) Allowing participants to choose the services and housing that meets their needs, within practical and funding limitations; 5) Connecting participants to appropriate support and services available in the community that foster long-term housing stability; 6) Offering financial assistance and supportive services in a manner which offers a minimum amount of assistance initially, adding more assistance over time if needed to quickly resolve the housing crisis by either ending homelessness, or avoiding an immediate return to literal homelessness or the imminent risk of literal homelessness. The type, duration, and amount of assistance offered shall be based on an individual assessment of the household, and the availability of other resources or support systems to resolve their housing crisis and stabilize them in housing; and 7) Any other practices promoted or required by HUD. 29 (Revised Version approved August 28, 2018) Rapid Rehousing projects serving homeless families with children will strive to place clients into permanent housing within 30 days of entering homelessness and will not screen out families based on criteria that will not impact future housing success. For vulnerable, chronically homeless individuals, the FMCoC uses a standardized Coordinated Entry assessment tool, which identifies those most at risk of dying on the street and will prioritize placement and services for those highest in need. If individuals are not chronically homeless, they will be targeted for the Rapid Rehousing, transitional housing, permanent housing, or income-based housing that they are best matched to. Non-chronically homeless individuals who identify a substance abuse and/or mental health disorder and interest in receiving services for these concerns will be referred to the appropriate residential treatment programs. Comprehensive and coordinated access to assistance will be provided regardless of where an individual or family is located in the CoC service area. Section 2. Order of Priority for CoC-Funded Permanent Supportive Housing. The Fresno / Madera Continuum of Care adopts the order of priority in HUD Notice CPD 16-11: Prioritizing Persons Experiencing Chronic Homelessness and Other Vulnerable Homeless Persons in Permanent Supportive Housing. The full notice is available at: https://www.hudexchange.info/resources/documents/notice- cpd-16-11-prioritizing-persons-experiencing-chronic-homelessness-and-other-vulnerable- homeless-persons-in-psh.pdf As a result of adopting Notice CPD 16-11, all PSH projects funded by the Fresno / Madera CoC that have dedicated or prioritized any beds for the use of people experiencing chronic homelessness will assign those beds based on (a) the length of time in which an individual or family has been homeless, and (b) the severity of the individual or family’s service needs. Likewise, all Fresno / Madera CoC-funded PSH beds that are not dedicated or prioritized for use by people experiencing chronic homelessness will, whenever it is possible to do so in a manner consistent with current grant agreements, assign beds according to the following priority scheme: 1. First Priority: Households with a Disability, Long Periods of Episodic Homelessness, and Severe Service Needs 2. Second Priority: Households with a Disability and Severe Service Needs 3. Third Priority: Households with a Disability coming from Places Not Meant for Human Habitation, Safe Havens, or Emergency Shelters 4. Fourth Priority: Households with a Disability coming from Transitional Housing. 30 (Revised Version approved August 28, 2018) The assignments and priorities discussed above are mandatory for all CoC-funded PSH beds and will be made in collaboration with the Fresno Madera Continuum of Care’s Coordinated Entry System, which will take the above priorities into account when making referrals and conducting case conferences. In some cases, the specific manner in which the Coordinated Entry System will take these priorities into account will include use of the VI-SPDAT, which collects information about the severity of a client’s service needs and the amount of time for which a client has been homeless. Section 3. Eligibility and Priority for CoC-Funded Rapid Re-Housing. Eligibility and priority for rapid re-housing assistance through both the CoC and the ESG program must be determined in compliance with HUD requirements and the standards established by the FMCoC or a committee that the FMCoC has granted authority to make such a determination. The calculation of rental payments must be conducted in a manner that is consistent with HUD requirements. Prioritizing Assistance The FMCoC will use VI-SPDAT Scores to assign priority for the subsidy. Priority will be given to those households who score highest in need on the RRH score on the VI-SPDAT. The VI-SPDAT is an assessment tool chosen for coordinated entry. The VI-SPDAT combines the strengths of two widely used existing assessments: • The Vulnerability Index (VI), developed by Community Solutions using leading medical research, which helps determine the chronicity and medical vulnerability of homeless individuals. • The Service Prioritization Decision Assistance Tool (SPDAT), developed by OrgCode Consulting, is an intake and case management tool. Based on a wide body of social science research and extensive field testing, the tool helps service providers allocate resources in a logical, targeted way. The VI-SPDAT is designed to help calibrate the response based on the individual, not merely the general population category into which they may fall (e.g., vulnerable, chronically homeless, etc.). The tool helps identify the best type of support and housing intervention for an individual. Structure of Rapid Rehousing Assistance Goal of Assistance: • After receipt of assistance, a household is able to remain stably housed. Subsidy Amount/Length of Time/Calculation: 31 (Revised Version approved August 28, 2018) • Rental subsidies provided are based on client income. Initial assistance can be as much as 100% of rent depending on client income. Client will pay a percentage of their income in rent based on the program’s assessment of the client’s financial and family situation. • Rental assistance would decline in steps based upon a fixed timeline at the program’s discretion based upon the client’s financial and family situation. Subsidy Ending: • The goal is for households to “graduate” from the program once they no longer meet the eligibility requirements of the program’s funding source and/or a Case Manager determines assistance can be terminated, whichever comes first. • An assessment tool is used regularly to determine the need for ongoing assistance. • If the household does not attain any of these goals, assistance ends at 24 months (or earlier time as set by the program). Move In Assistance: • Move-In Assistance will be targeted to households who are assessed as able to maintain their unit after the assistance. The amount of move-in assistance is determined by the program, within the limits set by the program’s funding source. • Move-In Assistance may be provided as one-time assistance or in tandem with Rental Assistance/Rental Subsidies. Rapid Rehousing Eligibility Requirements In order to qualify for rapid rehousing, households must fall within the target population as well as satisfy the following criteria: • Meet the current HUD definition of literally homeless for Rapid Re-housing services • Be the highest priority household available • Other eligibility criteria created at the program level Section 4. Orders of Priority for ESG-funded Activities. The Fresno-Madera CoC adopts the recommended order of priority established in 25 CCR 8409 for ESG-funded activities. The CoC will prioritize access to assistance for people with the most urgent and severe needs, including, but not limited to, survivors of domestic violence. ESG-funded activities shall seek to prioritize people who: 1) Are unsheltered and living in places not designed for human habitation, such as cars, parks, bus stations, and abandoned buildings; 32 (Revised Version approved August 28, 2018) 2) Have experienced the longest amount of time homeless; 3) Have multiple and severe service needs that inhibit their ability to quickly identify and secure housing on their own; and 4) For Homelessness prevention activities, people who are at greatest risk of becoming literally homeless without an intervention and are at greatest risk of experiencing a longer time in shelter or on the street should they become homeless. 33 (Revised Version approved August 28, 2018) Article VIII. Standards for Assistance Section 1. Permanent Supportive Housing Assistance. 1) Permanent Supportive Housing is community-based housing without a designated length of stay. 2) All CoC funded PSH programs must enter into a lease agreement with tenants that must be at least one year in duration and renewable. The lease agreement must observe Fair Housing regulations. 3) Participants in PSH rental assistance programs are expected to pay the higher of 30% of their income (monthly, adjusted) or 10% of their gross monthly income toward rent (including utilities). If the participant has zero income, the participants are not required to pay rent, but their supportive services partner is expected to work with them to secure income (either earned or unearned) as soon as possible. In no circumstance can a tenant be charged an amount above the rent calculation standard established by HUD. 4) Participants must meet with a case manager once per month and be reevaluated once per year. 5) Participants in leasing programs may be charged an occupancy charge up to 30% of the monthly adjusted income; 10% of the family’s gross income; or the portion of the family’s welfare assistance. 6) CoC-funded PSH projects are strongly encouraged to prioritize or dedicate beds to chronically homeless individuals and families, including chronically homeless youth and domestic violence survivors. Section 2. Rapid Re-Housing Assistance. Housing Requirements for Rapid Rehousing All housing supported by rapid rehousing resources must meet all HUD requirements, including but not limited to, Housing Quality Standards, rent reasonableness standards, FMR (as relevant), and others. Service Requirements/Components for Rapid Re-Housing Case Managers will provide intensive case management services in order to assist households to successfully retain housing and move off the subsidy and into self-sufficiency. Services will be provided at the program offices and Case Managers will conduct home visits when appropriate. Services may include, but are not limited to: • Intake and assessment • A minimum of one monthly face-to-face case management meeting • A minimum of one quarterly home visit 34 (Revised Version approved August 28, 2018) • Assistance with transportation, including accompaniment to appointments, home visits • Verification of progress toward achievement of short and long-term client objectives • Referral to behavioral health resources • Job search assistance • Benefits assistance and advocacy • Referral to vocational and training programs • Mediation and negotiation with landlords • Crisis intervention • Referral to child care resources • Referral to other services and resources • Assistance with housing applications • Budgeting and money management assistance • Social and organized activities During the clients’ participation in the program, clients must meet with a case manager not less than once per month to assist the program participant in ensuring long-term housing stability. The project is exempt from this requirement if the Violence Against Women Act of 1994 (42 U.S.C. 13925 et seq.) or the Family Violence Prevention and Services Act (42 U.S.C. 10401 et seq.) prohibits the recipient carrying out the project from making its housing conditional on the participant’s acceptance of services. All clients may receive follow-up services for up to 6 months to ensure stability and assess the effectiveness of RRH programs. Section 3. Transitional Housing Assistance. 1) Transitional Housing facilitates the movement of homeless individuals and families to PH within 24 months of entering TH. 2) All CoC funded TH programs must enter into a lease or occupancy agreement with tenants that must be at least one month in duration. The lease agreement must observe Fair Housing regulations. 3) Participants in TH rental assistance programs are expected to pay the higher of 30% of their income (monthly, adjusted) or 10% of monthly gross income toward rent (including utilities). If the participant has zero income, the participants are not required to pay rent, but their supportive services partner is expected to work with them to secure income (either earned or unearned) as soon as possible. In no circumstance can a tenant be charged an amount above the Rent Reasonableness standard established by HUD. Rents collected from residents of TH may be reserved in whole or part to assist the residents from they are collected to move to PH. 4) Participants in leasing programs may be charged an occupancy charge up to 30% of the monthly adjusted income; 10% of the family’s gross income; or the portion of the family’s welfare assistance. 35 (Revised Version approved August 28, 2018) Section 4. Emergency Shelter. Temporary and Basic Shelter Services 1) Temporary and basic shelters provide services coordinated to meet the immediate safety and survival needs of the individual or family served, including shelter, food, clothing and other support services. These services are provided in a minimally intrusive environment.   2) At a minimum, temporary and basic shelters provide the following services directly on- site: a. Sleeping accommodations;   b. Personal hygiene supplies and facilities, including toilets and wash basins; and  c. Showers and/ or bathtubs (temporary shelters may provide referrals to other facilities for these services).   Service Enriched Shelter Services 1) In addition to meeting basic needs, service-enriched shelters are designed to increase the client's coping and decision- making capacities and assist in planning for the client's reintegration into community living. 2) Program participants and staff understand that the primary goals of the emergency shelter are to: a. Provide temporary accommodation that is safe, respectful, and responsive to individual needs; and b. Re-house participants in permanent housing as quickly as possible, regardless of other personal issues or concerns. 3) Service enriched shelter programs are characterized by: a. Comprehensiveness, by directly providing a range of services or by serving as part of a network that provides a range of services;   b. Immediacy, by providing for timely intervention and avoidance of delays in implementing a workable plan; and   c. Continuity and linkage to after care (to the extent possible when funding is available), by providing services in cooperation with other resources and ensuring appropriate follow-up after the child, adult, or family has left the program. 36 (Revised Version approved August 28, 2018) 4) Participants are assisted with creating and updating individualized Housing Plans designed to re-house and stabilize participants as quickly as possible. 5) Participants are expected to be actively working on rehousing plans and engaging in related assistance to overcome immediate and direct barriers to securing housing. 6) Participants are provided or connected to housing location and placement assistance, including financial assistance for move-in costs, to achieve their Housing Plan goals. Assistance is provided: a. For all participants who cannot otherwise exit on their own; b. Without additional preconditions, such employment or sobriety; and c. With understanding that housing may cost greater than 30% of participant income and be precarious. 7) Participation in services unrelated to obtaining permanent housing is voluntary. Eligibility & Screening 1) In order to gain access to emergency shelter services, individuals or families must meet the HUD definition of homeless under Category 1, 2, or 4. 2) Other eligibility criteria may be created at the program level. 3) All persons seeking assistance must first be screened to identify whether they should be admitted to a shelter because of their homelessness status, diverted to a provider of other services, or referred for other mainstream resources. Persons who have other safe and appropriate housing options or resources are diverted away from emergency shelter and instead offered problem-solving assistance and immediate linkage to homelessness prevention assistance, as needed, desired, and available. 4) Evidence of screening for eligibility shall be documented for all persons seeking assistance. 5) All persons seeking shelter are also screened for critical health and safety needs to identify people with more severe service needs and provide an appropriate response. 6) Program admission is prioritized for people with the most urgent and severe needs as defined in 25 CCR § 8409. 7) All referrals to emergency shelter, including screening for program eligibility and prioritization, occur through Fresno/Madera County’s Coordinated Entry system protocols. 37 (Revised Version approved August 28, 2018) Assessment & Intake 1) Shelters will provide a basic intake within 24 hours of accepting a client into services. Required intake documents, include: a. Personal identification: at least one photo ID is preferred. If the client is unable to produce personal identification, the shelter may make a local decision about the necessity of pursuing ID; b. Documentation of homelessness status per federal guidelines; c. Income self-declaration; d. An assessment to determine clients’ needs; e. HMIS intake forms, except for individuals and households qualifying under Category 4 of HUD’s definition of homeless; and f. Signed acknowledgement of receiving program rules or requirements. 2) Shelters are prohibited from denying assistance to clients if they refuse to permit the shelter to share their information with other providers. In cases where a client does not consent to having their information shared, the information must still be collected by the shelter to determine eligibility, but it must not be shared via the HMIS if the program client objects. 3) Participant assessment focuses on: a. Immediate health and safety needs relevant to providing temporary accommodations; and b. Information relevant to securing housing, including: participant preferences; factors that would cause a landlord to reject the person’s application (past evictions, criminal history, etc.); factors that directly led to housing instability or homelessness in the past (failure to pay rent, lease violations, etc.); and other information necessary to link participants to financial assistance and housing-related resources. 4) Comprehensive assessments of admitted shelter program residents shall be conducted within one week of basic intake. 5) Program participants will be continually reassessed throughout their stay at a shelter to determine the earliest possible time that a resident can be discharged to permanent housing. 6) Shelters shall conduct a full assessment of residents before they leave the shelter. 7) Program participants will be referred to other forms of homeless assistance in the CoC service area according to the Fresno/Madera Country’s Coordinated Entry system procedures. 38 (Revised Version approved August 28, 2018) Access to Shelter 1) Notwithstanding restraints on program capacity and resource limitations, shelters shall follow a Housing First model with low barrier admission policies: access is provided without precondition, such as sobriety or ability to pay program fees. 2) A shelter may turn away a prospective participant if: a. The shelter has no availability. If admission otherwise would be appropriate, the shelter may, at its discretion, provide one night of shelter or place the client in a motel, prior to referring them back to a System Entry Point for routine placement. b. The household includes a child under the age of 18 and the provider operates a single adult shelter. c. Agreement with a legal guardian or appropriate authorities has not been secured for an unaccompanied minor. 3) A shelter may not turn away an individual or family qualifying under Category 4 of HUD’s definition of homeless except directly to a mutually agreed upon, more specialized next referral, suggested by a Coordinated Entry system entry point, via a “warm” hand-off with a phone call and transportation; or via other mutually agreed upon safe transition protocol. 4) Per federal requirements, the age and gender of a child under 18 cannot be used as a basis for denying any family’s admission to a shelter. 5) Shelters serving children must check adult names with the State sex offender registry before allowing entry. Single-gender adult shelters may accept sex offenders registered according to Sex Offender Registration Act (California Penal Code 290). Offenders will be asked to make legally required disclosures and will be advised of youth programs in the vicinity so they can stay in compliance with requirements. 6) Having an outstanding warrant does not disqualify a person from entering a shelter. Shelters may provide a voluntary program to help resolve outstanding warrants. Exits from Shelter Participants only move to other emergency shelter or transitional housing when: 1) They desire and choose; 39 (Revised Version approved August 28, 2018) 2) Doing so is more appropriate to meet their health and safety needs (e.g., persons in early recovery; domestic violence survivors; those who need special accommodations); and 3) No permanent housing solution currently available that is similar or better match for their needs. Exits to other homeless situations are avoided, even when program rules are violated. People who pose an imminent risk of harm to themselves or others may be existed to more appropriate assistance (i.e. a more intensive program, hospital, or other emergency responder) Program participants are referred to other forms of homeless assistance in the CoC service area according to the CoC’s Coordinated Entry System Policies and Procedures. Coordination Among Providers Emergency Shelter providers will coordinate with essential services providers, homeless prevention and rapid re-housing assistance providers, other homeless assistance providers, and mainstream service and housing providers by actively engaging in partnerships and through the CoC. Emergency Shelter staff are aware of and able to access a wide array of housing and services directly and through the CoC’s coordinated entry system. Emergency Shelter providers, with the support of CoC members, will make every effort to leverage other programs, services, and resources targeted to address homelessness and poverty within Fresno County and Madera County. Emergency Shelter operators shall ensure that participants are assessed for immediate health and safety needs, including identification of any barriers to obtaining housing, as well as provided with access to a wide array of community and housing services, including housing location and placement assistance. Participants are assisted with creating housing plans and are actively assisted in overcoming any barriers to securing housing, using a housing first, progressive engagement model. Section 5. Street Outreach. Street outreach is the provision of essential services necessary to reach out to unsheltered homeless people; connect them with emergency shelter, housing, or critical services; and provide urgent, non-facility-based care to unsheltered homeless people who are unwilling or unable to access emergency shelter, housing, or an appropriate health facility. Examples of street outreach include engagement, case management, emergency health services, emergency mental health services, transportation, and services for special populations. Eligibility for and Targeting Outreach 40 (Revised Version approved August 28, 2018) ESG- and CoC-funded street outreach programs will target for services individuals who meet the criteria under paragraph (1)(i) of the “homeless” definition under 24 CFR §576.2 and under 24 CFR 578. The Fresno-Madera CoC leverages multiple funding sources for Street Outreach programs and those activities may serve individuals qualified under other federal and state regulations. Providing Essential Services Street Outreach services providers will screen individuals with the VI-SPDAT to identify acuity of housing and service needs as a part of the coordinated entry system. They will then offer necessary and appropriate engagement, case management, emergency health and mental health, and transportation services. Section 6. Homelessness Prevention. Homelessness Prevention assistance will be provided to families and individuals who fall under the federal definition of “at-risk” of homelessness and who are eligible for such services under a provider’s criteria. Homeless prevention providers will prioritize services for families and individuals with the highest needs and barriers to retaining housing. Risk factors that determine who would be most in need of Homeless Prevention to avoid becoming homeless include but are not limited to the following: loss or imminent loss of employment or income, loss or imminent loss of housing, being “doubled up” in housing, and unstable family situation. Individual prevention assistance cannot exceed 24 months in a three-year period, and Homelessness Prevention providers must conduct participant evaluations at least every three months. Section 7. Participant Eligibility. The Fresno Madera Continuum of Care funds or will fund the following program types: Permanent Supportive Housing, Rapid Re-Housing, Transitional Housing, Hybrid Transitional Housing / Rapid Re-Housing, Planning, Safe Haven, HMIS, and Coordinated Entry. As set forth in the HEARTH Act, there are four categories of eligibility: 1) Literally Homeless, 2) Imminent Risk of Homelessness, 3) Homeless Under Other Federal Statutes (subject to cap), and (4) Fleeing/Attempting to Flee Domestic Violence. All CoC- and ESG-funded programs may serve only clients who meet federal definitions of homelessness, with the exception of homelessness prevention programs, which may serve persons “at-risk of homelessness.” The Fresno Madera Continuum of Care elects to serve categories 1, 2, and 4 due to the shortage of resources for those priority populations and excessive demand. As defined in the HEARTH Act, eligibility for Permanent Supportive Housing is limited to categories 1 and 4. Participants must also: 1) Enter from the street or shelter, or a transitional housing program to which they originally entered from the street or shelter (NOTE: if the project is designated for 41 (Revised Version approved August 28, 2018) chronically homeless, they may only enter from the street or shelter. Individuals may lose their chronically homeless designation after they enter a transitional housing program); and 2) At least one member of the household must have a disability of long duration, verified either by Social Security or a licensed professional that meets the state criteria for diagnosing and treating that condition. Section 8. Evaluating Eligibility for Assistance. Homeless status must be verified at intake for all incoming consumers, and providers must make every effort to meet federal standards of documentation. Acceptable forms of documentation include third-party documentation, second-party documentation (observation by provider) if third-party documentation is not available, and client self-certification if the other forms are not available. If third-party documentation is not available, records must certify the due diligence undertaken to obtain such documentation. Documenting Eligibility Documentation must be included in the case file, and/or scanned into the HMIS client record that demonstrates eligibility as follows: 1) Literally Homeless (in order of preference) a. Third party verification (HMIS print-out, or written referral/certification by another housing or service provider); or b. Written observation by an outreach worker; or c. Certification by the individual or head of household seeking assistance stating that (s)he was living on the streets or in shelter; If the provider is using anything other than a Third-Party Verification, the case file must include documentation of due diligence to obtain third party verification. 2) Imminent Risk of Homelessness a. A court order resulting from an eviction action notifying the individual or family that they must leave within 14 days; or b. For individual and families leaving a hotel or motel – evidence that they lack the financial resources to stay; or c. A documented and verified written or oral statement that the individual or family will be literally homeless within 14 days; and d. Certification that no subsequent residence has been identified; and e. Self-certification or other written documentation that the individual lacks the financial resources and support necessary to obtain permanent housing. 42 (Revised Version approved August 28, 2018) 3) Homeless Under Other Federal Statute (not applicable) 4) Fleeing/Attempting to Flee DV a. For victim service providers: a. An oral statement by the individual or head of household seeking assistance which states: they are fleeing; they have no subsequent residence; and they lack resources. Statement must be documented by a self-certification or a certification by the intake worker. b. For non-victim service providers: b. Oral statement by the individual or head of household seeking assistance that they are fleeing. This statement is documented by a self-certification or by the caseworker. Where the safety of the individual or family is not jeopardized, the oral statement must be verified; and c. Certification by the individual or head of household that no subsequent residence has been identified; and d. Self-certification or other written documentation, that the individual or family lacks the financial resources and support networks to obtain other permanent housing. As needed, the following documents will be gathered at follow-up: 1) Income Verification Form 2) If Chronic Homelessness was indicated on the HMIS Intake Form, Verification of Chronic Homelessness Form 3) If Chronic Homeless status is indicated on the Verification of Chronic Homelessness Form, the Certification of Disability Form should also be completed. At program enrollment, program intake forms may also be completed. However, program intake forms do not determine eligibility for the program. Income Levels Program participants receiving housing assistance where rent or occupancy charge is paid by the participant will be required to certify their income level, in compliance with 24 CFR § 578.103(a)(6). Coordinated Entry and Program Eligibility Assessment As set forth in the Fresno-Madera CoC Coordinated Entry Policies and Procedures, providers administering CoC- or ESG-funded permanent housing (either RRH or PSH) shall use Coordinated Entry to ensure housing is prioritized for the most vulnerable members of the 43 (Revised Version approved August 28, 2018) community who are eligible for the provider’s program. Providers will also use Coordinated Entry to prioritize clients for other services and interventions. Recordkeeping All providers must retain participants’ records for 5 years from expenditure of the grant, and all data should be entered into HMIS, in accordance with federal regulations at 24 CFR 576.500 (ESG Program), and 24 CFR 578.103(c) (CoC Program). Records required include the following: • Verification of Homeless Status • Verification of Chronic Homeless Status (if applicable) • Annual Income Verification and Rent Contribution Calculation for Participants receiving Housing Assistance • Program Participant Records • Signed Occupancy Agreements or Leases (if client is residing in housing) • Notice of Occupancy Rights and Certification Form required by VAWA • Housing Quality Standards • Services Provided • Other records required by HUD or individual programs 44 (Revised Version approved August 28, 2018) Article IX. Performance Monitoring Section 1. Emergency Solutions Grant (ESG) Monitoring Policies. The FMCoC plays an advisory role in managing the flow of ESG funds, monitoring performance and making recommendations as to how ESG funds should be distributed. As part of this advisory role, the FMCoC will request periodic reports from the ESG providers, and will review and analyze these reports to attempt to ensure compliance with HUD requirements and to ensure ongoing progress toward achieving substantive performance targets such as placements into permanent housing, increasing or stabilizing client income, and preventing clients from becoming homeless. This includes monitoring to ensure that the ESG projects are performing adequately, operated effectively, managed efficiently, and in compliance with HUD requirements. If applicable, the FMCoC incorporates by reference existing ESG policies and procedures within the geographic area of the CoC including those disseminated by the local or state entity responsible for allocating or administering ESG funding. Quarterly The Evaluation Committee will develop performance benchmarks that can be used to hold ESG recipients and sub-recipients accountable for meeting project goals and ensuring optimal performance. For program components that are comparable to CoC-funded programs, such as Rapid Re-Housing, performance targets will be similar or identical to the targets set for CoC projects of the same type. To set the targets for program components that are distinct to ESG, such as emergency shelter and homelessness prevention, the Evaluation Committee will study the performance of similar programs, from comparable funding sources, in nearby communities, as well as the historical performance of ESG programs in Fresno and Madera Counties. Once the benchmarks are developed and implemented, the Committee will review program and community-level performance using these benchmarks. The Committee will also identify any underperforming projects, taking into account reduced outcomes due to serving particularly high-needs populations. To the extent that technical assistance and training is needed, the Committee will provide recommendations to the Board of Directors and to the ESG direct recipient(s), including recommendations that underperforming projects be provided with more intensive, on-site monitoring. This may include site visits, client feedback, and/or review of grant records. In response to ongoing underperformance, the CoC may recommend targeted technical assistance and/or other responses. Annually In addition to review of quarterly reports, the Board of Directors may include a review of the HUD Consolidated Annual Performance and Evaluation Report (CAPER) as well as other local sources to ensure compliance with HUD requirements. The Board of Directors will coordinate 45 (Revised Version approved August 28, 2018) with any ESG recipients to share standard policies and templates that can enhance agency capacity. On an annual basis, the Evaluation Committee will also request copies of the program-level policies and documentation of ESG recipients and sub-recipients to confirm compliance in: • Eligibility and documentation of eligibility of clients; • Eligibility and documentation of eligibility of ESG-funded expenditures; • Eligibility and documentation of eligibility of ESG-funded staff time; • Policies and procedures for admission, diversion, referral, and discharge, including standards regarding length of stay; • Safeguards to meet the safety and shelter needs of special populations, e.g., victims of domestic violence, dating violence, sexual assault, and stalking; • Participation in HMIS (or in a comparable database for victim services providers); • Participation in Coordinated Entry; and • Safety and Sanitation standards of all facilities used for emergency shelter, including standards related to lead paint, air quality, cleanliness, personal security, energy efficiency, and handicapped accessibility. Section 2. Continuum of Care Monitoring Policies. The Fresno Madera Continuum of Care (CoC) is responsible for monitoring projects that receive CoC funds to ensure that the projects are performing adequately, operated effectively, managed efficiently, and in compliance with HUD requirements. Monthly 1. At the beginning of each month, HMIS Lead staff will pull performance data for the prior month from HMIS indicating benchmarks achieved and progress towards goals using percentile scoring. 2. Staff will develop a performance report based on the data needed for monitoring and review. 3. The Committee may note areas for focus or areas that need additional support or research. Samples of Performance Data that may be used (it will vary depending on the actual benchmarks/targets set): From HMIS, the percentage who: • Obtain permanent housing • Maintain/retain permanent housing (1 year) • Exit with earned income / employment 46 (Revised Version approved August 28, 2018) • Exit with mainstream benefits • Increase income • Exit to Known Destination • Return to homelessness after report start Also from HMIS: • Average Nightly Occupancy • Time (in days) from program entry to permanent housing for those obtaining permanent housing • HMIS data quality Quarterly Staff will also review program-level performance to identify strong/underperforming projects and trends throughout the CoC, taking into account populations served. To the extent that technical assistance and training is needed, the Evaluation committee will provide recommendations to the CoC Board of Directors. • Strong performers may be recognized. Additionally, the Evaluation Committee or CoC Board may reach out to them for best practices/lessons learned to share with providers serving similar populations. • Underperforming projects may be selected for more intensive, on-site monitoring. This may include site visits, client feedback, and/or review of grant records. Ongoing underperforming projects may be selected for targeted technical assistance or other response. The CoC Board will receive the quarterly report of system-level and program-level performance and the Committee’s analysis and provide feedback and direction. Bi-Annually In addition to the monthly and quarterly reports, the Evaluation Committee will lead the bi- annual performance monitoring and improvement program, which includes review of the HUD Annual Performance Report (APR), as well as other local sources of additional information. As part of the Review and Rank and quality improvement process, the committee may consider the following additional factors: • Do recipients have policies and procedures in place to support effective grant performance? Do recipients track staff understanding of and adherence to internal procedures? Do recipients have any unexecuted grants? 47 (Revised Version approved August 28, 2018) • Are required reports, including Annual Performance Reports, submitted in a timely manner? When a recipient starts a new project, is it able to deliver housing assistance and/or services in a timely manner? • Are recipients drawing down grant funds in a timely manner? Are CoC recipients drawing down funds at least quarterly? Are recipients and subrecipients spending all grant funds over the operating year? Are projects meeting their match requirements and documenting match correctly? Are the projects cost-effective? • Are there any HUD monitoring findings or independent audit findings? If so, has the recipient and/or subrecipient responded to the findings? • Is information submitted in HMIS accurately and in a timely manner? • Is the project accurately and completely documenting participant eligibility? If the project charges rent, is it calculating client income and rent correctly? If the project provides housing, is the project conducting housing assessments and documenting habitability? • Does the agency/project have a financial management system compliant with HUD standards? Does the system implement financial and cost accounting requirements? • Other HUD and local threshold criteria. In addition to deeper program analysis, annually, the Committee will reconsider the goals, indicators, and benchmarks used in the community. The Committee may see a need to change indicators or outcomes and will likely increase or change benchmarks from year to year. 48 (Revised Version approved August 28, 2018) Article X. Amendments Section 1. These bylaws may be amended when necessary by a vote of a quorum of the membership at the next scheduled meeting to be attended by the membership. Proposed amendments must be submitted to the Secretary to be sent out with regular Board announcements. Section 2. The membership shall review, update and approve these Bylaws at least annually. Article XI. Applicability Section 1. If there is any conflict between applicable Federal and/or State statutes, rules or regulations and these bylaws, such statute, rule or regulation will prevail. If any provision of these bylaws is held invalid, the remainder of these bylaws will not be affected thereby. 49 (Revised Version approved August 28, 2018) CERTIFICATE OF ADOPTION Certificate by Secretary I DO HEREBY CERTIFY: That I am duly elected, qualified, and acting Secretary of the above organization; that the foregoing bylaws, comprising of forty-eight (48) pages, the bylaws of said organization duly adopted at a meeting of the board and general membership thereof held on the 28th day of AUGUST, 2018. Signed and Approved on