Program Improvement Plan

Emergency Rental Assistance Program (ERA1)

1505-0266 Program Improvement Plan 10-22-2021

OMB: 1505-0266

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EMERGENCY RENTAL ASSISTANCE PROGRAM

U.S. DEPARTMENT OF THE TREASURY


Program Improvement Plan


This form of Program Improvement Plan has been developed to improve the delivery of emergency rental assistance (ERA) funds under the Consolidated Appropriations Act, 2021 and the American Rescue Plan Act of 2021. The assistance authorized by the Consolidated Appropriations Act, 2021 is referred to as “ERA1.” The assistance authorized by the American Rescue Plan Act of 2021 is referred to as “ERA2.”


The Consolidated Appropriations Act, 2021 requires the U.S. Treasury Department to begin reallocating “excess” ERA1 funds beginning on September 30, 2021. Treasury issued Reallocation Guidance, available on Treasury’s website, under which grantees that obligated less than 65% of their ERA1 allocations by September 30, 2021, or that do not provide an Obligated Funds Certification as described in the guidance, must submit for Treasury’s approval a Program Improvement Plan no later than November 15, 2021 in order to avoid an excess funds determination equal to 10% of the grantee’s initial allocation. A grantee may also submit a Program Improvement Plan to mitigate an excess funds determination that would result from an insufficient expenditure ratio based on the grantee’s reported expenditures through September 30, 2021.


In this Program Improvement Plan, the undersigned grantee (Grantee) will:


  1. Assess the Grantee’s ERA1 program by identifying (i) policies and practices recommended by Treasury that the Grantee has already implemented; (ii) whether the Grantee has adopted any policies or practices that Treasury has discouraged; and (iii) key obstacles to delivering ERA assistance to eligible households in the Grantee’s jurisdiction;

  2. Document actions the Grantee will take to improve program performance; and

  3. Project the Grantee’s ERA1 expenditures through February 2022.

1. Assess the Grantee’s ERA1 Program


A. Identify policies and practices implemented by the Grantee


Please indicate which of the following recommended policies or practices that the Grantee has already implemented. Note that the policies and practices that Treasury most strongly encourages are listed in bold type.

Application, Accessibility, and Prioritization

The Grantee’s application process:

  • Provides the opportunity to apply in-person

  • Provides the opportunity to apply over the phone

  • Provides the opportunity to apply online

  • Includes a mobile-friendly option to facilitate submitting an application with a smartphone

  • Ensures all application methods adopted by the Grantee are equally available and accessible by individuals with disabilities

  • Ensures all application methods adopted by the Grantee are available in languages other than English

      • If so, please list the languages ______________________________________________________

  • Prioritizes applications from households at high risk of eviction or facing other immediate threats to housing stability

  • Provides applicants a way to check on their application status


Determination of Household Eligibility

The Grantee:

  • Does not create additional eligibility requirements beyond those required by the statute

  • Partners with a neighboring jurisdiction on application policies, program terms and intake procedures to ensure regional consistency


Eviction Diversion, Housing Stability Services, and Legal Services

The Grantee:

If applicable, check any components of the diversion program:

      • Provides tenants access to an advocate or other legal assistance

      • Made available before the filing of an eviction complaint or pleading

      • Provides alternative(s) to formal court process (e.g., alternative dispute resolution)

      • Provides opportunity to apply for ERA and housing stability services

      • Participation is mandatory

      • Supported by policies that direct parties to apply for ERA before filing and that halt the eviction process where an application is initiated

      • Court-based or otherwise implemented through formal collaboration with the court

  • Provides information to judges, magistrates, court clerks, and other relevant court officials and sheriffs or law enforcement about the availability of ERA funds for tenant assistance and housing stability services and the importance of offering these services as early as possible in, or prior to the initiation of, the eviction process

  • Works with eviction court(s) to provide information about ERA program assistance to tenants and landlords as early in the adjudication process as possible

  • Refers ERA applicants to non-profit organizations for legal assistance

  • Expends funds to support legal assistance to tenants at risk of eviction

  • Refers ERA applicants to non-profit organizations for housing stability services

  • Expends funds on housing stability services provided by community-based and nonprofit organizations to keep people housed and meet essential household needs

  • Refers ERA applicants to non-profit organizations for culturally and linguistically relevant housing stability services

  • Expends funds to support housing stability services or legal assistance that are culturally and linguistically relevant to populations with limited English proficiency

  • Provides tenants with information about non-profit organizations that provide housing stability services on the ERA website and in the application


Marketing and Outreach

The Grantee:

      • If so, please list the languages ______________________________________________________


Payments

The Grantee:

  • Makes bundled payment arrangements with landlord or utility providers that serve more than 10 eligible tenants

  • Provides the tenant and landlord notice immediately upon approval of an application and prior to payment processing

  • Offers electronic payments to tenants and landlords

  • On average, makes payments less than two weeks after application approval

Program Design

The Grantee:

  • Will accept technical assistance when offered to strengthen the ERA program

  • Has created a publicly viewable data dashboard or program progress report

  • Has developed a risk-mitigation plan for fraud

  • Protects personally identifiable information (PII) of tenants, including by not collecting Social Security numbers



B. Discouraged Practices


In the box below, please identify any practices or policies expressly discouraged by Treasury’s FAQ guidance the Grantee believes are warranted for its ERA program and intends to continue. Examples include failing to allow tenants to apply directly when landlords do not participate; prohibiting applications from residents of federally assisted housing; establishing eligibility requirements beyond those required by statute or Treasury’s FAQs; and collecting Social Security numbers or other unnecessary personally identifiable information (PII) from applicants. At its option, the Grantee may provide further details and explanation under separate cover.


Discouraged Practices

















C. Identify key obstacles


In the boxes below, please identify the key obstacles to increasing the amount of ERA1 funds the Grantee expends on assistance to eligible households and increasing the number of households served by the Grantee’s ERA1 program on a monthly basis.


Obstacle # 1











Obstacle # 2











Obstacle #3












2. Actions for Program Improvement


In the boxes below, please list at least three specific actions that the Grantee will take to improve the performance of its ERA1 program, including to increase the amount of ERA1 funds the Grantee expends on assistance to eligible households and increase the number of households served by the Grantee’s ERA1 program on a monthly basis. To the maximum extent possible, the Grantee’s improvements should include policies and practices identified in bold in Section A above as those that Treasury most strongly encourages.


Improvement Action # 1







Improvement Action # 2







Improvement Action #3







Improvement Action #4







Improvement Action #5







3. Projected ERA1 expenditures


Please provide reasonable monthly projections of the Grantee’s ERA1 program’s expenditures and activities over the next four months.


November 2021

Number of unique households that will be assisted


Amount of assistance to eligible households expended

$

Number of applications submitted



December 2021

Number of unique households that will be assisted


Amount of assistance to eligible households expended

$

Number of applications submitted



January 2022

Number of unique households that will be assisted


Amount of assistance to eligible households expended

$

Number of applications submitted



February 2022

Number of unique households that will be assisted


Amount of assistance to eligible households expended

$

Number of applications submitted



Do you anticipate providing rental assistance between November 2021 and February 2022 funded with a source other than ERA1 (e.g. ERA2, State and Local Fiscal Recovery Funds, other funds made available by a state or local entity)?


  • Yes

  • No


If yes, please describe in the box below the sources of funding other than ERA1 that you anticipate will support the Grantee’s provision of rental assistance, and provide a projection for the next four months of the number of households that will receive such assistance and the amount to be expended.




Other Funding Sources










Projection

Month*

Number of Households

Amount

1. , 20



$

2. , 20



$

3. , 20



$

4. , 20



$


*The projection should begin with the first full month following plan submission.


Contact Information for Program Administrator:

For questions related to implementation of this plan, please list a program administrator contact:


Name: ____________________________________


Title: ____________________________________


Email: ____________________________________


Office phone: ____________________________________


Mobile phone: ____________________________________


Signature


[ERA GRANTEE]




By:

[Official’s Name]

[Official’s Title]



Date: , 20


PAPERWORK REDUCTION ACT NOTICE: The information collected will be used for the U.S. Government to determine the reallocation of emergency rental assistance funds. The estimated burden associated with this collection of information is 120 minutes per response. Comments concerning the accuracy of this burden estimate and suggestions for reducing this burden should be directed to the Office of Privacy, Transparency and Records, Department of the Treasury, 1500 Pennsylvania Ave., N.W., Washington, D.C. 20220. DO NOT send the form to this address. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid control number assigned by OMB.


PRIVACY ACT STATEMENT

AUTHORITY: Solicitation of this information is authorized by section 501 of division N of the Consolidated Appropriations Act, 2021 (the “Act”)

PURPOSE: The Act requires Treasury to allocate funds to eligible grantees for the delivery of emergency rental assistance to eligible households. Eligible grantees include states, local governments, U.S. territories, Tribes or Tribally Designated Housing Entities (TDHEs), as applicable, and the Department of Hawaiian Home Lands. Treasury maintains contact information for authorized representatives and contact persons of the ERA grantees for the purpose of communicating with ERA grantees regarding the administration of their award under the Act.

ROUTINE USES: The information you furnish may be shared in accordance with the routine uses outlined in the Treasury’s system of records notice, Treasury .017 – Correspondence and Contact Information, which can be found at 81 FR 78266 (Nov. 7, 2016).

DISCLOSURE: Disclosure of this information is voluntary. However, grantees/recipients that do not disclose contact information will be unable to communicate with Treasury on issues related to their obligations under the Act which may affect the status of their award.


OMB Approved No.: 1505-0266

Exp.: 11/30/2021


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