The Continuum of Care (CoC) Program is a U.S. Department of Housing and Urban Development (HUD) initiative meticulously crafted to support individuals and families experiencing homelessness. This includes unaccompanied youth, providing them with essential services to facilitate their transition into transitional and permanent housing, ultimately fostering long-term stability.
More broadly, the CoC Program champions community-wide strategic planning and resource allocation to combat homelessness effectively. It aims to enhance coordination and integration with mainstream resources and other programs designed for people facing homelessness. The program also prioritizes improved data collection and performance measurement. Crucially, it empowers each community to customize its programs, addressing the unique strengths and challenges in assisting homeless individuals and families within their specific locale.
Eligible Applicants for the Continuum of Care Program
Organizations seeking CoC Program funding must meet specific eligibility criteria as defined in the CoC Program interim rule. Eligible applicants encompass nonprofit organizations, States, local governments, and instrumentalities of State or local governments. It’s important to note that for-profit entities are not eligible to apply for grants or to serve as subrecipients of grant funds.
The process for organizations to apply for HUD funding involves an annual competition. Eligible applicants are required to submit a project application to the CoC’s designated Collaborative Applicant organization. Each CoC designates a single organization to act as the Collaborative Applicant. This Collaborative Applicant is responsible for submitting the complete application package, which includes the CoC application, individual project applications, and their respective rankings.
Program Components of the Continuum of Care Program
The CoC Program interim rule outlines five core program components that can be funded: Permanent Housing, Transitional Housing, Supportive Services Only, HMIS (Homeless Management Information System), and, under specific circumstances, Homelessness Prevention. Administrative costs are eligible across all components.
The design of these components prioritizes consistency with those of the Emergency Solutions Grants program where feasible. This alignment simplifies administrative processes for recipients involved in both programs and ensures consistent reporting requirements and data quality benchmarks for similar projects. A notable distinction between the Emergency Solutions Grants Program and the CoC Program lies in the eligible activities and administration requirements for rapid re-housing assistance, as detailed in the interim rule.
The five primary program components funded through the Continuum of Care Program are detailed below:
Permanent Housing (PH) under the CoC Program
Permanent housing (PH) within the Continuum of Care Program is defined as community-based housing without a set length of stay. It’s designed for formerly homeless individuals and families to live as independently as possible. Under the PH framework, program participants must be the leaseholder (or subleaseholder) for an initial term of at least one year, with automatic renewal and termination only for cause. Furthermore, these leases (or subleases) must be renewable for minimum terms of one month.
The CoC Program supports two primary types of permanent housing: permanent supportive housing (PSH) and rapid re-housing (RRH).
- Permanent Supportive Housing (PSH): PSH provides permanent housing coupled with indefinite leasing or rental assistance and supportive services. This is targeted towards homeless individuals with disabilities or families with a disabled adult or child member, aiming to achieve housing stability.
- Rapid Re-housing (RRH): RRH prioritizes swift transitions into permanent housing for homeless individuals and families (with or without disabilities). It emphasizes housing search and relocation services alongside short- to medium-term rental assistance.
Transitional Housing (TH) within the CoC Program
Transitional housing (TH) within the Continuum of Care Program is structured to offer interim stability and support to homeless individuals and families. The goal is to facilitate their successful transition to and maintenance of permanent housing. TH funding can cover housing costs for up to 24 months, accompanied by supportive services. Program participants in transitional housing are required to have a lease (or sublease) or occupancy agreement in place during their residency.
Supportive Services Only (SSO) under the CoC Program
Funding for Supportive Services Only (SSO) under the Continuum of Care Program is exclusively available to the entity designated by the CoC to lead its coordinated entry process. HUD mandates that each CoC establishes and operates a coordinated entry process. This process aims to enhance the efficiency of local crisis response systems and improve access to resources, including mainstream services.
SSO grants, specifically Supportive Services Only – Coordinated Entry (SSO-CE) grants, can fund a range of supportive services directly related to coordinated entry (CE) activities. These include outreach to sheltered and unsheltered homeless individuals and families (encompassing initial assessment, crisis counseling, and addressing urgent physical needs) and connecting people experiencing homelessness with housing and other 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 services funds to provide services to homeless individuals and families who are not residing in housing operated by the recipient. These supportive services can be offered in a centralized structure or across multiple scattered sites. Projects can also operate independently of a building, such as street outreach, and in diverse community-based settings, including homeless programs run by other agencies.
Homeless Management Information System (HMIS) under the CoC Program
Funds for the Homeless Management Information System (HMIS) component of the Continuum of Care Program are restricted to HMIS Lead Agencies. The HMIS Lead Agency is designated by the CoC to operate the CoC’s HMIS on its behalf.
Under the HMIS component, funding can cover leasing and operating a structure housing the HMIS, and/or other 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 can include HMIS-related costs within their projects under other program components (PH, TH, SSO, or HP), specifically costs associated with contributing data to the CoC’s HMIS.
Homelessness Prevention under the CoC Program
Recipients and subrecipients situated in HUD-designated High Performing Communities (HPCs) may utilize Continuum of Care Program funds for homelessness prevention assistance. This assistance targets individuals and families at risk of homelessness. The annual CoC Program Notice of Funding Opportunity (NOFO) provides further details about CoC designation as an HPC.
Services under this component may include housing relocation and stabilization services, as well as short- and medium-term rental assistance to prevent homelessness. Through this component, recipients and subrecipients can assist at-risk individuals and families in maintaining their current housing or transitioning to new permanent housing. Homelessness prevention activities must adhere to 24 CFR part 576.
Other Components of the CoC Program
Safe Havens
The Safe Haven program component is no longer an eligible component under the Continuum of Care Program for new projects. However, existing Safe Haven projects, and all projects eligible under the McKinney-Vento Act before the HEARTH Act passage, may be renewed. This renewal allows for continued leasing, operations, supportive services, rental assistance, HMIS operation, and administrative functions beyond the initial funding period. The annual CoC Program Notice of Funding Opportunity (NOFO) will provide further details.
Section 8 Moderate Rehabilitation SRO
Similarly, the Section 8 Moderate Rehabilitation SRO Program component is no longer eligible for new projects under the Continuum of Care Program. Current SRO projects will continue to be renewed under the Multifamily Assisted Housing Reform and Affordability Act of 1997.
Eligible Costs under the Continuum of Care Program
The CoC Program interim rule specifies eligible costs for each program component. It’s crucial to note that not all costs are eligible under every component, and certain costs may not be combined within a single unit or structure. Costs associated with contributing data to the CoC-designated HMIS are eligible across all components.
A summary of eligible costs is provided below:
Acquisition Costs
Acquisition of real property is an eligible cost category under the PH, TH, and SSO program components of the Continuum of Care Program. Grant funds can cover up to 100 percent of the cost of purchasing property for permanent housing, transitional housing, and supportive services only activities.
Rehabilitation Costs
Rehabilitation of structures is an eligible cost under the PH, TH, and SSO program components. Eligible rehabilitation costs include installing energy-saving measures and upgrading structures to meet health and safety standards. Rehabilitation on leased properties is not eligible.
New Construction Costs
New construction of structures is eligible under the PH and TH program components. This can include building entirely new facilities, constructing additions that increase floor area by 100 percent or more, and the cost of land for construction. Projects must demonstrate that new construction is more cost-effective than rehabilitation. The CoC Program interim rule does not set maximum grant limits for rehabilitation or new construction. CoC Program funds can cover up to 100 percent of costs, provided the match requirement is met through other resources. New construction on leased properties is not eligible.
Leasing Costs
Leasing is an eligible cost under the PH, TH, SSO, and HMIS program components. Funds can be used to lease individual units or entire structures or parts of structures. Rents must be reasonable and, for individual units, must not 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 within a partnership that owns the structure, without HUD authorization. When leasing funds are used for units, the lease must be between the recipient or subrecipient and the landowner, with a sublease or occupancy agreement for the program participant. Recipients may, but are not required to, charge program participants rent or occupancy charges, following interim rule parameters.
Rental Assistance Costs
Rental assistance is an eligible cost under the PH and TH program components and can be tenant-based (TBRA), sponsor-based (SBRA), or project-based (PBRA), depending on the component type. Rental assistance can be short-term (up to 3 months), medium-term (3 to 24 months), or long-term (over 24 months). The assistance duration depends on the funding component. Recipients must serve the number of program participants specified in their HUD funding application. If funds reserved for the grant term exceed actual costs, excess funds can be used for property damage, rent increases, or to serve more program participants.
- TBRA: Participants can choose any appropriately sized unit within the CoC’s geographic area, with potential restrictions on location by recipients or subrecipients to ensure supportive service availability.
- SBRA: Participants must reside in housing owned or leased by a sponsor organization, arranged through a contract with the recipient.
- PBRA: Participants must live in housing provided through a contract with an owner who agrees to lease subsidized units to program participants. Rental assistance is not portable if participants relocate outside the project.
When rental assistance funds are used, the lease must be between the program participant and the landowner. Each participant receiving rental assistance must contribute towards rent as per interim rule requirements.
Supportive Services Costs
Supportive services are eligible costs under the PH, TH, and SSO program components. The CoC Program interim rule specifies all eligible services, and any service not listed is ineligible. Services must be offered to PSH and TH residents for their entire residency. RRH programs must require at least monthly meetings between program participants and a case manager.
Services can be provided to formerly homeless individuals for up to six months after exiting homelessness, including the six months following transitional housing exit. Recipients and subrecipients must annually assess program participants’ service needs and adjust services accordingly. Eligible costs include service provision costs, staff salaries and benefits for service providers, and materials and supplies used in service delivery.
Operating Costs
Operating costs are eligible under the PH, TH, and HMIS program components. Funds can cover day-to-day operating costs in single structures or individual housing units, including maintenance (e.g., scheduled system replacements), repair, building security (if CoC Program funds cover over 50% of the facility by unit or area), utilities (electricity, gas, water), furniture, equipment, property insurance, and taxes. Operating costs cannot be combined with rental assistance costs within the same unit or structure and are not eligible under the SSO program component.
HMIS Costs
Costs related to contributing client data to or maintaining data in the CoC’s HMIS or comparable databases for victim services or legal services providers are eligible under the PH, TH, SSO, and HMIS program components. Eligible HMIS costs include hardware, software, and equipment; training and overhead; and staffing costs for data contribution to the CoC-designated HMIS for its geographic area.
Project Administration Costs
Recipients and subrecipients can use up to 10 percent of any grant (excluding CoC planning and Unified Funding Agency (UFA) costs from the CoC Program NOFO) for project administrative costs. These costs include expenses for overall grant administration (24 CFR part 578.59), such as management, coordination, monitoring, evaluation, and environmental review activities.
CoC Planning Costs
CoC Planning funds are exclusively for the CoC’s designated Collaborative Applicant and are awarded through a specific CoC Planning grant. Funds must be used for activities outlined in the interim rule, such as developing community-wide or region-wide coordination processes involving stakeholders and individuals with lived experience of homelessness, designing a coordinated entry process (excluding implementation), evaluating outcomes for CoC Program and Emergency Solutions Grant (ESG) program funded projects, preparing and submitting the annual HUD application on behalf of the CoC, and monitoring recipients and subrecipients for program compliance.
Unified Funding Agency (UFA) Costs
UFA costs funds are available only to Collaborative Applicants designated as a Unified Funding Agency (UFA) by HUD through the annual NOFO process and are awarded via a specific UFA Costs grant. Funds can be used for ensuring all financial transactions under the CoC Program are conducted and recorded according to generally accepted accounting principles. This includes arranging annual surveys, audits, or evaluations of financial records for each subrecipient project funded by a CoC Program grant.
