Exchanging a TLS Rental Subsidy for a Federal TBV

Integration of TLS into ICMS
- LA HSA’s Time-Limited Subsidy (TLS) program will be fully integrated into ICMS effective July 1, 2026.
- ICMS Providers will be expected to support participants receiving TLS as part of standard ICMS service delivery.
- In April and May 2026, HSH and Brilliant Corners will begin transitioning TLS rental assistance schedules into the TLS Financial Expense Portal and providing training to ICMS Providers on how to use this system.
- Providers using HOM for TLS payments are expected to continue doing so, even after TLS has been integrated into HSH.
TLS rental assistance is temporary. Federal TBVs are long-term.
ICMS participants with a TLS rental subsidy who are matched to federal TBV are already permanently housed. Homelessness ended when they moved into their unit. However, in order to maintain ongoing rental payment assistance and ensure housing stability, they must complete the rental subsidy exchange to the federal TBV before the TLS assistance ends.
A rental subsidy exchange swaps who provides the rental payment assistance—not whether the participant is housed.
Understanding the Distinction Between Two Key Dates
MOVE-IN DATE
Participant enters unit with TLS
Homelessness ends
↓ TBV match occurs and time passes while exchange is processed
TBV UTILIZATION DATE
Rental payment with TBV begins
Rental payment with TLS stops
The Move-In Date remains the same during a rental subsidy exchange. The TBV Utilization Date can occur weeks or months after move-in, but the participant has been housed the entire time.
Key Terms
Permanent Housing
- Housing without a time limit on occupancy (lease/rental agreement)
- Participant can remain housed as long as lease terms are met
- Someone can be permanently housed even if they don’t have a permanent rental subsidy (e.g., TLS)
Time-Limited Subsidy (TLS)
- Temporary rental payment assistance for participants to obtain permanent housing rapidly
- Designed as a bridge to permanent rental subsidy in permanent housing
- TLS ends, regardless of ongoing rental support needs
Federal Tenant-Based Voucher (TBV)
- Ongoing rental assistance (e.g., HCV)
- Administered by a PHA or CoC
- Intended to support long-term housing stability and affordability
Time is of the Essence
- TLS funding ends on a fixed timeline
- TBVs have strict utilization deadlines
- Delays risk housing loss
What can go wrong:
- Loss of unit
- Restarting housing search
- Gaps in rental payment
- Increased system churn
Lease-in-Place: The Preferred Path for Rental Subsidy Exchanges
Help the participant keep their current unit. Only the rental subsidy changes.
Why It’s Preferred:
- Faster
- Less risky
- Preserves stability
Risks of Searching for New Housing:
- Voucher expiration
- Market rent increases
- Losing housing entirely
Future relocation still possible later—leasing in place doesn’t lock a participant in to their unit forever
Application Pathways
UHA (Universal Housing Application) vs. Paper Applications
- Most TBV matches require UHA; some require paper applications
- Always verify the required application pathway at match confirmation
- Track UHA progress carefully in UHA Log of ICMS Snapshot
Sequence and Milestones: From TBV Match to TBV Utilization
- TBV MATCH CONFIRMED
Verify PHA & application type (UHA vs. paper) - TBV APPLICATION SUBMITTED
Track in UHA Log/ICMS Snapshot - TBV ISSUED BY PHA
Begin lease-in-place process immediately - PHA APPROVAL TO UTILIZE TBV
Confirm effective dates - RENTAL SUBSIDY EXCHANGE COMPLETE
TLS stops, TBV Utilization starts
The 9 Case Manager Action Steps
Language formatted for direct Care Plan entry in CHAMP
01 | Create Care Plan SMART Goal
Establish clear goal with participant at the start
- Explain why exchange is time-sensitive and critical to maintaining housing
- Develop SMART Goal with participant for TLS-to-TBV exchange
- Set target date: TLS end date minus 14-day buffer
- Add Action Steps to help track Goal progress
Note: Starting with a clear goal ensures participant understands the timeline and their role in the process.
Example SMART Goal: “Participant will complete all steps to exchange TLS for federal TBV prior to TLS end date of [DATE] to maintain current housing and prevent subsidy gap.”
02 | Verify TBV Match Details
Confirm PHA and application pathway before starting
- Identify PHA assignment and confirm jurisdiction
- Determine application type: UHA or paper required?
- Confirm housing resource partner contact information
Note: Always verify the application pathway at the start—using the wrong process causes delays.
03 | Ensure TBV App Submitted
Complete and submit required TBV application
- Complete UHA or paper application with participant
- Gather all required supporting documentation
- Submit to PHA and obtain confirmation of receipt
04 | Initiate Lease-in-Place
Request to keep participant in current unit (PREFERRED)
- Contact PHA to request lease-in-place processing
- First ensure landlord will accept TBV for rental payment
- Provide current lease agreement and landlord contact
Note: Lease-in-place is faster and less risky. Emphasize this option to participants early.
05 | Monitor TBV Issuance
Track progress using ICMS Snapshot
- Check UHA Log within ICMS Snapshot regularly
- Follow up if no status update within 10 business days
- Escalate delays to supervisor/housing resource partner
Note: Set a calendar reminder to check status weekly—don’t wait for updates to come to you.
06 | Coordinate PHA Inspection
Ensure unit meets Housing Quality Standards (HQS)
- Schedule PHA unit inspection with landlord and participant
- If deficiencies identified, coordinate repairs with landlord
- Confirm re-inspection if needed
07 | Confirm TBV Utilization Date
Verify timing aligns with TLS end date
- Obtain written confirmation of utilization date from PHA
- Compare TBV utilization date with TLS end date
- If gap exists: Request TLS extension immediately (14+ days before end date)
Note: A gap in rent coverage = risk of eviction. Act early if dates don’t align.
08 | Finalize Subsidy Exchange
Complete transition from TLS to TBV rental payments
- Confirm TLS final payment date with TLS administrator
- Confirm PHA first payment date and amount
- Verify no gap in rent coverage exists
09 | Update Care Plan
Mark Goal as achieved or adjust timeline as needed
- In CHAMP, update Goal status to “Closed” and outcome “Achieved” if exchange successful
- If extension granted, revise Goal target date, add relevant Action Steps, and continue monitoring
Contingency Options
If TLS Extension Needed
When: TBV issued but utilization delayed due to administrative barriers
Action: Submit TLS extension request with supporting documentation at least 14 days before TLS expiration
Important: Extensions are NOT guaranteed—document all delays and submit request early.
If Participant Requests Relocation with TBV
When: Participant declines lease-in-place and wants new unit
Action:
- Assess if relocation is necessary (safety) vs. preference
- Counsel on risks: TLS and TBV expiration, delays, market conditions
- Obtain signed acknowledgment of risks
- Attempt lease-in-place first—relocation is HIGHER RISK
Important: Most relocations can wait until after the rental subsidy exchange is complete and housing is stabilized.
Tools & Applications
ICMS Snapshot – UHA Log
Track voucher utilization progress (internal access)
Create a LAHSA Account
Required to submit UHA applications
Guides & Documentation
UHA Fact Sheet
Key facts about submitting the UHA
UHA User Guide for Case Managers
Step-by-step application instructions
HACLA Background Check Sample
Sample of documentation used
UHA Tutorial Video
Visual walkthrough of the application process
Training
UHA Trainings
Learn how to complete, submit, and manage UHA applications