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:
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;
Document actions the Grantee will take to improve program performance; and
Project the Grantee’s ERA1 expenditures through February 2022.
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.
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
Applies user-friendly website and application design practices
Partners with community-based organizations, tenant organizations or trusted community leaders to provide tenants with application assistance
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
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
Relies on a tenant’s self-attestation for purposes of determining whether an applicant has experienced a qualifying financial hardship (see sample application screen: COVID-19 Pandemic Impact)
Allows for self-attestation to establish that a tenant is at risk of housing instability or homelessness (see sample application screen: Risk of Housing Instability or Homelessness)
Accepts a self-attestation of income when determining an applicant’s income eligibility
Has defined a fact-specific proxy for purposes of supporting the determination of applicants’ income eligibility (see sample application screen: Income-Fact Specific Proxy)
Uses categorical eligibility when available to confirm an applicant’s income eligibility (see sample application screen: Income-Categorical Eligibility)
Combines self-attestation with other reasonable policies and procedures to document where the applicant resides and the applicant’s monthly rent payment in cases where the lease is either unwritten or there is no available copy (see application screen: Residence and Monthly Rent)
Allows tenants of public housing and other federally assisted housing to apply
The Grantee:
Has an eviction-diversion partnership with one or more courts that hear eviction cases from the grantee’s jurisdiction
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
As a condition to receiving ERA funds paid on a tenant’s behalf, requires a landlord’s agreement not to evict the tenant for nonpayment of rent for 30 to 90 days longer than the period covered by the rental assistance
Requires landlords and utility companies receiving funds for rental or utility payment arrears to terminate any debt collection actions and inform credit reporting agencies of the matter’s resolution
The Grantee:
Advertises the ERA program in print, television, radio, or online media specifically targeted to groups that may experience barriers to accessing ERA resources
Advertises the ERA program in print, television, radio, or online media in languages other than English
If so, please list the languages ______________________________________________________
Includes measures specially targeted to landlords that own or operate fewer than 10 units in its program outreach efforts
Conducts outreach to landlords through landlord and real-estate associations
Provides funding to community-based organizations, promotoras, tenant organizations, or trusted community leaders to support ERA outreach efforts, application assistance or navigation services
Coordinates with other health and social service providers serving low-income communities to identify and reach individuals who may qualify for the ERA program
Engages utility companies or agencies that administer the Low Income Home Energy Assistance Program (LIHEAP) to inform low-income tenants about the ERA program
Targets its outreach practices based on social vulnerability index scores, risk of evictions, or other data-driven measures of housing insecurity
Markets the ERA program through community institutions such as libraries, public schools, grocery stores, community centers, and health clinics
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
The Grantee:
Provides tenants the opportunity to apply and receive funds directly when landlords decline to participate in the application process
Collaborates with another ERA grantee to achieve administrative efficiencies or to prevent duplication of assistance
Notifies one or more utility companies about ERA applications in process to secure a payment grace period or service restoration for the applicant households
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 |
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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 |
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Obstacle # 2 |
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Obstacle #3 |
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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 |
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Improvement Action # 2 |
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Improvement Action #3 |
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Improvement Action #4 |
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Improvement Action #5 |
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Please provide reasonable monthly projections of the Grantee’s ERA1 program’s expenditures and activities over the next four months.
November 2021 |
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Number of unique households that will be assisted |
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Amount of assistance to eligible households expended |
$ |
Number of applications submitted |
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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 |
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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.
For questions related to implementation of this plan, please list a program administrator contact:
Name: ____________________________________
Title: ____________________________________
Email: ____________________________________
Office phone: ____________________________________
Mobile phone: ____________________________________
[ERA GRANTEE] |
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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.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Keyser, Raymond (Detailee) |
| File Modified | 0000-00-00 |
| File Created | 2023-08-25 |