Property Management PERMANENT SUPPORTIVE HOUSING - The Florida Housing Finance Corporation - Florida Housing Coalition

 
Property Management PERMANENT SUPPORTIVE HOUSING - The Florida Housing Finance Corporation - Florida Housing Coalition
PERMANENT SUPPORTIVE HOUSING
Property Management
                      GUIDEBOOK

      SPONSORED BY:               PRESENTED BY:
The Florida Housing               The Florida Housing Coalition
Finance Corporation               June 2018
Property Management PERMANENT SUPPORTIVE HOUSING - The Florida Housing Finance Corporation - Florida Housing Coalition
Property Management PERMANENT SUPPORTIVE HOUSING - The Florida Housing Finance Corporation - Florida Housing Coalition
INTRODUCTION...............................................................................................................................2

PART I: Planning a Permanent Supportive Housing Community...............................................................3
  Choices and Decisions
  Rehabilitation or New Construction
  Rehabilitation
  Capital Needs Assessment
  New Construction
  Property Characteristics
  Size and scale of property
  Target population
  Ownership and Management Structure
  Property Management: In-house or Outsource?
  Safety and Security Considerations
  Building Consensus, Support, and Momentum
  Board of Directors
  Support Service Providers
  Local government leadership, planning and housing staff
  The Development Team
  The Technical Advisor

PART II: Developing a Permanent Supportive Housing Community........................................................11
  Predevelopment
  Selecting a Co-Developer
  Site Location Criteria
  Areas of Opportunity
  Proximity Considerations
  Due Diligence Process for Site Selection
  Market Analysis
  Legal Consultation
  Financing Process
  Credit Underwriting
  Funding Award and Initial Closing
  Construction and Lease-Up
  Project Stabilization and Final Closing
  Period of Affordability
  Compliance Monitoring
  Regulatory Agreement / Land Use Restriction Agreement

PART III: Managing and Operating a Permanent Supportive Housing Development...............................18
  The Property Management Plan
  Staff Organization
  Organization Chart
  Property Management Policies
  Leasing Policies
  Maintenance and Repair Policies
  Operating Procedures
  Operation in Compliance with Financing Requirements
  Operating Budget and Reserves
  Set-asides and Unit Mix

                                                                      PE R M ANE NT SUPPOR T IV E HOUSING | PR OPE R T Y M ANAGEMENT GUI D EBO O K
Property Management PERMANENT SUPPORTIVE HOUSING - The Florida Housing Finance Corporation - Florida Housing Coalition
Income Limits
         Rent Limits
         Rental Assistance
         Utility Allowances
         Tenant Eligibility
         Financial Management
         Fair Housing
         General Fair Housing Requirements
         Marketing
         Reasonable Modifications and Reasonable Accommodations
         Affirmative Fair Housing Marketing Plan
         Support Services
         Administrative Procedures
         Compliance Monitoring
         Reporting Requirements
         Record Retention and Access
         Staff Training

      PART IV: Support Services in Permanent Supportive Housing...............................................................28
       Introduction
       Separation of Property Management and Support Services
       Voluntary Service Provision
       Service Provision Models
       Contracting Support Services
       Training and Competencies in Support Services
       Funding for Support Services
       Documentation and Privacy Issues

      APPENDIX I: Resources...................................................................................................................34

      APPENDIX II: Glossary.....................................................................................................................35

      APPENDIX III: Due Diligence............................................................................................................37

      APPENDIX IV: Property Management Plan Template...........................................................................39

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Property Management PERMANENT SUPPORTIVE HOUSING - The Florida Housing Finance Corporation - Florida Housing Coalition
WHAT IS
   Permanent Supportive Housing?
Permanent supportive housing (PSH) is an evidence-based hous-
ing model that combines affordable permanent housing with
access to flexible supportive services. Supportive housing is de-
signed for people with disabilities who are unlikely to be able to
maintain stable housing without service-enriched housing. This
combination of affordable housing and individualized support
services helps individuals live healthier, more stable lives.

Typically, supportive housing is rental housing with a standard lease. The PSH
apartments may be scattered through the community in mainstream apart-
ment complexes or may be project-based rental units in one or more devel-
opments. In some cases, permanent supportive housing apartments are set-
aside units in larger affordable subsidized housing complexes.

Combined with the rental housing are the individualized, flexible, and acces-
sible supportive services. These services may vary widely and often include
case management, health care coordination, behavioral health coordination,
job and education coaching, assistance with daily living skills, transportation
assistance, and assistance accessing mainstream resources such as food as-
sistance and disability income.

Permanent supportive housing for those with disabilities not only saves lives
and provides a platform for health and wellness, it also results in cost savings
to public service systems.

                                    PE R M ANE NT SUPPOR T IV E HOUSING | PR OPE R T Y M ANAGE M E NT GUI D EBO O K   1
Property Management PERMANENT SUPPORTIVE HOUSING - The Florida Housing Finance Corporation - Florida Housing Coalition
Introduction
    Affordable housing development begins with an idea or, for some, a vision. Bringing that vision to life starts with
    exploring choices, making decisions, and taking action. The same can be said about the permanent supportive
    housing (PSH) model. Permanent supportive housing is often more deeply affordable than general affordable hous-
    ing and offers a permanent private residence in which to thrive – a very different, and much more effective, approach
    as compared to a congregate setting, an institution, and or an emergency shelter.

    The idea or vision for PSH includes not only stable and            helpful for those who may be developing or operating
    affordable housing, but the supports needed to main-               PSH without FHFC financing because the basic tenets
    tain housing stability for a lifetime. The visionaries who         of good management and quality support services ap-
    strive to become developers and operators of perma-                ply to any PSH project or program.
    nent supportive housing have a special challenge to not
                                                                       This guidebook describes the steps and milestones
    only make the home a reality, but to integrate the com-
                                                                       required to bring the initial concept of permanent
    munity-based supportive services needed by house-
                                                                       supportive housing to successful development and
    holds with disabling conditions who tend to have expe-
                                                                       sustainable operation. The ultimate goal, of course, is
    rienced housing instability or homelessness.
                                                                       to position your project to provide a permanent resi-
    The primary purpose of this guidebook is to provide                dence for people who have faced serious challenges
    a tool to assist you in the operation and maintenance              in finding a home that meets their needs for accessibil-
    of permanent supportive housing, including basic                   ity, affordability, and supports.
    management operations, as well as the coordination
                                                                       The guidebook was prepared by the Florida Housing
    and delivery of support services. Part I of this guide
                                                                       Coalition, a statewide nonprofit organization whose
    is focused on the advance planning of a permanent
                                                                       mission is to bring together housing advocates and re-
    supportive housing project-based multifamily devel-
                                                                       sources so that all Floridians have a quality affordable
    opment. Part II focuses on predevelopment and de-
                                                                       home and suitable living environment. The Florida
    velopment activities to build a quality project-based
                                                                       Housing Coalition provides training, consulting, and
    PSH development. In Part III, we highlight the oper-
                                                                       technical assistance services in permanent supportive
    ating and property management approaches and ac-
                                                                       housing, as well as in community development, ending
    tions that qualify the PSH project property for afford-
                                                                       homelessness, affordable housing, and much more.
    able housing development financial assistance. Part IV
                                                                       Contact us if you have questions or stories to share!
    rounds out the PSH project framework by providing an
    overview of how to integrate into the project the sup-             Permanent supportive housing links decent, safe, af-
    port services needed – those that will enable tenants              fordable, community-based housing with flexible, vol-
    with histories of housing instability or homelessness to           untary support services designed to help the house-
    achieve housing stability and wellness, even while liv-            hold stay housed and live a more productive life in the
    ing with disabling conditions.                                     community. It looks and functions much like any other
                                                                       brand of housing. People living in supportive housing
    This guidebook is sponsored by the Florida Housing
                                                                       have a private and secure place to make their home,
    Finance Corporation (FHFC) to help applicants for de-
                                                                       just like other members of the community, with the
    velopment financing to understand FHFC’s policies and
                                                                       same rights and responsibilities. The difference is that
    regulations governing program design, operation, and
                                                                       they can access, at their option, services designed to
    compliance for permanent supportive housing. While
                                                                       build independent living and tenancy skills, assistance
    applicants for funding may include for profit and non-
                                                                       with integrating into the community, and connections
    profit organizations, or joint ventures between both,
                                                                       to community-based health care, treatment, and em-
    the guidance is primarily directed to the nonprofit, mis-
                                                                       ployment services. (USICH)
    sion-based organization. The guidebook will also be

2   FLO RI DA H O U S I N G COA L ITIO N | WWW. F L HOU S IN G.O R G
Property Management PERMANENT SUPPORTIVE HOUSING - The Florida Housing Finance Corporation - Florida Housing Coalition
PART ONE

Part I
Planning a Permanent Supportive
Housing Community
Choices and Decisions                                              • Is it right for our organization?
As an organization contemplates the possibility of de-             • Will this project further the mission, vision, and
veloping and operating permanent supportive hous-                    strategic plan of our organization?
ing, it is helpful to begin with a framework for exploring         • Does our organization have the time, capacity,
the project concept and consider the overall process of              and resources to launch a development project?
making initial decisions through the development pro-              • Is there a clear picture of the need and demand
cess. It is important to understand the complexity of this           for the type of housing being considered?
type of housing, including the long term legal, financial,         • Can the project be built as designed and be op-
and operational obligations that are involved.                       erated with the intended rent levels expected
                                                                     from the intended residents, or will fundraising
This section outlines the choices and decisions that                 and grantwriting be required as a permanent ac-
are followed by pre-development, development and                     tivity to successfully operate the housing? If the
management of permanent supportive housing. The                      latter, does our organization have the capacity to
development of affordable housing is a complex and                   ensure success in those arenas?
time-consuming process. It is essentially multifamily real         • What specific type of project would be appro-
estate development, made more complicated by the                     priate for our organization and most compatible
many strings attached from the source(s) of financing                with our mission?
and regulatory constraints.                                            • A single site project such as an apartment
                                                                         complex?
The graphic below shows the general sequence of the                    • Scattered site housing such as geographically
development of affordable housing, from concept to                       dispersed individual units detached or attached,
lease up and operation.                                                  that are leased with rental or other subsidies?
                                                                       • Unit set-asides in an affordable housing proj-
 The initial decision to pursue the development and opera-
                                                                         ect where the owner designates a specific
tion of permanent supportive housing is contingent upon                  number of units for persons with disabilities or
the consideration of several basic but essential questions.              special needs?

                          o Conceptual Vision
  The Development

                          o Site Selection
                          o Programming/Preliminary Design
                          o Funding Application
                PROCESS

                          o Credit Underwriting
                          o Funding Award and Initial Closing
                          o Construction and Lease-Up
                          o Project Stabilization and Final Closing
                          o Project Operation and Program Compliance

                                                        PE R M ANE NT SUPPOR T IV E HOUSING | PR OPE R T Y M ANAGE M E NT GUI D EBO O K   3
PART ONE

    While the residence type may vary, the common element                 • How will the community respond to the planning
    in permanent supportive housing is independent living                   and construction of the project?
    with voluntary supports that are not provided by the                  • Who will be the development team? Do the
    property manager. Permanent supportive housing does                     team members have experience in developing
    not include shelters, transitional housing, group homes,                the type of project under consideration?
    assisted living facilities, any other congregate setting, or
    other specialized licensed residential facilities.                 Rehabilitation or New Construction
    There are many other elements that require decisions               Rehabilitation
    during the conceptual phase of a permanent support-                In some cases, an organization may have access to an
    ive housing project. These additional considerations,              existing property. Once the concept is fully explored,
    along with an assessment of available resources and                it must be determined if that property is suitable for the
    opportunities, will shape the outcome of the project.              project in mind.

                                                                       The age, condition, and configuration of the property
        • Will this be new construction or acquisition and
                                                                       must be carefully considered. A capital needs assess-
          rehabilitation of an existing structure?
                                                                       ment will probably be required by funding sources if
        • What is the size and scale of the property?                  the organization is considering rehabilitating an exist-
        • What are the locational criteria for the project?            ing building. Whether by donation or purchase, exist-
        • Who is the target population?                                ing buildings must be thoroughly inspected.
        • What are the roles of the principals (i.e., owner,           General considerations include the following.
          developer, manager, or a combination)?
                                                                          • Is the building location optimal to serve the needs
        • How will we ensure safety and security of the                     of the residents?
          residents and staff?
                                                                          • Is the rehabilitation cost effective when
        • Will property management be performed in                          compared to either demolition and
          house or will a third party professional property                 reconstruction or acquisition of a new site and
          management company be engaged?                                    new construction?
        • How will the project support the intended
          population?

     While the residence type may vary, the common element in permanent supportive housing is
             independent living with voluntary supports
         that are not provided by the property manager. Permanent supportive housing does not
                include shelters, transitional housing, group homes, assisted living facilities,
              any other congregate setting, or other specialized licensed residential facilities.

4   FLO RI DA H O U S I N G COA L ITIO N | WWW. F L HOU S IN G.O R G
PART ONE

The table below describes the specific considerations that should be made for acquiring and rehabilitating an
existing building.

                              Considerations for Existing Buildings as
                     Suitable for Permanent Supportive Housing Development

  ENVIRONMENTAL                             Pre-1978 buildings may have asbestos or lead based paint on site.
  Hazardous materials in construction       Testing and remediation will be required. This should be done at the
  or vicinity including soils. Water and    outset of the due diligence process to determine if there will be a
  air quality, noise or light pollution.    severe cost impact or delay.

  STRUCTURAL CONDITION                      The Capital Needs Assessment will entail examinations by an
  Foundation, interior structure, exte-     engineer who must evaluate the condition of the building including
  rior coverings, roofing, doors, and       code violations or upgrades that will be required.
  windows.

  MECHANICAL SYSTEMS                        The Capital Needs Assessment process will evaluate the age esti-
  Heating, air conditioning, ventilation,   mated useful life of mechanical systems. The report should include
  ductwork.                                 a replacement analysis that is tied to capital reserves set aside for
                                            future repairs or replacement.

  ENERGY EFFICIENCY & RESILIENCY            Existing buildings should be tested for energy efficiency in the
  Utilities costs affect both tenant and    equipment and building envelope. A blower door test or other
  landlord. Consider renewable energy       techniques indicate the treatments required to optimize energy
  and wind-hazard mitigation.               efficiency.

  HISTORIC PRESERVATION                     The rehabilitation of designated historic structures can require ad-
  Historic buildings have significance at   ditional review and approval as well as rehabilitation methods that
  the local, state or federal level. They   protect and respect the integrity of the resource.
  add to the character and ambience of
  a neighborhood and possess unique
  architectural features that are desir-
  able and aesthetic.

  SECURITY                                  The site itself and the surrounding area should be considered for
                                            security features to provide safety for a vulnerable population.

  PAVING AND DRAINAGE                       The site should be evaluated for the efficiency of drainage systems
                                            on and immediately offsite. Existing paving and curbing condition
                                            should be considered for replacement.

  CODE COMPLIANCE                           Determine if the use of the property is compliant with current codes and
                                            if the structure and property configuration conform to current codes.

  ADAPTIVE REHABILITATION                   When converting from a non-residential use to a residential use, be
                                            aware of life safety code variations, the suitability of the building for
                                            housing, and the experience of the development team in the com-
                                            plex process of adaptive re-use.

  ACCESSIBILITY                             Existing buildings may not provide accessibility features critical in
                                            serving persons with disabilities. The renovation must meet and pos-
                                            sibly exceed ADA standards to serve the needs of the intended resi-
                                            dents. Rehab projects financed by FHFC are required to conduct an
                                            ADA compliance analysis.

                                                     PE R M ANE NT SUPPOR T IV E HOUSING | PR OPE R T Y M ANAGE M E NT GUI D EBO O K   5
PART ONE

    Capital Needs Assessment                                           ings that are 1, 2, or 3 stories with or without an eleva-
    A Capital Needs Assessment (CNA) is prepared fol-                  tor. A mid-rise is from 4 to 6 stories, while a high-rise is 7
    lowing an inspection of the property and results in a              or more stories. In both a mid-rise and high-rise, an ele-
    written evaluation of the property condition. The study            vator is required in each building. There are also smaller
    provides a minimum cost estimate for items requiring               scale options that could include single scattered site
    immediate attention. In addition, the study should pro-            properties, duplexes, triplexes, or quadraplexes.
    vide a schedule for the costs of future replacement of
                                                                       Many developers choose to have mixed uses on site,
    mechanical systems so that reserve accounts can be
                                                                       such as commercial space or services on the ground floor
    capitalized both at the time of completion and during
                                                                       with residences above. It is also possible to choose to in-
    operation. All rehabilitation projects to be financed by
                                                                       clude mixed incomes (i.e., a certain percentage of units
    FHFC require a CNA.
                                                                       for those with moderate incomes and the remainder for
    The plan should address the following issues.                      low income households). Mixed income developments
        • Analysis of structural components                            can provide the property owner higher rental income
        • Health and safety issues                                     and further the goal of integrating those with special
                                                                       needs into the mainstream. The development of a mixed
        • Accessibility features and deficiencies
                                                                       income community requires flexible financing to be able
        • Environmental hazards                                        to serve both very low and higher income residents.
        • Remaining useful life of mechanical systems and
          major structural components                                  Whether large or small, high-rise or garden, scattered
                                                                       site or an apartment complex, it is important that the
    New Construction                                                   setting be integrated into the community. Residents
    Most financing for the development of permanent sup-               should not be segregated or concentrated. While the
    portive housing tends to favor new construction. New-              housing itself has safety, affordability and accessibility,
    ly built properties typically result in lower maintenance          residents should also have easy access to the commu-
    and capital costs, as well as higher energy efficiency.            nity for employment, recreation, education, shopping,
    Further, accessibility features are part of the design and         services, and worship.
    can include the latest in assistive technology.
                                                                       The number of units and the unit size are also important
    Considerations for new construction include the                    to consider in the conceptual stages. To some degree
    following.                                                         the number of units and unit sizes are a reflection of the
        • Has it been determined that there are no existing            type of supportive housing contemplated. For exam-
          properties available that would be suitable for              ple, if the target population is persons who have expe-
          the project under consideration?
                                                                       rienced chronic or long-term homelessness and have
        • Is land available that would be readily prepared             a disabling condition, then a larger scale project with
          for the intended use?
                                                                       one-bedroom units might be the best configuration.
        • Does the development team have experience in                 Housing that will serve adults with developmental dis-
          new construction of affordable housing?
                                                                       abilities may consider a shared living model with one,
                                                                       two, and three-bedroom units with space for a live-in
    Property Characteristics                                           caregiver. Scattered site single family homes may be a
    Size and Scale of Property                                         good choice for supported independent living for fam-
    There are many choices when considering the size and               ilies with special needs.
    scale of a permanent supportive housing project. A
    project with fewer than 30 units is considered small,              Target Population
    while 30 to 60 units would be medium, and more than                Permanent supportive housing may serve a relatively
    60 would be large. The most common configuration is                broad spectrum of residents. The common element
    “garden style,” which may include one or more build-               is that supportive housing serves households who

6   FLO RI DA H O U S I N G COA L ITIO N | WWW. F L HOU S IN G.O R G
PART ONE

(1) are low income and (2) have special needs that            with disabling conditions requiring support services to
such that the household requires support services             remain stably housed, and may be focused on a special
to remain stably housed. People who are moving                subpopulation, as follows.
out of homelessness and have disabling conditions                People living with special needs or disabling condi-
generally fall into the very low-income or extreme-              tions may include a target subpopulation, such as:
ly low-income category. If a household has not yet
                                                                      • People moving out of homelessness
been awarded disability support income, they may
have no income at all.                                                • Survivors of domestic violence
                                                                      • Seniors
Housing that costs no more than 30 percent of house-
                                                                      • Foster youth aging out of the child welfare
hold income for low income persons is often not avail-
                                                                        system
able outside of public housing. For example, a person
                                                                      • Veterans
whose sole income is $750 from Supplemental Security
Income (SSI) would typically have to spend 100 percent        Ownership and Management Structure
of their income on housing in the private market and still    The developer must consider the ownership structure
might not have access to the supports needed to main-         it will form. The development of affordable housing
tain stability in the community.                              often requires a combination of team members, each
                                                              of whom brings specialized resources essential to the
As with the locational considerations, the developer
                                                              success of the project, both in completion of develop-
must evaluate financing choices and make decisions
                                                              ment and long-term operation. Affordable permanent
based on the population it will serve. Most organiza-
                                                              supportive housing is subsidized by public and private
tions have one or more target populations defined with-
                                                              sources each with expectations on the compliance and
in their mission, vision, and core values statements. The
                                                              sustainability of operations.
target population should comprise those who are living

                                                       PE R M ANE NT SUPPOR T IV E HOUSING | PR OPE R T Y M ANAGE M E NT GUI D EBO O K   7
PART ONE

                                                                   There are four primary roles comprising the team:

         According to the FHFC (Florida                                Nonprofit Organization as Owner. The nonprofit owner may pro-
            Housing) Compliance Guide-                                 vide land, equity, development oversight, and community good-
        book, it is the owner’s responsi-                              will. An experienced high-capacity nonprofit may not only be the
       bility to obtain Florida Housing’s                              owner, but also the developer, property manager, and provider of
           approval for the management                                 supportive services, or any combination of those roles.
      company selected to manage the
                                                                       Developer. The developer is responsible for securing financing,
        development. This requirement
                                                                       credit underwriting, construction oversight, and completion. The
       is in addition to the review of the
                                                                       developer may remain in the project as a co-owner or investor.
       management company informa-
           tion by the credit underwriter.                             Property Manager. The property manager takes responsibility for
       The owner shall advise the Asset                                marketing the property, lease-up, move in, move out, rent collec-
             Management Staff of Florida                               tions, evictions, accounting, supervision of maintenance, routine
            Housing of any change in the                               reporting to owner, compliance, and monitoring. The property
         owner’s selection of a manage-                                manager may be a contracted third party or may be a division with-
           ment company; any such new                                  in the ownership structure.
        management company shall be
      approved by Florida Housing pri-                                 Support Services Provider. While it is sometimes the case that the
       or to the firm assuming responsi-                               owner also takes responsibility for support services, it is more often
              bility for the development.                              true that the owner relies on third party service providers to work
                                                                       directly with residents to ensure they have access to services. Even
        The management company and                                     when most services will be provided by third parties, a support ser-
        all on-site personnel are respon-                              vices coordinator should be on the staff of the owner.
             sible to the owner for imple-
                                                                   Property Management: In-House or Outsource?
           menting the applicable Regu-
                                                                   The ongoing success of any affordable housing property is directly re-
         latory Agreement and program
                                                                   lated to the quality of its property management services. Permanent
        requirements correctly. Anyone
                                                                   supportive housing projects that receive financing from FHFC have
       who is authorized to lease apart-
                                                                   strict requirements for experienced property management. FHFC re-
          ment units to residents shall be
                                                                   quires the preparation of a Management Plan that identifies the role
            thoroughly familiar with each
                                                                   of the property manager and the role of support coordinators. As dis-
            federal and state law, rule, or
                                                                   cussed in more detail later, permanent supportive housing requires a
          regulation governing certifica-
                                                                   separation between property management and the provision of sup-
       tion and leasing procedures. It is
                                                                   port services. This distinction is important and must be designed into
        also important that the manage-
                                                                   the management plan with routine reviews.
            ment company provide infor-
            mation, as needed, to Florida                          Developers and owners who are just getting started in this arena will be
       Housing and submit all required                             required to hire an outside qualified property management company.
        reports and documentation in a                             In Florida, third party professional property management requires a Real
       timely manner. It is recommend-                             Estate Brokerage license. FHFC requires a property manager to have
       ed that a management company                                managed at least two properties similar in size and type as the proposed
              representative attend Man-                           permanent supportive housing project. As the entity gains experience,
          agement Reviews and Physical                             the owner may bring management in-house if approved by FHFC. In-
           Inspections conducted by the                            house management by the owner does not require a brokerage license.
        monitoring agent. (Section 2.3)                            The choice to manage in-house will depend on the availability of qualified
                                                                   staff and a strong web-based property management tracking program.

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PART ONE

According to the FHFC (Florida Housing) Compliance           Safety and Security Considerations
Guidebook, it is the owner’s responsibility to obtain        The safety and security of residents is of utmost impor-
Florida Housing’s approval for the management com-           tance in the management of supportive housing. De-
pany selected to manage the development. This re-            pending on the size of the property and characteristics
quirement is in addition to the review of the manage-        of the residents, security can be handled in a variety of
ment company information by the credit underwriter.          ways. A professional security analyst should be asked to
The owner shall advise the Asset Management Staff of         provide a plan with the type of systems recommended.
Florida Housing of any change in the owner’s selection       It is important to include the anticipated costs of securi-
of a management company; any such new management             ty in the operating budget estimates. Security methods
company shall be approved by Florida Housing prior to        may include any of the following, or other options.
the firm assuming responsibility for the development.            • Remotely monitored cameras
The management company and all on-site personnel are             • On-site 24-hour monitoring of camera feeds
responsible to the owner for implementing the applica-           • Locked entrance with attendant
ble Regulatory Agreement and program requirements                • Unattended locked entrance
correctly. Anyone who is authorized to lease apartment
                                                             In addition, each apartment should have security fea-
units to residents shall be thoroughly familiar with each
                                                             tures that would be appropriate to ensure the unit is
federal and state law, rule, or regulation governing cer-
                                                             safe and accessible.
tification and leasing procedures. It is also important
that the management company provide information,             Building Consensus, Support, and Momentum
as needed, to Florida Housing and submit all required        Once the organization has settled on a basic concept,
reports and documentation in a timely manner. It is rec-     it is important to gain confidence in the overall feasibil-
ommended that a management company representative            ity of the concept so that it can be further defined. The
attend Management Reviews and Physical Inspections           development of permanent supportive housing does
conducted by the monitoring agent. (Section 2.3)             not happen simply as a result of a building sketch and
The property manager must be knowledgeable and               raising some money. There are dozens of relationships
capable of being responsible for the following basic         that must be cultivated and maintained to bring all of
requirements.                                                the pieces together to accomplish the stages of devel-
                                                             opment and operation.
   • Marketing
   • Application intake, with support coordinator            Board of Directors
     assistance to applicants as appropriate                 The development of permanent supportive housing re-
   • Income qualification and annual re-certification,       quires an informed board of directors that has reached
     if required by financing source                         a consensus on the concept and the decision to move
   • Move-in and move-out procedures                         forward. Board members should be invited to participate
   • Eviction procedures consistent with Florida law         in the concept development phase and understand their
     (F.S. Chapter 83)                                       role going forward in guidance and direction. The board
   • Maintenance of buildings, grounds, and com-             should also be kept apprised of all activities and provid-
     mon areas                                               ed routine reports and updates. Many of the engage-
   • Accounting                                              ments that will be required in planning and financing the
   • Tracking and reporting for annual monitoring            development will require a board resolution in approval.
   • Annual inspection of units, with assistance from
                                                             Support Service Providers
     support staff as appropriate
                                                             It is important to inform and seek input from the network
   • Monitoring schedule and compliance with                 of appropriate support service providers and, if target-
     financing requirements

                                                      PE R M ANE NT SUPPOR T IV E HOUSING | PR OPE R T Y M ANAGE M E NT GUI D EBO O K   9
PART ONE

     ing those moving out of homelessness, the Continuum                The Development Team
     of Care. The successful management of the housing will             The formation of the development team should start
     depend on the availability of support services to help             early in the process. If your organization is not expe-
     tenants stabilize housing and achieve goals of health              rienced in development of this type, you will need an
     and wellness. This topic is covered in more depth in               experienced co-developer. Other members of the team
     Part IV of this guidebook.                                         include the architect, engineer, general contractor,
                                                                        and attorney. The development of affordable housing
     Local Government Leadership, Planning and                          should be led by a project manager responsible for as-
     Housing Staff                                                      sembling a team of professionals bringing experience
     Housing is a community asset that is locally based. Public         and expertise in their respective fields. For example,
     support of housing developments is tied to the problems            projects financed with low income housing tax credits
     they solve and the scope and quality of proposals. It is           or SAIL funding will be required to have a development
     critical to begin early to meet with several stakeholders in       team that already has experience with these funding
     the public sector to inform and to receive input. At some          mechanisms. The members of the development team
     point a project may require a public hearing for zoning or         include the following.
     funding, for example, and in those cases the importance
                                                                           •   Project Manager
     of having made these connections is amplified.
                                                                           •   Developer
     Many affordable housing projects are also eligible for                •   Appraiser/Market Analyst
     local government funding. It is important to undertake a              •   Architect/Engineer/Surveyor
     review of important local government documents such                   •   General Contractor
     as the Consolidated Plan, the Local Housing Assistance                •   Consultant
     Plan, and the Housing Element that is part of the Com-
                                                                           •   Legal Team
     prehensive Plan. These documents will help inform if
                                                                           •   Financing Partners
     the project fits within the local community affordable
                                                                           • Property Manager/Real Estate Agent
     housing plans.

     After reviewing the documents, meet with your local                The Technical Advisor
     government’s housing staff to determine the eligibil-              As early as possible, it is important to communicate with
     ity of your project for various funding programs, as               a technical advisor who has expertise in the develop-
     well as development incentives, application proce-                 ment of permanent supportive housing. The Florida
     dures, and critical deadlines and timeframes. It is im-            Housing Coalition’s technical assistance team has this
     portant to convey to the housing staff that the project            expertise and can provide guidance throughout the en-
     will meet a demonstrated need for permanent sup-                   tire process. Applicants for the Predevelopment Loan
     portive housing, and that the proposed project will                Program (PLP), administered by the Florida Housing
     be designed and operated to comply with program                    Finance Corporation, will be assigned a technical as-
     rules and regulations. Housing staff may have valu-                sistance provider to assist in forming the development
     able suggestions on adjusting the concept to ensure                plan and financing structure that are critical in the pre-
     eligibility for housing programs and fit within their              development phase. PLP is described further in Part II.
     available funding sources.

                    Access the Predevelopment Loan Program at FHFC at: http://www.floridahousing.org/programs/
                    special-programs/predevelopment-loan-program

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PART TWO

Part II
Developing a Permanent Supportive
Housing Community
Predevelopment                                                   experience of a co-developer allowing them to eventu-
The predevelopment stage spans the time from con-                ally develop more projects on their own.
cept development to ground breaking. This phase
                                                                 The selection of a development partner for permanent
should not be rushed because spending quality time
                                                                 supportive housing follows the same track as other
on predevelopment activities will save time, money,
                                                                 types of housing, but there are some additional consid-
and heartache during development. It is not uncom-
                                                                 erations. A Request for Qualifications may be the best
mon for the predevelopment phase to take longer
                                                                 way to systematically consider and evaluate potential
than the overall financing and construction phase of
                                                                 developers. If interested in a developer, it is instruc-
the project.
                                                                 tive to visit the developer’s projects and talk with their
During the predevelopment process the development                previous clients and funders. Seek to learn if they have
team is selected and begins to take action by selecting          completed projects on time and within the budget. De-
a site and designing the project. In this formative stage        termine if their previous nonprofit partners were active
there are opportunities to shift direction, choose a dif-        participants, both financially and during the develop-
ferent site, or stop the process altogether. Once financ-        ment process. Also consider if the type of housing they
ing and credit underwriting are underway, however, it is         have produced is similar to the concept desired (e.g.,
much more difficult to make substantial changes.                 renovating single family homes is different from new
                                                                 construction of a multifamily rental complex).
The Predevelopment Loan Program (PLP), which is ad-
ministered by the Florida Housing Finance Corporation,           The checklist below provides some questions to con-
is an excellent way to borrow low interest funds to pay for      sider when vetting possible co-developers.
many of the expenses incurred during predevelopment.
                                                                     • Experience
Often, nonprofit organizations do not have the funding
available to pay for these expenses in this stage, and the               • Is your project the type of project in which this
                                                                           developer specializes?
PLP provides the financing and technical assistance to
guide the organization through the process.                              • Does the developer deliver a quality product?
                                                                         • What is the developer’s reputation? Among
It should be noted that it is not a bad thing to terminate a               former nonprofit partners? Funders? Credit
project in the predevelopment stage if it has been deter-                  underwriters?
mined that the project was not feasible, the organization                • How many projects have they created and where?
did not have the capacity to execute the project, or the             • Resources
site had issues that could not be corrected or mitigated.
                                                                         • Do they have appropriate financing? How
                                                                           strong is their balance sheet?
Selecting a Co-Developer
Many organizations that aspire to develop permanent                      • Do they have sufficient liquidity?
housing do not have experience in the financing and                      • Do they have appropriate and sufficient staffing?
development of housing, nor in the management of                         • What other projects do they have in process
rental property. In these cases, predevelopment would                      or in the pipeline?
likely entail forming a partnership with an experienced                  • Are they well-connected?
developer who can take responsibility for the many re-                   • Consider compatibility of mission with Co-De-
quirements ahead. The nonprofit may benefit from the                       veloper partner

                                                         PE R M ANE NT SUPPOR T IV E HOUSING | PR OPE R T Y M ANAGE M E NT GUI D EBO O K   11
PART TWO

            • Is the developer a for-profit or nonprofit entity?        services, educational institutions, employment oppor-
            • Do they prioritize good design features                   tunities, medical and support services, shopping, and
              such as natural light, balconies, gardens,                recreational amenities.
              and amenities?
                                                                        One primary consideration for the location of project
            • Does the developer have an affiliation with a
                                                                        is whether the setting is urban, suburban, or rural. The
              property manager experienced in permanent
              support housing?                                          availability of transit, services, and employment are
                                                                        most relevant for the residents. The availability of financ-
            • Do they tend to have high requirements (i.e.,
              high barriers) for leasing to tenants? Do they            ing, land, and infrastructure are dependent and contin-
              require minimum credit scores, minimum                    gent upon these development considerations.
              income requirements, clear background
                                                                        The discussion below covers the locational criteria that
              checks, pristine former rental history? This is
              very critical. Seek a partner that will not im-           must be met to participate in the competitive multi-fam-
              pose high barriers to qualification for residen-          ily housing financing programs administered by FHFC.
              cy in permanent supportive housing.                       Even if a development will not be using FHFC funding,
                                                                        the criteria bear careful consideration as they are the re-
     Site Location Criteria                                             sult of demographic and market analyses that may im-
     The developer of permanent supportive housing must                 pact the feasibility of the planned project.
     consider the most important locational features for the
     project while at the same time, if seeking FHFC funding,           Areas of Opportunity
     balancing the locational requirements inherent in the              Projects that are located in defined “Areas of Opportu-
     FHFC competitive multifamily housing financing oppor-              nity” will receive preference for financing in many of the
     tunities. In exploring choices and making decisions, the           Requests for Applications offered by the Florida Hous-
     developer will weigh these and attempt to choose a site            ing Finance Corporation. Geographical criteria are
     that ensures residents’ convenient access to community             summarized in the table on the next page.

                   For more information on joint ventures, please visit and view the recorded webinar series by the Florida
                   Housing Coalition at https://vimeo.com/267291348 and https://vimeo.com/270495575.

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PART TWO

SITE SELECTION CRITERIA                                              DESCRIPTION

 Geographic Areas of                 Census tracts that are designated as two or three factor tracts. These are
 Opportunity                         locations with high indicators of community wellbeing:
                                     1) Tract median income is greater than the 40th percentile of all tracts in the
                                     county, and
                                     2) Educational attainment above the median of all tracts for adults over age
                                     25 have completed some college, and
                                     3) Tract employment rate is greater than the statewide employment rate.

 Difficult to Develop                DDA’s are areas that have high construction, land, and utility costs relative
 Areas (DDA’s)                       to area median gross income.
                                     DDA’s may qualify for a 30 percent basis boost for housing tax credit proj-
                                     ects. DDA’s apply to an entire county.

 Small Area Difficult to             More precisely defined DDA’s useful in metropolitan settings to qualify for
 Develop (SADDA)                     a basis boost and other incentives.

 R/ECAP Areas                        FHFC discourages new affordable housing development in R/ECAP areas
 Racially/Ethnically                 but will consider applications to preserve or redevelop housing in R/ECAPs.
 Concentrated Areas of
 Poverty

 Qualified Census Tracts             QCT’s are tracts in which at least half of the households in the tract have an
 (QCT)                               income less than 60 percent of the area median income (AMI) or there is
                                     a poverty rate of at least 25 percent. QCT’s are eligible for a “basis boost”
                                     for tax credit projects. Projects that are located in a QCT that is also in a R/
                                     ECAP area (see above) will not qualify for new construction.

 Limited Development                 LDA’s are defined by FHFC as having low occupancy conditions (less than
 Area (LDA’s)                        90 percent occupancy) in its rental property portfolio, where development
                                     is limited to allow existing properties to stabilize income and occupancy
                                     before new developments of similar scope are approved.

 Mandatory Distance                  FHFC publishes mandatory distance requirements for certain types of
 Requirement Areas                   housing in certain areas to prevent the overconcentration of subsidized
                                     housing which could affect the occupancy of assisted existing projects.

      The Beta Mapping Tool for Multi-family applications is a valuable aid in evaluating a particular site for its
      potential to be awarded financing from Florida Housing Finance corporation. The instructions for using the
      tool can be downloaded from this site: https://www.floridahousing.org/docs/default-source/programs/
      mapping-basics-user-guide.pdf?sfvrsn=2

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PART TWO

     Proximity Considerations                                           party reports and the use of a checklist to make sure the
     Another important location consideration is meeting                property can be developed as planned. Sites that must
     the proximity requirements within each Request for Ap-             be rezoned, require land use plan amendments, or do
     plication (RFA) for financing offered by FHFC. Proximity           not have infrastructure are least desirable. It is best to
     requirements are specified for each RFA; therefore, it is          acquire land that has the correct zoning and land use
     important to evaluate each RFA individually to ensure that         designations with infrastructure available to the site.
     the planned project will be on a site that meets the prox-
                                                                        To ensure project operating feasibility, supportive hous-
     imity requirements for services, as specified in the RFA.
                                                                        ing projects should have as little debt as possible. Land
     Importantly, the chosen site must have access to reliable          costs are often a large portion of the budget and can
     public transportation. Residents unable to walk to bus             impact the operational capacity if debt service must be
     or transit stops should be able to enroll in paratransit           covered. Many local governments have “surplus land”
     services. Services may be provided to provide transport            that can be made available to nonprofit housing organi-
     assistance to bus stops, shopping, and other locations.            zations. In Florida, municipalities are required to main-
     Residents must have access to groceries, medicine,                 tain an inventory of surplus land suitable for affordable
     household supplies, and general shopping.                          housing, so you should check with the appropriate lo-
                                                                        cal government housing department to view the inven-
     Each RFA that includes proximity criteria states the maxi-
                                                                        tory and consider making an application for acquisition.
     mum distance for a service to qualify as meeting locational
     requirements. Proximity to services includes the following.        An expanded list of site due diligence criteria is pro-
        • Bus/Rail stop                                                 vided in Appendix III.
        • Grocery store
                                                                        Market Analysis
        • Medical clinic                                                During the credit underwriting process, which is nec-
        • Pharmacy, for elderly and certain other projects              essary to obtain financing, a market analysis will be re-
        • Public/charter school, for family projects                    quired. The market analysis will determine how strong
                                                                        the demand is for this type of housing, how long it will
     Other community services that should be carefully ex-              take to reach stabilized occupancy (i.e., 90 percent)
     amined and identified include the following.                       and the level of effort or distance away from the site
        • Education for continuing education, vocational                where eligible tenants can be “captured” to move to
          training, and life skills such as cooking                     the property. While the formal market study is part of
        • Support services, such as behavioral health care
                                                                        the underwriting process, it is important to conduct an
        • Recreation such as volleyball, basketball, table              informal market study as part of the due diligence pro-
          tennis, bingo, dance classes                                  cess prior to site acquisition. For permanent supportive
        • After school programs for youth including ac-                 housing, the market has certain characteristics that go
          ademic achievement, social functioning, post                  beyond income level and would include persons with
          high school readiness, if youth will be residents
                                                                        disabling conditions, who are homeless, or who meet
          in the development
                                                                        other program requirements.
        • Community events
        • Small business incubators                                     Legal Consultation
        • Career source facilities for job preparation, job             Legal counsel should be available to review the details
          search assistance, job training                               of all land transactions and loan agreements. Attorneys
        • Child care                                                    should be experienced with affordable housing de-
                                                                        velopment as well as Florida real estate law. A project
     Due Diligence Process for Site Selection                           using Low Income Housing Tax Credits in financing will
     The evaluation of the suitability of a site for the pro-           need counsel experienced in the closing of these types
     posed development can be accomplished with third                   of agreements and loans.

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PART TWO

Financing Process
Once the site has been deemed appropriate for the project, financing must be secured. This process can involve
many different sources, each with specific requirements. In Florida, the primary source of financing for affordable
housing is from the Florida Housing Finance Corporation, which has provided support and financing for many per-
manent supportive housing developments. Some Requests for Applications (RFA’s) are for larger projects that will
utilize Low Income Housing Tax Credits (LIHTC) and SAIL (60 or more units), and others are for medium projects (30-
60 units) or smaller projects (less than 30 units).

The primary sources of funding for permanent supportive housing are described in the chart below.

                                              INCOME                         RENT
             FUNDING                                                                                       OTHER
                                             SET-ASIDE                      LIMITS

   SHIP (State Housing                    120% AMI                      30% of                    20% of program
   Initiatives Partnership                                              applicable                funds must be
   Funding for construction, rehab,                                     income limit              dedicated to persons
   emergency and rental assistance                                                                with developmental
                                                                                                  disabilities or other
                                                                                                  special needs

   SAIL (State Apartment                  20% for
PART TWO

     The application for financing through FHFC follows an annual process known as the Request for Applications or
     RFA cycle. The process allows for public input during the design of financing opportunities. The graphic below
     describes the general process of the RFA cycle, though dates vary depending on the RFA.

          JUNE                      AUG                     OCT           DEC                 MAR                      APR

        FHCA Board                  RFA                   RFA Issue     Application     Review Committee          FHFC Board to
       Approves RFA               Workshop                  Date         Due Date       Scores Applications      Approve Decisions

     Credit Underwriting                                                     tion process begins. During this time the owner and
     Projects that have been successfully ranked in the com-                 partners must oversee the development and respond
     petitive or non-competitive funding application process                 to requests for payment, inspections, and overall com-
     are invited to credit underwriting and a credit underwrit-              pletion of the units according to plan. During this time
     er will be assigned by the funder. The credit underwriter               the property manager is marketing to potential tenants
     will remain responsible for the project not only during                 and pre-leasing the units.
     the preparation of the Credit Underwriting Report, but
     throughout the construction, leasing and operations of                  Project Stabilization and Final Closing
     the project during the term of affordability.                           Once a project is cleared for occupancy the tenants
                                                                             move in. The property manager is responsible for intake
     The basic process of credit underwriting for project fea-               of applications, lease signings, and move ins. Property
     sibility is to determine if the project has a sound busi-               is considered stabilized when it reaches 90 percent oc-
     ness plan. The credit underwriting process evaluates                    cupancy. This status enables the owners to conduct the
     four main components, as follows:                                       final closing on the long-term financial obligations.
        • Suitability and readiness of the proposed project site
        • Financial capacity of developer                                    Period of Affordability
                                                                             Each funding source has a set of requirements on af-
        • Feasibility of project to operate long term as
          proposed                                                           fordability, number of set-aside units for special needs,
                                                                             and the term of compliance. The term of compliance
        • Ability to proceed
                                                                             is the length of time the property must serve a certain
     Funding Award and Initial Closing                                       population at certain affordable rents. The period of
     Once the project receives a favorable Credit Under-                     affordability can range from 15 to 50 years depending
     writing Report, the funds may be officially awarded and                 on the funding source. The long-term compliance re-
     there is a closing on the issuance of the loans and grants              quirements vary from program to program and the most
     that have been obtained. From this point construction                   stringent requirement always applies.
     may commence and funding draws can be requested.
                                                                             Compliance Monitoring
     Construction and Lease-Up                                               During underwriting a monitoring and compliance
     After the initial closing on the financing, and receipt of              schedule is set up in the regulatory documents that
     all development approvals and permits, the construc-                    defines the frequency and subject of monitoring over

                  See the Florida Housing Coalition Affordable Housing Resource Guide for comprehensive information on
                  each funding source: http://www.flhousing.org/wp-content/uploads/2017/05/Affordable-Housing-
                  Resource-Guide-2017-05.pdf

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PART TWO

the period of compliance. Multifamily rental properties     Regulatory Agreement /Land Use Restriction
financed by Florida Housing Finance Corporation are         Agreement
required to be monitored on several aspects of oper-        The financing agreements and conditions are de-
ations: onsite management, review of tenant files, ad-      scribed in a Regulatory Agreement, which is filed in the
ministrative procedures, and a physical inspection of       public records for the property as a Land Use Restriction
the property. Noncompliance is reported to the owners       Agreement (LURA).
and managers who must respond to any concerns and
correct any findings.

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PART THREE

     Part III
     Managing and Operating a Permanent
     Supportive Housing Development
     The Property Management Plan                                                  property is stabilized and there may be different per-
     The Property Management Plan is a key factor in the                           sonnel. It may be useful to include an organization chart
     successful and sustainable operation of permanent                             showing the relationship of the main entities, as well as
     supportive housing. The Management Plan defines                               the management team and the services team.
     the governing framework of the property and sets
     forth the policies and procedures to be used by man-                          Property Management Policies
     agement staff including leasing, support service coor-                        Policies for the management of permanent supportive
     dination, maintenance, and compliance with the Reg-                           housing should reflect the purpose and values of the or-
     ulatory Agreement and any other financing conditions.                         ganization and its commitment to provide a quality res-
     A separate Management Plan should be provided for                             idential community that meets the needs of its selected
     each property in the portfolio. This section provides                         tenancy. The policy descriptions below can be adapted
     guidance on the preparation of the plan. In Appen-                            for the property management plan.
     dix IV, we offer a property management template as a
     sample framework for new projects.                                            Leasing Policies
                                                                                   Lease Form
     Staff Organization                                                            The standard real estate lease provided by the Florida
     Organization Chart                                                            Bar/Florida Association of Realtors is recommended.
     The Management Plan should have an overview indi-                             The leases should not contain requirements for tenants
     cating all staff and their designated roles and positions.                    to accept support services, or any other requirements
     The initial operating team may change over time as the                        that are not contained in a standard lease (e.g., abstain-

                                                SAMPLE              Permanent Supportive Housing with internal property
      ORGANIZATION CHART                                            management and resident services

                                                                          Board of Directors

                                                                        Chief Executive Officer

              Resident              Real Estate                 Chief Financial          Operations         Human             Fundraising
              Services              Development                 Officer                  Director           Resources         Director

             Services                                             Compliance
                                                                  Director               Leasing
             Coordinator

                                                                                         Maintenance
             Case Manager

                                                                                         Accounting &
                                                                                         Reporting

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PART THREE

ing from alcohol). All occupants of the unit must be             tions must take into account the recency, nature, and
listed on the lease and leases must be current and fully         severity of the crime. Arrest records alone cannot be
executed. Lease terms must be consistent with the Reg-           used to disqualify an applicant for tenancy.
ulatory Agreement.
                                                                 Timeliness
Housing First                                                    The leasing process must be convenient, streamlined,
Housing First should be followed as the core value of            and efficient to best serve future residents. The review
the property. This means that individuals and families           and approval or denial process should be clearly stated.
experiencing homelessness who have disabilities can              Once an application is submitted, this process should
be rapidly housed in permanent housing without pre-              take no longer than several days to a week.
conditions (e.g., drug testing), and then connected to
                                                                 Appeal Process
voluntary support services to help achieve housing sta-
                                                                 A written and easy to understand appeals process must
bility, wellness, and independence.
                                                                 be in place and made available to applicants who are
Referrals                                                        denied tenancy. The applicant must be notified as to
For properties serving residents who have experienced            the reasons for the denial and be provided an oppor-
homelessness, the Continuum of Care (CoC) Coordi-                tunity to provide additional information or explanation
nated Entry System is the most effective way to priori-          and bto have the denial reconsidered.
tize individuals in the most need of permanent sup-
                                                                 Eligibility Determination
portive housing. New units coming online should be
                                                                 If the prospective tenant is referred through the CoC
registered with the CoC through HMIS to create new
                                                                 Coordinated Entry System or LINK referral agency, the
program capacity according to the set-aside character-
                                                                 referral will typically include the documentation required
istics of the property. The Coordinated Entry System’s
                                                                 for the determination of eligibility. For all applicants, the
prioritization programming will determine the highest
                                                                 property manager must determine the eligibility of an
priority for each eligible group, which in turn will result
                                                                 applicant based on program requirements, coordination
in the screening in of referrals in priority order facilitat-
                                                                 with service providers, and as provided for in the Regula-
ing a smooth enrollment process. All vacancies should
                                                                 tory Agreement. The property manager must certify that
be filled through the prioritization and referral of the
                                                                 the tenant meets eligibility requirements.
Coordinated Entry System of the Continuum of Care.
For properties serving non-homeless subpopulations,              Tenant Income Certification
referrals may be received through FHFC’s LINK referral           The income of applicants must be verified and certified
agencies or other human services agencies or health              in accordance with the funding sources. Tenants may
care organizations.                                              not be required to have income to live at the proper-
                                                                 ty if there is evidence that housing costs can be paid
Screening In
                                                                 through another source. For instance, the owner and
The tenant selection process must rely on an approach
                                                                 services provider may identify alternative sources of
that will screen tenants in, rather than screen them out.
                                                                 rent subsidies or housing vouchers to cover the rent
It is recognized that applicants for permanent support-
                                                                 and utilities for tenants who do not have income while
ive housing may have poor credit, past evictions and
                                                                 they work with the tenant to obtain income. All tenants’
negative rental histories, and so on. An applicant with
                                                                 income must be re-verified and certified on an annual
a recent history of poor credit or evictions should be
                                                                 basis or according to the Regulatory Agreement.
provided an opportunity to present mitigating informa-
tion and additional information to address concerns or,          Annual Re-certification
if appropriate and feasible, pay an additional security          The property manager must re-certify the eligibility of
deposit. Criminal background checks should be per-               tenants on an annual basis or as required by funding
formed only to identify recent convictions for violent           sources. A development that is categorized as perma-
crimes, and the consideration of any criminal convic-            nent supportive housing certifies that 100 percent of its

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