The HUD Continuum of Care (CoC) Program stands as a cornerstone initiative by the U.S. Department of Housing and Urban Development (HUD). It is meticulously crafted to empower communities in their efforts to combat homelessness. This program provides crucial assistance to individuals and families grappling with homelessness, including unaccompanied youth, offering a pathway towards transitional and permanent housing solutions. The ultimate aim of the CoC Program is to foster long-term stability and self-sufficiency among those it serves.
More than just providing housing, the CoC Program embodies a holistic approach to tackling homelessness. It is designed to galvanize community-wide planning and the strategic deployment of resources to effectively address this complex issue. The program emphasizes enhanced coordination and integration with mainstream resources and other initiatives dedicated to assisting individuals experiencing homelessness. Furthermore, it prioritizes the improvement of data collection and performance measurement to ensure accountability and effectiveness. Recognizing the unique challenges and strengths of each community, the CoC Program allows for tailored approaches, enabling each locality to customize its programs to best assist its homeless population.
Who Can Apply for CoC Program Funding?
Eligibility for CoC Program funding is clearly defined to ensure that resources are directed to capable and committed organizations. According to the CoC Program interim rule, eligible applicants encompass:
- Nonprofit organizations
- State governments
- Local governments
- Instrumentalities of State or local governments
It is important to note that for-profit entities are not eligible to apply for grants directly or to serve as subrecipients of grant funds.
Funding from HUD is accessed through an annual competitive process. Organizations seeking to participate must submit a project application to the Collaborative Applicant designated by their local CoC. Each CoC appoints a Collaborative Applicant, which is responsible for compiling and submitting the complete application package to HUD. This package includes the CoC application itself, along with all individual project applications and their respective rankings as determined by the CoC.
Key Program Components
The CoC Program interim rule outlines five core program components that can be funded. These components are designed to address various aspects of homelessness and provide a comprehensive spectrum of assistance:
- Permanent Housing
- Transitional Housing
- Supportive Services Only
- Homeless Management Information System (HMIS)
- Homelessness Prevention (in specific cases)
Administrative costs are recognized as eligible across all program components, acknowledging the operational needs of these vital projects.
To streamline administration and ensure consistency, the components of the CoC Program align, where feasible, with those of the Emergency Solutions Grants program. This harmonization simplifies the process for organizations participating in both programs and promotes standardized reporting and data quality benchmarks across similar project types. A notable distinction between the two programs lies in the specific activities and administrative requirements for rapid re-housing assistance, as detailed in the CoC Program interim rule.
Let’s delve deeper into each of the five program components:
Permanent Housing (PH)
Permanent housing (PH) is defined as long-term, community-based housing without mandated time limits, designed to foster independent living for individuals and families who were formerly homeless. In PH arrangements, program participants are required to be the leaseholder (or sub-leaseholder) with an initial lease term of at least one year, renewable and terminable only for legitimate cause. Furthermore, all leases (or subleases) must be renewable for a minimum term of one month thereafter, ensuring housing security.
The CoC Program supports two distinct types of permanent housing:
- Permanent Supportive Housing (PSH): This is permanent housing coupled with ongoing supportive services and indefinite leasing or rental assistance. PSH is specifically targeted towards homeless individuals with disabilities or families where an adult or child member has a disability. The goal of PSH is to help these individuals and families achieve and maintain long-term housing stability.
- Rapid Re-Housing (RRH): Rapid re-housing prioritizes swiftly moving homeless individuals and families (with or without disabilities) into permanent housing. RRH initiatives focus on housing search and relocation services, combined with short- to medium-term rental assistance to facilitate a quick transition into stable housing.
Transitional Housing (TH)
Transitional housing (TH) serves as an intermediate step for homeless individuals and families. It is designed to offer temporary stability and the necessary support services to enable a successful transition to and maintenance of permanent housing. CoC Program funds can cover costs associated with transitional housing for up to 24 months, including supportive services provided during this period. Program participants in transitional housing are required to have a lease (or sublease) or an occupancy agreement in place during their residency, ensuring clear terms of occupancy.
Supportive Services Only (SSO)
Funds allocated under the Supportive Services Only (SSO) component are specifically designated for the entity leading the CoC’s coordinated entry process. HUD mandates that each CoC establish and operate a coordinated entry process. This process aims to streamline local crisis response systems, enhance access to resources (including mainstream services), and ensure efficient service delivery.
Alt text: A diverse group of individuals stands in front of a building, representing the community-focused aspect of the HUD Continuum of Care program.
SSO grants, specifically designated as Supportive Services Only – Coordinated Entry (SSO-CE) grants, can be used for a range of supportive services directly related to coordinated entry activities. These services include outreach to sheltered and unsheltered homeless individuals and families (encompassing initial assessments, crisis counseling, and addressing immediate physical needs) and connecting individuals experiencing homelessness with housing and other essential resources.
While general SSO grants are no longer available for entities that are not the CE Lead Agency, recipients and subrecipients can still receive supportive service funds to provide services to homeless individuals and families who are not residing in housing directly operated by the recipient. These supportive services can be delivered in centralized locations or through scattered-site models within the community. Projects may also operate independently of physical buildings, such as street outreach programs, and can be implemented in various community-based settings, including homeless programs managed by other agencies.
Homeless Management Information System (HMIS)
The Homeless Management Information System (HMIS) component is exclusively for HMIS Lead Agencies. The HMIS Lead Agency is the entity designated by the CoC to manage and operate the CoC’s HMIS on its behalf.
HMIS funds can be utilized for leasing and operating the physical structure housing the HMIS, as well as for covering other essential costs associated with establishing, operating, and customizing a CoC’s HMIS. While other recipients and subrecipients cannot directly apply for HMIS program component funds, they are permitted to include costs related to contributing data to the CoC’s HMIS within their project budgets under other program components (PH, TH, SSO, or HP). This ensures comprehensive data collection and management across all CoC-funded projects.
Homelessness Prevention
In HUD-designated High Performing Communities (HPCs), recipients and subrecipients have the option to utilize CoC Program funds for homelessness prevention assistance. This assistance is targeted towards individuals and families who are identified as being at risk of homelessness. The annual CoC Program Notice of Funding Opportunity (NOFO) provides detailed information regarding the criteria and process for CoCs to apply for HPC designation.
Alt text: A happy family stands in front of their new house, symbolizing the goal of the HUD CoC program to achieve housing stability and prevent homelessness.
Services offered under the homelessness prevention component can include housing relocation and stabilization services, along with short- and medium-term rental assistance. These interventions are designed to help at-risk individuals and families maintain their current housing situation or transition to new, permanent housing, thereby preventing them from experiencing homelessness altogether. Homelessness prevention activities funded by the CoC Program must be administered in full compliance with 24 CFR part 576.
Other Program Components: Status Updates
It’s important to note the current status of two previously available program components:
Safe Havens
The Safe Haven program component is no longer an eligible option for new projects under the CoC Program. While no new Safe Haven projects will be funded, the CoC Program interim rule explicitly allows for the renewal of existing Safe Haven projects. This renewal provision ensures the continuation of leasing, operations, supportive services, rental assistance, HMIS operation, and administrative functions for projects that were eligible under the McKinney-Vento Act prior to the HEARTH Act’s passage. The annual CoC Program Notice of Funding Opportunity (NOFO) will provide further details on renewal processes.
Section 8 Moderate Rehabilitation SRO
Similarly, the Section 8 Moderate Rehabilitation SRO Program component is also no longer available for new projects under the CoC Program. No new SRO projects will be funded. However, existing SRO projects will continue to be renewed under the Multifamily Assisted Housing Reform and Affordability Act of 1997, ensuring ongoing support for these housing units.
Understanding Eligible Costs
The CoC Program interim rule meticulously outlines the costs that are eligible for funding under each program component. It’s crucial to recognize that not all costs are eligible across every component, and certain cost combinations may be restricted within a single unit or structure. Notably, costs associated with contributing data to the CoC-designated HMIS are considered eligible across all program components, emphasizing the importance of data-driven approaches.
Here’s a summary of the eligible cost categories:
Acquisition
Acquisition of real property is an eligible cost under the Permanent Housing (PH), Transitional Housing (TH), and Supportive Services Only (SSO) program components. Grant funds can cover up to 100 percent of the costs associated with purchasing property for the purpose of providing permanent housing, transitional housing, and supportive services activities.
Rehabilitation
Rehabilitation of existing structures is an eligible cost category for PH, TH, and SSO components. Eligible rehabilitation activities include installing energy-saving measures and bringing structures up to required health and safety standards. However, rehabilitation of leased properties is not eligible for CoC Program funding.
New Construction
New construction of structures is eligible under both the PH and TH program components. This can include building entirely new facilities, constructing additions to existing structures that increase the floor area by 100 percent or more, and the cost of land acquisition for construction. Projects involving new construction must demonstrate that it is a more cost-effective solution compared to rehabilitation. Unlike previous regulations, the CoC Program interim rule does not impose maximum grant limits for rehabilitation or new construction, allowing for up to 100 percent funding coverage as long as the matching requirement is met through other resources. New construction on leased properties is not eligible.
Leasing Costs
Leasing is an eligible cost category across PH, TH, SSO, and HMIS program components. Funds can be used to lease individual housing units or entire structures or portions thereof. Rents must be reasonable and, in the case of individual units, cannot exceed HUD-determined Fair Market Rents (FMRs). Leasing funds cannot be used for units or structures owned by the recipient, subrecipient, their parent organizations, related organizations, or organizations that are part of a partnership owning the structure, unless a specific HUD-authorized exception is granted. When leasing funds are used for rental units, the lease must be between the recipient or subrecipient and the landowner, with a sublease or occupancy agreement established with the program participant. Recipients have the option, but are not obligated, to charge program participants rent or occupancy charges, adhering to the guidelines specified in the interim rule.
Rental Assistance Costs
Rental assistance is an eligible cost under the PH and TH program components. It can be provided in three forms, depending on the component type: tenant-based (TBRA), sponsor-based (SBRA), or project-based (PBRA). Rental assistance can be short-term (up to 3 months), medium-term (3 to 24 months), or long-term (over 24 months), with the duration determined by the specific program component. Recipients are required to serve the number of program participants outlined in their HUD funding application. If the funds allocated for the grant term exceed actual rental assistance costs, the surplus can be used to cover property damage, rent increases, or to extend assistance to a greater number of program participants.
- TBRA: Program participants can choose any suitable unit within the CoC’s geographic area. However, recipients or subrecipients may impose location restrictions in certain circumstances to ensure access to appropriate supportive services.
- SBRA: Program participants must reside in housing owned or leased by a sponsor organization, arranged through a contract between the recipient and the sponsor organization.
- PBRA: Program participants are required to live in housing provided through a contract with a property owner, where the owner agrees to lease subsidized units to program participants. Participants in PBRA programs cannot retain their rental assistance if they move to a unit outside the designated project.
When rental assistance funds are used for units, the lease must be between the program participant and the landowner. Each program participant receiving rental assistance is required to contribute towards rent, consistent with the requirements outlined in the interim rule.
Supportive Services Costs
Supportive services are eligible costs under the PH, TH, and SSO program components. The CoC Program interim rule provides a detailed list of all eligible services, clarifying that any service not specifically listed is ineligible for funding. Services must be consistently offered to residents of PSH and TH for the entire duration of their residency. RRH programs must mandate that program participants meet with a case manager at least once per month to ensure ongoing support and progress towards self-sufficiency.
Supportive services can be extended to formerly homeless individuals for up to six months after they exit homelessness, including the six months following their departure from a transitional housing project. Recipients and subrecipients are required to conduct an annual assessment of the service needs of their program participants and adjust service delivery accordingly to meet evolving needs. Eligible costs include the direct costs of providing services, staff salaries and benefits for service providers, and necessary materials and supplies used in service delivery.
Operating Costs
Operating costs are eligible under the PH, TH, and HMIS program components. Funds can be used to cover day-to-day operating expenses in single structures or individual housing units. These costs include maintenance (such as scheduled replacement of major systems), repairs, building security (when CoC Program funds cover more than 50 percent of the facility by unit or area), utilities (electricity, gas, water), furniture, equipment, property insurance, and property taxes. It is important to note that operating costs cannot be combined with rental assistance costs within the same unit or structure, and operating costs are not eligible under the SSO program component.
HMIS Costs
Costs directly related to contributing client data to or maintaining data within the CoC’s HMIS, or a comparable database for victim services providers or legal services providers, are eligible costs under the PH, TH, SSO, and HMIS program components. Eligible HMIS costs encompass hardware, equipment, and software, training and overhead expenses, and staffing costs associated with contributing data to the HMIS designated by the CoC for its geographic area. This broad eligibility underscores the importance of robust data management in effective homelessness programs.
Project Administration
Recipients and subrecipients are permitted to allocate up to 10 percent of any grant (excluding funds for CoC planning and Unified Funding Agency (UFA) costs) obtained through the CoC Program NOFO for project administrative costs. These costs cover expenses related to the overall management and administration of the grant (as defined in 24 CFR part 578.59), such as general management, coordination, monitoring, evaluation activities, and environmental reviews. This allocation recognizes the necessary administrative infrastructure to ensure successful project implementation.
CoC Planning Costs
CoC Planning funds are exclusively for the CoC’s designated Collaborative Applicant and are awarded through a separate CoC Planning grant. These funds must be used for specific activities outlined in the interim rule, such as developing community-wide or region-wide processes involving diverse stakeholders and individuals with lived experience of homelessness. This includes designing a coordinated entry process (though not its implementation), evaluating outcomes for projects funded under the CoC Program and the Emergency Solutions Grant (ESG) program, preparing and submitting the annual application to HUD on behalf of the CoC, and monitoring recipients and subrecipients to ensure compliance with program requirements.
Unified Funding Agency (UFA) Costs
UFA costs funds are available only to Collaborative Applicants that HUD has designated as a Unified Funding Agency (UFA) through the annual NOFO process, and these funds are awarded through a specific UFA Costs grant. These funds are designated for costs associated with ensuring sound financial management of the CoC Program. This includes ensuring that all financial transactions are conducted and records are maintained in accordance with generally accepted accounting principles. UFA funds also support arranging for an annual survey, audit, or evaluation of the financial records of each project carried out by a subrecipient funded through the CoC Program.
The Hud Continuum Of Care Program represents a significant investment in addressing homelessness across the nation. By understanding its components, eligibility criteria, and funding mechanisms, communities can effectively leverage this program to create meaningful and lasting solutions for those experiencing homelessness.
