Homelessness Partnering Strategy Directives 2014-2019

The Directives provide guidance, details and expectations to assist communities in preventing and reducing homelessness.

Directive 1: Chronically and Episodically homeless populations

The purpose of this directive is to define the chronically and episodically homeless populations and clarify the activities related to identifying these populations that can be supported under Housing First and Non-Housing First dedicated funding.

Description of Directive 1

The target population for the Housing First approach under the Homelessness Partnering Strategy (HPS) is individuals who are chronically and episodically homelessFootnote 1. HPS has defined these populations as follows:

  • Chronically homeless refers to individuals, often with disabling conditions (e.g. chronic physical or mental illness, substance abuse problems), who are currently homeless and have been homeless for six months or more in the past year (i.e., have spent more than 180 cumulative nights in a shelter or place not fit for human habitation).
  • Episodically homeless refers to individuals, often with disabling conditions, who are currently homeless and have experienced three or more episodes of homelessness in the past year (of note, episodes are defined as periods when a person would be in a shelter or place not fit for human habitation, and after at least 30 days, would be back in the shelter or inhabitable location).

The definitions of chronically and episodically homeless individuals include all sub-populations, such as Veterans and/or Aboriginals. The definitions also include individuals exiting institutions (e.g. child welfare system, mental health facilities, hospitals, and correctional institutions) who have a history of chronic and episodic homelessness and cannot identify a fixed address upon their release.

Once a community has housed 90% of its chronic and episodic homeless population, it may focus the Housing First interventions on the group with the next highest needs.

Examples include:

  • Individuals who have been homeless (in a shelter or living on the street) for three to five months over a year.
  • Individuals who experienced two or more episodes of homelessness over a year.
  • Individuals currently in transitional housing.
  • Individuals with the greatest needs as identified in the HPS Community Plan.

The community is responsible for providing an update on its Housing First program and a rationale for selecting the next group of clients in the Annual Community Plan Update.

Developing a local portrait of homelessness

Communities should determine the size and make-up of the chronic and episodic homeless populations, so that by in the 10 largest communities or by in the smaller communities that receive an allocation over $200K under the HPS Designated Communities or Aboriginal Homelessness funding streams are able to implement an appropriate Housing First program and develop an intake system to ensure that those most in need are given priority.

Data sources that support this work include established shelter data collection and reporting systems such as the Homeless Individuals and Families Information System (HIFIS) or a provincially-mandated system, point-in-time counts, and information collected by service organizations across the community. Data should be re-examined regularly as new individuals may become part of the target group. Depending on the size of the chronic and episodic homeless populations, it may be necessary to consider additional criteria to ensure that the clients with the highest needs are prioritized for a Housing First intervention. For example, the intervention could be further focused on specific populations or those who have been homeless for the longest period (e.g. over five years) or on those with the highest cumulative number of days using shelters over the last year.

Developing an intake system

Communities are encouraged to work with shelters and service providers to ensure that the intake of clients prioritizes those with the highest needs. Depending on the size of the populations, this may require some communities to develop a more comprehensive and coordinated intake system.

Eligible activities

Housing First dedicated funding:

  • Client Intake and Assessment:
    • Activities include:
      • coordinated intake management (where feasible, and where numbers warrant it); and
      • client identification, intake and assessment, focusing on the chronically and episodically homeless populations (e.g. developing client assessment tools).
  • Data, Tracking & Monitoring:
    • Activities include:
      • identifying the size and make-up of the chronically and episodically homeless population such as accessing shelter data, which includes the coordination of shelter data to identify and measure chronic and episodic homelessness populations (e.g. technical support for data collection, activities intended to build partnerships for data collection and analysis); and
      • tracking Housing First clients.

Ineligible activities

For both Housing First and Non-Housing First dedicated funding:

  • Software development or purchase of hardware for the collection or management of homelessness data that results in an inability to participate in the National Homelessness Information System initiative; and that constitutes a redundant use of funds and duplicates activities already offered through HIFIS. For example: purchasing alternative software that performs similar functions to the HIFIS software.

Directive 2: Connecting to and maintaining housing

The purpose of this directive is to clarify the activities that are related to connecting and maintaining housing and that can be supported under Housing First and Non-Housing First dedicated funding.

Description of Directive 2

A key element of Housing First is ensuring clients have access to permanent, affordable and safe housing while providing the necessary housing supports to ensure they stay housed. As such, each community needs to work through how it will connect Housing First clients to permanent housing and how it will support them to maintain that housing.

Housing choice is a key principle of Housing First under the Homelessness Partnering Strategy (HPS). Clients should have the choice of private market, social or permanent supportive housing. Acceptance of any services, including treatment, or sobriety is not a requirement for accessing or maintaining housing, but clients must be willing to accept regular visits, often weekly.

Outside Housing First, housing placement should be used with clients who are likely to be successful at maintaining their housing.

Eligible activities

Housing First dedicated funding:

  • Connecting clients to permanent housing:
    • The activities include:
      • Facilitating access to housing, which includes:
        • determining client’s preferences and needs for housing and type of supports;
        • securing housing for clients by working with private and public local real estate, landlord associations, etc. to identify available housing units; and
        • providing emergency housing funding as required (e.g. interim funding to help clients cover housing costs in the short term while awaiting access to supports under the provincial/territorial/municipal systems).
      • Setting-up apartments (insurance, damage deposit, first and last months’ rent, basic groceries and supplies at move-in, etc.). If a provincial social assistance or other program offers clients first and last month’s rent or damage deposits this funding should be exhausted first before HPS funding is used for these purposes.
      • Furnishing apartments for Housing First clients (furniture, dishes, etc.).
      • Repairing damages caused by Housing First clients.
      • Providing Landlord-tenant services, which includes:
        • building and maintaining relationships with landlords; and
        • providing landlord mediation and training on roles and responsibilities of tenants and landlords.
      • Re-housing (if required).
  • Support services to improve the self-sufficiency of chronically and episodically homeless individuals and families in the Housing First program through individualized services, including:
    • Connecting clients to income supports.
    • Life skills development (e.g. budgeting, cooking).
    • Supports to improve clients’ social integration.
    • Culturally relevant responses to help Aboriginal clients.
    • Providing support services to clients who have already been placed in housing through a Housing First approach already implemented in the community before and have a history of chronic and episodic homelessness. Note: although the services provided to existing Housing First clients count towards Housing First funding targets, these clients should not be included in outcome tracking for Results Reporting as they were Housing First clients prior to 2014.

Non-Housing First dedicated funding:

  • Individualized support services to improve the self-sufficiency of homeless individuals and families and those at imminent risk of homelessnessFootnote 2 (outside of Housing First programs).
    • Activities include:
      • housing placement (outside of Housing First), which includes identifying and placing clients in suitable housing;
      • connecting clients to income supports;
      • pre-employment support, and bridging to the labour market;
      • life skills development (e.g. budgeting, cooking);
      • supports to improve clients’ social integration; and
      • culturally relevant responses to help Aboriginal clients.

Ineligible activities

For both Housing First and Non-Housing First dedicated funding:

  • Assist with regular cleaning and general maintenance.

Directive 3: Emergency Housing Funding

The purpose of this directive is to clarify the activities related to Emergency Housing Funding that can be supported under Housing First.

Description of Directive 3

The Homelessness Partnering Strategy (HPS) has defined Emergency Housing Funding as follows:

  • Reasonable funding used to help a client cover housing costs in the short term. The funding provides a temporary bridge when needed for Housing First clients who are waiting to access rent supplements from provincial, territorial or municipal programs. While there is no maximum time limit for individual Housing First clients to access Emergency Housing Funding, communities must not spend more than 50% of their HPS Housing First allocation on this activity.
  • The objective is not to create a new rent subsidy or rent supplement program, but rather to transition clients to a sustainable solution for the long-term, including integration into the provincial, territorial or municipal system of supports and ultimately, self-sufficiency. Clients are expected to contribute up to 30% of their income towards their rent. Emergency Housing Funding must not exceed what provincial, territorial or municipal rent supplement programs would normally support.

Rent supplements (sometimes called rent subsidies) are the provincial, territorial or municipal supports that help individuals pay rent. These supplements consist of amounts that are paid to the renter or landlord and that are based on the renter’s income (or up to a maximum portion of it).

Partnering with provincial, territorial, or municipal programs

The Community Advisory Board and the Community Entity need to partner with the provincial, territorial, or municipal governments to ensure that any HPS Emergency Housing Funding aligns with the existing provincial, territorial, or municipal housing initiatives in the community and avoid creating new support programs where they already exist. HPS expects communities to understand how rent supplement programs work in the Province, Territory, or Municipality. Communities should also connect the client to all available provincial, territorial, or municipal support (e.g. social assistance, income support) for which the client is eligible.

Designing HPS emergency housing funding

When designing and implementing an Emergency Housing Funding approach, communities need to ensure alignment with provincial, territorial, or municipal requirements (e.g. income testing, eligibility). While temporary Emergency Housing Funding can be offered under HPS, it is not intended to provide long-term support. As such, as soon as a Housing First client gets Emergency Housing Funding under HPS, the community must have determined a process and timeline for their integration into the provincial, territorial or municipal programs.

Using a commitment of assured rental income paid directly to the landlord and not the Housing First client, and the willingness to cover any damage repairs, communities may approach landlords to negotiate lower rent as a strategy to control costs, and make the accommodation more affordable for the clients over the longer term. Such a strategy can be useful in all communities, particularly in those where the rental vacancy rate is high.

Eligible activities

  • Temporary Emergency Housing Funding, which must not represent more than 50% of the HPS Housing First allocation, for Housing First clients who have expended their first and last months’ rent provision under the provincial, territorial, or municipal social assistance programs, including utility payments and emergency one-time rental deposits. Emergency Housing Funding may include:
    • Providing Emergency Housing Funding to help clients cover housing costs temporarily while awaiting access to supports under the provincial, territorial, or municipal systems.

Ineligible activities

  • Emergency Housing Funding to individuals who are not Housing First clients.
  • Emergency Housing Funding while the Housing First client is effectively supported by the provincial, territorial, or municipal welfare and rent supplement programs.
  • Permanent Emergency Housing Funding.

Directive 4: Treatment services and case management

The purpose of this directive is to clarify the activities related to treatment services and case management that can be supported under Housing First and Non-Housing First dedicated funding.

Description of Directive 4

An important element of a Housing First program is ensuring that Housing First clients have access to clinical and treatment services. However, the Homelessness Partnering Strategy (HPS) funding does not support the provision of general clinical health, medical, mental health, or addictions support services, such as the direct provision of harm reduction, as these are provincial and territorial areas of responsibility. Therefore, communities must ensure that HPS programs are not supporting these services. While HPS funding cannot be used to provide clinical, health and treatment services, it can be used for case management and activities to link Housing First clients to these services. It is important to engage partners to map out how these services will work in the community. In the case of homeless Veterans or Veterans at risk of homelessness, Veterans Affairs Canada (VAC) is responsible for providing case management.

Similarly, HPS funding cannot be used to create an Assertive Community Treatment (ACT) team, which directly provides clinical, health and treatment services. If a community intends to create an ACT team, it needs to leverage any medical services from the Province or Territory. However, HPS funding can be used to fund some parts of an ACT team (e.g. peer support worker, employment counsellor, landlord liaison). HPS funding can also support coordination activities to work with the Province or Territory to identify how clinical, health and treatment services can be provided using sources other than HPS. Also, HPS funding can be used to fund an Intensive Case Management (ICM) team whose role would be to achieve better collaboration and coordination to provide Housing First clients access to the necessary clinical, health and treatment services available within the community.

Eligible activities

Housing First dedicated funding:

  • Connecting Housing First clients to clinical, health and treatment services through case management, including through an ICM team.
  • Hiring housing support or tenancy expertise, basic skills training, and education or employment specialists, including as part of an ICM team.
  • Peer support: helping clients to empower themselves in addressing their health issues and progress toward self-sufficiency.
  • Partnership development, liaison and integration to bring together services to support the needs of Housing First clients or to establish case management teams where none exists.
  • Project coordination on an ACT team.
  • Linking Housing First clients to existing ACT teams.

Non-Housing First dedicated funding:

  • Connecting homeless individuals and families and those at imminent risk of homelessnessFootnote 3 to support services through case management.

Ineligible activities

For both Housing First and Non-Housing First dedicated funding:

  • Providing general health and medical services (e.g. doctors, nurses and other medical professional salaries), mental health or addictions support services (e.g. counselling, treatment, and hospitalization).
  • Harm reduction and related activities
    • Any costs related to the direct delivery of a harm reduction approach and related activities
    • Purchase, storage, distribution, provision and/or supervised use of materiel and/or supplies in support of harm reduction (e.g. needles, alcohol, drugs, substitutes, etc.)

Directive 5: Coordination of resources and leveraging

The purpose of this directive is to clarify the activities related to the coordination of resources and leveraging that can be supported under Housing First and Non-Housing First dedicated funding.

Description of Directive 5

Coordination of resources

The Homelessness Partnering Strategy (HPS) has defined coordination of resources as follows:

  • Planning, developing partnerships and implementing solutions in support of a Housing First approach or a broader systematic approach to addressing homelessness, which includes activities to:
    • identify, integrate and improve services on an ongoing basis;
    • work with the relevant sectors to identify barriers to permanent housing and opportunities to address the barriers; and,
    • maximize all investments by coordinating funded activities to avoid duplication and gaps, ensuring that funding is used strategically to maximize results.

When delivering services under a Housing First approach, coordinating resources with partners is criticalFootnote 4. Partners may include municipal, provincial and territorial departments, as well as federal agencies, such as the Canada Mortgage and Housing Corporation (CMHC) or Veterans Affairs Canada (VAC). It is particularly important to coordinate resources for services that are ineligible for HPS funding (e.g. clinical services, which fall under provincial or territorial jurisdiction). In order to effectively support Housing First planning and successfully implement a local Housing First approach, Community Advisory Boards (CABs) and Community Entities (CEs) need to have a good understanding of the resources available in their community. Also, in communities where separate CABs are responsible for HPS funding under the Designated Communities and Aboriginal Homelessness funding streams, these CABs need to work together to ensure that the local Housing First approach effectively supports homeless Aboriginal clients.

Information on the resources available in the community helps to assess gaps in the homelessness serving system, better integrate available services, and maximize collaboration among partners. For example, if a community determines that a significant number of chronically and episodically homeless individuals have mental health issues, the community should be working with the Province, Territory or Municipality to ensure that these clients have access to the necessary services that address their needs.

Leveraging

In addition, CABs and CEs need to work with other partners to leverage existing programs and services in order to offer Housing First clients the range of services they requireFootnote 5.

Eligible activities

For both Housing First and Non-Housing First dedicated funding:

  • Activities to ensure coordination of resources and leveraging of services and resources, including:
    • determining a model in support of a broader systematic approach to addressing homelessness;
    • identifying, integrating and improving services (including staff training on activities and functions in support of a broader systematic approach to addressing homelessness);
    • partnership development in support of a broader systematic approach to addressing homelessness; or
    • working with the housing sector to identify opportunities for and barriers to permanent housing (e.g. establishing landlord relationships, mapping of current available assets) in support of a broader systematic approach to addressing homelessness.
  • Under non-Housing First dedicated funding, consultation, coordination, planning, and assessment (e.g. community planning) can also be included as eligible activities.

Ineligible activities

For both Housing First and Non-Housing First dedicated funding:

  • Holding meetings solely to provide networking opportunities or in recognition of past efforts.

Directive 6: Sustainability

The purpose of this directive is to clarify the expectations and requirements related to sustainability.

Description of Directive 6

The Homelessness Partnering Strategy (HPS) considers projects sustainable when either the project activities or benefits achieved as a result of the project activities continue after the HPS funding has ended. Within Housing First, sustainability occurs at the client and program levels. Sustainability for clients means ensuring that Housing First clients have successfully moved to mainstream or other services not funded by HPS or that there are plans in place to transition all existing HPS Housing First clients to services that will continue after the HPS funding has ended. Sustainability at the Housing First program level means working with partners and other funders to ensure that the programs are sustainable in the long term.

Sustainability of the Housing First approach

The extent to which communities have been able to establish a coordinated and integrated homeless-serving system will support sustainability (See Directive 5: Coordination of Resources and Leveraging for more detailed information). Communities implementing the Housing First approach need to ensure that there will be no gaps in services for Housing First clients at the end of the HPS in March 2019. As such, the communities’ effort to orient their Housing First clients into mainstream services is very important to ensure that Housing First programming effectively brings clients toward self-sufficiency.

To ensure that the Housing First approach is sustainable, communities need to:

  1. Integrate sustainability into planning and sub-project agreement management: Community Advisory Boards (CABs) are advised to start thinking about sustainability when they develop and submit their HPS Community Plans. Communities are expected to consider planning the transition of Housing First clients into mainstream services as soon as clients are able. The CAB is expected to have the sustainability of the Housing First approach documented, through a sustainability plan and/or general or individual transition plan(s) for Housing First clients (which can also be developed by local support service agencies).

  2. Partner with the relevant sectors: To support Housing First clients, communities need to partner with the relevant sectors, especially those responsible for providing the mainstream services such as healthcare providers. This supports the coordination and integration of the Housing First approach within existing programming, as well as planning for the transition of Housing First clients into mainstream services. This can also help other partners reorient their programming to integrate Housing First clients and consider their specific needs.

    As some Housing First clients may be able to move to mainstream services sooner than others, and some may require more closely case managed supports, it is important that communities meet with their partners to manage resources and pressures on other service systems.

  3. Plan for the transition of Housing First clients: Although planning for the transition of Housing First clients is primarily about supporting them to become self-sufficient, it also serves to mitigate the risk of clients relying on ongoing supports provided by the HPS after the end of the funding in March 2019. Communities may develop individual transition plans for each Housing First client or general plans applicable for all or groups of clients. Over time, clients should gain a certain degree of independence, require fewer supports, and be able to access or be integrated into mainstream services. For example, some communities that have already implemented Housing First set a guideline of, on average, 12 to 16 months to move clients to mainstream services.

    Communities that have secured other funding and resources to support Housing First clients would be able to continue to intake new clients in the final year of the HPS. Otherwise, communities should focus on transitioning Housing First clients toward mainstream services by 2018-2019. HPS recognizes that this will have an impact the community’s Housing First results and will take this into consideration in the analysis and evaluation of the impact of the program.

Sustainability at the community level

At the community level, beyond Housing First, engaging key stakeholders and developing and maintaining partnerships are also central to sustainability. Partnership development at the outset, during the community planning and priority-setting phase, helps to align efforts and maximizes contributions.

As with previous iterations of the HPS, the CAB and the Community Entity (CE) play a key role in ensuring the sustainability of HPS sub-project activities beyond . The CAB and CE should:

  • assess existing community resources available;
  • assess the level of activities such as leadership development, participation of stakeholders in the planning and implementation processes, and the momentum of planning and implementing action;
  • assess existing levels and quality of partnerships within their community; and,
  • target investments to help address gaps in capacity at the community level.

Directive 7: Placement of clients in interim and transitional housing

The purpose of this directive is to clarify the activities that are related to the placement of clients in interim and transitional housing that can be supported under Housing First and Non-Housing First dedicated funding.

Description of Directive 7

The Homelessness Partnering Strategy (HPS) has defined transitional housing as follows:

  • Housing facilities that provide services beyond basic needs and that, while not permanent, generally allow for a longer length of stay than emergency housing facilities (up to three years). These facilities offer more privacy to residents than emergency housing. Transitional housing is targeted to those in need of structure, support, and/or skill-building to move from homelessness to housing stability, and ultimately to prevent a return to homelessness.

The HPS has defined interim housing as follows:

  • Temporary housing facilities that generally allow for a longer length of stay than emergency housing facilities (3-4 months). The purpose of this housing option is to afford Housing First clients a stable place to live while they are looking for permanent housing. Unlike transitional housing, it is not intended to help prepare the client to be ready for self-sufficiency. It is intended to be used in exceptional circumstances, for example, when a community faces very low vacancy rates combined with high rental rates.

Housing First dedicated funding

The HPS Housing First approach focuses on finding sustainable long-term permanent housing solutions for Housing First clients. However, in exceptional circumstances, communities may use interim housing to support their Housing First programs, with the assurance that the person will be placed in permanent housing. For example, during the client assessment phase, the community could place a client in interim housing until a permanent unit is available. In these cases, the Housing First client must only stay in such housing on a temporary basis (maximum of 3-4 months) until they are able to secure permanent housing.

Non Housing First dedicated funding

HPS can support transitional housing outside Housing First where evidence supports its effectiveness (e.g. for youth). Activities eligible for HPS funding related to transitional housing may consist of capital investments or supports delivered through transitional housing facilities.

Individuals who are already placed in transitional housing at the time of the implementation of a Housing First approach are not considered Housing First clients as these clients are considered to be housed. As such, HPS funding toward the clients already housed in transitional housing does not count toward reaching Housing First investment targets. This should not, however, prevent a community from taking a Housing First approach with these clients, using non-Housing First dedicated funding.

As well, once a community has housed 90% of its chronic and episodic homeless population, it may focus the Housing First interventions on the group with the next highest needs, such as individuals currently in transitional housing. The community is responsible for providing an update on its Housing First program and a rationale for selecting the next group of clients in the Annual Community Plan Update.

Eligible activities

Housing First dedicated funding:

  • Access to short-term interim housing for Housing First clients (individuals who are chronically and episodically homeless) until permanent housing is secured (i.e. activities related to identifying interim housing and placement services).

Non-Housing First dedicated funding:

  • Capital investments in transitional housing.
  • Support services to improve the self-sufficiency of individuals living in transitional housing through individualized services.

Ineligible activities

Housing First dedicated funding:

  • Placement of Housing First clients in transitional housing for a medium to long-term period.

Directive 8: Supporting Homeless Veterans

The purpose of this directive is to clarify the activities under Housing First and Non-Housing First dedicated funding related to supporting Veterans who are homeless or at imminent risk of homelessness.

Description of Directive 8

Veterans who are homeless or at imminent risk of homelessness should have access to the full range of supports that is available to them. It will be important for communities to be aware of the benefits and services provided by Veterans Affairs Canada (VAC), to ensure that homeless Veterans are referred to local VAC offices for assessment as appropriate. To that end, Community Advisory Boards (CAB) are encouraged to have representation from or linkages to VAC or Veteran-serving organizations within their membership.

The following outlines a process that involves local VAC offices and HPS community coordination to efficiently identify, refer, and assess homeless and at imminent risk of homelessness Veterans to ensure supports provided by VAC and HPS are complementary and coordinated.

  1. Identification and Referral: Veterans who are chronically or episodically homeless are eligible for supports funded under the HPS Housing First-dedicated funding. If the Veteran is not chronically or episodically homeless, the Veteran may be eligible for supports funded under the non-Housing First dedicated funding. It is important that during the intake into Housing First or other programs and services, including at shelters or through outreach, that clients are asked if they have ever served in the military. Individuals identified as Veterans should then be immediately connected to the nearest VAC Area Office, where they will be linked with a VAC Case Manager.

    The Homeless Individuals and Families Information System (HIFIS) contains a mandatory data field that enables service providers that use HIFIS software to identify clients who have military service, which further supports the referral and linkage to VAC programs and services.

  2. Assessment: For each Veteran, VAC case management determines their eligibility for any VAC benefits and/or services. If the Veteran is eligible, VAC then provides the Veteran with these benefits and services that may include rehabilitation services, financial support, mental health services, health care and career transition services. If not eligible, VAC still provides case management services to the Veteran to identify and access services available locally from the community.

  3. Intervention: Coordination of supports between VAC local offices and community organizations will maximize the impact of interventions for the homeless Veteran. For example, VAC Case Managers should form part of the overall team supporting a homeless Veteran receiving Housing First supports. As well, VAC Case Managers should be part of an Intensive Case Management team (see Treatment Directive). HPS funding can be used to fund services and supports which complement but do not duplicate those offered through VAC case management.

Eligible Activities

Housing First Dedicated Funding:

  • Support services and housing for homeless Veterans with a history of chronic or episodic homelessness.

Non-Housing First Dedicated Funding:

  • Support services to improve the self-sufficiency of homeless Veterans and those at imminent risk of homelessness through individualized services (these services must not overlap or duplicate those provided by VAC).

Ineligible Activities (both for Housing First and non-Housing First dedicated funding)

  • Services that duplicate those delivered by VAC.

Directive 9: Capital Investments

The purpose of this directive is to clarify the activities that are related to capital investments that can be supported under Housing First and Non-Housing First dedicated funding.

Description of Directive 9

Housing First Dedicated Funding

The only capital costs that can be funded and count towards the Housing First investment target include:

  • Furnishing apartments for Housing First clients.
  • Repairing damages in apartments resulting from Housing First clients in private rental market (not social housing).

Non-Housing First Dedicated Funding

Capital investments are intended to preserve or increase the capacity of facilities used to address the needs of people who are homeless or at imminent risk of homelessness. The capital costs that can be funded include:

  • new construction;
  • purchase;
  • renovation of transitional or permanent supportive housing;
  • repurposing facilities (e.g. transitional housing into permanent housing);
  • renovation of emergency shelters; and
  • purchase of furniture, equipment, and/or vehicles.

In recognition of infrastructure needs in rural and remote communities and non-designated communities receiving funding under the Aboriginal Homelessness funding stream, HPS funding may be used to construct or purchase emergency shelters in these communities only.

If a community is going to invest in a capital project, the community and project sponsor must demonstrate they have done the following: linked with the Province or Territory; encouraged leveraging, and ensured sustainability.

  • Linking with the Province or Territory: Efforts should be made to link with provincial, territorial or municipal funding. It is important to provide evidence of the need to purchase, construct, or renovate facilities and that provincial/territorial and municipal partners have been engaged to ensure that the community is best placed to undertake the capital project. This should be demonstrated through the HPS Sustainability Checklist for Applicants of Capital Investment ProjectsFootnote 6. HPS funds can be used to complement other capital investments made by a province, territory or municipality. However, HPS funding must not duplicate or displace funding from other programs (should be used to fill a gap in these instances).
  • Encouraging leveraging: Where possible, communities are encouraged to ensure that HPS is not the sole funder in capital projects. For capital projects consisting of new construction or purchase of facilities, the community is required to record the in-kind and financial contributions of each capital investment sub-project funded under HPS.
  • Ensuring sustainability: Capital projects often represent a significant investment of program funds and provide an asset of enduring value to the community to support their efforts to combat homelessness. Capital projects funded under HPS should lead to new or improved services that will be maintained after project completion. Accordingly, applicants must provide a sustainability plan that demonstrates how the service(s) supported by the capital investment will be maintained once HPS funding has ended. Applicants must identify all relevant funding sources for the operation of the facility and/or new services through their application documents.

In their sustainability plan, organizations must:

  • describe their partnerships;
  • confirm their funding sources for ongoing operations;
  • report if the project will increase the level of services or if they will remain stable; and
  • include a timeline for the completion of their activities.

As part of the application process for a sub-project, capital project applicants must follow the Sustainability Checklist in order to demonstrate that the minimum project sustainability standards have been addressed. Applicants seeking capital funding under the regionally delivered HPS funding streams (Designated Communities; Rural and Remote Homelessness; and Aboriginal Homelessness) are required to complete the checklist as part of any proposal to create or expand a facility which could result in increased annual operational costs. The sustainability checklist can also be used to assess sustainability in capital projects that do not incur increased annual operational costs (e.g. equipment purchase or renovations in a facility where no space, beds or units are added or no service is created or expanded).

Communities are responsible to review the checklist completed by applicants through the solicitation or proposals, as part of the assessment process.

Capital Project Expenses and Monitoring (Applicable to both Housing First and Non-Housing First Dedicated Funding)

As HPS allocations are annual, multi-year projects must be managed (expensed) on a fiscal year basis.

Under certain conditions outlined in Annex C of the Funding Agreement with Canada, capital projects are also subject to monitoring for up to five (5) years after the project end-date to ensure recipients are compliant with the terms of their funding agreement with Employment and Social Development Canada (ESDC).

Service Canada monitors capital investments for emerging issues and may ask for course correction as needed.

Eligible Activities

Housing First Dedicated Funding

  • Furnish housing units for Housing First clients in private market, social or permanent supportive housing (capital costs are limited to furniture, dishes, etc.).
  • Repairs of damages resulting from Housing First clients (only in private rental market housing, and within the period a Housing First client is housed through HPS).

Non-Housing First Dedicated Funding

  • Renovation of emergency shelters, transitional housing, permanent supportive housing, or non-residential facilities, including:
    • Renovating an existing facility for upgrades and to meet building standards.
    • Repurposing an existing property to create transitional housing or permanent supportive housing.
    • Expanding an existing facility.
    • Renovating a property following a transfer under the Surplus Federal Real Property for the Homelessness Initiative (SFRPHI) to create transitional housing and/or permanent supportive housing.
  • New construction of transitional or permanent supportive housing, or non-residential facilities, including:
    • Building a facility.
    • Tearing down an existing facility and building a new one.
    • Service space where the Investments in Affordable Housing Initiative (IAH) is building or renovating to create permanent housing.
  • Purchase of transitional housing, permanent or permanent supportive housing, and non-residential facilities to create new space or units:
    • Eligible costs related, professional fees, such as consultants, audit, technical expertise, facilitation, legal, and construction contractors, and capital costs of the purchase of a land or building.
  • Purchase of furniture, equipment and/or vehicles, including:
    • Eligible costs related to other capital costs (e.g. vehicles, tools, equipment, machinery, computers, and furniture).
    • Purchased vehicles must be used exclusively for HPS service delivery.
    • All capital assets must be managed in accordance with ESDC’s Disposition of Capital Assets policy.
  • Only under the HPS Rural and Remote Homelessness funding stream and non-designated communities receiving funding under the Aboriginal Homelessness funding stream:
    • Capital Investments to build (e.g., pre-development, purchase of land, construction, renovation and purchase of appliances and furniture) new emergency shelter facilities.

Ineligible Activities

Both for Housing First and non-Housing First Dedicated Funding

  • Purchase or construction of new emergency shelters (except under the HPS Rural and Remote Homelessness funding stream and non-designated communities receiving funding under the Aboriginal Homelessness funding stream).
  • Construction and renovation of housing units whose funding is covered by the bilateral Investments in Affordable Housing Initiative (IAH) agreement with the Canada Mortgage and Housing Corporation and most Provinces and Territories.
  • Affordable or social housing, including:
    • Repairs to social housing units.
    • Renovation of affordable or social housing units.
    • Creation of affordable or social housing units.

Directive 10: Basic Needs Services

The purpose of this directive is to clarify the activities related to basic needs services that can be supported by Housing First dedicated and non-Housing First dedicated funding.

Description of Directive 10

Housing First Dedicated Funding

The only eligible activity for funding basic needs services under Housing First is for the initial apartment set up. Investments in ongoing basic needs services are not considered eligible activities for the purpose of implementing Housing First, and they cannot count towards the Housing First investment target. Under the Homelessness Partnering Strategy (HPS), communities are encouraged to partner with relevant sectors to ensure that Housing First clients have access to other support they may require in the subsequent months to be able to live in their units, including, for example, groceries and personal hygiene products.

Non-Housing First Dedicated Funding

Funding for basic needs services should support outcomes that contribute to a reduction in homelessness. For example, short-term food and emergency shelter assistance are eligible activities as a means to assist homeless individuals to obtain placement in more stable housing e.g. transitional, supportive or regular housing. Longer-term food programs can also be funded if they are part of another intervention that is considered an eligible activity (e.g., serving meals during the delivery of other support services that enable clients to participate in social or cultural activities to assist them with community reintegration).

Communities are encouraged to partner with relevant sectors to ensure that homeless clients using shelters or living on the street access basic needs services, such as food, clothing and blankets.

Eligible Activities

Housing First Dedicated Funding

  • Groceries, personal hygiene and other supplies as part of initial apartment set up for Housing First clients.

Non-Housing First Dedicated Funding

Basic needs services include:

  • Access to shower and laundry facilities;
  • Food services related to food banks, soup kitchens, collective/community kitchens;
  • Personal hygiene items;
  • Clothing, footwear and blankets;
  • Storage for belongings;
  • Basic first aid;
  • Access to technology (e.g. phones, computers, etc.) in a community setting (e.g. in a resource or drop-in centre); and
  • Bus or public transit tickets related to job search/interviews, appointments/reconnecting to family for example.

It is important that these support services are connected to broader services/strategies to help clients move towards more stable living arrangements (short, medium or long term) or conditions (i.e. enhanced social integration).

Ineligible Activities

Both for Housing First and Non-Housing First Dedicated Funding

  • Delivery of basic needs services that may serve to maintain homeless people on the street rather than stabilize and improve their living conditions, (e.g. distribute food or hygiene kits without any demonstrated outreach or intervention to improve housing stability or social/economic integration for clients as part of the project activities).

Directive 11: Prevention

The purpose of this directive is to define the population at imminent risk of homelessness and clarify the prevention-related activities that can be supported under Non-Housing First dedicated funding only.

Description of Directive 11

The Homelessness Partnering Strategy (HPS) has defined the populations at imminent risk of homelessness as follows:

  • Populations at imminent risk of homelessness are defined as individuals or families whose current housing situation end in the near future (i.e. within two months) and for whom no subsequent residence has been identified. These individuals are unable to secure permanent housing because they do not have sufficient resources or support networks immediately available to prevent them from moving to an emergency shelter or a public or private place not meant for human habitation. The population at imminent risk of homelessness is not among the groups that are the focus of Housing First under HPS.

HPS funding targeted towards prevention activities must fit the HPS definition of clients who are “at imminent risk of homelessness”. The examples below describe emergency situations where individuals and families are at imminent risk of homelessness and could be eligible for an HPS funded prevention intervention.Footnote 7

  • Individuals or households facing eviction, with a poor rental history and insufficient cash reserves or assets to acquire new housing.
  • Breakdown in family relations, including separation, conflicts between parents (caregivers and children), and/or episodes of violence, where one or more parties have insufficient cash reserves or assets to acquire new housing.
  • Individuals due to be released from institutional care who do not have arrangements made for safe and permanent accommodation upon release. Institutional care includes criminal justice system, medical/mental health institutions, residential treatment programs or child protection. If these individuals have no fixed address and a history of homelessness, they may fall under the definition of chronic and episodic homelessness.

Eligible Activities

Non-Housing First Dedicated Funding

Interventions to support individuals and families at imminent risk of homelessness consist of providing:

  • Housing loss prevention supports to respond to emergency situations (e.g. support when there is an eviction notice i.e. utility deposit, one-time rent arrears assistance, direct tenant landlord intervention, informing tenants of their rights and responsibilities, financial management services that help people retain their housing and reduce debts, support to solve issues related to hoarding).
  • Support services (e.g. counselling supports, housing placement etc.) for individuals whose discharge from the health, child protection or criminal justice system is imminent.

Ineligible Activities

  • Provision or payment for student housing;
  • Supports for low-income individuals or families who do not face an imminent risk of homelessness;
  • Repeated and regular direct funds or income supports to a client in order to maintain housing.

Directive 12: Data Collection, Sharing, and Dissemination

The purpose of this directive is to clarify the activities related to data collection, sharing, and dissemination that can be supported under Housing First and Non-Housing First dedicated funding.

Description of Directive 12

Under the Homelessness Partnering Strategy (HPS), data collection, sharing and dissemination activities enhance the understanding of local homelessness issues and help support decision-making, longer-term planning and outcome measurement to prevent and reduce homelessness.

Communities need to place an enhanced focus on data collection and analysis at the local level. An information management system on homelessness and shelter use will be a critical tool to support communities in implementing successful Housing First programs and in reporting. Data will play an important role in measuring the progress being made by the HPS at both the community and national level.

Collection and Management of Personal Information

Communities must ensure that personal information is managed according to the applicable laws in the jurisdictions where they operate. In particular, Community Entities (CEs), Data Coordinators, and service providers are responsible for ensuring the security of personal information that is collected or compiled in the context of their business as it relates to the delivery of the HPS, and that it is protected against such risks as unauthorized access, collection, use, disclosure or disposal.

HPS Data Collection

The data collected is used to create a national portrait of homelessness and contributes to knowledge around the issue of homelessness (e.g. through the National Shelter Study, and the Shelter Capacity Report). Data will be collected through the following sources:

  • Community Plans;
  • National Homelessness Information System (NHIS) including the Homeless Individual and Families Information System (HIFIS);
  • Results Reporting on-line (RROL).

HPS Expectations

In moving to a Housing First approach, HPS expectations for data collection, sharing, and dissemination are the following:

  • For community planning, communities need access to any data that exists in the community, including shelter, census, housing and project data. The community needs to consider whether everyone involved in the local efforts to address homelessness is collecting the data needed to tell the story of the community and the progress around the goal of reducing homelessness.
  • Communities need to determine the size of their chronic and episodic homeless population on a regular basis, such as year-end, so they can report reductions through HPS-funded activities through Housing First or non-Housing First interventions.
  • Monitoring and accountability are also important. Projects should be seen as investments that need to be carefully monitored to make sure they are achieving their objectives. Projects that are not achieving expected outcomes or providing good results relative to the investments need to be monitored closely and adjusted accordingly.

Expectations on Shelter Data Collection

Shelter data is key to providing most of the information about emergency shelter users, including chronic and episodic shelter users, as well as other users of particular interest, such as VeteransFootnote 8. The following are the expectations specifically for Community Entities (CEs) under the HPS:

  • CEs encourage local shelters and service providers to collect and share data to support decisions based on evidence at the local level. CEs can also mandate sponsors of subprojects to use the Homeless Individuals and Families Information System (HIFIS) and share data with the CEFootnote 9.
  • CEs are involved in local efforts to ensure shelter data is collected and used. Where HIFIS Community Coordinators exist, CEs may want to connect with them to discuss data requirements and develop a plan to access existing resources.

To support the role of the CE regarding shelter data where HIFIS is the data collection system, the following supports are available from HPS:

  • Technical supports and training, including E-learning, the HIFIS website, and instructional documents;
  • HIFIS Support Desk; and
  • HIFIS Community Coordinators, funded through the NHIS funding stream.

Eligible Activities (both for Housing First and Non-Housing First Dedicated Funding)

  • Collection of data to demonstrate accountability, support decision-making, and inform of the homelessness situation;
  • Activities intended to build partnerships for data collection and analysis;
  • Gathering, sharing, and disseminating information with the Community Advisory Board (CAB), CE, and other interested parties about:
    • the size and composition of the homeless and imminently at-risk populations, including how the size and/or composition are changing over time;
    • the progress made in preventing and reducing homelessness;
    • the tracking and monitoring of activities; and
    • the relevant information needed to make better informed decisions.
  • Technical support for data collection, analysis, and management;
  • Purchase of equipment to collect and compile data (e.g., computer, server); and
  • Hire a local Data Coordinator to perform analysis and report development only where there is not already a NHIS-funded Community Coordinator at the local or provincial level performing these duties.).

Ineligible Activities (both for Housing First and Non-Housing First Dedicated Funding)

Regionally-Delivered Funding Streams: Designated Communities, Aboriginal Homelessness, and Rural and Remote Homelessness funding streams

  • Information gathered or refocused primarily for the purpose of advocacy, public education or awareness;
  • Development of shelter data collection systems other than HIFIS;
  • Hiring a consultant to compile data to complete Results Reporting On-line;
  • Local research other than the data collection activities described under “Eligible Activities”; and
  • Developing software and/or the purchase of hardware for the collection and management of homelessness data that constitutes a redundant use of funds and duplicates activities already offered through the HIFIS software. For example: purchasing alternative software that performs similar functions to the HIFIS software.

Directive 13: Persons with Lived Experience (PWLE) of Homelessness

The purpose of this directive is to clarify the activities related to persons with lived experience of homelessness that can be supported under Housing First (HF) and Non-HF dedicated funding.

Description of Directive 13

The Homelessness Partnering Strategy (HPS) has defined the concept of “lived experience” as follows:

  • “Lived experience” refers to the level of expertise of an individual in a given area – be it homelessness, mental health, addictions, or another field – due to their own personal understanding having lived the condition. It is also associated with recovery, which implies the person with lived experience is developing greater self-sufficiency in their pursuit of personal goals and functional capacity, despite ongoing symptoms.

HPS encourages communities to include persons with lived experience (PWLEs) in the Community Advisory Board (CAB). Including PWLEs in the local approach to reducing and preventing homelessness can bring the following benefits to the community:

  • Leadership: PWLEs can offer a unique perspective on local solutions to homelessness in the community, as they have experienced first-hand what works. Their voices are traditionally missing from planning, program and policy development. When included in the decision-making process, PWLEs can serve as a voice reminding and explaining the impact that systems, services, programs and policies have on them. Consequently, the participation of PWLEs ensures that the community infrastructure is accountable to people experiencing homelessness. An effective way to include PWLEs in the decision-making process is through the establishment of a volunteer advisory group which can be instrumental in providing feedback, forming recommendations and/or developing solutions related to homelessness and poverty in the community.
  • Empowerment and Peer Support: Those who experience homelessness can often feel powerless and or feel that they are not taken seriously by those in society who hold power. The formation of advisory groups can provide a starting point for turning those dynamics around and empowering people affected. PWLEs are a valuable asset in service programs and delivery, in that they are able to provide a unique skill set: peer support. PWLEs are able to offer support to clients from an equal “playing field” because of the common mutual lived experience that both the peer and the client share. As suggested above, forming advisory groups of PWLEs can be beneficial to informing decision-making; however, it can also provide strength to a cause – providing a forum for peers to interact, reducing their isolation and supporting both the peer and the mentee’s personal growth and leadership skills.
  • Social inclusion: PWLEs are often stigmatized, seen as more susceptible to addictions, mental health issues, sickness and not understanding social norms or professional boundaries. As a result, PWLEs are marginalized when in fact they can offer valuable strengths and assets in service delivery and policy making. Being involved in peer groups and solicited for their personal experience allows PWLEs to connect with others in their community, and help them to build social relationships thereby promoting their own societal integration.

Eligible Activities

Housing First Dedicated Funding

  • Wages for a PWLE to be a peer support worker.

Non-Housing First Dedicated Funding

  • Activities to ensure the participation of a PWLE in the CAB or Regional Advisory Board (RAB), which may include:
    • Involving a PWLE in consultation, coordination, planning & assessment
    • Ensuring the participation of a PWLE in partnership & network development in support of implementing the HF approach, service integration and improvement
    • Reimbursing participation costs of a PWLE (i.e. transportation costs to CAB or community meetings)

Ineligible Activities

Within and Outside Housing First

  • Paying salary to a PWLE for their participation in the CAB/RAB

Directive 14: Education, Training, and Employment Services

The purpose of this directive is to clarify the activities related to education, training, and employment services that can be supported under Housing First (HF) and Non-HF dedicated funding.

Description of Directive 14

Funding of educational, training and employment services under the HPS requires caution, as many of these services fall under provincial or territorial responsibility. HPS funding must not be used to duplicate existing provincial or territorial education and labour market training programs. Communities and sponsors are encouraged to partner with training institutions and other organizations that deliver training.

HPS activities may be used to provide additional supports to homeless and at-imminent- risk individuals to bridge individuals to existing labour market programs and/or provide them with supports to complement existing labour market programs (e.g., life skills or pre-employment services).

Eligible Activities

For both Housing First and non-Housing First Dedicated Funding

Only the portion of the education, training or pre-employment services used for HF clients counts toward the HF investment target.

  • Education and Training services, including:
    • Life skills (e.g., job interview training, anger management, sessions on healthy relationships, parenting skills development, effective communication, budgeting, healthy eating)
    • Activities aiming at increasing the essential skills of Housing First clients, homeless individuals or those at risk of homelessness to facilitate their labour market readiness (e.g. volunteer activities that would help people to better communicate or work with others, or a computer training session offered by a homeless-serving organization). Essential skills include: reading, document use, numeracy, writing, oral communication, working with others, thinking, computer use and continuous learning.
  • Employment services, including:
    • Pre-employment services or employment development specialists that bridge Housing First clients, homeless individuals or those at imminent risk of homelessness to existing employment programs or remove barriers to employment or skill enrichment to facilitate labour market readiness (e.g. life skills sessions that will lead to greater self-sufficiency and facilitate placement, support services, and post-program support activities).
    • Helping Housing First clients, homeless individuals or those at imminent risk of homelessness to take advantage of labour market placement opportunities by providing relevant support; for example, wrap-around services, stable housing, life skills sessions, job readiness and maintenance coaching.

Ineligible Activities

For both Housing First and Non-Housing First Dedicated Funding

  • Employment activities that are normally delivered by other federal, provincial or territorial labour market programs
  • Job wages for Housing First clients, homeless individuals or those at risk of homelessness for participating in an education, training, or pre-employment program
  • Salary for a full-time teacher to provide an alternative to provincial or territorial education
  • Tuition
  • Workplace skills development
  • Apprenticeship grants
  • Child care, bus passes, clothing or equipment in support of a training or educational program

Directive 15: Advocacy, Public Education, and Awareness

The purpose of this directive is to clarify the eligibility of activities related to advocacy, public education, and awareness

Description of Directive 15

This Directive provides clarification on two activities that are ineligible for Homelessness Partnering Strategy (HPS) funding: (1) advocacy, and (2) public education and awareness.

The HPS has defined these activities as follows:

  • Advocacy involves attempts to influence political decisions. Advocacy tools strongly recommend that action be taken and may even recommend a course of action. These activities cannot be funded using HPS funding.
  • Public education and awareness activities are directed towards educating the public on the importance of addressing homelessness issues and aim to mobilize public opinion. As with tools created to support advocacy efforts, public awareness tools do not simply inform the public of the current situation, but seek to influence the public to promote change. Public education and awareness activities are not eligible for funding under HPS.

Eligible Activities

For both Housing First and Non-Housing First Dedicated Funding

It is not always clear which activities may eventually be used for advocacy, public education and/or awareness, so special consideration must be given to identify the intent and purpose of the activity. Activities that directly support HPS purposes, including community planning, decision-making, and/or setting funding priorities as described below would be deemed eligible:

Activities relating to the improvement, collection and use of data, such as:

  • collecting and sharing information on what the community itself has done or is currently doing to support homeless and imminently at-risk individuals; or
  • informing the public and soliciting feedback on activities, past or future, intended to prevent and reduce homelessness

Ineligible Activities

For both Housing First and Non-Housing First Dedicated Funding

However, if the intent is to increase public awareness of homeless issues more generally, it would be considered ineligible for funding under the HPS. Ineligible activities include:

  • Gathering or refocussing information primarily for the purpose of advocacy, public education or awareness
  • Creating or distributing tools for advocacy or public awareness purposes
  • Advocacy activities including, public education, awareness sessions, and workshops

Directive 16 - Official Language Minority Communities

The Government of Canada has a responsibility under the Official Languages Act to ensure that programs and services meet the needs of Official Language Minority Communities (OLMCs)Footnote 10. The purpose of this directive is to clarify the expectations and responsibilities for Community Advisory Boards (CAB)Footnote 11 and Community Entities (CE) related to OLMCs.

In developing a coordinated and integrated homeless-serving system, CABs and CEs are expected to identify OLMCs within their community and ensure that appropriate services and supports are available in both official languages where there is significant demand. The OLMCs should be considered in the development and implementation of the Community Plan to ensure the needs of these populations are assessed and that appropriate measures are put in place to address those needs.

The role of the CABs and CEs includes the following steps:

  • Identify the OLMC in the community within the homeless population targeted by the HPS (supported by data, where available).
  • Engage the OLMC to ensure they are involved in the planning and implementation of the community’s overall approach to homelessness.
  • Assess the specific needs of the OLMC to determine the nature of homelessness services required to address those needs.

When an OLMC is identified and the assessment indicates additional and specific needs for that group, the community (CAB and CE) must have a plan in place to ensure these needs are appropriately addressed. The following principles will guide the development of a plan to address the OLMC needs and ensure a minimum of substantive equality:

  • Formal Equality: is achieved when members of the official language minority community and those of the majority community are treated the same way by providing identical services in English and French.
  • Substantive Equality: is achieved by taking into consideration the specific needs of the minority community by providing activities or services with different content or using a different delivery method to ensure that the minority receives services of the same quality as the majority.

In accordance with the CE funding agreement, the CE is responsible for the following activities related to support for official languages (Schedule C, section 6, 6.1):

  • 6.1 The Recipient shall:
    1. make Project-related documentation and announcements available (for the public and prospective Project participants, if any) in both official languages;
    2. actively offer Project-related services in both official languages;
    3. encourage members of both official language communities to participate in the Project; and
    4. provide its services, where appropriate, in such a manner as to address the needs of both official language communities.

Note: The CE (i.e. the Recipient) must ensure these criteria are considered in the planning and selection of sub-projects where OLMCs have been identified.

Communities must have a plan in place to ensure that the mix of sub-projects they fund enables the community to provide service to the OLMC that is of substantively equal quality to the service provided to the majority Official Language (OL) population.

The CEs should be able to demonstrate how the needs of both OL communities were considered in the development of the Community Plan (or annual Community Plan update) and the assessment and selection of projects funded under the HPS.

In the event where the CEs initial plan to meet the OLMC requirements is not achieved, the CE must have an alternate plan to demonstrate how the needs of the OLMC will be met.

This can be accomplished in a variety of ways, for example:

  • in advance of a solicitation of proposals process, the CAB/CE can decide how the OLMC needs will be incorporated into the project selection and/or assessment of proposals process;
  • through a partnership agreement between/amongst organizations; and
  • through coordination of existing project-related services in the community that are already well-established and readily accessible.

The CAB and CE are encouraged to work with local Service Canada representatives in the application of this directive.