Comment Received

July 20, 2007

P.O. Box 130159

P.O. Box 130159
Birmingham, AL 35213-0159
205.591.6888
fax 205.591-6890
[email protected]

Lillian L. Deitzer
Departmental Reports Management Officer, QDAM
Department of Housing and Urban Development (HUD)
451 Seventh Street, SW., Room 4176
Washington, DC 20410

RE: Request for Comments Housing Opportunities for Persons
with AIDS (HOPWA) Program Forms (OMB Control Number:
2506-0133)

Board of Directors
Joanne Terrell, LCSW, PIP, President
Lewis Burks, Treasurer
Paul Romjue, Secretary

a. HOPWA Competitive and Renewal of Permanent Supportive
Housing Project Budget Summary (HUD-40110-B)
b. Annual Performance Report (APR) for Competitive Grantees
(HUD-40110-C)
c. Consolidated Annual Performance and Evaluation Report
(CAPER) (HUD-40110-D)

Staff
Russell L. Bennett, LGSW
Executive Director
[email protected]

Dear Ms. Deitzer:

Sharon Fenstermaker, MSW
Director of Operations
[email protected]
Crystal Pope, LCSW
Senior Program Director
[email protected]
Ashley Kerr, LCSW
Project Manager
[email protected]

It is pleasure to be given the opportunity to submit comments
regarding the Housing Opportunities for Persons with AIDS
(HOPWA) Program. The comments enclosed with this letter are
the combined comments of national HOPWA technical assistance
providers, as well as, national AIDS housing advocates.
The enclosed comments are provided and are based on the
collective national experience of working in partnership with
HOPWA grantees and project sponsors. The suggestions provided
are based on this experience and are made to further streamline
reporting, clarify programs issues for grantees, and to further
enhance the reporting tools available to grantees. In making these
comments available to HUD, it is our goal that HOPWA
performance outcomes will be accurately and efficiently reported
and will demonstrate the effectiveness of the program nationally.
The enclosed joint comments represent comments from the
following organizations:

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National AIDS Housing Coalition (NAHC)
Nancy Bernstein, Executive Director
727 15th Street NW, 6th Floor
Washington, DC 20005

(202) 347-0333
AIDS Housing Coalition (AHC)
Jonathan Sherwood, Deputy Director
Sandra Parker, Project Manager
29 Stanhope Street
Boston, MA 02116
(617) 927-0088
AIDS Housing of Washington (AHW)
Mariah Ybarra, Manager, AIDS Housing Initiatives
Kelly Zelenka, Manager, Training and Technical Assistance
Nykia Johnson, Technical Advisor
2014 East Madison, Suite 200
Seattle, WA 98122
(206) 322-9444
Collaborative Solutions, Inc. (CSI)
Russell Bennett, Executive Director
Crystal Pope, Senior Program Director
P.O. Box 130159
Birmingham, AL 35212
(205) 939-0411
We are pleased to provide these comments to HUD to further improve the program. If you
require additional information or clarification, please feel free to contact any of the organizations
listed above.
Sincerely,

Russell L. Bennett
Executive Director

Cc David Vos
William Rudy

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I.

Comments on HOPWA Competitive and Renewal of Permanent Supportive Housing
Project Budget Summary (HUD-40110-B)

a. Application Budget Summary (all applicants)
i. Page 2, item 6 Tenant-based rental assistance.
Comment: It is unclear if this activity also includes project-based rental
assistance (PBRA).
Suggested Action: PBRA should be added to this line item or a new line item
should be created.
ii. Page 2, new item:
Comment: Technical Assistance as related to community residence is not
included in the budget form, however it is an eligible activity in the HOPWA
regulations.
Suggested Action: Below resource identification add a line item for technical
assistance related to community residences as outlined in the HOPWA
regulations.
b. Detailed Project Budget and Housing Outputs (each organization)
i. Page 3, add new item.
Comment: Technical Assistance as related to community residence is not
included in the budget form, however it is an eligible activity in the HOPWA
regulations.
Suggested Action: Below resource identification add a line item for technical
assistance related to community residences as outlined in the HOPWA
regulations.

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II.

Comments on HOPWA Annual Progress Report (APR) Measuring Performance Outcomes
(HUD-40110-C)

a. Part 1: Grantee Information - Section 2, page 2 – Contractor/Subcontractor Information
Comment: The information requested in this section is similar to information requested in
Part 5A: Summary of Project Sponsor Information, however clarification has not been
made as to why the two are distinct. It would seem information collected under Part 5A
would be provided to the grantee and reiterating such information in Part I is burdensome
to grantees. Additionally, the use of the terms “contractors” and “subcontractors” are not
clear and should be further defined as they relate to the HOPWA program. For example,
it is unclear if project sponsor organizations are also contractor or subcontractors and thus
must complete the form.
Suggested Action: 1) Clarify the relation to Part I: Contractor/Subcontractor Information
to Part 5A: Summary of Project Sponsor Information and 2) Define the terms contractor
and subcontractor as it relates to the HOPWA terms grantee and project sponsor.
b. Part 2: Grantee Narrative and Performance Assessment
i. C. Barriers and Recommendations (Page 3)
Comment: To gain better clarity on community barriers that often impact the
delivery of or access to permanent housing, add additional barriers often faced
within a community.
Suggested Action: Add the following barriers to the list presented: 1) criminal
history 2) credit history 3) rental history 4) housing affordability and 5) other
barrier, with the option to explain further.
ii. F. Unmet Housing Need: Assessment of Unmet Need for HOPWA Eligible
Households. (Page 4)
Comment: The inclusion of the chart to identify unmet housing needs is a
positive step towards creating a national picture of the HIV/AIDS housing need.
The note in the instructions to this section, limits the completion of the chart to
grantees providing housing in non-formula areas. To create a national picture of
HIV/AIDS need, HUD should consider expanding this requirement to all
grantees regardless of the service area they target.
Because needs assessment processes vary from community to community, it is
important to understand the methodology utilized to collect and analyze data, as

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well as, give an understanding of the community process used to prioritize such
data.
Suggested Action:
i.
Change the instructions to require this chart for all grantees, not just
grantees serving non-formula areas.
ii.
Include a narrative section for grantees to describe their methodology for
collecting data, as well as, provide additional information on unmet
housing need within their area.
c. Part 3: Summary Overview of Grant Activities (page 7), B. Budget and Grant Sources for
Leveraging.
Comment: This section is much clearer and will be easier for grantees to report as
compared to the current APR. The instructions to this section include collecting
information on “in-kind” contributions. In the current version of the APR, leveraged
sources are limited to cash resources. The inclusion of in-kind resources requires further
clarification to aid grantees in understanding the meaning of in-kind resources, how to
value these resources, and where to report these resources. The current chart (2. Sources
of Leveraging) does not provide a space to capture in-kind resources.
Additionally, the classification of cash resources as federal, state, or local resources is not
consistently applied. Some grantees report any source that originates from a federal
agency as a federal source, where other grantees determine the source depending upon
where the contract for the funds is held. For example, if a grantee has a contract with a
state agency the source of funds would be considered state resources even if the federal
government provided the funds. HUD should provide clarity on how to distinguish
between federal, state, and local resources.

Suggested Actions:
i.
ii.
iii.

Define in-kind resources. Include within the definition examples of in-kind
resources and a method for determining the value of in-kind resources.
Include a space within the chart (2. Source of Leveraging) to report on in-kind
resources.
Define how federal, state, or local resources are to be defined. Examples might
include: Defined by their original source (i.e. CDBG funds given to state agency
which contacts with grantee, funds would be considered federal) or defined by
the entity that holds the contract with the grantee (i.e. state agency contracts with
grantee for CDBG funds, because the grantee contracts with a state agency these
funds would be considered state funds).

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d. Part 3: Summary Overview of Grant Activities, C. Performance and Expenditure Information
(page 8-9)
Comment: It is unclear where to report scattered-site leasing programs in the provided
form or any leasing programs for housing facilities.
Supporting services reporting (page 9, row 9) combines supportive service spending
regardless of whether it is combined with HOPWA funded housing. This may be
confusing to grantees, since in Part 5: Summary of Project Sponsor Information (pages 16
and 22) supportive services are separated into supportive service in conjunction with
HOPWA funded housing and supportive services only. This same division should be
provided in the grantee section to reduce confusion and errors in reporting.
Additionally, in row 13 of the chart, resource identification and technical assistance are
combined and should be separated into two rows as these are two distinct HOPWA
activities in the HOPWA regulations.
Suggested Actions:
i.

ii.

iii.

iv.

HUD should clarify how units supported through scattered-site leasing programs
should be reported. Possible clarification can be given to report such units under
“2a: Households in permanent housing facilities” or “2b: Households in
transitional/short-term facilities” Housing of the performance and expenditure
chart. Additionally, clarification to the term “operating subsidies” should be
given to state that operating subsidies including operating costs or leasing costs
supported through HOPWA funds.
Additionally, on the row for adjustment for duplication, between rows 4 and 5 –
black out the box in column 2. An adjustment for duplication in expended
HOPWA funds is not needed. Similarly, black out the box between row 11 and
12 in column 2.
For supportive services reporting (page 9, row 9), create an additional row to
separate supportive service reporting into two areas to be consistent with project
sponsor reporting. Create: 1) Row 9a. - Supportive Services in conjunction with
HOPWA funded housing assistance and 2) Row 9b. - Supportive Services only.
Create an additional row after row 13 and include technical assistance related to
community residences in this row. This will create a separate and distinct
reporting line consistent with the HOPWA regulations. Strike the reference to
technical assistance in row 13.

e. Part 4: Summary of Performance Outcomes, Section 1: Housing Stability Outcomes (page
10)
Comments: Overall the chart is an improvement over previous versions. HUD should
clarify how grantees should report leased housing units, especially those units leased in a
scattered-site model.

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Suggested Actions:
i.
Clarify reporting of leased units, especially scattered-site units. These units
could be reported under “permanent supportive housing facilities” or
“transitional/short-term support facilities,” whichever term applies.
ii.
Please note in the instructions to this chart, that columns 2 (Number of
Households Continuing) and 3 (Exited Households) summed will equal the total
households reported in column 1.
iii.
Under B. Transitional Housing Assistance (last two rows of chart, page 10), in
Column 3 the term “Other Temporary Housing” (item 2) is used. The addition of
the word “other” does not offer added clarity, rather it seems more confusing. It
is recommended to delete the word “other” and simply have the item title be
“Temporary Housing.” Delete the asterisk behind the statement.
f.

Part 4: Summary of Performance Outcomes, Section 2: Prevention of Homelessness: STRMU
Outcomes (page 11)
Comments: This chart is an improvement over previous additions and provides a clear
way to report client accomplishments related to STRMU. The chart clearly identifies
clients’ housing status with specific outcomes.
The chart is hard to read and may cause some problems to grantees completing the form.
The chart should be made easier to read and specific locations for data input should be
identified.
Suggested Actions:
i.
In the example provided for “Maintain private housing without subsidy” (row 1,
column 2), it is suggested that the example be made more positive. The
following are suggested changes:
(e.g. Assistance provided/completed and client is stable, not likely to seek
additional support)
ii.

It is suggested that an additional row be added to the listing of options for
stable/permanent housing (PH) to accommodate individuals that may move from
the STRMU assisted private unit into another non-assisted private unit. The
recommendation is to add the following as an option:
Other Private Housing without subsidy
The above option would include individuals that move in with family or friends
to gain additional care or support and expect to live in the unit for greater than 90
days. Also the option could be used when a client moves to a more affordable
non-assisted private unit. Including this option will clearly identify those tenants

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that stay in the STRMU assisted unit from clients that move to other private
housing situations because of case management intervention.
iii.

In the title for column 3 (page 11) “HOPWA Client Outcomes*,” delete the
asterisk.

iv.

In the fifth row, “Likely to maintain current housing arrangements*,” delete the
asterisk and pull the additional information into the box. Suggested wording:
Likely to maintain current housing arrangements, with additional STRMU
assistance.

v.

vi.

To aid in reporting, make the chart easier to read by:
i.
Divide column 2, Assessment of Housing Status into two columns. The
wording for the row should be in the first column and the second column
should be used by grantees to report households assisted; and
ii.
In questions 1a and 1b on STRMU assistance provided in previous years,
add a box to report numbers or divided the rows into two columns. One
column would contain the question as listed. The second column would
provide space for the grantee to report the number of households
assisted.
For question B. Assessment of Households that Received STRMU Assistance
and Access to Care, delete this question. The information is collected later in the
report and is redundant.

g. Part 4: Summary of Performance Outcomes, Section 3: Access to Care and Support (Page 12)
Comments: The chart is clearer than previous versions. Requiring reporting on
households served over the operating year will be easier for grantees than the previous
two points-in-time reporting.
Suggested Actions:
i.
In Chart 1A, row 1 it should be clarified that a housing plan should be created for
clients receiving STRMU. The outcome could read as follows: 1. Has a housing
plan for maintaining or establishing stable on-going housing (includes STRMU
assistance).
ii.
In outcome 3, separate this outcome on primary healthcare and medical insurance
into two separate outcomes. Suggested reading:

Outcome 3. Has contact with a primary health care provider consistent with the
schedule specified in client’s individual service plan. Outcome indicator: Access
to Health Care.

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Outcome 4. Has accessed and can maintain medical insurance/assistance.
Outcome indicator: Access to Health Care.
iii.

Add an additional outcome to measure access to support. The suggested
outcome will help to measure client engagement with case management outside
of primary health care. Such case management would include access to
additional social supports including life skills (i.e. budgeting), transportation,
child care etc. Such supports are necessary to maintaining housing stability.
Outcome 5. Has contact with case manager, benefits counselor, or housing
counselor consistent with the schedule specified in client’s individual service
plan. Outcome indicator: Access to Support.

iv.

Repeat the Sources of Income and Sources of Medical Insurance charts listed on
page 13 on page 12. Some grantees may not complete both sections and
including such information on both pages will ease grantee reporting. If this is
done, delete the note in the instructions that states: For information on types and
sources of income and medical insurance/assistance, refer to Charts 2C and 2D
on page 13.

h. Part 5: Summary of Project Sponsor Information, B. Summary of all Supportive Services
(Page 16)
Suggested Actions: In the instructions to this section, edit to clarify that project sponsors
should report on activities that they deliver through HOPWA funds, as well as, activities
delivered through contracts with third parties through HOPWA funds. Insert the
suggested wording as underlined: Provide the (unduplicated) total of all households and
expenditures for supportive services, housing placement, and grant administration and
other activities provided or administered by the project sponsor…”
The following changes in the chart are recommended for clarity in reporting:
i. Move row a. TOTAL Supportive Services Provided under row o. Other to be
consistent with other sections of the chart. After moving row a., insert a row between
row o. Other and the Total Supportive Services row to include a row for Adjustment
for Duplication, similar to other sections of the chart. This row is necessary as
individuals may receive multiple supportive services.
ii. In the newly added Adjustment for Duplication row, in the second Column Amount of
Funds Expended by Project Sponsor, black out the box, as it will not be needed.
iii. Note in the instructions to this chart, that the numbers reported in this section will
correspond to the totals reported in the grantee section, page 9, row 9.
iv. In row R. Total Housing Placement Assistance, change the following: (unduplicated,
total rows 16+17) edit to read (unduplicated, total rows [enter corresponding
letters].

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v. Under the Housing Placement Assistance Categories, in the row for Adjustment for
duplication, second column for reporting HOPWA expenditures, black out this box.
HOPWA expenditures will not have to be unduplicated.
vi. Insert a new row under row s. Resource Identification to allow for reporting of
Technical Assistance as related to community residences as outlined in the HOPWA
regulations.
i.

Part 5: Summary of Project Sponsor Information, C. Housing Assistance and Supportive
Services (page 18)
Suggested Actions:
i.
Requested change in terminology used in Section 1. Tenant-based rental
Assistance (TBRA), row b. Rental Assistance (RA) program using a reduced
subsidy, as approved in the grant agreement. It is suggested that such
terminology not be used as this may be confusing to grantees. Further it
suggests that the option of providing rental assistance with reduced subsidies
is an activity currently supported by HUD and new grantees could seek HUD
approval to undertake this activity. Suggested options include: 1) delete this
row and include within the instructions to this section that grantees
undertaking any rental assistance program report under row a. Tenant-based
rental assistance; or 2) rephrase the wording in row b. to read Other
Approved Rental Assistance Programs.
ii.
Row d. Total TBRA Supportive Services, collects information already
reported in other sections of the report. Delete this row from the chart.
iii.
In section 2. Short-Term Rent, Mortgage and Utility Assistance (STRMU),
row b. Total STRMU assistance to homeowners (mortgage and/or utility),
edit the wording to read as follows: Of the above, total STRMU assistance to
homeowners (mortgage and /or utility).
iv.
Row c. Total STRMU Supportive Services, collects information already
reported in other sections of the report. Delete this row from the chart.

j.

Part 5: Summary of Project Sponsor Information, D. Facility-based Housing Assistance and
Supportive Services. (Pages 19-21)
Comments: Overall the instructions for this section are confusing and it is unclear which
sections have to be completed for each facility. The separation of facilities into shortterm, transitional, or permanent is repeated throughout this section which creates added
reporting burdens and confusion. For example in pages 19-21, project sponsors are
asked to define if their projects are short-term, transitional, or permanent housing
facilities in each section. Streamlining facility-based reporting by requiring pages 19-21
to be completed for each facility would reduce redundancy, ease reporting, and increase
accuracy in reporting.
Suggested Actions:

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i. Edit instructions to this section to require completion of D. Facility-based Housing
Assistance and Supportive Services (pages 19-21) for each facility being developed
or supported through HOPWA funds.
ii. If HUD required this section for each facility, the reporting on a facility as shortterm, transitional, or permanent could be completed on page 19 and would be
consistent throughout the remainder of this section (pages 20-21). Thus all
references to short-term, transitional, and permanent housing should be deleted.
iii. On page 20, the chart of housing facility types should be modified. Delete the
following: c. Short-term or transitional housing facility, as the type of facility is
reported on page 19. The suggested listing may read as:
a. Single room occupancy dwelling
b. Community residence
c. Units leased by project sponsor
d. Project-based rental assistance units
e. Other housing facility. Specify
iv. In the definitions section to the APR, it is recommended that HUD provide a
definition for community residence and housing facilities, as these are two different
housing scenarios. To ensure accurate reporting from HOPWA grantees, these terms
should be defined and related to the HOPWA regulations.
v. Section 3a and 3b that capture expenditure data on housing facilities, these two charts
could be combined into one chart as the separation of permanent housing and shortterm/transitional is not needed, as it is reported on Page 19.
vi. In the new chart, on row e. Adjustment to eliminate duplication, in the second
column, Total HOPWA funds expended, black in the box as expenditures will not
need to be unduplicated.
vii. Delete row g. Total Facility-based Supportive Services, as this duplicates information
collected in other sections of the report.
k. Part 5: Summary of Project Sponsor Information, E. Supportive Services ONLY (page 22)
Suggested Actions: Make edits as suggested above. See comments on Part 5: Summary
of Project Sponsor Information, B. Summary of all Supportive Services (page 16).
l.

Part 6: Worksheet – Determining HOPWA Outcomes (page 25).
Suggested Actions:
i. Delete Chart 2. STRMU Prior Year Assessment. The chart does not offer any other
benefit to grantees as a tool and repeats requested information in the required chart
on page 11 of the APR.
ii. In the definition of Temporary Housing (page 25), delete the reference to “other
temporary housing” as this is no longer needed per the edits made above.
iii. Clarify or delete reference to Tenure Assessment (page 26), as it does not refer to the
worksheet on the previous page.
iv. Delete STRMU Prior Year Assessment instructions (page 26) as this chart is now
deleted, per i. above.

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III.

Comments on Consolidated Annual Performance and Evaluation Report (CAPER) (HUD40110-D)

a. Part 1: Grantee Executive Summary - Sections 2 & 3, page 3 – Contractor/Subcontractor
Information
Comment: The use of the terms “contractors” and “subcontractors” are not clear and
should be further defined as they relate to the HOPWA program. For example, it is
unclear if the contractor form (section 3) applies to both contracts between grantees and
contractors and contracts between project sponsors and contractors. Additionally, the
instructions state that the form should be completed for organizations holding a contract
with grantees, project sponsors, or other organizations. The term “other organizations”
should be defined.
Suggested Action:
i. Define the terms contractor and subcontractor as it relates to the HOPWA terms
grantee and project sponsor.
ii. Define the term “other organization” as it relates to contracts and subcontracts.
iii. Separate sections 2 &3, Project Sponsor Information and Contractor Information onto
different pages. Since multiples of each document may be submitted, separating the
forms on to different pages will ease grantee reporting.
iv. Include in Section 3. Contractor Information Form, the grantee or project sponsor
organization name so contract information can be tied back to the contracting
organization.
b. Part 1: Grantee Executive Summary - Narrative , C. Barriers and Trends Overview (page 4)
Comment: To gain better clarity on community barriers that often impact the delivery of or
access to permanent housing, add additional barriers often faced within a community.
Suggested Action: Add the following barriers to the list presented: 1) criminal history 2)
credit history 3) rental history 4) housing affordability and 5) other barrier, with the option to
explain further.

c. Part 1: Grantee Executive Summary, D. Unmet Housing Needs (page 5)
Comment: Because needs assessment processes vary from community to community, it is
important to understand the methodology utilized to collect and analyze data, as well as, give
an understanding of the community process used to prioritize such data.

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Suggested Action: Include a narrative section for grantees to describe their methodology for
collecting data, as well as, provide additional information on unmet housing need within their
area.
d. Part 2: Sources of Leveraging (page 6)
Comment: This section is much clearer and will be easier for grantees to report as compared
to the current CAPER. The instructions to this section include collecting information on “inkind” contributions. In the current version of the CAPER, leveraged sources are limited to
cash resources. The inclusion of in-kind resources requires further clarification to aid
grantees in understanding the meaning of in-kind resources, how to value these resources, and
where to report these resources. The current chart (Sources of Leveraging) does not provide
a space to capture in-kind resources.
Additionally, the classification of cash resources as federal, state, or local resources is not
consistently applied. Some grantees report any source that originates from a federal agency
as a federal source, where other grantees determine the source depending upon where the
contract for the funds is held. For example, if a grantee has a contract with a state agency the
source of funds would be considered state resources even if the federal government provided
the funds. HUD should provided clarity on how to distinguish between federal, state, and
local resources.
Suggested Actions: 1) Define in-kind resources. Include within the definition examples of inkind resources and a method for determining the value of in-kind resources; 2) Include a
space within the chart (Source of Leveraging) to report on in-kind resources; 3) Define how
federal, state, or local resources are to be defined. Examples might include: Define funds by
their original source (i.e. CDBG funds given to state agency which contacts with grantee,
funds would be considered federal) or defined by the entity that holds the contract with the
grantee (i.e. state agency contracts with grantee for CDBG funds, because the grantee
contracts with a state agency these funds would be considered state funds).
e. Part 3: Accomplishment Data – Planned Goal and Actual Outputs (page 7)
Comment: It is unclear where to report scattered-site leasing programs in the provided form
or any leasing programs for housing facilities.
Supporting services reporting (page 7, row 10) combines supportive service spending
regardless if it is combined with HOPWA funded housing. This may be confusing to
grantees, since later in the CAPER supportive service accomplishments are divided based on
connection to HOPWA funded housing (pages 10 and 11). This same division should be
provided in the chart provided on page 7 to reduce confusion and errors in reporting.
Additionally, in the chart, technical assistance as related to community residences is not
included as an available line item even though it is an allowable expense in the HOPWA
regulations.

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Suggested Actions: HUD should clarify how units supported through scattered-site leasing
programs should be reported. Possible clarification can be given to report such units under
“2a: Households in permanent housing facilities” or “2b: Households in transitional/shortterm facilities” Housing of the performance and expenditure chart. Additionally, clarification
to the term “operating subsidies” should be given to state that operating subsidies include
operating costs or leasing costs supported through HOPWA funds.
For supportive services reporting (page 7, row 10), create an additional row to separate
supportive service reporting into two areas to be consistent with charts on pages 10 & 11.
Insert: 1) Row 10a. - Supportive Services in conjunction with HOPWA funded housing
assistance; 2) Row 10b. - Supportive Services only; 3) insert row 10c. Total Supportive
Services.
Create an additional row after row 15 and include technical assistance related to community
residences in this row. This will create a separate and distinct reporting line consistent with
the HOPWA regulations.
f.

Part 4: Summary of Performance Outcomes, Section 1: Housing Stability (page 8)
Comments: Overall the chart is an improvement over previous versions. HUD should
clarify how grantees should report leased housing units, especially those units leased in a
scattered-site model.
Suggested Actions:
i.
Clarify reporting of leased units, especially scattered-site units. These units could
be reported under “permanent supportive housing facilities” or “transitional/shortterm support facilities” whichever term applies.
ii.
Please note in the instructions to this chart, that columns 2 (Number of Households
Continuing) and 3 (Exited Households) summed will equal the total households
reported in column 1.
iii.
Under B. Transitional Housing Assistance – in Column 3, row 2. “Other
Temporary Housing.” The addition of the word “other” does not offer added
clarity, rather it seems more confusing. It is recommended to delete the word
“other” and simply have the item title be “Temporary Housing.” Delete the
asterisk behind the statement.
iv.
In the instructions to this section which reads: Note: Refer to the destination codes
that appear in Part 6: Appendix: Worksheet on Determining HOPWA Outcomes
and Connections with HMIS. Edit to read: Note: Refer to the destination housing
stability codes that appear in Part 5: Worksheet - Determining Housing Stability
Outcomes.

g. Section 2: Prevention of Homelessness: STRMU Outcomes (page 9)

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Comments: This chart is an improvement over previous additions and provides a clear
way to report client accomplishments related to STRMU. The chart clearly identifies
clients’ housing status to specific outcomes.
The chart is hard to read and may cause some problems to grantees completing the form.
The chart should be made easier to read and specific locations for data input should be
identified.
Suggested Actions:
i.
Column 2, row 1 – Maintain private housing without subsidy – delete asterisk.
ii.
In the example provided for “Maintain private housing without subsidy” (row 1,
column 2), it is suggested that the example be made more positive. The
following are suggested changes:
1. (e.g. Assistance provided/completed and client is stable, not likely to seek
additional support)
iii.

It is suggested that an additional row be added to the listing of options for
stable/permanent housing (PH) to accommodate individuals that may move from
the STRMU assisted private unit into another non-assisted private unit. The
recommendation is to add the following as an option:
Other Private Housing without subsidy
The above option would include individuals that move in with family or friends
to gain additional care or support and expect to live in the unit for greater than 90
days. Also the option could be used when a client moves to a more affordable
non-assisted private unit. Including this option will clearly identify those tenants
that stay in the STRMU assisted unit from clients that move to other private
housing situations because of case management intervention.

iv.

In the fifth row, “Likely to maintain current housing arrangements*,” delete the
asterisk and pull the additional information into the box. Suggested wording:
Likely to maintain current housing arrangements, with additional STRMU
assistance.

v.

To aid in reporting, make the chart easier to read by:
a. Divide column 2, Assessment of Housing Status into two
columns. The wording for the row should be in the first column
and the second column should be used by grantees to report
households assisted; and
b. In questions 1a and 1b on STRMU assistance provided in
previous years, add a box to report numbers or divided the rows

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vi.

into two columns. One column would contain the question as
listed. The second column would provide space for the grantee
to report the number of households assisted.
For question B. Assessment of Households that Received STRMU Assistance
and Access to Care, delete this question. The information is collected later in the
report and is redundant.

h. Section 3: Access to Care and Support (Page 10 & 11) - comments apply tables 1A, 1B, 2A.
& 2B
Comments: The chart is clearer than previous versions. Requiring reporting on
households served over the operating year will be easier for grantees than the previous
two-points in time reporting.
Suggested Actions:
i.
In Chart 1A, row 1 it should be clarified that a housing plan should be created for
clients receiving STRMU. The outcome could read as follows: 1. Has a housing
plan for maintaining or establishing stable on-going housing (includes STRMU
assistance).
ii.
In outcome 3, separate this outcome on primary healthcare and medical insurance
into two separate outcomes. Suggested reading:
Outcome 3. Has contact with a primary health care provider consistent with the
schedule specified in client’s individual service plan. Outcome indicator: Access
to Health Care.
Outcome 4. Has accessed and can maintain medical insurance/assistance.
Outcome indicator: Access to Health Care.
iii.

Add an additional outcome to measure access to support. The suggested
outcome will help to measure client engagement with case management outside
of primary health care. Such case management would include access to
additional social supports including life skills (i.e. budgeting), transportation,
child care etc. Such supports are necessary to maintaining housing stability.
Outcome 5. Has contact with case manager, benefits counselor, or housing
counselor consistent with the schedule specified in client’s individual service
plan. Outcome indicator: Access to Support.

iv.

Repeat the Sources of Income and Sources of Medical Insurance charts listed on
page 11 on page 10. Some grantees may not complete both sections and
including such information on both pages will ease grantee reporting. If this is
done, delete the note in the instructions that states: For information on types and
sources of income and medical insurance/assistance, refer to Charts 2C and 2D
on next page.

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i.

Part 5: Worksheet – Determining Housing Stability Outcomes
Suggested Actions:
i. Delete Chart 2. STRMU Prior Year Assessment. The chart does not offer any other
benefit to grantees as a tool and repeats requested information in the required chart
on page 9 of the CAPER.
ii. In the definition of Temporary Housing (page 12), delete the reference to “other
temporary housing” as this is no longer needed per the edits made above.
iii. Clarify or delete reference to Tenure Assessment (page 13), as it does not refer to the
worksheet on the previous page.
iv. Delete STRMU Prior Year Assessment instructions (page 13) as this chart is now
deleted, per i. above.