The Continuum of Care (CoC) Program stands as a cornerstone initiative by the U.S. Department of Housing and Urban Development (HUD) to combat homelessness. This program is meticulously crafted to support individuals and families, including unaccompanied youth, who are experiencing homelessness. It aims to provide not just immediate shelter, but a pathway towards long-term stability through transitional and permanent housing solutions, coupled with essential supportive services.
More than just providing housing, The Continuum Of Care Coc Program is strategically designed to foster a community-wide, coordinated approach to tackling homelessness. It encourages communities to engage in comprehensive planning and optimize resource allocation. A key objective is to enhance collaboration and integration between mainstream resources and various programs dedicated to assisting those experiencing homelessness. Furthermore, the program emphasizes the importance of robust data collection and performance measurement to ensure effectiveness and accountability. Crucially, the CoC Program is designed to be adaptable, allowing each community to tailor its strategies and programs to address the specific strengths and challenges unique to their local context in assisting homeless individuals and families.
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Who Can Apply for CoC Program Funding?
Eligibility for CoC Program funding is clearly defined by HUD. According to the CoC Program interim rule, eligible applicants encompass a range of organizations committed to addressing homelessness. These include:
- Nonprofit organizations
- State governments
- Local governments
- Instrumentalities of State or local governments
It’s important to note that for-profit entities are not eligible to directly apply for grants or serve as subrecipients of grant funds.
Funding from HUD is awarded through a competitive annual process. Organizations seeking to participate must submit a project application to the designated Collaborative Applicant organization within their local CoC. Each CoC designates a single organization to act as the Collaborative Applicant. This Collaborative Applicant then consolidates all project applications, including their own CoC application and project rankings, into a comprehensive application package submitted to HUD.
Key Program Components of the CoC Program
The CoC Program operates through five core program components, each designed to address different facets of homelessness and housing solutions. These components, as outlined in the interim rule, are:
- Permanent Housing
- Transitional Housing
- Supportive Services Only
- Homeless Management Information System (HMIS)
- Homelessness Prevention (in specific cases)
Administrative costs are eligible under all of these program components, providing flexibility in program management.
The structure of these components is intentionally aligned with those of the Emergency Solutions Grants (ESG) program where feasible. This alignment aims to streamline administrative processes for organizations involved in both programs, ensuring consistent reporting standards and data quality benchmarks across similar projects. However, it is important to note distinctions, such as in the eligible activities and administrative requirements for rapid re-housing assistance within the CoC Program, compared to the ESG Program.
Let’s delve deeper into each of these five core components of the continuum of care coc program:
Permanent Housing (PH)
Permanent Housing (PH) is defined as community-integrated housing without a set time limit for residency. It is designed to allow formerly homeless individuals and families to live as independently as possible. A key feature of PH is that participants must be tenants with a lease (or sublease) that is initially for at least one year, renewable, and can only be terminated for legitimate cause. These leases must also be renewable for a minimum term of one month thereafter, ensuring housing security.
The CoC Program supports two primary types of permanent housing:
- Permanent Supportive Housing (PSH): This is permanent housing combined with ongoing supportive services for individuals with disabilities or families where an adult or child member has a disability. PSH aims to help them achieve and maintain long-term housing stability.
- Rapid Re-housing (RRH): Rapid Re-housing prioritizes quickly moving homeless individuals and families (with or without disabilities) into permanent housing. It emphasizes housing search and relocation assistance, along with short- to medium-term rental assistance to facilitate a swift transition.
Transitional Housing (TH)
Transitional Housing (TH) serves as an interim solution, offering stability and support to homeless individuals and families as they work towards securing and maintaining permanent housing. TH can cover housing costs for up to 24 months, coupled with necessary supportive services. Residents in transitional housing must have a lease (or sublease) or an occupancy agreement in place during their stay, ensuring a structured and secure living environment.
Supportive Services Only (SSO)
Funding under the Supportive Services Only (SSO) component is specifically designated for the entity leading the CoC’s coordinated entry process. HUD mandates that each CoC establish and operate a coordinated entry process. This process is crucial for streamlining local crisis response systems and improving access to resources, including mainstream services.
SSO grants focused on Coordinated Entry (SSO-CE) can fund a range of supportive services directly related to these activities. This includes outreach to both sheltered and unsheltered homeless individuals and families, initial assessments, crisis counseling, addressing urgent physical needs, and connecting people experiencing homelessness with housing and other essential resources.
While SSO grants are no longer available for entities other than 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 services can be delivered in centralized locations, scattered sites, or even through street outreach programs, adapting to the diverse needs of the community.
Homeless Management Information System (HMIS)
The Homeless Management Information System (HMIS) component is exclusively for HMIS Lead Agencies. These agencies are designated by the CoC to manage and operate the CoC’s HMIS on their behalf.
HMIS funding can cover costs associated with leasing and operating facilities that house the HMIS, as well as other expenses related to establishing, running, and customizing the CoC’s HMIS. While other recipients and subrecipients cannot directly apply for HMIS component funds, they can incorporate HMIS-related costs, such as data entry, into their projects under other program components like PH, TH, SSO, or Homelessness Prevention.
Homelessness Prevention
Homelessness Prevention funding through the continuum of care coc program is available to recipients and subrecipients located in HUD-designated High Performing Communities (HPCs). The annual CoC Program Notice of Funding Opportunity (NOFO) provides detailed information for CoCs seeking HPC designation.
Services funded under this component include housing relocation and stabilization services, as well as short- to medium-term rental assistance. These interventions aim to prevent individuals and families at risk of homelessness from losing their housing or facilitate their transition to new permanent housing. Homelessness prevention activities must be administered in accordance with 24 CFR part 576, ensuring regulatory compliance and effective program delivery.
Components No Longer Eligible for New Projects
It is important to note that some components are no longer eligible for new projects under the CoC Program, although existing projects may be renewed.
Safe Havens
The Safe Haven program component is no longer eligible for new CoC Program funding. However, existing Safe Haven projects, which were eligible under the McKinney-Vento Act prior to the HEARTH Act, may be renewed. This renewal allows for the continuation of leasing, operations, supportive services, rental assistance, HMIS operation, and administrative functions beyond their initial funding period. Detailed information is available in the annual CoC Program Notice of Funding Opportunity (NOFO).
Section 8 Moderate Rehabilitation SRO
Similarly, the Section 8 Moderate Rehabilitation SRO Program component is no longer open to new projects under the CoC Program. Existing SRO projects will continue to be renewed under the Multifamily Assisted Housing Reform and Affordability Act of 1997, ensuring ongoing support for these vital housing resources.
Eligible Costs Under the CoC Program
The CoC Program interim rule clearly outlines the costs that are eligible for funding under each program component. It is crucial to understand that not all costs are eligible under every component, and certain costs cannot be combined within the same unit or structure. However, costs associated with contributing data to the designated HMIS are eligible across all components.
Here is a summary of the eligible cost categories within the continuum of care coc program:
Acquisition
Acquisition of real property is an eligible cost under the PH, TH, and SSO program components. CoC Program funds can cover up to 100% of the costs associated with purchasing property for permanent housing, transitional housing, and supportive services only activities.
Rehabilitation
Rehabilitation of existing structures is also eligible under the PH, TH, and SSO components. Eligible rehabilitation costs include energy-saving upgrades and bringing properties up to health and safety standards. However, rehabilitation of leased properties is not eligible for funding.
New Construction
New construction of structures is an eligible cost for PH and TH program components. This can include building entirely new facilities or adding to existing structures if the addition increases the floor area by 100% or more. The cost of land for construction can also be covered. Projects involving new construction must demonstrate that it is more cost-effective than rehabilitation. Notably, the CoC Program interim rule does not set maximum grant limits for rehabilitation or new construction, and funds can cover up to 100% 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 category for PH, TH, SSO, and HMIS components. Funds can be used to lease individual housing 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 units or structures owned by the recipient, subrecipient, parent organizations, related organizations, or partnership members without HUD authorization. When leasing funds are used for rental 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 guidelines.
Rental Assistance Costs
Rental assistance is an eligible cost under the 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 to 24 months), or long-term (over 24 months), with the duration depending on the funded component. Recipients must serve the number of program participants specified in their HUD application. If funds allocated for the grant term exceed actual costs, the excess can be used for property damage, rent increases, or to serve more participants.
- TBRA: Participants can choose any suitable unit within the CoC’s geographic area, with potential location restrictions to ensure access to supportive services.
- SBRA: Participants must reside in housing owned or leased by a sponsor organization and arranged through a contract with the recipient.
- PBRA: Participants reside in housing under contract with a property owner who agrees to lease subsidized units. Participants cannot retain rental assistance if they move outside the project.
When rental assistance funds are used, the lease must be between the program participant and the landowner. Participants are required to contribute towards rent, as per interim rule requirements.
Supportive Services Costs
Supportive services are eligible costs under the PH, TH, and SSO 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 require at least monthly case manager meetings with participants.
Services can be provided to formerly homeless individuals for up to six months after exiting homelessness, including the six months post-transitional housing. Recipients and subrecipients must conduct annual service needs assessments for program participants and adjust services accordingly. Eligible costs include service provision, staff salaries and benefits for service providers, and related materials and supplies.
Operating Costs
Operating costs are eligible under the PH, TH, and HMIS components. Funds can cover day-to-day operating costs in housing structures or individual units, including maintenance (like system replacements), repair, building security (if CoC Program funds cover over 50% of the facility), utilities, furniture, equipment, property insurance, and taxes. Operating costs cannot be combined with rental assistance within the same unit or structure and are not eligible under the SSO component.
HMIS Costs
Costs related to client data contribution or maintenance in the CoC’s HMIS (or comparable databases for victim services or legal services providers) are eligible under PH, TH, SSO, and HMIS components. Eligible HMIS costs include hardware, software, training, overhead, and staffing costs associated with data contribution to the CoC-designated HMIS.
Project Administration
Recipients and subrecipients can use up to 10% of any grant (excluding CoC planning and UFA costs) for project administrative costs. These costs cover overall grant administration (24 CFR part 578.59), including 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 community-wide coordination, designing coordinated entry processes (excluding implementation), evaluating project outcomes, preparing annual HUD applications, 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, awarded through a specific UFA Costs grant. Funds can cover costs related to ensuring financial transaction compliance under the CoC Program, including annual surveys, audits, or evaluations of subrecipient project financial records.
This comprehensive overview of the continuum of care coc program provides a detailed understanding of its structure, components, eligibility, and funding mechanisms. It serves as a valuable resource for organizations seeking to engage with the program and contribute to the collective effort to address homelessness in communities across the United States.
