CARES Act Emergency Rental Assistance Notice of Funding Availability

Parameters of the program design are as follows:

• Up to six months of assistance can be provided, and can include back payments of rent and past due utilities, as well as current rental payments or current utility bills. 
• Eligible applicants to the proposed program must demonstrate that they have not been able to pay or have not received rental payments for any period of time starting March 1, 2020, and will need to certify that the reason is related to COVID-19. 
• Additional documentation of need may be required, and staff will conduct further review of the CARES Act, Coronavirus Relief Act (CRF) guidance prior to entering into funding agreements with contractor(s). 

Background

The goal of the CARES Act Relief Fund is to promote recovery by providing funding to support the needs of those impacted by the COVID-19 public health emergency. The Sonoma County Board of Supervisors has prioritized short-term emergency rental assistance for low-income tenants and low-income landlords. 

The CARES Act provides that payments from the Fund may only be used to cover costs that: 

• Are necessary expenditures incurred due to the public health emergency with respect to COVID–19;
• Were previously unbudgeted costs of necessary expenditures incurred due to the COVID-19 public health emergency; and
• Were incurred during the period that begins on March 1, 2020, and ends on December 30, 2020. 

Funds MUST be expended by December 30, 2020.

Eligible Applicants

Both public and private non-profit organizations are eligible to apply for this funding. Private non-profit organizations must be in good standing with the Secretary of State and be listed as Active in the Federal System for Award Management (sam.gov).

Schedule

Technical Assistance

 Due to the timeline for the distribution of funds, a technical assistance session will not be offered. Any questions regarding this NOFA should be directed to Holly.Kelley@sonoma-county.org.

Scope of Services

In response to the COVID-19 crisis, the Sonoma County Community Development Commission (CDC), is seeking one or more contractors to administer an Emergency Rental Assistance Program (Program) to aid low-income renters and low-income landlords who are unable to pay their rent or are not receiving rental payments due to the COVID-19 public health emergency. The Program will provide short-term, emergency utility and rental assistance to up to 400 eligible low-income renter and landlord households using federal CARES Act Funding.

The CARES Act Emergency Rental Assistance program will provide up to a maximum of $6,000 to cover utility bills and rental assistance for no more than six months to qualifying households. Rental assistance may include past due utility bills and rent in arrears starting March 1, 2020.

In order to be eligible for assistance, households must be meet the following conditions:

1. Be low-income, as defined as 80% of Area Median Income (AMI); and
2. Be a tenant unable to pay their rent and/or utility bills OR a landlord not receiving rent as a result of the COVID-19 public health emergency.

Self-certification of the above conditions will be accepted.

The selected Contractor(s) will be expected to demonstrate that they can provide fast and direct financial assistance to individuals and families in the wake of the coronavirus pandemic and are ready to immediately commence the work at hand without extensive ramp-up time. Contractor(s) will conduct a robust outreach plan to those that are disproportionately impacted by the pandemic, screen applicants for eligibility in accordance with program and funding requirements, and administer short-term, emergency assistance on behalf of eligible families. The provision of additional wraparound support in the areas of income, employment, living conditions, access to food, transportation, and medical care, among others, is also encouraged but not required.

Contractors with significant experience in providing rental assistance, particularly those serving diverse communities and working with Community Development Block Grant (CDBG) or other state or federal housing funds, are encouraged to submit a proposal.

The CDC may select more than one contractor in order to ensure adequate capacity to meet program needs.

Award and Disbursement of Funds

The review committee consisting of County and Commission staff will make funding recommendations to the Board of Supervisors which will ultimately determine final award(s) and grant amount(s). Awards will depend upon the number of applicants, availability of funds, and demonstrated qualifications and experience. The Sonoma County Community Development Commission reserves the right to offer awards different from the specified amount requested.

Equity and Social Justice

The Community Development Commission supports fair, accessible, and relevant services for families and individuals that promote equity and social justice. Proposers should understand how the intersectionality of social categorizations such as gender, race, socio-economic status, immigration status, ethnicity, nationality, sexual orientation, family structural identities, religion, age, mental disability, physical disability, mental illness, and physical illness create overlapping and interdependent systems of discrimination and disadvantage; and have a commitment to naming biases, suspending judgment and redefining assumptions and cultural norms through a practice of cultural humility

Grant Recipient Reporting Requirements

• Fiscal
  1. Chosen Contractor(s) will be required to report both monthly obligation and monthly expenditure costs.
  2. Invoices must be submitted by December 30, 2020 for personnel, administrative and program delivery expenses incurred with grant funds. Recipient must make all necessary information available to confirm expenditures were eligible under this grant including adequate documentation of receipts and corresponding financial records. 
  3. Additional fiscal reporting requirements may be required and are to be determined.
• Program
  1. Programmatic reporting requirements will be determined between the CDC and chosen contractor(s)

CARES Act Relief Funds Record Retention Requirements

Recipients of Coronavirus Relief Fund payments shall maintain and make available to the Treasury Office of Inspector General (OIG) upon request all documents and financial records sufficient to establish compliance with subsection 601(d) of the Social Security Act, as amended, (42 U.S.C. 801(d)), which provides: 

(d) USE OF FUNDS.—A State, Tribal government, and unit of local government shall use the funds provided under a payment made under this section to cover only those costs of the State, Tribal government, or unit of local government that— 

1. Are necessary expenditures incurred due to the public health emergency with respect to COVID-19;
2. Were not accounted for in the budget most recently approved as of the date of enactment of this section for the State or government; and
3. Were incurred during the period that begins on March 1, 2020, and ends on December 30, 2020.

Records to support compliance with subsection 601(d) may include, but are not limited to, copies of the following:

1. General ledger and subsidiary ledgers used to account for (a) the receipt of Coronavirus Relief Fund payments and (b) the disbursements from such payments to meet eligible expenses related to the public health emergency due to COVID-19;
2. Budget records for 2019 and 2020;
3. Payroll, time records, human resource records to support costs incurred for payroll expenses related to addressing the public health emergency due to COVID-19;
4. Receipts of purchases made related to addressing the public health emergency due to COVID-19;
5. Contracts and subcontracts entered into using Coronavirus Relief Fund payments and all documents related to such contracts;
6. Grant agreements and grant subaward agreements entered into using Coronavirus Relief Fund payments and all documents related to such awards;
7. All documentation of reports, audits, and other monitoring of contractors, including subcontractors, and grant recipient and subrecipients;
8. All documentation supporting the performance outcomes of contracts, subcontracts, grant awards, and grant recipient subawards;
9. All internal and external email/electronic communications related to use of Coronavirus Relief Fund payments; and
10. All investigative files and inquiry reports involving Coronavirus Relief Fund payments. 

Records shall be maintained for a period of five (5) years after final payment is made using Coronavirus Relief Fund monies. These record retention requirements are applicable to all prime recipients and their grantees and subgrant recipients, contractors, and other levels of government that received transfers of Coronavirus Relief Fund payments from prime recipients.

Application Documents and Submittal Instructions

The following forms should be submitted electronically to Holly.Kelley@sonoma-county.org by the due date and time listed in Section III. Schedule.

• CARES Act Emergency Rental Assistance Program Application
• CARES Act Emergency Rental Assistance Program Budget
  1. The Program Budget should include anticipated costs for the period March 1, 2020 to December 30, 2020.
  2. Indirect costs should be limited to 10% unless Agency has an Indirect Cost Rate approved by a cognizant federal agency.

Who can apply for this NOFA?

Right now, the County is soliciting non-profit organizations that have the capacity to run a rental assistance program. This particular application is not for tenants. Once the funds are awarded at the end of this month, the selected nonprofits will begin running the rental assistance programs and have a way for landlords and tenants to apply. 

Is this program in any way residential or merely for businesses/non-profit?

This particular application is for non-profits. Ultimately, the non-profits selected through this application will run a rental assistance program for tenants and landlords who are in need of assistance due to COVID-19. 

When can tenants and landlords in need apply for funding? 

The awards to selected nonprofit agencies are scheduled to be made by the Board of Supervisors on September 22nd, 2020. Programs should be up and running very shortly after. 

How will I know which nonprofit to apply to for rental assistance? 

The preliminary staff recommendation for awards will be posted online after the review process is complete. The final awards will also be included as part of the September 22nd Sonoma County Board of Supervisors meeting. It will be up to the awarded agencies to provide instruction on how to apply for their rental assistance program. 

Is there a minimum amount that an agency can apply for?

There is no minimum or maximum request limit for agencies, as long as the entirety of the award can be spent by the December 30^th deadline.

Is landlord assistance available for lost rental income? If so, how is this to be documented / self certified?

Yes, low-income landlords will be eligible for assistance. It will ultimately be up to the agencies administering the programs to determine the level and type of documentation they would need to verify income. Some methods might be having landlord applicants include their own bank statements, utility bills for their rental properties, and/or some record of tenant payments that shows when payment stopped, how much rent income has been lost, and that the landlord doesn’t have sufficient income from another source to maintain their own living expenses. 

How will agencies prove eligibility for rental assistance? 

The application would require proof individuals live at the residence and can provide appropriate paperwork indicating loss of job or income loss due to COVID-19 (pay check stubs, bank statements, medical bills, etc...) Eligible applicants must demonstrate that they have not been able to pay or have not received rental payments for any period of time starting March 1, 2020 and will need to certify that the reason is related to COVID-19. Self-certification of these conditions will be accepted. 

Do mortgage payments qualify as certification that a landlord is low-income? 

As long as there is proof or self-certification of lost income due to COVID-19, mortgage payments can be included as a determinant of whether a landlord is in need of assistance.

Are their requirements regarding legal residency of beneficiaries?

County Counsel issued a legal opinion that for this program, administrators do not need to document status of legal residency to provide assistance.