#	Recommendation	Management Response	Est Comp Date	Status Updates (In Progress; Pending; Complete; Requires Resolution)
1	That the City develop formal procedures for all RGI administration oversight functions including procedures to be performed during Housing Provider (HP) site visits such as testing the RGI subsidy calculations.	Management agrees with this recommendation. Although informal procedures have been in place for a number of years, staff are in the process of planning and developing a detailed procedure manual. The procedure manual will capture and formalize in writing, the procedures for all RGI administration oversight functions including procedures to be performed during Housing Provider site visits. This process will be completed in Q1 2011.	Q1 2011	December 2009: In Progress. In the process of hiring a consultant firm to complete this task within the timelines agreed to.
3	That the City review and analyze the major cause(s) of the delays in the AIR reconciliation process and establish a plan of action for eliminating these delays.	Management agrees with this recommendation. A review has been completed and action is now underway to create a second Financial Co-ordinator position by eliminating an existing position. The job description for the Financial Co-ordinator has been updated to appropriately reflect the responsibilities regarding RGI administration, reconciliation and duties related to the SHRA. Staffing will be completed in Q2 2010.	Q2 2010	December 2009: In Progress. In the process of recruiting a second financial officer.
4	That the City implement a process for periodic validation of the HP self-assessment of compliance.	Management agrees with this recommendation. It is current practice for the Program Administrator to review and confirm accuracy of the HP self-assessment during a site visit with a housing provider. This review also includes a governance practices review, a property management review, a tenant file review and a review of RGI calculations. This process, which includes a tracking system, will be formalized through the development of the policy and procedure manual referenced in management’s response to Recommendation 1. The procedure manual will be completed in Q1 2011.	Q1 2011	December 2009: In Progress. Practice is in place. The policy and procedure manual as referenced in Recommendation1 will be completed by Q1 2011.
5 5	That the City ensure follow up of the Site Visit Report recommendations is completed on a timely basis and that a record of any form of communication with the HPs be maintained in the HP file for future reference and follow up.	Management agrees with this recommendation. Staff will incorporate standardized procedures in the policy and procedure manual for RGI administration (refer to management’s response to Recommendation 1) to ensure timely reporting to and from the Housing Provider regarding Site Visit Reports. A tracking system has been implemented to ensure reporting timelines are met with appropriate notification and follow-up according to a prescribed schedule. The procedure manual will be completed in Q1 2011.	Q1 2011	December 2009: In Progress. Practice in place. The policy and procedure manual as referenced in Recommendation 1 will be completed by Q1 2011.
6	That the City develop a risk profile to identify the sample of HPs that should be given priority for site visits.	Management agrees with this recommendation. A risk assessment tool will be incorporated into the procedure manual referenced in management’s response to Recommendation 1. The risk assessment tool will take into consideration information received through the Annual Information Review (AIR) process and site visits. It will include an evaluation on how the Housing Provider meets the housing standards outlined in the Social Housing Standards document which was developed by housing providers and the City in 2008. The procedure manual will be completed in Q1 2011.	Q1 2011	December 2009: In Progress. Will be developed as part of the policy and procedures manual as referenced in Recommendation 1, which will be completed in Q1 2011.
7	That the City perform periodic site visits to the Registry to test the Registry’s compliance with the SHRA and with the Registry’s Agreement with the City.	Management agrees with this recommendation. A formal site visit and operational review will be conducted in the winter of 2010. Site visits are scheduled to occur every three years or more often if the Service Manager deems it necessary. The formal site visit and operational review will be completed in Q2 2010.	Q2 2010	December 2009: In Progress. Site visit review is scheduled for April 2010.
8	That Council petition the Ministry of Community and Social Services and MMAH to develop legislation that allows greater sharing of social assistance information across municipal programs.	Management agrees with this recommendation. The item will be brought forward to Council in Q2 2010.	Q2 2010	December 2009: In Progress. A report to CPS committee will be developed for Q2 2010. City staff currently participates on a MMAH information sharing workgroup. The City has agreed to participate in a MMAH pilot initiative to develop and implement increased information sharing between MCSS, MMAH and the municipality. The pilot is at the initial implementation stage.
9 9	That City ensure the job descriptions of the positions involved in the RGI administration process are current and specifically include responsibilities related to RGI administration and other duties related to the SHRA.	Management agrees with this recommendation. A majority of the job descriptions involved in the RGI administration process have been updated (Program Administrator, Technical Assessor, Financial Coordinator, Rent Supplement Clerk, Housing Officer). The remaining job descriptions will be updated by the end of Q3 2010.	Q3 2010	December 2009: In Progress. Remaining positions will be updated in Q2 & Q3 2010.
10	That the City pursue an expansion of the role of the Registry to include an initial needs assessment.	Management agrees with this recommendation. Completing an initial household income verification at the time of application would assist in determining if households are eligible for the “below market rent” (BMR) income threshold. If eligible, they can be placed on the BMR waiting list in addition to the social housing Centralized Waiting List which, will improve options for housing. This, however, will not replace the requirement that household income verification be completed by the housing provider at time of offer. The rent subsidy is based on a unit specific calculation of household income in relation to the market rent for the specific unit offered and income. Those contributing to the income in a household may, and often do, change between the time of the initial application and the time of offer which may be several years later. The income verification process and procedure will be completed by Q2 2010 and will be included in the procedure manual referenced in management’s response to Recommendation 1. In addition, a directive will be issued to the Registry regarding this issue.	Q2 2010	December 2009: In Progress. Income disclosure is currently on the Registry application form. Registry staff confirmed that they are verbally requesting income verification documentation at the time of application. The Registry will make this documentation a mandatory requirement starting in Q1 2010. A formal written Service Manager Directive will be issued by January 31, 2010 formalizing this procedure. Upon review of an application, The Registry currently issues a letter introducing the BMR program to all households that have household income that would qualify for the BMR program. This practice will be continued and formalized. In addition, an Eligibility Review Checklist Form is under development, for use by Registry staff when completing an Application Review. There will be an income verification category on the Checklist Form, confirming income verification documentation has been received, and qualification for the BMR program has been reviewed. The Checklist Form will be in use by February 2010.
11 11	That the City seek Council direction on the desire to petition the Municipal Affairs and Housing to allow the City to require confirmation that anyone claiming abuse has commenced legal proceedings.	Management disagrees with this recommendation. Individuals fleeing abuse may lack financial or other resources required to commence legal proceedings, or they may not be ready or willing to do so. Although confirmation that legal proceedings have commenced would be helpful in documenting an individual's situation, a letter signed by a doctor, social worker, or other acceptable representative, as is the current requirement, is a more appropriate indicator of need.		December 2009: Requires Resolution.
12	That the Registry reduce the types of documents that establish that a household meets the residency eligibility requirements by only allowing for example the following types of proof: · Canadian passports · Birth Certificates issued by a Canadian Province or Territory · Landed Immigrant Status papers · Residency cards issued by the Canadian Government	Management disagrees with this recommendation. Management agrees that the list of acceptable documentation should be limited but also believes that the Service Manager needs to retain flexibility so as not to deny an eligible household who may be without the aforementioned documents at the time of application. Examples of such circumstances could include: a household fleeing abuse or a family becoming homeless because of a fire in their residence – leaving their documentation behind. It takes time and money to re-establish residency and some temporary discretion should be allowed in situations such as these. In addition, current legislation allows and promotes flexibility in residency eligibility documentation in cases of provincial housing priority (Special Provincial Priority) for households experiencing domestic violence. Management believes that it is reasonable to substitute alternative documents such as Ontario Works (OW) or Ontario Disability Support Program (ODSP) pay stubs as proof of residency status. OW and ODSP have rigorous standards which must be satisfied confirming residency status before funds are issued.		December 2009: Requires Resolution.
13 13	That the Registry document that arrears checking has been performed in all cases.	Management agrees with this recommendation. A directive has been issued to the Registry to ensure this is procedure is followed. Compliance with this requirement will be monitored through site visits and normal exchange of data. Site visits are scheduled to occur every three years or more often if the Service Manager deems it necessary.	Q1 2010	December 2009: In Progress. A verbal directive was given to the Registry in September 2009. A formal written Service Manager Directive will be issued by January 31, 2010 formalizing the procedure. It has been verified that they are now following this directive, and they place a note on file confirming arrears verification. In addition an Eligibility Review Checklist Form is under development, for use by Registry staff when completing an Application Review. There will be an arrear verification category on the Checklist Form confirming both the provincial and local area database has been checked for arrears. The Checklist Form will be in use by February 2010.
14	That the City work with HPs to develop standardized procedures for Housing Placement, Annual Review Process, Changes to Household Occupancy and Overhoused Households, including: · Placement decision processes to ensure only Provincial- and City-mandated criteria are used and other criteria (i.e. ethnic, religious etc.) are not, · Calculating the RGI subsidy under various circumstances, · Utilizing T1 Assessments for all household members, · Requiring a second person to check the RGI calculations for households reporting self-employment income, · Calculating interest income, and · Proof of residency to be obtained for cases where an occupant is added to a household.	Management agrees with this recommendation and will work with Housing Providers to meet the objectives as outlined in the recommendation. However, requiring a second person to check RGI households for self-reporting income may not be feasible for the smaller providers who rely on only one half-time coordinator to manage the administration of the building. In these cases, there is no other employee to check RGI calculations. By developing clear and consistent guidelines for the calculation of RGI including those households with self-employment income, the risk of error will be minimized. Standardized procedures (refer to management’s response to Recommendation 1) will be completed in Q1 2011.	Q1 2011	December 2009: In Progress. The policy and procedure manual as referenced in Recommendation 1 will address this issue.
15 15	That Housing Providers ensure all households with overhoused units are placed on the Registry’s CWL within one year of becoming overhoused and that these lists are updated on a quarterly basis.	Management agrees with this recommendation. This requirement will be incorporated into the standardized procedures being developed in response to Recommendation 1. A directive has been sent to all Housing Providers regarding this requirement, and the Service Manager will check for compliance as part of site visits by the end of Q1 2010.	Q1 2011	December 2009: In Progress. Over-housed verification has been highlighted within the site visit compliance checklist. A Service Manager e-bulletin was issued to all housing providers on October 10, 2008. This will be formally included in the Policy and Procedure manual as referenced in Recommendation 1, which will be completed in Q1 2011.
16	That the City establish a clear timeframe for final implementation of SHAMIS.	Management agrees with this recommendation. Staff are currently testing a revision of the SHAMIS software that will eliminate the need for manual calculations. Commencing Q1 2010, staff will use only the SHAMIS software to complete calculations.	Q1 2010	December 2009: In Progress. Staff are working with the Rent Supplement Office to reinforce procedures to eliminate duplicate calculations.
17	That the RSO rely on the residency verification performed by the Registry and discuss the file transfer process with the Registry to ensure that a mutually agreeable timeframe can be established for the transfer of the files.	Management agrees with this recommendation. However, management wishes to clarify that if a household has changed composition since the last update to the application file at the Registry, the RSO will still need to verify that anyone added meets the residency verification. The RSO and the Registry will develop a protocol to ensure the timely transfer of files by the end of Q1 2010.	Q1 2010	December 2009: In Progress. Staff are working with the RSO and Registry to streamline the file transfer process. The Registry has agreed to implement a scheduled weekly file transfer to the Rent Supplement office starting in January 2010.