The Continuum of Care (CoC) Program stands as a cornerstone initiative by the U.S. Department of Housing and Urban Development (HUD), meticulously crafted to address the multifaceted challenges of homelessness across communities. At its heart, the CoC Program is more than just temporary aid; it’s about fostering continuing care for individuals and families facing homelessness, including unaccompanied youth, guiding them towards stable, permanent housing solutions and long-term independence.
This comprehensive program is designed to be a catalyst for community-wide strategic planning and resource utilization in combating homelessness. It emphasizes enhanced coordination and integration with mainstream support systems and other programs aimed at assisting those experiencing homelessness. Furthermore, the CoC Program prioritizes robust data collection and performance measurement to ensure effectiveness and allows communities the flexibility to tailor their approaches to best suit their unique local contexts and challenges.
Who Can Apply for CoC Program Funding?
Eligibility for CoC Program funding is clearly defined by HUD’s interim rule, targeting a range of organizations capable of making a significant impact. Eligible applicants include:
- Nonprofit organizations
- State governments
- Local governments
- Instrumentalities of State or local governments
It’s important to note that for-profit entities are not eligible to apply directly for grants or to act as subrecipients of these crucial funds.
The application process for HUD funding is competitive and annual. Organizations seeking to participate must submit a project application to the Collaborative Applicant designated by their local CoC. Each CoC appoints a Collaborative Applicant, responsible for compiling and submitting a comprehensive application package to HUD. This package encompasses the CoC application itself, along with individual project applications and their respective rankings within the community’s strategy.
Key Components of the CoC Program for Continuing Care
The CoC Program operates through five core components, each designed to address different aspects of homelessness and contribute to a cohesive Continuing Care Program: Permanent Housing, Transitional Housing, Supportive Services Only, HMIS, and Homelessness Prevention. Administrative costs are eligible across all components, ensuring efficient program operation.
These components are strategically aligned with those of the Emergency Solutions Grants program, streamlining administration for organizations involved in both and ensuring consistent standards for reporting and data quality across similar projects. However, it’s important to note distinctions, particularly in the eligible activities and administration of rapid re-housing assistance.
Let’s delve into each component to understand how they contribute to the overall framework of continuing care:
Permanent Housing: The Goal of Long-Term Stability
Permanent Housing (PH) is defined as community-integrated housing without time limits, designed to enable formerly homeless individuals and families to live as independently as possible. A key feature of PH is that participants must be tenants with leases (or subleases) for an initial term of at least one year, renewable and terminable only for legitimate cause. These leases must also be renewable for minimum terms of one month, providing security and stability.
Alt text: Image depicting a house in a suburban neighborhood, symbolizing permanent housing and stability for individuals and families.
The CoC Program supports two primary types of permanent housing:
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Permanent Supportive Housing (PSH): This is continuing care focused permanent housing for individuals with disabilities and families where an adult or child member has a disability. It combines indefinite rental assistance with supportive services aimed at achieving and maintaining housing stability.
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Rapid Re-housing (RRH): Rapid re-housing is designed to quickly move homeless individuals and families (with or without disabilities) into permanent housing. It emphasizes housing search and relocation services, along with short- to medium-term rental assistance to facilitate a swift transition to stable living.
Transitional Housing: Interim Support for the Journey to Permanence
Transitional Housing (TH) provides crucial interim stability and support to homeless individuals and families, preparing them for successful transitions to and maintenance of permanent housing. It can cover housing costs for up to 24 months, coupled with essential supportive services. Participants in transitional housing are required to have a lease (or sublease) or occupancy agreement, ensuring a structured and supportive living environment.
Alt text: A group of people gathered in a community room setting, representing transitional housing and the supportive community it provides for residents.
Supportive Services Only: Coordinated Entry and Beyond
The Supportive Services Only component is specifically targeted towards the entity designated by the CoC to lead its coordinated entry process. HUD mandates that each CoC establishes and operates a coordinated entry process to streamline local crisis response systems and enhance access to resources, including mainstream services.
Funds from Supportive Services Only – Coordinated Entry (SSO-CE) grants are used for a range of supportive services directly related to coordinated entry activities. This includes outreach to both sheltered and unsheltered homeless individuals and families, encompassing initial assessments, crisis counseling, addressing immediate physical needs, and connecting individuals with housing and other vital resources.
While stand-alone SSO grants are no longer available for entities other than the CE Lead Agency, recipients and subrecipients can still access supportive service funds to provide services to homeless individuals and families who are not residing in housing operated by the recipient. These services can be delivered in centralized or scattered sites, or even through street outreach programs, adapting to diverse community needs.
Homeless Management Information System: Data-Driven Support
The Homeless Management Information System (HMIS) component is exclusively for HMIS Lead Agencies, the entities designated by the CoC to manage the CoC’s HMIS.
HMIS funds support the infrastructure of data management, covering costs such as leasing and operating facilities housing the HMIS, and other expenses related to establishing, operating, and customizing the CoC’s HMIS. While other recipients and subrecipients cannot directly apply for HMIS funds, they can include HMIS-related costs within their project budgets under other program components, recognizing the importance of data contribution to the overall continuing care system.
Homelessness Prevention: Proactive Intervention
Recipients and subrecipients in HUD-designated High Performing Communities (HPCs) are eligible to utilize CoC Program funds for homelessness prevention assistance. This is a proactive approach aimed at individuals and families at risk of homelessness. The annual CoC Program Notice of Funding Opportunity (NOFO) provides details on HPC designation.
Homelessness prevention services can include housing relocation and stabilization services, as well as short- and medium-term rental assistance. This component enables recipients and subrecipients to assist at-risk individuals and families in maintaining their current housing or transitioning to new permanent housing, preventing homelessness before it occurs. Homelessness prevention activities must adhere to 24 CFR part 576 regulations.
Important Program Component Changes
It’s important to note some changes in the CoC Program components:
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Safe Havens: This program component is no longer available for new projects under the CoC Program. However, existing Safe Haven projects eligible under the McKinney-Vento Act may be renewed to continue essential operations and services.
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Section 8 Moderate Rehabilitation SRO: Similarly, the Section 8 Moderate Rehabilitation SRO Program component is closed to new projects. Current SRO projects will continue to be renewed under the Multifamily Assisted Housing Reform and Affordability Act of 1997.
Understanding Eligible Costs for CoC Program Funds
The CoC Program interim rule specifies eligible costs for each program component, ensuring funds are used effectively and appropriately. Not all costs are eligible under every component, and certain costs cannot be combined within a single unit or structure. Costs related to HMIS data contribution are eligible across all components, highlighting the program’s data-centric approach.
Here’s a summary of eligible cost categories:
Real Estate and Housing Costs
- Acquisition: Funds can cover up to 100% of the cost of purchasing property for permanent housing, transitional housing, and supportive services only activities.
- Rehabilitation: Eligible for PH, TH, and SSO components, including energy-saving measures and health and safety upgrades. Rehabilitation of leased properties is not eligible.
- New Construction: Eligible for PH and TH, including new facilities or significant additions. Construction must be proven more cost-effective than rehabilitation. New construction on leased properties is not eligible.
- Leasing Costs: Eligible under PH, TH, SSO, and HMIS, for leasing units or structures. Rents must be reasonable and cannot exceed HUD Fair Market Rents (FMRs). Leasing from related organizations is restricted without HUD authorization.
- Rental Assistance Costs: Eligible under PH and TH, can be tenant-based (TBRA), sponsor-based (SBRA), or project-based (PBRA). Assistance can be short-, medium-, or long-term, depending on the component.
Operational and Support Costs
- Supportive Services Costs: Eligible under PH, TH, and SSO, covering a wide range of services detailed in the CoC Program interim rule. Services must be provided throughout residency in PSH and TH, and RRH programs require at least monthly case manager meetings. Services can extend up to six months post-homelessness exit.
- Operating Costs: Eligible under PH, TH, and HMIS for day-to-day costs like maintenance, utilities, security, furniture, insurance, and taxes. These cannot be combined with rental assistance in the same unit, and are not eligible under SSO.
- HMIS Costs: Covers hardware, software, training, staffing, and overhead related to HMIS data management.
Administrative and Planning Costs
- Project Administration: Up to 10% of any grant (excluding CoC planning and UFA costs) can be used for administrative expenses like management, coordination, monitoring, evaluation, and environmental review.
- CoC Planning Costs: Exclusively for the Collaborative Applicant, for activities like community-wide planning, coordinated entry design (not implementation), outcome evaluation, application preparation, and recipient monitoring.
- Unified Funding Agency (UFA) Costs: For Collaborative Applicants designated as UFAs, to ensure sound financial management and annual audits of subrecipient projects.
Conclusion: The CoC Program as a Foundation for Continuing Care
The Continuum of Care Program is a vital framework for communities to effectively address homelessness through a structured and continuing care approach. By providing funding across a spectrum of housing and service components, the CoC Program empowers communities to create comprehensive systems that not only address immediate housing needs but also foster long-term stability and independence for individuals and families experiencing homelessness. Understanding the intricacies of the CoC Program – from eligibility and program components to eligible costs – is crucial for organizations dedicated to making a tangible difference in the lives of those experiencing homelessness and building stronger, more resilient communities.
