Program Integrity is a vital consideration for grantees of the Emergency Rental Assistance (ERA) programs that ensures efficiency and equity in distribution. Treasury requires grantees to implement policies and procedures that include robust compliance and risk-management controls, while also making certain that eligible households can receive timely assistance that supports housing stability.
ERA programs across the country operate in a wide variety of environments, with circumstances varying across population density, geography, the interconnectivity of the community, and many other localized considerations. Accordingly, grantees have identified a variety of program integrity measures that meet the particular needs for their community.
FAQs 1 and 31 both address program integrity. FAQ 1 states that grantees must:
"specify in their policies and procedures under what circumstances they will accept written attestations from the applicant without further documentation to determine any aspect of eligibility or the amount of assistance, and in such cases, grantees must have in place reasonable validation or fraud-prevention procedures to prevent abuse."
FAQ 31 states:
while “grantees are not required to obtain documentation evidencing the use of ERA program funds by tenants and landlords,” they are “expected to apply reasonable fraud-prevention procedures and to investigate and address potential instances of fraud or the misuse of funds that they became aware of.”
These policies and procedures support the integrity of the ERA programs, ensuring that funds are expediently directed toward qualifying rental assistance, utilities and home energy costs, other expenses related to housing, housing stability services and other affordable housing and eviction prevention purposes. Robust and thoughtful controls may also limit grantees’ risks of audit findings, noncompliance with the ERA Award Terms, fraud, waste, and abuse.
Advantages to using this practice
Reduces risk of inequitable distribution
- Avoids duplication of assistance
- Optimizes effective operations
- Encourages robust landlord engagement and community partnerships
- Supports program reputation
- Limits program risks
Strategies to Consider
Grantees’ program integrity policies and procedures are likely to vary in accordance with local needs and experiences, as well as with the structure of grantees’ ERA programs. Nonetheless, grantees may wish to consider some of the following in designing controls.
- High-tech and/or high-touch?: Programs relying on technology-focused intake may use more automated risk management—a “high-tech” approach—while those who rely on more interpersonal intake processes may rely on more “high-touch” strategies. Larger grantees processing high volumes of applications may find it helpful to use technological solutions that flag potentially problematic applications or patterns using risk scores, data analytics, or other tools. Grantees with lower application volume may benefit from a hands-on approach to application review, leveraging firsthand staff knowledge of the community and application trends to identify possible issues.
- Staffing up: Staff with past experience in fraud detection, disaster recovery, and quality control for other benefit programs can help strengthen programs’ integrity policies and procedures. Applying lessons, practices, and tools from comparable contexts—especially contexts that require timely processing—can strengthen risk management.
- Leveraging vendors: Partnering with vendors offering fraud or risk management tools and platforms may also promote program integrity, particularly for grantees pursuing a “high-tech” strategy. Vendors can provide technological solutions and platforms, as well as useful data like fraud lists or records.
- “Screening in” versus “screening out”: “Screen-in” approaches seek out a pathway to responsibly approve an applicant based on relevant traits or available documentation, instead of focusing on reasons to exclude or deny applicants. “Screen-in” approaches seek out a pathway to responsibly approve an applicant based on relevant information or available documentation, instead of focusing on reasons to exclude or deny applicants. While a screening-in practices must be paired with robust controls, such an approach can help ensure that program integrity systems don’t erect barriers for eligible applicants.
- Application intake channels: Programs may consider differing eligibility documentation requirements or risk tiering strategies depending on the application intake channel. For instance, applicants that come to an ERA program through court-based eviction diversion programs or through a trusted social services program may have differing application processing and risk mitigation procedures compared to an applicant that comes to the program through an online application. Differing treatment of applications based on intake channel, as well as the rationale for such treatment, should be documented in the program’s policies and procedures.
- Landlord and utility company engagement: Landlords and utility companies can be key actors in promoting housing stability. Strong cooperation can often provide supporting documentation about applicants and further support the integrity of the application process. Also, building knowledge of the landlord and utility landscape in the community can help an ERA program develop informed strategies.
- Communications with tenants, landlords, and utilities: Building strong and transparent communication channels with tenants, landlords, and utility companies eases uncertainty, can support stronger cooperation with ERA programs, and allow space for more successful risk mitigation strategies. These communications may take the form of regular communications to stakeholders about the status of an application and/or access to information about the applicant’s status.
- Coordination with adjacent or overlapping jurisdictions: Creating a communication loop and/or establishing data sharing agreements with adjacent or overlapping jurisdictions may help to increase program integrity practices. This coordination between ERA programs can help to significantly reduce the likelihood of duplication of ERA benefits.
Steps to take
- Choose strategies that make sense for the needs of your community and program, and integrate a quality control strategy into your program policies and procedures.
- Partner with networks and organizations that can help in the effort to maintain program integrity.
- Build strong landlord, utility company, eviction court, and tenant engagement strategies, which can help enhance cooperation, documentation intake, and support strategic risk mitigation efforts.
- Consistently reevaluate policies and procedures and adjust as necessary.
Examples of maintaining program integrity
High tech vs. High touch
- One major city uses a high-tech risk management approach, integrating a variety of cross-agency systems into one platform to facilitate collaboration and case management across the city’s social services and identify potential applicant flags on the backend. The jurisdiction also uses a vendor to conduct identity and property verification to flag potential risks using complementary data resources.
- One county on the East Coast uses a high-touch program integrity approach focusing on eviction court cases. Program staff attend court in person to intervene in eviction cases and assist applicants in identifying and uploading necessary documents for their rental assistance case to be processed.
- One Tribally Designated Housing Entity (TDHE) has partnered with the county’s social services and behavioral health departments, and reentry specialists to focus on tenants most in need of housing stability. Meetings with reentry specialists has assisted those that are reintegrating after being unhoused with stable housing to rebuild their lives. Additionally ERA Housing Occupancy Specialists work closely through phone calls and in-person meetings with local hotels, landlords, and the local utility data system to determine tenants in need in individual villages.
Communications with tenants, landlords, and utilities:
- One state in the Midwest uses a waterfall of options to qualify an application for ERA assistance, beginning with Supplemental Nutrition Assistance Program (SNAP), Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), and/or Temporary Assistance for Needy Families (TANF) programs. They utilize an online unemployment system to verify unemployment in real time. Additionally, they engage landlords in the process by requesting property documentation once the applicant is determined to be eligible.
- One major city uses an online scoring system with their applications to assess for risk. They speak to every applicant once verifying eligibility, and also pursue robust landlord engagement strategies resulting in a consistent and transparent feedback loop.
- One county in the south partners with their local compliance department to assist with quality control. Additionally, case managers utilize a checklist during the application process to ensure consistency with checks and balances.
- Review Program Integrity Practices and Data: Consider conducting regular reviews of program integrity policies and practices—how can they be strengthened, added to, or streamlined? Tracking and assessing key program integrity metrics will facilitate these analyses and highlight areas for growth.
- Learn from Other Grantees: Grantees may find it helpful to consult with other grantees, particularly grantees in their area or grantees sharing important features, like strategies to manage applicant volume or budget. Sharing experiences can help grantees identify best practices or areas for growth.
- Consider your long-term strategy for program integrity infrastructure: Identify other programs that can be beneficiaries of the knowledge gained from the implementation of the ERA program. Have you implemented application process and distribution of innovations that might help other programs implement successful program integrity measures?
 Treasury recognizes that programs vary according to local circumstances; these examples are intended to help programs identify opportunities to enhance the effectiveness of their own programs but may not be universally applicable to all grantees. The program information provided herein is intended solely to illuminate “promising practices” that grantees might consider when developing their jurisdiction’s program policies and infrastructure. All such policy development must proceed in accordance with the applicable ERA Award Terms, ERA authorizing statute, and other applicable laws, regulations, and ERA guidance. Nothing herein should be construed as (i) altering these requirements or (ii) confirming that any specific grantee’s program policies or administrative practices have been fully reviewed and found compliant.