April 8, 2020
HUD COVID Waivers for the Continuum of Care Program
HUD is allowing greater flexibility to communities to prevent the spread of COVID-19 and better assist individuals and families experiencing homelessness. UNITY has requested approval to use the CoC waivers with the CoC and HOPWA programs for which UNITY is the grantee. Below is a summary of the waivers and recommended documentation for CoC programs. If you have any questions, please contact vcoffin@unitygno.org or your contract manager.
| Program Area | Usual Requirement | Waiver Requirements | Recommended Documentation |
| Fair Market Rent for Leasing | Rent payments for individual units with leasing dollars may not exceed Fair Market Rent (FMR). | FMR restriction is waived from March 31, 2020 until September 31, 2020. The rental amount must still meet rent reasonableness standards. | Revise the rent payment standard to reflect FMR is waived for this time period. Refer to the HUD COVID-19 waiver notice in the leasing file. Ensure unit meets rent reasonableness standards. |
| Disability Documentation for PSH | Documentation of disability must be documented at entry or with intake worker’s observation with additional confirming evidence (by a medical professional) within 45 days. | If disability documentation is documented by intake worker observation only, the documentation by a certified professional must be obtained no later than September 31, 2020. | Document in the intake paperwork the evidence available regarding client disabling condition including case worker observation, medical records, documentation for prior years. Cite the HUD COVID-19 waiver. Indicate the plan to obtain documentation within 6 months. Update progress on a monthly basis for any clients accepted under this waiver. |
| Eligible Housing Search and Counseling Service Costs | Eligible activities do not include client debt. | CoC Program funds may be used for up to 6 months of client utility arrears and up to 6 months of rent arrears If those arrears make it difficult to obtain housing. Waiver is in effect until March 31, 2021. | Program must obtain a budget revision to move funds into this line item. Program should document how the client cannot obtain housing without payment of arrears. |
| Rapid Rehousing Monthly Case Management | Program participants are required to meet with a case manager not less than once per month. | Since some clients do not have a phone or internet, the monthly requirement is waived until May 31, 2020. | Document that the client does not have access to phone or internet. Document attempts to meet with client using social distancing. Continue to assist the client to obtain phone or internet access and document such assistance in case files. |
| Housing Quality Standards (HQS) – Initial Inspection | A physical inspection is required for any unit supported by leasing or rental assistance funds to ensure the unit meets housing quality standards (HQS) before any assistance will be provided on behalf of a program participant. | Waiver until September 31, 2020 allows a visual inspection using technology such as video streaming AND the project sponsor physically re-inspects the unit within 3 months after health officials special measures to prevent the spread of COVID-19 are no longer necessary. | Agencies should document that the HQS was conducted through a visual inspection as allowed under the HUD COVID-19 waiver. Program policies should indicate that visual inspections will be followed-up with a physical inspection within 3 months of the end of special measures. Program should create a tracking list of inspections conducted in this method to ensure physical inspections are conducted in a timely way. |
| Housing Quality Standards (HQS) – Re-inspection of Units | All units for which leasing or rental assistance funds are used must be inspected at least annually to ensure the unit continues to meet HQS. | Re-inspections are not required until March 31, 2022. | When conducting the annual client recertification, note in the client file that the HQS inspection was not conducted due to COVID-19 under the HUD Waiver. Indicate in the file that there is reasonable belief that the unit continues to meet HQS standards. |
| One-Year Lease Requirement | Program participants residing in PSH must be the tenant on a lease for a term for at least one year that is renewable and terminable for cause. | The one year lease requirement is waived until September 30, 2020, so long as the initial lease term is for more than one month. | Document attempts to obtain a 12-month lease. Keep a log of leases made during this time which will need to be converted to 12 month leases when the waiver has expired. |
HUD Waiver Notice Published March 31, 2020