Emergency Rental Assistance Program — Program Improvement Plan Form (U.S. Department of the Treasury)
Summary
The U.S. Department of the Treasury's form of Program Improvement Plan for the Emergency Rental Assistance Program, covering ERA1 funds under the Consolidated Appropriations Act, 2021 and ERA2 funds under the American Rescue Plan Act of 2021. It states that grantees that obligated less than 65% of their ERA1 allocations by September 30, 2021 must submit a plan by November 15, 2021 to avoid an excess funds determination equal to 10% of their initial allocation. The form asks a grantee to check which Treasury-recommended practices it uses, such as self-attestation of income and eviction-diversion partnerships with courts, and to name discouraged practices it keeps, such as collecting Social Security numbers. It then asks for key obstacles, at least three improvement actions and monthly ERA1 projections for November 2021 through February 2022. The form is unfilled.
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- Ppr Int Dd05F2C15Dffd30B Program Improvement Plan Form D92Bb001C8
Cite this document
“Emergency Rental Assistance Program — Program Improvement Plan Form (U.S. Department of the Treasury).”
Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/ppr-int-dd05f2c15dffd30b-program-improvement-plan-form-d92bb001c8/
, SHA-256 5221d09086db1528560e96b618098cd475567d698a05948496a3c18fc051e074.Full text
EMERGENCY RENTAL ASSISTANCE PROGRAM
U.S. DEPARTMENT OF THE TREASURY
Program Improvement Plan
This form of Program Improvement Plan has been developed to improve the delivery of
emergency rental assistance (ERA) funds under the Consolidated Appropriations Act, 2021 and
the American Rescue Plan Act of 2021. The assistance authorized by the Consolidated
Appropriations Act, 2021 is referred to as “ERA1.” The assistance authorized by the American
Rescue Plan Act of 2021 is referred to as “ERA2.”
The Consolidated Appropriations Act, 2021 requires the U.S. Treasury Department to begin
reallocating “excess” ERA1 funds beginning on September 30, 2021. Treasury issued
Reallocation Guidance, available on Treasury’s website, under which grantees that obligated
less than 65% of their ERA1 allocations by September 30, 2021, or that do not provide an
Obligated Funds Certification as described in the guidance, must submit for Treasury’s approval
a Program Improvement Plan no later than November 15, 2021 in order to avoid an excess
funds determination equal to 10% of the grantee’s initial allocation. A grantee may also submit
a Program Improvement Plan to mitigate an excess funds determination that would result from
an insufficient expenditure ratio based on the grantee’s reported expenditures through
September 30, 2021.
In this Program Improvement Plan, the undersigned grantee (Grantee) will:
1. Assess the Grantee’s ERA1 program by identifying (i) policies and practices
recommended by Treasury that the Grantee has already implemented; (ii) whether the
Grantee has adopted any policies or practices that Treasury has discouraged; and (iii)
key obstacles to delivering ERA assistance to eligible households in the Grantee’s
jurisdiction;
2. Document actions the Grantee will take to improve program performance; and
3. Project the Grantee’s ERA1 expenditures through February 2022.
1. Assess the Grantee’s ERA1 Program
A. Identify policies and practices implemented by the Grantee
Please indicate which of the following recommended policies or practices that the Grantee has
already implemented. Note that the policies and practices that Treasury most strongly
encourages are listed in bold type.
Application, Accessibility, and Prioritization
The Grantee’s application process:
Provides the opportunity to apply in-person
OMB Approved No.: 1505-0266
Exp.: 11/30/2021
Provides the opportunity to apply over the phone
Provides the opportunity to apply online
Includes a mobile-friendly option to facilitate submitting an application with a smartphone
Applies user-friendly website and application design practices
Partners with community-based organizations, tenant organizations or trusted community
leaders to provide tenants with application assistance
Ensures all application methods adopted by the Grantee are equally available and accessible by
individuals with disabilities
Ensures all application methods adopted by the Grantee are available in languages other than
English
If so, please list the languages
______________________________________________________
Prioritizes applications from households at high risk of eviction or facing other immediate
threats to housing stability
Provides applicants a way to check on their application status
Determination of Household Eligibility
The Grantee:
Does not create additional eligibility requirements beyond those required by the statute
Partners with a neighboring jurisdiction on application policies, program terms and intake
procedures to ensure regional consistency
Relies on a tenant’s self-attestation for purposes of determining whether an applicant has
experienced a qualifying financial hardship (see sample application screen: COVID-19
Pandemic Impact)
Allows for self-attestation to establish that a tenant is at risk of housing instability or
homelessness (see sample application screen: Risk of Housing Instability or Homelessness)
Accepts a self-attestation of income when determining an applicant’s income eligibility
Has defined a fact-specific proxy for purposes of supporting the determination of applicants’
income eligibility (see sample application screen: Income-Fact Specific Proxy)
Uses categorical eligibility when available to confirm an applicant’s income eligibility (see
sample application screen: Income-Categorical Eligibility)
Combines self-attestation with other reasonable policies and procedures to document where
the applicant resides and the applicant’s monthly rent payment in cases where the lease is
either unwritten or there is no available copy (see application screen: Residence and Monthly
Rent)
Allows tenants of public housing and other federally assisted housing to apply
Eviction Diversion, Housing Stability Services, and Legal Services
The Grantee:
Has an eviction-diversion partnership with one or more courts that hear eviction cases from
the grantee’s jurisdiction
If applicable, check any components of the diversion program:
Provides tenants access to an advocate or other legal assistance
Made available before the filing of an eviction complaint or pleading
2
Provides alternative(s) to formal court process (e.g., alternative dispute
resolution)
Provides opportunity to apply for ERA and housing stability services
Participation is mandatory
Supported by policies that direct parties to apply for ERA before filing and that
halt the eviction process where an application is initiated
Court-based or otherwise implemented through formal collaboration with the
court
Provides information to judges, magistrates, court clerks, and other relevant court officials and
sheriffs or law enforcement about the availability of ERA funds for tenant assistance and
housing stability services and the importance of offering these services as early as possible in, or
prior to the initiation of, the eviction process
Works with eviction court(s) to provide information about ERA program assistance to tenants
and landlords as early in the adjudication process as possible
Refers ERA applicants to non-profit organizations for legal assistance
Expends funds to support legal assistance to tenants at risk of eviction
Refers ERA applicants to non-profit organizations for housing stability services
Expends funds on housing stability services provided by community-based and nonprofit
organizations to keep people housed and meet essential household needs
Refers ERA applicants to non-profit organizations for culturally and linguistically relevant
housing stability services
Expends funds to support housing stability services or legal assistance that are culturally and
linguistically relevant to populations with limited English proficiency
Provides tenants with information about non-profit organizations that provide housing stability
services on the ERA website and in the application
As a condition to receiving ERA funds paid on a tenant’s behalf, requires a landlord’s agreement
not to evict the tenant for nonpayment of rent for 30 to 90 days longer than the period covered
by the rental assistance
Requires landlords and utility companies receiving funds for rental or utility payment arrears to
terminate any debt collection actions and inform credit reporting agencies of the matter’s
resolution
Marketing and Outreach
The Grantee:
Advertises the ERA program in print, television, radio, or online media specifically targeted to
groups that may experience barriers to accessing ERA resources
Advertises the ERA program in print, television, radio, or online media in languages other than
English
If so, please list the languages
______________________________________________________
Includes measures specially targeted to landlords that own or operate fewer than 10 units in
its program outreach efforts
Conducts outreach to landlords through landlord and real-estate associations
3
Provides funding to community-based organizations, promotoras, tenant organizations, or
trusted community leaders to support ERA outreach efforts, application assistance or
navigation services
Coordinates with other health and social service providers serving low-income communities to
identify and reach individuals who may qualify for the ERA program
Engages utility companies or agencies that administer the Low Income Home Energy Assistance
Program (LIHEAP) to inform low-income tenants about the ERA program
Targets its outreach practices based on social vulnerability index scores, risk of evictions, or
other data-driven measures of housing insecurity
Markets the ERA program through community institutions such as libraries, public schools,
grocery stores, community centers, and health clinics
Payments
The Grantee:
Makes bundled payment arrangements with landlord or utility providers that serve more than
10 eligible tenants
Provides the tenant and landlord notice immediately upon approval of an application and prior
to payment processing
Offers electronic payments to tenants and landlords
On average, makes payments less than two weeks after application approval
Program Design
The Grantee:
Provides tenants the opportunity to apply and receive funds directly when landlords decline
to participate in the application process
Collaborates with another ERA grantee to achieve administrative efficiencies or to prevent
duplication of assistance
Notifies one or more utility companies about ERA applications in process to secure a payment
grace period or service restoration for the applicant households
Will accept technical assistance when offered to strengthen the ERA program
Has created a publicly viewable data dashboard or program progress report
Has developed a risk-mitigation plan for fraud
Protects personally identifiable information (PII) of tenants, including by not collecting Social
Security numbers
4
B. Discouraged Practices
In the box below, please identify any practices or policies expressly discouraged by Treasury’s
FAQ guidance the Grantee believes are warranted for its ERA program and intends to continue.
Examples include failing to allow tenants to apply directly when landlords do not participate;
prohibiting applications from residents of federally assisted housing; establishing eligibility
requirements beyond those required by statute or Treasury’s FAQs; and collecting Social
Security numbers or other unnecessary personally identifiable information (PII) from applicants.
At its option, the Grantee may provide further details and explanation under separate cover.
Discouraged Practices
5
C. Identify key obstacles
In the boxes below, please identify the key obstacles to increasing the amount of ERA1 funds
the Grantee expends on assistance to eligible households and increasing the number of
households served by the Grantee’s ERA1 program on a monthly basis.
Obstacle # 1
Obstacle # 2
Obstacle #3
6
2. Actions for Program Improvement
In the boxes below, please list at least three specific actions that the Grantee will take to
improve the performance of its ERA1 program, including to increase the amount of ERA1 funds
the Grantee expends on assistance to eligible households and increase the number of
households served by the Grantee’s ERA1 program on a monthly basis. To the maximum extent
possible, the Grantee’s improvements should include policies and practices identified in bold in
Section A above as those that Treasury most strongly encourages.
Improvement Action # 1
Improvement Action # 2
Improvement Action #3
Improvement Action #4
Improvement Action #5
7
3. Projected ERA1 expenditures
Please provide reasonable monthly projections of the Grantee’s ERA1 program’s expenditures
and activities over the next four months.
November 2021
Number of unique households that will be assisted
Amount of assistance to eligible households $
expended
Number of applications submitted
December 2021
Number of unique households that will be assisted
Amount of assistance to eligible households $
expended
Number of applications submitted
January 2022
Number of unique households that will be assisted
Amount of assistance to eligible households $
expended
Number of applications submitted
February 2022
Number of unique households that will be assisted
Amount of assistance to eligible households $
expended
Number of applications submitted
Do you anticipate providing rental assistance between November 2021 and February 2022
funded with a source other than ERA1 (e.g. ERA2, State and Local Fiscal Recovery Funds, other
funds made available by a state or local entity)?
Yes
No
If yes, please describe in the box below the sources of funding other than ERA1 that you
anticipate will support the Grantee’s provision of rental assistance, and provide a projection for
the next four months of the number of households that will receive such assistance and the
amount to be expended.
8
Other Funding Sources
Projection
Month* Number of Households Amount
1. , 20 $
2. , 20 $
3. , 20 $
4. , 20 $
*The projection should begin with the first full month following plan submission.
9
Contact Information for Program Administrator:
For questions related to implementation of this plan, please list a program administrator contact:
Name: ____________________________________
Title: ____________________________________
Email: ____________________________________
Office phone: ____________________________________
Mobile phone: ____________________________________
Signature
[ERA GRANTEE]
By: Date: , 20
[Official’s Name]
[Official’s Title]
PAPERWORK REDUCTION ACT NOTICE: The information collected will be used for the U.S. Government to determine the
reallocation of emergency rental assistance funds. The estimated burden associated with this collection of information is 120
minutes per response. Comments concerning the accuracy of this burden estimate and suggestions for reducing this burden
should be directed to the Office of Privacy, Transparency and Records, Department of the Treasury, 1500 Pennsylvania Ave.,
N.W., Washington, D.C. 20220. DO NOT send the form to this address. An agency may not conduct or sponsor, and a person is
not required to respond to, a collection of information unless it displays a valid control number assigned by OMB.
PRIVACY ACT STATEMENT
AUTHORITY: Solicitation of this information is authorized by section 501 of division N of the Consolidated Appropriations Act,
2021 (the “Act”)
PURPOSE: The Act requires Treasury to allocate funds to eligible grantees for the delivery of emergency rental assistance to
eligible households. Eligible grantees include states, local governments, U.S. territories, Tribes or Tribally Designated Housing
Entities (TDHEs), as applicable, and the Department of Hawaiian Home Lands. Treasury maintains contact information for
authorized representatives and contact persons of the ERA grantees for the purpose of communicating with ERA grantees
regarding the administration of their award under the Act.
ROUTINE USES: The information you furnish may be shared in accordance with the routine uses outlined in the Treasury’s
system of records notice, Treasury .017 – Correspondence and Contact Information, which can be found at 81 FR 78266 (Nov. 7,
2016).
DISCLOSURE: Disclosure of this information is voluntary. However, grantees/recipients that do not disclose contact
information will be unable to communicate with Treasury on issues related to their obligations under the Act which may affect
the status of their award.
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