The Continuum of Care (CoC) Program is a vital initiative designed to support individuals and families facing homelessness, including unaccompanied youth. It provides essential services to facilitate their transition into transitional and permanent housing, ultimately aiming for long-term stability. This program is not directly related to automotive repair, but understanding community programs can be valuable for business owners and individuals alike. This guide offers a detailed look at the CoC Program, its components, and how it functions within communities.
More broadly, the CoC Program serves as a cornerstone for community-wide planning and the strategic allocation of resources to effectively combat homelessness. It enhances coordination and integration with mainstream resources and other programs specifically targeted at assisting those experiencing homelessness. Furthermore, it focuses on improving data collection and performance measurement to ensure accountability and effectiveness. Crucially, the program empowers each community to tailor its strategies and programs to address the unique strengths and challenges present in assisting their homeless populations. This localized approach ensures that solutions are relevant and impactful within each specific community context.
Who Can Apply for CoC Program Funding?
Eligibility to apply for CoC Program funding is clearly defined to ensure that resources are directed to capable and relevant organizations. According to the CoC Program interim rule, eligible applicants include:
- Nonprofit Organizations: These form the backbone of many community support systems and are crucial in direct service provision.
- State Governments: State-level involvement ensures broader reach and coordination across larger geographical areas.
- Local Governments: Local government agencies are essential for implementing programs tailored to specific community needs.
- Instrumentalities of State or Local Governments: This category encompasses public agencies or bodies created by state or local governments to carry out specific functions, including homelessness assistance.
It is important to note that for-profit entities are explicitly ineligible to apply for grants or to act as subrecipients of grant funds. This restriction ensures that the focus remains on mission-driven organizations dedicated to public service rather than profit-making ventures.
The application process for HUD funding operates on an annual competitive basis. Organizations seeking funding must submit a project application to the CoC’s designated Collaborative Applicant organization. Each CoC designates a single organization to serve as the Collaborative Applicant, streamlining the application process. This Collaborative Applicant is responsible for submitting the complete application package, which includes the overarching CoC application along with individual project applications and their respective rankings. This consolidated approach ensures a coordinated and strategic funding distribution process within each community.
Key Program Components of the Continuum of Care
The CoC Program interim rule outlines five core program components through which funds can be channeled to address homelessness effectively. These components are designed to provide a comprehensive range of interventions and support services:
- Permanent Housing (PH): Providing long-term housing solutions for individuals and families.
- Transitional Housing (TH): Offering temporary housing and support to facilitate the move to permanent housing.
- Supportive Services Only (SSO): Funding services independent of housing to connect individuals with resources and support.
- Homeless Management Information System (HMIS): Supporting data collection and management to improve program effectiveness.
- Homelessness Prevention: In specific cases, funds can be used to prevent individuals and families from becoming homeless.
Notably, administrative costs are eligible across all five program components, acknowledging the necessary overhead for effective program management.
The CoC Program components are intentionally aligned with those of the Emergency Solutions Grants program wherever feasible. This consistency aims to reduce the administrative burden on organizations managing both programs and ensures standardized reporting requirements and data quality benchmarks across similar projects. However, a key distinction exists in the eligible activities and administration requirements for rapid re-housing assistance within the CoC Program, highlighting the program’s tailored approach to specific housing solutions.
Let’s delve deeper into each of these five program components:
Permanent Housing: A Stable Foundation
Permanent housing (PH) is defined as community-based housing that offers indefinite stays, allowing formerly homeless individuals and families to live as independently as possible. A crucial aspect of PH is the tenant’s rights and responsibilities: program participants must be the leaseholder (or sub-leaseholder) with an initial lease term of at least one year, renewable and terminable only for cause. Furthermore, lease renewals must be for a minimum term of one month, providing tenants with security and stability.
The CoC Program supports two primary types of permanent housing:
- Permanent Supportive Housing (PSH): This is permanent housing coupled with ongoing supportive services for individuals with disabilities or families with a disabled member. PSH aims to help them achieve and maintain housing stability through integrated support.
- Rapid Re-housing (RRH): Rapid re-housing focuses on quickly moving homeless individuals and families (with or without disabilities) into permanent housing through housing search assistance, relocation services, and short- to medium-term rental assistance. The emphasis is on speed and efficiency in securing permanent housing.
Transitional Housing: A Bridge to Permanence
Transitional housing (TH) is designed to offer homeless individuals and families temporary stability and support, acting as a bridge to permanent housing. TH can fund up to 24 months of housing costs along with accompanying supportive services. Program participants in transitional housing must have a lease (or sublease) or occupancy agreement, ensuring their rights and responsibilities are clearly defined during their stay.
Supportive Services Only: Connecting to Essential Resources
Funds under the Supportive Services Only (SSO) component are specifically directed 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 to streamline local crisis response systems and improve access to resources, including mainstream services.
SSO-Coordinated Entry (CE) grants fund a range of supportive services directly related to CE activities. These include outreach to sheltered and unsheltered homeless individuals and families (including initial assessment, crisis counseling, and addressing immediate physical needs) and connecting them to housing and other vital resources.
While stand-alone SSO grants are no longer available for entities not designated as 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 services can be delivered in centralized locations, scattered sites, or even through street outreach programs, ensuring flexibility and accessibility.
Homeless Management Information System: Data-Driven Solutions
The Homeless Management Information System (HMIS) component is exclusively for HMIS Lead Agencies, which are designated by the CoC to operate the CoC’s HMIS on its behalf.
HMIS funds cover the costs associated with operating the HMIS, including leasing or operating a physical structure to house the HMIS, and other expenses related to establishing, operating, and customizing the system. While other recipients and subrecipients cannot directly apply for HMIS funds, they can include HMIS-related costs within their projects under other components (PH, TH, SSO, or HP) to support data contribution and system maintenance.
Homelessness Prevention: Stopping Homelessness Before It Starts
Recipients and subrecipients located in HUD-designated High Performing Communities (HPCs) are eligible to utilize CoC Program funds for homelessness prevention assistance. This component targets individuals and families at risk of homelessness, aiming to intervene before they lose their housing. The annual CoC Program Notice of Funding Opportunity (NOFO) provides detailed information regarding the criteria and process for CoCs seeking HPC designation.
Homelessness prevention services can include housing relocation and stabilization services, as well as short- and medium-term rental assistance. These interventions aim to help at-risk individuals and families maintain their current housing or transition to new permanent housing, effectively preventing homelessness before it occurs. Homelessness prevention activities must adhere to the regulations outlined in 24 CFR part 576.
Discontinued Components: Safe Havens and Section 8 Moderate Rehabilitation SRO
It’s important to note that two program components are no longer eligible for new projects under the CoC Program:
Safe Havens
The Safe Haven program component is no longer accepting new projects. However, existing Safe Haven projects that were eligible under the McKinney-Vento Act prior to the HEARTH Act may be renewed to continue ongoing operations, leasing, supportive services, rental assistance, HMIS operation, and administrative functions. The annual CoC Program Notice of Funding Opportunity (NOFO) provides further details on renewals.
Section 8 Moderate Rehabilitation SRO
Similarly, the Section 8 Moderate Rehabilitation SRO Program component is also closed to new projects. Current SRO projects will continue to be renewed under the Multifamily Assisted Housing Reform and Affordability Act of 1997, ensuring continued support for existing projects but no expansion through new SRO initiatives.
Understanding Eligible Costs Under the CoC Program
The CoC Program interim rule meticulously defines the costs eligible for funding under each program component. It is crucial to understand that not all costs are eligible under every component, and certain cost combinations may be restricted within a single unit or structure. However, costs associated with contributing data to the CoC’s designated HMIS are eligible across all components, emphasizing the importance of data collection and management.
Here’s a summary of eligible costs categories:
Acquisition
Acquisition of real property is an eligible cost under the PH, TH, and SSO components. Grant funds can cover up to 100% of the cost of purchasing property for permanent housing, transitional housing, and supportive services only activities.
Rehabilitation
Rehabilitation of existing structures is eligible under PH, TH, and SSO components. Eligible rehabilitation costs include energy-saving upgrades and bringing structures up to health and safety standards. However, rehabilitation on leased properties is not eligible.
New Construction
New construction of structures is eligible under the PH and TH components. This can include building entirely new facilities or significant additions (increasing floor area by 100% or more). Funds can also cover land costs for construction. Projects must demonstrate that new construction is more cost-effective than rehabilitation. Importantly, the CoC Program interim rule sets no maximum grant limits for rehabilitation or new construction, and funds can cover up to 100% of costs if match requirements are met through other sources. New construction on leased properties is also ineligible.
Leasing Costs
Leasing is an eligible cost category under PH, TH, SSO, and HMIS components. Funds can be used to lease individual units or entire structures. Rents must be reasonable and, for individual units, cannot exceed HUD-determined Fair Market Rents (FMRs). Leasing funds cannot be used for properties owned by the recipient, subrecipient, or related organizations without HUD authorization. When leasing funds are used for units, the lease must be between the recipient/subrecipient and the landowner, with a sublease or occupancy agreement for the program participant. Recipients may charge program participants rent or occupancy charges, consistent with program guidelines.
Rental Assistance Costs
Rental assistance is eligible under PH and TH 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 (3-24 months), or long-term (over 24 months), varying by component. Recipients must serve the number of participants outlined in their funding application. If funds exceed actual costs, excess funds can be used for property damage, rent increases, or serving more participants.
- TBRA: Participants can choose any suitable unit within the CoC’s area, with potential location restrictions to ensure service access.
- SBRA: Participants reside in housing owned or leased by a sponsor organization, arranged through a contract with the recipient.
- PBRA: Participants live in housing under contract with an owner who agrees to lease subsidized units to program participants. Rental assistance is tied to the project location.
When rental assistance is used, the lease is between the participant and landowner. Participants must contribute towards rent as per interim rule requirements.
Supportive Services Costs
Supportive services are eligible under PH, TH, and SSO components. The CoC Program interim rule specifies all eligible services, and any service not listed is ineligible. Services must be available to PSH and TH residents for their entire residency. RRH programs require monthly case manager meetings.
Services can be provided to formerly homeless individuals for up to six months after exiting homelessness, including post-transitional housing exit. Recipients/subrecipients must annually assess service needs and adjust services accordingly. Eligible costs include service provision, staff salaries/benefits for service providers, and related materials/supplies.
Operating Costs
Operating costs are eligible under PH, TH, and HMIS components. Funds can cover daily operating costs in structures or individual units, including maintenance (major system replacements), repair, building security (if CoC Program funds over 50% of the facility), utilities, furniture, equipment, property insurance, and taxes. These costs cannot be combined with rental assistance in the same unit/structure and are ineligible under the SSO component.
HMIS Costs
Costs related to client data contribution or maintenance in the CoC’s HMIS (or comparable databases for victim/legal services providers) are eligible under PH, TH, SSO, and HMIS components. Eligible HMIS costs include hardware, software, training, overhead, and staffing for data contribution to the CoC’s designated HMIS.
Project Administration
Recipients and subrecipients can use up to 10% of any grant (excluding CoC planning and UFA costs) for project administration. These costs cover grant administration (24 CFR part 578.59), including management, coordination, monitoring, evaluation, and environmental review.
CoC Planning Costs
CoC Planning funds are exclusively for the CoC’s Collaborative Applicant and are awarded through a specific CoC Planning grant. Funds must be used for activities outlined in the interim rule, such as community-wide coordination, coordinated entry process design (not implementation), ESG/CoC program outcome evaluation, annual HUD application preparation, and recipient/subrecipient monitoring and compliance enforcement.
Unified Funding Agency (UFA) Costs
UFA costs funds are available only to Collaborative Applicants designated as a Unified Funding Agency (UFA) by HUD. These funds support ensuring financial transaction compliance with generally accepted accounting principles, including annual surveys, audits, or evaluations of subrecipient project financial records.
Understanding the intricacies of the Continuum of Care (CoC) program, its components, and eligible costs is crucial for organizations working to combat homelessness. This comprehensive guide provides a valuable overview for automotive repair professionals seeking to understand community initiatives and potentially engage in local support efforts. While seemingly distant from the automotive industry, community health and stability are interconnected and understanding such programs can contribute to a more informed and engaged citizenry.
