COVID-19 new interim homeless assistance program guidance

The California Department of Social Services (CDSS) has issued new guidance CalWORKs Homeless Assistance (HA) and COVID-19.  This new guidance supersedes CDSS’ March 19, 2020 All County Welfare Directors Letter for HA only.

Up to 16 days of motel vouchers are available from HA for eligible or apparently eligible CalWORKs participants.  Because of COVID-19, counties may waive the three-day limit to verify homelessness.  Counties may issue benefits in increments of more than one week, up to all 16 days at once.

Families should be granted good cause for not completing daily permanent housing search.

Receiving HA because of a state or federally declared disaster does not count against a client’s once per 12-months limit on HA.  In addition, clients affected by COVID-19 may be eligible for an exception to the once per 12-months limit because of uninhabitability of the home or a medical illness. For example, if a parent needs to isolate themselves because of COVID-19, HA should be granted based on exception because of medical illness.

HA applications are not required to be made in person or to include a face-to-face interview.  Counties can complete the application and have the client electronically sign it.  Counties can also record a verbal attestation over the phone or enter a case note stating the client attested to the information.

Counties can accept sworn statements for not providing paper verification such as hotel receipts or counties can grant good cause for not submitting paper verification.

Although existing guidance requires counties to issue vendor payments when there has been a finding of mismanagement, if there is no feasible way to issue vendor payments because of COVID-19, counties should consider issuing benefits on the client’s EBT card.  (All County Welfare Directors Letter, March 31, 2020.)

COVID-19 CDC guidance on responding to people experiencing homelessness

The Center for Disease Control (CDC) has issued guidance regarding steps to protect people experiencing homelessness from COVID-19.  CDC recommends partnerships across local sectors including homeless outreach teams, state and local health departments, hospitals and law enforcement.

CDC’s prevention measures are not to clear encampments during community spread of COVID-19 unless individual housing units are available because doing so increases risk of disease spread.  CDC also recommends ensuring restrooms near encampments have functioning water, hand hygiene materials and bath issue, and they remain open 24 hours per day to people experiencing homelessness.  If toilets or handwashing facilities are not available nearby, portable toilets with handwashing facilities should be brought for encampments of more than 10 people.

Persons experiencing unsheltered homelessness with suspected or confirmed COVID-19 should be provided isolation housing.  Behavioral health teams should be involved in the planning for these sites to facilitate access to community support.  If they need to be hospitalized, a discharge plan should be in place.  (CDC COVID-19 Interim Guidance, March 22, 2020.)

COVID-19 TCAC compliance monitoring and essential management operations

The California Tax Credit Allocation Committee (TCAC) has issued guidance for compliance monitoring and management functions because of COVID-19.  TCAC is cancelling all scheduled inspections until April 30, 2020.  Starting in May, 2020, TCAC will conduct desk audits with physical inspections to occur at a later date.

Day-to-day operation of a property is considered an essential business practice that must continue despite shelter in place and stay at home orders.  TCAC has several recommendations to perform essential business functions and protect the safety of on-site staff and residents including having an emergency protocol plan, limiting office hours and having a sign-up sheet, posting a sign on the window or door of the office about how to apply, and having an online application or drop box to pick up and drop off applications.  (Tax Credit Allocation Committee Memo, March 24, 2020.)

COVID-19 TCAC guidance for recertifications, services and work orders

The California Tax Credit Allocation Committee (TCAC) has issued guidance for recertifications, services and work orders because of COVID-19.  For households that start their 120 day certification/recertification period on or after March 20, 2020, management should provide households with a certification/recertification packet containing all TCAC required forms.  Third party verifications should be sent to employers directly.  Tenants should be able to return document via mail or drop box.  TCAC strongly suggests giving tenants 60 to 90 days to gather and return information.  Management agents can sign forms after the date the tenants signs and returns the forms if it is within the normal 120 day certification/recertification period.

For certifications and recertifications that were in process on March 19, 2020, management should provide households with a certification/recertification packet containing all TCAC required forms. Tenants should be able to return document via mail or drop box.  Management agents can sign forms after the date the tenants signs and returns the forms if it is within the normal 120 day certification/recertification period.

Initial tenant income certification meetings and other necessary meetings will continue in person.

Any documentation signed after the normal 120 day certification/recertification period must have  a statement in the tenant file stating why the recertification was completed late.

For work orders, management should notice tenants that any non-essential work order will be postponed.  Remaining work orders should be scheduled based on need and severity.

Service amenities including access to the community room and after school programs should be limited for social distancing.  All food-related programs should be suspended except for canned or prepackaged deliveries.  For properties that cancel or postpone required service amenities, required hours must be made up before the end of 2020.  (Tax Credit Allocation Committee Memo, March 19, 2020.)

COVID-19 reverification of employment and appraisals for FHA Single Family loans

The United States Department of Housing and Urban Development temporarily changed re-verification of employment and appraisal rules for FHA Single Family programs.  Until May 17, 2020 mortgagees do not need to re-verify employment within 10 days of the Note or within 10 days of loan disbursement if there is no loss of employment by the borrower.

Appraisers may do Exterior-only (viewing from the street) or Desktop-Only (relying on various documents and not viewing the property) appraisals for FHA Single Family loans.

There changes also apply to refinances and reverse mortgages.  (Mortgagee Letter 2020-05, March 27, 2020.)

COVID-19 foreclosure and eviction moratorium for Sections 184 and 184A loans

The United States Department of Housing and Urban Development has authorized a moratorium on foreclosures and evictions for loans guaranteed under the Section 184 Indian Home Loan Guarantee Program and Section 184A Native Hawaiian Housing Loan Guarantee Program for 60 days.

Properties secured by Section 184 or 184A guaranteed loans are subject to a moratorium on initiation of foreclosures and foreclosures in process for 60 days.  Eviction of people from properties previously secured by Section 184 or 184A guaranteed loans are suspended for 60 days.  (DLL -2020-04, March 20, 2020.)