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Homelessness Resolution Program Monitoring Guide

Homelessness Resolution Program (HRP) Overview

The Homelessness Resolution Program (HRP) in Colorado, like in other states, is designed to assist individuals and families who are homeless or at risk of homelessness. Here's an overview of the HRP program background specific to Colorado:

Program Background: The U.S. Department of Housing and Urban Development (HUD) grants HRP funds to states and local communities to address homelessness. In Colorado, these funds are administered by the Colorado Department of Local Affairs (DOLA). Colorado's Homelessness Resolution Program is vital to the state's broader strategy to combat homelessness and ensure access to safe and stable housing for all residents. HRP ensures that individuals and families can access safe and stable housing.

Eligible Activities: The HRP program in Colorado supports a range of activities, including:

  • Emergency shelter operations and services
  • Homelessness prevention assistance, such as rental assistance and utility payments
  • Rapid rehousing services, including housing search assistance, short-term rental assistance, and case management
  • A homeless management information system (HMIS) supports the collection of data on homelessness and tracking outcomes
  • Street Outreach supports outreach efforts to identify and engage individuals and families experiencing homelessness, especially those living on the streets or in other places not meant for human habitation.

Target Population: The HRP program serves individuals and families who are homeless or at risk of homelessness, including those fleeing domestic violence, youth, veterans, and individuals with disabilities.

Partnerships: HRP funds typically grant funding to local governments, non-profit organizations, and other community-based agencies that provide housing resources and supportive services to homeless individuals and families. Collaboration between government agencies, service providers, and community stakeholders is essential for the program's effective implementation.

Reporting and Compliance: Colorado's recipients of HRP funds must comply with HUD regulations and reporting requirements, including data collection, performance monitoring, and fiscal accountability. Accurate reporting ensures transparency and accountability in the use of federal funds.

Impact: The HRP program addresses homelessness and housing instability in Colorado by providing essential support services and resources to vulnerable populations. It contributes to efforts to reduce homelessness, increase housing stability, and improve the overall well-being of individuals and families in the state.

Colorado's Homelessness Resolution Program is vital to the state's broader strategy to combat homelessness and ensure access to safe and stable housing for all residents.

Purpose of Monitoring

This Monitoring Guide outlines the process and procedures used by the State of Colorado’s Division of Housing (DOH) HRP program to ensure compliance with Local, State, and Federal laws and requirements for the Homelessness Resolution Program (HRP). HRP CDOH encourages each subrecipient to share this guide with their employees and members of the organization involved in administering or overseeing the HRP-funded programs.

HRP program staff conduct monitoring to ensure compliance with the Homelessness Resolution Program (HRP) requirements, which include verifying program compliance, reviewing financial records, and evaluating administrative structures and practices. The primary goals of the on-site compliance visit are to ensure compliance with HRP requirements, which include verifying participant eligibility, eligible activities, unit requirements, financial management, data collection and reporting, and other federal requirements. Additionally, staff will evaluate organizational and project performance during the visit.

New subrecipients will be monitored within the first year of their grant agreement. Subrecipients are scheduled for ongoing on-site monitoring based on risk factors identified during the scoring of each subrecipient risk analysis assessment. Additionally, the HRP office conducts quarterly Desk Monitoring of all HRP subrecipients, which consists of reviewing financial source documentation for at least one reimbursement request per Subrecipient per quarter. Supporting documentation is reviewed for accuracy and eligibility. Each Subrecipient will have at least four requests reviewed annually; desk monitoring may also include reviewing client files, program policies, procedures, financial policies, etc.  

All DOH HRP subrecipients are expected to use HRP funds according to HUD guidelines, regardless of funding source. These regulations can be found on the HUD Exchange website.

Monitoring Selection Process

As a part of the grant management process for every HRP grant agreement or cycle, DOH HRP carries out a risk analysis. Typically, at least 20% of grant agreements undergo monitoring. It is important to note that HRP will require on-site monitoring for non-compliance during desk monitoring, which categorizes the subrecipient as high-risk. DOH monitors HRP-funded organizations based on perceived risk, which includes, but is not limited to:

  1. Monitoring History: Agencies that have not been monitored at least once during the previous three years.
  2. Financial Management: If payment requests show ineligible costs or prolonged spending, there is an increased risk of monitoring.
  3. New Subrecipients or Activities: New subrecipients or those performing a new HRP activity will undergo monitoring.
  4. Compliance Issues: Indicators of inadequate grant management or observations from visual inspections that signal the subrecipient needs to execute funded activities more effectively will undergo monitoring.
  5. Organizational Changes: Consistent staff turnover, restructuring, or other changes in the HRP program may increase the risk of monitoring.

Subrecipient Preparation for Monitoring

Organizations and local governments funded by DOH HRP will undergo monitoring for compliance with the Homelessness Resolution Program (HRP) regulations, guidelines, and procedures. On-site monitoring visits typically last one day, and key staff members (such as the Executive Director, Program Manager, and Finance Controller) must be available throughout or as specifically requested. During desk reviews, we require a representative from your organization to be available during the scheduled monitoring to clarify the documentation under review readily.

The monitoring visit is comprised of the following:

  • Notification and Preparation: HRP staff will formally notify the subrecipient, specifying the monitoring dates and relevant exhibits. HRP staff will also ensure that the subrecipient receives the necessary monitoring tools for a successful monitoring process, including the option for an Entrance conference. An entrance conference during monitoring is an initial meeting between the monitoring team and HRP staff. It aims to establish the monitoring process's scope, objectives, and procedures, clarify expectations, and address any initial questions or concerns.
  • Review Process: We highly encourage subrecipients to review the formal monitoring notification letter provided carefully and promptly contact HRP staff if they have any questions or require clarification regarding the letter's content or the requested documents.
  • During the Review: The subrecipient should have staff available for HRP staff to contact if further information or clarification is needed.

Monitoring Results

  • Recommendations: A suggestion or proposal for action to ensure program compliance and encourage best practices.
  • Concerns: A concern is a deficiency in program performance that is not based on regulatory or other programmatic requirements. A concern will likely lead to a finding if it is not corrected. This report will identify any Concern(s) that, like Findings, require corrective measures by the Sub-recipient by the date indicated on this report, including a written response detailing the corrective action (s) to our office.
  • Findings: A 'finding' refers to any issue, discrepancy, or violation found during the monitoring process. The severity of the findings can range from minor administrative errors to significant non-compliance with HUD regulations or program requirements. If a finding is identified, the State must notify the Sub-recipient and provide details regarding corrective measures. The Sub-recipient must take corrective measures by the date indicated in the report and submit a written response detailing the corrective measures. Failure to correct the identified issues may result in the repayment of HUD funds to the State.

Post-Monitoring Process

  • Summary and Feedback: After the review, the subrecipient will receive a monitoring letter, including a summary of the results. Subrecipients can request an exit interview for further discussion, though this is not mandatory. If no findings or concerns are found, nothing further will be required. The monitoring records will be kept on file and may be used for future funding considerations.
  • Corrective Action Plan (CAP): A Corrective Action Plan (CAP) will be in place if any findings are identified during the review. The subrecipient will collaborate with HRP staff to address and rectify any identified issues and work toward compliance. Your corrective action submission must include a plan detailing how the organization will take steps to ensure the finding/concern won’t happen again. This plan should outline the internal control measures, training, and how the organization will ensure that all client files follow HUD policy and the HRP Monitoring Guide.
  • Curing process: As applicable, subrecipients will have 30 days to correct or cure any deficiencies. After 30 days, the subrecipients will submit documentation to the monitor. If findings or concerns remain unresolved after 30 days, the monitor will develop a Corrective Action Plan (CAP).

Helpful Tips

  • Subrecipients are encouraged to create a ‘Core Documents’ grant file that includes a copy of the executed grant agreement; any HUD or HRP correspondence mailed or received about the funded activity; monthly financial submissions; training materials received or reviewed; the funded activity’s procedures manual, etc.
  • Have a workspace for the monitors to comfortably work without disrupting the organization’s regular workday routine.
  • Please be prepared to give the monitors a tour of the facility during on-site visits.
  • If applicable, be available for the entrance and exit conference.
  • Respond to the corrective actions in the monitoring report within the allotted time (if applicable).
  • HRP staff aim to ensure that clients meet eligibility requirements and that their expenses qualify as allowable. A random client file will be selected for examination during the review process.

HRP Monitoring Tools

This form should be used to report problems or issues with this website. Questions pertaining to a program or service provided by DOH should be addressed to contact information located on the specific program pages.

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