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Level Two: Counseling. (Action Plan Implementation) To qualify for a Level Two payment <br />$300.00 Contractor will be required to complete the following steps: <br />L Authorization. If not already on file, Contractor must collect a signed authorization form <br />from the client or have other legally -permissible client authorization on record that will <br />allow the Contractor to (a) submit client -level information to the DCS for this grant, (b) <br />allow IHCDA and NFMC to open files to be reviewed for program monitoring and <br />compliance purposes, and (c) allow IHCDA and NFMC to conduct follow-up with client <br />related to program evaluation. Clients may opt -out of (c) above only, but proof of this opt - <br />out must be retained in the client's file. Clients that opt out of (a) or (b) above cannot be <br />uploaded into the DCS. Files uploaded in to the DCS without a signed authorization can <br />create a legal liability, therefore the Contractor must ensure client files submitted to the DCS <br />have a signed authorization form in the client file. Contractor is responsible for performing <br />counseling within the limits of the laws in the State of Indiana. <br />2. Disclosure. Contractor must provide to all clients a disclosure statement. The disclosure <br />statement must explicitly describe the various types of services the Contractor provides and <br />any financial relationships between the Contractor and any other industry partners. The <br />disclosure must state clearly that the client is not obligated to receive any other services <br />offered by the Contractor or its exclusive partners. This must be presented to the client at <br />the time of counseling. Proof that the client received the disclosure must be maintained in <br />the file. Such proof can include. a statement signed by the homeowner or an electronic <br />signature, if applicable. <br />3. Privac Polic .z Contractor must provide �o all clients a copy of its privacy policy. Proof <br />that the client received the policy must be maintained in the file. Such proof can include a <br />statement signed by the homeowner or an electronic signature, if applicable. Although it is a <br />best practice to provide the client with the privacy policy at the time of counseling, the <br />Contractor may elect to share the privacy policy after the counseling occurs. If that is the <br />case, Contractor must keep on file proof that the policy was sent to the homeowner via e- <br />mail, fax, or postal snail. Having access to the privacy policy on Contractor's website does <br />not satisfy this requirement unless there is affirmative confirmation and documented roof <br />that the client has reviewed the policy in the file. Clients that choose toot -out and not <br />share their information with affiliated third -parties cannot be u loaded into the DCS for <br />payment. <br />4. Budget Verification. Contractor must engage in budget verification during which s/he <br />reviews documented evidence provided by the client to establish true debt obligations (e.g., <br />credit report), monthly expenses (e.g., monthly bills, bank statements, mortgage statement, <br />credit card statement, utility bill) and spending patters, and realistic opportunities for <br />income (e.g., tax returns, pay stubs, profit and loss statement, third party verification). Note: <br />a credit report alone does not satisfy the budget verification requirement. Contractor should <br />collect verification of all income, expenses, and debt as stated by the client (must be within' <br />z It is acceptable for Contractor to combine the Authorization Form, Disclosure Statement, and Privacy Policy into a <br />single document which the client signs and the Contractor maintains in the client file. <br />(00028595-1) <br />Page 26 of 39 <br />