Friday, January 1, 2016

De-Coding Salem’s Federal Homeless Program Lingo

Introduction
The Federal Housing and Urban Development Department (HUD) allocates funding to the states under numerous programs.  We are concerned here with programs intended to alleviate and end homelessness, and the local entities responsible for administering those programs.  First, we look briefly at the Salem Housing Authority (SHA).  Although SHA administers most of Salem’s federal funds, its programs and reports are transparent and more or less comprehensible with a little work.  The situation is different with respect to HUD’s Community Development Block Grant (CDBG) program, the Home Investment Partnership (HOME) program, and the Continuum of Care (CoC) program, whose requirements and reports are not at all easy to understand.  Therefore, we will focus most of our attention on the latter programs (after a brief look at SHA).

Federal Programs Administered by Salem Housing Authority
Salem’s public housing authority, the third largest in Oregon, acts as Salem’s “lead housing agency”, and is organized as a division of Salem's Urban Development Department, although it was established in 1969 under provisions of Oregon law (see ORS 456.075).  Salem  Housing Authority (SHA) is actively regulated by its funding sources which include federal, state, and local governments, as well as private investors.  In addition to providing safe, decent, affordable housing to Salem and Keizer residents, SHA ably administers a variety of programs designed to assist low- and moderate-income families achieve self-sufficiency through stable housing, economic opportunity, community investment, and coordination with social service providers.  

The SHA Board of Commissioners (or SHA Commission) meet at 6:30 every second and fourth Monday (just prior to the Urban Renewal Agency, followed by the City Council meeting).  SHA files regular, brief but detailed program management reports (see, e.g., here), and ranks with HUD as “high performing.”   

SHA staff organize and manage the Emergency Housing Network, consisting of 150 housing and social service providers.  EHN was originally a subcommittee of the Marion and Polk Continuum of Care Collaborative (aka the Mid-Valley Housing and Services Collaborative).  (See below.)  When that Collaborative “merged” with the Rural Oregon Continuum of Care in 2011 (see below), the EHN became Salem’s primary housing and social services network.  The EHN has met for more than 20 years.  Note: the 2015-9 Con-Plan’s description of the local institutional delivery structure reflects the situation prior to 2011.  See page 137.   

HUD’s Office of Community Planning and Development
CDBG, HOME and CoC are programs of HUD’s Office of Community Planning and Development (CPD).  CPD “seeks to develop viable communities by promoting integrated approaches that provide decent housing, a suitable living environment, and expand economic opportunities for low and moderate income persons.”  By “integrated approaches” HUD means public-private partnerships.  Lots of them.

Continuum of Care
The CoC program originated under President Ronald Reagan.  Its primary purpose is “to promote community-wide commitment to the goal of ending homelessness.”  To that end, CPD “competitively awards grants” for “new construction; acquisition, rehabilitation, or leasing of buildings to provide transitional or permanent housing; rental assistance; payment of operating costs; supportive services; re-housing services; payment of administrative costs; and grants for technical assistance.”  

Private nonprofit organizations, states, local governments, and instrumentalities of state and local governments are eligible to apply “if they have been selected by the CoC for the geographic area in which they operate.”  The area Coc is the grantee of HUD CoC funds for the area, and is also a network of housing and social service agencies, who are “members” of the area CoC.  This network sometimes has a name, sometimes not.  Members of the area CoC may propose specific projects, which the area CoC approves or disapproves on a project-by-project basis.

Oregon has several area CoCs, and a “Balance of State CoC”, also known as the Rural Oregon CoC (ROCC).  ROCC is divided into seven regions representing 28 counties.  Marion, Polk and Yamhill counties are Region 7.  ROCC meets around the state on the fourth Wednesday of each month.

Before 2011, there was a Marion and Polk County CoC, whose network was called the Mid-Valley Housing and Services Collaborative.  But complying with HUD’s increasingly onerous requirements proved too difficult, and in 2011, Marion and Polk Counties joined or “merged” with ROCC.  When that occurred, the Emergency Housing Network, a subcommittee of the the Mid-Valley Housing and Services Collaborative became Salem’s primary housing and social services network.  This network is managed by the Salem Housing Authority (see above) and meets the second Thursday of each month.  

Since 2011, Marion and Polk Counties, along with the Salem Housing Authority (SHA) and the Mid-Willamette Valley Community Action Agency (MWVCAA) have all been members of ROCC.  MWVCAA administers funds for programs in Marion County, Polk County and/or the City of Salem.  MWVCAA also coordinates meetings of regional ROCC “grantees” called the Mid-Valley Community Action Collaborative on the second Thursday each month (as needed).  The 2015-9 Con-Plan still refers to this group as the Mid-Valley Housing and Services Collaborative.    


CDBG and HOME
The CDBG program has been around since 1974.  It’s one of HUD’s oldest, continuously run programs. Its stated purpose is to provide decent housing and a suitable living environment, and to expand economic opportunities, principally for low- and moderate-income persons.  The HOME program was started around 1990.  It is the largest Federal block grant to state and local governments designed exclusively to create affordable housing for low-income households.  Its stated purpose is to provide funds for direct (meaning not housing assistance vouchers, aka Section 8) rental assistance to low-income people and building, buying, and rehabilitating affordable housing.  Both programs require participants to develop a Consolidated Plan every five years, including developing and following “a detailed plan that provides for and encourages citizen participation” in the planning process.  HOME participants are required to provide 25% matching funds.  

In 2015, the City of Salem received $1,233,989 from the CDBG program, and $586,147 from the HOME program (HOME funds are received through the Salem-Keizer HOME Consortium).  Projects using City of Salem CDBG funds must serve Salem residents.  HOME projects serve both Salem and Keizer residents.  Both funds are administered by Salem’s Urban Development Department (UD), Federal Programs Division.  UD “oversees” Consolidated Plan development and implementation, and Federal Programs directs and monitors how the funds are spent.  When asked to describe its efforts to prevent homelessness for the most recent Consolidated Plan, the City responded, honestly enough, that its “strategy” was “marketing CDBG and HOME funds to community agencies.”  See here at 15.  

Consolidated Plans are supposed to help local jurisdictions “assess their affordable housing and community development needs and market conditions...make data-driven, place-based investment decisions.” They are also supposed to be “the framework for a community-wide dialogue to identify housing and community development priorities” for the way the funds will be spent.  In Salem, that “community-wide dialogue” consists in the main of Federal Programs staff attending meetings (e.g., business and neighborhood association meetings) to ask people to answer a long series of rather techno-, bureaucratic questions during July, August and September (when most Oregonians on vacation and interest in civic affairs and meetings generally is low), allowing people to comment on the draft plan, and holding a public hearing before the City Council before the plan is adopted.  The City Council adopted the most recent Con-Plan without a single question from either the Council or the public.      

The Consolidated Plan (Con-Plan) is “carried out” through Annual Action Plans (AAPs).  AAPs are supposed to be “a concise summary of the actions, activities, and the specific federal and non-federal resources that will be used each year to address the priority needs and specific goals identified by the Consolidated Plan.”  In reality, AAPs simply describe who was awarded what funds for what purpose following that year’s grant application process.  

The “community-wide dialogue” on the AAP begins each January, when a volunteer advisory committee some of whose members are routinely unable, due to conflicts of interest, to participate, begins to review grant applications.  The present committee was formed in 2015 when the Salem Social Services Advisory Board [SSAB] and the Housing and Urban Development Advisory Committee [HUDAC]) were “merged.”   The review process is usually completed in February with a recommendation to UD Director as to who should receive what, if any, CDBG (historically about $1.2M), HOME (historically about $600,000), and City of Salem General Fund (historically about $400,000) funding.  The committee meetings are open to the public.

Through the City's budget process, the recommendations are incorporated into a draft AAP.  In mid-March, a 30-day comment period on the draft AAP opens, followed by a public hearing in mid-April, and adoption in May.  Rarely is there any public comment.  The AAP process/document is included with the Con-Plan process/document in the years Con-Plans are adopted.  

Following the close of the fiscal/funding year on June 30, there’s another “community wide dialogue” concerning the City and its sub-grantees’ “accomplishments and progress” toward implementing the AAP and Con-Plan.  It begins in mid-August with a 15-day comment period on the draft Consolidated Annual Performance and Evaluation Report or CAPER), followed by a public hearing prior to its adoption, usually in September.  In 2015, as usual, there was no public comment on the CAPER.  

Federal Programs
Planning/Reporting Schedule

Jan - an advisory committee reviews applications for CDBG, HOME, etc. funds
Feb - the committee submits a recommendation to the City Council/Budget Committee
Feb/Mar - the recommendation is incorporated into a draft AAP (may be combined w/ Con-Plan)
Mid-Mar - 30-day comment period on draft AAP (combined w/ Con-Plan every 5-6 years)
Mid-Apr - public hearing on on draft AAP (combined w/ Con-Plan every 5-6 years)
Mid-May - City Council adopts AAP (combined w/ Con-Plan every 5-6 years)
Jun 30 - fiscal/funding year closes
Jul 1 - fiscal/funding year begins
Mid-Jul - (every 5-6 years) 60-day Con-Plan survey period opens
Mid-Aug - 15-day comment period on draft CAPER opens
End Sep - public hearing at City Council and CAPER is approved for submission to HUD
Nov - 60-day period to apply for CDBG, Home and City of Salem General funds opens


2015-2016 Programs
(from the Federal Programs webpage 12/29/15)

[LMI = low/moderate income]

Security Deposit Program
Telephone number:  503.588.6368
Description: Assistance provided to LMI families to help pay security
deposits in the Salem/Keizer area.

Tenant Based Rental Assistance
Telephone number: 971.673.0159
Description:  Program provides LMI households living with AIDS/HIV with rental assistance.

Tenant Based Rental Assistance
Telephone number: 503.370.9752
Description: Provides rental assistance to LMI homeless families with children.

Micro Enterprise Program
Subrecipient: MERIT   
Telephone number: 503.588.6368
Description: Provides services in both English and Spanish to LMI qualified microenterprises
or future entrepreneurs located within the City of Salem.

Latino Microenterprise Program
Subrecipient:  Interface Network, Inc.
Telephone number:  503.365.0088
Description:  Microenterprise services in both English and Spanish to LMI qualified
microenterprises or future entrepreneurs located within the City of Salem.

Interim Housing Assistance
Telephone number:  503.391.4365   
Description: Emergency one month rental assistance provided to LMI families
in the City of Salem.

Job Savers Program
Subrecipient: MERIT  
Telephone number: 503.588.6368
Description: Job training program for LMI households in welding

Garten Job Training
Subrecipient: Garten Services, Inc.
Description:  Job training program for the new facility.

Public Services
Subrecipient:  City of Salem, Urban Development Department
Telephone number:  503.588.6178

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