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ALAMEDA COUNTY
YOUTH HOMELESSNESS DEMONSTRATION PROGRAM (YHDP)
JOINT COMPONENT
TRANSITIONAL HOUSING—RAPID RE-HOUSING
(TH-RRH)
PROGRAM
MANUAL
Last Updated 8/4/2025
Alameda County YHDP Joint Component (TH-RRH) Program Manual
1 Updated 8/4/2025
CONTENTS
Program Overview ............................................................................................................................. 3
Purpose & Goals ............................................................................................................................. 3
Philosophy and Principles ............................................................................................................... 4
Program Description ....................................................................................................................... 5
Target Population .................................................................................................................................. 5
Referral and Enrollment ........................................................................................................................ 6
The TH Housing Component ................................................................................................................. 6
The RRH Housing Component ............................................................................................................... 6
Case Management ................................................................................................................................ 7
Supportive Services ............................................................................................................................... 7
Program Guidelines & Documentation Requirements .......................................................................... 8
Enrollment and Intake ............................................................................................................................... 8
Assessment, Crisis Management & Stabilization ...................................................................................... 8
Case Management & Supportive Services ................................................................................................ 8
Home Visits ........................................................................................................................................... 9
Service Planning & Documentation ...................................................................................................... 9
Supportive Services ............................................................................................................................... 9
Housing Identification ............................................................................................................................. 11
Housing Requirements: Habitability Standards and Rent Reasonableness ........................................ 11
Lease Requirements ............................................................................................................................ 12
Rental Assistance ..................................................................................................................................... 13
Income Verification & Budgeting ........................................................................................................ 13
RRH Rental Contribution Policy ........................................................................................................... 13
Program Exit ............................................................................................................................................ 15
Grievance Policy ............................................................................................................................... 17
Updating the Program Manual ......................................................................................................... 17
Appendix A: Alameda County YHDP Joint-Component TH-RRH Project: YHDP Flexibilities Policies,
Procedures, and Forms ..................................................................................................................... 18
Appendix B:
Alameda County YHDP Joint Component TH-RRH Spending Guidance ................................................ 37
Alameda County YHDP Joint Component (TH-RRH) Program Manual
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Alameda County YHDP Joint Component (TH-RRH) Program Manual
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These written standards provide an overview of the expectations for the YHDP Joint-Component TH-RRH
Project (hereafter referred to as the “program”) funded by the Youth Homelessness Demonstration
Program (YHDP) in Alameda County. This program is part of the larger homeless response system in
Alameda County. Please refer to Alameda County Homelessness Response System Written Standards for
a comprehensive overview of that system. Unless otherwise indicated, these standards are consistent
with and expand upon the system-wide standards governing TH and RRH programs. Where this program
manual is silent, the System Written Standards apply.
This document includes the minimum requirements for the program, including:
● Eligible program participants.
● Referral, admission, and discharge processes for the program, including anticipated and
maximum lengths of program enrollment.
● The scope of services and resources that programs are required to provide or otherwise refer
participants to receive through other community partners.
● Required program coordination with other programs and partners, including benefits programs,
health care, employment, and education.
● Policies, procedures, and forms for special YHDP flexibilities and other relevant services and
resources.
Program Overview
The Joint-Component Transitional Housing - Rapid Re-Housing (TH-RRH) program combines two existing
Continuum of Care (CoC) program components, Transitional Housing (TH) and Rapid Re-Housing (RRH),
in a single project to provide young people with short-term housing coupled with short- to medium-
term rental assistance and support to identify, move into, and transition to maintaining permanent
housing on their own.
Purpose & Goals
The Youth Action, A Way Home, Alameda County’s Coordinated Community Plan to prevent and end
youth homelessness, identified that youth and young adults need more time and options while
navigating housing insecurities and homelessness. They found that the traditional 2-year timeframe of
Transitional Housing (TH) and Rapid Re-Housing (RRH) programs do not typically provide enough time
for a young person to be ready to maintain their own permanent housing, especially given the local
housing market.
This project was identified as critical to addressing youth homelessness in Alameda County because
through the combination of the TH and RRH components, it can offer young people up to 5 years of
supported housing and services to prepare them to successfully maintain permanent housing
independently. It is intended to increase our systems capacity to provide necessary short- to medium-
term crisis housing for youth and young adults who do not have many other options that feel safe,
approachable, and accessible to them.
The ability to link this crisis intervention directly to longer-term housing supports using RRH is also
essential in our community. While holistic supportive services are a necessary and vital factor in
supporting youth experiencing homelessness, the ability to provide needed housing for youth
experiencing homelessness continues to be a huge challenge for our community. It is critical for young
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people experiencing homelessness to have access to safe and stable housing they are satisfied with in
conjunction with needed services to transition out of survival mode and towards healthy and
sustainable independence.
This program is intended to lead to improved mental health (decreased stress and anxiety) and help to
build a stable foundation from which young people can focus on employment, education, wellness, and
other personal goals. The stability and longevity of this TH-RRH housing will also allow young people to
build savings and increase their financial literacy to support long-term financial stability. Both
components of this project, TH and RRH, are designed to meet young people where they are in their
housing journey and support them in increasing their income and building the necessary skills to obtain
and maintain permanent housing.
Philosophy and Principles
TH-RRH programs utilize a person-centered, Housing First approach in which resources and services are
tailored to the unique needs of each young person. Young people work in collaboration with their case
worker to reach their individual housing stability and other goals. Both components of the program, TH
and RRH, are also grounded in the practices of trauma-informed care, Positive Youth Development, and
harm reduction. This program adheres to the following principles derived from the Housing First for
Youth model1:
● A right to housing with no preconditions. This project cannot require participants to be sober,
abstinent, employed, in school, in treatment for any condition, or enrolled on services as a
condition of being housed in TH or RRH. Further, services and the offer of support are tied to the
young people, whether or not they are currently housed (e.g., the program may not exit a young
person because they got evicted). Young people in the program are not required to accept
services or other offers of support.
● Youth choice, youth voice, and self-determination. Young people are experts in their own
experiences, needs, and lives. Young people in the program have full control over their lives,
including when they may make choices that service providers would not choose for them. The
service provider’s job is to meet each young person where they are, work with them to reduce
harm when possible, and support them in learning through the process of making choices and
experiencing the positive and negative consequences of those choices. Note that this
implementation of youth “choice” does not mean that anyone can and should do whatever they
want whenever they want. Rather, providers should help set boundaries and help young people
understand the boundaries of choice when considering consequences they do and do not want
to face. Further, each young person’s ideas, opinions, and knowledge should be a respected and
be a leading contributor to program implementation and policy.
● Positive Youth Development & wellness orientation. Programming and supports are oriented
around young people’s assets, strengths, dreams, and hopes. Programming should support
young people in building self-esteem, a positive sense of self, buy-in for working toward and
achieving their own goals, and access to supports and opportunities that will allow them to
pursue their personal interests and dreams. Further, the program embeds trauma-informed
practices that recognize intersectionality, increase safety, decrease harm, and prevent re-
traumatization.
1 Please refer to these resources for more detail on the Housing First for Youth (HF4Y) model: THIS is HF4Y Part 1:
Program Model Guide (The Homeless Hub) and THIS is HF4Y Part 2: Operations Manual (The Homeless Hub)
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Case Management & Supportive Services
● Individualized & youth-driven supports. The program understands and respects that, once
housed, each young person will want, need, and choose to participate in a unique type and level
of support or services. The program promotes active engagement from case managers without
coercing young people to accept that engagement or other services offered.
● Social inclusion & community integration. The housing offered to youth through this program
should never stigmatize or isolate youth, nor should it force them to participate in a
“community” they are not choosing for themselves (e.g., in a site-based setting). Service
providers should consider how to offer individualized opportunities for social, cultural, and
spiritual engagement, and staff should be equipped to explore if, when, and with which
boundaries participants may want to connect or reconnect with natural supports and family in
their lives.
As part of upholding a youth-centered and youth-driven approach, the program is also encouraged to
use the YHDP special activity that permits employment of young people who are receiving services,
including housing, from the program. Recipients that utilize this special YHDP activity must maintain
documentation that discloses the nature of work that the youth does, and that the youth is not in a
position that creates a conflict of interest. For more information and appropriate forms, see Employing
People Enrolled in Services policy and procedures in Appendix A.
Program Description
This program provides young people with short-term housing coupled with short- to medium-term
rental assistance and support in identifying, moving into, and transitioning to maintaining longer-term
housing on their own. Young people can begin either in the TH or the RRH component, depending on
the young person’s current level of needed support and their preference.
Regardless of where a youth begins the program, they will first receive crisis management and
stabilization, followed by housing identification, then housing assistance (i.e., leasing and rental
assistance). Additionally, case management and supportive services are offered throughout the course
of their enrollment in the program. More details and guidelines for each of these program elements is
provided in the Program Guidelines & Documentation Requirements section of this document.
Target Population
The target population for this project is all young people under the age of 25 who are homeless, at
imminent risk of losing their housing, or fleeing violence (i.e., young people meeting HUD Category 1, 2,
or 4 definitions of homelessness2). Particular consideration will be given to providing supports within
the program specifically designed for young people who are pregnant and parenting, who are
2 For more information regarding these definitions and determining the homelessness status of youth visit
https://files.hudexchange.info/resources/documents/Determining-Homeless-Status-of-Youth.pdf
Crisis Management & Stabilization Housing Identification Housing Assistance
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undocumented or a migrant, who have experienced labor or sexual exploitation, or who have been
involved with the juvenile justice system or foster care system.
There are no minimum or maximum income limits when determining the initial eligibility of a household
(income verification will only be conducted as part of determining the amount of rental assistance, see
Income Verification on page 13). Programs shall not establish additional eligibility requirements beyond
age and homelessness and those required by current or future funders. Declining a young person’s
admission into a program should be rare and occur only in limited situations (e.g., when a young person
is in need of a higher level or more specialized care that can be better provided by another program. In
these instances, the young person should be referred to the more appropriate program.3).
The program also follows Housing First principles regarding how participants are screened and enrolled.
Potential participants cannot be screened out due to having too little or no income, an active or history
of substance use disorder, a history of domestic violence, a criminal record (apart from any applicable
state restrictions). Additionally, young people cannot be screened out due to belonging to or identifying
with any group protected in the non-discrimination policy outlined in Alameda County’s Coordinated
Entry Manual.
Referral and Enrollment
Both the TH and RRH components of the program participate in Alameda County’s Coordinated Entry
System (CES) to receive referrals and enroll participants in the program. Program providers must use the
CoC-wide Prioritization Order for enrollment. The only documentation necessary to enroll in the
program is proof of age and proof of homelessness status (see Target Population, above). This program
must align with HUD recordkeeping requirements for demonstrating homelessness for any young
person enrolled in the program.
The TH Housing Component
The TH component of the program provides short- to medium-term crisis housing for young people with
no other safe alternative. To do so, it uses leasing resources to provide up to 24 months of housing and
supportive services designed to help participants successfully move to and sustain permanent housing.
All participants in the TH program must have an occupancy or lease agreement for a specified term,
which may be month-to-month. The lease must be automatically renewable upon expiration, except
upon prior notice by either party, for up to a maximum of 24 months. TH units must also meet
habitability standards (See Habitability Standards policy and documentation in Appendix A).
TH units are directly linked with RRH units so that all young people who enter the TH component are
guaranteed entry to the RRH component upon exit from TH if the young person needs and wants
ongoing support. A young person is supported in moving from TH to RRH whenever they say they are
ready. Young people should not move from RRH to TH, except in rare instances (e.g., if they get evicted
from a RRH unit and have nowhere else to stay).
3 Details on the coordinated entry assessment and prioritization process can be found with Alameda County’s most
recent coordinated entry policies available at https://homelessness.acgov.org/coordinated-entry.page.
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The RRH Housing Component
The RRH component of the program provides young people with up to 36 months of rental assistance
for housing in the community and supportive services. 24 months of rental assistance is guaranteed to
all young people in the program. This can be extended for up to 36 months so long as the program
documents the young person’s eligibility for ongoing rental assistance (for more details on this and
required documentation, see the Additional Rental Assistance policy in Appendix A). As stated above, a
young person does not have to first be enrolled in the TH component of the program to be eligible for
entry into the RRH component; however, if the young person enters first in the TH Housing Component
and then remains in the program for the maximum length of time, participants may have a total of 60
months of housing support through the program.
All young people in the Rapid Rehousing program must have a signed lease in their name and all RRH
units must be regularly inspected to ensure they meet habitability standards (See Habitability Standards
policy and documentation in Appendix A). Both the young person and the program must pay rent/rental
assistance directly to the landlord. Projects may not collect rent from participants for units using rental
assistance.
Case Management
Case management is offered to participants throughout their enrollment in the program and is designed
to assist in assessment, crisis management, stabilization, housing identification, housing assistance, and
provision of and/or referral to needed supportive services. This is accomplished through creation and
regular updating of a service plan and voluntary meetings between the young person and their case
manager. The young person and the case manager will collaboratively identify goals for housing,
education/employment, well-being, permanent connections, as well as any other areas the youth may
identify; make plans towards achieving these goals; and monitor progress. Case management meetings
should be approached as an opportunity to support the young person in skill development, problem
solving, and working towards meeting their goals. More details about the case management process and
service plan documentation are provided in the Program Guidelines & Documentation Requirements
section of this document.
Case management meetings are held at times and locations (including virtual or remote options) that
are best for the young person. Young people are not required to come into an office for case
management meetings.
Supportive Services
An array of supportive services is also offered to participants throughout their enrollment in the
program, and for up to 24 months after their last housing assistance payment. Services are designed to
address needs around employment, education, well-being, permanent connections, legal supports, and
other youth-identified needs to support young people in being able to maintain their own housing long-
term and in alignment with the overarching goals of YHDP. This includes provision of and/or referral to
additional supportive services specifically designed for young people who are pregnant and parenting,
undocumented/migrant, who have experienced labor/sexual exploitation, or who have been impacted
by the juvenile justice system or foster care system.
The full breadth of housing and services provided through this program are described in more detail in
the Scope of Housing Resources & Services section of this document. Program providers must directly
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provide, pay for, or make connections and referrals to all services listed in the Supportive Services
section of Allowable Housing Resources & Services below.
Program Guidelines & Documentation Requirements
The following details expectations of program operations over the course of a young person’s
enrollment. Additional program details as well as the specific program policies and required
documentation can be found in Appendix A. Spending guidance for all program components is in
Appendix B.
Enrollment and Intake
Program staff should welcome young people to the program by holding an intentional space to get to
know the young person and start building trust. This should happen at the young person’s point of entry
to the program and (if applicable) when they transition from TH to RRH. Minimum required
documentation for enrollment should be collected (i.e., proof of age and homelessness status), but any
other documentation needed to provide ongoing assistance or services (e.g., documentation necessary
to access housing) can be obtained post-enrollment and should not interfere with program enrollment.
The intake and orientation to the program should include the following elements:
• Opportunity to get to know each other, become comfortable, and establish a safe space
• Inquire as to how the young person is feeling and their current situation
• Begin to explore the young person’s goals
• Provide a verbal program overview as well as a welcome packet that outlines program services
and supports and program and participant expectations
• Review the program documentation together and inquire about any additional support they
may need to review and understand the program materials
• Check for the young person’s understanding of the program
• Make an initial action plan with clear next steps (this does not need to be formal)
• Emphasize that the intake process can be completed over multiple sessions over the first 30
days and additional information can be shared as the young person is comfortable.
Assessment, Crisis Management & Stabilization
A young person’s immediate needs are assessed at intake and throughout the first few case
management sessions, as trust and rapport is built. Any immediate needs identified should be addressed
as swiftly as possible to support initial stabilization. A complete intake and needs assessment is then
conducted within the first few case management sessions. This should include assessing for eligibility
and enrollment in other social services, including CalFresh, Medi-Cal, SSI/SSDI, General Assistance, and
others as applicable. This initial assessment forms the basis for the service plan discussed below.
During this stage, case managers should also review program expectations and community guidelines
with the young person to ensure the young person is clear on what is expected of them, what support
they can expect from the program, and how to communicate with staff if they have questions or needs
that are not being addressed.
Case Management & Supportive Services
Case management is offered consistently to all young people throughout the course of their time in the
program. The level to which a young person engages in case management is at their discretion;
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however, case managers and/or housing specialists (titles may differ; hereafter referred to as case
managers) must regularly offer to meet with the young person at times and locations that are
convenient to the young person to address their needs and develop and make progress on their service
plan. At a minimum, HUD requires rapid rehousing projects to meet with a program participant not less
than once per month, to assist the program participant in maintaining long-term housing stability.4
Therefore, case managers should seek to connect with the young person at least once each month and
as part of the quarterly update to their service plan (see more details on service plan updates below);
however, intensive case management services must be offered to all young people, with case
management meetings offered weekly. It is up to each young person how much they would like to
engage in case management and supportive services. A young person cannot be exited from the
program solely for refusing case management or other services.
Communication
Case managers are generally expected to respond to a young person on their caseload within one
business day, and the program must have and communicate to young people alternative contacts and
resources in the event of a case manager being unavailable or a young person needing urgent assistance
outside of the program’s regular hours.
Home Visits
Home visits provide an opportunity to provide further case management and should be approached as
an opportunity to support the young person in skill development, problem solving, and working towards
meeting their goals. As with case management, home visits cannot be required beyond what is
necessary for habitability inspections (See Habitability Standards policy and documentation in Appendix
A) and must be scheduled at times that are best for the young person. With the exception of what is
required for habitability inspections (See Habitability Standards policy and documentation in Appendix
A), the young person has discretion as to what parts of their home are viewed during any home visit. If a
landlord has expressed concerns, the case manager should work with the young person and the landlord
to collaborate in order to address concerns and the landlord may enter the property in accordance with
the lease agreement and State law.
Service Planning & Documentation
Case managers should develop voluntary service plans with participants and document all referrals
made for services to address identified needs. Service planning begins at intake and focuses on
identifying and transitioning the young person to the most appropriate permanent housing situation
and supportive services.
The service plan document should serve as a roadmap to independent housing and personal growth for
the young person. The document should be strengths-based and include goals and progress tracking for
housing, education, employment, well-being, permanent connections, and personal growth. The service
plan should be reviewed and updated with the youth quarterly and as needed, with a full reassessment completed annually.
Providers must keep records for all participants that document the assessed needs of the young person
and outline the services provided in response. This should include evidence that, at a minimum,
quarterly assessments of service needs were completed, and the service plan updated accordingly.
4 See CoC Interim Rule § 578.37(a)(1)(ii)(F)
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Supportive Services
Program providers must directly provide, pay for, or otherwise make connections and referrals to all
of the following services in accordance with each young person’s needs:
● Annual assessment of service needs
● Assistance with moving costs (this is allowable multiple times for each youth as needed)
● Case management
● Childcare
● Education Services
● Employment assistance and job training
● Housing search and counseling services
● Legal services
● Life skills training
● Mental health services
● Outpatient health services
● Substance abuse treatment services
● Transportation
● Utility deposits
● Direct provision of services
● Food (see the Food Provision Policy Appendix A)
In addition, there are some special YHDP flexibilities that require specific processes to be followed to
demonstrate necessity to support the young person in obtaining and maintaining housing in order to
justify using them; however, these should also be provided whenever needed:
● Security deposits (not to exceed 2 months of rent);
● The costs to pay for any damage to housing due to the action of a program participant.
● Household cleaning supplies.
● Housing start-up expenses (furniture, pots and pans, linens, toiletries, and other household
goods, not to exceed $300 in value per program participant).
● The one-time cost of purchasing a cellular phone and service for program participant use.
● The cost of internet in a program participant’s unit.
● Payment of rental arrears (for up to 6 months of rent, including any late fees).
● Payment of utility arrears (for up to 6 months per service).
● Up to three months of utilities.
● Gas or mileage costs for a program participant’s personal vehicle for trips to and from medical
care, employment, childcare, or other program eligible services.
● Legal fees, including court fees, bail bonds, and required courses and equipment.
See Appendix A for details on how these regular or special activities are implemented in a standardized,
HUD-compliant, consistent, and equitable way for each service participant, including applicable forms
for documenting need for specific YHDP flexibilities. See Appendix B for eligible costs and spending
guidance for each identified service.
Supportive services should continue to be provided to program participants for up to 24 months after
the program participant exits homelessness, transitional housing or after the end of housing
assistance.
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Supportive Interventions: The program must provide supportive, equity-focused interventions to
address behavioral or other challenges that may arise while a young person is in the program to support
their continued successful participation in the program, aligned with the core principles outlined in this
document. When implemented, these must be documented in a youth’s service plan. These supportive
interventions may include:
● One-on-one reflective check-in with case manager and/or trusted staff.
● Conflict mediation.
● Community Guidelines review and sign off:
○ Discuss and document clear expectations on the youth’s behavior moving forward;
○ Document clear, supportive intervention steps (e.g., referral to stress management
workshop, therapy, etc.); and,
○ Sign Community Guidelines (young person and staff).
Housing Identification
Ultimately, it is up to the program participant to select a housing unit in which to live and the people
with which they will share that housing, if any. Typically, housing identified should be based on
household size to ensure sustainability of the housing upon exit from the program. If the young person
is interested in pursuing a shared housing situation, see the Shared Housing section below for more
information on important requirements in these situations. Within the limits of the young person’s
anticipated income, program providers must help young people access units that are desirable and
sustainable, i.e., that are in neighborhoods where they want to live, have access to transportation, are
close to employment, and are safe. The program must provide each young person with multiple housing
choices that are in alignment with the young person’s housing desires and goals (e.g., neighborhood,
amenities, etc.) within practical constraints, and continue to do so until a suitable unit is secured for the
young person.
Housing identification efforts should be designed and implemented to actively recruit and retain
landlords and property managers willing to rent to young people who may otherwise fail to pass typical
tenant screening criteria.5
Housing identification services include:
● At enrollment or within 72 hours of enrollment, review and update of the young person’s
coordinated entry assessment of housing barriers, needs, and preferences.
● Development of an action plan for locating housing.
● Actively assisting young people with housing searches (i.e., identifying landlords, helping young
people view apartments, etc.)
● Outreach to and negotiation with housing owners.
● Assisting young people with submitting rental applications and understanding leases.
● Assisting young people with obtaining utilities and making moving arrangements.
● Tenant counseling.
● Providing basic support to all landlords who lease to young people in the program.
5 See the NAEH RRH Toolkit for further guidance.
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● Continual recruitment and retention of landlord partners and maintenance of a system to track
unit vacancies, locations, characteristics, and costs.
● Exploring options such as shared housing and placements with family and friends to the degree
to which it is safe and appropriate for a young person (See Shared Housing Guidance in
Appendix B for more details).
Housing Requirements: Habitability Standards and Rent Reasonableness
Housing identified must comply with Habitability Standards, which requires inspection of the property
within the first 30 days and at least once every 12 months during the period of housing assistance.
This is a special YHDP flexibility that provides a more flexible standard than the Housing Quality
Standards in 24 CFR 578.75 that is typically required. To implement this special YHDP flexibility,
programs must keep documentation of which standards are applied to the units and proof that the units
complied with the standards before assistance is provided for every unit funded by YHDP. See
Habitability Standards Policy & Procedure for more details on proper processes and forms for complying
with meeting habitability standards for a unit.
Rent must be determined to be reasonable for any housing for which the program is providing rental
assistance. This is done by comparing rent for the unit to receive rental assistance in relation to rents
being charged for comparable unassisted units, taking into account the location, size, age, type, quality,
amenities, facilities, housing services, utilities provided, and management and maintenance of each unit.
Reasonable rent must not exceed rents currently being charged by the same owner for comparable
unassisted units.
To calculate rent reasonableness for a shared housing situation, the Fair Market Rent (FMR) for the
shared housing is the lower of the FMR for the family unit size or the pro-rata share of the FMR for the
shared housing unit size. The pro-rata share is calculated by dividing the number of bedrooms available
for occupancy by the assisted family in the private space by the total number of bedrooms in the
unit. For example, in the case of a single person household renting one room in a 4-bedroom house, the
FMR used would be the lower of the 1-bedroom FMR or the pro-rata share of the 4-bedroom FMR (1/4
of the 4-bedroom FMR).
Lease Requirements
Each household being assisted with CoC Program tenant-based rental assistance must have their
own separate lease with the property owner to be considered a separate household for the purposes of
eligibility to receive rental assistance. To receive rental assistance, program participants must enter into
a lease agreement for a term of at least one year, which is terminable for cause, unless the case
manager and young person have together determined that utilization of the YHDP flexibility for a
shorter lease term is beneficial. To utilize this flexibility, See the Minimum Lease Term Policy and
Procedure in Appendix A. All leases must be automatically renewable upon expiration for terms that are
a minimum of one month long, except on prior notice by either party.
Shared Housing
A variety of housing types may be assisted with CoC Program funds, including shared housing, as long as
the housing meets the conditions set forth in the CoC Program interim rule and is consistent with the
scope of the program.
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Safety is one of the biggest concerns people have about sharing a housing unit. The living situation must
be safe and comfortable for everyone.
Under the CoC Program interim rule, if you are going to house people in shared housing/roommate
situations, there are certain requirements that must be met, and other considerations to keep in mind.
First, HUD requires participants in a shared housing situation to have separate leases. This is a
requirement designed to protect the tenant from facing eviction because of actions from the roommate.
If this requirement is posing a barrier, please reach out to the Alameda County Youth Program Services
Coordinator to assist in collaborating with HUD to explore possible flexibilities. Because each program
participant will be required to have a separate lease, rental payments made on each program
participant's behalf should be made separately to the landlord based upon each program participant's
rent calculation and contribution.
Rental Assistance
Once housing is identified for a young person, rental assistance
will be provided based on the young person's income and the
RRH Rental Contribution Policy detailed below and the Rental
Assistance Spending Guidance in Appendix B.
Income Verification & Budgeting
Income verification is necessary to determine the rental
contribution via the rental calculator (See below for more
details). Upon entry into the RRH component, the case manager should use at least two months’ worth
of paychecks to calculate the young person’s average monthly income, as well as support the young
person in developing a budget that reflects their current needs and anticipated future rent payments
that will increase. The case manager must complete the Income Evaluation Form, as well as collect and
maintain on file applicable source documents (wage statements, bank statements, etc.).
Income verification must then occur at least every 3 months prior to rent re-calculation. The case
manager must complete the Income Evaluation Form, as well as collect and maintain on file applicable
source documents for each income verification. See the Income Verification Policy in Appendix A for
more details.
Budget Review & Significant Change in Status
A case manager must offer to review a young person’s budget at least monthly to help determine
whether the young person’s income has decreased. If a young person has decreased income, they may
request a new income verification and adjustment to their rent contribution before the regular
verification is due.
A significant change in status is defined as an unplanned* life event that occurs outside of the
household’s control, significantly decreases their income, and causes significant hardship. Case
managers can re-calculate the household’s rent portion immediately if a significant change of status has
occurred. This can include, but is not limited to:
1. Fleeing domestic violence or other threats of violence
2. Unemployment and delay in unemployment benefits
3. Major medical or psychiatric hospitalization of household or household’s immediate family
member
You can access the Rental
Contribution Calculation Form
and all other program forms at
https://drive.google.com/drive/f
olders/1bYOuenYT7Sn7TB6L013
DGNT3pHUGyEYp
Alameda County YHDP Joint Component (TH-RRH) Program Manual
14 Updated 8/4/2025
4. Death of a child or immediate family member, or chosen family, as identified by the youth
5. Enrollment in a short-term vocational or educational program that will lead to increased
earning potential at the end of the program (* this may be a planned event at the time of
entry into the program)
6. An unplanned event that the case manager deems significant enough in nature to
determine a rent recalculation or payment plan would be appropriate. (Note that the
rationale for this must be clearly documented in the case notes.)
7. Other circumstances as determined with participants, case managers, and program
managers and recorded in case notes.
RRH Rental Contribution Policy
Rapid Re-Housing is a time-limited rental assistance program. Rental contributions will be based on a
combination of the percentage of total rent owed and the young person’s income, with rental
contribution amounts increasing every 3 to 6 months. Young people may receive up to 36 months of
rental assistance and 24 months of supportive services after their last rental assistance payment, but
participation should be evaluated on an ongoing basis, and young people should be exited when they
are able to maintain housing without financial assistance and supportive services from the program.
All rental contribution policies will be clearly communicated and an outline of the rental increase
timeline will be provided to the young person when the program begins paying their subsidy. The young
person should sign a copy of the RRH Rent Calculation Form and be given copies of their rent calculation,
which should be logged in their file. If a household refuses to sign, attempts to remediate the concern
with the young person and obtain the signature should be documented in the case notes. Each young
person will also be provided with a copy of their rental contribution logs monthly. Notification for rental
contribution increases will be provided to the young person at least 30 days prior to the increase taking
effect. The following provides an outline of the anticipated timeline for rent increases and the
corresponding percent of income caps:
Month of Rental
Assistance from RRH
% of Rent Youth is
Responsible for Paying
Max % of Youth’s Take-home
Income Dedicated to Rent
Months 1 – 3 0% 0%
Months 4 – 6 20% 5%
Months 7 – 12 40% 10%
Months 13 – 18 50% 20%
Months 19 – 24 60% 30%
Months 25 – 36 75% 40%
Case managers should use the Rental Contribution Calculation Form to calculate each youth’s
appropriate rental contribution. To calculate the young person’s rental contribution, start by calculating
what would be the percentage of rent owed by the young person based on the total amount of rent
owed and the young person’s length of the time in the program. Then calculate the maximum about of
the young person’s take-home income that can be dedicated to rent based on the young person’s length
of time in the program. Then compare the two. If the young person’s calculated rental contribution
would exceed the maximum amount of their income that can be dedicated to rent, then the young
person’s rental contribution is the maximum amount of their income dedicated to rent, otherwise the
young person’s contribution is the calculated rental contribution.
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At least every 3 months, the case manager should recalculate the household’s rent using the RRH Rent
Calculator. The household rent portion should increase at the percentage intervals listed above, and the
young person should be exited once the maximum amount of their income that can be dedicated to rent
is equal to or greater than the full amount of rent owed.
Utility Allowances
Utilities that are not included in the program participant’s rent may be paid using rental assistance
funds. Furthermore, all RRH programs are required to adhere to HUD’s Notice CPD-17-11: Determining a
Program Participant's Rent Contribution, Occupancy Charge or Utility Reimbursement in the Continuum
of Care (CoC) Program when the Program Participant is Responsible for the Utilities. Specifically, the CoC
interim rule requires all RRH projects to calculate rent as the sum of the total monthly rent for the unit
and, if the tenant pays separately for utilities, the monthly allowance for utilities established by the local
public housing authority for the area in which the housing is located.67 Therefore, if utilities are not
included in a young person’s rent, the rental calculation must incorporate the applicable utility
allowance, and the young person must be reimbursed for any amount that the allowance exceeds the
program participant’s share of rent. HUD’s Notice CPD-17-11 linked above includes clear examples for
how to calculate and pay utilities in cases where it is required.
Program Exit
YHDP-funded TH-RRH programs may offer housing in TH for a maximum of 24 months. During this time,
the household should be working on and supported to find permanent housing that they will be able to
move into and afford after they leave the program. This is likely to include using the RRH component of
the program for a period of time, though other housing options may be explored.
YHDP-funded TH-RRH programs may offer housing through rental assistance in RRH for a maximum of
36 months (using specific policies listed in the policies document for anyone receiving more than 24
months of rental assistance), with up to 6 months of services after the last rental assistance payment (or
up to 24 months of services after the last rental assistance payment using the policy listed in the policies
document).
Continuation of Supportive Services after Program Exit
The program may continue providing supportive services to program participants for up to 24 months
after the program participant exits homelessness, transitional housing or after the end of housing
assistance if the program demonstrates: 1) the proposed length of extended services to be provided; 2)
the method it will use to determine whether services are still necessary; and 3) how those services will
result in self-sufficiency and ensure stable housing for the YHDP program participant. The program may
continue providing supportive services to program participants for up to 36 months after the program
participant exits homelessness, if the services are in connection with housing assistance, such as the
Foster Youth to Independence initiative, or if the recipient can demonstrate that extended supportive
services ensures continuity of case workers for program participants. See Additional Supportive Services
policy, procedure, and forms in Appendix A for more details and guidance on how to implement this
continuation of services for a young person.
6 See CoC Interim Rule 24 CFR § 578.37(a)(1)(ii)(B))
7 Find information on all of the local Public Housing Authorities in Alameda County at
https://www.achcd.org/housing-vouchers-and-alameda-county-housing-authorities/
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Support To Transition from the Program
When participants transition from TH to RRH or transition out of the program entirely, the program
should use a transition or exit checklist that covers all necessary steps for transitioning to RRH or exiting
the program, including administrative tasks, updated resume, community resources/connections, social
support, personal growth reflections, and future planning. The transition guide should also include
information on who the young person should reach out to if they encounter any challenges or need
additional support, resources in their area, and updated plan that the young person can continue
working on independently after program exit. Warm handoffs should be made to any ongoing
supportive services prior to the young person’s exit from the program.
Following these steps will ensure that participants successfully progress through and ultimately leave
the program with a sense of accomplishment, confidence, and readiness for independent housing and
personal growth.
Early Exit – Graduation
Program participation should be evaluated on an ongoing basis, and young people should graduate
when they are able to maintain housing without financial assistance and supportive services from the
program. A young person is considered able to maintain housing without financial assistance when no
more than 40% of their income is dedicated to rent, they have successfully paid their rent on time for at
least 5 of the last 6 months, and they have an amount saved that is greater than or equal to half of their
monthly rent payment. Young people who exit early may still re-enter if they did not receive rental
assistance for the maximum number of months available in the program. Any youth who exits early
should also be given a transition guide as discussed above in conjunction with warm hand-offs to
ongoing supports.
If a young person enrolled in the program obtains another source of rental assistance, such as by
receiving a Section 8 housing voucher, it is the young person’s choice whether to remain in the program
or use the alternate rental assistance and graduate from the program.
Early Exit – Termination
As stated in the federal Continuum of Care Interim Rule8, program assistance may be terminated to a
program participant who violates program requirements or conditions of occupancy; however, doing
should be a last resort after exhausting all other solutions and carefully considering a young person’s
obstacles to stability. The termination process must be a formalized process that, at minimum, includes
the following:
• Provision of a written copy of the program rules and the termination process before the young
person begins to receive assistance.
• Written notice to the young person containing a clear statement of the reasons for termination.
• A review of the decision, in which the program participant is given the opportunity to present
written or oral objections before a person other than the person or a subordinate of that person
who made or approved the termination decision.
• Prompt written notice of the final decision to the program participant.
8 See 24 CFR § 578.91
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The program is expected to exercise reasonable judgement throughout the termination process and
examine all extenuating circumstances in determining when violations are serious enough to warrant
termination so that a young person’s assistance is terminated only in the most severe cases. See the
Program Termination policy in Appendix A for more details on the process for mediation/termination
and possible causes for doing so.
If a young person becomes unreachable, the case manager should make concerted efforts to contact the
young person using all available contact information for the young person, their household members,
and their care team. At minimum 6 unique outreach attempts must be made, including at least one
attempted wellness check/home visit, prior to exiting the young person from the program. In addition,
the case manager should do an incarceration search and search all other public systems in an attempt to
locate the young person. If all contact means have been exhausted and the young person remains
unreachable for 90 days, then the case manager should send a notice of disenrollment to the young
person and then disenroll the participant in HMIS if there is no response within the time period
identified in the letter.
All steps taken in the mediation/termination process and their results should be provided to the young
person and documented in the participant’s file. This should include all attempts to contact the young
person, as well as documentation that all applicable federal requirements specified above were
followed.
Termination does not bar the young person from providing further assistance at a later date to the
young person.
Evictions
The young person is responsible for following all requirements of their lease, and their case manager
should support them in doing so. If a participant is evicted from a unit while enrolled in RRH, they should
not be terminated from the program. The program should assist them in finding a new housing location,
moving them into it, and processing the events leading up to the eviction to identify any changes
necessary to ensure they will not be evicted again.
In extreme circumstances, California’s Transitional Housing Misconduct Law9 authorizes operators of
transitional housing programs to remove program participants from housing by applying to a court for a
temporary restraining order and injunction where certain types of misconduct have occurred and the
participant has not resided on the premises for more than six months. “Misconduct” in this context
describes acts that substantially interfere with the orderly operation of the program and involve abuse
or illegal behavior as defined in the statute. If the participant has been in transitional housing for more
than six months and/or the termination of services is for causes other than those covered in the statute,
the situation may require formal eviction proceedings.
Grievance Policy
If a young person wishes to report a grievance, the young person and relevant provider should follow
provider-level grievance policies to resolve the issue. Any participant who is dissatisfied with the
handling or response to their grievance may appeal to Alameda County Health’s Housing and
Homelessness Services by contacting the Youth Program Services Coordinator.
9 California Civil Code 1954.11-18
Alameda County YHDP Joint Component (TH-RRH) Program Manual
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Updating the Program Manual
These standards were developed by the YHDP core team, part of the Alameda County Health, Housing
and Homelessness Services (H&H) office. H&H may make amendments as required by YHDP or another
funding source used in the project to ensure timely compliance with regulations without a formal review
process and will provide notice to all program providers and the Youth Advisory Board (YAB) of any such
changes. All other changes must be reviewed and approved by providers of the program and by the
Youth Advisory Board (YAB). H&H will review the entire policy document and propose any updates or
changes on an annual basis.
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Appendix A: Alameda County YHDP Joint-Component TH-RRH Project:
YHDP Flexibilities Policies, Procedures, and Forms
CONTENTS
Policies to Support YHDP Flexibilities
(1) Minimum Lease Term Policy & Procedure ......................................................................................... 19
(2) Habitability Standards Policy & Procedure ........................................................................................ 21
(3) Flexible Costs Policy & Procedure ...................................................................................................... 23
(4) Additional Rental Assistance (24 to 36 Total Months) Policy & Procedure ....................................... 29
(5) Additional Supportive Services Assistance (6 to 36 Total Months after End of Rental Assistance)
Policy & Procedure .................................................................................................................................. 31
(6) Employing People Enrolled in Services Policy & Procedure ............................................................... 33
General Policies
(7) Food Provision Policy ......................................................................................................................... 34
(8) Income Verification Policy .................................................................................................................. 34
(9) Program Termination ......................................................................................................................... 35
Alameda County YHDP Joint Component (TH-RRH) Program Manual
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The policies, procedures, and forms in this manual serve as documentation of compliance with HUD’s
requirements, as set forth in the CoC Interim Rule and in HUD’s Fiscal Year 2019/2020 YHDP Notice of
Funding Opportunity (YHDP NOFO), Appendix A.
This manual uses the terms “flexibilities” and “special activities” interchangeably to refer to the list of
activities HUD approved for use under this grant agreement, as allowed in the YHDP NOFO, Appendix A,
Part I.C.1.
Policies to Support YHDP Flexibilities
(1) Minimum Lease Term Policy & Procedure
Purpose
The policy provides flexibility to youth and young Adults (YYA) seeking housing through the Joint-
Component TH-RRH project by allowing minimum lease terms of one month under the rental assistance
budget line items.
Under this HUD grant agreement, this Joint Component TH-RRH project is allowed to “have leases for a
minimum term of one month under rental assistance budget line items” (per YHDP NOFO Appendix A,
Part I.C.1.a.(1)). The NOFO does not require this project to have any specific policies around when and
how this flexibility is used, but this project wishes to institute one to ensure decisions to allow lease
terms of under 12 months are in the participant’s best interest and are low-risk in their potential to
exploit the participant.
Policy
This Joint-Component TH-RRH project may provide rental assistance under RRH for participants with
leases with a minimum term of one month (usually, the CoC Program requires a minimum lease term of
12 months). The minimum term of one month aims to provide flexibility and accessibility for YYA who
have experienced homelessness, allowing them to secure stable housing without being constrained by
longer-term lease obligations.
Case managers must work with youth participants to identify whether a lease term of under 12 months
(a) is what they want and (b) seems like a strength and seems unlikely to be exploitative to the
participant longer term. Case managers must document their justification for using this flexibility.
Eligible justification:
• Credit or Rental History: For example, YYA has experienced rental evictions or rental debt,
making it challenging to secure a landlord willing to commit to a year-long lease. A flexible
leasing option would help them to demonstrate a commitment to timely payments while
building trust with the landlord.
Alameda County YHDP Joint Component (TH-RRH) Program Manual
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• Housing Uncertainty: For example, YYA's housing plan is currently not aligned with Fair Market
Rent and is on various housing waitlists for affordable housing or other supports outside of this
program. This means they are uncertain about the duration of their waitlisted status and require
a shorter-term lease to avoid being bound by longer-term obligations, ensuring flexibility as
their housing situation evolves.
• Upcoming Life Changes: For example, YYA is planning to enter college and live on campus, enter
into the military, move elsewhere, or move in with a partner in less than 12 months. These life
events introduce a level of uncertainty regarding housing needs, making a shorter-term or
month-to-month lease the most suitable option to support the young person’s choice and goals.
• Fulfilled year-long lease and it’s now changing terms: For example, a YYA had a year-long lease
that they fulfilled and it transitions to month-to-month after the first year.
• Other: This flexibility can be utilized for other reasons as determined by the participant, case
manager, and program manager.
Process
1. The case manager must fill out the form below, including an attached copy of the proposed
lease, whenever a program participant needs or requests a lease term of less than 12 months.
2. Program manager must review within 2 business days. The program manager must document
their approval or denial of the proposed lease term and plan and notify the case manager once a
decision has been made.
a. If denied, and if there is more documentation needed to be able to approve the request,
the case manager must follow up and repeat steps 1 and 2 within a week, in
consultation with the program participant.
3. The case manager must save a copy of the completed form and documentation alongside the
participant’s lease in their case file.
Form
The minimum lease term request form is available at
https://drive.google.com/drive/folders/1bYOuenYT7Sn7TB6L013DGNT3pHUGyEYp
Alameda County YHDP Joint Component (TH-RRH) Program Manual
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(2) Habitability Standards Policy & Procedure
Purpose
This policy supports the implementing agency in using habitability standards rather than Housing Quality
Standards for this Joint-Component TH-RRH grant.
Under this HUD grant agreement, this Joint Component TH-RRH project is allowed to “use habitability
standards in 24 CFR 576.403(c) rather than Housing Quality Standards in 24 CFR 578.75 for short or
medium-term (up to 24 months) housing assistance” (per YHDP NOFO Appendix A, Part I.C.1.a(7)). To
use this special YHDP activity, the NOFO requires the project to “keep documentation of which
standards are applied to the units and proof that the units complied with the standards before
assistance is provided for every unit funded by YHDP.”
Additional resources related to habitability standards may be found at these links:
• ESG Minimum Habitability Standards for Emergency Shelters and Permanent Housing (HUD
Exchange). Includes:
o Overview document of HUD’s habitability standards as they apply to emergency shelter
and permanent housing settings
o Sample habitability inspection checklist.
• Sample Habitability Standards Checklist (hud.gov)
Policy
In the first 30 days, and at least once every 12 months during the period of assistance, case managers
are required to conduct a habitability standards inspection using the attached form for any participant
housed by this program to ensure that any unit for which this project is paying leasing or rental
assistance meets HUD’s habitability standards in 24 CFR 576.403(c).
Program managers are required to review and approve all Habitability Standards Forms before the
program pays for any rental assistance or leasing dollars toward a program participant’s housing. Ideally,
participants should not sign leases before completing the inspection, as doing so may risk loss of security
deposit or other negative impacts on their rental history and credit.
Process
1. Case manager conducts a habitability standards inspection using the Habitability Standards
Form that accompanies this policy within 3 business days of the unit being identified as an
option for a program participant.
a. If the unit does not pass inspection, the case manager provides required updates to the
landlord.
i. If the landlord makes the requisite fixes, the case manager must re-do step 1
before moving to step 2.
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ii. If the landlord does not comply with the request, then the participant / case
manager must find another unit for the participant to move into that does pass
inspection.
2. If the unit passes the inspection, the case manager submits the form to the program manager.
3. Program manager reviews the Habitability Standards Form within 1 business day.
a. If the program manager has questions or concerns with the form’s completion or the
state of the unit, they must discuss with the case manager within 2 business days to
determine next steps.
4. If the program manager approves the Habitability Standards Form, they sign off on it and notify
the case manager that they can move forward with next steps to support the program
participant in signing a lease and moving into the unit.
5. Case manager must save a copy of the completed and signed Habitability Standards Form in
each program participant’s file and upload in HMIS.
Form
The habitability standards form is available at
https://drive.google.com/drive/folders/1bYOuenYT7Sn7TB6L013DGNT3pHUGyEYp
Alameda County YHDP Joint Component (TH-RRH) Program Manual
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(3) Flexible Costs Policy & Procedure
Purpose
This policy enables the agencies implementing this Joint-Component TH-RRH project to spend
supportive service dollars on specific costs and activities beyond those normally allowed under the CoC
Interim Rule. For more information on allowable costs, see Appendix B.
Under this HUD grant agreement, this Joint Component TH-RRH project is allowed to pay for or directly
provide the specific costs/activities detailed in the policy section below (per YHDP NOFO Appendix A,
Part I.C.1.a.(10), subparts (a), (b), (c), (d), (e), (f), (g), (h), (i), (j), and (k)). In alignment with HUD’s
requirements as stated in the YHDP NOFO Appendix A, Alameda County Housing & Homelessness
Services staff notified HUD’s Deputy Assistant Secretary of Special Needs via email (to Micah Sneed and
youthdemo@hud.gov) that this project also intended to use special activity I.C.1.a(10)(l), which was not
originally included in the HUD grant agreement.
To use this special YHDP activity, the NOFO requires the project to “maintain records establishing how it
was determined paying the costs was necessary for the program participant to obtain and retain
housing and must also conduct an annual assessment of the needs of the program participants and
adjust costs accordingly.”
Policy
This project may pay for or directly provide the following “flexibilities,” if they are necessary to assist
program participants to obtain and maintain housing. In addition to the required documentation and
payment guidelines listed for each item, the program must (1) maintain documentation justifying why
paying the costs was necessary for the program participant to obtain and retain housing and (2)
conduct annual assessment of program participant needs and adjust costs accordingly. The form that
accompanies this policy embeds prompts to maintain this documentation alongside other required
documentation.
Flexibility Required Documentation Payment Guidelines
a. Security deposits for units
in an amount not to
exceed 2 months of rent
• Lease in participant’s name,
documenting security deposit
and rent amounts
• W-9 form for landlord
• Payment must be
made directly to the
landlord
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Flexibility Required Documentation Payment Guidelines
b. The costs to pay for any
damage to housing due to
the action of a program
participant, which may be
paid while the youth
continues to reside in the
unit. The total costs paid
for damage per program
participant may not
exceed the cost of two
months’ rent.
• Lease in participant’s name,
documenting monthly rent
amount
• Photos of the damage to be
repaired
• If contracting with a person or
company to do the repairs: At
least 2 estimates for the cost to
repair damage to justify cost
reasonableness
• If building / landlord is managing
the repairs: invoice from them
for costs to be incurred.
• Receipts from contractors paid
or materials purchased to repair
damage
• All payments must be
made directly to a
third party. This could
be the person or
company that repairs
the damage (if
contracting) or the
store from which
materials used to
repair damage were
purchased.
c. The costs of providing
household cleaning
supplies to clients.
• Itemized receipt of household
cleaning supplies purchased.
• Can be paid directly to
store or company
from which supplies
are purchased
• If paying with a gift
card: this amount is
not reimbursable
unless you have a
receipt for the total
amount of the gift
card that details that
all funding went
toward cleaning
supplies.
d. Housing start-up expenses
for program participants,
including furniture, pots
and pans, linens,
toiletries, and other
household goods, not to
exceed $300 in value per
program participant.
• Itemized receipt of items
purchased.
• Verify that it costs $300 or less
per participant.
• Can be paid directly to
store or company
from which items are
purchased
• If paying with a gift
card: this amount is
not reimbursable
unless you have a
receipt for the total
amount of the gift
card that details that
all funding went
toward eligible items.
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Flexibility Required Documentation Payment Guidelines
• Cannot exceed $300.
e. The one-time cost of
purchasing a cellular
phone and service for
program participant use,
provided that access to a
cellular phone is
necessary to obtain or
maintain housing and the
costs of the phone and
services are reasonable
per 2 CFR 200.404.
• Itemized receipt for the cell
phone purchased
• Itemized receipt for the service
deposit paid (if applicable)
• Justification for reasonable cost
• Must pay vendor of
cell phone or service
deposit directly
• This cost can only be
incurred one time per
participant. This
means that you
cannot pay for cell
phone service
ongoing. This can only
cover the service
deposit cost, if
applicable.
f. The cost of internet in a
program participant’s unit
and the costs of the
service is reasonable per 2
CFR 200.404.
• Invoice for the cost of internet
services with the participant’s
name and unit address (which
must match the address on their
lease or the unit in which the
program holds a lease for them to
reside) on the invoice
• Justification for reasonable cost
• Must pay internet
service provider
directly
g. Payment of rental arrears
consisting of a one-time
payment for up to 6
months of rent in arrears,
including any late fees on
those arrears.
• Copy of the lease under which the
participant accrued arrears. Their
name must be on the lease.
• Invoice for rental arrears accrued
• Documentation of the number of
months of rental arrears paid (can
include late fees)
● Documentation that rental arrears
were paid to the landlord in
accordance with the lease
(recommend getting landlord’s W9,
too)
• Must pay the landlord
directly.
• Program can only make
this payment one time.
h. Payment of utility arrears
of up to 6 months per
service.
• Invoice for utility arrears accrued,
for each utility service to which
arrears have been applied. The
participant’s name must be on
the account.
• Documentation of the number of
months of utility arrears paid. If
the utility company cannot
• Must pay the utility
company(ies) directly.
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Flexibility Required Documentation Payment Guidelines
provide a month by month
breakdown, document
assumptions and justification for
how many estimated months this
payment includes.
i. (i) Up to three months of
utilities for a program
participant, based on the
utility costs schedule for
the unit size and location.
• Invoice for the cost of
utilities with the
participant’s name and unit
address (which must match
the address on their lease or
the unit in which the
program holds a lease for
them to reside) on the
invoice. Dates of service
must occur during
participant’s enrollment in
the project; if they were from
before, please refer to the
utility arrears section above.
• Must use current utility costs
schedule for the unit size and
location. These are set by the
local Housing Authority. The
current (June 2024) version is
available here: Utility Allowance
| Housing Authority Of County
Of Alameda HACA
• Itemized receipt for payment
made directly to the utility
service that aligns with utility
allowance and utility bill.
• Must pay directly to
the utility service.
j. In addition to
transportation costs
eligible in 24 CFR
578.53(e)(15), a recipient
may pay gas and mileage
costs for a program
participant’s personal
vehicle for trips to and
from medical care,
employment, childcare, or
• If paying for gas: Documentation
of the # of miles the participant is
driving to eligible locations (work,
school, child care, medical
appointments, or other services
eligible under this grant), an
estimated number of miles per
gallon needed to drive that
amount, and an itemized gas
receipt showing that the program
• If paying for gas: Must
pay for gas directly to
align # gallons
purchased with miles
driven, as noted to the
left.
• If paying for mileage:
Can pay the program
participant directly.
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Flexibility Required Documentation Payment Guidelines
other services eligible
under this section.
only paid for gas for the
participant to get to eligible
locations.
• If paying for mileage: A mileage
log with each date mileage is
provided, # miles driven, and the
origin and destination (which can
only be to the same eligible
services/ activities as noted
above). Use the relevant federal
mileage rate, available here:
Privately owned vehicle (POV)
mileage reimbursement rates |
GSA. (For 2024, the rate is
$0.67/mile)
k. Legal fees, including court
fees, bail bonds, and
required courses and
equipment.
• Official documentation of the
amount owed and for what,
including the participant’s name
• Payment must be made
directly to the third
party charging the fees
or providing the
courses or equipment.
Before paying for any of the costs detailed above, the case manager must complete the form below, and
the program manager must sign off.
Program managers should regularly (at least quarterly) review total spending per participant to monitor
that program participants have equitable access to these (and other) service costs, depending on their
circumstance and need. That is, participants should have equal access to these resources, regardless of
who their case manager is and regardless of how much funding they need to obtain and maintain
housing.
Process
1. Case manager works with program participant to identify when these eligible costs would
support the young person in obtaining or maintaining their housing.
2. Case manager fills out the Flexible Costs Form below, attaches any required documentation, and
submits it to the program manager for review.
3. Program manager reviews within 2 business days.
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a. If they have further questions or deny the request, they must communicate that and
any needed next steps or additional documentation to the case manager. The case
manager must repeat step 2 if applicable.
4. If the program manager approves the request, the case manager must file this form and the
accompanying documentation in the participant’s file. The agency should follow their internal
processes for getting direct costs paid.
Forms
All required forms for utilizing the YHDP flexible costs are available at
https://drive.google.com/drive/folders/1Yc887-d7pSPRNvsLhZ4s14tJHYYdjGPj?usp=sharing
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(4) Additional Rental Assistance (24 to 36 Total Months) Policy & Procedure
Purpose
This policy documents what agencies must do to provide more than 24 months of RRH rental assistance
and up to a maximum of 36 months of rental assistance to project participants.
Under this HUD grant agreement, this Joint Component TH-RRH project is allowed to provide project
participants with up to 36 months of rental assistance in RRH (per YHDP NOFO Appendix A, Part
I.C.1.b(1)). To use this flexibility, the NOFO requires the project to demonstrate: “(1) the method it will
use to determine which youth need rental assistance beyond 24 months and (2) the services and
resources that will be offered to ensure youth are able to sustain their housing at the end of the 36
months of assistance.”
Policy
This Joint-Component TH-RRH project may provide rental assistance under RRH for participants for up to
24 total months without special permission, and up to 36 total months if approved under this policy.
RRH rental assistance extensions may be requested in 3- or 6-month increments, up to a maximum of 36
total months of rental assistance, to address specific barriers impacting the participant’s housing
stability.
Case managers must work with participants to identify (1) why they have a need for more than 24
months of rental assistance, and (2) how the participant and case manager will support the participant
in being able to sustain housing long-term at the end of their housing assistance.
Eligible justification for extended rental assistance:
• Health/Medical Issues that impact participant’s housing and self-sufficiency. This may include
changes in medical/health status over the course of program enrollment (e.g., new diagnoses) or
ongoing chronic health/medical issues that the participant needs additional time to stabilize.
• Mental health, addiction, or developmental issues, either new or ongoing, that interfere with the
participant’s progress in achieving self-sufficiency.
• Job loss or other reduction in income that renders the participant unable to afford the full cost of
housing/utilities.
• Social factors or experiences that have impacted the participant’s progress in achieving self-
sufficiency. This could include changes in circumstances related to the participant’s
pregnancy/parenting status, domestic violence, bereavement, victimization, legal issues, or human
trafficking.
• Student status or enrollment in a training program that impacts the participant’s ability to
maintain a full-time income for a set period of time.
• Other (must specify and provide supporting documentation).
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Process
1. At least one month before the program participant’s rental assistance is set to expire (i.e., by
the 23rd month of rental assistance and at least a month before any previously approved
extensions expire), the case manager works with program participant to identify whether they
may need ongoing housing assistance.
2. Case manager fills out the Additional Rental Assistance Request Form below and submits it to
the program manager for review.
3. The program manager reviews within 5 business days.
a. If they have further questions or deny the request, they must communicate that and
any needed next steps or additional documentation to the case manager. The case
manager must repeat step 2 if applicable.
4. If the program manager approves the request, the case manager must file this form in the
participant’s file.
Form
The Additional Rental Assistance Request form is available at
https://drive.google.com/drive/folders/1bYOuenYT7Sn7TB6L013DGNT3pHUGyEYp
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(5) Additional Supportive Services Assistance (6 to 36 Total Months after End of Rental
Assistance) Policy & Procedure
Purpose
This policy documents what agencies must do to provide more than 6 months and up to 24 total months
of supportive services to project participants after their last housing assistance payment (i.e., after the
last RRH rental assistance payment).
Under this HUD grant agreement, this Joint Component TH-RRH project is allowed to provide project
participants with up to 24 months of services after their last RRH rental assistance payment or up to 36
months if the services are in connection with housing assistance, such as the Foster Youth to
Independence initiative, or if the recipient can demonstrate that extended supportive services ensures
continuity of case workers for program participants (per YHDP NOFO Appendix A, Part I.C.1.b(2)). To use
this flexibility, the NOFO requires the project to demonstrate: “(1) the proposed length of extended
services to be provided; (2) the method it will use to determine whether services are still necessary; and
(3) how those services will result in self-sufficiency and ensure stable housing for the YHDP program
participant.”
Policy
This Joint-Component TH-RRH project may provide supportive services (including paying direct costs
covered under those eligible for this grant’s supportive services) to participants for up to 6 months after
their last rental assistance payment without special permission, and up to 24 total months after their
last rental assistance payment if approved under this policy.
Supportive services extensions may be requested in 3- or 6-month increments, up to a maximum of 24
total months of post-housing-assistance services, to address specific barriers impacting the participant’s
housing stability.
Case managers must work with participants to identify (1) why they have a need for more than 6
months of services after their housing assistance ends, (2) the services to be provided, and (3) how the
participant and case manager will support the participant in being able to sustain housing long-term
once their access to these services ends.
Eligible justification for extended supportive services:
• Health/Medical Issues that impact participant’s housing and self-sufficiency. This may include
changes in medical/health status over the course of program enrollment (e.g., new diagnoses)
or ongoing chronic health/medical issues that the participant needs additional time to stabilize.
• Mental health, addiction, or developmental issues, either new or ongoing, that interfere with
the participant’s progress in achieving self-sufficiency.
• Job loss or other reduction in income that renders the participant unable to afford the full cost
of housing/utilities.
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• Social factors or experiences that have impacted the participant’s progress in achieving self-
sufficiency. This could include changes in circumstances related to the participant’s
pregnancy/parenting status, domestic violence, bereavement, victimization, legal issues, or
human trafficking.
• Student status or enrollment in a training program that impacts the participant’s ability to
maintain a full-time income for a set period of time.
• Other (must specify and provide supporting documentation).
Process
1. At least one month before the program participant’s supportive services timeframe is set to
expire (i.e., by the 5th month after their last rental assistance payment and at least a month
before any previously approved extensions expire), the case manager works with program
participant to identify whether they may need ongoing supportive services.
2. Case manager fills out the Additional Supportive Services Assistance Form below and submits it
to the program manager for review.
3. The program manager reviews within 5 business days.
a. If they have further questions or deny the request, they must communicate that and
any needed next steps or additional documentation to the case manager. The case
manager must repeat step 2 if applicable.
4. If the program manager approves the request, the case manager must file this form in the
participant’s file.
Form
The Additional Supportive Services Assistance Request form is available at
https://drive.google.com/drive/folders/1bYOuenYT7Sn7TB6L013DGNT3pHUGyEYp
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(6) Employing People Enrolled in Services Policy & Procedure
Purpose
This policy documents what agencies must do when employing current or former participants to avoid
conflicts of interest and inappropriate power dynamics.
Under this HUD grant agreement, this Joint Component TH-RRH project is allowed to employ youth who
are receiving services from this project or agency (per YHDP NOFO Appendix A, Part I.C.1.a(6)). To
employ youth who meet this definition, the NOFO requires the project to “maintain documentation that
discloses the nature of work that the youth does, and that the youth is not in a position that creates a
conflict of interest.”
Policy
Agencies implementing this project are committed to hiring young people whose lived experience and
other skills equip them to be excellent staff supporting people experiencing or at risk of homelessness.
This agency is committed to ensuring that, upon hiring people with past, current, or future engagement
as service participants in this or other programs operated by the employing agency, this will not present
a conflict of interest for the person hired or anyone else on staff.
Supervisors who supervise any employee who is also enrolled in services as a participant must include in
regular check-ins questions about any conflicts of interest that are coming up, including any potentially
uncomfortable or coercive power dynamics arising from the person’s role as both employee and service
participant.
Process
When hiring a young person enrolled in the Joint Component TH-RRH project or other services offered
by the agency implementing this project, the Joint Component TH-RRH project’s program manager must
complete the relevant form(s) below and keep this documentation on file in both the employee’s
records and in their participant records/case file.
Form
Forms for employing current or former participants and for enrolling current employees available at
https://drive.google.com/drive/folders/1bYOuenYT7Sn7TB6L013DGNT3pHUGyEYp
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General Policies
(7) Food Provision Policy
Each program is expected to provide a monthly allocation of groceries to each participant in the project.
This support should be provided regardless of any other food assistance the participant is receiving.
Each program should provide $200/month of grocery assistance to each household, regardless of the
number of household members. The amount of assistance is set at the project level and cannot be
adjusted without notifying the CoC or collaborative applicant and getting approval from the Youth
Action Board.
Please note that you must be able to document that funds were spent on food items only for
participants that are enrolled in the YHDP- funded program.
(8) Income Verification Policy
YHDP RRH programs are governed by section 578.37(a)(1)(ii) of the CoC Program interim rule, the CoC’s
written standards, and these policies.
The CoC Program interim rule does not identify any required documentation for determining income
when calculating a participant’s rent contribution. Additionally, the interim rule does not address the
timeframe for income verification documentation. Therefore, the timeframe and documentation
standards for YHDP-RRH projects have been by local policy.
SSI/SSDI and other documentation generally provided on
an annual basis
Must be dated within a year
Pay stubs and other documentation generally provided
on a monthly or weekly basis
Must be dated within 30 days
Non-traditional work (unverifiable) Can be self-reported/estimated without
documentation
Income should be re-certified every 3-months to determine the amount of contribution toward rent to
be paid by the program participant. Adjustments to a program participant’s rent contribution must be
made as changes in income are identified.
Significant Change in Status
A significant change in status is defined as an unplanned life event that occurs outside of the
household’s control, that significantly decreases their income and causes significant hardship. Case
managers can re calculate the household’s rent portion immediately if a significant change of status has
occurred. This can include, but is not limited to:
1. Fleeing domestic violence or other threats of violence
2. Unemployment and delay in unemployment benefits
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3. Major medical or psychiatric hospitalization of household, or household’s immediate family
member
4. Death of a child or immediate family member
5. Enrollment in short term vocational or educational program that will lead to increased earning
potential at the end of the program (* this may be a planned event at the time of entry into the
program)
6. An unplanned event that the case manager deems significant enough in nature to determine a
rent recalculation or payment plan would be appropriate. (please note that rationale for this
must be clearly documented in the case notes.)
A participant must not be terminated from housing if their income cannot be recertified.
Additional Resources:
• Part 5 (Section 8) Income and Asset Inclusions and Exclusions:
https://www.hudexchange.info/resource/5180/part-5-section-8-income-inclusions-and-
exclusions/
• Part 5: Determining Income and Calculating Rent: PHOG_Income_Determination_FINAL
(hud.gov)
(9) Program Termination
Programs are strongly encouraged to proactively outreach and use case management with program
participants to help them comply with the terms of their lease and maintain housing stability.
Programs should provide a written termination and grievance procedure, including the process by which
participants can provide feedback. Participants should acknowledge they have received a copy of the
program’s rules and termination and grievance policy prior to receiving assistance. This
acknowledgement should be documented in the participant’s file. Participants should only be
considered for termination for severe and/or repeated offenses.
Causes for Mediation and Possible Termination (including but not limited to:
• Persistently making others feel unsafe with harassment or violence.
• Persistent substance use or substance selling/manufacturing causing an unsafe situation for
oneself or others.
• Persistent violation of house/program norms resulting in an unsafe situation for others.
• Persistent violation of lease between participant and landlord and refusal to participate in a
corrective action plan / landlord-participant mediation.
• Destruction of property.
• Extended period of no contact with program staff.
Mediation/Termination Procedure:
First Step – Verbal and written warning that the participant will be terminated if they continue to
violate program rules and a description of corrective steps to take. Participant and Case Worker will
collaborate on a corrective action plan.
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Second Step – Mediation meeting with the Case Worker and Supervisor and discussion in case
conferencing.
Third Step (if necessary) – Solutions and suggestions will be provided by agency leadership and a
final warning given to the participant.
Fourth Step – Termination from the program. Participant receives verbal and written confirmation
of their termination. Referred to other support services as eligibility allows.
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Appendix B:
Alameda County YHDP Joint Component TH-RRH Spending Guidance
CONTENTS
Supportive Services ...................................................................................................................... 38
Annual Assessment of Service Needs ................................................................................................. 39
Assistance with Moving Costs ............................................................................................................. 39
Case Management .............................................................................................................................. 39
Child Care ............................................................................................................................................ 39
Education Services .............................................................................................................................. 40
Employment Assistance and Job Training ........................................................................................... 41
Food .................................................................................................................................................... 42
Housing Search and Counseling Services ............................................................................................ 43
Legal Services ...................................................................................................................................... 44
Life Skills Training ................................................................................................................................ 45
Mental Health Services ....................................................................................................................... 45
Outpatient Health Services ................................................................................................................. 45
Outreach Services ............................................................................................................................... 46
Substance Abuse Treatment Services ................................................................................................. 46
Transportation ..................................................................................................................................... 46
Utility Deposits .................................................................................................................................... 49
Direct Provision of Services ................................................................................................................. 49
Additional Eligible Costs via YHDP Flexibilities.................................................................................... 49
Cleaning Supplies
Housing Start-Up Expenses
Cell Phones
Internet
Ineligible Supportive Services Costs .................................................................................................... 50
Rental Assistance ......................................................................................................................... 50
Monthly Rent ...................................................................................................................................... 50
Personnel ............................................................................................................................................ 51
Security deposits ................................................................................................................................. 51
Utility Allowances ............................................................................................................................... 51
Additional YHDP Eligible Cost: Property Damages ............................................................................. 51
Additional YHDP Eligible Cost: Rental Arrears .................................................................................... 51
Additional YHDP Eligible Cost: Utility Arrears .................................................................................... 52
Administrative Costs ..................................................................................................................... 52
Additional YHDP Eligible Administrative Costs ................................................................................... 53
Operating Costs (TH Only) ............................................................................................................. 53
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This guide was developed in collaboration with technical assistance (TA) partners specifically for
Alameda County’s YHDP Joint-Component Transitional Housing-Rapid Re-Housing (TH-RRH) project. It
includes guidance from the CoC Program Interim Rule, HUD’s Ask-A-Question (AAQ) desk, and the FY
2019/2020 YHDP Notice of Funding Opportunity (NOFO) (specifically Appendix A) on what this grant can
and cannot spend funds on. It is provided specifically to address what HUD’s requirements are, though
there may be local policies and requirements that impose stricter limits on some activities and items.
Where applicable, this project must use the YHDP flexibilities policies, procedures, and forms provided
in Appendix A to implement these special activities, as many of them require the project staff to
document a standard process for determining when special activities should be used.
Supportive Services
Grant funds may be used to pay the eligible costs of supportive services that address the special needs
of the program participants. If the supportive services are provided in a supportive service facility not
contained in a housing structure, the costs of day-to-day operation of the supportive service facility,
including maintenance, repair, building security, furniture, utilities, and equipment are eligible as a
supportive service.
Supportive services must be necessary to assist program participants obtain and maintain housing.
The program must conduct an annual assessment of the service needs of the program participants and
should adjust services accordingly.
For transitional housing, supportive services must be made available to residents throughout the
duration of their residence in the project.
Services may also be provided to former residents of transitional housing and current residents of
permanent housing who were homeless in the prior 6 months, for no more than 6 months after leaving
transitional housing or homelessness, respectively, to assist their adjustment to independent living.
Rapid rehousing projects must require the program participant to meet with a case manager not less
than once per month as set forth in § 578.37(a)(1)(ii)(F), to assist the program participant in maintaining
long-term housing stability.
Eligible supportive services are covered in § 578.53 Supportive services, subsection (e) Eligible Costs, of
the CoC Program Interim Rule. Each one is listed below, alongside some additional guidance on how it
can and can’t be used.
Costs in this section are also inclusive of the costs of staff to provide these services.
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Annual Assessment of Service Needs
From the CoC Interim Rule: The costs of conducting annual assessment as required by CoC Interim Rule
§ 578.53(a)(2).
Assistance with Moving Costs
Normally, under the CoC Interim Rule, a project can provide moving expenses one time per participant;
however, this program may provide moving expenses more than one time to a program participant as
a special YHDP activity/flexibility.
Eligible costs under this activity include:
• Hiring a moving company
• Renting a truck/vehicle to move
Note that each “time” you use this activity per client this doesn’t just have to be one single day or trip to
move, as long as it’s a single incident of moving into one unit. That is, you could have costs associated
with moving someone’s things from a storage unit to new unit, could pick up furniture from a furniture
bank on a different day, etc.
Case Management
From the CoC Interim Rule: “The costs of assessing, arranging, coordinating, and monitoring the delivery
of individualized services to meet the needs of program participants. Activities include:
• Counseling;
• Developing, securing, and coordinating services;
• Using the centralized or coordinated assessment system as required under CoC Interim Rule §
578.23(c)(9).
• Obtaining federal, State, and local benefits;
• Monitoring and evaluating program participant progress;
• Providing information and referrals to other providers;
• Providing ongoing risk assessment and safety planning with victims of domestic violence, dating
violence, sexual assault, and stalking; and
• Developing an individualized housing and service plan, including planning a path to permanent
housing stability.”
Child Care
From the CoC Interim Rule: “The costs of establishing and operating child care, and providing child-care
vouchers, for children from families experiencing homelessness, including providing meals and snacks,
and comprehensive and coordinated developmental activities, are eligible.
• The children must be under the age of 13, unless they are disabled children.
• Disabled children must be under the age of 18.
• The child-care center must be licensed by the jurisdiction in which it operates in order for its
costs to be eligible.”
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Education Services
The CoC Interim Rule allows for “the costs of improving knowledge and basic educational skills.” These
include:
• Services include instruction or training in consumer education, health education, substance
abuse prevention, literacy, English as a Second Language, and General Educational Development
(GED).
• Component services or activities are screening, assessment and testing; individual or group
instruction; tutoring; provision of books, supplies, and instructional material; counseling; and
referral to community resources.”
In general, eligible educational expenses under the CoC Program should be used for classes or
training provided by the service provider (i.e., the recipient) (or a subrecipient, contractor, or outside
vendor).
When the service provider (i.e., the recipient) (or a subrecipient, contractor, or outside vendor) is
providing educational services, some supplies such as a computer may be eligible. (See the section
below on purchasing technology as an education service)
In some cases, CoC Program funds may be used to pay for a class or a few classes at an institution of
learning, such as a community college, to provide program participants with basic skills that are directly
necessary for increasing their self-sufficiency, such as ESL classes or basic computer skills. However, in
no case can CoC Program funds be used to pay for the full cost of tuition for a degree or vocational
accreditation. In some cases, a vocational accreditation may be an eligible expense under section
578.53(e)(6), employment assistance and job training, but in no cases would it be eligible under
education services.
However, the cost of obtaining something like a commercial driver’s license (CDL) and/or certificate
could be considered an eligible employment assistance cost so long as the cost is reasonable and
appropriate.
OMB Circular 2 CFR 200.75 outlines participant support costs such as stipends, which are allowable in
connection with training projects. Similarly, the COC Program interim rule at Section 578.53(e)(6) states:
"The cost of providing reasonable stipends to program participants in employment assistance and job
training programs is also an eligible cost." A recipient may provide a stipend when a participant
participates in an employment assistance and job training programs, even one operated by another
organization.
A "stipend" is fixed sum of money paid periodically to program participants for services or to defray
expenses. The stipend must be paid directly to program participants. Once the program participant
receives the stipend (s)he may use it to cover his or her expenses.
As it relates to what would be considered a "reasonable" stipend would be, "reasonable" refers to the
amount being paid or provided to defray costs as similar when compared to similar tasks or
expenses. You should take into consideration the costs of living for your particular region. This means
that reasonable will vary from community to community based on the cost of living. For example, if you
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are trying to defray the costs of travel, then you should consider the costs of travel in general for your
region.
Recipients must document that the stipend covers reasonable costs.
Technology to Support Education Services
The short answer is: no, you can’t buy clients technology even if it supports their education or
employment. Here’s official language from the AAQ:
“For the purpose of this response, consider "computer" to refer to computers, laptops, tablets, mini-
pads like the iPad, etc.
Computers/laptops/tablets
No CoC (this includes YHDP) Program grant funds may not be used to purchase computers
that participants consider their own. If a computer is for the personal use by program participants, it is
not an eligible CoC program cost.
There is one exception about computer costs for participants. Section 578.53(e)(5) Educational Services
provides that the costs of improving knowledge and basic educational skills are eligible costs under the
CoC Program. Eligible component services or activities include supplies and instructional material. The
costs of a computer for program participants to use (but not own) may be considered an eligible supply
so long as it is necessary and directly related to carrying out educational activities and so long as it is
necessary for program participants to obtain and maintain housing.
Further, the cost of a computer must comply with the requirements in the Omni Circular (2 CFR 200).
The Omni Circular requires that all CoC Program costs must be reasonable and appropriate. In addition,
in order for the computer to be considered a supply rather than equipment, the cost must be less than
$5000. Keep in mind, it important that the recipient or subrecipient maintain documentation that all of
the requirements above are documented and maintained in the organizations records for the timeframe
required by the program regulation (see 24 CFR 578.103 for more information).
CoC Program interim rule: https://www.hudexchange.info/resource/2033/hearth-coc-program-
interim-rule/
Employment Assistance and Job Training
The CoC Interim Rule states that the following are eligible under this line item: “The costs of establishing
and operating employment assistance and job training programs are eligible, including classroom, online
and/or computer instruction, on-the-job instruction, services that assist individuals in securing
employment, acquiring learning skills, and/or increasing earning potential. The cost of providing
reasonable stipends to program participants in employment assistance and job training programs is also
an eligible cost.
• Learning skills include those skills that can be used to secure and retain a job, including the
acquisition of vocational licenses and/or certificates.
• Services that assist individuals in securing employment consist of:
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o Employment screening, assessment, or testing;
o Structured job skills and job-seeking skills;
o Special training and tutoring, including literacy training and pre-vocational training;
o Books and instructional material;
o Counseling or job coaching; and
o Referral to community resources.”
If you’re doing employment services, you have flexibility to pay for things like work clothes, expensive
certification programs, etc.
Additionally, the CoC Program interim rule does not identify a maximum amount that can be spent on
employment assistance and job training. Nevertheless, recipients and subrecipients should consider
several factors:
• The OMB Omni-Circular at 24 CFR Part 200 requires that all costs paid for with federal funds
must be allowable, reasonable, and allocable. In addition, the recipient or subrecipient must
maintain documentation that all of the requirements above are documented and maintained in
the organizations records for the timeframe required by the program regulation. (See 24 CFR
578.103 for more information.)
https://www.federalregister.gov/articles/2013/12/26/2013-30465/uniform-administrative-
requirements-cost-principles-and-audit-requirements-for-federal-awards
• In their policies and procedures, recipients/subrecipients should document their decision-
making process and practices for paying for supportive services like employment assistance and
job training and educational assistance. Policies and procedures need to be clearly understood
by participants and applied consistently.
• Grant funds are limited. Recipients/subrecipients should take budget constraints into
consideration when deciding the payment amounts for various programs.
Food
From the CoC Interim Rule: “The cost of providing meals or groceries to program participants is eligible.”
Note that you must have itemized receipts for what was purchased, and you can only seek
reimbursement after a purchase has been made.
The cost of gift cards to grocery stores or other places are not eligible costs in and of themselves. They
are only eligible costs (and therefore only reimbursable) once they have been used to pay for eligible
food purchases, and only in the amount used to purchase eligible items.
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Housing Search and Counseling Services
From the CoC Interim Rule: “Costs of assisting eligible program participants to locate, obtain, and retain
suitable housing are eligible.
• (i) Component services or activities are tenant counseling; assisting individuals and families to
understand leases; securing utilities; and making moving arrangements.
• (ii) Other eligible costs are:
o (A) Mediation with property owners and landlords on behalf of eligible program
participants;
o (B) Credit counseling, accessing a free personal credit report, and resolving personal
credit issues; and
o (C) The payment of rental application fees.”
• (iii) Housing counseling, as defined in § 5.100, that is funded with or provided in connection with
grant funds must be carried out in accordance with § 5.111. When recipients or subrecipients
provide housing services to eligible persons that are incidental to a larger set of holistic case
management services, these services do not meet the definition of Housing counseling, as
defined in § 5.100, and therefore are not required to be carried out in accordance with the
certification requirements of § 5.111.
With regard to housing search and counseling services, the Housing Counseling Final Rule defines
housing counseling as: independent, expert advice customized to the need of the consumer to address
the consumers’ housing barriers and achieve their housing goals and must include the following process:
intake; financial and housing affordability analysis; an action plan, except for reverse mortgage
counseling; and a reasonable effort to have follow-up communication with the client when possible.
It is generally understood that the following are eligible activities:
• Tenant counseling
• Assisting individuals and families to understand leases
• Securing utilities
• Making moving arrangements
• Mediation with property owners and landlords on behalf on eligible program participants
• Credit counseling, assessing a free personal credit report, and resolving personal credit issues;
and
• Payment of rental application fees
Credit Repair
Common question: How is "resolving personal credit issues" defined and what activities are allowed?
"Personal credit issues" typically refer to factors that affect a person's credit report and the evaluation
of their applications for credit, insurance, employment, and leases, to include debt and debt
collections; late payments on bills, rent, and student loans; and unpaid judgments.
Activities related to resolving those issues could include assisting participants connect with reputable
housing counseling agencies or credit counseling organizations, obtain their credit
reports, dispute credit reports or billing, or communicate with a debt collector.
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CoC Program funds can be used for the staff and overhead costs to engage in these activities with
participants. Section 578.59(a) of the CoC Program interim rule states that staff and overhead costs
directly related to carrying out activities that are eligible under §578.43 through § 578.57 are eligible as
part of those activities in the grant agreement.
Resolving personal credit issues does not include making payments on a client's behalf. Unfortunately,
past bills incurred by clients prior to entry are not an eligible cost under the CoC Program interim
rule. HUD recommends using leveraged funds to cover debt, such as a credit report fee. Resolving
personal credit issues by paying a fee on a credit report would not qualify as housing counseling because
it doesn't meet the definition from the Housing Counseling Final Rule as stated above.
Leverage in the CoC Program is cash and in-kind contributions in excess of the minimum required match
contributions for a project. A recipient/subrecipient may use leveraged funds for other aspects of a
project even if the costs are not allowable in the CoC Program.
Legal Services
From the CoC Interim Rule: Eligible costs are the fees charged by licensed attorneys and by person(s)
under the supervision of licensed attorneys, for advice and representation in matters that interfere with
the homeless individual or family's ability to obtain and retain housing.
• (i) Eligible subject matters are child support; guardianship; paternity; emancipation; legal
separation; orders of protection and other civil remedies for victims of domestic violence, dating
violence, sexual assault, and stalking; appeal of veterans and public benefit claim denials;
landlord tenant disputes; and the resolution of outstanding criminal warrants.
• (ii) Component services or activities may include receiving and preparing cases for trial,
provision of legal advice, representation at hearings, and counseling.
• (iii) Fees based on the actual service performed (i.e., fee for service) are also eligible, but only if
the cost would be less than the cost of hourly fees. Filing fees and other necessary court costs
are also eligible. If the subrecipient is a legal services provider and performs the services itself,
the eligible costs are the subrecipient's employees' salaries and other costs necessary to
perform the services.
• (iv) Legal services for immigration and citizenship matters and issues related to mortgages and
homeownership are ineligible. Retainer fee arrangements and contingency fee arrangements
are ineligible.
Additional YHDP Eligible Cost: Legal Fees
YHDP grant funds may be used for the following if they are necessary to assist program participants to
obtain and maintain housing:
• Legal fees, including court fees, bail bonds, and required courses and equipment.
You must follow your written policies and procedures and maintain records establishing how it was
determined that paying this cost was necessary for the participant to obtain and retain housing.
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Assistance with Naturalization Documentation
[The following comes from the AAQ. The requestor asked specifically about being able to file Form N-565,
Application for Replacement Naturalization/Citizenship Document, with a $555 filing fee, to support a
young person in a YHDP RRH project in getting access to existing citizenship records.]
As noted above, legal services for immigration and citizenship matters are not eligible costs under the
CoC Program. However, under Section 578.53(e)(9)(iii) of the CoC Program interim rule, filing fees and
other necessary court costs are eligible when they help a program participant obtain and maintain
housing. Therefore, you could use your supportive service budget line item to pay for the cost of the
filing fee.
Life Skills Training
From the CoC Interim Rule: “The costs of teaching critical life management skills that may never have
been learned or have been lost during the course of physical or mental illness, domestic violence,
substance abuse, and homelessness are eligible. These services must be necessary to assist the program
participant to function independently in the community. Component life skills training are the budgeting
of resources and money management, household management, conflict management, shopping for
food and other needed items, nutrition, the use of public transportation, and parent training.”
Mental Health Services
From the CoC Interim Rule: “Eligible costs are the direct outpatient treatment of mental health
conditions that are provided by licensed professionals. Component services are crisis interventions;
counseling; individual, family, or group therapy sessions; the prescription of psychotropic medications or
explanations about the use and management of medications; and combinations of therapeutic
approaches to address multiple problems.”
Outpatient Health Services
The CoC Interim Rule names eligible costs are the direct outpatient treatment of medical conditions
when provided by licensed medical professionals including:
• Providing an analysis or assessment of an individual's health problems and the development of a
treatment plan
• Assisting individuals to understand their health needs;
• Providing directly or assisting individuals to obtain and utilize appropriate medical treatment
(this includes glasses and other medical equipment needed to treat health conditions);
• Preventive medical care and health maintenance services, including in-home health services and
emergency medical services;
• Provision of appropriate medication;
• Providing follow-up services; and
• Preventive and non-cosmetic dental care”
Program funds should not be used to pay the costs of medication, medical equipment, or glasses
when a client is eligible to have these costs paid for by Medicare, Medicaid, or another government
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program. Please keep in mind the costs must also be reasonable and appropriate (as required by 2 CFR
200). In general, under the CoC Program, all supportive services paid for with grant funds must be
necessary to assist program participants with obtaining and maintaining housing.
The purchase of Narcan is also be an allowable cost under “Outpatient Health Services” as long as the
Narcan is purchased and made available in accordance with the allowable cost criteria in 2 CFR 200.403.
It should be prescribed and provided by a licensed medical professional. Please also review Fact Sheet
on Naloxone for CoC, ESG, YHDP and HOPWA Grantees.
Outreach Services
It is unlikely that this project will engage in outreach services as defined in the CoC Program Interim
Rule, given where it sits within our system. However, for reference, here is what is allowable under this
line item:
“The costs of activities to engage persons for the purpose of providing immediate support and
intervention, as well as identifying potential program participants, are eligible.
• Eligible costs include the outreach worker‘s transportation costs and a cell phone to be used by
the individual performing the outreach.
• Component activities and services consist of: initial assessment; crisis counseling; addressing
urgent physical needs, such as providing meals, blankets, clothes, or toiletries; actively
connecting and providing people with information and referrals to homeless and mainstream
programs; and publicizing the availability of the housing and/or services provided within the
geographic area covered by the Continuum of Care.”
Substance Abuse Treatment Services
The CoC Interim Rule allows for: “The costs of program participant intake and assessment, outpatient
treatment, group and individual counseling, and drug testing are eligible. Inpatient detoxification and
other inpatient drug or alcohol treatment are ineligible.”
Transportation
Under the CoC Interim Rule, eligible costs are:
• The costs of program participant‘s travel on public transportation or in a vehicle provided by the
recipient or subrecipient to and from medical care, employment, child care, or other services
eligible under this section.
• Mileage allowance for service workers to visit program participants and to carry out housing
quality inspections;
• The cost of purchasing or leasing a vehicle in which staff transports program participants and/or
staff serving program participants;
• The cost of gas, insurance, taxes, and maintenance for the vehicle;
• The costs of recipient or subrecipient staff to accompany or assist program participants to utilize
public transportation; and
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• If public transportation options are not sufficient within the area, the recipient may make a one-
time payment on behalf of a program participant needing car repairs or maintenance required
to operate a personal vehicle, subject to the following:
o Payments for car repairs or maintenance on behalf of the program participant may not
exceed 10 percent of the Blue Book value of the vehicle (Blue Book refers to the
guidebook that compiles and quotes prices for new and used automobiles and other
vehicles of all makes, models, and types);
o Payments for car repairs or maintenance must be paid by the recipient or subrecipient
directly to the third party that repairs or maintains the car; and
o The recipients or subrecipients may require program participants to share in the cost of
car repairs or maintenance as a condition of receiving assistance with car repairs or
maintenance.
Additional YHDP Eligible Cost: Gas & Mileage for Youth’s Vehicle
YHDP grant funds may be used for the following if they are necessary to assist program participants to
obtain and maintain housing:
• Gas and mileage costs for a program participant’s personal vehicle for trips to and from
medical care, employment, childcare, or other services eligible under this section.
You must follow your written policies and procedures and maintain records establishing how it was
determined that paying this cost was necessary for the participant to obtain and retain housing.
Purchasing a vehicle for the program:
If you’re going to purchase a vehicle for YHDP program use that’s not 100% dedicated to that program,
you need to prorate that purchase in some reasonable way (e.g., by # of participants enrolled in each
program). You’ll also need to have backup documentation that proves it was used for eligible activities
and clients enrolled in the program (e.g., mileage log with a description of the activity, and a link to the
client ID or name for whom transportation was provided).
Official guidance from HUD’s Ask a Question (AAQ) desk:
“As you know, eligible transportation costs are identified under Section 578.53 of the CoC
program interim rule. Eligible transportation costs in this case include the following:
• The cost of purchasing or leasing a vehicle in which staff transports program participants
and/or staff serving program participants; and
• The cost of gas, insurance, taxes, and maintenance for the vehicle.
CoC funds must be spent for eligible costs and must be reasonable and appropriate according to
the Omni Circular (2 CFR 200). Note that the mileage reimbursement specified in section
578.53(e)(15)(ii) of the CoC Program interim rule is only permissible if staff is not using a vehicle
owned by a recipient or subrecipient.
The CoC program interim rule does not prohibit a recipient or subrecipient from sharing the
costs of the van with a non-CoC funded organization, such as the mental health center, so long
as the costs are prorated.
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HUD does not prescribe the way in which the costs of the van should be prorated. Prior to
purchasing the van, the recipient should work with the mental health agency to determine to
what extent each organization anticipates using the van. Since eligible and ineligible activities
are carried out using the same equipment (in this case, the van) or supplies, the costs that are
actually charged to the CoC Program grant must be prorated to capture costs that were
incurred. For example, recipients could prorate costs based on the amount of time that the van
will be used by staff for eligible versus ineligible activities or based on a percentage of the
mileage incurred conducting eligible and ineligible activities. Good documentation is especially
important for activities paid for with different funding sources”
Be sure to follow your agency’s procurement policy for large purchases like vehicles.
Providing participants with ride-shares (Uber, Lyft, etc.) & public transportation
You can pay for ride-shares for clients to get to eligible services (work, school, medical appointments,
etc.). You need to have a consistent way to document that public transportation isn’t a good option –
e.g., that it would take much longer, that it isn’t reasonably available at the time when it’s needed (e.g.,
for third-shift workers), that the area the young person would have to walk through or wait in line to
catch transport is unsafe, or COVID-19 concerns.
Official guidance from HUD’s AAQ:
• A taxi, Uber, or Lyft would be an eligible cost under transportation in the supportive service
section of the CoC Program interim rule, so long as the costs are reasonable and appropriate,
and other public transportation options are not available or reasonable for a program
participant.
• When public transportation, recipient/subrecipient transport, taxis, Ubers, and Lyfts are used by
a program participant for eligible activities under 578.53(e)(15), and the recipient or
subrecipient is able to document that it was used to pay for eligible costs, a recipient or
subrecipient may draw down funds and be reimbursed for these costs.
• If the recipient or subrecipient is not able to determine and document that the program
participant used these modes of transportation for eligible activities, they may not be
reimbursed with CoC grant funds for their costs.
Eligible transportation costs include both the costs of a program participant’s travel on public
transportation (such as a fare pass) or in a vehicle provided by the recipient or subrecipient to and from
medical care, employment, child care, or other services eligible under the CoC Program. Therefore, bus
tokens or other single fare passes on public transportation are eligible to be paid for with CoC Program
funds and provided to program participants so long as the recipient or subrecipient is able to document
that the program participant is going to a service eligible under section 578.53(e)(15) of the CoC
Program interim rule. Generally, a case manager providing case notes and a receipt that the participant
used the transportation to access an eligible CoC Program supportive services would be adequate
documentation for these costs. Please consult with your local Field Office to determine forms of
acceptable documentation.
In general, the cost of monthly bus passes will not be eligible since the only time fare passes are eligible
transportation costs is when they will be used to transport a program participant to and from services
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eligible under the CoC Program. CoC Program funds cannot be used to transport clients to places not
eligible under the CoC Program.
Car repairs for clients’ personal vehicles
The CoC Interim Rule, Section 578.53 (Supportive Services), subsection (15) (Transportation) names
eligible car repair payments for clients:
“(vi) If public transportation options are not sufficient within the area, the recipient may make a one-
time payment on behalf of a program participant needing car repairs or maintenance required to
operate a personal vehicle, subject to the following:
(A) Payments for car repairs or maintenance on behalf of the program participant may not
exceed 10 percent of the Blue Book value of the vehicle (Blue Book refers to the guidebook
that compiles and quotes prices for new and used automobiles and other vehicles of all
makes, models, and types);
(B) Payments for car repairs or maintenance must be paid by the recipient or subrecipient
directly to the third party that repairs or maintains the car; and
(C) The recipients or subrecipients may require program participants to share in the cost of car
repairs or maintenance as a condition of receiving assistance with car repairs or
maintenance.”
Utility Deposits
The CoC Interim Rule allows the following under the utility deposits line item: “This form of assistance
consists of paying for utility deposits. Utility deposits must be a one-time fee, paid to utility companies.”
Direct Provision of Services
From the CoC Interim Rule: “If the service described in paragraphs (e)(1) through (e)(16) of this section is
being directly delivered by the recipient or subrecipient, eligible costs for those services also include:
• The costs of labor or supplies, and materials incurred by the recipient or subrecipient in directly
providing supportive services to program participants; and
• The salary and benefit packages of the recipient and subrecipient staff who directly deliver the
services.”
Additional Eligible Costs via YHDP Flexibilities
YHDP grant funds may be used for the following if they are necessary to assist program participants to
obtain and maintain housing. Recipients and subrecipients must maintain records establishing how it
was determined paying the costs was necessary for the program participant to obtain and retain
housing and must also conduct an annual assessment of the needs of the program participants and
adjust costs accordingly.
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Cleaning Supplies
The program may pay the costs of providing household cleaning supplies to clients.
Housing Start-up Expenses
The program may pay housing start-up expenses for program participants, including furniture, pots and
pans, linens, toiletries, and other household goods, not to exceed $300 in value per program participant.
Cell Phones
The program may pay the one-time cost of purchasing a cellular phone and service for program
participant use, provided that access to a cellular phone is necessary to obtain or maintain housing and
the costs of the phone and services are reasonable per 2 CFR 200.404.
Internet
The program may pay the cost of internet in a program participant’s unit and the costs of the service is
reasonable per 2 CFR 200.404.
To utilize these additional YHDP flexibilities, the program must follow the written policies and
procedures and maintain records establishing how it was determined that paying this cost was
necessary for the participant to obtain and retain housing. See Appendix A for the polices, procedures,
and forms for utilizing these flexibilities.
Ineligible Supportive Services Costs
Any cost that is not described as an eligible cost under this section is not an eligible cost of providing
supportive services using Continuum of Care program funds. If you are unsure whether a cost would be
eligible, reach out to the Alameda County Youth Program Services Coordinator.
Staff training and the costs of obtaining professional licenses or certifications needed to provide
supportive services are not eligible costs.
Rental Assistance
Grant funds may be used for rental assistance for participants. Rental assistance cannot be provided to a
program participant who is already receiving rental assistance, or living in a housing unit receiving rental
assistance or operating assistance through other federal, state, or local sources.
Monthly Rent
The program may pay monthly rental payments in accordance with the program design of youth rental
contributions as specified in the program manual. Rented units must also have a lease in the
participant’s name and comply with all HUD requirements (rent reasonableness, habitability, etc.) as
specified in the program manual. Rent paid may be above Fair Market Rent (FMR) as long as the unit is
still found to be Rent Reasonable. For more information see the Rental Assistance section of the
program manual.
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Vacancies. If a unit assisted under this section is vacated before the expiration of the lease, the
assistance for the unit may continue for a maximum of 30 days from the end of the month in which the
unit was vacated, unless occupied by another eligible person. No additional assistance will be paid until
the unit is occupied by another eligible person. Brief periods of stays in institutions, not to exceed 90
days for each occurrence, are not considered vacancies.
Personnel
The costs of administering rental assistance are considered service delivery costs and are therefore
eligible under rental assistance. Costs can include:
o Processing rental payments to landlords
o Verifying participant income and family composition
o Providing housing information and navigation
o Performing rent reasonableness determinations and housing search
o Inspecting units for compliance with habitability or housing quality standards
o Receiving new participants into the program
Security deposits
Under the CoC Interim Rule, rental assistance grant funds may be used for security deposits in an
amount not to exceed two months of rent. An advance payment of the last month's rent may be
provided to the landlord, in addition to the security deposit and payment of first month's rent.
If anyone under 25 is moving into a housing authority-funded voucher, note that public housing
authorities (PHAs) do not have the money to pay for security deposits. YHDP-funded rental assistance
under RRH can pay for those security deposits.
Utility Allowances
Utilities that are not included in the program participant’s rent may be paid using rental assistance
funds, based on the Public Housing Authority’s utility costs schedule for the unit size and location.
Additional YHDP Eligible Cost: Property Damages
The program may pay the costs to pay for any damage to housing due to the action of a program
participant, which may be paid while the youth continues to reside in the unit. The total costs paid for
damage per program participant may not exceed the cost of two months’ rent.
Additional YHDP Eligible Cost: Rental Arrears
The program may pay rental arrears consisting of a one-time payment for up to 6 months of rent in
arrears, including any late fees on those arrears.
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Additional YHDP Eligible Cost: Utility Arrears
The program may pay utility arrears of up to 6 months per service.
To utilize these additional YHDP flexibilities, the program must follow the written policies and
procedures and maintain records establishing how it was determined that paying this cost was
necessary for the participant to obtain and retain housing. See Appendix A for the polices, procedures,
and forms for utilizing these flexibilities.
Administrative Costs
The program may use up to 10% of the grant award for the payment of project administrative costs
related to the planning and execution of supportive services provided by the project. Eligible
administrative costs include:
• General management, oversight, and coordination. Costs of overall program management,
coordination, monitoring, and evaluation. These costs include, but are not limited to, necessary
expenditures for the following:
o Salaries, wages, and related costs of staff engaged in program administration. In
charging costs to this category, the recipient may include the entire salary, wages, and
related costs allocable to the program of each person whose primary responsibilities
with regard to the program involve program administration assignments, or the pro rata
share of the salary, wages, and related costs of each person whose job includes any
program administration assignments. The recipient may use only one of these methods
for each fiscal year grant. Program administration assignments include the following:
Preparing program budgets and schedules, and amendments to those budgets
and schedules;
Developing systems for assuring compliance with program requirements;
Developing agreements with subrecipients and contractors to carry out program
activities;
Monitoring program activities for progress and compliance with program
requirements;
Preparing reports and other documents directly related to the program for
submission to HUD;
Coordinating the resolution of audit and monitoring findings;
Evaluating program results against stated objectives; and
Managing or supervising persons whose primary responsibilities with regard to
the program include such assignments as those described in this section.
o Administrative services performed under third-party contracts or agreements, including
general legal services, accounting services, and audit services; and
o Other costs for goods and services required for administration of the program, including
rental or purchase of equipment, insurance, utilities, office supplies, and rental and
maintenance (but not purchase) of office space.
• Training on Continuum of Care requirements. Costs of providing training on Continuum of Care
requirements and attending HUD-sponsored Continuum of Care trainings.
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Additional YHDP Eligible Administrative Costs
Allowable YHDP flexibilities in the project administrative costs that do not require special
documentation to use them:
• Costs associated with involving youth with lived experience in project implementation,
execution, and improvement.
• Attending conferences and trainings that are not HUD-sponsored or HUD-approved, provided
that the subject matter is relevant to youth homelessness.
Operating Costs (TH Only)
Grant funds may be used to pay the costs of the day-to-day operation of transitional housing in a single
structure or individual housing units. Eligible costs include:
• The maintenance and repair of housing;
• Property taxes and insurance;
• Scheduled payments to a reserve for replacement of major systems of the housing (provided
that the payments must be based on the useful life of the system and expected replacement
cost);
• Building security for a structure where more than 50 percent of the units or area is paid for with
grant funds;
• Electricity, gas, and water;
• Furniture; and
• Equipment.
Leasing Costs (TH Only)
Grant funds may be used to lease a structure or a portion of a structure that will be used for Transitional
Housing or to lease individual housing units for Transitional Housing. Leasing funds may not be used to
lease units or structures owned by the organization.
Rent paid must be reasonable in relation to rents being charged in the area for comparable space or
units. If electricity, gas, and water are included in the rent, these utilities may be paid from leasing funds
otherwise, these utility costs are an operating cost. Grants funds may also be used to pay security
deposits, in an amount not to exceed two months of rent, and first and last month’s rent (up to one
month each, allowed as an advanced payment), as well as related costs to carrying out leasing activities,
such as conducting Housing Quality Standards inspections, paying landlords, etc.