Q: can HMIS funds be used for the purchase and/or lease of a scanner for uploading client files into HMIS as outlined in the workflow agreement
A: Yes. However the cost must be proportionately allocated to NHAP activities as per 2 CFR 200.405
Q: Must all funding that supports homeless assistance programs (i.e. ESG, VASH, private/community foundation funding, VOCA, etc.) be reported under “other funding sources”.
A: Yes. All funds that support the subrecipient agency homeless and/or at risk of homelessness programs must be reported on page 4 of the NHAP application.
Q: Per ESG Guidelines 24 CFR 576.400 (d), victim services providers may choose not to use the Continuum of Care’s centralized or coordinated assessment system. Given that stipulation, how are victim service providers to answer the following question on the NHAP application: “Describe your agency’s participation in the applicable regional Coordinated Entry System to ensure streamlined accessibility to permanent housing programs. Provide narrative regarding how the agency is utilizing the standardized assessment tools (VI-SPDAT and/or F-VISPDAT) to determine the needs of the agency’s program participants.”
A: Victim service agencies may note the exemption on their NHAP application. However, NHAP will be working with victim service providers and the Coordinated Entry agency to evaluate the possibilities, in certain circumstances, for in maintaining confidentiality for victims who may benefit from increased accessibility to permanent housing programs. Under no circumstances would NHAP require sharing of confidential information as protected by VAWA. If it is found that program participants of victim services programs would benefit from housing options that may be available through participation in the Coordinated Entry system, the program participant must be made aware with whom personal data is shared through a limited Release of Information.
Q: I have a question in regards to the NHAP grant for indirect cost. Can we allocate 4% of the Fiscal Managers position and 4% of the Data Specialist position that we have to NHAP the 4% comes from what we factor time spent on NHAP related activities such as fiscal management, reporting, data base statistical information, processing, etc….
If so do these request go under the indirect cost? However it states must have an approved amount?
A: There is a 2 part answer to this question:
Administrative costs (fiscal managers, executive directors, and other staff that do not provide direct services) are unallowable as a direct expense but may be partially recaptured through a federally approved Indirect Cost rate or through the use of a “de minimus rate”. If an agency has never had a federally negotiated indirect cost rate, the agency can choose to use the “de minimus” rate of 10% of modified total direct costs (MTDC). All calculations must be presented in the application to show how “de minimus” rate was determined. See 24 CFR 200.414 for additional guidance. If the agency has a federally negotiated Indirect Cost rate, the current approval letter must be submitted with the NHAP application.
Agencies may request funding for personnel (data specialists, case managers, etc.) to enter data into the HMIS system or the comparable data base for victim service providers as outlined per § 576.107 HMIS component. See CFR for full list of eligible expenses under HMIS component category.
Q: Can any of the personnel costs for the fiscal manager/accountant/administrative assistant who processes payments for NHAP activities ever be eligible as a direct cost in the event that an agency does not have a negotiate indirect cost rate and does not want to utilize the “de minimis” rate?
A: Yes, however, the agency has to ensure that the personnel costs are proportionate to the time the personnel is spending time on NHAP related activities. The personnel’s timesheet would need to clearly identify the time allocated to these activities in the activity log. See the following for an example:
To allocate these costs, first determine the program component under which these costs fall; then allocate the costs to an activity within the component. For example, staff time expended on processing checks for utility payments for program participants could be eligible under the rapid re-housing component or the homelessness prevention component; the activity would be housing relocation and stabilization services.
For the salaries and related costs of staff that are not fully dedicated to a particular component, costs should be reimbursed in proportion to the actual hours worked on each NHAP component. A staff position that is not fully dedicated to ESG cannot be paid solely through ESG funds.
For example, if an accountant spends 100 percent of his/her time tracking rental assistance or security deposits for homelessness prevention activities, then paying for this time is allowable under the homelessness prevention component because the accountant's time is only spent working on a single component. Alternatively, the cost for an accountant to process checks for both the homelessness prevention and rapid re-housing components must be pro-rated by each component. Also, the accountant's time preparing an invoice to obtain NHAP funds from the recipient would be an administrative cost. Therefore, recipients or subrecipients must break out the accountant's time based on the activities performed.
Q: Can we include deposit assistance in the agency budget for Homelessness Prevention or Rapid Rehousing financial assistance funds to be utilized to pay security deposits for rental units though local Public Housing Authorities?
A: Yes as long as there are no other public funds being provided for the same type of service through another public source. The sources of financial assistance or rental assistance is an important distinction to determine eligibility. In addition, the use of ESG/NHAP funds for financial assistance must adhere to other federal ESG guidelines.
ESG/NHAP funds for financial or rental assistance cannot be provided to a program participant who is receiving the same type of assistance through other public sources (24 CFR § 576.105(d) and 24 CFR § 576.106(c)). However, ESG funds can be used to provide “different type(s) of assistance” from that being provided to the program participant through other public sources (e.g., public housing, Section 8 vouchers, permanent supportive housing or other supportive housing programs, and Supportive Services for Veteran Families (SSVF)) if the following criteria are met:
• First, the individual or family must meet the eligibility criteria for ESG rapid re-housing assistance (24 CFR 576.104)
• Second, the costs of ESG assistance are only eligible to the extent that the assistance is necessary to help the program participant move as quickly as possible into permanent housing and achieve stability in that housing.
This means that if the above criteria are met, a household that needs ESG financial assistance (e.g., security deposit, renal arrears, moving expenses, or utilities assistance) in order to be able to use the rental assistance from another public source may be eligible for such ESG assistance as long as another public funding source is not providing any portion of the same costs that are being paid through ESG.
Q: Please share how you would like DV programs to provide the supporting documentation regarding our data? Last year we submitted over 25 pages of our excel spreadsheets showing our documentation. Is this what you are looking since we are exempt from HMIS.
A: As with any agency applying for NHAP funds, please provide supporting documentation as succinctly as possible to support the performance measures. The supporting documentation should be straightforward to demonstrate the agency’s performance on the outcome measures for ease of evaluation by NHAP and the review teams.