The Continuum of Care (CoC) Program stands as a cornerstone initiative by the U.S. Department of Housing and Urban Development (HUD) to tackle homelessness across the nation. This program is specifically designed to support individuals and families, including unaccompanied youth, who are experiencing homelessness. It delivers crucial services aimed at transitioning these vulnerable populations into stable housing solutions, encompassing both temporary and permanent options, with the ultimate objective of achieving lasting stability and independence.
The CoC Program’s impact extends beyond immediate housing provision. It serves as a catalyst for fostering comprehensive community-wide strategies to address homelessness. This involves promoting the efficient allocation of resources, enhancing coordination among various service providers and mainstream programs, and refining data collection and performance measurement practices. Crucially, the program empowers each community to tailor its approach, allowing for customized strategies that effectively address the unique challenges and leverage the specific strengths within their local context in assisting individuals and families experiencing homelessness.
Core Objectives of the CoC Program
The CoC Program operates on several key principles designed to maximize its effectiveness in combating homelessness:
- Community-Wide Planning: The program emphasizes the importance of a unified, community-driven approach to addressing homelessness. It encourages stakeholders to collaborate and develop cohesive strategies that are responsive to local needs.
- Strategic Resource Utilization: By promoting efficient resource allocation, the CoC Program ensures that funding and services are deployed where they can have the greatest impact, preventing duplication and maximizing reach.
- Enhanced Coordination and Integration: A central goal is to bridge the gap between homelessness-specific programs and mainstream resources like healthcare, employment services, and education. This integration ensures individuals receive holistic support.
- Data-Driven Performance Improvement: The CoC Program prioritizes robust data collection and performance measurement. This data informs program adjustments, identifies areas for improvement, and ensures accountability in achieving desired outcomes.
- Tailored Local Solutions: Recognizing that homelessness manifests differently across communities, the program encourages local flexibility. Communities can adapt program components to align with their unique strengths, challenges, and the specific needs of their homeless populations.
Who Can Apply for CoC Program Funding?
Eligibility for CoC Program funding is clearly defined to ensure resources are directed to capable and appropriate organizations. According to HUD guidelines, eligible applicants include:
- Nonprofit Organizations: Established non-profits with a mission focused on housing and homelessness services are primary applicants.
- State and Local Governments: Governmental bodies at the state, county, and city levels are eligible to apply for funding to support local initiatives.
- Instrumentalities of State or Local Governments: Agencies or entities created by state or local governments to address specific needs, such as housing authorities, can also apply.
It’s important to note that for-profit entities are not eligible to directly apply for or receive CoC Program grants, nor can they serve as subrecipients of grant funds.
Funding is awarded through an annual competitive process. Organizations seeking to participate must submit project applications to the Collaborative Applicant designated by their local CoC. Each CoC designates a single organization to act as the Collaborative Applicant. This entity is responsible for compiling and submitting a comprehensive application package to HUD, which includes the CoC application, individual project applications from local organizations, and a prioritized ranking of these projects.
Key Components of the CoC Program
The CoC Program offers flexibility in how communities address homelessness through five core program components:
Permanent Housing (PH)
Permanent Housing (PH) is designed to provide long-term housing solutions for individuals and families who have experienced homelessness. It is characterized by:
- Community-Based Housing: PH is integrated within the broader community, avoiding segregated or isolated settings.
- Indefinite Length of Stay: There is no predetermined time limit for residency as long as tenants adhere to lease terms.
- Independent Living: Residents are empowered to live as independently as possible, with support services available as needed.
- Tenant Leases: Program participants must be tenants with legally binding leases (or subleases) for an initial term of at least one year, renewable and terminable only for cause. Leases must renew for minimum terms of one month thereafter.
The CoC Program funds two distinct types of permanent housing:
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Permanent Supportive Housing (PSH): PSH targets chronically homeless individuals with disabilities and families with a disabled adult or child member. It combines long-term or indefinite rental assistance with ongoing supportive services. The goal of PSH is to enable residents to achieve and maintain housing stability and improve their overall quality of life.
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Rapid Re-housing (RRH): Rapid Re-housing is designed to quickly move individuals and families experiencing homelessness, with or without disabilities, into permanent housing. RRH prioritizes housing search and relocation services, along with short-term to medium-term rental assistance. The focus is on minimizing the duration of homelessness and swiftly connecting people to stable housing.
Transitional Housing (TH)
Transitional Housing (TH) offers temporary housing and supportive services to individuals and families experiencing homelessness. It serves as an important bridge to permanent housing by providing:
- Interim Stability: TH offers a safe and structured environment for individuals to stabilize their lives and address barriers to permanent housing.
- Supportive Services: Programs incorporate services like case management, counseling, job training, and life skills development to prepare residents for independent living.
- Lease or Occupancy Agreement: Residents have a lease or occupancy agreement during their stay in transitional housing.
- Up to 24 Months of Housing: CoC Program funds can cover housing costs for up to 24 months, along with accompanying supportive services.
Supportive Services Only (SSO)
Supportive Services Only (SSO) funding is specifically directed towards enhancing Coordinated Entry (CE) systems within communities. These funds are available only to the entity designated by the CoC to lead the coordinated entry process. SSO grants for CE activities support:
- Coordinated Entry Activities: Funding supports a range of activities that directly facilitate the operation of a CE system.
- Outreach and Initial Assessment: SSO funds can be used for outreach to unsheltered and sheltered individuals and families, including initial assessments, crisis counseling, and addressing immediate physical needs.
- Connection to Resources: A key function of SSO is to connect individuals experiencing homelessness to housing options and other essential mainstream resources.
While general SSO grants are no longer available to entities that are not CE Lead Agencies, recipients and subrecipients can still receive supportive service funds within other program components to provide services to homeless individuals not residing in their housing projects. These services can be delivered in centralized locations, scattered sites, or through street outreach.
Homeless Management Information System (HMIS)
The Homeless Management Information System (HMIS) component focuses on supporting the technological infrastructure needed to collect and analyze data on homelessness. HMIS funding is exclusively for the HMIS Lead Agency designated by each CoC. HMIS funds can be used for:
- HMIS Operations: Covering costs related to leasing and operating physical spaces for HMIS operations.
- System Establishment and Customization: Funding supports the setup, ongoing operation, and customization of the CoC’s HMIS.
- Data Management: Ensuring effective data collection, storage, and reporting to improve understanding of homelessness and program performance.
While other recipients and subrecipients cannot apply directly for HMIS funding, they can include HMIS-related costs within their project budgets under other program components (PH, TH, SSO, or HP) to cover expenses associated with contributing data to the CoC’s HMIS.
Homelessness Prevention
Homelessness Prevention funding is available to recipients and subrecipients located in HUD-designated High Performing Communities (HPCs). This component aims to prevent individuals and families at risk of homelessness from losing their housing. Eligible services include:
- Housing Relocation and Stabilization Services: Assistance to help at-risk individuals and families maintain their current housing or transition to new permanent housing.
- Short- and Medium-Term Rental Assistance: Temporary financial aid to prevent eviction and housing loss.
Homelessness prevention activities must be administered in accordance with HUD regulations outlined in 24 CFR part 576.
Other Components (Note on Discontinued Programs)
It’s important to note that two former CoC Program components are no longer available for new projects:
- Safe Havens: New Safe Haven projects are not funded under the CoC Program. However, existing Safe Haven projects can be renewed.
- Section 8 Moderate Rehabilitation SRO: New SRO projects are also not funded. Existing SRO projects will continue to be renewed under separate legislation.
These components are mentioned for context but are not active areas for new CoC Program funding.
Understanding Eligible Costs Under the CoC Program
The CoC Program outlines specific costs that are eligible for funding under each component. It’s crucial to understand these eligible cost categories to develop compliant and effective project budgets. Not all costs are eligible under every component, and certain cost combinations within a single unit or structure may be restricted. However, costs associated with contributing data to the CoC’s HMIS are eligible across all program components.
Key eligible cost categories include:
Acquisition
Acquisition costs, covering the purchase of real property, are eligible under PH, TH, and SSO components. CoC Program funds can cover up to 100% of property purchase costs for these program types.
Rehabilitation
Rehabilitation of existing structures is an eligible cost under PH, TH, and SSO. This includes renovations to improve health and safety standards, and installation of energy-saving measures. Rehabilitation on leased properties is not eligible for CoC funding.
New Construction
New construction of structures is eligible under PH and TH components. This can include building new facilities or adding significant expansions to existing ones. Projects must demonstrate that new construction is more cost-effective than rehabilitation. Similar to rehabilitation, new construction on leased land is not eligible.
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. Rents must be reasonable and within HUD Fair Market Rent (FMR) limits. Leasing from related organizations generally requires HUD authorization. Leases are typically between the recipient/subrecipient and landowner, with a sublease or occupancy agreement for the program participant.
Rental Assistance Costs
Rental assistance is eligible under PH and TH and can be tenant-based (TBRA), sponsor-based (SBRA), or project-based (PBRA). Assistance can be short-term (up to 3 months), medium-term (3-24 months), or long-term (over 24 months), depending on the component. Recipients must serve the planned number of participants, but excess funds can be used for property damage, rent increases, or serving more participants.
- Tenant-Based Rental Assistance (TBRA): Participants can choose housing anywhere within the CoC’s area, with potential location restrictions to ensure service access.
- Sponsor-Based Rental Assistance (SBRA): Housing is provided in properties owned or leased by a sponsor organization through a contract with the recipient.
- Project-Based Rental Assistance (PBRA): Housing is tied to specific units in a structure under contract with a property owner. Assistance is not portable if the participant moves outside the project.
Participants receiving rental assistance are typically required to contribute towards rent payments.
Supportive Services Costs
Supportive services are eligible under PH, TH, and SSO. The CoC Program specifies eligible services, and any service not listed is ineligible. Services must be offered throughout the residency period in PSH and TH. RRH programs require at least monthly case management meetings. Services can extend up to six months post-housing exit, including after leaving transitional housing. Annual needs assessments and service adjustments are required. Eligible costs include service provision, staff salaries/benefits for service delivery, and related materials and supplies.
Operating Costs
Operating costs are eligible under PH, TH, and HMIS for day-to-day operational expenses within housing units or structures. This includes maintenance, 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 in the same unit or structure and are not eligible under SSO.
HMIS Costs
Costs related to HMIS data contribution and maintenance are eligible under all components (PH, TH, SSO, and HMIS). This encompasses hardware, software, training, overhead, and staffing costs directly related to HMIS data management.
Project Administration
Recipients and subrecipients can allocate up to 10% of a grant (excluding CoC planning and UFA costs) for project administration. This covers overall grant management, coordination, monitoring, evaluation, and environmental reviews.
CoC Planning Costs
CoC Planning funds are exclusively for the Collaborative Applicant and are awarded through a separate CoC Planning grant. Eligible uses include community-wide planning, coordinated entry design (not implementation), ESG/CoC project outcome evaluation, annual HUD application preparation, and recipient/subrecipient monitoring and compliance enforcement.
Unified Funding Agency (UFA) Costs
UFA costs are available only to Collaborative Applicants designated as a Unified Funding Agency by HUD. These funds support activities ensuring sound financial management of CoC Program funds, including annual surveys, audits, or evaluations of subrecipient financial records.
Conclusion
The Continuum of Care Program is a vital federal initiative that provides a comprehensive framework and essential funding to communities across the United States to address the complex challenge of homelessness. By emphasizing coordinated community planning, strategic resource allocation, and a range of housing and supportive service options, the CoC Program strives to create effective local systems that not only provide immediate relief but also foster long-term housing stability and self-sufficiency for individuals and families experiencing homelessness. Understanding the program’s objectives, components, and eligible uses of funds is crucial for organizations and communities dedicated to making a meaningful impact in ending homelessness.
