The Continuum of Care (CoC) Program stands as a cornerstone initiative aimed at combating homelessness across communities. Funded by the U.S. Department of Housing and Urban Development (HUD), the CoC Program is meticulously designed to support individuals and families experiencing homelessness, including unaccompanied youth, by providing access to crucial services that facilitate their transition into stable housing – both transitional and permanent. The ultimate objective is to foster long-term stability and self-sufficiency for those most vulnerable.
More than just immediate housing solutions, the CoC Program champions a holistic, community-driven strategy to tackle homelessness. It encourages and resources communities to engage in comprehensive planning and optimize resource allocation. A key focus is enhancing coordination and integration among mainstream resources and various programs specifically designed for individuals facing homelessness. By improving data collection and performance measurement, the CoC Program ensures accountability and effectiveness. Furthermore, it empowers each community to tailor its programs, allowing for flexibility in addressing the unique strengths and challenges inherent in assisting their local homeless population.
Who Can Apply? Eligible Applicants for CoC Program Funding
Eligibility to apply for CoC Program funding is clearly defined to ensure that resources are directed to capable and appropriate organizations. According to the CoC Program interim rule, eligible applicants encompass a range of entities committed to addressing homelessness. These include:
- Nonprofit Organizations: Community-based nonprofits with a mission to serve vulnerable populations.
- States: State-level government agencies focused on housing and community development.
- Local Governments: City, county, and other local governmental bodies directly involved in community services.
- Instrumentalities of State or Local Governments: Public entities or authorities created by state or local governments to carry out specific functions, such as housing authorities.
It is important to note that for-profit entities are explicitly ineligible to apply for CoC Program grants or to act as subrecipients of grant funds. This ensures that the program’s focus remains on mission-driven organizations dedicated to public service rather than commercial interests.
Organizations seeking HUD funding through the CoC Program must navigate an annual competitive process. To participate, an eligible applicant needs to submit a project application to the CoC’s designated Collaborative Applicant organization. Each CoC (Continuum of Care) designates a single organization to serve as this Collaborative Applicant. This entity plays a pivotal role by consolidating all project applications, ranking them based on local priorities, and submitting the complete application package to HUD. The package includes both the overarching CoC application and the individual project applications with their respective rankings, streamlining the process and ensuring local coordination.
Alt text: Icon representing the role of a Collaborative Applicant in the Continuum of Care Program application process, emphasizing coordination and submission of project applications to HUD.
Core Components of the CoC Program
The CoC Program is structured around five core program components, each designed to address different facets of homelessness and housing stability. These components, as outlined in the CoC Program interim rule, dictate how CoC Program funds can be utilized to support various project types. These components are designed to be largely consistent with those of the Emergency Solutions Grants (ESG) program to streamline administration for entities involved in both. This consistency ensures uniform reporting standards and data quality benchmarks across similar project types, reducing administrative complexities for recipients managing multiple funding streams. However, it’s important to note distinctions, such as in the rapid re-housing component’s eligible activities and administration requirements, which are specifically detailed in the interim rule.
The five primary program components eligible for CoC Program funding are:
1. Permanent Housing (PH)
Permanent Housing (PH) is defined as community-based housing designed for long-term residence, without mandated time limits. It aims to provide formerly homeless individuals and families the opportunity to live as autonomously as possible within a stable community setting. A crucial element of PH is that program participants must be the leaseholder (or sub-leaseholder) with an initial lease term of at least one year. This lease must be renewable, typically on a month-to-month basis after the initial term, and can only be terminated for legitimate cause, ensuring tenant protections and housing security.
The CoC Program supports two distinct types of permanent housing models tailored to different needs:
Permanent Supportive Housing (PSH)
Permanent Supportive Housing (PSH) targets chronically homeless individuals with disabilities and families where at least one adult or child member has a disability. PSH combines permanent housing with indefinite leasing or rental assistance alongside intensive supportive services. These services are crucial to help individuals and families not only secure housing but also maintain housing stability and improve their overall well-being. PSH is designed for those with significant barriers to housing and requires ongoing support to live independently.
Rapid Re-housing (RRH)
Rapid Re-housing (RRH) is designed to swiftly move homeless individuals and families, regardless of disability status, into permanent housing. RRH prioritizes housing search and relocation services, coupled with short-term to medium-term rental assistance. The goal is to minimize the duration of homelessness by quickly connecting people to housing and providing the necessary financial and logistical support to establish themselves in stable living situations. RRH is effective for those who need short-term assistance to overcome the immediate barriers to housing.
Alt text: Icon representing Permanent Supportive Housing, symbolizing long-term housing stability and integrated support services for individuals and families experiencing homelessness.
2. Transitional Housing (TH)
Transitional Housing (TH) serves as an interim housing solution for homeless individuals and families. It is specifically designed to offer stability and support during the transition from homelessness to permanent housing. TH projects can provide housing for up to 24 months, accompanied by a range of supportive services tailored to help residents achieve self-sufficiency and secure permanent housing. Program participants in transitional housing must have a formal lease (or sublease) or occupancy agreement, ensuring their rights and responsibilities are clearly defined during their stay.
3. Supportive Services Only (SSO)
The Supportive Services Only (SSO) component under the CoC Program has a specific focus: supporting the CoC’s coordinated entry process. Funds under this component are exclusively available to the entity designated by the CoC to lead and manage this critical function. HUD mandates that every CoC must establish and operate a coordinated entry process. This process is designed to streamline local crisis response systems, making it easier for individuals and families experiencing homelessness to access housing and supportive services, including mainstream resources.
SSO funding awarded as a Supportive Services Only – Coordinated Entry (SSO-CE) grant can be used for a variety of activities directly related to implementing and operating coordinated entry. These activities include:
- Outreach: Engaging with sheltered and unsheltered homeless individuals and families to inform them about available resources.
- Initial Assessment: Conducting assessments to understand the needs and vulnerabilities of those seeking assistance.
- Crisis Counseling: Providing immediate support and counseling to address urgent emotional and psychological needs.
- Addressing Urgent Physical Needs: Connecting individuals with resources to meet immediate needs like food, shelter, and healthcare.
- Housing and Resource Referrals: Linking individuals and families to appropriate housing options and other supportive services within the community.
While general SSO grants are no longer available for entities that are not the CE Lead Agency, recipients and subrecipients can still access supportive services funds to provide assistance 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 and can even include street outreach programs, extending support beyond traditional housing settings.
Alt text: Flowchart illustrating the Coordinated Entry system process, highlighting steps from outreach and assessment to referral and housing placement for individuals experiencing homelessness.
4. Homeless Management Information System (HMIS)
The Homeless Management Information System (HMIS) component of the CoC Program is dedicated to enhancing data collection and management within homeless service systems. Funding under this component is exclusively available to HMIS Lead Agencies. These agencies are designated by the CoC to operate and maintain the CoC’s HMIS on its behalf. The HMIS is a crucial data system used to collect client-level data on homelessness in a community.
HMIS funding can cover various costs associated with establishing, operating, and customizing a CoC’s HMIS. Eligible costs include:
- Leasing Costs: Renting physical space to house HMIS operations.
- Operating Costs: Covering utilities, maintenance, and other operational expenses for the HMIS facility.
- HMIS-related Costs: Costs associated with hardware, software, customization, and ongoing operation of the HMIS.
While other recipients and subrecipients cannot directly apply for HMIS component funds, they can 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 across all CoC-funded projects.
5. Homelessness Prevention (HP)
The Homelessness Prevention (HP) component of the CoC Program is specifically targeted at preventing individuals and families at risk of homelessness from actually becoming homeless. Currently, access to HP funding is limited to recipients and subrecipients located within HUD-designated High Performing Communities (HPCs). The annual CoC Program Notice of Funding Opportunity (NOFO) provides detailed information on how CoCs can apply for HPC designation.
HP funding can be used to provide services aimed at stabilizing housing situations and preventing displacement. These services may include:
- Housing Relocation and Stabilization Services: Assistance with moving costs, security deposits, utility hook-ups, and case management to ensure housing stability.
- Short- and Medium-Term Rental Assistance: Temporary financial aid to help at-risk households maintain their current housing or move into new permanent housing.
Through the HP component, recipients and subrecipients can intervene proactively to help individuals and families at imminent risk of homelessness maintain their existing housing or transition to new, stable housing arrangements. Homelessness prevention activities must be administered in strict accordance with 24 CFR part 576, which outlines the regulatory requirements for emergency solutions grants and prevention activities.
Understanding Eligible Costs Under the CoC Program
The CoC Program interim rule meticulously outlines the costs that are eligible for funding under each program component. It is crucial to understand that not all cost categories are applicable to every component, and in some instances, certain costs cannot be combined within a single unit or structure. However, a universally eligible cost across all components is the cost associated with contributing data to the CoC’s designated HMIS.
Here is a breakdown of the eligible cost categories under the CoC Program:
1. Acquisition
Acquisition of real property is an eligible cost under the Permanent Housing (PH), Transitional Housing (TH), and Supportive Services Only (SSO) program components. CoC Program funds can cover up to 100 percent of the costs associated with purchasing property. This provision is intended to facilitate the creation of facilities for permanent housing, transitional housing, or locations to deliver supportive services.
2. Rehabilitation
Rehabilitation of existing structures is also an eligible cost category under the PH, TH, and SSO components. This funding can be used to improve existing buildings, including installing energy-efficient upgrades and ensuring the structures meet health and safety standards. Importantly, rehabilitation on leased properties is not eligible for CoC Program funding, focusing investment on owned or to-be-owned properties.
3. New Construction
New construction of facilities is eligible under the PH and TH program components. This can include building entirely new housing facilities or constructing additions to existing structures that significantly increase the floor area (by 100 percent or more). The cost of land acquisition for new construction can also be covered. Projects proposing new construction must demonstrate that this approach is more cost-effective than rehabilitation as a condition of funding. 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 as long as the required matching funds are secured from other sources. Similar to rehabilitation, new construction on leased properties is not eligible.
4. Leasing Costs
Leasing is an eligible cost category across a broad range of components: PH, TH, SSO, and HMIS. Funds can be used to lease individual housing units or entire structures. Rents must be reasonable and, for individual units, must not exceed HUD-determined Fair Market Rents (FMRs) to ensure cost-effectiveness. There are restrictions on leasing from entities closely related to the recipient or subrecipient without explicit HUD authorization to prevent conflicts of interest. When leasing funds are used for rental units, the lease must be between the recipient or subrecipient and the property owner, with a sublease or occupancy agreement in place for the program participant. Recipients have the discretion to charge program participants rent or occupancy charges, within the parameters specified in the interim rule.
5. Rental Assistance Costs
Rental assistance is a vital eligible cost under the PH and TH components. It can take three forms:
- Tenant-Based Rental Assistance (TBRA): Assistance tied to the tenant, allowing them to choose housing anywhere within the CoC’s geographic area, with some location restrictions permissible to ensure service accessibility.
- Sponsor-Based Rental Assistance (SBRA): Assistance linked to housing owned or leased by a sponsor organization, arranged through a contract with the recipient.
- Project-Based Rental Assistance (PBRA): Assistance attached to specific housing units within a project, provided through a contract with the property owner, limiting participant mobility if they wish to retain the assistance.
Rental assistance can be short-term (up to 3 months), medium-term (3 to 24 months), or long-term (over 24 months), depending on the component under which it is funded. Recipients are expected to serve the number of program participants outlined in their HUD funding application. If funds allocated for the grant term exceed actual rental assistance needs, the surplus can be used for property damage, rent increases, or to serve a greater number of participants. In all rental assistance models, the lease must be between the program participant and the landowner, and participants are required to contribute towards rent as per interim rule guidelines.
6. Supportive Services Costs
Supportive services are eligible costs under the PH, TH, and SSO program components. The CoC Program interim rule provides a comprehensive list of eligible services, emphasizing that any service not explicitly listed is ineligible. These services must be consistently offered to residents of PSH and TH throughout their residency. RRH programs require at least monthly case management meetings with program participants.
Services can extend to formerly homeless individuals for up to six months after they exit homelessness, including the period following exit from a transitional housing project. Recipients and subrecipients are mandated to conduct annual assessments of their program participants’ service needs and adjust service provision accordingly. Eligible costs encompass the direct costs of providing services, staff salaries and benefits for service providers, and necessary materials and supplies.
7. Operating Costs
Operating costs are eligible under the PH, TH, and HMIS program components. These funds cover day-to-day operational expenses in single structures or individual housing units. Examples include:
- Maintenance and Repair: Routine maintenance and necessary repairs, including scheduled replacement of major systems.
- Building Security: Security measures, particularly when CoC Program funds cover more than 50 percent of the facility.
- Utilities: Electricity, gas, water, and other essential utilities.
- Furniture and Equipment: Necessary furnishings and equipment for housing units or facilities.
- Property Insurance: Insurance coverage for the property.
- Taxes: Property taxes.
It is critical to note that operating costs cannot be combined with rental assistance costs within the same housing unit or structure, and operating costs are not eligible under the SSO program component.
8. HMIS Costs
Costs related to contributing client data to or maintaining data within the CoC’s HMIS, or comparable databases used by victim services or legal services providers, are eligible across all program components (PH, TH, SSO, and HMIS). Eligible HMIS costs include expenses for:
- Hardware, Equipment, and Software: Technology infrastructure for HMIS.
- Training: Staff training on HMIS usage and data entry.
- Overhead: Administrative overhead associated with HMIS operations.
- Staffing: Personnel costs directly related to data entry and HMIS maintenance.
9. Project Administration
Recipients and subrecipients can allocate up to 10 percent of any grant (excluding amounts for CoC planning and Unified Funding Agency (UFA) costs) for project administration. These costs cover the overall administrative functions necessary for grant management, such as:
- Management and Coordination: General grant oversight and coordination.
- Monitoring and Evaluation Activities: Program monitoring and performance evaluation.
- Environmental Review: Costs associated with environmental compliance.
10. CoC Planning Costs
CoC Planning funds are exclusively for the CoC’s designated Collaborative Applicant and are awarded through a specific CoC Planning grant. These funds must be used for activities that enhance community-wide planning and coordination, such as:
- Developing Community-Wide Processes: Establishing coordinated systems involving diverse stakeholders, including individuals with lived experience of homelessness.
- Coordinated Entry Process Design: Designing and refining the Coordinated Entry process (implementation costs are separate).
- Project Outcome Evaluation: Assessing the effectiveness of CoC Program and ESG-funded projects.
- Annual Application Preparation: Preparing and submitting the annual CoC Program application to HUD.
- Recipient and Subrecipient Monitoring: Overseeing and ensuring compliance of funded projects with program requirements.
11. Unified Funding Agency (UFA) Costs
UFA costs are specifically for Collaborative Applicants designated as a Unified Funding Agency (UFA) by HUD, awarded through a dedicated UFA Costs grant. These funds are intended to ensure sound financial management and accountability within the CoC Program, covering costs associated with:
- Financial Transaction Compliance: Ensuring all financial activities comply with generally accepted accounting principles.
- Annual Audit or Evaluation: Arranging for annual financial reviews of each subrecipient project funded through the CoC Program.
Conclusion
The Continuum of Care (CoC) Program is a vital and multifaceted resource for communities striving to end homelessness. Through its comprehensive framework, the CoC Program provides essential funding and guidance to develop and implement housing and supportive services tailored to the unique needs of homeless populations. By understanding the program’s structure, components, and eligible costs, communities can effectively leverage CoC Program resources to make a significant and lasting impact on homelessness, fostering stability and improved lives for vulnerable individuals and families. The CoC Program’s emphasis on coordinated, community-wide efforts ensures a more strategic and impactful approach to addressing homelessness, moving beyond temporary fixes to create lasting solutions and a true continuum of care.
