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Continuum of Care (CoC)
Program: Overview of the
Interim Rule and FY 2012
Competition July 10, 2012
1
Presenters:
Ann M. Oliva, Acting Deputy Assistant Secretary for Special Needs/
Director, Office of Special Needs Assistance Programs
Lora D. Routt, Deputy Director, Office of Special Needs Assistance Programs
Overview of Today’s Presentation
• HEARTH Act Implementation – Big Picture
• Overview: the Interim CoC Program Rule
• Key Concepts from the CoC Program Rule
• FY 2012 CoC Program Competition
• Additional Resources
2 2
HEARTH Act Implementation
• Signed into law on May 20, 2009
• Reauthorized and amended the McKinney-Vento Act
• Six sets of regulations were developed: – Definition of Homeless
– Emergency Solutions Grants program
– Conforming Amendments to the Consolidated Plan
– Homeless Management Information Systems
– Continuum of Care program
– Rural Housing Stability Assistance Program
3
HEARTH Act Purposes
• To codify in Federal law the continuum of
care planning process as a required and
integral local function necessary to
generate the local strategies for ending
homelessness.
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HEARTH ACT Purposes
• To establish a Federal goal of ensuring
that individuals and families who become
homeless return to permanent housing
within 30 days.
5
HEARTH Act Purposes
• To provide clarification on the following
terms:
– "homeless,"
– "homeless individual,"
– "homeless person," and
– "homeless individual with a disability”
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HEARTH Act Implementation
• The goals of Opening Doors: Federal
Strategic Plan to Preventing and Ending
Homelessness
– Guided many of the policies set forth in the
ESG, CoC, and RHS programs
– Will guide the policies set forth in the CoC
and RHS competitions in FY 2012 and
beyond
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CONTINUUM OF CARE
PROGRAM
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CoC Program - Purposes
• Consolidate the SHP, S+C, and Section 8
SRO program activities into one grant
program.
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CoC Program - Purposes
• Promote community-wide commitment to the goal of ending homelessness
• Provide funding for efforts by nonprofit providers, States, and local governments to quickly re-house homeless individuals and families while minimizing the trauma and dislocation caused to homeless individuals, families, and communities by homelessness
10
CoC Program - Purposes
• Promote access to effective utilization of
mainstream programs by homeless
individuals and families
• Optimize self-sufficiency among
individuals and families experiencing
homelessness
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CoC Program - Purposes
• Provide funding to support the CoC
structure and process
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CoC Program -- Purposes
• Codify the CoC structure and process.
Formalizes the following CoC responsibilities:
• Coordinating, or be involved in the coordination of,
all housing and services for homeless persons
within its geographic area
• Coordinating McKinney-Vento funds awarded
within its geographic area 13
CoC Program -- Purposes
• Codify the CoC structure and process.
(Continued):
Formalizes the following CoC responsibilities:
• Establishing and operating the HMIS within its
geographic area
• Establishing and operating, or designating, the
centralized or coordinated assessment to be used
with its geographic area 14
CoC Program Rule - Structure
• The interim CoC rule is organized into 7
subparts:
– Subpart A – General Provisions
– Subpart B – Establishing and Operating a
Continuum of Care
– Subpart C – Application and Grant Award
Process
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CoC Program Rule - Structure
• The interim CoC rule is organized into 7
subparts (cont.):
– Subpart D – Program Components and
Eligible Costs
– Subpart E – High Performing Communities
– Subpart F – Program Requirements
– Subpart G – Grant Administration
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CoC Program Rule – Subpart A
• Subpart A contains the following:
– Purpose and Scope of the CoC program
– Definitions
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CoC Program Rule – Subpart B
• Subpart B contains the following:
– Requirements for establishing the CoC
– Responsibilities of the CoC
– Process for preparing an application for funds
– Process for being designated a UFA
– Remedial actions that HUD may take for
CoCs that do not meet the criteria of the Act
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CoC Program Rule – Subpart C
• Subpart C contains the following:
– Eligible applicants
– Process for applying for funds
– Process for awarding funds, including the
grant execution/agreement process
– Requirements for appealing funding
decisions made by:
• The CoC
• The Consolidated Planning Jurisdiction
• HUD 19
CoC Program Rule – Subpart D
• Subpart D contains the following:
– Program components
– Eligible costs
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CoC Program Rule – Subpart E
• Subpart E contains the following:
– Standards CoCs must meet to apply to be
designated a High Performing Community
– The application process for becoming a High
Performing Communities
– Eligible activities a recipient within a High
Performing Community may carry out
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CoC Program Rule – Subpart F
• Subpart F contains the following:
– Matching requirements
– Housing standards
– Calculation of rent and occupancy charges
– Limitations on uses of funds
– Timeliness standards
– Other Federal requirements
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CoC Program Rule – Subpart G
• Subpart G contains the following:
– Recordkeeping requirements
– Standards for grant and project changes
– HUD and recipient sanctions
– Close-out procedures
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CoC Program – Key Terms
Continuum of Care (CoC) means the group composed of representatives of organizations, including nonprofit homeless providers, victim service providers, faith-based organizations, governments, businesses, advocates, public housing agencies, school districts, social service providers, mental health agencies, hospitals, universities, affordable housing developers, law enforcement, organizations that serve homeless and formerly homeless veterans, and homeless and formerly homeless persons that are organized to carry out the responsibilities required under this part.
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Continuum of Care – Key Terms
Applicant means an eligible applicant that has been designated by the CoC to apply for assistance
Collaborative applicant means the eligible applicant that has been designated by the CoC to apply for a grant for CoC planning funds under this part on behalf of the CoC
Unified Funding Agency (UFA) means an eligible applicant selected by the CoC to apply for a grant for the entire CoC, which has the capacity to carry out the duties in §578.11(b), which is approved by HUD and to which HUD awards a grant.
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Continuum of Care – Key Terms
Preliminary Pro Rata Need Amount (PPRN) is the total dollar amount for each geographic area claimed by a CoC that is determined by the formula described in § 578.17
Renewal Demand is the sum of the annual renewal amounts of all projects within a CoC eligible to apply for renewal (including S+C)
Final Pro Rata Need is the higher of PPRN or Renewal Demand and serves as the base for the CoC’s maximum award amount
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Continuum of Care – Key Terms
CoC’s Maximum Award Amount is the
CoC’s FPRN plus any additional eligible
amounts for:
– CoC planning
– UFA costs
– Adjustments to leasing, operating and rental
assistance line items based on changes to
FMR; and
– Available bonuses 27
FY 2012 CoC Program Competition
• Big Picture Overview
– Continuum of Care Applicants
• Grant Inventory Worksheets
• Registration
• Application
– Project Applicants
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FY 2012 CoC Program Competition
• Continuum of Care
– Operations and Structure
– HMIS
– Objectives
– Coordination
– Attachments
29
FY 2012 CoC Program Competition
• Project Applications
– Permanent Housing
– Transitional Housing
– Supportive Services Only
– Homeless Management Information Systems
(HMIS)
– Safe Haven – Renewal Only
30
FY 2012 CoC Program Competition
• Reallocation
– All Projects
• Rental Assistance
– Current leasing may actually be rental
assistance
31
Additional Resources
• Visit www.hudhre.info to:
– Download a copy of the CoC Program interim rule
– Ask a question through the Virtual Help Desk
– Review additional training materials
• Note: Due to the high volume of questions,
please read the CoC Program interim rule and
the available training materials prior to
submitting your question to the Virtual Help
Desk 32
