The U.S. Department of Housing and Urban Development (HUD) offers the Continuum of Care (CoC) Program, a vital initiative designed to support individuals and families experiencing homelessness. This program is dedicated to providing the essential services necessary to transition people into stable housing, aiming for long-term independence and well-being. It’s a cornerstone of Continuing Care Programs for vulnerable populations, ensuring a structured approach to tackling homelessness at the community level.
More than just immediate housing, the CoC Program fosters a strategic, community-wide approach to resource allocation and planning to effectively combat homelessness. It emphasizes enhanced coordination and integration with mainstream support systems and other programs aimed at assisting those experiencing homelessness. This integrated approach ensures better data collection and performance measurement, allowing each community to tailor its programs to best address the unique challenges and leverage the strengths within their local context.
Who Can Apply? Eligible Applicants for CoC Program Funding
Eligibility for CoC Program funding is clearly defined by HUD to ensure resources are directed to capable and relevant organizations. As detailed in the CoC Program interim rule, eligible applicants include:
- Nonprofit organizations: Community-based nonprofits with a mission to serve the homeless population.
- State governments: State-level agencies focused on housing and community development.
- Local governments: City and county governments directly addressing homelessness within their jurisdictions.
- Instrumentalities of State or local governments: Public housing agencies or similar governmental bodies.
It’s important to note that for-profit entities are not eligible to apply directly for CoC Program grants or to act as subrecipients of these funds. This focus on non-profit and governmental organizations underscores the program’s commitment to public service and community benefit.
Funding is awarded through an annual competitive process. Organizations seeking to apply must submit a project application to the Collaborative Applicant designated by their local CoC. Each CoC appoints a Collaborative Applicant, which acts as the lead organization. This Collaborative Applicant is responsible for compiling and submitting the complete application package to HUD, which includes the CoC application itself, individual project applications from various organizations, and the CoC’s prioritization rankings for these projects. This centralized application process ensures a coordinated and strategic approach to addressing homelessness within each Continuum of Care.
Key Program Components of the CoC Program
The CoC Program utilizes a framework of five distinct program components, as outlined in the interim rule, allowing for a comprehensive and flexible approach to addressing the diverse needs of the homeless population. These components ensure that funding can be directed to a variety of housing and service solutions, creating a robust continuing care program network. The five core components are:
- Permanent Housing (PH)
- Transitional Housing (TH)
- Supportive Services Only (SSO)
- Homeless Management Information System (HMIS)
- Homelessness Prevention (in specific cases)
Administrative costs are eligible across all program components, recognizing the necessary infrastructure to support effective program delivery.
The design of these components aligns with those of the Emergency Solutions Grants (ESG) program where feasible. This consistency simplifies administration for organizations managing both ESG and CoC funding, ensuring uniform reporting standards and data quality benchmarks across similar project types. A key difference between the ESG and CoC programs lies in the specifics of eligible activities and administrative requirements for rapid re-housing assistance, a crucial element within the CoC Program’s framework.
Let’s explore each of these components in detail:
Permanent Housing (PH)
Permanent Housing (PH) is defined as long-term, community-integrated housing without mandated time limits, designed to enable formerly homeless individuals and families to live as independently as possible. A core principle of PH is tenant rights: program participants must hold a lease (or sublease) agreement, initially for at least one year with automatic renewal, and terminations are only permissible for legitimate cause. These leases must renew for minimum terms of one month thereafter, ensuring housing security and stability.
The CoC Program supports two primary types of permanent housing:
- Permanent Supportive Housing (PSH): This is permanent housing combined with ongoing supportive services tailored for individuals with disabilities or families where a member has a disability. PSH offers indefinite leasing or rental assistance, coupled with services designed to help residents achieve and maintain housing stability and overall well-being. It’s a critical element of continuing care programs, addressing the complex needs of vulnerable individuals.
- Rapid Re-housing (RRH): Rapid re-housing focuses on swiftly moving homeless individuals and families (with or without disabilities) into permanent housing. RRH provides housing search and relocation assistance, along with short to medium-term rental subsidies. The emphasis is on speed and efficiency in transitioning people from homelessness to stable housing.
Transitional Housing (TH)
Transitional Housing (TH) serves as an intermediate step towards permanent housing. It is designed to offer homeless individuals and families temporary stability and supportive services to facilitate their successful transition to and maintenance of permanent housing solutions. CoC Program funds can support transitional housing for up to 24 months, including the provision of necessary supportive services. Residents of transitional housing must have a lease (or sublease) or occupancy agreement, ensuring a degree of security and structure during their stay. TH acts as a bridge within continuing care programs, offering a structured pathway to long-term stability.
Supportive Services Only (SSO)
The Supportive Services Only (SSO) component is specifically targeted to enhance the coordinated entry (CE) processes within a CoC. Funding under this component is exclusively available to the entity designated by the CoC to lead its coordinated entry system. HUD mandates that each CoC establish and operate a coordinated entry process to streamline local crisis response systems and improve access to resources, including mainstream services.
Grants awarded under the Supportive Services Only – Coordinated Entry (SSO-CE) designation are used for a range of supportive services directly related to CE activities. These include:
- Outreach to sheltered and unsheltered homeless individuals and families: Engaging with people experiencing homelessness in various locations.
- Initial assessment: Evaluating needs and connecting individuals to appropriate resources.
- Crisis counseling: Providing immediate support during times of acute distress.
- Addressing urgent physical needs: Connecting individuals with immediate necessities like food, shelter, and healthcare.
- Connecting individuals to housing and other resources: Facilitating access to housing programs and other relevant support services.
While general SSO grants are no longer available to entities other than the CE Lead Agency, recipients and subrecipients can still receive supportive services funds to serve homeless individuals and families who are not residing in housing directly operated by the recipient. These services can be delivered at a centralized site, across scattered sites, or even through street outreach programs, offering flexibility in service delivery and ensuring that continuing care programs reach individuals in diverse situations.
Homeless Management Information System (HMIS)
The Homeless Management Information System (HMIS) component is crucial for data collection and informed decision-making in addressing homelessness. Funding under this component is exclusively for HMIS Lead Agencies, which are designated by each CoC to manage and operate the CoC’s HMIS on their behalf.
HMIS funds can be used for:
- Leasing and operating facilities housing the HMIS.
- Covering costs related to establishing, operating, and customizing the CoC’s HMIS.
While other recipients and subrecipients cannot directly apply for HMIS component funds, they can include costs associated with contributing data to the CoC’s HMIS within their project budgets under other components (PH, TH, SSO, or HP). Accurate and comprehensive data collection through HMIS is vital for evaluating the effectiveness of continuing care programs and improving service delivery.
Homelessness Prevention
Homelessness Prevention is a proactive component designed to intervene before housing crises escalate into homelessness. Recipients and subrecipients located in HUD-designated High Performing Communities (HPCs) are eligible to utilize CoC Program funds for homelessness prevention assistance for individuals and families at risk of homelessness. Details regarding HPC designation criteria are provided annually in the CoC Program Notice of Funding Opportunity (NOFO).
Services under this component may include:
- Housing relocation and stabilization services: Assistance to help individuals maintain current housing or move to new stable housing.
- Short- and medium-term rental assistance: Temporary financial aid to prevent eviction or housing loss.
Through homelessness prevention, recipients and subrecipients aim to help at-risk individuals and families maintain their existing housing or transition to new permanent housing, acting as a preventative measure within the broader network of continuing care programs. Homelessness prevention activities must adhere to the regulations outlined in 24 CFR part 576.
Program Components No Longer Available for New Projects
It’s important to note that some program components are no longer open to new projects, reflecting program evolution and strategic shifts. These include:
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, can be renewed. This allows for the continuation of leasing, operations, supportive services, rental assistance, HMIS operation, and administrative functions for these established projects beyond their initial funding periods. 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 no longer eligible for new CoC Program funding. No new SRO projects will be funded 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 projects despite the program component’s discontinuation for new initiatives.
Understanding Eligible Costs Under the CoC Program
The CoC Program interim rule specifies eligible costs for each program component, ensuring fiscal responsibility and alignment with program goals. It’s 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. Costs associated with contributing data to the designated HMIS are eligible across all components.
Here’s a summary of eligible cost categories:
Acquisition
Acquisition of real property is an eligible cost under the PH, TH, and SSO components. CoC Program 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. This includes costs for energy-saving upgrades and bringing properties up to health and safety standards. Notably, rehabilitation of leased properties is not eligible for CoC Program funding.
New Construction
New construction is eligible under the PH and TH components. This can include building entirely new facilities or adding substantial expansions (increasing floor area by 100% or more) to existing structures, as well as land acquisition for construction. Projects must demonstrate that new construction is more cost-effective than rehabilitation. Unlike previous regulations, there are no maximum grant limits for rehabilitation or new construction under the CoC Program interim rule, though the match requirement must be met through other funding sources. New construction on leased properties is also ineligible.
Leasing Costs
Leasing is an eligible cost across PH, TH, SSO, and HMIS components. Funds can be used to lease individual units or entire structures or portions thereof. 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, parent organizations, related entities, or partnership members without prior HUD authorization. When leasing 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 charge program participants rent or occupancy charges, adhering to interim rule 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. Assistance can be short-term (up to 3 months), medium-term (3 to 24 months), or long-term (over 24 months), with the duration determined by the funding component. Recipients must serve the number of participants outlined in their HUD application. If funds reserved for the grant term exceed actual costs, excess funds can be used for property damage, rent increases, or to serve additional participants.
- TBRA: Participants can choose any suitable unit within the CoC’s area, though location restrictions may apply to ensure access to necessary supportive services.
- 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 a property owner who agrees to lease subsidized units to program participants. Rental assistance is tied to the project unit and not portable if the participant moves outside the project.
When rental assistance is 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 PH, TH, and SSO components. The CoC Program interim rule specifies all eligible services, and any service not listed is ineligible. Services must be provided throughout the residency period in PSH and TH programs. RRH programs require at least monthly case management meetings with participants.
Services can be provided to formerly homeless individuals for up to six months after exiting homelessness, including post-transitional housing. Recipients and subrecipients must annually assess participant service needs and adjust service provision accordingly. Eligible costs include service delivery costs, staff salaries and benefits for service providers, and related materials and supplies.
Operating Costs
Operating costs are eligible under PH, TH, and HMIS components. These funds cover day-to-day operating expenses in structures or individual units, including maintenance (e.g., system replacements), repairs, building security (if CoC funds cover over 50% of the facility), utilities, furniture, equipment, property insurance, and taxes. Operating costs cannot be combined with rental assistance costs within the same unit or structure and are not eligible under the SSO component.
HMIS Costs
Costs related to contributing client data to or maintaining data 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 directly involved in HMIS data contribution and management.
Project Administration
Recipients and subrecipients can allocate 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 reviews.
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 support activities like developing community-wide homelessness strategies, designing coordinated entry processes (excluding implementation), evaluating CoC and ESG program outcomes, preparing annual HUD applications, and monitoring recipient/subrecipient compliance.
Unified Funding Agency (UFA) Costs
UFA costs are available only to Collaborative Applicants designated as a Unified Funding Agency (UFA) by HUD and are awarded via a specific UFA Costs grant. Funds support ensuring financial transaction compliance and record-keeping according to generally accepted accounting principles. This includes arranging annual surveys, audits, or evaluations of subrecipient project financial records funded through the CoC Program.
By understanding the intricacies of the CoC Program, eligible organizations can effectively apply for funding to develop and enhance continuing care programs that make a real difference in the lives of individuals and families experiencing homelessness, fostering community-wide solutions and long-term housing stability.
