Topic Question
Permanent Supportive Housing

If a CoC's coordinated entry (CE) system is not yet fully operational for permanent supportive housing (PSH), how does a PSH project that is not yet able to participate in a CE system follow the order of priority established in the Prioritization Notice?

Prioritization is the most effective when performed through a coordinated entry process. HUD recognizes that in many communities the coordinated entry system is still being developed and might not currently be in place for every housing type. In the meantime, recipients of CoC Program-funded PSH may still prioritize following the order of priority established in the Prioritization Notice by selecting persons from their project’s wait list in a ...
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Permanent Supportive Housing

How should communities that want to prioritize persons in accordance with the orders of priority established in the Prioritization Notice reconcile the Notice with their own assessment and ranking systems?

For this question, consider an example where some communities’ assessment tools assign a score to each person when they are assessed and in some cases, a person with a high assessment score would not be considered the highest priority based on the Prioritization notice. Appendix A of the Prioritization Notice provides guidance on what HUD considers to be qualities of a good assessment tool and encourages CoCs to select a tool that will work in ...
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Permanent Supportive Housing

For many persons experiencing chronic homelessness, obtaining required third-party documentation can take a long period of time. Are recipients of PSH required to have all third-party documentation at the point of intake and enrollment of a program participant into a project?

The recordkeeping requirements included in the Final Rule on Defining “Chronically Homeless” are meant to ensure that, when applicable, permanent supportive housing (PSH) that is dedicated to serving persons experiencing chronic homelessness is being used to serve persons that meet the definition. It was never HUD’s intention that these requirements act as a barrier to housing those most in need of PSH as quickly as possible. In fact, ...
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Permanent Supportive Housing

For DedicatedPLUS projects, are there any particular requirements for how recipients must prioritize households for assistance, including in the event that there are no households meeting the eligibility requirements outlined in the NOFA?

Prioritizing Eligible Households HUD included the option of DedicatedPLUS in the FY 2017 CoC Program NOFA to provide CoCs with more flexibility to serve vulnerable populations and to more effectively and more immediately address the needs of persons experiencing chronic homelessness, at risk of experiencing chronic homelessness, or who were chronically homeless prior to being housed and who have recently become homeless again. In general, househ...
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Permanent Supportive Housing

What are the data collection and reporting requirements for a program participant that is enrolled in a PSH project, but is residing in a transitional housing project until a unit can be found?

Example: A chronically homeless person has been accepted into a permanent supportive housing program and has begun working with the recipient to identify a permanent supportive housing unit. The program participant is currently living on the streets and has no friends or family to stay with temporarily while an appropriate unit is located and secured. The permanent housing recipient is able to make arrangements with a transitional housing recipie...
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Permanent Supportive Housing

Are records contained in HMIS or a comparable database used by victim services or legal services providers acceptable evidence of third-party documentation?

Yes - Records contained in a Homeless Management Information System (HMIS) or comparable database used by victim service or legal service providers are acceptable evidence of third-party documentation and intake worker observations if the HMIS retains an auditable history of all entries, including the person who entered the data, the date of entry, and the change made; and if the HMIS prevents overrides or changes of the dates entries are made.

Permanent Supportive Housing
Permanent Supportive Housing

What is the order of priority for CoC Program-funded PSH beds that are not dedicated or prioritized?

HUD encourages CoCs and recipients of non-dedicated and non-prioritized CoC Program-funded PSH to offer housing to persons experiencing chronic homelessness first, to the maximum extent possible. For all other CoC Program-funded PSH, where the CoC adopts the orders of priority established in the Prioritization Notice and incorporates them into their written standards, households should be selected in the following order: Order of Priority 1 - A h...
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Permanent Supportive Housing

Are there any circumstances when a program participant’s diagnosis can be documented via self-report?

No - The recipient must maintain evidence of a diagnosis with one or more of the following conditions: substance use disorder, serious mental illness, developmental disability (as defined in Section 102 of the Developmental Disabilities Assistance Bill of Rights Act of 2000 (42 U.S.C. 15002), post-traumatic stress disorder, cognitive impairments resulting from brain injury, or chronic physical illness or disability. The condition must be doc...
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Permanent Supportive Housing

When documenting a program participant’s chronically homeless status, under what circumstances is it acceptable for the length of time homeless to be documented based solely on a program participants self-report?

The Prioritization Notice provides guidance on how recipients of CoC Program-funded PSH are now required to document a household’s status as chronically homeless for dedicated and prioritized beds, including the order of priority for obtaining evidence. In general, recipients must seek documentation in the following order: (1) third-party documentation, (2) intake worker observations, and (3) certification from the person seeking assistance, se...
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Permanent Supportive Housing

If a project receives funding through the CoC Program and another federal program that requires that all participants have a serious mental illness to be eligible for services, how would the CoC prioritize under this circumstance?

HUD is encouraging recipients of CoC Program-funded PSH to follow the order of priority outlined in the Prioritization Notice, as adopted by the CoC, while also considering the goals and any identified target populations served by the project. CoC Program-funded PSH that is targeted to specific subpopulations should follow the order of priority under Sections III.A. or III.B. of the Prioritization Notice to the extent persons within that subpopul...
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Permanent Supportive Housing

Many assessment tools gauge vulnerability or level of service needs by assessing for certain types of disabilities. Is this compliant with fair housing laws?

Protections should be in place to ensure compliance with all civil rights requirements, including, but not limited to, the Fair Housing Act, Title VI of the Civil Rights Act of 1964, and Section 504 of the Rehabilitation Act of 1973. To be compliant with fair housing laws: The assessment tool must not seek disability-related information unless it is necessary for determining the need for housing-related services.   The coordinated entry pro...
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Permanent Supportive Housing

What are examples of data-driven methods to identify whether or not a household has severe service needs?

The Prioritization Notice states that a household is considered to have severe service needs if they have a history of high utilization of crisis services and/or have significant health or behavioral health challenges or functional impairments which require a significant level of support in order to maintain housing. The Prioritization Notice goes on to say that severe service needs should be verified through data-driven methods or through the us...
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Permanent Supportive Housing

Our CoC wants to adopt the orders of priority established in the Prioritization Notice but has CoC Program-funded PSH projects with existing waiting lists. In such cases, how do CoCs create a single prioritized list, as encouraged by HUD in the Prioritization Notice?

HUD encourages CoCs to incorporate into their operating policies and procedures (which are included in the CoC’s governance charter) a requirement that all CoC-funded PSH only accept referrals through a single prioritized list that is created through the CoC’s coordinated entry process. This will allow recipients of CoC Program-funded PSH to maintain their own project-level waiting lists, if necessary, provided that all households are referre...
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Permanent Supportive Housing

How are these commitments made by CoCs in the FY 2013/FY 2014 CoC Application related to information entered in the project application and how will HUD monitor those commitments?

CoCs can expect to report on progress made on goals set and commitments made in the FY 2013/FY 2014 CoC Application in the FY 2015 CoC Application. HUD cannot comment on how that information will be requested or the extent it will contribute to the CoCs overall score. In addition, where project applicants for PSH have indicated some or all of their non-dedicated PSH beds will be prioritized for use by the chronically homeless, the proje...
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Permanent Supportive Housing

Are recipients of dedicated or prioritized PSH funded under the CoC Program required to hold beds vacant indefinitely while trying to identify persons that meet the highest priority?

No - HUD does not expect recipients of dedicated or prioritized CoC Program-funded PSH to hold vacant beds open indefinitely while waiting to locate chronically homeless persons with the longest histories of homelessness and most severe service needs. Recipients are only expected to exercise due diligence and should document the efforts they have undertaken to locate persons that would be considered the highest priority. HUD does not have a speci...
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Permanent Supportive Housing

Does HUD expect CoCs and recipients of CoC Program-funded PSH to also prioritize veterans?

In addition to ending chronic homelessness, Opening Doors also seeks to end homelessness among veterans by the end of this year. HUD is strongly encouraging CoCs to work and coordinate with local Veterans Affairs (VA) Medical Centers on the HUD-Veterans Affairs Supportive Housing (HUD-VASH) program, to the extent that the program is available in a geographic area, to coordinate efforts related to ending veteran’s homelessness. In particular, Co...
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Permanent Supportive Housing

What is the order of priority for CoC Program-funded PSH beds that are either dedicated or prioritized for the chronically homeless?

Where the CoC has adopted the orders of priority described in the Prioritization Notice, recipients of either dedicated or prioritized CoC Program-funded PSH must select persons for permanent supportive housing in the following order: Order of Priority 1 - A household should be prioritized first in dedicated or prioritized PSH if all of the following are true: Individual or head of household meets the definition of chronically homeless per ...
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Permanent Supportive Housing

Does HUD expect all PSH funded through the CoC Program to prioritize the chronically homeless?

At this time, only 30 percent of all CoC Program-funded PSH is dedicated to the chronically homeless. In order to meet the Administration’s goal of ending chronic homelessness, recipients must significantly increase the number of PSH units targeted to persons with the highest needs and greatest barriers towards obtaining and maintaining housing on their own. HUD expects recipients of PSH to serve people with the longest histories of homelessnes...
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Permanent Supportive Housing

Are recipients of Permanent Supportive Housing (PSH) funded under the CoC Program required to follow the orders of priority provided in the Prioritization Notice?

No - However, HUD strongly encourages CoCs to incorporate the orders of priority described in the Prioritization Notice into their written standards. By doing so, CoCs may then require all CoC Program-funded PSH recipients to comply and follow these orders of priority. Although not required, HUD would only consider a CoC as following the orders of priority provided in the Prioritization Notice when orders of priority are incorporated exactly...
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Permanent Supportive Housing

What is the difference between a “dedicated” permanent supportive housing (PSH) bed and a “prioritized” PSH bed?What is an example of each?

A CoC Program-funded PSH project with beds that are specifically targeted to persons experiencing chronic homelessness are considered to be either dedicated or prioritized. Section II of the Prioritization Notice provides guidance on what each of these classifications mean and how they are different. Here is a further breakdown of each: Dedicated PSH - A PSH bed is considered to be “dedicated” when the project recipient has committed to ...
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Permanent Supportive Housing

Can a child with a disability qualify a household as chronically homeless?

Under the definition of chronically homeless, the head of household (either an adult or a minor if there is no adult present) must have the qualifying disability and meet all of the other criteria (i.e., length of time homeless) in order for a family to be considered chronically homeless. Where there is no adult member of the family, then a minor can be identified as the head of household and that individual is who must meet the criteria. Note: w...
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Rental Assistance

May a public housing agency (PHA) provide CoC Program rental assistance funds on behalf of a program participant residing in a unit that the PHA owns?

Yes, a recipient/subrecipient who is a public housing agency (PHA) may provide rental assistance on behalf of program participants who are residing in PHA-owned units. However, the rent reasonableness determinations and housing quality inspections must be conducted by an entity that is not the PHA. It must also be established that the PHA-owned units assisted with rental assistance are not also being assisted with any other duplicative federal, S...
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Rental Assistance

May CoC Program funds for rental assistance be used to pay rent for units above the FMR?

Yes, if a program participant leases a unit where the rent charged exceeds the FMR, the recipient/subrecipient may use rental assistance funds for that unit for an amount above FMR. However, the contract rent charged must be determined to be reasonable in relation to rents being charged for comparable unassisted units in the area. HUD will only provide rental assistance on behalf of a program participant for a unit if the rent for that unit is reasonable.

Rental Assistance
Rental Assistance

May CoC Program funds for rental assistance be used to pay the security deposit for a unit?

Yes, recipients/subrecipients may use rental assistance funds to pay the security deposit for a unit. The amount of grant funds used to pay the security deposit must not exceed 2 months of rent. In addition to a security deposit, recipients/subrecipients may make an advance payment for first and/or last month's rent.

Rental Assistance
Rental Assistance

May CoC Program funds for rental assistance be used to pay for property damage?

Yes, recipients/subrecipients may use rental assistance funds to pay for any damage to housing due to the action of a program participant. The amount paid must not exceed 1-month’s rent and is a one-time cost per program participant, paid upon the program participant’s exit from the unit.

Rental Assistance
Rental Assistance

For CoC Program projects that provide rental assistance, are program participants required to pay rent?

When rental assistance is provided as part of a transitional or permanent supportive housing project, program participants receiving rental assistance are required to pay rent. Recipients/subrecipients must follow the requirements in 24 CFR 578.77(c) when calculating a program participant’s rent, which states that each program participant must pay the highest of the following amounts:   (A) 30 percent family's monthly adjusted income; &nbs...
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Rental Assistance

What is long-term rental assistance?

Long-term rental assistance is rental assistance that is provided for an indefinite period of time. It is only eligible under the Permanent Housing: Permanent Supportive Housing program component of the CoC Program. Long-term rental assistance may be tenant-based, project-based, or sponsor-based.

Rental Assistance
Rental Assistance

What is medium-term rental assistance?

Medium-term rental assistance is rental assistance that is provided for 4 to 24 months and is eligible under the following CoC Program components: Permanent Housing: Rapid Rehousing, Homelessness Prevention, and Transitional Housing. Depending on the program component under which medium-term rental assistance is being provided, it could be tenant-based, project-based, or sponsor-based.

Rental Assistance
Rental Assistance

What is short-term rental assistance?

Short-term rental assistance is rental assistance that is provided for 3 months or less and is eligible under the following CoC Program components: Permanent Housing: Rapid Rehousing, Homelessness Prevention, and Transitional Housing. Depending on the program component under which short-term rental assistance is provided, it may be tenant-based, project-based, or sponsor-based.  

Rental Assistance
Rental Assistance

What are the characteristics of sponsor-based rental assistance?

In sponsor-based rental assistance, program participants must reside in housing owned or leased by a sponsor organization and arranged through a contract between the recipient/subrecipient and the sponsor organization. A sponsor may be a private, nonprofit organization, or a community mental health agency established as a public nonprofit organization. 

Rental Assistance
Rental Assistance

What are the characteristics of project-based rental assistance?

In project-based rental assistance, program participants must reside in housing provided through a contract with the owner of an existing structure whereby the owner agrees to lease subsidized units to program participants. Program participants do not retain the rental assistance if they relocate to a unit outside the project; the subsidy remains with the project.

Rental Assistance
Rental Assistance

What are the characteristics of tenant-based rental assistance?

In tenant-based rental assistance (TBRA), program participants are responsible for locating housing in the private rental market. If a program participant later moves to another unit, he/she can take the rental assistance and use it in the new unit. Although TBRA program participants may move and retain the rental assistance, recipients/subrecipients administering TBRA may limit where participants may reside if it is necessary to facilitate the c...
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Rental Assistance

I am a recipient of funds for transitional housing under the CoC Program. What effect does the language in the Consolidated Appropriations Act of 2014 that authorizes nonprofit organizations to administer rental assistance in permanent housing have on my project?

The Consolidated Appropriations Act of 2014 (Public Law 113-76, approved January 17, 2014) authorized nonprofit organizations to administer rental assistance only for permanent housing under the CoC Program. This means, as a recipient of funds for transitional housing, you may only use a State, local government, of Public Housing Authority (PHA) to administer rental assistance under your transitional housing project. This is because 24 CFR 5...
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Rental Assistance

I am a recipient of funds for leasing under the CoC Program. What effect does the language in the Consolidated Appropriations Act of 2014 that authorizes nonprofit organizations to administer rental assistance in permanent housing have on my project?

The Consolidated Appropriations Act of 2014 (Public Law 113-76, approved January 17, 2014) authorized nonprofit organizations to administer rental assistance in permanent housing funded with fiscal year (FY) 2012, FY 2013, or FY 2014 CoC Program funds. This means, as a recipient of funds for leasing for a permanent housing project, your existing grant is not affected by this language. However, 24 CFR 578.105 states that recipients may make certai...
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Rental Assistance

I am a recipient of funds for rental assistance under the CoC Program. What effect does the language in the Consolidated Appropriations Act of 2014, which authorizes nonprofit organizations to administer permanent housing rental assistance, have on my project?

The Consolidated Appropriations Act of 2014 (Public Law 113-76, approved January 17, 2014) authorized nonprofit organizations to administer rental assistance in permanent housing under the CoC Program. This means, as a recipient of funds for rental assistance for a permanent housing project, you have the option of contracting with a State, local government, Public Housing Authority (PHA), or nonprofit organization to administer the rental assista...
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Rental Assistance

Can PHAs administer rental assistance?

PHAs may administer rental assistance awarded under the CoC Program. 

Rental Assistance
Environmental Review

What forms should be used to complete Part 58 reviews in the CoC Program?

The Office of Environment & Energy (OEE) has posted generic formats for Part 58 Exempt, CENST, CEST, and EA reviews: Exempt or Categorically Excluded (CENST) Format Activities Categorically Excluded under 58.35(a) (CEST) Format Environmental Assessment (EA) Format Responsible Entities may have different local or regional forms that they are accustomed to using and are not required to use the formats posted on the HUD Exchange. Additionally,...
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Environmental Review

What level of environmental review is required for Tenant Based Rental Assistance (TBRA) in the CoC Program?

For purposes of conducting an environmental review, “tenant-based rental assistance” is defined as rental assistance that is attached to the program participant and not the unit (meaning that the program participant would be free to select their own unit). Where the program participant selects the location, providing TBRA is Categorically Excluded Not Subject to 58.5 (CENST) (see 24 CFR 58.35(b)(1)). The environmental review record for TBRA i...
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Environmental Review

What is Part 58?

Regulations at 24 CFR Part 58 authorize units of general local government to conduct environmental reviews for projects funded with HUD money where permitted by program legislation. Local governments performing environmental review responsibilities under Part 58 are known as Responsible Entities (RE). When a HUD recipient is a unit of general local government, it must conduct the environmental review and does not have the option to push the respo...
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Environmental Review

What forms should be used to complete Part 50 reviews in the CoC Program?

HUD has developed 2 forms which together complete the Part 50 environmental review for CoC Program leasing, Project Based Rental Assistance (PBRA), and Sponsor Based Rental Assistance (SBRA) projects. These include a form to be prepared by the recipient and submitted to HUD and a second form to be completed by HUD staff upon receipt of the recipient’s form. There should not be a need for Part 50 CENST reviews in the CoC Program.  The proce...
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Environmental Review

I am a CoC Program recipient and a HUD staff person is completing an environmental review under Part 50. What steps do I take?

First, it is important to ensure that having HUD staff complete an environmental review under Part 50 is the appropriate action, as this should be the case only under very limited circumstances. Environmental reviews for CoC Program projects should be conducted by Responsible Entities under Part 58 by default. Before proceeding with the review under Part 50, work with HUD to find a Responsible Entity able to conduct the environmental review under...
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Environmental Review

Is there a citation or clarifying language regarding the definition of "operations" with regards to environmental review requirements? It seems that the level of environmental review depends on the type of expense.

24 CFR 58.35(b)(3) designates “operating costs including maintenance, security, operation, utilities, furnishings, equipment, supplies, staff training and recruitment and other incidental costs” as CENST. The HUD Memorandum: Guidance for Categorizing an Activity as Maintenance for Compliance with HUD's Environmental Regulations, 24 CFR Parts 50 and 58 will clarify the meaning of “maintenance.” All other listed activities should ...
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Environmental Review

Where is the exact citation (regulation, memo, other HUD guidance, etc.) where it lists sponsor-based and project-based rental assistance as falling under leasing with regards to environmental review?

The environmental regulations specify that tenant-based rental assistance is CENST (see 24 CFR 50.19(b)(11), 58.35(b)(1)) and that leasing is CEST (see 50.20(a)(4), 58.35(a)(5)). The environmental regulations are silent regarding project based rental assistance (PBRA) and sponsor-based rental assistance (SBRA), but they have long been interpreted as being equivalent to leasing because the funding is attached the unit or structure (like leasing) a...
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Environmental Review

When dealing with a Balance of State CoC, the recipient is often far away from the closest entitlement community. Would a recipient defer to the State as the Responsible Entity (RE)?

The recipient in a Balance of State CoC does not have to defer to an entitlement jurisdiction to perform the environmental review. Any unit of government may act as the Responsible Entity (RE) to complete the environmental review. If a recipient is a nonprofit organization and local government refuses to act as the RE, then the recipient may request the state to act as RE.

Environmental Review
Environmental Review

How often should environmental reviews be conducted?

HUD recommends a new review every five years or sooner if/when environmental conditions change.

Environmental Review
Environmental Review

Is an environmental review required for units assisted with CoC Program rental assistance funds[Tenant-Based Rental Assistance (TBRA), Sponsor-Based Rental Assistance (SBRA), and Project-Based Rental Assistance (PBRA)]?

Yes, all CoC Program projects require environmental reviews. Reviews for TBRA, SBRA, and PBRA may be conducted by the CoC Program recipient under Part 58 if the recipient is a unit of government or HUD per Part 50 if the recipient is not of a unit of government and a Responsible Entity does not have the capacity to conduct an environmental review. Tenant-based rental assistance is Categorically Excluded Not Subject to 58.5 (CENST), because the re...
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Environmental Review

For CoC Program leasing projects, is an environmental review required for each new program participant? New lease?

Generally, yes; however, this is a very quick process. Environmental reviews should be based on the building and the surrounding geography, and not on the actual unit. Therefore, if a unit is located within a building where an environmental review was already conducted, then HUD or the Responsible Entity (RE) will only need to verify that a review was conducted within the last five years or if/when the environmental conditions change. If HUD...
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Environmental Review

Are environmental reviews required to be conducted onsite?

Most reviews for CoC Program projects do not require an environmental review to be conducted onsite, since most projects only require a limited scope review. This includes: leasing, project-based, and sponsor-based rental assistance. Consult with your Field Environmental Officer for information on how to conduct a limited scope review. If a CoC Program project involves any activities beyond leasing or rental assistance, including repairs, rehabil...
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Environmental Review

Are environmental reviews required on all CoC Program projects?

Yes. All CoC Program projects are required to have an environmental review. However, not all projects require the same level of review. Most CoC Program projects will be at the Categorically Excluded, Not Subject To Part §58.5 or Categorically Excluded Subject To §58.5, which do not require the reviewer to be physically onsite of a CoC Program project.

Environmental Review
Environmental Review

What are the different levels of Environmental Review?

There are 5 different levels of environmental review. However, CEST is the only level of review required by HUD CPD field office staff: CEST: Categorically Excluded, Subject To §58.5 (also subject to §58.6) Includes CoC Program leasing, sponsor-based and project-based rental assistance, minor rehabilitation The remaining 4 levels of review are: CENST: Categorically Excluded, Not Subject To §58.5 (still subject to §58.6) Includes CoC Pr...
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Environmental Review

What is Part 50?

Per 24 CFR Part 50, HUD performs environmental reviews. Recipients of HUD funds will assist HUD with the preparation of the environmental review by supplying key documents and analysis; however, HUD is legally responsible for the content of the environmental review. Part 50 applies where program legislation does not permit the use of Part 58, if the Responsible Entity (RE) does not have capacity to conduct an environmental review, or if 24 CFR 58...
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Environmental Review

Can a CoC Program recipientuse CoC Program funds to pay for environmental reviews?

Yes, CoC Program recipients may use project administrative funds to pay any costs associated with the environmental review responsibilities. See Section 578.59(a)(3) of the CoC Program interim rule for more information.

Environmental Review
Environmental Review

What is an Environmental Review?

An environmental review is an analysis of the impact of a project on the surrounding environment and vice versa. This ensures that HUD-funded projects provide decent, safe, and sanitary housing. Environmental reviews MUST be conducted BEFORE funds are committed to a project.

Environmental Review
Accessing and Submitting the Self-Assessment

How many respondents and respondent types must the CoC Lead invite to complete the Self-Assessment?

The total number of stakeholder respondents for your CoC should be at least 6 and no more than 20. There are four required respondent types (CoC Lead, HMIS Lead, ESG/HPRP Grantee(s), and CoC Provider). If no one from these categories completes a self-assessment tool the overall CoC Check-up self-assessment will be considered incomplete.

Accessing and Submitting the Self-Assessment
Accessing and Submitting the Self-Assessment

Will CoCs be able to choose a Group of individuals (like a regional group) to complete the Check-up as ONE respondent?

Yes, this is the CoC’s tool. Please remember that there is a minimum requirement of 6 respondents in order to complete the Check-up. Four of the respondent types must be the CoC Lead, HMIS Lead, ESG/HPRP Grantee, and one CoC Provider.

Accessing and Submitting the Self-Assessment
Accessing and Submitting the Self-Assessment

Will the CoC Lead be able to review an individual respondent’s Self-Assessment?

The CoC Lead will only be able to generate reports reflecting an aggregate of all the respondents’ answers.

Accessing and Submitting the Self-Assessment
Accessing and Submitting the Self-Assessment

Can I access the survey once I submit?

Once the survey is submitted it cannot be edited or accessed again. The respondent will have the option to print the completed self-assessment once they submit the survey by selecting “OK”.

Accessing and Submitting the Self-Assessment
Accessing and Submitting the Self-Assessment

How do I submit the CoC Self-Assessment?

When you finish the last question of the Self-Assessment, you will be taken to a screen where you can “Return” to the survey or “Submit” the survey. Once you click “Submit”, a message will pop-up reminding the respondent that once the Self-Assessment is submitted it cannot be edited or accessed again. If you are sure you are ready to submit, click “Ok”. Once the survey is submitted you will be able to print the survey or save it a...
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Accessing and Submitting the Self-Assessment

Do respondents have to answer all of the questions on the screen to move back to a previous page?

No, respondents can click “Previous” to navigate to a previous screen.

Accessing and Submitting the Self-Assessment
Accessing and Submitting the Self-Assessment

Do respondents have to answer all of the questions on the screen in order to move forward?

Yes, the respondent must answer all questions on the screen in order to move forward.

Accessing and Submitting the Self-Assessment
Accessing and Submitting the Self-Assessment

Can the CoC Self-Assessment be exited and re-entered like e-snaps?

Yes, the system will bookmark on the screen the respondent last entered an answer. When a respondent logs back in, he or she will be taken to this page.

Accessing and Submitting the Self-Assessment
Accessing and Submitting the Self-Assessment

Do I have to enter comments on every survey page?

No, the comment box is for comments across the specific domain.

Accessing and Submitting the Self-Assessment
Accessing and Submitting the Self-Assessment

How long will it take a respondent to complete the CoC Self-Assessment survey?

Public reporting burden for this collection of information is estimated to average 1.5 hours per respondent, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.

Accessing and Submitting the Self-Assessment
Accessing and Submitting the Self-Assessment

How does the CoC Lead invite CoC Stakeholders to take the survey?

Once in the CoC Lead Portal, CoC Leads can choose to “Enter Respondents” by listing contact information for each respondent and then selecting the “Send Invitation” button. An email will immediately be sent to each person listed with a link to access the survey.

Accessing and Submitting the Self-Assessment
Accessing and Submitting the Self-Assessment

How do CoC stakeholders access the CoC Self-Assessment?

CoC stakeholders who are invited to complete the assessment will receive an email with a link to the survey from their CoC Lead. If the respondent does not complete the survey in one session they will use the same link to re-enter the site. The system will bookmark where they stopped the survey and when they reenter they will be taken to that page.

Accessing and Submitting the Self-Assessment
Final CoC Self-Rating

Do I have to complete the whole Final CoC Self-Rating survey or just update certain indicators?

Yes, the whole Final CoC Self-Rating must be completed by each CoC. The final CoC Self-Rating is not the same as the CoC Lead rating provided during stage 1 of the CoC Check-up process. The self-rating survey represents the ratings for each indicator that the CoC lead decision-making group believes best reflect the CoC's performance.   The final self-ratings may be the same as or different than the mean/median rating across all stakeholders,...
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General Technical

Other than compelling CoCs to evaluate their performance, will participation in the Check-up process become a scoring factor in renewal or new grant awards?

No, The CoC Check-up is not associated with the application process. HUD will not have access to individual CoC responses or reports.HUD will only see aggregated data at the regional and national level.

General Technical
General Technical

Is the CoC Check-up process for all CoCs or just selected ones?

All CoCs are encouraged to participate in the CoC Check-up process. While it is not mandatory, completion of the CoC Check-up is required to request HUD-funded Technical Assistance (TA).

General Technical
General Technical

What does the CoC Check-up measure?

The Check-up is an opportunity for CoCs to assess how they function across a wide cross-section of CoC accountabilities. These accountabilities are organized into the following four domains, each with their own sub-elements and corresponding indicators:  CoC Governance and Structure CoC Plan and Planning Process CoC Infrastructure and Administrative Capacity CoC Housing and Services Survey questions will measure elements related to each of...
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General Technical

Is participation in the CoC Check-up mandatory?

No, participation in the CoC Check-up is not mandatory, but completion is required to request HUD-funded Technical Assistance (TA).

General Technical
General Technical

What is the purpose of the CoC Check-up?

The CoC Check-up serves multiple purposes:  To determine the current functional capabilities of each CoC, and the degree to which CoCs are prepared for HEARTH implementation. To help CoCs identify areas for improvement. To serve as a tool for continuous improvement by helping CoCs identify (and track progress against) specific goals and action steps that will be documented in a CoC Action Plan. To help identify areas for possible technical ...
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Program Income

What are the eligible uses of program income in the CoC Program?

Recipients/subrecipients may use program income on any eligible costs in Subpart D of the CoC Program Interim Rule, in accordance with the requirements of the CoC Program, even if the cost was not documented in the approved grant agreement. However, recipients/subrecipients must document that the program income was expended in accordance with the requirements of the CoC Program. Therefore, recipients/subrecipients are prohibited from using progra...
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Program Income

May a recipient/subrecipient charge program participants program fees?

No. Section 578.87(d) of the CoC Program Interim Rule prohibits recipients/ subrecipients from charging program participants any charges other than occupancy charges or rent. Section 578.77 further explains how to calculate rent and occupancy charges; the amount that a program participant must pay varies depending on the type of assistance provided by the recipient/subrecipient. ...
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General

What is a High Performing Community (HPC)?

An HPC is a CoC that meets all of the requirements found in Subpart E of 24 CFR part 578. To be considered for HPC designation, the Collaborative Applicant, on behalf of the CoC, must complete the HPC forms in e-snaps, as well as attach the required documents for HUD review. As indicated in the Notice CPD-18-06: CoC Program High Performing Community (HPC) Registration Notice, certain types of information will be confirmed against the information...
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General

How does HUD define employment income?

For the purpose of defining employment income for reporting in the Homeless Management Information System (HMIS), HUD relies on the Internal Revenue Service’s (IRS) definition of wages, salaries, tips, and business income. The IRS requires people to report all income received from a business, unless it is excluded by law, and any income paid as compensation for employment. The income may come in regular increments (e.g., through a regular paych...
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General

What are the responsibilities of the HMIS Lead?

The HMIS Lead is responsible for managing the HMIS for the CoC's geographic area, in accordance with the requirements of the CoC Program Interim Rule and any HMIS requirements prescribed by HUD. Any additional responsibilities assigned to the HMIS Lead should be documented in the CoC's governance charter, but may also be clarified in a separate, more detailed written agreement that is incorporated by reference into the CoC’s governance charter....
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General

What is the HMIS Lead?

The HMIS Lead is the eligible applicant designated by the CoC, in accordance with the CoC Program Interim Rule, to manage the CoC‘s HMIS on the CoC's behalf.

General
General

How should I classify the exit destination of clients who exit a continuum project to attend college?

The exit destination for persons attending college will depend on the specifics of the exit situation, but it is important to select a destination response category that reflects both the true nature of the situation and the fact that continuing education is a positive outcome for the client.  In some cases, a client may be exiting to live with his or her family or with friends with the expectation that they will live there while they are in...
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General

What is a subrecipient in the CoC Program?

A subrecipient in the CoC Program is a private nonprofit organization, State or local government, or instrumentality of a State or local government, or a public housing agency that receives a subgrant from a recipient to carry out all or part of a CoC Program project. 

General
General

What is a recipient in the CoC Program?

A CoC Program recipient is an applicant of CoC Program funds that executes a grant agreement with HUD for those CoC Program funds. To be eligible to apply for CoC Program funds, an applicant must be a private nonprofit organization, State, local government or instrumentality of State or local government, or a public housing agency.  

General
General

What is a Collaborative Applicant?

The Collaborative Applicant is the eligible applicant (State, unit of local government, private, nonprofit organization, or public housing agency) designated by the CoC to: Collect and submit the required CoC Application information for all projects the CoC has selected for funding, and Apply for CoC planning funds on behalf of the CoC. The CoC may assign additional responsibilities to the Collaborative Applicant so long as these responsibiliti...
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General

What is a CoC Board?

The CoC board is the collective of individuals designated to provide oversight and governance on behalf of the CoC. The CoC Board’s responsibilities are defined by the CoC and must be described in the CoC’s governance charter. The CoC Board must be representative of the relevant organizations and of projects serving homeless populations and subpopulations within the CoC's geographic area. The CoC Board must also include at least one homeless ...
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General

What is a Continuum of Care?

A Continuum of Care (CoC) is the group organized to carry out the responsibilities prescribed in the CoC Program Interim Rule for a defined geographic area. A CoC should be composed of representatives of organizations including: nonprofit homeless providers, victim service providers, faith-based organizations, governments, businesses, advocates, public housing agencies, school districts, social service providers, mental health agencies, hospitals...
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General

What is the purpose of the CoC Program?

The purpose of the CoC Program is to: Promote community-wide commitment to the goal of ending homelessness; Provide funding for efforts by nonprofit providers, States, and local governments to quickly re-house homeless individuals and families while minimizing the trauma and dislocation caused to homeless individuals, families, and communities by homelessness; Promote access to and effective utilization of mainstream programs by homeless individ...
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Unified Funding Agencies

As a Unified Funding Agency (UFA), what are my limitations for moving funds within the grant?

The way UFA grants are setup are different than grants funded under a Collaborative Applicant. Because the UFA renewal grant encompasses all renewal projects, the UFA has unique ability to move funds across all projects, regardless of component type, within the grant. The UFA must work with its local HUD field office to make changes to the projects under the UFA grant. All budget changes will be reflected in eLOCCS via the local HUD field office....
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Unified Funding Agencies

What are the Annual Performance Report (APR) submission requirements for Unified Funding Agencies (UFAs)?

UFAs are unique for many reasons, some of which directly affect reporting requirements. UFAs receive two grants: one for all renewal projects, UFA costs, and Continuum of Care (CoC) planning funds; the other for new projects. UFAs are required to report on their outputs and outcomes for all projects. Because funding for several projects is combined in the single renewal grant it is important to clarify that UFAs are not required to submit a separ...
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Unified Funding Agencies

Are Unified Funding Agencies (UFAs) required to use subrecipients to carry out projects?

No - UFAs are not required to use subrecipients for their grants. The UFA is ultimately responsible for carrying out all of the activities as listed in the project application(s) and grant agreement.

Unified Funding Agencies
Unified Funding Agencies

What happens if a Unified Funding Agency (UFA) needs to replace a subrecipient? What if the UFA cannot find a suitable replacement subrecipient?

If a UFA must replace a subrecipient because the subrecipient is not compliant or it no longer has the capacity or desire to continue carrying out the activities of the project, the UFA may find another subrecipient that has the capacity or the UFA may administer the project itself. HUD expects the UFA to have the capacity to ensure that the project continues with or without the subrecipient.

Unified Funding Agencies
Unified Funding Agencies

May Unified Funding Agencies (UFAs) impose sanctions on their subrecipients?

Yes - UFAs may impose remedial actions and sanctions on subrecipients that are not in compliance with CoC Program regulation. Per 24 CFR 578.107(a)-(b), remedial actions and sanctions include: Requiring the subrecipient to submit and comply with proposals for action to correct, mitigate, and prevent noncompliance with program requirements; Changing the method of payment to a reimbursement basis; Suspending payments to the extent the UFA determin...
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Unified Funding Agencies

Who is responsible for monitoring Unified Funding Agencies (UFAs)? Who is responsible for monitoring the UFAs’ subrecipients?

As a recipient, the UFA will be monitored by HUD via the local HUD field office. As described in 24 CFR 578.11(b)(3), the UFA is responsible for monitoring all of its subrecipients. 24 CFR 578.23(c)(8) states that recipients and subrecipients must be monitored annually. Remember, the UFA is the only recipient of grant agreements for the CoC and 24 CFR 578.7(a)(6) establishes that one of the responsibilities of the CoC is to monitor its recipient(...
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Application Renewal

Are Safe Havens eligible for renewal in the CoC Program?

The HEARTH Act repealed the "Safe Havens for Homeless Individuals Demonstration Program". HUD will not fund any new Safe Haven projects under the CoC Program. However, HUD will continue to renew funding for an existing Safe Haven project as long as: The project continues to operate within the scope of the grant in effect on August 30, 2012, serving the same population, same number of persons or assisting the same number of units in the same type...
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Coordinated Entry

Are there actions a Continuum of Care may take within its Coordinated Entry process to prioritize persons who are at increased risk of severe illness from COVID-19?

Yes, a Continuum of Care (CoC) may choose to incorporate specific factors into its Coordinated Entry (CE) process that will assist to identify and prioritize persons most at risk of severe illness from COVID-19. The processes of assessment, scoring, prioritization, and determining eligibility comprise four distinct elements of the CE process that connect CE participants to potential housing and services. In particular, prioritization must be base...
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Coordinated Entry

My CoC needs to prioritize households to meet the requirements of HUD’s Notice CPD-17-01, but we are concerned that we might inadvertently violate federal civil rights laws and requirements, including the Fair Housing Act. How do we prioritize related to vulnerability/need in a non-discriminatory way?

The assessment and prioritization process must be based on an individual’s vulnerability or need level according to a Continuum of Care’s (CoC) standardized prioritization criteria. In the prioritization stage, the Coordinated Entry (CE) staff person uses assessment data to compare the participant’s level of need with the needs of others on the priority list and prioritizes the person for housing and supportive services based on the CoC’s...
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Coordinated Entry

Can a CoC implement a regional approach to coordinated entry when the amount and types of resources available in different parts of the CoC's geography vary?

Notice-CPD-17-01 states that CoCs covering a large geographic area may design their coordinated entry to include multiple referral zones in order to avoid making persons travel or move long distances in order to be assessed or served. HUD wants to clarify that this is only an option where there are actually housing and service resources available within each referral zone. In the event that resources are concentrated exclusively in particular cou...
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Coordinated Entry

How can CoCs ensure they are taking the needs of all youth into consideration while developing a CE process? What is the role of stakeholders not exclusively dedicated to serving youth experiencing homelessness (e.g., schools, justice, health, and behavioral health providers)?

An inclusive and responsive coordinated entry (CE) process for all youth can only be achieved through widespread stakeholder participation in planning and implementing CE. To ensure that the CE process incorporates the needs of youth, the planning and implementation process needs to include: Youth experiencing homelessness; Youth homeless assistance providers including those funded by the Runaway and Homeless Youth Act; Child welfare systems and...
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Coordinated Entry

Has HUD published guidance about what it expects communities to report regarding coordinated entry?

No - HUD is not currently requiring reports for coordinated entry. However, HUD is working on guidance specific to coordinated entry and HMIS for both project set-up and reporting, which it will issue in the near future. Communities should ensure that their HMIS is programmed to the 2014 HMIS Data Standards.

Coordinated Entry
Coordinated Entry

Our CoC uses a module outside of our HMIS to collect assessment data as part of our coordinated entry process; is this permissible?

Yes - However, it is important to note that data collected for assessment—which could be as simple as scores from assessment tools or something more complex—is not necessarily the same as data collected for HMIS. To the extent that the data overlaps and if your CoC plans to import the data into the HMIS at any point, the CoC must ensure that the module meets all HMIS data and technical standards (i.e., the data collected complies with th...
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Coordinated Entry

Are CoCs required to use their HMIS in their coordinated entry process?

No - HUD does not require CoCs to use their HMIS as part of their coordinated entry process. However, many communities recognize the benefit of using this option and have incorporated HMIS into their coordinated entry process. HUD is encouraging communities to consider using HMIS but recognizes that other systems might be better or more quickly able to meet the community’s coordinated entry needs, which is acceptable so long as the co...
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Coordinated Entry

Our CoC’s HMIS is closed and the data is only seen by the provider entering it into the HMIS. Can recipients and subrecipients still use our HMIS in our coordinated entry process?

Depends - HUD recognizes that many HMIS implementations are closed and do not share data across providers. While it is possible to use a closed HMIS as a tool in your coordinated entry process, functionality will vary by system. Your organization should work with the HMIS Lead and HMIS vendor to determine if using the HMIS for the coordinated entry process is possible in your community.

Coordinated Entry
Coordinated Entry

Is it permissible for recipients and subrecipients to use CoC or ESG funds to pay to update their HMIS to become part of our coordinated entry process?

Yes - HMIS funds in the CoC and ESG Programs may be used to pay for coordinated entry, but only to the extent that the coordinated entry is integrated in the CoC’s HMIS. Per 24 CFR 576.107(a)(2) and 24 CFR 578.57(b) HMIS Leads may use funds to pay to customize or enhance the CoC’s HMIS to integrate coordinated entry. Additionally, per 24 CFR 576.107(a)(1) and 24 CFR 578.57(a), all recipients and subrecipients contributing data to the HMIS may...
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Coordinated Entry

How is the CE “Assessment” connected to the comprehensive screening and assessment processes often implemented in youth and health service related contexts?

The primary purpose of the coordinated entry (CE) standardized assessment process is to gather information necessary to determine the severity of a youth’s needs and their eligibility for housing and services in a way that utilizes their strengths and is based on evidence of the risk of becoming or remaining homeless. The CE assessment should gather information on factors that can help systems prevent youth from experiencing homelessness or end...
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Coordinated Entry

Is family reunification an appropriate referral within CE?

Yes. In many situations, family reunification is an appropriate referral within coordinated entry (CE), provided that the family home is a safe and stable environment. Family reunification should be a primary referral option for youth under 18, where only a small percentage may be most appropriately served by an independent, safe, and stable housing situation, and many youth 18 and older will also benefit from family reunification services. The C...
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Coordinated Entry

What is the role of Runaway and Homeless Youth (RHY) providers in the development and implementation of a CE entry process?

RHY programs, whether they are funded federally or privately, are an integral part of many communities’ efforts to prevent and end homelessness. It is therefore vitally important for all RHY providers to be integrated into their community’s Continuum of Care (CoC), to be at the table to provide input, and to help ensure that the coordinated entry (CE) process is fully responsive to the needs of youth experiencing homelessness. In addition to ...
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Coordinated Entry

What populations of youth experiencing homelessness and who have runaway should be part of the CE process?

Under current regulations, coordinated entry (CE), at a minimum, must serve youth defined as homeless and at-risk of homelessness by HUD. However, HUD and HHS strongly encourage communities to also include youth considered homeless or runaway by other federal definitions*. The CE process will encounter youth when they are in various stages of experiencing a housing-related crisis and should be designed to accommodate a broad range of youth who ar...
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Coordinated Entry

How can we make sure that the CE process is appropriate for youth?

Regardless of whether it is through a youth-specific coordinated entry (CE) process or a single CE process serving all populations, including youth, there are critical youth factors for communities to consider when developing a CE process to ensure it is appropriate for youth. Several of these considerations are: Youth-Centered: The CE process should be built on relationships between adults and youth that are empowering to youth and based on pos...
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Coordinated Entry

How can the CE referral process ensure that youth are referred to appropriate housing and services?

In order to ensure that youth are referred to appropriate housing and services, a broad array of youth focused housing and services need to be included among all of the resources available to the coordinated entry (CE) process. Youth who have been assessed for housing and services need to know exactly which program they are being referred to, what will be expected of them, and what they should expect from the program. Providers and caseworkers kn...
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Coordinated Entry

How does prioritization account for the unique experiences and vulnerabilities of youth?

Prioritization ensures that youth with the most severe service needs and levels of vulnerability are prioritized for limited housing and homeless assistance resources that meet their needs and strengths and is the process by which a youth is placed in a relative order for referral to different types of housing and services. As discussed in FAQ 2940, runaway and homeless youth (RHY) and other youth providers should play an active role in the Conti...
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Coordinated Entry

How can youth providers or other community partners participate as an access point for coordinated entry (CE)?

There are several models for access points which include, but are not limited to, the following: “Single point of access” at one central community location, sometimes referred to as centralized intake;   “Multisite centralized access” at several locations in a community, sometimes referred to as hubs or a hybrid approach, that can serve all or certain special populations;   “No wrong door” available on location at any commu...
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Coordinated Entry

How does a CE process work for youth experiencing homelessness?

A coordinated entry (CE) process standardizes and coordinates the way youth access the community’s homelessness crisis response system and connect with the appropriate resources they need to achieve safety and stability. The process should ensure that youth receive the housing and service supports they need to resolve their homelessness crisis as quickly as possible, with the lowest possible barriers. The CE process should be able to answer the...
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Coordinated Entry

Can our coordinated entry (CE) process establish a separate assessment process for youth?

Yes. As described in the February 2015 HUD Coordinated Entry Policy Brief, it may be appropriate, though not required, for communities to establish processes, “including different access points and screening and assessment tools,” for four specific groups only: Youth;   Families;   Individuals; and   Victims of Domestic Violence (including trafficked youth, victims of other forms of abuse and exploitation, and youth fleeing or...
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Coordinated Entry

Why should my community develop a CE process for youth?

Federal partners have recently identified coordinated entry (CE) as a key component of the coordinated community response to prevent and end youth homelessness in 2020. CE is also required for all housing programs receiving HUD Continuum of Care (CoC) and Emergency Solutions Grants (ESG) funding and strongly recommended for all of a community’s homelessness-dedicated resources. In order for these community-wide processes to appropriately serve ...
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Coordinated Entry

Does HUD require an assessment form or tool that our CoC can use?

Although HUD does not endorse or require the use of any specific assessment form, tool, or approach, it has described some universal qualities that should be incorporated into any form, tool, or approach used by a Continuum of Care (CoC) for its coordinated entry process. See HUD’s Coordinated Entry Policy Brief for a full description of these qualities and criteria. HUD recognizes the need for further guidance as both the process and the tools...
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Coordinated Entry

If our CoC chooses to create a separate coordinated entry process for victims of domestic violence, what should it look like?

If the Continuum of Care (CoC) chooses to create a separate coordinated entry process for people fleeing domestic violence, including separate access points, that process must be developed in coordination with local victim service providers, adhere to the same requirements as the broader coordinated entry process, and be designed according to the qualities outlined in the Coordinated Entry Policy Brief, with the only difference being that it is t...
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Coordinated Entry

How can our CoC serve victims of domestic violence when our coordinated entry location is known to the entire community, potentially endangering those victim households?

Continuums of Care (CoCs) will find the victim service providers and state domestic and sexual violence coalitions in their communities to be excellent resources in developing a coordinated entry process that has protocols in place to ensure the safety of the individuals seeking assistance. CoCs should engage with these organizations as well as other experienced stakeholders and providers to determine the best options for victims fleeing domestic...
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Coordinated Entry

What safeguards must our CoC build into our coordinated entry process to protect victims of domestic violence?

Domestic violence is often very traumatic for households, including children exposed to domestic violence. It is imperative that coordinated entry processes be designed to prevent further trauma and to provide households with control over the process and referrals. Trauma-informed practices that are sensitive to the lived experience of all people presenting for services need to be incorporated into every aspect of the coordinated entry process. T...
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Coordinated Entry

How do coordinated entry staff determine when domestic violence or trauma experiences are best addressed by a victim service provider rather than a general homeless assistance provider?

Individuals and families fleeing or healing from domestic violence or trauma should have access to the full range of housing and service intervention options available in their community, including prevention, diversion, rapid re-housing, and other housing and mainstream services. However, special consideration must be given to their unique and often complex physical and emotional safety needs. In particular, they might benefit from participation...
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Coordinated Entry

Is it permissible for a victim service provider to participate in their Continuum of Care’s coordinated entry process?

Yes - HUD allows and actively promotes the full participation and integration of victim service providers into the Continuum of Care (CoC) coordinated entry process. The form this integration takes will vary by community, but the overarching goal is for individuals and families presenting to the homeless and victim services system to have full and complete access to the housing and service resources available through both systems. Specifical...
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Coordinated Entry

How does HUD define victim service provider?

HUD defines a victim service provider to mean a private nonprofit organization whose primary mission is to provide direct services to victims of domestic violence. This term includes permanent housing providers—including rapid re-housing, domestic violence programs (shelters and non-residential), domestic violence transitional housing programs, dual domestic violence and sexual assault programs, and related advocacy and supportive services programs.

Coordinated Entry
Coordinated Entry

Is it permissible to include Domestic Violence providers in the coordinated entry process if the CoC uses HMIS as a tool?

Yes - While victim service providers are prohibited from entering personally identifying information into HMIS, HUD is encouraging CoCs to work with their victim services providers to establish either a process for their participation in the CoC’s coordinated entry process or establish their own coordinated entry process outside of the HMIS. It is important that this process provides access to all available housing and services regardless of wh...
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Coordinated Entry

Is it permissible for households once served by a victim service provider who then enter a non-victim service provider project to withhold consent to have their data shared via HMIS?

Yes - All households, regardless of their domestic violence (DV) status, have the right to refuse to share their information among providers within the Continuum of Care (CoC). In fact, all service providers are prohibited from denying assistance to program applicants and program participants if they refuse to permit the provider to share their information with other providers. However, some information may be required by the project, or by publi...
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Definition of Chronic Homelessness

For many persons experiencing chronic homelessness, obtaining required third-party documentation can take a long period of time. Are recipients of PSH required to have all third-party documentation at the point of intake and enrollment of a program participant into a project?

The recordkeeping requirements included in the Final Rule on Defining “Chronically Homeless” are meant to ensure that, when applicable, permanent supportive housing (PSH) that is dedicated to serving persons experiencing chronic homelessness is being used to serve persons that meet the definition. It was never HUD’s intention that these requirements act as a barrier to housing those most in need of PSH as quickly as possible. In fact, ...
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Definition of Chronic Homelessness

Can a child with a disability qualify a household as chronically homeless?

Under the definition of chronically homeless, the head of household (either an adult or a minor if there is no adult present) must have the qualifying disability and meet all of the other criteria (i.e., length of time homeless) in order for a family to be considered chronically homeless. Where there is no adult member of the family, then a minor can be identified as the head of household and that individual is who must meet the criteria. Note: w...
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Definition of Chronic Homelessness

What may be considered acceptable (but not third party) documentation for an individual or head of household's history of residing in a place not meant for human habitation, emergency shelter, or safe haven in light of the final rule on the definition of chronically homeless?

The Final Rule on Defining “Chronically Homeless” clarifies that the order of priority for obtaining documentation of an individual or head of household’s history of residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven is first third-party documentation, followed second by the written observation of an intake worker, and third by the self-certification of the individual or head of household seeking...
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Definition of Chronic Homelessness

How does a dedicated PSH project document the efforts they have taken to locate persons considered the highest priority when there are no chronically homeless persons in their geographic area?

HUD understands that in order to implement the definition outlined in the Final Rule on Defining “Chronically Homeless,” it will require that communities exercise due diligence to identify and engage all persons experiencing homelessness with chronic homelessness within the CoC’s geographic area. Therefore, HUD encourages CoCs to establish policies and procedures for identifying and serving chronically homeless households including, but not...
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Definition of Chronic Homelessness

How can a record from HMIS or a comparable database count as documentation of homelessness?

A single record of a stay in an emergency shelter or a safe haven or an outreach contact of an individual or head of household residing in a place not meant for human habitation in a single month is sufficient documentation to consider the individual or head of household as residing in that location for the entire month unless there is clear evidence of a break such as an HMIS record of an exit to permanent housing. Where data is available, the i...
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Definition of Chronic Homelessness

What are acceptable forms of third-party documentation for documenting an individual or head of household’s history of residing in a place not meant for human habitation, emergency shelter, or safe haven?

Acceptable forms of third-party documentation based on the recordkeeping requirements that were established in the Final Rule on Defining “Chronically Homeless” include: An individual record of a stay in an emergency shelter, a safe haven, or from a street outreach contact from an HMIS, or comparable database used by victim service or legal service providers; A written observation by an outreach or intake worker of encounters with the indivi...
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Definition of Chronic Homelessness

Can an individual or head of household be considered chronically homeless if they are coming directly from an institution? Why or why not?

An individual or head of household with a qualifying disability can be considered chronically homeless if they are coming directly from an institution where they have resided for fewer than 90 days and resided in a place not meant for human habitation, an emergency shelter, or a safe haven immediately prior to entering the institution and were either: Residing in one of these locations for at least the last 12 months continuously or 12 months cu...
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Definition of Chronic Homelessness

How must an individual or head of household’s qualifying disability be documented with regard to the recordkeeping requirements that were established in the final rule on the definition of chronically homeless?

To be considered chronically homeless, the individual or head of household must be a “homeless individual with a disability” as defined by the McKinney-Vento Act as amended by the HEARTH Act. An individual or head of household’s qualifying disability must be documented by one of the following: Written verification of the disability from a professional licensed by the state to diagnose and treat the disability and his or her certification t...
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Definition of Chronic Homelessness

How can recipients and subrecipients document stays in institutions of fewer than 90 days with regard to the recordkeeping requirements that were established in the final rule on the definition of chronically homeless?

As established in the Final Rule on Defining “Chronically Homeless”, stays in institutions of fewer than 90 days are not considered a break. In addition, so long as the individual or head of household was residing in a place not meant for human habitation, an emergency shelter, or a safe haven immediately prior to entering the institution, the amount of time spent in the institution counts towards the individual or head of household’s tota...
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Definition of Chronic Homelessness

Can housing or service providers such as emergency shelter staff, members of law enforcement, or healthcare professionals verify homelessness?

Another housing or service provider may provide a referral of the individual or head of household’s current or prior residence in an emergency shelter, safe haven, or place not meant for human habitation. HUD considers other housing or service providers to include members of law enforcement, a healthcare professional within the community, an educator, or another person that has encountered the individual or head of household while in their offi...
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Definition of Chronic Homelessness

Can a community member, such as a shopkeeper or neighborhood resident, verify homelessness?

An intake worker may accept as third-party documentation, the oral or written observation of someone in the community, including but not limited to, a shopkeeper, a building owner, or a neighborhood resident (regardless of relationship with the household) that has physically observed where the individual or head of household is or has been residing. If the community member is unwilling to provide a written observation, the intake worker may docum...
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Definition of Chronic Homelessness

How can encounters with the individual or head of household by the outreach worker or intake worker be documented so that it is considered third-party documentation?

To document where the individual or head of household is currently coming from, the outreach worker or intake worker, if applicable, must have physically observed where the individual or head of household is currently residing. The written observation must include the intake or outreach worker’s own encounter of the individual or head of household in that location. To document where the individual or head of household has been residing for pri...
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Definition of Chronic Homelessness

What are the recordkeeping requirements that were established in the final rule on the definition of chronically homeless?

The Final Rule on Defining “Chronically Homeless” establishes recordkeeping requirements for the following criteria, which must be documented for the individual or head of household presenting for assistance: The history of residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven, including where the individual or head of household is coming from currently; Stays in institutions; Breaks of seven nights ...
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Definition of Chronic Homelessness

With regard to the final rule on the definition of chronically homeless, what constitutes an occasion of homelessness and how does HUD define a break?

The amended definition as found in the Final Rule on Defining “Chronically Homeless” does not establish a minimum number of days that each occasion must total and instead defines the end of an occasion as a break of at least seven nights where the individual or head of household is not residing in an emergency shelter, safe haven, or is residing in a place meant for human habitation (e.g., with friends or family) or a period of 90 days or lon...
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Definition of Chronic Homelessness

When does the final rule on defining “chronically homeless” take effect and who must be in compliance?

The Final Rule on Defining “Chronically Homeless” went into effect for the CoC Program on January 4, 2016 and HUD expected Permanent Supportive Housing (PSH) providers to begin using it for all new admissions as of January 16, 2016. This means, beginning January 16, 2016, any PSH projects required to serve persons that are chronically homeless (either dedicated or prioritized) may only accept new program participants that meet this definition...
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Definition of Chronic Homelessness

What are the main differences between the previous definition of “chronically homeless” and the definition included in the final rule?

The following is a summary of the most significant changes between the definitions of chronically homeless previously in effect and the definition included in the CoC Program interim rule as amended by the Final Rule Defining “Chronically Homeless”: To be considered chronically homeless, an individual or head of household must meet the definition of “homeless individual with a disability” from the McKinney-Vento Act, as amended by t...
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Definition of Homelessness

Does the criteria that “The primary nighttime residence will be lost within 14 days of the date of application for homeless assistance” apply when an individual or family who is living with someone is told they need to move out in a week?

Yes, as long as they meet all of the other requirements of category 2 of the homeless definition. The second category of the definition of homeless includes individuals and families who are within 14 days of losing their housing, including housing they own, rent, are sharing with others, or are living in without paying rent. It also includes individuals and families who are living in hotels and motels that they are paying for using their own reso...
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Definition of Homelessness

The Homeless Definition final rule has a typo (pg 75977) that written documentation of disability includes written verification from a professional licensed by the state to diagnose and treat the condition AND written verification from the SSA or the receipt of disability check.

The regulatory text found on page 76016 and page 76019 contain the correct requirements. These sections indicate that acceptable evidence of a disability includes: Written verification of the disability from a professional licensed by the state to diagnose and treat the disability and his or her certification that the disability is expected to be long-continuing or of indefinite duration and substantially impedes the individual’s ability to li...
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Definition of Homelessness

With regard to the final rule on the definition of homeless, are all individuals and families that are currently residing in transitional housing programs now eligible for permanent supportive housing?

No, not all individuals and families currently residing in transitional housing will be eligible for permanent supportive housing. Permanent housing projects must continue to abide by the limitations and requirements included in the NOFA under which they were funded, including the limitation on eligibility. Projects funded in the FY 2011 CoC Competition must continue to abide by the limitation on Permanent Supportive Housing set forth in the NOFA...
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Definition of Homelessness

With regard to the final rule on the definition of homeless, does the amended definition also apply to the Section 8 Moderate Rehabilitation Program for Single Room Occupancy Dwellings?

No, the HEARTH Act revised definition did not amend the definition of homeless used in the Section 8 Moderate Rehabilitation Program for Single Room Occupancy Dwellings for Homeless Individuals.  These projects will continue to use the following definition of homeless: "An individual who lacks a fixed, regular, and adequate nighttime residence; and an individual who has a primary nighttime residence that is — A supervised publicly or priv...
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Definition of Homelessness

Are youth who are within 14 days of exiting the foster care system who have not identified other permanent housing and have no other resources or support networks to obtain permanent housing defined as homeless under Category 2 of the definition of homeless?

No. Youth who are within 14 days of exiting the foster care system who have not identified other permanent housing and who have no other resources or support networks to obtain permanent housing are not defined as homeless under Category 2 of the definition of homeless. This is different than how HUD operationalized eligibility for Transitional Housing and Supportive Service Only projects under the Supportive Housing Program. The HEARTH...
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Definition of Homelessness

Is an individual or family that is receiving Rapid Re-Housing Assistance considered chronically homeless for purposes of remaining eligible for permanent housing placements dedicated to serving the chronically homeless?

Yes. Program participants that are receiving Rapid Re-Housing Assistance through programs such as the Emergency Solutions Grants (ESG) Program, the Continuum of Care (CoC) Program, the Supportive Services for Veterans Families (SSVF) Program, or the Veterans Homelessness Prevention Demonstration Program (VHPD) maintain their chronically homeless status for the purpose of eligibility for other permanent housing programs dedicated to serving the ch...
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Definition of Homelessness

Is an individual or family that is receiving Rapid Re-Housing Assistance considered homeless for purposes of remaining eligible for other permanent housing placements?

Yes. Program participants that are receiving Rapid Re-Housing Assistance through programs such as the Emergency Solutions Grants (ESG) Program, the Continuum of Care (CoC) Program, the Supportive Services for Veterans Families (SSVF) Program, or the Veterans Homelessness Prevention Demonstration Program (VHPD) maintain their homeless status for the purpose of eligibility for other permanent housing programs, such as HUD-VASH and CoC-funded perman...
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Eligible Activities

Is “case management” that is commonly conducted to help households find and maintain stable housing under the Continuum of Care (CoC) program, considered “housing counseling” for purposes of this rule?

Holistic case management for persons experiencing homelessness is not housing counseling as defined in the Final Rule. Therefore, if an activity provided under the CoC program is part of holistic case management for persons experiencing homelessness, it is not housing counseling and certification is not required. However, there may be instances where housing counseling, as defined in the Final Rule, is being provided under the CoC program. For ex...
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Eligible Activities

The Continuum of Care (CoC) program is listed in the certification rule as a “HUD Program where housing counseling is funded under the HUD program.” How is the CoC program affected by the Final Rule on housing counselor certification?

Housing counseling is an eligible supportive service under the CoC program. If a recipient or subrecipient chooses to fund housing counseling activities under their program, the housing counseling must be provided by HUD certified housing counselors working for an agency approved to participate in HUD’s Housing Counseling Program, by August 1, 2021, the Final Compliance Date.

Eligible Activities
Eligible Activities

How must recipients demonstrate site control?

When CoC Program grant funds are used for acquisition, rehabilitation, new construction, operating costs, or supportive services, the recipient/subrecipient must demonstrate that it has control of the assisted site (i.e., site control) within 12 months of the award announcement. The recipient/subrecipient has 24 months to prove site control if the CoC Program funds will be used for acquisition, rehabilitation, or new construction. Where there is ...
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Eligible Costs

May recipients and subrecipients of CoC Program funds purchase cell phones and wireless service plans for program participants to use when receiving supportive services?

Yes, under certain conditions. 24 CFR 578.53(e)(17) makes the costs of supplies and materials incurred by the recipient or subrecipient when directly providing supportive services to program participants an eligible supportive service cost. To qualify as an eligible supply and material cost the cell phone must be owned by the recipient/subrecipient and the wireless service plan must be the recipient/subrecipient's, but the phone may be loaned to...
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Eligible Costs

Can CoC project administrative funds be used to train recipient staff to safely deliver assistance during the COVID-19 pandemic?

Yes. 24 CFR 578.59(a)(2) permits the use of project administrative costs for training on Continuum of Care (CoC) requirements and attending HUD-sponsored CoC trainings. If CoCs have established standards or recommended procedures on how to deliver services during the COVID-19 pandemic (including how to recognize symptoms, how to protect recipient staff from infection, and how to protect against spreading the virus while providing assistance to pr...
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Eligible Costs

According to 578.55(b)(3), an eligible operating cost is scheduled payments to a reserve fund for the future replacement of major building systems (e.g., a roof or HVAC system). If I have this cost in my grant, am I supposed to draw down money regularly or leave it in LOCCS and are there any limits to how much of my grant funds I can put towards the reserve fund?

Scheduled payments to a reserve fund for the repair of major building systems are an eligible cost for recipients of transitional or permanent supportive housing projects where the recipient or subrecipient owns or operates the building(s). The repayment schedule, the total amount to be placed in reserve over the grant term and the scheduled payment amount, the system or systems to be replaced and the useful life/lives of the system(s) must be su...
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Eligible Costs

May CoC Program funds be used to purchase gift cards for program participants?

No, gift cards are considered a form of cash. Under the CoC Program, recipients/subrecipients are prohibited from making direct cash payments to program participants.

Eligible Costs
Eligible Costs

Can operating costs be used for building security when less than 50% of the building is paid for with grant funds?

No. In order for building security to be an eligible operating cost under the CoC Program, more than 50% of the units or building area must be paid for with grant funds. If 50% or less of the units or building area is paid for with grant funds, even if the building is used 100% for housing for the homeless, then no costs for building security may be charged to the CoC Program grant. Note: this also means that any funds used on building secur...
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Eligible Costs

May a CoC Program recipient change a project’s program component through a grant agreement amendment? For example, may a CoC Program recipient change a project from TH to PSH through a grant agreement amendment?

No. Section 578.105 of the CoC Program interim rule sets forth the parameters for grant and project changes. Paragraph (b) defines significant changes as: a change of recipient, a change of project site, additions or deletions in the types of eligible activities approved for a project, a shift of more than 10 percent from one approved eligible activity to another eligible activity, a reduction in the number of units, and a change in the subpopula...
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Eligible Costs

The new CoC Program interim rule lists eligible supportive services. The use of language interpreters is not listed as either eligible or ineligible. Are interpreter services eligible under the CoC Program?

Interpreters are not listed as an eligible cost under supportive services. However, interpreters may be a part of other supported services such as education and so may be counted as a subcategory of another supported service eligible cost. It may be possible to list interpreters as an administrative or operating cost, depending on how the interpreters are used.

Eligible Costs
Eligible Participants

Does the footnote from HUD’s CPD Memorandum (described below) apply only to veterans seeking services through HUD-VASH, or are the same Veterans considered chronic for HUD-funded PSH outside of VASH as well?

In HUD's CPD Memorandum: Guidance for Determining Eligibility for Permanent Supportive Housing for Persons Participating in Certain Department of Veteran's Affairs Programs, footnote 2 on page 3 says that HUD recognizes that the Department of Veteran's Affairs (VA) determines chronic homeless status at the initial intake into VA services and that veterans served by the VA can maintain that chronic status throughout their episode of care with the ...
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Eligible Participants

How should recipients determine a family’s eligibility for Permanent Supportive Housing (PSH) if the individual members of the family are residing in different places when they present for assistance to the project?

Under the CoC Program, persons presenting together for assistance regardless of marital status, actual or perceived sexual orientation, or gender identity are considered a family and can be served as a family. When determining whether a family where the individual members are not residing together when they present for intake to the project is eligible, the recipient must determine eligibility based on the status of: The adult head of household ...
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Eligible Participants

How should recipients determine a family’s eligibility for assistance under the Emergency Solutions Grants (ESG) Program or for the Continuum of Care (CoC) Program when the individual members of the family are residing in different places upon presentation to the project?

Under HUD's Homeless Assistance Programs, persons presenting together for assistance regardless of marital status, actual or perceived sexual orientation, or gender identity are considered a family and can be served as a family in the ESG and CoC programs. In general, when determining the homeless status of families where the individual members are not residing together when they present for intake into the project (e.g. one parent is staying in ...
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Eligible Participants

How is the definition of ‘family’ that was included in the Equal Access to Housing in HUD Programs – Regardless of Sexual Orientation or Gender Identity apply to recipients and subrecipients of ESG and CoC Program funds?

The Equal Access Rule defines family as follows: Family includes, but is not limited to, regardless of marital status, actual or perceived sexual orientation, or gender identity, the following: A single person, who may be an elderly person, displaced person, disabled person, near-elderly person, or any other single person; or, A group of persons residing together, and such group includes, but is not limited to: A family with or without children...
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HMIS Eligible Costs

What are the HMIS participation requirements for legal services providers?

Legal services providers that are recipients or subrecipients under the CoC Program are required to collect client-level data, consistent with HMIS data collection requirements. To protect clients, legal services providers may choose instead to enter data into a comparable database that complies with HMIS requirements. They may use CoC Program funds to establish and operate a comparable database. Legal services providers who do not use the CoC’...
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HMIS Eligible Costs

What are the HMIS participation requirements for victim services providers?

Victim services providers that are recipients or subrecipients under the CoC Program are required to collect client-level data consistent with HMIS data collection requirements, BUT they must not directly enter data into an HMIS. To protect clients, victim services providers must enter required client-level data into a comparable database that complies with HMIS requirements. They may use CoC Program funds to establish and operate a comparable da...
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HMIS Eligible Costs

How do I determine eligible HMIS costs if staff time/resources are not dedicated 100% to HMIS work?

The staff time dedicated to eligible HMIS-funded costs can be calculated as a proportion of that staff’s overall time, and billed accordingly.

HMIS Eligible Costs
HMIS Eligible Costs

Who is eligible to access CoC funds for HMIS eligible costs?

HMIS is an eligible cost under all CoC Program components. CoC recipients and subrecipients who contribute data to an HMIS, but are not the HMIS lead, may use funds under the HMIS eligible cost to pay the expenses related to contributing data to the HMIS designated by the CoC for the area.  A project funded under the transitional housing program component, for example, can apply for funds for costs related to contributing data to the HMIS de...
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HMIS Eligible Costs

Who is eligible to access CoC funds under the CoC HMIS program component?

Only HMIS leads are eligible to apply for funds under the CoC HMIS program component. While other applicants can apply for HMIS costs under the other component types, the following costs are unique to the HMIS component:  Hosting and maintaining HMIS software or data; Backing up, recovering, or repairing HMIS software or data; Upgrading, customizing, and enhancing the HMIS; Integrating and warehousing data, including development of data war...
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HMIS Eligible Costs

What is the difference between HMIS as a program component and HMIS as an eligible cost?

Under the CoC Program, HMIS can be funded as a program component and an eligible cost. Program components establish the overall purpose and nature of the project that is being funded, whereas eligible costs specify what may be funded by the grant. Each program component is associated with eligible costs. There are five CoC Program components. All CoC projects must fit into one of these components. A project cannot include multiple components. Whe...
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HMIS Eligible Costs

Are the salaries of staff conducting data entry into HMIS and other HMIS-related overhead costs eligible as project administrative costs?

Staff and overhead costs directly related to contributing data to HMIS are considered HMIS eligible costs and are not eligible project administrative costs.

HMIS Eligible Costs
Match

Are mainstream benefits that are paid directly to program participants considered match in the CoC Program?

HUD does not consider mainstream benefits provided directly to program participants match in the CoC Program because the benefits are not committed to the recipient/subrecipient for the activities funded through the project. Generally, such benefits are provided to the program participant and are based on program participant eligibility for that respective program. However, if funds from mainstream resources (e.g., TANF or Medicaid) are provided ...
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Match

What are the minimum requirements of a Memorandum of Understanding (MOU) in the CoC Program for match documentation?

A memorandum of understanding (MOU) is a written document that must establish unconditional commitment, upon selection to receive a grant, by the third party to provide the services, the specific service to be provided, the profession of the persons providing the service, and the hourly cost of the service to be provided. At a minimum, a MOU must be executed between a recipient and/or subrecipient and a third party service provider and inclu...
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Match

What are the documentation requirements for in-kind services as match?

Documentation of in-kind service match requires a different approach than documentation of in-kind goods and equipment. The recipient/subrecipient must enter into a formal memorandum of understanding (MOU) with the agency providing the in-kind service(s) and must establish a system to document the actual value of services provided during the term of the grant. A recipient or subrecipient may use a letter from the partner agency to document t...
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Match

What are the documentation requirements for in-kind goods and equipment?

When the source of match is in-kind goods and/or equipment, written documentation must conform to the OMB Circular requirements in 24 CFR Parts 84 and 85 and the standards described below. Written documentation of the donation of in-kind goods and/or equipment must be provided on the source agency's letterhead, signed and dated by an authorized representative of the source agency, and must, at a minimum, include the following: Value of donated g...
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Match

What are the documentation requirements for cash match?

When the source is cash, written documentation should be provided on the source agency's letterhead, signed and dated by an authorized representative, and, at a minimum, should include the following:  Amount of cash to be provided to the recipient for the project; Specific date the cash will be made available; The actual grant and fiscal year to which the cash match will be contributed; Time period during which funding will be available; an...
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Match

What are allowable sources of in-kind match in the CoC Program?

Allowable in-kind match resources may be from public (not statutorily prohibited by the funding agency from being used as a match) or private resources and may include the value of any real property, equipment, goods, or services contributed to the project. The recipient must ensure that any funds used to satisfy the in-kind matching requirements are eligible under the laws governing the services in order to be used as match for a grant awarded u...
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Match

What are allowable sources of cash match in the CoC Program?

Recipients/subrecipients may use funds from any source, including any other federal sources (excluding Continuum of Care Program funds), as well as state, local, and private sources, provided that funds from the source are not statutorily prohibited to be used as a match. The recipient must ensure that any funds used to satisfy the cash match requirements are not prohibited from being used as a match under the laws governing those funds. In gener...
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Match

What is leverage?

Leverage is the non-match cash or non-match in-kind resources committed to making a CoC Program project fully operational. This includes all resources in excess of the required 25 percent match for CoC Program funds as well as other resources that are used on costs that are ineligible in the CoC Program. Leverage funds may be used for any program related costs, even if the costs are not budgeted or not eligible in the CoC Program. Leverage may be...
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Match

What is cash match?

Cash match is actual cash contributed to a CoC Program grant provided that the cash contribution is spent on eligible CoC Program costs outlined in Subpart D of the interim rule (see Section 578.73(b) for more information) in accordance with the requirements of the CoC Program Interim Rule. For more information on the documentation requirements for cash match in the CoC Program, review the CoC 2.0 podcast titled The Importance of Documenting Matc...
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Match

What is in-kind match?

In-kind match is the value of any real property, equipment, goods, or services contributed to a CoC Program grant that would have been eligible costs under the CoC Program if the recipient/subrecipient was required to pay for such costs with CoC Program grant funds.   For more information on the documentation requirements for in-kind match in the CoC Program, review the CoC 2.0 podcast titled The Importance of Documenting Match Under the CoC...
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Match

What are the match requirements in the CoC Program?

Match is actual cash or in-kind resources contributed to the grant. All costs paid for with matching funds must be for activities that are eligible under the CoC Program, even if the recipient is not receiving CoC Program grant funds for that activity. All grant funds must be matched with an amount no less than 25% of the awarded grant amount (excluding the amount awarded to the leasing budget line item) with cash or in-kind resources. Match reso...
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Term of Commitment, Repayment of Grants,
and Prevention of Undue Benefits

For CoC Program projects that are awarded funding for new construction, rehabilitation, or acquisition, how long must the recipient/subrecipient use the structure and/or property constructed, rehabilitated, or acquired to serve homeless individuals and families?

In general, all recipients/subrecipients receiving CoC Program grant funds for acquisition, rehabilitation, or new construction must operate the housing or provide supportive services, in compliance with the McKinney-Vento Act and the CoC Program regulation, for at least 15 years from the date of initial occupancy by a program participant or the date of initial service provision by the recipient/subrecipient. ...
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and Prevention of Undue Benefits
System Performance Measures

Successful housing placement does not seem like a fair measure, as it is dependent on local factors that CoCs cannot control (housing market, etc.). How can HUD expect project types that do not provide housing (e.g. street outreach) to report on successful housing placement?

HUD believes that housing placement is in fact a very important measure and also one that we have asked CoCs to measure even before the system performance measures. Our ultimate goal is, and has been, to help people exit homelessness to a stable housing situation. Keep in mind that “successful” for 7a.1 includes sheltered or temporary situations and not just permanent housing, while the latter two metrics—7b.1 and 7b.2—focus on permanent ...
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System Performance Measures

Several measures are looking at Emergency Shelter data. Our community has sanctioned very structured homeless camps that could provide similar data, however they are not emergency shelters. Is HUD considering a new program type for these types of transitional camp/shelter sites?

At this time, camps are not counted as a separate project type and HUD is not considering adding them as a project type. Camps will continue to be viewed as unsheltered situations for measurement purposes, as indicated in the language in the HEARTH “Homeless” Definition final rule. HUD will continue to learn what it can and provide guidance and technical assistance where needed to assist communities to address encampments, sanctioned or other...
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System Performance Measures

Measure 1 asks for data on ES and SH projects in a single row. Why is HUD including SH with ES data? Before SH was designated as its own housing type, SH projects were considered either TH or PSH. How does it now translate to an ES length of stay calculation?

HUD is not lumping Safe Haven (SH) with Emergency Shelter (ES) but does include it in the first metric under Measure 1, Length of Time Homeless, because SH and ES are the project types that map to the chronically homeless definition. SH is a unique and important program model, and HUD understands that SH stays may be longer than ES stays. SH projects that did not previously reclassify as Transitional Housing (TH) or Permanent Supportive Housing (...
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System Performance Measures

If we are submitting data for the period 10/1/2014 - 9/30/2015, what is the significance of the lookback date provided of 10/1/2012?

The lookback date refers to the earliest date that data from the Homeless Management Information System (HMIS) will be used in order to complete reporting for this reporting year. The relevance of 10/1/2012 is related primarily to the method for calculating Measure 2. This measure begins with clients who exited to a permanent housing destination in the date range two years prior to the report date range. Of those clients, the measure reports on h...
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System Performance Measures

For 7a.1 exits from street outreach: If a Projects for Assistance in Transition from Homelessness (PATH) street outreach project is serving a client who was in Emergency Shelter (ES) when they first contacted the client, should that client count in this measure?

Yes. All clients assisted through PATH street outreach projects and entered in the CoC’s Homeless Managements Information System (HMIS) are included in this measure and should be treated like any other street outreach project for calculation purposes. PATH clients who are in ES when initially enrolled should still have their Destination data (data element 3.12) collected and entered in HMIS. If such client exits PATH and still remains in ES, th...
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System Performance Measures

When determining the universe for Measure 2, how should we count clients that exited from different project types on the same day?

For this question, consider an example where a client exited from both an outreach project and an emergency shelter (ES) project, both with a permanent housing (PH) destination. The Homeless Management Information System (HMIS) programming specifications address many such issues. Generally, HUD discourages having persons in multiple projects at the same time. While this is not always possible, it often is. For instance, with regard to the example...
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System Performance Measures

How far back into Homeless Management Information System (HMIS) data does the Length of Time Homeless Measure (Measure 1) look?

The HMIS Programming Specifications clarify that the length of time goes to either the longest continuous length of time beyond 365 days from the reporting period or to the “lookback” date. CoCs do not include time prior to the lookback date for system data. That means that any time homeless before October 1, 2012, will not be included. When CoCs begin using data from 3.17 (this data element will be renamed 3.9.17 starting 10/1/2016), HUD pla...
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System Performance Measures

Are victim services providers included in any of the data on System Performance Measures?

Victim service provider projects do not enter client-level data into their Homeless Management Information System (HMIS). These projects must enter their data into a comparable database, and therefore will not be included in any calculation of system coverage or in any of the data for the system performance measures. Please note that this only applies to projects that are defined as “victim service providers” under the Violence Against Women ...
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System Performance Measures

I have several projects in my CoC that do not participate in HMIS, and that are not required by any funding source to do so. What impact will their lack of participation have on my CoC?

HUD will take into account Homeless Management Information System (HMIS) bed coverage and data quality in reviewing the system performance measures, and while data collection and quality challenges will be considered in reviewing the measures, it remains a priority to have the most complete data as possible, both through high bed coverage and good data quality. As CoCs strategically plan to meet the needs of persons seeking homeless services, it ...
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System Performance Measures

Several of the Performance Measures refer to “system-level” data. How does HUD define a system? Are SSO projects included? Are RRH projects included? What about projects funded by PATH, ESG, SSVF, VASH, and other funders?

The concept of system performance is that all members involved with the effort of ending homelessness are coordinated to end homelessness. HUD believes that CoCs must see their efforts to end homelessness as a united effort. Most of the system performance measures rely on the use of Homeless Management Information System (HMIS) data that reflects the full system of homeless assistance available in each community, and not just those projects that ...
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System Performance Measures

How will CoCs submit their System Performance Measure data to HUD? When is the data due to HUD?

After running the System Performance Measure report out of your vendor’s Homeless Management Information System (HMIS) software, CoCs will enter that data into HUD’s Homelessness Data Exchange (HDX). For the FY 2016 CoC Program NOFA, the data submission deadline was originally Monday, August 1, 2016 at 7:59:59 PM EDT. However, on July 26, 2016, HUD announced that the deadline has been extended to August 15, 2016 at 7:59:59 PM EDT. View the ne...
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System Performance Measures

We are concerned that some of our numbers may not be accurate or may reflect poorly on our CoC. How can we explain our responses?

Users should leave a note of explanation for each validation warning received or any other field they wish. A note of explanation should be completed for each warning received by clicking on the field with the warning and entering a note. Click on the “Save Notes” box on the bottom left of the notes box to save your explanation.

System Performance Measures
System Performance Measures

Will any data cleaners reach out to contact us following our submission?

No. The submission by the CoC will be considered final.

System Performance Measures
System Performance Measures

Once data is entered in the Homelessness Data Exchange (HDX), can the entry be overwritten? Can we re-submit data if there are errors?

Data can be overwritten, whether manually entered or imported, until the point of submission. Once you have submitted your data, you may request assistance via the HUD Exchange Ask A Question (AAQ) portal if you wish to resubmit prior to the due date.

System Performance Measures
System Performance Measures

What is the source of the Point-in-Time (PIT) Count data that is auto-populated in the Homelessness Data Exchange (HDX)? What if our CoC did not conduct a street count last year?

In 2016, the PIT Count data is auto-populated from the final PIT submission from the January 2015 count. The previous year’s data is populated from the 2014 count, unless no street count was conducted that year. In that case, the 2013 street count is used.

System Performance Measures
System Performance Measures

For submission in the Homelessness Data Exchange (HDX) in 2016, what reporting period should my submission cover? Do I need to submit data to populate the previous period fields?

The reporting period for the System Performance Measures report that will be submitted in HDX in summer 2016 is 10/1/2014 - 9/30/2015. You do not need to submit data to populate the previous period fields. In future years, these fields will be auto-populated with your submissions from prior years.

System Performance Measures
System Performance Measures

What steps should a CoC take if they cannot see the new report or submit button?

In order to be able to access the System Performance Measures (Sys PM) reporting module in the Homelessness Data Exchange (HDX), each CoC must designate a Primary Contact in HDX. The Primary Contact is the contact person for the HUD approved Collaborative Applicant and that individual is responsible for ensuring that HUD receives complete and accurate System Performance Measures data from the CoC. To achieve this, the Collaborative Applicant ofte...
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System Performance Measures

Measure 7b reports on the retention of Permanent Housing. Does HUD have a time frame for retention of permanent housing to be considered successful?

For this measure, HUD does not have a timeframe requirement. Historically, the retention requirement was 6 months. One of the reasons HUD is not focusing on this is because it did not have access to data on returns to homelessness. The data on returns in Measure 2 will capture data on people who do not retain their permanent supportive housing as well as other forms of permanent housing, so together, Measure 2 and 7 cover the cycle of ending home...
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System Performance Measures

Given that no data will be submitted for Measure 6 in 2016, how will the baseline for the Measure be established?

Measure 6 is not applicable to CoCs in 2016, as no CoC has exercised the authority provided by the HEARTH Act to serve homeless families with children and youth defined as homeless under other Federal statutes (see section 422(j)). In future years, if a CoC exercises that flexibility, their baseline year for this measure will be established at that point.

System Performance Measures
System Performance Measures

Why does Measure 4 look only at increased income, rather than maintaining or increasing income like the Annual Performance Report (APR) measures?

The HEARTH Act defined the selection criteria that are the basis for the System Performance Measures. The criterion related to income is “jobs and income growth for homeless individuals and families.” HUD is aware that this system-level measure is different from the project-level measures in the APR.

System Performance Measures
System Performance Measures

Do the System Performance Measures replace the Annual Performance Report (APR)?

No. The APR is still required of all CoC Program recipients, and is a grantee-level report that allows HUD to understand how grant funds were expended and the outcome of those efforts. The System Performance Measures are system-level data that allow HUD to understand how a CoC’s entire system of homeless assistance is performing.

System Performance Measures
System Performance Measures

My CoC covers a very large geography, and we often analyze our data by regions. Is it possible to submit System Performance Measure data by subset or region?

While it is useful to look within your CoC at different regions for your own analysis and planning, for HUD purposes, you will submit a single set of data in the Homelessness Data Exchange (HDX) for the entire CoC. We encourage communities to carefully document the details of their challenges when they submit their data.

System Performance Measures
System Performance Measures

Has HUD set any performance benchmarks or targets for the System Performance Measures?

HUD will be comparing communities to themselves, and will limit the amount of comparison done across CoCs. HUD wants to see positive changes for the entire CoC (such as declines in length of time homeless), but it does not yet have enough data on these measures to know what reasonable benchmarks or targets for improvement would be for any of the measures. HUD will carefully analyze the System Performance Measure data that is submitted to get a be...
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System Performance Measures

Our CoC funds some projects that are located outside of our geography – should those projects be included in our System Performance Measures?

CoCs should only include data on projects within their CoC boundaries. This may involve prorating some projects where there are not clear boundaries. This is most relevant when working with projects funded by other sources, including the U.S. Department of Veterans Affairs (VA). The first place where this would show up is the Housing Inventory Count (HIC). There should be a fairly close relationship between the projects included in the system per...
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System Performance Measures

Has HUD set any system coverage or data quality thresholds for the System Performance Measures, as is currently done for the Annual Homeless Assessment Report (AHAR)?

For the short term, no thresholds have been set. Unlike the AHAR, HUD expects every community to report the System Performance Measure data. HUD may impose data quality factors in its CoC Program NOFA criteria in the future. This would likely apply to both the data quality and bed coverage. For bed coverage, HUD set a standard of 86 percent in the FY 2016 CoC Program NOFA. However, data quality and bed coverage standards will evolve over time as ...
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System Performance Measures

What is the reporting period for the measures?

The reporting period follows the Federal Fiscal Year, which is October 1st through September 30th. For the FY 2016 CoC Program Competition, CoCs will submit data for October 1, 2014 through September 30, 2015. The timeframe allows HUD to gather data in a uniform fashion across all CoCs and the projects in those CoCs, regardless of individual project grant periods.

System Performance Measures
System Performance Measures

How will the System Performance Measure data affect a CoC’s submission for the FY16 CoC Program NOFA?

For the FY 2016 CoC Program Competition, HUD will focus on a CoC’s ability to produce the System Performance Measures data. This is intended to be a test for whether CoCs can run the data. However, data quality is and will continue to be important in producing data and measuring against the CoC’s baseline. HUD expects CoCs to incorporate this data into their larger system improvement activities. Additionally, HUD is aware that this first roun...
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Content current as of February 20, 2024.