Our Quick Analysis of HUD’s FY17 CoC Program Competition Registration Notice
On April 10, the U.S. Department of Housing and Urban Development released its FY17 Notice of Opportunity to Register and Other Important Information for Electronic Application Submission for the Continuum of Care (CoC) Program Competition. Registration closes on May 1 at 8 p.m. Eastern.
I’m sure you’ve combed through the Notice already and are beginning the process of registering. As you prepare to do so, we want to offer our quick analysis of what’s included. There are a few changes that may have caught your eye:
- The addition of a new Joint Transitional Housing and Rapid Re-housing Component project type
- New opportunities for reallocated projects
- Emphasis on merging CoCs to address funding challenges and create efficiencies
- A new Grant Inventory Worksheet process
New Joint Component Project Type
HUD created a new Joint Transitional Housing and Rapid Re-housing Component (“Joint Component”) project type to allow communities to provide low-barrier, temporary housing while individuals and families are being quickly and seamlessly connected to permanent housing through a rapid re-housing intervention. Current HUD funding for transitional housing does not allow recipients to use grant funds to pay for financial assistance, including short- or medium-term rental assistance to help households residing in transitional housing move into permanent housing. By allowing CoCs to create a project that combines transitional housing and rapid re-housing, individuals and families will have access to low-barrier temporary housing and the financial supports necessary to help them quickly move into and sustain permanent housing.
We believe that this new project type enhances rapid re-housing and supports our shared vision for developing flexible systems that can offer housing opportunities tailored to the distinct and varied needs of households. Joint component projects may be particularly impactful in high-cost communities with high numbers of people experiencing unsheltered homelessness. In such communities, it can be difficult to quickly connect households to permanent housing opportunities because rents are high and affordable housing units are limited. Providing such connections is further complicated where emergency shelter bed space or other crisis housing resources are limited.
The joint component project type is aligned with an overall emphasis on building systems that are oriented toward Housing First approaches. Programs cannot impose preconditions to entry or participation in services in either the transitional housing or the rapid re-housing portion of the project. In addition, the search for permanent housing must begin as soon as the household enters the transitional housing portion of the project, and providers should connect participants to rapid re-housing as soon as they express a desire to do so.
Because this joint program component project is available to any individual or family experiencing homelessness, it can be an important tool to target resources for specific populations, such as: survivors of domestic violence; unaccompanied youth, including pregnant or parenting youth; or individuals in early recovery from a substance use disorder who may desire more intensive supports. The joint component project is particularly well-suited for addressing the housing needs of survivors of domestic violence and their families who have higher safety and security needs or who are navigating significant legal or financial challenges. Creating joint component projects will allow providers to offer seamless, tailored wrap-around services and supports to participants as they move from temporary to permanent housing.
In the FY17 Competition, HUD plans to allow the use of reallocation to create the following new projects:
- Permanent supportive housing projects that will primarily serve individuals and families experiencing chronic homelessness, including unaccompanied youth
- Rapid re-housing projects for individuals and families experiencing homelessness, including unaccompanied youth, coming directly from the streets or emergency shelter, or persons fleeing domestic violence situations and other persons meeting the criteria of paragraph 4 of the definition of homelessness
- Joint component projects, as described above
- Dedicated HMIS projects
- Supportive Services Only (SSO) projects for centralized or coordinated assessment systems
This range of options for reallocating funding increases a CoC’s flexibility in creating the types of programs that meet the distinct needs and strengths of communities.
HUD puts additional emphasis on merging CoCs in this Notice. We believe their intention is to provide a mechanism for smaller CoCs across the country to come together to implement broader system-level efforts, such as improving data collection through HMIS and the Point-in-Time Count, and developing and implementing coordinated entry processes. While the merger process may be challenging, there are likely to be benefits for small CoCs that have historically not fared as well in the CoC Competition. Note that requests to merge must be submitted to CoCMerger@hud.gov no later than 5 days before the end of the CoC Program Registration Period on May 1. You should refer to the Notice for additional instructions.
Grant Inventory Worksheet
HUD has implemented a new Grants Inventory Worksheet (GIW) process as part of this year’s Registration. This year, the GIW will be pre-populated by HUD and posted to the Exchange instead of emailed directly to CoC points of contact. This allows CoCs and all recipients of CoC Program funding to simultaneously review the information. Any changes that need to be made must be completed on the GIW Change Form and submitted to your local field office for review. This will hopefully make your jobs a little bit easier throughout the Competition process.
As always, if you have technical questions about the registration process, contact the HUD Exchange Ask A Question. Once the NOFA is released, we’ll follow up with more in-depth analysis and our annual webinar to highlight key strategies for success.