Thank you for the helpful input sessions. This program is so critical to the mission of community action and we appreciate DHCD’s leadership and efforts. Below are suggested priority changes. We share these suggestions with the intent to help strengthen program impact for clients.
Scoring: Community Need Scores
The Community Access and Community Need Scores are noted as set published criteria. Please include the points per locality per DHCD’s scoring in the appendix so that applicants can fully understand and access. Also please note the rule to average community need across localities could encourage applicants to exclude neighboring localities that would bring this score down. Bringing high need and lower need regional application together can bring additional local match. We urge DHCD to factor in the legislative intent to have statewide coverage with special focus on areas of greatest need and help applicants understand how to balance both of these policy goals.
Scoring: Community Access Scores
The Score for this criteria should be decreased significantly as it can be very subjective and not all applicants will have all information. If we understand correctly the more resources an applicant is aware of and shares on this needs assessment the lower score they will receive. This could be very problematic and subjective. The need for rent assistance outstrips availability in all of the Commonwealth.
Scoring: Priority for Match
Please ensure the local match bonus points are clearly understood to be applicant or applicant partner match regardless of the local source. As locally controlled federal and state funding should also count such as HUD CDBG, HOME, HHS CSBG, HHS TANF and many other sources. Any cash or in-kind match relevant to the project should count. This should clarify as well that existing local or organization investments with funds regardless of source satisfy the match requirement.
Please also provide bonus points to applicants that already have existing housing counseling, emergency services, housing services and other programs that complement the application.
One applicant selected per region or locality should be reconsidered
We urge DHCD to allow more than one applicant per region or locality. Or to allow DHCD to ask applicants from the same or overlapping regions to consider a joint program or partnership. Everything possible should be done in scoring and guidelines to encourage partnership amongst this whole ecosystem. One winning applicant per locality is an impediment to cooperation. DHCD can reserve the right to fund the highest scoring application from a region but then also add funding to be sub granted and pull in the match of other application from a region.
Administrative Costs vs. Programmatic Costs – Please clarify to ensure grantee capacity and programmatic staff capacity
The guidelines establish a 10% administrative cost limitation, which may include certain personnel costs. To ensure DHCD is supporting the true capacity needs to manage complex grant programs for nonprofits and local governments we urge allowing the federal de minimis rate of 15% for indirect costs. Administrative cost definitions are hard to define and lead programs to have insufficient capacity to deliver. Instead, we recommend a set minimum percentage of direct funds that should be budgeted for program participants and allow flexibility for direct staffing costs for program managers, housing counselors, court navigators, or other staff directly delivering VERP services to be considered programmatic personnel and therefore direct services. These services should be clearly defined as not subject to any administrative cap or the program will be much less effective at serving clients and achieving the goals of VERP.
Capacity Building
The required grant elements may be difficult for many applicants to develop in an initial proposal. The requirement to have both prevention and court navigation services and other policy goals make the program more complex. Recommend that smaller grants be allowed to help the needs of smaller communities with less experience. These areas could use the ability to first apply for eviction prevention services and surging support to the prevention space. The court navigation space is important but requires more funding and resources to be effective. At a minimum allow grantees to focus first on prevention and build out court navigation and policy role requirements to implement in the second year of the grant.
Building a New Statewide Effort Requires Statewide Training Grants and Capacity Building that ties VERP to other Housing and Human Services Efforts
In addition, a statewide training grant or grants should be offered as part of the RFP to allow state associations of local governments, community action and other nonprofit providers to build capacity to incorporate more training and cross collaboration for all existing housing and human services efforts with VERP.
What to Expect
Please add what to expect section for applicants to help plan for potential award including when funding is expected to start and fully utilize funds by, whether funding for year two application is expected at the same or reduced effort to help plan for whether a ramp up and then ramp down may be required. It would also be helpful for applicants to know what the minimum and max grant request can be.
Regional Requirement
VACAP supports a focus on regional applicants. However, DHCD should consider allowing applications that serve a single locality when there is a demonstrated need or where regional collaboration is documented as not feasible.
Capacity Building vs. Personnel
The guidelines state that DHCD may reserve funding for "capacity-building" in high-priority or high-need localities when no fundable application is received. Clarification on which activities are intended to fall under capacity-building. Specifically, does capacity-building include limited personnel costs, such as funding for staff necessary to establish or expand an eviction prevention program, or is it intended solely for activities such as training, technical assistance, partnership development, and organizational planning?
Six-Month Assistance Limit
The guidelines allow exceptions to the six-month financial assistance limit for households residing in subsidized or income-based housing with documented justification. DHCD should consider allowing documented exceptions for households in market-rate housing as well. Households in market-rate housing often experience significant rent increases and financial hardships without the benefit of rental subsidies. Allowing flexibility based on documented need, regardless of housing type, would enable grantees to address unique circumstances while maintaining appropriate oversight.
Post-Eviction Engagement
The guidelines state that VERP funds may not be used to assist households whose eviction occurred prior to, or outside of, their engagement with the program. Clarification on what constitutes as "engagement with the program." For example, if a household interacts with a VERP provider several days before a scheduled eviction and begins the intake process prior to the eviction date, would that household be considered engaged and therefore eligible for assistance?
Prioritization Process
The guidelines require grantees to prioritize households based on risk factors and imminent eviction. While we support prioritizing households with the greatest need, especially households with children as specified in the reporting requirements to the General Assembly, please clarify whether DHCD expects a formal scoring methodology or whether grantees may use operationally appropriate triage processes. For example, households presenting with a Writ of Eviction may receive same-day assistance, while households with a Pay or Quit Notice are scheduled as appointments become available. We recommend allowing flexibility for grantees to implement prioritization processes that align with local court operations and service delivery.
Fiscal Management
The fiscal management section requires reporting of significant transactions to the CEO. Since many local governments and public entities do not have a Chief Executive Officer, clarification/inclusion of the intended equivalent positions would be helpful (e.g., City Manager, Executive Director, or other authorized official).
Payment Process Questions
What documentation will be required to receive subsequent payments? It is critical that clear, consistent and as simple as possible reimbursement paperwork be required as possible. A template provided upon award is critical to success and ongoing training around reimbursement processes. In addition, a clear and consistent appeal process and quick timelines are needed when reimbursements are denied or additional documentation is needed.