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Agenda 03/22/2022 Item #16D2 (Emergency Rental Assistance 1 & 2 Programs Updates)03/22/2022 EXECUTIVE SUMMARY Recommendation to approve updates to the Emergency Rental Assistance 1 and 2 programs from the U.S. Department of Treasury to expand allowable activities for households seeking assistance to include payments to collection agencies and allowing for the payment of fees required by landlords under these programs. OBJECTIVE: To continue to provide grant funding to Collier County residents unable to pay rent and utilities due to the impacts of the COVID-19 pandemic. CONSIDERATIONS: On January 5, 2021, the U.S. Department of Treasury announced funding available to state and local governments to provide financial support to residents that are unable to pay rent and utilities due to the impacts of the COVID-19 pandemic. Collier County was eligible for this funding since our resident population exceeds 200,000 per the Consolidated Congressional Act of 2021. The Emergency Rental Assistance (ERA) 1 Program made available $25 billion to assist nationwide. On January 26, 2021, Agenda Item #16D7, the Board of County Commissioners (Board) accepted the ERA 1 funding in the amount of $11,622,381. On March 25, 2021, the County was notified that the US Treasury had modified our award terms, extending the award and administrative cost terms. On June 8, 2021, Agenda Item #16D1 the Board accepted the amendment to ERA 1. On March 11, 2021, President Biden signed the American Rescue Plan (ARP) which included additional funds and created the Emergency Rental Assistance Program 2 (ERA 2). These funds were received by the County on May 10, 2021. On June 08, 2021, Agenda Item #16D1, the Board accepted the ERA 2 funding in the amount of $9,088,102. On October 12, 2021, Item#10B, the Board accepted changes to further streamlining eligibility and expanding allowable activities under the program based on US Treasury guidance issued on August 4, 2021. To ensure that assistance is made available to all who qualify, further expanding allowable activities for the County's Emergency Rental Assistance 1 and 2 programs is necessary and includes the following: Individual Assistance (Rental, Utilities, and Housing Stability Payment) 1. Allow payments to be made directly to a collection agency after the tenant no longer resides in the unit. On October 12, 2021, the Board of County Commissioners approved payments to landlords after tenants vacated the property, however, if the account has been turned over for collection, the landlord typically will not accept payments. To assist with credit repair, it is necessary for the County to issue payments directly to the collection agency, in order to remove barriers a household may face in accessing new housing, avoid further collection efforts, and credit damage. 2. Provide additional assistance to applicants seeking a new rental property by allowing the following: Payments on behalf of the applicants to the new landlords for first month’s rent, last month’s rent, and initial fees including, but not limited to, security deposit, application fee, utility fees, pet fees, or any other fees associated with obtaining a new lease agreement. FISCAL IMPACT: There is no new Fiscal impact with this amendment. The funding source for this 16.D.2 Packet Pg. 658 03/22/2022 grant is Community & Human Services Grant Fund (705) Projects 33734 and 33761. GROWTH MANAGEMENT IMPACT: There is no Growth Management impact associated with this item. LEGAL CONSIDERATIONS: This item is approved for form and legality and requires a majority vote for Board action. -JAB RECOMMENDATION: To approve updates to the Emergency Rental Assistance 1 and 2 programs from the U.S. Department of Treasury to expand allowable activities for households seeking assistance to include payments to collection agencies and allowing for the payment of fees required by landlords under these programs. Prepared By: Jennessee Delgado, Grant Coordinator, Community and Human Services Division ATTACHMENT(S) 1. US Treasury Agreement amendment (PDF) 2. US Treasury Agreement (PDF) 3. AGREEMENT TERMS DOT ERA2 - executed (PDF) 4. ERA EXECUTIVE SUMMARY 10.12.21 (PDF) 16.D.2 Packet Pg. 659 03/22/2022 COLLIER COUNTY Board of County Commissioners Item Number: 16.D.2 Doc ID: 21345 Item Summary: Recommendation to approve updates to the Emergency Rental Assistance 1 and 2 programs from the U.S. Department of Treasury to expand allowable activities for households seeking assistance to include payments to collection agencies and allowing for the payment of fees required by landlords under these programs. Meeting Date: 03/22/2022 Prepared by: Title: – Community & Human Services Name: Jennesse Delgado 02/11/2022 10:06 AM Submitted by: Title: Manager - Federal/State Grants Operation – Community & Human Services Name: Kristi Sonntag 02/11/2022 10:06 AM Approved By: Review: Community & Human Services Kristi Sonntag CHS Review Completed 02/15/2022 3:40 PM Community & Human Services Donald Luciano Additional Reviewer Completed 02/17/2022 6:03 PM Community & Human Services Maggie Lopez Additional Reviewer Completed 02/22/2022 9:23 AM Operations & Veteran Services Kimberley Grant Additional Reviewer Completed 02/22/2022 11:21 AM Public Services Department Todd Henry PSD Level 1 Reviewer Completed 02/22/2022 12:49 PM Public Services Department Tanya Williams PSD Department Head Review Completed 02/23/2022 9:39 AM Grants Erica Robinson Level 2 Grants Review Completed 02/24/2022 2:14 PM County Attorney's Office Jennifer Belpedio Level 2 Attorney of Record Review Completed 03/07/2022 4:17 PM Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 03/08/2022 8:54 AM Growth Management Operations Support Christopher Johnson Additional Reviewer Completed 03/09/2022 9:34 AM County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 03/10/2022 4:31 PM Grants Therese Stanley Additional Reviewer Completed 03/11/2022 2:52 PM County Manager's Office Dan Rodriguez Level 4 County Manager Review Completed 03/14/2022 9:50 AM Board of County Commissioners Geoffrey Willig Meeting Pending 03/22/2022 9:00 AM 16.D.2 Packet Pg. 660 U.S. DEPARTMENT OF THE TREASURY EMERGENCY RENTAL ASSISTANCE March 26, 2021 Effective as of the date hereof, the award terms accepted by Recipient as a condition to the receipt of payment from Treasury pursuant to section 501 of Subdivision N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) are amended as follows: Section 3 is amended by replacing “December 31, 2021” with “September 30, 2022”. Section 4 is deleted in its entirety and replaced with the following: 4. Administrative costs. a. Recipient may use funds provided to the Recipient to cover both direct and indirect costs. b. The total of all administrative costs, whether direct or indirect costs, may not exceed 10 percent of the total amount of the total award. Attached hereto are the award terms restated to reflect this amendment. 16.D.2.a Packet Pg. 661 Attachment: US Treasury Agreement amendment (21345 : ERA Grants Allowable Activities) 2 U.S. DEPARTMENT OF THE TREASURY EMERGENCY RENTAL ASSISTANCE Use of Funds. Recipient understands and agrees that the funds disbursed under this award may only be used for the purposes set forth in Section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) (referred to herein as “Section 501”). Repayment and reallocation of funds. a. Recipient agrees to repay excess funds to Treasury in the amount as may be determined by Treasury pursuant to Section 501(d). Such repayment shall be made in the manner and by the date, which shall be no sooner than September 30, 2021, as may be set by Treasury. b. The reallocation of funds provided by Section 501(d) shall be determined by Treasury and shall be subject to the availability of funds at such time. Availability of funds. a. Recipient acknowledges that, pursuant to Section 501(e), funds provided under this award shall remain available only through September 30, 2022, unless, in the case of a reallocation made by Treasury pursuant to section 501(d), Recipient requests and receives from Treasury an extension of up to 90 days. b. Any such requests for extension shall be provided in the form and shall include such information as Treasury may require. c. Amounts not expended by Recipient in accordance with Section 501 shall be repaid to Treasury in the manner specified by Treasury. Administrative costs. a. Recipient may use funds provided to the Recipient to cover both direct and indirect costs. b. The total of all administrative costs, whether direct or indirect costs, may not exceed 10 percent of the total amount of the total award. Reporting. a. Recipient agrees to comply with any reporting obligations established by Treasury, including the Treasury Office of Inspector General, as relates to this award, including but not limited to: (i) reporting of information to be used by Treasury to comply with its public reporting obligations under section 501(g) and (ii) any reporting to Treasury and the Pandemic Response Accountability Committee that may be required pursuant to section 15011(b)(2) of Division B of the Coronavirus Aid, Relief, and Economic Security Act (Pub. L. No. 116-136), as amended by Section 801 of Division O of the Consolidated Appropriations Act, 2021 (Pub. L. No. 116-260). Recipient acknowledges that any such information required to be reported pursuant to this section may be publicly disclosed. b. Recipient agrees to establish data privacy and security requirements as required by Section 501(g)(4). 16.D.2.a Packet Pg. 662 Attachment: US Treasury Agreement amendment (21345 : ERA Grants Allowable Activities) 3 Maintenance of and Access to Records a. Recipient shall maintain records and financial documents sufficient to support compliance with Section 501(c) regarding the eligible uses of funds. b. The Treasury Office of Inspector General and the Government Accountability Office, or their authorized representatives, shall have the right of access to records (electronic and otherwise) of Recipient in order to conduct audits or other investigations. c. Records shall be maintained by Recipient for a period of five (5) years after all funds have been expended or returned to Treasury. Cost Sharing. Cost sharing or matching funds are not required to be provided by Recipient. Compliance with Applicable Law and Regulations. a. Recipient agrees to comply with the requirements of Section 501 and Treasury interpretive guidance regarding such requirements. Recipient also agrees to comply with all other applicable federal statutes, regulations, and executive orders, and Recipient shall provide for such compliance in any agreements it enters into with other parties relating to this award. b. Federal regulations applicable to this award include, without limitation, the following: i. Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 C.F.R. Part 200, other than such provisions as Treasury may determine are inapplicable to this Award and subject to such exceptions as may be otherwise provided by Treasury. Subpart F – Audit Requirements of the Uniform Guidance, implementing the Single Audit Act, shall apply to this award. ii. Universal Identifier and System for Award Management (SAM), 2 C.F.R. Part 25 and pursuant to which the award term set forth in Appendix A to 2 C.F.R. Part 25 is hereby incorporated by reference. iii. Reporting Subaward and Executive Compensation Information, 2 C.F.R. Part 170, pursuant to which the award term set forth in Appendix A to 2 C.F.R. Part 170 is hereby incorporated by reference. iv. OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), 2 C.F.R. Part 180 (including the requirement to include a term or condition in all lower tier covered transactions (contracts and subcontracts described in 2 C.F.R. Part 180, subpart B) that the award is subject to 2 C.F.R. Part 180 and Treasury’s implementing regulation at 31 C.F.R. Part 19. v. Recipient Integrity and Performance Matters, pursuant to which the award term set forth in 2 C.F.R. Part 200, Appendix XII to Part 200 is hereby incorporated by reference. vi. Governmentwide Requirements for Drug-Free Workplace, 31 C.F.R. Part 20. vii. New Restrictions on Lobbying, 31 C.F.R. Part 21. 16.D.2.a Packet Pg. 663 Attachment: US Treasury Agreement amendment (21345 : ERA Grants Allowable Activities) 4 c. Statutes and regulations prohibiting discrimination applicable to this award, include, without limitation, the following: i. Title VI of the Civil Rights Act of 1964 (42 U.S.C. §§ 2000d et seq.) and Treasury’s implementing regulations at 31 C.F.R. Part 22, which prohibit discrimination on the grounds of race, color, or national origin under programs or activities receiving federal financial assistance; ii. The Fair Housing Act, Title VIII-IX of the Civil Rights Act of 1968 (42 U.S.C. § 3601 et seq.), which prohibits discrimination in housing on the basis of race, color, national origin, sex, familial status, or disability; iii. Section 504 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794), which prohibits discrimination on the basis of handicap under any program or activity receiving or benefitting from federal assistance; iv. The Age Discrimination Act of 1975, as amended (42 U.S.C. §§ 6101 et seq.) and Treasury’s implementing regulations at 31 C.F.R. Part 23, which prohibit discrimination on the basis of age in programs or activities receiving federal financial assistance; and v. The Americans with Disabilities Act of 1990, as amended (42 U.S.C. §§ 12101 et seq.), which prohibits discrimination on the basis of disability under programs, activities, and services provided or made available by state and local governments or instrumentalities or agencies thereto. False Statements. Recipient understands that false statements or claims made in connection with this award may result in fines, imprisonment, debarment from participating in federal awards or contracts, and/or any other remedy available by law. Publications. Any publications produced with funds from this award must display the following language: “This project [is being] [was] supported, in whole or in part, by federal award number [enter project FAIN] awarded to [name of Recipient] by the U.S. Department of the Treasury.” Debts Owed the Federal Government. a. Any funds paid to Recipient (1) in excess of the amount to which Recipient is finally determined to be authorized to retain under the terms of this award; (2) that are determined by the Treasury Office of Inspector General to have been misused; or (3) that are not repaid by Recipient as may be required by Treasury pursuant to Section 501(d) shall constitute a debt to the federal government. b. Any debts determined to be owed the federal government must be paid promptly by Recipient. A debt is delinquent if it has not been paid by the date specified in Treasury’s initial written demand for payment, unless other satisfactory arrangements have been made. Interest, penalties, and administrative charges shall be charged on delinquent debts in accordance with 31 U.S.C. § 3717 and 31 C.F.R. § 901.9. Treasury will refer any debt that is more than 180 days delinquent to Treasury’s Bureau of the Fiscal Service for debt collection services. c. Penalties on any debts shall accrue at a rate of not more than 6 percent per year or such other higher rate as authorized by law. Administrative charges, that is, the costs of processing and handling a delinquent debt, shall be determined by Treasury. 16.D.2.a Packet Pg. 664 Attachment: US Treasury Agreement amendment (21345 : ERA Grants Allowable Activities) 5 d. Funds for payment of a debt must not come from other federally sponsored programs. Disclaimer. a. The United States expressly disclaims any and all responsibility or liability to Recipient or third persons for the actions of Recipient or third persons resulting in death, bodily injury, property damages, or any other losses resulting in any way from the performance of this award or any other losses resulting in any way from the performance of this award or any contract, or subcontract under this award. b. The acceptance of this award by Recipient does not in any way constitute an agency relationship between the United States and Recipient. Protections for Whistleblowers. a. In accordance with 41 U.S.C. § 4712, Recipient may not discharge, demote, or otherwise discriminate against an employee as a reprisal for disclosing information to any of the list of persons or entities provided below that the employee reasonably believes is evidence of gross mismanagement of a federal contract or grant, a gross waste of federal funds, an abuse of authority relating to a federal contract or grant, a substantial and specific danger to public health or safety, or a violation of law, rule, or regulation related to a federal contract (including the competition for or negotiation of a contract) or grant. b. The list of persons and entities referenced in the paragraph above includes the following: i. A member of Congress or a representative of a committee of Congress; ii. An Inspector General; iii. The Government Accountability Office; iv. A Treasury employee responsible for contract or grant oversight or management; v. An authorized official of the Department of Justice or other law enforcement agency; vi. A court or grand jury; and/or vii. A management official or other employee of Recipient, contractor, or subcontractor who has the responsibility to investigate, discover, or address misconduct. c. Recipient shall inform its employees in writing of the rights and remedies provided under this section, in the predominant native language of the workforce. Increasing Seat Belt Use in the United States. Pursuant to Executive Order 13043, 62 FR 19217 (April 8, 1997), Recipient should and should encourage its contractors to adopt and enforce on-the-job seat belt policies and programs for their employees when operating company-owned, rented or personally owned vehicles. Reducing Text Messaging While Driving. 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"ƠË ¯Ïƿ%Ɓƽƿbā)ƿƿ fƿ^t @ƿƿÜSơƿ'ƿƂƿ nƵƿ ĈB F UľX 9ƿ*ƃƿ'ƿ ƿŉ% Ìƿ¸A 70h° 9ƿ ƿ bĂĿoƿ ƿ fƄƿ "#ƿ ÷ƿ 3ò ƿ Ŧ ƿ ƅ % ƿ ƶĕƿ!ƿ !ƿ slŀŞNƿƿ ĭ & ƿ 7Ɔƿ Pƿ *± ²3ŭƿƿĉ ƿĮƿ#ŖƿƿƷ'm ƿøƿv!ƿ6 ! ƿƿ"įƓƿ ƿC ƿ ƿ&ƿƢƿ l ƿƣİ ƿ ƭ ƿƿƿ+ŋĊ³ .E´ ÚƇıĐƿ: ƿÐŗƤƿJƿƿ>ƿJ ƿ: ƥµƿ_ƮC ƿ ƿÓƹTR0 ƿß ƿ.8¹E8ƿÃDƿÖH [\D¼ÄƿƈŁ)ƿÇƿ ½È\ÅƿâĲƿ!%ƿƿ,ƯƿC' ƿ0 ƿ 5uƿ Ūƿƿ` c ƿy,ŊƿƿŘzƿĳƿƿ# ƿċƉƿ ł5ƿ?ƿ }!ƿ #w /+ƿ ƿ ƿ rşƿ2ƿ !Ĵ .Á¶ G*kdƿIƺ ƿÝđĵdƿêŃƿ^ ń ĶĒ·ƿ á*{ŧƿƦƿÔƻưz7ƿà1ƿ.8Â[8ƿ G# Ɣ,*ƿKS ƿķƧƿ"pƿT$Ɗ#ƿ ƿ tQƋƿ(ƿ; ƿŨƿČƿm ,ƿ$ƿ Ƽƨƿ ĸ ƿV,ƿU ƿ ƿ3#&(ƿ!Ʊ)ƿŅ>ƿV Ōíƿ<a #rņĹƿ ƿ ƿ/ ƿ*;ƿƿ( ƿ'M ƌZ 16.D.2.b Packet Pg. 670 Attachment: US Treasury Agreement (21345 : ERA Grants Allowable Activities) 0MB Approv od No.: 1505-0270 Expiration Date: 10/31/2021 Eligible grantee name and address: Collier County 3299 Tamia mj Trail E, Ste 700 Naples Flori a 34112-5749 U.S. DEPARTMENT OF THE TREASURY EMERGENCY RENTAL ASSISTANCE DUNS Number: 076997790 Taxpayer ldentificatioa Number: 596000558 Assistance Li ting Number and Title: 21.023-Emergency Rental Assistance Program Section 3201(a) of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021), authorizes the Department of the Treasury ("Treasury") to make payments to certain ligible grantees to be used to provide emergency rental assistance. The eligible grantee hereby agrees, as a conditi receiving such payment from Treasury, to the terms attached hereto. Authorized Representative Signature (above) [To be signed by chief executive officer if reci ·ent is a local government.] Authorized Representative Name: Authorized Representative Title: Date Signed: U.S. Department of the Treasury: Authorized Representati-ve Title: Date: Mark Isackson County Manager PAP'ERWORK BDUCTIO ACT NOTICE: The information coll� will be used for the U.S. Government to process requests for !illJlport. The estimated burden associate.I with this collection of information is IS minutes per response. Comments concerning the eccuracy of this burden estimate and suggesti011B for reducing this urden should be directed to the Office of Privacy Transpermcy and Records Department of the Ttewiury, 1500 Pennsylvania Ave., N.W., WashiDgton, D.C. 20220. DO NOT send the form to this address. An agency may not conduct or sponsor, and a pel'llOl1 is 1101 required to respond to, a collection of infi rmation unless it displays a valid control number usigned by 0MB. PRIVACY ACT STATEMENT AUTHORITY:� licitation of this information is authorized by the American Rescue Plan Act of 2021, Title m, Pub. L. No. 117-2. PURPO E: Trea iUJ)' is required by the American Rescue Plan Act of2021 ID identify eligible grant.eesl_recipients ID provide emcrge11cy te111al 8.S!istance ro individuals who qualify for relief under the Act Eligible granteeshecipients are state, local, and te:nitorlal govemmml!l which identify households requiring relief according 1 requiremcnts contained in the Act. Treasury maintains contact information_ for authorized representatives and contact persons for the pmposc of como unicating with eligt'ble grantees regarding issues related to implementation of the Act. ROUTINE USE.': 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 Contactlnformation, which can be found at 81 FR 78266 (Nov, 7, 2016). DISCLOSURE: )isclosurc of this information to Treasury is required in order to comply with the requirements the American Rescue Plan Act of 2021. Disclo= of tbi information is voluntary, however, grantces/recipienlS that do not disclo e contact information will be unable to communicate with Treasury on illsu1:11 related to their obligations under the Act and this may affect the status of their award. 16.D.2.c Packet Pg. 671 Attachment: AGREEMENT TERMS DOT ERA2 - executed (21345 : ERA Grants Allowable Activities) 16.D.2.c Packet Pg. 672 Attachment: AGREEMENT TERMS DOT ERA2 - executed (21345 : ERA Grants Allowable Activities) 16.D.2.c Packet Pg. 673 Attachment: AGREEMENT TERMS DOT ERA2 - executed (21345 : ERA Grants Allowable Activities) 16.D.2.c Packet Pg. 674 Attachment: AGREEMENT TERMS DOT ERA2 - executed (21345 : ERA Grants Allowable Activities) EXECUTIVE SUMMARY Recommendation to accept changes to the U.S. Department of Treasury Emergency Rental Assistance 1 and 2 programs to streamline eligibility requirements and add allowable activities for households seeking assistance under the programs to benefit all eligible residents and those impacted by the sale of the Gordon River Apartments. OBJECTIVE: To continue to provide grant funding to Collier County residents unable to pay rent and utilities due to the impacts of the COVID-19 pandemic. CONSIDERATIONS: On January 5, 2021, the U.S. Department of Treasury announced funding available to state and local governments to provide financial support to residents that are unable to pay rent and utilities due to the impacts of the COVID-19 pandemic. Collier County was eligible for this funding since our resident population exceeds 200,000 per the Consolidated Congressional Act of 2021. The Emergency Rental Assistance (ERA) 1 Program made available $25 billion to assist nationwide. On January 26, 2021, Agenda Item #16D7, the Board of County Commissioners (Board) accepted the ERA 1 funding in the amount of $11,622,381. On March 25, 2021, the County was notified that the US Treasury had modified our award terms, extending the award and administrative cost terms. On June 8, 2021, Agenda Item #16D1 the Board of County Commissioners accepted the amendment to ERA 1. On March 11, 2021, President Biden signed the American Rescue Plan (ARP) which included additional funds and created the Emergency Rental Assistance Program 2 (ERA 2). These funds were received by the County on May 10, 2021. On June 08, 2021, Agenda Item #16D1, the Board accepted the ERA 2 funding in the amount of $9,088,102. On August 24, 2021, Agenda Item#16D1, the Board of County Commissioners accepted a clarifying Executive Summary to further streamline the eligibility requirements for households seeking assistance under the program based on US Treasury guidance issued on August 4, 2021. In September 2021 the Gordon River Apartments were sold to a private real estate investment firm. Since the sale, residents of the complex have been negatively impacted and many are in need of housing. Residents of this complex have been impacted by Covid and/or experienced reduction in household income, incurred significant cost, or experienced other financial hardship during or due directly or indirectly to the Coronavirus outbreak. Therefore, incorporating the modifications published by the US Treasury on August 25, 2021 will allow the County to expand the program through additional services thus benefitting a large population. To ensure that assistance is made available to all who qualify for the Emergency Rental Assistance 1 and 2 programs, Collier County is further streamlining eligibility and expanding allowable activities under these grants as follows: Individual Assistance (Rental, Utilities, and Housing Stability Payment) 1. Allow rental payments for hotel or motel rooms, not to exceed the published GSA rate The cost of a hotel/motel room occupied by an eligible household may be covered using ERA Assistance within the category of “Other Expenses” under the following circumstances: 16.D.2.d Packet Pg. 675 Attachment: ERA EXECUTIVE SUMMARY 10.12.21 (21345 : ERA Grants Allowable Activities) a. The household has been temporarily or permanently displaced from its primary residence or does not have a permanent residence elsewhere b. The total assistance provided to the household does not exceed the applicable time limit of 18 months c. The cost of the hotel/motel room may include all applicable sales tax and fees customary for room rental. d. The allowable hotel/motel stay will be limited to 30 days or will be extended at the discretion of the County according to the need of each applicant and may not include expenses incidental to the charge for the room. 2. Allow prospective rental payments for recertifications based on rental obligation as stated on lease agreement (i.e. pay at once for the remainder of the lease term) a. Prospective rent payments for recertified applicants will be based on the rental obligation stated on the lease, not require a rent ledger ongoing, provided the rent is all inclusive, and there are no additional monthly charges, i.e. water, sewer. Applicants requesting additional late charges will be asked to provide updated rent ledgers documentation for additional late charges and fees. 3. Allow payments to landlords after the tenant no longer resides in the unit due to owing back rent if qualified a. In order to remove barriers a household may face in accessing new housing, avoid further collection efforts and credit damage, as well as limit the financial burden on landlords, the County may, at the tenant’s request, provide assistance for rental or utility arrears after the eligible tenant has vacated a unit. If the account has been turned over for collection, the County may require the landlord or utility provider to notify the tenant and collection agency that payment has been received and that there will be no further collection efforts. 4. Allow payments to landlords with homesteaded properties a. Per Florida statutes 196.031 and 196.061, homesteaded properties may not be rented in their entirety or in part, unless there is a completely separate living quarters (apartment, in-law suite, etc.), whether attached to, or detached from the primary home. Any non-shared living space is eligible for rent, and payments should be provided to the landlord. Room rentals where there are shared common areas (kitchens, bathrooms, etc.), are not allowed. 5. Payments related to current eviction cases can be determined by the landlord. a. In order to reduce the wait time to receive payment in court registered eviction cases, and return the applicant to good standing as soon as possible, landlords may determine payments be made directly to them instead of being paid to the Court Registry. 6. Allow self-certification in the ERA 2 program to verify a reduction in household income, incurred significant cost or experienced other financial hardship during or due directly or indirectly to the Coronavirus outbreak. All other previously approved requirements remain in effect in addition to those noted above. County staff in collaboration with other municipalities and organizations will utilize these proposed changes and other program guidance to assist those eligible residents. 16.D.2.d Packet Pg. 676 Attachment: ERA EXECUTIVE SUMMARY 10.12.21 (21345 : ERA Grants Allowable Activities) FISCAL IMPACT: There is no new Fiscal impact with this amendment. The funding source for this grant is Community & Human Services Grant Fund (705) Projects 33734 and 33761. GROWTH MANAGEMENT IMPACT: There is no Growth Management impact associated with this Item. LEGAL CONSIDERATIONS: Chair signature is not required for the clarifications. This item is approved for form and legality and requires a majority vote for Board action. - JAB RECOMMENDATION: Accept changes to the U.S. Department of Treasury Emergency Rental Assistance 1 and 2 programs to streamline eligibility requirements and add allowable activities for households seeking assistance under the programs to benefit all eligible residents and those impacted by the sale of the Gordon River Apartments. Prepared By: Kristi Sonntag, Director, Community and Human Services 16.D.2.d Packet Pg. 677 Attachment: ERA EXECUTIVE SUMMARY 10.12.21 (21345 : ERA Grants Allowable Activities)