Policy
and Prodcedures: &=
nbsp; (Insert Organization Name) MEANS TEST
Section
1: Overview
1(a): Policy Introduction – Reques=
t for
Duplication of Benefits Exemption
A request by MDA’s Disaster
Recovery Division (DRD) for a blanket exemption from the Stafford Act’=
;s
duplication of benefits provision was made to the Department of Housing and
Urban Development (HUD) in April 2009.&nbs=
p;
The request was denied; however, HUD did determine that “there=
is
no prohibition on providing additional assistance in cases in which the ini=
tial
assistance was insufficient to meet a household’s disaster recovery
housing needs”. Further, HUD recognized there are
instances where a person or family has received benefits from the Federal
Emergency Management Agency (FEMA) or another source, including Community
Development Block Grant (CDBG) disaster recovery assistance, but the assist=
ance
was insufficient to put the disaster victim back into decent, safe and sani=
tary
housing.
(Insert organization name)
has been authorized by MDA to process an appeal of the duplication of benef=
its
determination by using means testing for clients that have a duplication of
benefits determination but still have unmet housing needs.
1(b): Purpose
The principle objective of this po=
licy
is to provide clients with the opportunity to appeal a duplication of benef=
its
determination and demonstrate that they have additional unmet housing
needs.
1(c): Responsibility
It is the responsibility of the cl=
ient
to justify the need for additional assistance; however, (insert organization name) must thoroughly document the need in the
client’s application file. To
proceed with the Means Testing, the client must account for the use and
disposition of all previously awarded disaster assistance for housing toget=
her
with the proceeds of the disposition of damaged real property. Previous benefits for housing and =
the
proceeds from the disposition of damaged real property must go into housing=
. This should be documented in the
file. If any of these funds a=
re
remaining, they must also be used in lieu of additional MDA assistance. Previous benefits for housing t=
hat
were utilized for other than housing needs cannot be replaced with CDBG fun=
ds.
(Insert organization name)
will collect financial information and documentation regarding the utilizat=
ion
of other benefits received and the disposition of the client’s real
property. This information will be used as follows to determine the unmet
needs:
1.&n=
bsp;
Determine i=
f,
after the proper utilization of previous benefits, there remains an unmet n=
eed
for additional housing benefits.
2.&n=
bsp;
Show the cl=
ient
has less than $25,000 in cash or liquid assets and less than a $75,000 net
worth. This is the threshold =
for
proceeding with means testing. Applicants
over the thresholds are not eligible.
3.&n=
bsp;
Conduct the=
means
assessment and determine if the applicant should be required to utilize the
assets on hand in lieu of additional MDA benefits.
The person doing the intake will m=
ake an
initial recommendation to fund or not to fund. The recommendation, along with all
supporting documentation, should be forwarded to (insert name of person or agency/departme=
nt)
that will do the review and make a determination on funds to be granted.
Section
2: Client Eligibility and
Sub-Recipient Required Actions
2(a): Client Eligibility
Each client must complete a current
financial statement showing all assets (including all assets disposed of in=
the
previous six months for less than fair market value), liabilities and income
(from any source). The financ=
ial
statement must be signed by the client under penalty of perjury.
If a review of an individual
client’s financial statement reveals more than $25K in liquid assets =
or a
total net worth in excess of $75K, the client is ineligible for addition fu=
nds.
And no further means testing will be performed.
2(b): (Insert organization name) Required Actions<= o:p>
|
TO DO LIST |
|
|
|
<=
![if !supportLists]>ü
|
Obtain
information on previous benefits received |
Person Responsible |
|
<=
![if !supportLists]>ü
|
Document
disposition of all previous disaster assistance and insurance proceeds |
Person Responsible |
|
<=
![if !supportLists]>ü
|
Facilitate
client completion of LTWH means assessment financial statement, ensuring =
that
all supporting documentation is received |
Person Responsible |
|
<=
![if !supportLists]>ü
|
Assess
liquid and net worth to ensure that they don’t exceed the maximum
limitations |
Person Responsible |
|
<=
![if !supportLists]>ü
|
Obtain
client signature on financial statement certifying that information recei=
ved
is accurate |
Person Responsible |
|
<=
![if !supportLists]>ü
|
Conduct
detailed review of information received and make a recommendation to (insert proper person/group) regarding amount
needed. |
Person Responsible |
|
<=
![if !supportLists]>ü
|
Conduct
final review of financial statement, supporting documentation and
recommendation |
Person Responsible |
|
<=
![if !supportLists]>ü
|
Approve
or Deny recommendation |
Person Responsible |
|
<=
![if !supportLists]>ü
|
Complete
the Sub-Recipient certification and update into OnBase database |
Person Responsible |
2(c): Means Assessment Tools: Financial Statement
The financial statement should be =
fully
completed by each client. Pro=
gram
funds are limited; therefore, failure to comply with the means test financi=
al
statement requirement or documentation could result in denial of additional
assistance. Upon completing t=
he
financial statement, a LTWH Means Test Assessment Cover Sheet should be com=
pleted
and submitted to (insert
name of person/group).
2(d): Suggested Acceptable/Unacceptable
Expenditures
Included in the financial statemen=
t is a
section requesting information regarding the disposition of disaster benefi=
ts,
including insurance policy proceeds.
A suggested list of acceptable/unacceptable uses for awarded disaster
assistance is found below. Th=
e list
is not exhaustive and some subjective determinations may need to be made in
assessing benefit expenditures. MDA
grant funds should only be provided to those who are unable to fund their o=
wn
housing and housing-related expenses.
To receive additional funding, previously awarded disaster assistance
must have been properly utilized.
|
Su=
ggested
Acceptable Expenditures |
|
Fo=
rced
Mortgage Payoff – with receipt |
|
Ho=
using
Expenses |
|
Fu=
rniture
Expenses |
|
Temporary Hous=
ing
Expenses - |
|
|
|
Unacceptable Expenditures |
|
Entertainment (i.e. vacations, gambling, etc.=
) |
|
Vehicle Expenses |
|
Jewelry, Electronics or Fine Dining |
|
Unreasonable Clothing Expenses |
|
Medical Expenses, especially routine medical<= o:p> |
|
Ed=
ucational Expenses |
|
Job
Search Expenses |
|
Co=
nsumer
Debt Absolution |
|
Ch=
ild
Care |
![](3D"MeansTestingSamplePolicyandProdcedures_files/image002.gif")
![](3D"MeansTestingSamplePolicyandProdcedures_files/image004.gif")
![](3D"MeansTestingSamplePolicyandProdcedures_files/image006.gif")