HUD OAHP Provides HOME-ARP Allocation Plan Checklist and “Common Issues” Fact Sheets

The Office of Affordable Housing Programs (OAHP) in HUD’s Office of Community Planning and Development (CPD) issued two new HOME-American Rescue Plan (ARP) fact sheets. The “HOME-ARP Allocation Plan Checklist Fact Sheet” provides guidance for completing a HOME-ARP Allocation Plan, which is a substantial amendment to a Participating Jurisdiction’s (PJ’s) fiscal year (FY) 2021 Annual Action Plan. The “HOME-ARP Allocation Plan Common PJ Issues Fact Sheet” provides an overview of common problems found by OAHP in initial submissions of PJs’ HOME-ARP Allocation Plans. Although written to help staff of PJs and those receiving HOME-ARP funds, advocates may benefit by reviewing the two fact sheets to improve their understanding of the information that should be included by their PJ in their HOME-ARP Allocation Plan, as well as their awareness of the shortcomings identified by OAHP in some HOME-ARP Allocation Plans.

The “American Rescue Plan” (ARP) provided $5 billion to assist individuals or households who are homeless or at risk of homelessness, as well as other vulnerable populations, by providing access to housing, rental assistance, supportive services, and non-congregate shelter in order to reduce homelessness and increase housing stability. Notwithstanding the program’s title, HOME-ARP is very different from the regular HOME program.

The “HOME-ARP Allocation Plan Checklist” reminds PJs of HOME-ARP requirements set out in Notice CPD-21-10. PJs submit their HOME-ARP Allocation Plans to their OAHP Field Office, which reviews them and, if necessary, rejects them, informing the PJ of the reasons the HOME-ARP Allocation Plan falls short. PJs have 45 days to resubmit their plans after responding to the “issues” identified by the OAHP Field Office.

The “Checklist” includes options for responding to requirements to: consult with other agencies and service providers; carry out required public participation activities, such as holding public hearings, providing a public comment period of at least 15 days, undertaking efforts to enable broad public participation, and summarizing public comments; and evaluate the size and demographic composition of all “qualifying populations” (see below), as well as assess qualified populations’ respective unmet housing and service needs.

A HOME-ARP Allocation Plan must identify the amount of planned HOME-ARP funding that will be devoted to each activity. It must also identify whether a PJ intends to give preference to one or more qualifying populations or a subpopulation for any activity or project, being careful not to violate the requirements of the “Fair Housing Act.”

The “HOME-ARP Allocation Plan Common PJ Issues Fact Sheet” can help advocates focus on apparently typical shortcomings found by OAHP with a number of PJs’ initial HOME-ARP Allocation Plan submissions. The two-page fact sheet highlights problems regarding: consultation with other agencies and service providers; inadequate public participation; issues involving the needs and gap analysis; and a variety of fair housing issues that might arise with preferences in single-sex or adult-only housing or non-congregate shelter, and housing or shelter that is limited to people with a specific disability.

HOME-ARP funds must be used primarily to benefit individuals or families from the following qualifying populations:

  • Homeless people, as defined in section 103(a) of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11302(a));
  • Those at-risk of homelessness, as defined in section 401(1) of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11360(1));
  • People fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking, as defined by HUD;
  • Other populations, if supportive services or assistance under section 212(a) of the Act (42 U.S.C. 12742(a)) would prevent homelessness or would serve those with the greatest risk of housing instability; and
  • Veterans and households that include a veteran member and that meet one of the preceding criteria.

HOME-ARP funds can be used for four eligible activities:

  • Production or preservation of affordable housing;
  • Tenant-Based Rental Assistance (TBRA);
  • Supportive services, homeless prevention services, and housing counseling; and
  • Purchase and development of Non-Congregate Shelter (NCS). These structures can remain in use as non-congregate shelter or can be converted to emergency shelter under the Emergency Solutions Grant program, permanent housing under the Continuum of Care program, or affordable housing under the HOME Program.   

Read the “HOME-ARP Allocation Plan Checklist Fact Sheet” at: https://bit.ly/3tBEW7X

Read the “HOME-ARP Allocation Plan Common PJ Issues Fact Sheet” at: https://bit.ly/3tByzSc

Read previously issued HOME-ARP fact sheets at: https://bit.ly/3LfVHvl

Visit CPD’s HOME-ARP website at: https://bit.ly/3LbFnfb