CDBG Certifications

HOME Certifications

ESG Certifications

HOPWA Certifications

AP-05 Executive Summary - 24 CFR 91.200(c), 91.220(b)

Introduction
The City of Tulsa is pleased to submit its 2024-2025 Annual Action Plan. This is the fifth and final year of the 2020-20 Consolidated Plan. The Consolidated Plan is carried out through Annual Action Plans, which provide a concise summary of actions, activities, and the specific federal and non-federal resources that will be used each year to address the priority needs and specific goals identified in the Consolidated Plan.

Summarize the objectives and outcomes identified in the Plan 
The primary objective of the Annual Action Plan is to improve the quality of life of principally low and moderate income Tulsans, by creating suitable living environments, improving the availability of affordable housing, and enhancing economic opportunities. The Annual Action Plan process identified the same overarching needs within the community as identified in the Consolidated Plan. The following seven priority needs adopted are: 

1. Housing Acquisition, Construction, and Rehabilitation 
2. Essential Services
3. Homeless/Special Populations
4. Economic Development
5. Public Facilities and Infrastructure Improvements
6. Housing Subsidies/Assistance
7. Demolition of Substandard Buildings

The outcomes of addressing these needs will be measured by the increase in availability/accessibility, affordability and sustainability created by the programs, and services provided throughout the course of the Consolidated Plan. By concentrating funds on a small number of specific needs, it is hoped that the main objective will be achieved and a greater number of principally low and moderate income persons will benefit from the available funding.  

Evaluation of past performance
The City continues to improve its processes and delivery of services to address the housing, community development, and economic development objectives that were identified in the 2020 - 2024 Consolidated Plan. We are currently in the fourth year of the plan which will end on June 30, 2024. Complete and detailed year-end reports have been written, summarizing the result of activities that have taken place during each year of the previous Consolidated Plan period, 2015-2019. Copies of these reports can be found at https://www.cityoftulsa.org/government/departments/finance/grants/plans-and-reports/.

Utilizing Community Development Block Grant (CDBG), HOME Investment Partnerships Program (HOME), Emergency Solutions Grant (ESG), and Housing Opportunities for Persons with AIDS (HOPWA) funds, the City of Tulsa has promoted Decent Housing, Suitable Living Environments, and Economic Opportunities.  During the first three years of the City’s 2020-2024 Consolidated Plan, the City has expended approximately $33 million and has: 

• Assisted 33,876 people with public service activities
• Provided Short-Term Rent, Mortgage, and Utility Assistance (STRMU), Tenant-Based Rental Assistance (TBRA), and Permanent Housing Placement to 491 persons with AIDS
• Provided Rapid Re-Housing and Homeless Prevention activities to 868 households 
• Provided emergency shelter to 2,954 people
• Created/retained 207 jobs
• Assisted 83 new and existing businesses
• Rehabilitated 568 owner occupied homes
• Assisted 58 first time homebuyers
• Rehabilitated 5 public facilities
• Carried out clearance and demolition activities on 95 substandard structures

Summary of Citizen Participation Process and Consultation Process
The goals of the City's citizen participation process as it relates to the Consolidated Plan and Annual Action Plans are: 

• To increase the involvement of low-income persons, residents of public housing, minority populations, non-English speaking persons, and persons with special needs;
• To clarify roles and responsibilities to enable a variety of organizations to participate cooperatively in meeting the goals and objectives identified by the community; 
• To ensure that all citizens and organizations have an opportunity to participate in the evaluation of funded activities.

During the development of this Fifth Year Annual Action Plan, citizens were provided the following opportunities to participate in the process:   

• Needs Assessment public hearing – July 13, 2023
• The U.S. Department of Housing and Urban Development (HUD) Community Development Committee meeting to set priority needs and goals – July 13,2023
• HUD Community Development Committee (CDC) meetings for recommendation of awards (Appendix A) – February 1 and 6, 2024

Summary of public comments
During the needs assessment public hearing, five speakers presented information to the HUD Community Development Committee. The expressed needs were as follows: 

• Continued support for Economic Development (ED) of small businesses in Tulsa
• Deterring anti-poverty through the strategy of early education programs and facilities
• Shortage of affordable housing
• Down Payment Assistance Programs
• Support for the housing needs and services of those who are fleeing Domestic Violence

Written comments from two agencies were submitted. The first comment provided data on the challenges related to domestic violence and how those result in homelessness, especially for women and children. Outlining the mission of their agency to address the problem and how the availability of an emergency shelter and Legal Services are two of the most important factors in a community to reduce the incidence of domestic violence. The Second comment provided data on the large percentage of children under 5 years of age living in poverty, especially those of color and those in homes where English is not their primary language. They also shared the critical need for infant and toddler care. This need was supported by data from the U.S. Census Bureau, American Community Survey, 2021; Oklahoma Department of Human Services, Annual Report, 2022, comparing that of 18,411 children between the ages of 3 and 4, only 919 children are potentially awaiting pre-k services, compared to 18,239 infants and toddlers that are not served in any type of care. Meeting this need helps parents enter and stay in the workforce, especially for those under 5 years of age, and the need to invest in early childhood education and care programs and facilities.

The HUD Committee, during regular meetings on February 1^st and 6^th, 2024, made recommendations for funding.   

The public hearing on the draft 2024-2025 Annual Action Plan will be held on March 14, 2024. Comments provided at the Public Hearing will be considered in the development of the final plan. 

Summary of comments or views not accepted and the reasons for not accepting them
To be addressed in Final Plan 

Summary
The City of Tulsa looks forward to meeting the community's underserved needs and improving the quality of life of principally low and moderate income Tulsans. The fifth year of the Consolidated Plan will see 24 external agencies and 4 City departments conducting 39 activities totaling $6,348,622 in grant funding; not including administration costs. 

PR-05 Lead & Responsible Agencies 24 CFR 91.200(b)

Describe agency/entity responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source
The following are the agencies/entities responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source.

Table 1 – Responsible Agencies

Narrative (optional)

Consolidated Plan Public Contact Information

The City of Tulsa Finance Department Grants Administration is the lead entity responsible for preparing the Consolidated Plan and for the administration of the Community Development Block Grant (CDBG), the HOME Investment Partnerships Program (HOME), Housing Opportunities for Persons With AIDS (HOPWA) and the Emergency Solutions Grant (ESG). 

Consolidated Plan Public Contact Information 

Questions or comments regarding the plan should be addressed to: 
Rhys Williams, Grants Manager 
City of Tulsa, Grants Administration 
175 E 2nd Street, Suite 1560 
Tulsa, OK 74103-3208 
[email protected] 

AP-10 Consultation – 91.100, 91.200(b), 91.215(I)

Introduction

The City of Tulsa Grants Administration is committed to working with local agencies and service providers to create solutions to best address the needs of the community. The entities that have provided input and insight into the 2023-2024 Annual Action Plan are listed in the following section. 

Provide a concise summary of the jurisdiction’s activities to enhance coordination between public and assisted housing providers and private and governmental health, mental health and service agencies (91.215(l))

Tulsa benefits from a strong and cohesive coalition of local government officials, service providers, lenders, and volunteers.  These various groups coordinate effectively to avoid duplication of services and facilitate a delivery system that meets the needs of Tulsa's various populations. 

The City continues a targeted public outreach effort to educate and engage the public in the annual planning and funding opportunities process.  Activities include: 

• Posting and advertising all public meetings with adequate advance notice to citizens to maximize participation
  • Ensuring all public meetings, and other forms of communication, are accessible to people with disabilities and non-English speaking persons
• Utilizing web-based communication tools to solicit input from citizens
• Working with local service providers, Indian Nations Council of Governments (INCOG), the Housing Authority of the City of Tulsa, local lenders, and others to leverage public and private resources
• Coordinating resources and services for affordable and supportive housing, in conjunction with local service providers, housing officials, lending institutions, developers, and nonprofit organizations, including the City's Continuum of Care
• Conducting meetings with HUD funded grantees
• Meeting with funded agencies to discuss their programs, successes and challenges
• Providing on-going citizen participation opportunities in HUD Community Development Committee meetings

Describe coordination with the Continuum of Care and efforts to address the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans, and unaccompanied youth) and persons at risk of homelessness.

The City of Tulsa and the Tulsa City/County Continuum of Care (CoC) have made great strides in the development of a more inclusive coordination and consultation process. Although it is still a work in progress, the focus remains to collaborate on all aspects of the Emergency Solutions Grant process including planning, funding, implementing, and evaluating homeless assistance and prevention programs at the local level. The HUD Community Development Committee’s responsibilities include the following duties which play an important role in fulfilling the City’s collaboration with the CoC: 

• Receiving public input of needs
• Receiving input from the CoC regarding homeless needs, priorities, goals, outcomes, and evaluation measures
• Consulting with the CoC regarding allocation of funds, developing performance standards, and evaluating outcomes of ESG assisted projects

The Homeless Management Information System (HMIS) lead agency, Center for Housing Solutions, and the HMIS administrator participate in the A Way Home for Tulsa (Tulsa CoC) governance council meetings bringing forward HMIS data standards, policies and performance reports for review and approval. The administrator provides access to licenses, hands-on training, and technical support to all of the ESG subrecipients and submits performance reports to the City of Tulsa for the ESG programs. Based on an agreement between the City of Tulsa and the HMIS lead, the City of Tulsa allocates a minimum of 3% of the ESG funds each year to assist the HMIS lead in meeting the regulatory requirements of the data collection and mandatory reporting. 

Describe consultation with the Continuum(s) of Care that serves the jurisdiction's area in determining how to allocate ESG funds, develop performance standards for and evaluate outcomes of projects and activities assisted by ESG funds, and develop funding, policies and procedures for the operation and administration of HMIS

A member of the CoC sits on the HUD Community Development Committee and provides expertise during the allocation process. To ensure compliance with the HEARTH Act, Grants Administration (GA) continues to work closely with the City’s Continuum of Care and Emergency Solutions grant recipients serving the homeless.  

Describe Agencies, groups, organizations and others who participated in the process and describe the jurisdiction’s consultations with housing, social service agencies and other entities
Table 2 – Agencies, groups, organizations who participated

Identify any Agency Types not consulted and provide rationale for not consulting 
Multiple agencies were consulted.  

Other local/regional/state/federal planning efforts considered when preparing the Plan 

Table 3 – Other local / regional / federal planning efforts

Narrative (optional):
The City of Tulsa consulted with both Tulsa County and the Indian Nations Council of Government (INCOG). A member of INCOG sits on the HUD Community Development Committee and was involved during the development of the goals and the allocation process.  

AP-12 Citizen Participation – 91.105, 91.115, 91.200(c) and 91.300(c)

Summary of citizen participation process/Efforts made to broaden citizen participation

Summarize citizen participation process and how it impacted goal-setting

The Citizen Participation Plan and Title 12 §800 of City of Tulsa Municipal Code is the guiding documents that facilitate the process for the determination of needs, priorities, and allocation of HUD funds.  The HUD CDC receives citizen input and makes funding recommendations (Appendix A). 

The CDC solicits public input regarding the long-term and short-term needs of the community to develop funding priorities.  This committee consists of the following members who all have voting privileges:  the 9 City Councilors and Mayor who shall serve ex-officio; 5 residents of the City of Tulsa, designated by the City Council, 3 of whom shall reside within a low to moderate income census tract, with no more than one representative from each Council district; 1 representative from the  Indian Nations Council of Governments (INCOG); 1 representative from a financial institution;  1 representative from the Continuum of Care; 1 representative with grant allocation experience; and  1 representative from the City of Tulsa Planning Department. The Mayor shall designate the representatives from a financial institution, the Continuum of Care, and the individual with grant allocation experience.   

The priority needs for the City of Tulsa’s 2024-2025 Annual Action Plan were determined through analysis of information gathered from a variety of sources and progress of goals during the First- Second-Year Annual Action Plans as well as projections of anticipated goals for the Third and Fourth Year Annual Action Plan. The priority needs were presented to the HUD CDC and approved along with the fifth-year goals on July 13, 2023, which were then presented to the Mayor and City Council for approval. The priority needs and goals were accepted by the Mayor and City Council on August 24, 2023 and included in the 2024 Request for Proposals released by Grants Administration on September 12, 2023. 

Citizen Participation Outreach

 Table 4 – Citizen Participation Outreach

AP-15 Expected Resources – 91.220(c)(1,2)

Introduction
Currently, the City of Tulsa receives CDBG, HOME, HOPWA, and ESG funding.  These funding sources are expected to be available over the remaining  year of the five-year Consolidated Plan timeframe.  In PY 2024, the City is anticipating an allocation of $4,037,960.08 in CDBG funds, $2,784,535.59 in HOME funds, $800,571 in HOPWA funds, and $309,822 in ESG funds.  It is anticipated that funding levels will be similar over the 5 years of this Consolidated Plan. These anticipated amounts are noted in the chart below. As all funding sources are subject to annual Congressional appropriations, as well as potential changes in funding distribution formulas, these figures are subject to change. 

Anticipated Resources

Table 1 - Expected Resources – Priority Table

Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied

The federal, state, and local resources available to address the needs identified in the plan include federal formula grant funds under CDBG, ESG, HOME, and HOPWA.  The local Continuum of Care (CoC) also awards grant funds under the competitive McKinney-Vento Homeless Assistance Act.  These funds will be leveraged with the City's general funds, various state and county resources, local nonprofit resources, and private foundation grants. 

Essential Services projects will concentrate efforts to address the needs of families, children, and youth in high-risk populations consistent with the identified priority needs.  Use of CDBG and ESG funds will leverage other nonprofit resources and private foundation funds to assist low-income households. 

Physical improvements will use a combination of public funds, CDBG funds, City general funds, and nonprofit and private foundation funds to enhance selected projects. 

HOME Match:  The sources of matching contributions for HOME funds will be from developers and subrecipients' nonfederal contributions, the City and its Community Housing Development Organization(s) (CHDOs). The City requires developers, subrecipients and CHDOs to match up to 25% of award. First re-use CHDO proceeds, as regulated by HOME, are used as leverage to fund HOME activities. Banked match is available if organizations are not able to generate the required match. The City has $11.3 million in available banked match as of June 30, 2023.  

Emergency Solutions Grant Match: The jurisdiction will fulfill the ESG requirement of a matching contribution equal to the grant program funds. Each organization is required to provide matching funds equal to the amount of funds awarded; this stipulation is included in the written agreement. The City of Tulsa will provide in-kind administrative funds, as necessary, to match administrative funds received. Documentation of match is required when subrecipients submit the monthly request for funds. 

If appropriate, describe publicly owned land or property located within the jurisdiction that may be used to address the needs identified in the plan

N/A

Discussion

The Expected Amount Available for the Remainder of Consolidated Plan is an estimate of the funds expected to be received during the last year of the Consolidated Plan. Estimates were calculated using the confirmed funding to be received during the fourth year of the Consolidated Plan plus expected program income.  

The CDBG program income total includes an estimated $2,000,000 per year in revolving loans funds received through economic development activities plus an additional $133,413 in general program income. It is estimated that a similar amount of Revolving Loan funds will be received over the remaining year of this the Consolidated Plan. 

HOME CHDO Reserve funds in the amount of $250,000 was allocated in Year 5.  

AP-20 Annual Goals and Objectives

Goals Summary Information

Table 2 – Goals Summary

Goal Descriptions

Estimate the number of extremely low-income, low-income, and moderate-income families to whom the jurisdiction will provide affordable housing as defined by HOME 91.215(b) 
Throughout the course of the PY24 Annual Action Plan 528 families will be assisted with affordable housing solutions. All funding streams will be utilized to achieve this goal. 

AP-35 Projects – 91.220(d)

Introduction
The City of Tulsa will provide activities that support one or more of the following projects during Program Year 2024. 

Projects

Table 57 – Project Information

Describe the reasons for allocation priorities and any obstacles to addressing underserved needs
The priority needs for the City of Tulsa’s 2020-2024 Consolidated Plan were determined through analysis of information gathered from a variety of sources. The priorities for the Fourth Year Annual Action Plan were determined at the Needs Assessment Public Hearing on July 13, 2023, and included in the Request for Proposals issued September 14, 2023. Agencies were asked to identify which priority their program most closely related. During the evaluation phase, all applications were screened to ensure the proposed project or activity met one of the priority needs. 

Most agencies do not have necessary funds to provide all services needed by the clients and have stated in their applications that without HUD funds the project or program may not be able to fully serve the client needs. 

AP-38 Project Summary

AP-50 Geographic Distribution – 91.220(f)

Description of the geographic areas of the entitlement (including areas of low-income and minority concentration) where assistance will be directed
In the development of the Consolidated Plan, two specific target areas were defined and approved beyond the City Wide target area. These areas all suffer with high levels of poverty and unemployment, and with the exception of a small proportion of the Peoria Bus Rapid Transit (BRT) route, all are designated as LMI census tracts.   

Geographic Distribution

Table 4 - Geographic Distribution

Rationale for the priorities for allocating investments geographically
Concentrating resources in specific geographies is necessary to adequately address the scale of needs and achieve short and long-term improvements to identified substandard conditions. These identified substandard conditions could be deteriorated housing and infrastructure, access to lead-based paint free housing, reconstruction, and overall revitalization. The City elects to focus activity in the areas of the City with a high concentration of poverty, unemployment, and basic needs as well as areas where other public funds and private investments are anticipated as a basis for allocating investments geographically with the jurisdiction. The result of geographical allocation of HUD funding is efficient and an effective use of the funds to elevate and create more opportunities for areas where needs are greatest. 

Discussion 
The percentages listed above represents funded projects that will be located exclusively within the target areas. The geographic distribution of funds, where the location of services will vary during the year, will be included in the Consolidated Annual Performance and Evaluation Report (CAPER) due in September 2025.  

AP-55 Affordable Housing – 91.220(g)

Introduction
The City will utilize CDBG, HOME, ESG and HOPWA funds to support the following affordable housing goals: 

Non-homeless households 

• CDBG will support the rehabilitation of 172 housing units.
• HOME will support the rehabilitation of 6 housing units and Down Payment Assistance for 25 housing units.  
• ESG will support 620 households with homelessness prevention assistance.

Special-needs households 

• HOPWA will support 133 households/persons with TBRA and STRUMU.

Tulsa CARES will utilize HOPWA funds to support 43 households with Tenant Based Rental Assistance (TBRA) and 90 persons Short Term Mortgage Rent Utility Assistance (STRUMU). Rental assistance will be provided in the form of Homelessness Prevention to 20 persons with ESG funds managed by Family Safety Center. Homelessness Prevention will be provided by Center for Housing Solutions, assisting 600 persons who are facing housing instability or threat of eviction.  A total of 753 households/persons will be served.   

The rehabilitation of owner-occupied units will be funded with both CDBG and HOME. CDBG funds will provide homeowners up to $7,500 to carryout repairs to ensure safe and sanitary living conditions.  HOME funds will provide loans up to $45,000 for major repairs of owner-occupied housing. CDBG funds will support 146 housing units and HOME 10 housing units. 

HOME assistance will be provided to 25 low to moderate income households to purchase their first home. HOME assistance will also be awarded to Mental Health Association of Oklahoma for the Rehabilitation of Quincy Square Apartments, assisting 6 Low to Moderate income households.

Table 6 - One Year Goals for Affordable Housing by Support Requirement

Table 7 - One Year Goals for Affordable Housing by Support Type

Discussion
The number for Special Needs is not duplicated in the other categories.  

AP-60 Public Housing – 91.220(h)

Introduction
The City will continue to support public housing projects during the Consolidated Plan. The City will help support Tulsa Housing Authority with CDBG funds toward infrastructure improvements specifically associated with the 2021 Choice Neighborhood Implementation Grant.  

Actions planned during the next year to address the needs to public housing
Additionally, THA will receive the first-year commitment for the 2021 Choice Neighborhood Implementation Grant at Commanche Park Apartments in North Tulsa. The City has pledged $1.5 million over five years for this project. The allocation in PY24 is $375,000 to be used for infrastructure needs.  

Actions to encourage public housing residents to become more involved in management and participate in homeownership
The Housing Authority of the City of Tulsa (THA) provides Resource Centers at its remaining public housing family community.  A computer lab is furnished on-site with updated systems and high-speed internet access which can be used for job searches and other related activities.  The resource centers are staffed by a Service Coordinator that provides intake, assessment, planning, coordination, and delivery of services that support economic development and self-sufficiency. The service coordinators identify barriers, such as transportation, childcare, and education. They offer programs that will enhance the resident’s quality of life and prepare them to enter the workforce, thereby breaking the cycle of poverty. The service coordinators also provide information to the residents to assist them with pursuing homeownership. 

Public housing residents are encouraged to enroll in the Family Self-Sufficiency (FSS) Program. This program provides community support and resources to assist families with becoming self-sufficient. The Family Self-Sufficiency Coordinator meets with the interested resident and if selected for the program, the participant establishes a set of goals such as employment or homeownership. Monthly meetings are held to assess progress and assist the participant with any barriers in reaching their stated goals. An incentive of the FSS is an escrow account; as the family's income increases, contributions are made to the escrow account on the family's behalf.  Once the family is determined "Self-Sufficient" by meeting their goals and moving out of public housing, the money in the escrow account is paid to the participant.  No conditions are imposed on the use of the money. The family is encouraged to pursue homeownership and information on Homebuyer Education Programs is provided to them. 

Residents of THA communities are actively involved in the planning and development of programs for their communities. Each community is encouraged to establish a Resident Association which meets monthly to discuss areas of concern as well as plan events and activities for their communities. Each association has a set of bylaws that outlines how the association will operate. Training involving job duties, parliamentarian procedures, communication, and financial bookkeeping is provided to all Resident Association officers.   

If the PHA is designated as troubled, describe the manner in which financial assistance will be provided or other assistance
The Housing Authority of the City of Tulsa is not designated as troubled. 

Discussion 
N/A 

AP-65 Homeless and Other Special Needs Activities – 91.220(i)

Introduction
The City of Tulsa collaborates with and engages a diverse range of stakeholders dedicated to supporting a community-wide effort to end and prevent homelessness. City departments and leaders coordinate internal ongoing planning meetings and participate in external stakeholder meetings to ensure coordination of services and leveraging of resources. The city is an active participant in Continuum of Care (CoC) planning as a voting member on the CoC Leadership Council. CoC member organizations hold seats and participate in city led initiatives (e.g., committees, feedback sessions). The city uses ESG funding to provide vital services to those at-risk of homelessness through Homelessness Prevention activities and those experiencing literal homelessness through Emergency Shelter activities and Street Outreach. ESG funds are also used to support funding costs of the local HMIS database.   

Describe the jurisdictions one-year goals and actions for reducing and ending homelessness including

Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs
The City is allocating ESG funding to Housing Solutions to conduct Street Outreach for persons experiencing unsheltered homelessness. The City also supports outreach efforts through leveraging partnerships and supporting community led initiatives. Street outreach ensures persons living in unsheltered locations across the geographic region are being located, offered basic need resources, and engaged in housing and other supportive services. The OK-501 Tulsa City and County Continuum of Care (CoC) Lead Agency, Housing Solutions, will use $44,600 in ESG funding to employ street outreach specialists offering direct services and staffing to coordinate the community-wide outreach efforts. Housing Solutions serves unsheltered clients using a Housing First approach to connect clients to housing as well as transportation, case management, access to vital records (I.D.s, birth certificates), mainstream benefits, and temporary non-congregate shelter for those who are highly vulnerable. Everyone is provided the opportunity to complete the coordinated entry assessment, and is entered into the Homeless Management Information System (HMIS) to ensure connection to housing resources through the Coordinated Entry System. Housing Solutions’ Street Outreach Project includes strong collaboration with several local nonprofits, city, and county governments, churches and faith-based organizations, and private citizens. The local government collaborative efforts are a key aspect of the outreach due to partnerships with the leadership at all levels, including the Mayor’s Office, 3-H Taskforce, Tulsa Police Department, Department of City Experience (code enforcement), Tulsa Fire Department, and City Council members. 

Addressing the emergency shelter and transitional housing needs of homeless persons
The lead agency for the CoC, Housing Solutions, reported that the current shelter capacity in February 2023 is 546 beds. The City of Tulsa is providing ESG and CDBG funds to 3 emergency shelters and to assist with shelter services and operations serving 121 beds. The agencies receiving funds include Domestic Violence Intervention Services, Tulsa Day Center, and Youth Services of Tulsa. Each shelter provides varying services or targets a specific population to avoid duplication of efforts in the community. Specialized assistance is provided to youth, victims of domestic violence, and families with children. In addition to providing a safe place to stay, the shelters provide services in the form of case management, childcare, counseling, safety planning for victims of domestic violence, medical services, life skills, parenting, relationship skills, and therapeutic exercise classes and services to meet basic needs.    

Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again. 
The Tulsa County region implemented a Coordinated Entry System in 2019 with the aim of prioritizing resources to our most vulnerable community members and ensuring persons experiencing chronic homelessness have access to Permanent Housing resources.  

Family Safety Center will use funds for Homelessness Prevention by providing various assistance to individuals and families of domestic violence through obtaining or maintaining affordable access to safe and sanitary housing. 

In addition to the shelter, Youth Services of Tulsa (YST) assists unhoused unaccompanied youth ages 17-24, through a coordinated referral and application process to quickly move out of homelessness and into temporary housing through transitional housing (TH) programming. While in TH, case management services are provided to increase personal, social, educational, and occupational skills needed to transition into permanent housing. Youth and young adults are also connected with mental health services and other YST and community-based services to ensure their needs are met and permanent housing is obtained and sustained over time.  

Our community offers 584 Permanent Supportive Housing (PSH) Units and 515 Rapid Re-Housing (RRH) units through a diverse range of funding sources. Permanent Housing programs receive referrals through the local Coordinated Entry System.  

Helping low-income individuals and families avoid becoming homeless, especially extremely low-income individuals and families and those who are: being discharged from publicly funded institutions and systems of care (such as health care facilities, mental health facilities, foster care and other youth facilities, and corrections programs and institutions); or, receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs 
The City of Tulsa awarded funds to a program to assist individuals being discharged from correctional facilities.  Resonance Center for Women will provide incarcerated and formerly incarcerated females with relapse prevention education, job readiness training, domestic violence services, and education among other life skills training. This project works toward preventing individuals from becoming homeless after discharge. 

 There are a variety of efforts undertaken by the City of Tulsa and CoC member organizations to prevent homelessness. There are six primary preventative services offered by various provider organizations including, but not limited to: 

• Mortgage assistance
• Rental assistance
• Utilities assistance
• Counseling/advocacy
• Legal assistance
• Landlord/Tenant Outreach

Each service is designed to keep families housed by offering services and support during times of financial or legal difficulty. HOPWA funds will be provided for homelessness prevention to individuals diagnosed with HIV/AIDS and their families in the form of short-term rent, mortgage and utility assistance, tenant-based rental assistance, permanent housing placement, and supportive services. 

The Tulsa CoC’s 2020-2024 Strategic Plan includes the goal of stopping homelessness before it begins. Through multi-sector collaboration, community partners support this goal with action steps to improve discharge policies to reduce the number of individuals that exit institutions and systems of care (e.g., hospitals, jails, foster care) into homelessness. Housing Solutions operates the Landlord Tenant Resource Center (LTRC) to provide extremely low-income individuals and families and property owners access to housing-related advocacy, legal services, and education. The Social Services Hub (LTRC), a multi-partner collaboration that includes the local district court, provides services and housing navigation services to landlords and tenants to reduce Tulsa’s high rate of evictions. The LTRC also facilitates a focus group for tenants and landlords to identify the specific needs of the community. JusticeLink launched in 2022  provides free, voluntary court/resource navigation services for justice-involved Tulsans recently released from city or county jail with active justice-involvement. Through funding provided by ProsperOK, Housing Solutions partners with JusticeLink to provide an embedded housing navigation team to serve clients who identify as homeless, qualify for housing services including, but not limited to: 

• Navigation and application assistance for public housing programs
• Navigation and application assistance for private housing providers
• Engagement with sober living facilities upon client request
• Move-in and housing stabilization assistance
• Eviction prevention services for those at risk of homelessness
• Provision of financial assistance for application fees, risk fees, deposits, first-month’s rent, and fees associated with recovery-centered housing

Discussion 
The City of Tulsa and homelessness service providers, including Tulsa’s CoC, are committed to providing solutions and serving the needs of individuals experiencing homelessness. The Tulsa CoC lead agency, Housing Solutions, empowers the local homelessness system through the provision of free community-wide training aimed at supporting staff and leadership with the tools needed to serve the needs of our citizens. Trainings may include Housing-Focused Case Management, Motivational Interviewing, LGBTQ+ Preparedness, and Trauma-Informed Care.  

The Tulsa City and County Continuum of Care, in alignment with the Strategic Plan, expanded the CoC Written Standards with the creation of the local A Way Home for Tulsa Services Standards. The City of Tulsa adopted the CoC Services Standards to serve as the ESG Written Standards for the jurisdiction. In addition to the required elements of the ESG and CoC Written Standards, the Services Standards provides Tulsa’s homelessness service providers a guide for equitably delivering services across the continuum in a safe and inclusive way. 

AP-70 HOPWA Goals - 91.220 (l)(3)

AP-75 Barriers to Affordable Housing – 91.220(j)

Introduction:
Public policies are meant to address the overall needs of citizens in the City.  There are times when public policy may have a negative effect on certain aspects of the community, specifically affordable housing and residential investment.  Affordable housing as well as public and private residential investments are key components in furthering fair housing in any community.  The primary tool communities have for identifying contributing factors for these barriers to housing is an assessment of fair housing and fair housing choice.  In 2020, the City updated the previous 2015 assessment.  Analysis from the 2020 update has found: 

• A limited supply of affordable housing and extensive cost burden, especially for extremely low- and very low- income renters, causing those renters to face significant affordability “gaps”; and
• Fair housing education is lacking and must be better understood by community residents and property owners.

The City plans corresponding actions designed to strengthen the supply of affordable housing and narrow the affordability “gaps.”  Elements of those actions appear within the 2020-2024 Consolidated Plan and beyond.  Additionally, the City anticipates a review of public policies that may impede the development of affordable housing and to improve the understanding of their consequences.   

The City’s actions identified in the 2020 assessment of fair housing include actions that will help to ameliorate barriers to affordable housing. These actions include addressing Disproportionate Housing Problems and Economic Barriers and addressing Lack of Access to Transportation Options Reducing Housing and Economic Opportunities.  Through these actions the City will work to give special consideration to rental housing development, particularly accessible housing, and will expand access to public transportation giving residents greater access to housing and economic opportunities. 

Discussion: N/A 

AP-85 Other Actions – 91.220(k)

Introduction:
The City will use CDBG, ESG, HOME and HOPWA funds to provide a variety of services within the City of Tulsa. The sections below address specific projects funded. A complete list of activities, by funding source, is included in Appendix A. 

Actions planned to address obstacles to meeting underserved needs 
For PY 2024, the City of Tulsa will provide funds to 24 external agencies and 4 City departments to conduct activities across this Annual Action Plan. By awarding a variety of agencies and multiple activities, the City is attempting to address obstacles to meeting the underserved needs of the community. 

The City of Tulsa plans to serve 12,535 people with CDBG Essential Services, ESG, and HOPWA funds.  Broken down by funding source, CDBG Essential Services will account for approximately 8,610 people, Emergency Solutions will account for 3,755 people, and HOPWA will serve 170 people.  

Public facility improvements will benefit 8,479 people and will meet the low to moderate income clientele national objective. Projects will include the City of Tulsa’s Streets and Stormwater Department installing new sidewalks in low and moderate income areas. The Tulsa Children’s Coalition will upgrade the children’s playground at Skelly Pre-School by replacing worn playground equipment and surfaces, add a shade structure, and correct drainage and grading issues, this will assist 159 persons.

Additionally, in partnership with the Tulsa Housing Authority, the second year of the Choice Neighborhood Implementation for the Commanche Apartments located in the Pheonix District will continue. 

Through an economic development activity for small business loans, 35 jobs will be created of which at least 51% will be for low to moderate income persons. The CDBG funds are used to provide loans to businesses normally excluded from the economic mainstream.  

The City of Tulsa's Department of City Experience (DCE) will use CDBG funds to conduct clearance and demolition activity in low to moderate-income census tracts within the City.  

Actions planned to foster and maintain affordable housing 
The City of Tulsa has awarded funding that will foster and maintain affordable housing.  One City department will conduct owner occupied housing rehabilitation projects for 146 homeowners and one agency received funding for a rental rehabilitation project assisting 6 low to moderate income households.

HOME assistance will be provided to 25 low to moderate income households to purchase their first home. 

Actions planned to reduce lead-based paint hazards 
The City of Tulsa ensures that inspections for lead-based paint (LBP) hazards will occur, as required, for all funded housing activities.  Proper notifications will be provided regarding lead-based paint hazards.  All housing units constructed prior to 1978 will be tested for LBP by a certified LBP inspector or Risk Assessor. If LBP is detected, all covered renovations will follow HUDs Lead Safe Housing Rules and be performed by certified firms using certified renovators and other trained workers. 

Actions planned to reduce the number of poverty-level families 
The City identified priorities that will encompass services that assist in breaking the cycle of poverty. Of the proposals received, 24 were chosen for funding and will serve the following needs to reduce the number of poverty level-families: 

• Education programs for children and youth including early childhood education, after school programs, and transitional living programs for homeless youth
• Mentoring, life skills, education, job training, and placement services for unemployed, underemployed, and those recently released from prison
• Crisis services for children, adults, and special populations
• Services to seniors, homeless individuals, and families 

Actions planned to develop institutional structure  
During Program Year 2024, the City of Tulsa plans to continue providing training and technical assistance for all grant recipients to ensure the jurisdiction has a strong delivery system. Grant-specific roundtable sessions will be scheduled as needed; these have proven invaluable in the past by keeping an open dialogue with agencies regarding project activities, best practices, and compliance requirements.  

Actions planned to enhance coordination between public and private housing and social service agencies 
Tulsa benefits from a strong and cohesive coalition of local government officials, service providers, lenders, and volunteers. These various groups coordinate effectively to avoid duplication of services and facilitate a delivery system that meets the needs of Tulsa's various populations. The City continues a targeted public outreach effort to educate and engage the public. 

Discussion:  
N/A 

AP-90 Program Specific Requirements – 91.220(l)(1,2,4)

Introduction:

Community Development Block Grant Program (CDBG)
Reference 24 CFR 91.220(l)(1)
Projects planned with all CDBG funds expected to be available during the year are identified in the Projects Table. The following identifies program income that is available for use that is included in projects to be carried out.

Other CDBG Requirements

HOME Investment Partnership Program (HOME)
Reference 24 CFR 91.220(l)(2)

1. A description of other forms of investment being used beyond those identified in Section 92.205 is as follows:
    The City of Tulsa does not use any form of assistance that is not described in Section 92.205(b). 

2. A description of the guidelines that will be used for resale or recapture of HOME funds when used for homebuyer activities as required in 92.254, is as follows:
    The City of Tulsa homeownership program activity uses the recapture provisions of 24 CFR 92.254(a)(4)(ii).  It is believed this process is the closest to normal market approaches to financing, the easiest for borrowers to understand, enables the deed restriction requirements of the alternative option to be avoided (which we believe constitutes a barrier to private financing participation), and better enables HOME funds to be marketed in coordination with other private lending.   An ongoing homeownership assistance activity has been the City's goal and is in keeping with the basic HOME program descriptions. 

A purchaser of a property may apply for and be provided HOME assistance subject to the property and said buyer meeting HOME program eligibility criteria, a written agreement to comply with program terms and conditions, and the availability of funds.  Mortgages include the "principal residence" requirement of the program during the affordability period, failure of which will constitute a default of the second mortgage.  

The recapture option is a mechanism to recapture all or a portion of the direct HOME subsidy if the HOME recipient decides to sell the house within the affordability period at whatever price the market will bear. Forgiveness will be tied to the length of time the homebuyer has occupied the home in relation to the period of affordability and the net proceeds of the sale.  The affordability period is based on the amount of HOME funds provided for the property and is forgiven as designated in the GRANTS ADMINISTRATION HOME policies and procedures.  Calculations for the recapture include the HOME Investment, the Homebuyer Investment, and the Net Proceeds.  These are defined as:  

1. HOME Investment is all HOME funds contributed to the unit and any direct subsidies consisting of any financial assistance that reduces the purchase price from fair market value to an affordable price, or otherwise subsidizes the purchase;
2. Homebuyer Investment consists of the portion of initial down payment paid by the homebuyer combined with the value of any capital improvements made with the homebuyer funds; and 
3. Net Proceeds are the sales price minus closing costs and any non-HOME loan repayments.  To allow low-income homebuyers to retain some equity in their property should they need to sell, the City of Tulsa recaptures HOME funds using the following steps:

 a) Reduction during affordability period.  The HOME investment amount to be recaptured will be reduced on a prorated basis for the time the homeowner has owned and occupied the housing measured against the required affordability period;  

1. b) Owner investment returned first. From the net proceeds of the sale, the homebuyer may recover their entire investment before the HOME investment is recaptured; and
2. c) Shared Net Proceeds.  If the net proceeds are not sufficient to recapture the full HOME investment (or a reduced amount according to the time the homeowner occupied the home), plus enable the homeowner to recover the amount of their down payment and any capital improvement investment made since purchase, the net proceeds will be divided proportionally.  The formula used will be HOME Investment multiplied by Net Proceeds divided by HOME Investment plus Homeowner Investment equals HOME Recapture.

3. A description of the guidelines for resale or recapture that ensures the affordability of units acquired with HOME funds? See 24 CFR 92.254(a)(4) are as follows: 

The administration of homebuyer programs includes thoroughly informing each potential homebuyer of all the requirements under the HOME Program. This will ensure they understand what is required through the affordability period and the recapture provisions if they sell the property prior to the expiration of the affordability period. This information is included in the Homebuyer Written Agreement and explained verbally by a housing counselor.  In addition, a second mortgage is executed at closing and is not released until after the affordability period has expired.  Provisions in these documents include the following criteria, which are verified annually until the end of the affordability period: 

• Principle Residence
• Current on Mortgage, Taxes, and Insurance
• Upkeep of Property (no code violations from the City of Tulsa)

All organizations that administer the program for the City are required to keep an inventory of all properties that remain under the affordability period.  This information is submitted to Grants Administration at the end of each program year. 

4. Plans for using HOME funds to refinance existing debt secured by multifamily housing that is rehabilitated with HOME funds along with a description of the refinancing guidelines required that will be used under 24 CFR 92.206(b), are as follows:
    

The City of Tulsa does not use HOME funds to refinance existing debt. 

5. If applicable to a planned HOME TBRA activity, a description of the preference for persons with special needs or disabilities. (See 24 CFR 92.209(c)(2)(i) and CFR 91.220(l)(2)(vii)). 

   The PY24 TBRA Activity will contain a preference for persons with special needs or disabilities. The description/question for persons with special needs or disabilities is “Have you ever been a victim of discrimination or prejudice?  This could be with your race, ethnicity, disability status, gender, sexual orientation, or age. (Including hate crimes. No proof necessary.)” In this context “disability” is defined by Federal nondiscrimination laws as a person with a disability to include any (1) individual with a physical or mental impairment that substantially limits one or more major life activities; (2) individual with a record of such impairment; or (3) individual who is regarded as having such an impairment.

6. If applicable to a planned HOME TBRA activity, a description of how the preference for a specific category of individuals with disabilities (e.g. persons with HIV/AIDS or chronic mental illness) will narrow the gap in benefits and the preference is needed to narrow the gap in benefits and services received by such persons. (See 24 CFR 92.209(c)(2)(ii) and 91.220(l)(2)(vii)).

N/A

Emergency Solutions Grant (ESG)
Reference 91.220(l)(4)

1. Include written standards for providing ESG assistance (may include as attachment)

In accordance with 24 CFR 576.400(d) the City of Tulsa has adopted written standards for the provision of ESG assistance in collaboration with the Tulsa Continuum of Care (CoC). These written standards are included in Appendix E. 

2. If the Continuum of Care has established centralized or coordinated assessment system that meets HUD requirements, describe that centralized or coordinated assessment system. 

Tulsa’s Continuum of Care’s coordinated entry system is All Doors Open. This system is designed to provide each individual, or family, with adequate services and support to meet their housing needs, with a focus on returning them to housing as quickly as possible. The components of All Doors Open are listed below: 

1. Access and Screening
2. Assessment
3. Prioritization and By-Name List(s)
4. Case Conferencing
5. Referral
6. Placement

The system operates with a decentralized “no-wrong-door” system of access, so that persons in need can enter the system at multiple participating agencies in different geographic locations. All Doors Open strives to be inclusive and continuously seeks partnerships with public service institutions (health departments, county clinics, human services), faith-based organizations, other institutions (hospitals and jails), and mainstream resources to serve as access points. 

At various provider access points, individuals and families experiencing a housing crisis complete a screening tool that considers the individual or family’s need for specialized services and the ability to prevent or divert the individual or family from experiencing homelessness. Should homelessness not be avoidable, a standardized common assessment tool is used to determine the individual or family’s vulnerability. The common assessment tool is integrated into the Homeless Management Information System (HMIS) and may be conducted at partner agencies including shelters, drop-in centers, transitional housing programs, outreach programs, telephonically, or wherever people who are experiencing homelessness first enter Tulsa’s coordinated entry system. 

Housing programs, including permanent supportive housing, rapid re-housing, transitional housing, and safe-haven housing fill available spaces in their programs from a By-Name-List of eligible individuals and families generated from HMIS. To ensure the most vulnerable are housed first, the By-Name-List is prioritized based on common assessment scores and length of time homeless. This coordination improves the targeting of housing resources and reduces the need for people to separately seek assistance at various partner providers. 

The HMIS system is fully compliant with HUD's requirement for victim services and does not include domestic abuse service providers.  

3. Identify the process for making sub-awards and describe how the ESG allocation available to private nonprofit organizations (including community and faith-based organizations).

The HUD grant selections are made through a joint process adopted by the Tulsa City Council and Mayor in which applications are accepted from nonprofit agencies serving within the corporate limits of the City of Tulsa. Through public meetings and surveys, the HUD Community Development Committee determine the needs of the community, sets the funding priorities, and reviews the community development plan. The Continuum of Care and/or member agencies present homeless needs at the Needs Assessment Public Hearing.  Applications are created based on the priority needs determined by the committee and grant guidelines. Upon review of the applications, the HUD Community Development Committee submits funding recommendations to the Mayor and City Council for approval. A member of the Continuum of Care is appointed by the Mayor to serve on the HUD Community Development Committee for the award of ESG funds as well as the other HUD funds.  

4. If the jurisdiction is unable to meet the homeless participation requirement in 24 CFR 576.405(a), the jurisdiction must specify its plan for reaching out to and consulting with homeless or formerly homeless individuals in considering policies and funding decisions regarding facilities and services funded under ESG. 

As part of the written agreement, subrecipients are required to provide for the participation of a homeless individual or formerly homeless individual in a policy-making function within the organization. This may include involvement of a homeless or formerly homeless person on the Board of Directors or similar entity that considers and sets policy or makes decisions for the organization. 

5. Describe performance standards for evaluating ESG.  

The City of Tulsa contractually holds subrecipients responsible for meeting the accomplishments established for each grant activity in a written agreement. Each agency is also required to report program outcomes and participant demographics into HMIS and submit quarterly reports to the City. The City works closely with subrecipients and the CoC to develop program and service outcome benchmarks. The AWH4T Outcome Standards are used as a guideline for ensuring the success and effectiveness of all homeless programs including ESG. These standards are included in Appendix E. The 4 goals included in the standards include: 

1. Stop Homelessness Before It Begins
2. Transform the Homeless System of Care to Be More Effective, Equitable, and Person-Centered
3. Increase Access to Housing
4. Partner Across Tulsa to Build Solutions and Access Resource

• Appendices