This resource explains how to properly document prior living situation when a participant from a non-homeless living situation (transitional, temporary, permanent, or other) is eligible for and transfers to a CoC-funded housing project. For example, in instances of project transfers or RRH to PSH transfers, where eligibility would typically require the participant to meet category 1 or 4 of homelessness. It is important to properly document this information, so HUD receives accurate eligibility data when conducting Annual Performance Reports (APR).
Entering Prior Living Situation in HMIS
Per HUD, the client’s Prior Living Situation should always be where they slept the night before the enrollment, even if it does not align with project eligibility. In the transfer process, this typically means that the Prior Living Situation indicates that the participant is housed the night prior to entering the program.
More information about how to document prior living situations for transitional housing and subsidy types (including RRH, housing vouchers, public housing, etc.) can be found here: Living Situations – Helpdesk - Homeless Management Information System (HMIS)
Eligibility and APR Submissions
If the prior living situation does not reflect a category of homelessness that deems them eligible for your program, you will manually explain the situation as part of your APR submission. The CoC APR Guidebook contains guidance on where in the APR form you will put this explanation:
The APR form uses the information uploaded in the APR CSV from Q15: Living Situation. This data reports where all adults and heads of household resided immediately prior to project start, thereby in part identifying eligibility. The response options are divided into general groupings: Homeless Situations, Institutional Situations, Temporary Housing Situations, Permanent Housing Situations and Other. The form will display the total number of adults and heads of household for each living situation grouping reported in the APR CSV. For those coming from non-homeless situations (transitional, temporary, permanent, and other), an explanation must be provided indicating how persons entering the project were determined eligible and documented as homeless. Sage identifies where information is required to be completed by presenting a text box in the documentation column of the form.
APR Response Requirements
The CoC APR Guidebook also contains a table that breaks down HUDs response requirements for different eligibility situations. This question is not to verify documentation on all participants, but rather to clarify eligibility of participants who enter from situations where eligibility is not obvious.
Example
Situation: A client is transferring from a Rapid Re-Housing (RRH) program into your Permanent Supportive Housing (PSH) program. Prior living situation is entered as “Rental by client, with ongoing housing subsidy.”
On your APR submission form you will fill out an explanation in the “Temporary Situation (Transitional Housing)” section.
Your explanation should fulfill the response requirements in the table above. For example:
All clients reported in the category of “Permanent Situation” have homelessness documentation that confirms they were experiencing category 1 homelessness upon entering a Rapid-Rehousing (RRH) or other Permanent Housing (PH) program. Each client has one or more of the following in their file: a written observation by an outreach worker, a written referral by another housing or service provider, or self-certification with documentation of due diligence to obtain 3rd party verification."