Prioritization is the most effective when performed through a coordinated entry process. HUD recognizes that in many communities the coordinated entry system is still being developed and might not currently be in place for every housing type. In the meantime, recipients of CoC Program-funded PSH may still prioritize following the order of priority established in the Prioritization Notice by selecting persons from their project’s wait list in a ...
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Prioritization is the most effective when performed through a coordinated entry process. HUD recognizes that in many communities the coordinated entry system is still being developed and might not currently be in place for every housing type. In the meantime, recipients of CoC Program-funded PSH may still prioritize following the order of priority established in the Prioritization Notice by selecting persons from their project’s wait list in a prioritized manner. Where a waitlist does not exist, the provider should be exercising due diligence to locate persons that meet the highest levels of priority according to the Prioritization Notice.

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For this question, consider an example where some communities’ assessment tools assign a score to each person when they are assessed and in some cases, a person with a high assessment score would not be considered the highest priority based on the Prioritization notice. Appendix A of the Prioritization Notice provides guidance on what HUD considers to be qualities of a good assessment tool and encourages CoCs to select a tool that will work in ...
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For this question, consider an example where some communities’ assessment tools assign a score to each person when they are assessed and in some cases, a person with a high assessment score would not be considered the highest priority based on the Prioritization notice.

Appendix A of the Prioritization Notice provides guidance on what HUD considers to be qualities of a good assessment tool and encourages CoCs to select a tool that will work in their community based on those criteria but has not endorsed any specific assessment tool. Ideally, an assessment tool will be aligned with HUD’s requirements and priorities; however, assessment tools are created and developed independent of HUD and might place higher emphasis on factors that are not weighed as high by HUD when considering how to prioritize households for permanent supportive housing.

Communities choosing a tool that assigns a score to each person assessed, such as the Vulnerability Index & Service Prioritization Decision Assistance Tool (VI-SPDAT), might find persons receiving the highest score do not necessarily meet the highest priority according to the Prioritization Notice. In such cases, HUD expects the CoC to use the assessment tool as a starting point but use the guidelines of the Prioritization Notice to establish a single prioritized list.

Some assessment tools might also prioritize specific disability-types which would not be consistent with fair housing requirements. CoCs can resolve this by ensuring that other factors are taken into consideration beyond the assessment tool when determining how a household should be prioritized for assistance. Even when the assessment tools do not align exactly with the Prioritization Notice, they provide valuable information to CoCs and are necessary to ensure that households are all assessed consistently across the CoC.

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The recordkeeping requirements included in the Final Rule on Defining “Chronically Homeless” are meant to ensure that, when applicable, permanent supportive housing (PSH) that is dedicated to serving persons experiencing chronic homelessness is being used to serve persons that meet the definition. It was never HUD’s intention that these requirements act as a barrier to housing those most in need of PSH as quickly as possible. In fact, ...
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The recordkeeping requirements included in the Final Rule on Defining “Chronically Homeless” are meant to ensure that, when applicable, permanent supportive housing (PSH) that is dedicated to serving persons experiencing chronic homelessness is being used to serve persons that meet the definition. It was never HUD’s intention that these requirements act as a barrier to housing those most in need of PSH as quickly as possible. In fact, HUD believes that its final recordkeeping requirements for the definition of chronically homeless strike the appropriate balance and do not create a level of documentation that is too burdensome. This is part of the reason that HUD permitted each project to serve up to 25 percent of the individuals and families in a given operating year who do not have at least 9 months of their stays in a place not meant for human habitation, safe haven, or emergency shelter documented by third-party documentation.

However, even with this 25 percent allowance, HUD has received comments that some additional time is often needed by recipients and subrecipients to obtain the appropriate documentation of an individual or head of household’s chronic homeless status. Therefore, although the final rule requires documentation of eligibility at intake to the project, it does not require that all third-party documentation be acquired at the point of intake. HUD recognizes that it may take a little bit more time to obtain third-party documentation for documenting chronic homeless status in accordance with the final rule for prior months or occasions. Therefore, HUD has determined that although the recipient must follow the order of priority for obtaining evidence as required in the final rule, written self-certification at the point of intake for up to the full period of time homeless required by the definition of chronically homeless is sufficient (if no other documentation can be obtained at that point in time) for the recipient to enroll the household into the project. The recipient then must work to obtain the required third-party documentation within 180 days from the point in which the project participant is enrolled in the project. Project participants that have been enrolled in the project for less than 180 days may be excluded from the calculation for determining whether or not at least 75% of program participants have at least 9 months of third-party documentation.

Following the first 180 days from the point of a program participant’s enrollment, if the recipient or subrecipient has not been able to obtain third-party documentation for at least 9 months of the individual or head of household’s residence in a place not meant for human habitation, a safe haven, or an emergency shelter, then one of the following applies:

1. If the recipient or subrecipient has not already reached their 25 percent cap, the program participant can continue to be assisted in the project and the recipient or subrecipient must consider this program participant as counting towards their 25 percent allowance; or
    
2. If the recipient or subrecipient has already reached their 25 percent allowance, no additional CoC Program funds can be used to continue serving this household in that project. For this reason, HUD encourages recipients that are currently at their 25 percent allowance to use this additional time carefully and only for program participants where they are fairly certain that the required third-party documentation can be obtained. It is also for this reason that HUD encourages recipients and subrecipients to continue to obtain at least 9 months of third-party documentation for program participants, even after a program participant has been enrolled in the program for some time, because if a recipient is ultimately able to obtain 9 months of third-party documentation of a head of household’s homeless status, then that household can be removed from the 25 percent calculation.

Example: Henry is a program participant that entered a project on June 1st. He reports that he has been living in a place not meant for human habitation, a safe haven, or an emergency shelter for the last 12 months. At the point of intake, there was only 2 months of third-party documentation of Henry residing in one of these locations. The recipient of PSH may obtain a self-certification from Henry for the remaining 10 months in order to enroll Henry in the program and get him into housing. The recipient then has up to 180 days from the point of his enrollment to obtain at least 7 additional months of third-party documentation (to add to the 2 months that had been obtained at the point of intake) to get to the 9 months of required third-party documentation. At any point in time, the program will calculate whether or not they are meeting the requirement that at least 75 percent of program participants have third-party documentation for at least 9 months of their homelessness history based on program participants that enrolled after January 15, 2016 and had been enrolled in the program for 180 days or more. If the recipient is not able to do so, and is not at their 25 percent allowance, then they could continue to serve Henry, but must count him towards their 25 percent allowance. But, if the recipient was already at their 25 percent allowance, the recipient could no longer serve Henry in that project.

Please note, recipients must continue to obtain third-party documentation of the head-of-household’s disability within 45 days, as required by the final rule.

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Prioritizing Eligible Households HUD included the option of DedicatedPLUS in the FY 2017 CoC Program NOFA to provide CoCs with more flexibility to serve vulnerable populations and to more effectively and more immediately address the needs of persons experiencing chronic homelessness, at risk of experiencing chronic homelessness, or who were chronically homeless prior to being housed and who have recently become homeless again. In general, househ...
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Prioritizing Eligible Households

HUD included the option of DedicatedPLUS in the FY 2017 CoC Program NOFA to provide CoCs with more flexibility to serve vulnerable populations and to more effectively and more immediately address the needs of persons experiencing chronic homelessness, at risk of experiencing chronic homelessness, or who were chronically homeless prior to being housed and who have recently become homeless again. In general, households that meet any of the criteria in Section III.A.3.d. of the FY 2017 CoC Program NOFA may be served in any order established by the CoC, though the CoC must be incorporate any orders of priority into their written standards for prioritizing assistance in PSH. When making changes to their written standards, HUD encourages CoCs to continue adopting prioritization standards based on the length of time a potential program participant resided on the streets, in an emergency shelter, or in a safe haven along with the severity of their service needs.

For dedicated PSH beds–as defined in Section III.A.3.b of the FY 2017 CoC Program NOFA–CoCs must follow existing CoC written standards for prioritizing assistance for persons experiencing chronic homelessness in those beds (i.e., if the CoC has adopted the orders of priority in Notice CPD-16-11, the recipient will be required to fill these dedicated beds consistent with section III.A of that Notice).

Prioritizing in DedicatedPLUS Projects When There Are No Eligible Households

Consistent with HUD's expectations for recipients of dedicated permanent supportive housing (PSH) projects, recipients of DedicatedPLUS projects will be expected to exercise due diligence when conducting outreach and assessment to locate and engage eligible households as outlined in Section III.A.3.d. of the FY 2017 CoC Program NOFA. HUD recognizes that some persons might require significant engagement and contacts prior to their entering or re-entering housing and recipients are not required to keep units vacant indefinitely while waiting for an identified eligible individual or family to accept an offer of PSH. However, please note that street outreach providers are expected to continue to make attempts to engage those persons that have been resistant to accepting an offer of PSH and recipients of DedicatedPLUS projects should be following a Housing First approach to the maximum extent practicable. 

At the point in which a vacancy occurs, if there are no eligible households identified who are ready to accept assistance, recipients should consider the following:

• Where there are no chronically homeless persons identified, Dedicated PSH beds included in DedicatedPLUS projects may fill the vacancy either in accordance with section III.B.1.(b)-(d) of Notice CPD-16-11 or households eligible for DedicatedPLUS as outlined in Section III.A.3.d of the NOFA. The CoC must document how these beds will be prioritized in the event of such a vacancy in the CoC's written standards.
• Where there are no persons meeting the eligibility criteria for DedicatedPLUS as outlined in Section III.A.3.d of the NOFA, recipients are encouraged to follow the order of priority outlined in section III.B.1.(b)-(d) of Notice CPD-16-11 to fill any vacancies. At a minimum, the CoC should consider the total length of time the potential program participant has been residing in a place not meant for human habitation, emergency shelter, or safe haven and severity of service needs. The CoC must document how these beds will be prioritized in the event of such a vacancy in the CoC's written standards.
• The recipient must always continue to prioritize households that are eligible for DedicatedPLUS (and dedicated PSH, if applicable). This means that anytime there is a new vacancy, the recipient must always first seek to fill it with an eligible household even if it was most recently used to serve a household that would not otherwise be eligible due to the circumstances outlined above.

The recipient of DedicatedPLUS PSH projects must maintain records to document efforts to locate persons meeting the eligibility criteria in Section III.A.3.d of the FY 2017 CoC Program NOFA. Ideally, the CoC should have comprehensive and high-quality data on all households that are currently presenting for assistance within the CoC that is informed by a comprehensive outreach strategy. To justify serving a non-eligible household, a recipient of DedicatedPLUS projects must have documentation from the CoC that demonstrates that outreach is occurring regularly and that the CoC is making reasonable efforts to locate and identify all persons experiencing homelessness within the community.

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Example: A chronically homeless person has been accepted into a permanent supportive housing program and has begun working with the recipient to identify a permanent supportive housing unit. The program participant is currently living on the streets and has no friends or family to stay with temporarily while an appropriate unit is located and secured. The permanent housing recipient is able to make arrangements with a transitional housing recipie...
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Example: A chronically homeless person has been accepted into a permanent supportive housing program and has begun working with the recipient to identify a permanent supportive housing unit. The program participant is currently living on the streets and has no friends or family to stay with temporarily while an appropriate unit is located and secured. The permanent housing recipient is able to make arrangements with a transitional housing recipient to allow the person to reside in one of the transitional housing beds temporarily during this interim period.

The program participant cannot be entered into two residential programs in HMIS at the same time. Based on the 2014 HMIS Data Standards Manual, the project entry date must be collected at project entry and indicates the date a client has joined the project. For a permanent supportive housing project, this is the date of entry into a permanent supportive housing unit.

Therefore, for the program participant temporarily residing in a transitional housing bed while a permanent supportive housing unit is being located and secured, the program participant must be entered into the transitional housing project in HMIS. The project entry date would be the date they move into the transitional housing bed. Once a permanent supportive housing unit has been secured and the program participant begins to occupy the unit, the program participant must be exited from the transitional housing project in HMIS and entered into the PSH project. The PSH entry date is the date the program participant moves into their permanent supportive housing unit.

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Yes - Records contained in a Homeless Management Information System (HMIS) or comparable database used by victim service or legal service providers are acceptable evidence of third-party documentation and intake worker observations if the HMIS retains an auditable history of all entries, including the person who entered the data, the date of entry, and the change made; and if the HMIS prevents overrides or changes of the dates entries are made.

Permanent Supportive Housing

HUD encourages CoCs and recipients of non-dedicated and non-prioritized CoC Program-funded PSH to offer housing to persons experiencing chronic homelessness first, to the maximum extent possible. For all other CoC Program-funded PSH, where the CoC adopts the orders of priority established in the Prioritization Notice and incorporates them into their written standards, households should be selected in the following order: Order of Priority 1 - A h...
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HUD encourages CoCs and recipients of non-dedicated and non-prioritized CoC Program-funded PSH to offer housing to persons experiencing chronic homelessness first, to the maximum extent possible. For all other CoC Program-funded PSH, where the CoC adopts the orders of priority established in the Prioritization Notice and incorporates them into their written standards, households should be selected in the following order:

Order of Priority 1 - A household should be prioritized first in non-dedicated and
non-prioritized PSH if the following are true:

1. Household is eligible for CoC Program-funded PSH meaning that there is a household member with a disability and they are coming from a place not meant for human habitation, a safe haven, or in an emergency shelter. This includes persons exiting an institution where they have resided for 90 days or less but were living or residing in a place not meant for human habitation, a safe haven, or in an emergency shelter immediately prior to entering the institution; and
2. The household has been identified as having severe service needs.

Order of Priority 2 - A household should be prioritized second in non-dedicated and non-prioritized PSH if all of the following are true:

1. Household is eligible for CoC Program-funded PSH meaning that there is a household member with a disability and they are coming from a place not meant for human habitation, safe haven, or emergency shelter. This includes persons exiting an institution where they have resided for 90 days or less but were living or residing in a place not meant for human habitation, a safe haven, or in an emergency shelter immediately prior to entering the institution; and,
2. The household has been living in a place not meant for human habitation, a safe haven, or in an emergency shelter for at least 6 months or has experienced three occasions in the past 3 years of living in one of these locations; and,
3. The household has not been identified as having severe service needs; and,
4. There are no eligible households within the CoC’s geographic area that meet the criteria under Order of Priority 1 for non-dedicated or non-prioritized PSH.

Order of Priority 3 - A household should be prioritized third in non-dedicated and non-prioritized PSH if all of the following are true:

1. Household is eligible for CoC Program-funded PSH meaning that there is a household member with a disability and they are coming from a place not meant for human habitation, safe haven, or emergency shelter. This includes persons exiting an institution where they have resided for 90 days or less but were living or residing in a place not meant for human habitation, a safe haven, or in an emergency shelter immediately prior to entering the institution; and,
2. The household has not been identified as having severe service needs and has been living in a place not meant for human habitation, a safe haven, or in an emergency shelter for less than six months or has experienced less than three occasions of living in one of these locations in the past 3 years; and,
3. There are no eligible households within the CoC’s geographic area that meet the criteria under Order of Priority 1 and 2 for non-dedicated or non-prioritized PSH.

Order of Priority 4 - A household should be prioritized fourth in non-dedicated and non-prioritized PSH if the following is true:

1. Any household that is eligible for CoC Program-funded PSH meaning that there is a household member with a disability and they are coming from transitional housing where they entered directly from a place not meant for human habitation, emergency shelter, or safe haven.
2. There are no eligible households within the CoC’s geographic area that meet the criteria under Order of Priority 1, 2, and 3 for non-dedicated or non-prioritized PSH.

Summary of Each Order of Priority

Order of Priority for Dedicated or Prioritized, Non-Dedicated Beds

Order of Priority for Dedicated and Prioritized PSH	Meets HUD’s Chronic Homelessness Definition	Has Severe Service Needs?	Other Requirement
1	Yes	Yes	At least 12 months continuous or at least 12 months cumulative across 4 episodes in three years
2	Yes	No	At least 12 months continuous or at least 12 months cumulative across 4 episodes in three years
3	Yes	Yes	Less than 12 months cumulative across 4 episodes in three years
4	Yes	No	Less than 12 months cumulative across 4 episodes in three years

Order of Priority for Non-Dedicated and Non-Prioritized PSH	Meets HUD’s Chronic Homelessness Definition	Has Severe Service Needs?	Other Requirements
1	No	Yes	Coming from streets, safe haven, emergency shelter
2	No	No	Coming from streets, safe haven, and emergency shelter PLUS at least 6 months continuously homeless or at least 3 occasions in 3 years.
3	No	No	Coming from streets, safe haven, emergency shelter
4	No	No	Coming from transitional housing (first came from streets, safe haven, emergency shelter)

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No - The recipient must maintain evidence of a diagnosis with one or more of the following conditions: substance use disorder, serious mental illness, developmental disability (as defined in Section 102 of the Developmental Disabilities Assistance Bill of Rights Act of 2000 (42 U.S.C. 15002), post-traumatic stress disorder, cognitive impairments resulting from brain injury, or chronic physical illness or disability. The condition must be doc...
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No - The recipient must maintain evidence of a diagnosis with one or more of the following conditions: substance use disorder, serious mental illness, developmental disability (as defined in Section 102 of the Developmental Disabilities Assistance Bill of Rights Act of 2000 (42 U.S.C. 15002), post-traumatic stress disorder, cognitive impairments resulting from brain injury, or chronic physical illness or disability. The condition must be documented with third-party documentation.

For eligibility in PSH, a program participant’s disability must also be of long and continuing duration, substantially impede the program participant’s ability to live independently, and be improved by the provision of more suitable housing conditions. Although not specifically stated, by virtue of the nature of chronic homelessness, a person that meets all of the criteria of the definition of "chronically homeless" can be reasonably assumed to meet this standard. For additional information regarding documenting evidence of a diagnosis, refer to Section V.B.b.iii. of the Prioritization Notice. 

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The Prioritization Notice provides guidance on how recipients of CoC Program-funded PSH are now required to document a household’s status as chronically homeless for dedicated and prioritized beds, including the order of priority for obtaining evidence. In general, recipients must seek documentation in the following order: (1) third-party documentation, (2) intake worker observations, and (3) certification from the person seeking assistance, se...
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The Prioritization Notice provides guidance on how recipients of CoC Program-funded PSH are now required to document a household’s status as chronically homeless for dedicated and prioritized beds, including the order of priority for obtaining evidence. In general, recipients must seek documentation in the following order: (1) third-party documentation, (2) intake worker observations, and (3) certification from the person seeking assistance, self-report. This means that ideally, all documentation would be obtained first through third-party documentation, then intake worker observations, and lastly through self-report if neither of the other sources are available.

When documenting duration of homelessness, either continuous period of homelessness or number of occasions, there are limitations on the extent a period can be documented solely through self-report. To document 12 months of continuous homelessness, only 3 months can be documented via self-report. So at least 9 months of the 1-year period must be documented by one of the following: (1) HMIS data, (2), a written referral, or (3) a written observation by an outreach worker. To document at least four distinct occasions of homelessness, at least three of the occasions must be documented in the same manner. Up to 3 months for continuous or one occasion for occasional may be documented via self-report from the person seeking assistance.

In extremely rare circumstances, a self-report may be accepted for the entire period when third-party evidence cannot be obtained. When such cases present, the intake worker must obtain a certification from the individual or head of household seeking assistance, and document all efforts made to obtain third-party documentation. The intake worker must also document the severity of the households living situation. An example of where this might occur is where an individual has been homeless and living in a place not meant for human habitation in a secluded area for more than 1 year and has not had any contact with the homelessness assistance system during that entire period.

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HUD is encouraging recipients of CoC Program-funded PSH to follow the order of priority outlined in the Prioritization Notice, as adopted by the CoC, while also considering the goals and any identified target populations served by the project. CoC Program-funded PSH that is targeted to specific subpopulations should follow the order of priority under Sections III.A. or III.B. of the Prioritization Notice to the extent persons within that subpopul...
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HUD is encouraging recipients of CoC Program-funded PSH to follow the order of priority outlined in the Prioritization Notice, as adopted by the CoC, while also considering the goals and any identified target populations served by the project. CoC Program-funded PSH that is targeted to specific subpopulations should follow the order of priority under Sections III.A. or III.B. of the Prioritization Notice to the extent persons within that subpopulation meets the criteria.

For example, Project Home is a PSH project with dedicated beds that also receives funds from the Department of Health and Human Services (HHS) to pay for supportive services in conjunction with CoC Program-funded PSH that targets persons with a serious mental illness. The HHS funding requires that all participants that receive assistance have a serious mental illness. On the CoC’s single prioritized waiting list there are five chronically homeless households that would meet the first tier under the order of priority for dedicated beds (i.e., longest history of homelessness and most severe service needs); however, none of them have a serious mental illness. Project HOME would not be required to serve these households even though they are higher priority within the CoC overall; instead, Project Home would prioritize the chronically homeless person with a serious mental illness that has the longest history of homelessness and most severe service needs among all other eligible persons with a mental illness within a CoC.

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Protections should be in place to ensure compliance with all civil rights requirements, including, but not limited to, the Fair Housing Act, Title VI of the Civil Rights Act of 1964, and Section 504 of the Rehabilitation Act of 1973. To be compliant with fair housing laws: The assessment tool must not seek disability-related information unless it is necessary for determining the need for housing-related services.   The coordinated entry pro...
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Protections should be in place to ensure compliance with all civil rights requirements, including, but not limited to, the Fair Housing Act, Title VI of the Civil Rights Act of 1964, and Section 504 of the Rehabilitation Act of 1973. To be compliant with fair housing laws:

1. The assessment tool must not seek disability-related information unless it is necessary for determining the need for housing-related services.
    
2. The coordinated entry process must ensure program participants are informed of rights and remedies available under applicable federal, state, and local fair housing and civil rights laws, in accordance with the requirement at 24 CFR 578.93(c)(3).
    
3. The assessment tool can make certain considerations for specific disabilities provided that no housing decisions are made solely on the basis of a specific disability. 

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The Prioritization Notice states that a household is considered to have severe service needs if they have a history of high utilization of crisis services and/or have significant health or behavioral health challenges or functional impairments which require a significant level of support in order to maintain housing. The Prioritization Notice goes on to say that severe service needs should be verified through data-driven methods or through the us...
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The Prioritization Notice states that a household is considered to have severe service needs if they have a history of high utilization of crisis services and/or have significant health or behavioral health challenges or functional impairments which require a significant level of support in order to maintain housing. The Prioritization Notice goes on to say that severe service needs should be verified through data-driven methods or through the use of an assessment tool.

One example of a data-driven method is to conduct data matches using administrative data from hospitals, mental health systems, jails, or similar systems to spot frequent users and generate a list of priority individuals. This list can be cross-referenced with the current shelter census or other crisis service settings to locate and assertively engage potential program participants.

Another data-based strategy for targeting services is to use de-identified administrative data to develop predictive models that can be used in multiple venues to identify persons at highest risk of long-term homelessness and repeat hospitalization, recidivism or chronic child welfare involvement.

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HUD encourages CoCs to incorporate into their operating policies and procedures (which are included in the CoC’s governance charter) a requirement that all CoC-funded PSH only accept referrals through a single prioritized list that is created through the CoC’s coordinated entry process. This will allow recipients of CoC Program-funded PSH to maintain their own project-level waiting lists, if necessary, provided that all households are referre...
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HUD encourages CoCs to incorporate into their operating policies and procedures (which are included in the CoC’s governance charter) a requirement that all CoC-funded PSH only accept referrals through a single prioritized list that is created through the CoC’s coordinated entry process. This will allow recipients of CoC Program-funded PSH to maintain their own project-level waiting lists, if necessary, provided that all households are referred to the project-level waiting list based on where they fall on the CoC’s single prioritized list and not on the date in which they first applied for housing assistance.

The CoC Program interim rule does not include any requirement that CoCs or recipients of CoC Program funds establish or maintain waiting lists. HUD recently published a policy brief on coordinated entry and the waiting list process. HUD strongly encourages CoCs and recipients of PSH to limit project-level waiting lists to the maximum extent feasible, however, when a waiting list cannot be avoided CoCs and recipients of PSH must consider the following:

1. Where a CoC adopts the order of priority established in the Prioritization Notice, recipients and subrecipients must only take referrals from a single prioritized list–each CoC and its providers, may determine the most effective way to address existing project-level waiting lists.
    
2. CoCs may, for example, decide to reassess all persons currently on a projects waiting list or eliminate the existing waiting list altogether. The CoC and recipients must notify all persons on the existing project-level waiting list(s) of such actions and ensure a transparent and open process.
    
3. The CoC’s single prioritized list must not exclude eligible persons from housing (e.g., only prioritizing persons with a specific disability type).

This specific guidance only applies to projects that are funded with CoC Program funds where there are no other funding sources whose regulations prohibit the intended treatment of existing project-level waiting lists. HUD is working with other program offices (e.g., HOME Program) to develop guidance around how PSH receiving other sources of funding from HUD can participate in a meaningful way. See FAQ 1901 for specific information regarding projects that receive funding through both the CoC Program and the HOME Program. 

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CoCs can expect to report on progress made on goals set and commitments made in the FY 2013/FY 2014 CoC Application in the FY 2015 CoC Application. HUD cannot comment on how that information will be requested or the extent it will contribute to the CoCs overall score. In addition, where project applicants for PSH have indicated some or all of their non-dedicated PSH beds will be prioritized for use by the chronically homeless, the proje...
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CoCs can expect to report on progress made on goals set and commitments made in the FY 2013/FY 2014 CoC Application in the FY 2015 CoC Application. HUD cannot comment on how that information will be requested or the extent it will contribute to the CoCs overall score.

In addition, where project applicants for PSH have indicated some or all of their non-dedicated PSH beds will be prioritized for use by the chronically homeless, the project grant agreement will incorporate this commitment. This means that as those beds turnover, the recipient will prioritize persons experiencing chronic homelessness for housing.

It is important to note that CoCs made commitments, and were scored for this criterion, based on the extent to which all CoC Program-funded PSH beds that turnover in a given operating year will be prioritized for the chronically homeless. Project applicants enter the number of beds that will be prioritized for the chronically homeless if and when they turnover. HUD will not penalize CoCs or project applicants where the turnover rate is lower than expected; however, HUD expects CoCs and project applicants to have met the overall percentage of turnover for which they committed.

For example, if a CoC indicated in the FY 2013/FY 2014 CoC Application that it would have 100 beds made available through turnover in 2014 and they committed 85 percent of those, or 85 beds, to be prioritized for the chronically homeless. However, in 2014 there were only 75 beds that came available through turnover HUD would expect that only 85 percent of those, or 63 beds, to have been prioritized for the chronically homeless in 2014. Alternatively, if the CoC had a higher number of beds made available through turnover in 2014, HUD would expect a higher number of beds–based on the commitment of 85 percent–to have been prioritized for the chronically homeless.

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No - HUD does not expect recipients of dedicated or prioritized CoC Program-funded PSH to hold vacant beds open indefinitely while waiting to locate chronically homeless persons with the longest histories of homelessness and most severe service needs. Recipients are only expected to exercise due diligence and should document the efforts they have undertaken to locate persons that would be considered the highest priority. HUD does not have a speci...
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No - HUD does not expect recipients of dedicated or prioritized CoC Program-funded PSH to hold vacant beds open indefinitely while waiting to locate chronically homeless persons with the longest histories of homelessness and most severe service needs. Recipients are only expected to exercise due diligence and should document the efforts they have undertaken to locate persons that would be considered the highest priority. HUD does not have a specific time frame that a recipient must hold a bed vacant.

This is also the case when there are no persons identified within the CoC that meet the definition of chronically homeless in general. Where the orders of priority have been adopted by a CoC, if there are no persons within the CoC’s geographic area that meet the definition of chronically homeless per 24 CFR 578.3, recipients of dedicated and prioritized CoC Program-funded PSH may serve households that are not experiencing chronic homelessness and in the order of priority described in the Prioritization Notice for non-dedicated and not-prioritized PSH beds. Should the bed turnover and become vacant again, the recipient must start by first seeking households that meet Order of Priority 1 for dedicated and prioritized CoC Program-funded PSH. 

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In addition to ending chronic homelessness, Opening Doors also seeks to end homelessness among veterans by the end of this year. HUD is strongly encouraging CoCs to work and coordinate with local Veterans Affairs (VA) Medical Centers on the HUD-Veterans Affairs Supportive Housing (HUD-VASH) program, to the extent that the program is available in a geographic area, to coordinate efforts related to ending veteran’s homelessness. In particular, Co...
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In addition to ending chronic homelessness, Opening Doors also seeks to end homelessness among veterans by the end of this year. HUD is strongly encouraging CoCs to work and coordinate with local Veterans Affairs (VA) Medical Centers on the HUD-Veterans Affairs Supportive Housing (HUD-VASH) program, to the extent that the program is available in a geographic area, to coordinate efforts related to ending veteran’s homelessness.

In particular, CoCs and CoC Program-funded PSH projects targeting homeless veterans should generally prioritize homeless veterans that are not eligible for VA housing and services. Further, where CoCs have adopted the orders of priority described in the Prioritization Notice, HUD encourages CoCs to further prioritize veteran households. Essentially this means that if two households present for assistance and both fall under the same order of priority (i.e., both chronically homeless and fall under Order of Priority 1 for dedicated and prioritized PSH) but one is a veteran household and the other is not, the veteran household should be prioritized first.

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Where the CoC has adopted the orders of priority described in the Prioritization Notice, recipients of either dedicated or prioritized CoC Program-funded PSH must select persons for permanent supportive housing in the following order: Order of Priority 1 - A household should be prioritized first in dedicated or prioritized PSH if all of the following are true: Individual or head of household meets the definition of chronically homeless per ...
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Where the CoC has adopted the orders of priority described in the Prioritization Notice, recipients of either dedicated or prioritized CoC Program-funded PSH must select persons for permanent supportive housing in the following order:

Order of Priority 1 - A household should be prioritized first in dedicated or prioritized PSH if all of the following are true:

1. Individual or head of household meets the definition of chronically homeless per 24 CFR 578.3; and,
2. The length of time the individual or head of household has been homeless is at least 12 months continuously or over a of at least four occasions in the past 3 years where the total length of time homeless totals at least 12 months; and,
3. The individual or head of household has been identified as having severe service needs.

Order of Priority 2 - A household should be prioritized second in dedicated or prioritized PSH if all of the following are true:

1. Individual or head of household meets the definition of chronically homeless per 24 CFR 578.3; and,
2. The length of time the individual or head of household has been living in a place not meant for human habitation, a safe haven, or in an emergency shelter is at least 12 months continuously or over a period of at least four occasions in the past 3 years where the total length of time homeless totals at least 12 months; and,
3. The individual or head of household has not been identified as having severe service needs; and,
4. There are no chronically homeless households within the CoC’s geographic area that meet the criteria under Order of Priority 1 for dedicated or prioritized PSH.

Order of Priority 3 - A household should be prioritized third in dedicated or prioritized PSH if all of the following are true:

1. Individual or head of household meets the definition of chronically homeless per 24 CFR 578.3; and,
2. The length of time the individual or head of household has been living in a place not meant for human habitation, a safe haven, or in an emergency shelter is at least four occasions in the past 3 years where the total length of time homeless totals less than 12 months; and,
3. The individual or head of household has been identified as having severe service needs; and
4. There are no chronically homeless households within the CoC’s geographic area that meet the criteria under Order of Priority 1 and 2 for dedicated or prioritized PSH.

Order of Priority 4 - A household should be prioritized fourth in dedicated or prioritized PSH if all of the following are true:

1. Individual or head of household meets the definition of chronically homeless per 24 CFR 578.3;
2. The length of time the individual or head of household has been living in a place not meant for human habitation, a safe haven, or in an emergency shelter is at least four occasions in the past 3 years where the total length of time homeless totals less than 12 months (see FAQ 1897); and,
3. The individual or head of household has not been identified as having severe service needs; and
4. There are no chronically homeless households within the CoC’s geographic area that meet the criteria under Order of Priority 1, 2, and 3 for dedicated or prioritized PSH.

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At this time, only 30 percent of all CoC Program-funded PSH is dedicated to the chronically homeless. In order to meet the Administration’s goal of ending chronic homelessness, recipients must significantly increase the number of PSH units targeted to persons with the highest needs and greatest barriers towards obtaining and maintaining housing on their own. HUD expects recipients of PSH to serve people with the longest histories of homelessnes...
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At this time, only 30 percent of all CoC Program-funded PSH is dedicated to the chronically homeless. In order to meet the Administration’s goal of ending chronic homelessness, recipients must significantly increase the number of PSH units targeted to persons with the highest needs and greatest barriers towards obtaining and maintaining housing on their own. HUD expects recipients of PSH to serve people with the longest histories of homelessness and the most severe service needs. Although this typically would be persons experiencing chronically homeless, HUD recognizes that there are homeless individuals and families that have severe service needs that are in need of PSH but that do not yet meet the criteria required to be considered chronically homeless.

Therefore, the Prioritization Notice establishes two orders of priority aimed at ensuring that all PSH funded through the CoC Program targets the persons who need it the most–whether that be a person experiencing chronic homelessness or a person with the most severe needs that do not yet meet the requirements to be considered chronically homeless–and moves communities away from a first-come-first-served approach that has been ineffective in reducing chronic homelessness.

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No - However, HUD strongly encourages CoCs to incorporate the orders of priority described in the Prioritization Notice into their written standards. By doing so, CoCs may then require all CoC Program-funded PSH recipients to comply and follow these orders of priority. Although not required, HUD would only consider a CoC as following the orders of priority provided in the Prioritization Notice when orders of priority are incorporated exactly...
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No - However, HUD strongly encourages CoCs to incorporate the orders of priority described in the Prioritization Notice into their written standards. By doing so, CoCs may then require all CoC Program-funded PSH recipients to comply and follow these orders of priority. Although not required, HUD would only consider a CoC as following the orders of priority provided in the Prioritization Notice when orders of priority are incorporated exactly as stated in the Prioritization Notice.

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A CoC Program-funded PSH project with beds that are specifically targeted to persons experiencing chronic homelessness are considered to be either dedicated or prioritized. Section II of the Prioritization Notice provides guidance on what each of these classifications mean and how they are different. Here is a further breakdown of each: Dedicated PSH - A PSH bed is considered to be “dedicated” when the project recipient has committed to ...
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A CoC Program-funded PSH project with beds that are specifically targeted to persons experiencing chronic homelessness are considered to be either dedicated or prioritized. Section II of the Prioritization Notice provides guidance on what each of these classifications mean and how they are different. Here is a further breakdown of each:

Dedicated PSH - A PSH bed is considered to be “dedicated” when the project recipient has committed to exclusively serving the persons experiencing chronic homelessness for the duration of the grant. These typically are beds in projects that were funded under special Notice of Funding Availability (NOFA) requirements in a given CoC Program Competition (formerly Homeless Assistance Grants competition).

For example, beds in PSH projects that were originally funded as a Samaritan Housing Bonus project are considered to be dedicated and this designation cannot generally be changed. Similarly, in FY 2013 and FY 2014 the only permissible PSH projects that could be funded, either through reallocation or through the FY 2014 bonus, were projects that would exclusively serve chronically homeless individuals and families. These beds are also considered to be dedicated. A recipient may also choose to designate some or all of the beds in a PSH project as dedicated on their own, even when not required through NOFA. Under either circumstance, the recipient is required through its grant agreement to exclusively serve persons experiencing chronic homelessness in those beds that are dedicated unless there are no persons within the CoC’s geographic area that meet that criteria. 

HUD does not expect recipients of dedicated or prioritized CoC Program-funded PSH to hold vacant beds open indefinitely while waiting to locate persons experiencing chronic homelessness. For more information, see FAQ 1895. These beds are also identified as “CH Beds” on a CoC’s Housing Inventory Count. Where PSH projects have dedicated beds on their own and not as part of a NOFA funding requirement, the designation can be changed but only through a grant agreement amendment, because HUD considers this a significant change to the grant agreement.

Prioritized PSH - A PSH bed is considered to be “prioritized” when a project recipient has prioritized persons experiencing chronic homelessness in some or all of its beds even though this was not the target population identified in the original project application. 

Prior to 2013, HUD did not have a meaningful way to track these beds. Beginning in the FY 2013 CoC Program Competition, HUD updated the project application to include a field for the project applicant to identify beds that would be prioritized for use by persons experiencing chronic homelessness. This information is incorporated into the grant agreement for that year and the recipient is required to prioritize persons experiencing chronic homelessness in at least as many beds as indicated in the most recent project application. A recipient of PSH may choose to prioritize persons experiencing chronic homelessness in more beds than indicated in the project application without being required to execute a grant agreement amendment.

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Under the definition of chronically homeless, the head of household (either an adult or a minor if there is no adult present) must have the qualifying disability and meet all of the other criteria (i.e., length of time homeless) in order for a family to be considered chronically homeless. Where there is no adult member of the family, then a minor can be identified as the head of household and that individual is who must meet the criteria. Note: w...
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Under the definition of chronically homeless, the head of household (either an adult or a minor if there is no adult present) must have the qualifying disability and meet all of the other criteria (i.e., length of time homeless) in order for a family to be considered chronically homeless.

Where there is no adult member of the family, then a minor can be identified as the head of household and that individual is who must meet the criteria.

Note: when there are multiple adults in the presenting family, or multiple minors in a family with no adult, HUD does not specify which adult or minor must be the head of household and relies upon the family to self-determine which adult is the head of household.

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Yes, a recipient/subrecipient who is a public housing agency (PHA) may provide rental assistance on behalf of program participants who are residing in PHA-owned units. However, the rent reasonableness determinations and housing quality inspections must be conducted by an entity that is not the PHA. It must also be established that the PHA-owned units assisted with rental assistance are not also being assisted with any other duplicative federal, S...
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Yes, a recipient/subrecipient who is a public housing agency (PHA) may provide rental assistance on behalf of program participants who are residing in PHA-owned units. However, the rent reasonableness determinations and housing quality inspections must be conducted by an entity that is not the PHA. It must also be established that the PHA-owned units assisted with rental assistance are not also being assisted with any other duplicative federal, State, or local housing program as determined by HUD.

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Yes, if a program participant leases a unit where the rent charged exceeds the FMR, the recipient/subrecipient may use rental assistance funds for that unit for an amount above FMR. However, the contract rent charged must be determined to be reasonable in relation to rents being charged for comparable unassisted units in the area. HUD will only provide rental assistance on behalf of a program participant for a unit if the rent for that unit is reasonable.

Rental Assistance

Yes, recipients/subrecipients may use rental assistance funds to pay the security deposit for a unit. The amount of grant funds used to pay the security deposit must not exceed 2 months of rent. In addition to a security deposit, recipients/subrecipients may make an advance payment for first and/or last month's rent.

Rental Assistance

Yes, recipients/subrecipients may use rental assistance funds to pay for any damage to housing due to the action of a program participant. The amount paid must not exceed 1-month’s rent and is a one-time cost per program participant, paid upon the program participant’s exit from the unit.

Rental Assistance

When rental assistance is provided as part of a transitional or permanent supportive housing project, program participants receiving rental assistance are required to pay rent. Recipients/subrecipients must follow the requirements in 24 CFR 578.77(c) when calculating a program participant’s rent, which states that each program participant must pay the highest of the following amounts:   (A) 30 percent family's monthly adjusted income; &nbs...
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When rental assistance is provided as part of a transitional or permanent supportive housing project, program participants receiving rental assistance are required to pay rent. Recipients/subrecipients must follow the requirements in 24 CFR 578.77(c) when calculating a program participant’s rent, which states that each program participant must pay the highest of the following amounts:

  (A) 30 percent family's monthly adjusted income;
  (B) 10 percent of the family's monthly income; or
  (C) the welfare rent (if applicable in your state; if unsure, check with the HUD field office).

However, the rent calculation in 24 CFR 578.77 does not apply to program participants assisted with rental assistance in rapid rehousing or homelessness prevention. Recipients providing rental assistance under the Permanent Housing: Rapid Re-housing or the Homelessness Prevention component must follow the CoC’s written standards for the amount of rental assistance each program participant must pay. These standards are not subject to the rent calculation at 24 CFR 578.77.

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Long-term rental assistance is rental assistance that is provided for an indefinite period of time. It is only eligible under the Permanent Housing: Permanent Supportive Housing program component of the CoC Program. Long-term rental assistance may be tenant-based, project-based, or sponsor-based.

Rental Assistance

Medium-term rental assistance is rental assistance that is provided for 4 to 24 months and is eligible under the following CoC Program components: Permanent Housing: Rapid Rehousing, Homelessness Prevention, and Transitional Housing. Depending on the program component under which medium-term rental assistance is being provided, it could be tenant-based, project-based, or sponsor-based.

Rental Assistance

Short-term rental assistance is rental assistance that is provided for 3 months or less and is eligible under the following CoC Program components: Permanent Housing: Rapid Rehousing, Homelessness Prevention, and Transitional Housing. Depending on the program component under which short-term rental assistance is provided, it may be tenant-based, project-based, or sponsor-based.  

Rental Assistance

In sponsor-based rental assistance, program participants must reside in housing owned or leased by a sponsor organization and arranged through a contract between the recipient/subrecipient and the sponsor organization. A sponsor may be a private, nonprofit organization, or a community mental health agency established as a public nonprofit organization. 

Rental Assistance

In project-based rental assistance, program participants must reside in housing provided through a contract with the owner of an existing structure whereby the owner agrees to lease subsidized units to program participants. Program participants do not retain the rental assistance if they relocate to a unit outside the project; the subsidy remains with the project.

Rental Assistance

In tenant-based rental assistance (TBRA), program participants are responsible for locating housing in the private rental market. If a program participant later moves to another unit, he/she can take the rental assistance and use it in the new unit. Although TBRA program participants may move and retain the rental assistance, recipients/subrecipients administering TBRA may limit where participants may reside if it is necessary to facilitate the c...
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In tenant-based rental assistance (TBRA), program participants are responsible for locating housing in the private rental market. If a program participant later moves to another unit, he/she can take the rental assistance and use it in the new unit. Although TBRA program participants may move and retain the rental assistance, recipients/subrecipients administering TBRA may limit where participants may reside if it is necessary to facilitate the coordination of supportive services.

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The Consolidated Appropriations Act of 2014 (Public Law 113-76, approved January 17, 2014) authorized nonprofit organizations to administer rental assistance only for permanent housing under the CoC Program. This means, as a recipient of funds for transitional housing, you may only use a State, local government, of Public Housing Authority (PHA) to administer rental assistance under your transitional housing project. This is because 24 CFR 5...
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The Consolidated Appropriations Act of 2014 (Public Law 113-76, approved January 17, 2014) authorized nonprofit organizations to administer rental assistance only for permanent housing under the CoC Program. This means, as a recipient of funds for transitional housing, you may only use a State, local government, of Public Housing Authority (PHA) to administer rental assistance under your transitional housing project. This is because 24 CFR 578.51(b) requires rental assistance under both permanent and transitional housing to be administered by a State, unit of general local government, or PHA. The Consolidated Appropriations Act of 2014 only addressed rental assistance administration in permanent housing.

If you would like to amend your grant to move your funds to Permanent Housing: Rapid Re-housing, or, if you believe that your project is not appropriately categorized as TH, meaning it should be a Permanent Housing: Rapid Re-housing project, please contact your local HUD CPD Field Office which will consider your request using the standards applied to any other such request under 24 CFR 578.105.

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The Consolidated Appropriations Act of 2014 (Public Law 113-76, approved January 17, 2014) authorized nonprofit organizations to administer rental assistance in permanent housing funded with fiscal year (FY) 2012, FY 2013, or FY 2014 CoC Program funds. This means, as a recipient of funds for leasing for a permanent housing project, your existing grant is not affected by this language. However, 24 CFR 578.105 states that recipients may make certai...
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The Consolidated Appropriations Act of 2014 (Public Law 113-76, approved January 17, 2014) authorized nonprofit organizations to administer rental assistance in permanent housing funded with fiscal year (FY) 2012, FY 2013, or FY 2014 CoC Program funds. This means, as a recipient of funds for leasing for a permanent housing project, your existing grant is not affected by this language.

However, 24 CFR 578.105 states that recipients may make certain changes to their grants, through a grant agreement amendment, including a shift in funds from one budget line item to another budget line item. If you would like to shift funds from leasing to rental assistance through a grant agreement amendment, please contact your local HUD CPD field office, which will consider your request using the standards applied to any other such request under 24 CFR 578.105.

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The Consolidated Appropriations Act of 2014 (Public Law 113-76, approved January 17, 2014) authorized nonprofit organizations to administer rental assistance in permanent housing under the CoC Program. This means, as a recipient of funds for rental assistance for a permanent housing project, you have the option of contracting with a State, local government, Public Housing Authority (PHA), or nonprofit organization to administer the rental assista...
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The Consolidated Appropriations Act of 2014 (Public Law 113-76, approved January 17, 2014) authorized nonprofit organizations to administer rental assistance in permanent housing under the CoC Program. This means, as a recipient of funds for rental assistance for a permanent housing project, you have the option of contracting with a State, local government, Public Housing Authority (PHA), or nonprofit organization to administer the rental assistance under your project effective immediately. Remember, to award contracts, you must comply with applicable procurement procedures. Alternatively, any of these entities – State, local government, PHA, or nonprofit organizations – may choose to administer the rental assistance themselves.

However, you should be aware that this authorization under the Consolidated Appropriations Act of 2014 was limited to permanent housing rental assistance funded with Fiscal Year (FY) 2012, FY 2013, and FY 2014 CoC Program funds. The ability for nonprofit organizations to administer permanent housing rental assistance with FY 2015 CoC Program funds and beyond is dependent on the renewal of this authority or a permanent statutory fix. If, at any time, Congress discontinues the authority allowing nonprofit organizations to administer permanent housing rental assistance under the CoC Program, any State, local government, PHA, or nonprofit organization contracting with a nonprofit organization to administer rental assistance will be required to cancel the contract with the nonprofit organization and contract with a State, local government, or PHA to administer the rental assistance, and any nonprofit organization administering its own rental assistance would be required to contract with a State, local government, or PHA to administer the rental assistance. If the recipient is a State, local government, or PHA, it may choose to administer the rental assistance itself. 

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PHAs may administer rental assistance awarded under the CoC Program. 

Rental Assistance

The Office of Environment & Energy (OEE) has posted generic formats for Part 58 Exempt, CENST, CEST, and EA reviews: Exempt or Categorically Excluded (CENST) Format Activities Categorically Excluded under 58.35(a) (CEST) Format Environmental Assessment (EA) Format Responsible Entities may have different local or regional forms that they are accustomed to using and are not required to use the formats posted on the HUD Exchange. Additionally,...
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The Office of Environment & Energy (OEE) has posted generic formats for Part 58 Exempt, CENST, CEST, and EA reviews:

• Exempt or Categorically Excluded (CENST) Format
• Activities Categorically Excluded under 58.35(a) (CEST) Format
• Environmental Assessment (EA) Format

Responsible Entities may have different local or regional forms that they are accustomed to using and are not required to use the formats posted on the HUD Exchange.

Additionally, OEE has developed a special format specifically for Part 58 leasing, Project Based Rental Assistance (PBRA), and Sponsor Based Rental Assistance (SBRA) reviews in the CoC Program. This format and accompanying instructions are available at Limited Scope Environmental Review Format for the CoC Program.

HUD has made a determination in the CoC Program No Potential to Cause Effects Memorandum that CoC Program leasing and rental assistance projects with no associated repairs or rehabilitation have No Potential to Cause Effects under Section 106 of the National Historic Preservation Act. This finding should significantly streamline the Section 106 process, as Responsible Entities need only include the memorandum with this finding in their Environmental Review Records to document compliance with that section. No consultation under Section 106 is required for projects that conform to the requirements described in this memorandum.

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For purposes of conducting an environmental review, “tenant-based rental assistance” is defined as rental assistance that is attached to the program participant and not the unit (meaning that the program participant would be free to select their own unit). Where the program participant selects the location, providing TBRA is Categorically Excluded Not Subject to 58.5 (CENST) (see 24 CFR 58.35(b)(1)). The environmental review record for TBRA i...
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For purposes of conducting an environmental review, “tenant-based rental assistance” is defined as rental assistance that is attached to the program participant and not the unit (meaning that the program participant would be free to select their own unit). Where the program participant selects the location, providing TBRA is Categorically Excluded Not Subject to 58.5 (CENST) (see 24 CFR 58.35(b)(1)). The environmental review record for TBRA is very limited and can generally be completed quickly. View formats for completion of a CENST review.

In the CoC Program, recipients and subrecipients providing TBRA may limit where program participants may live when necessary to facilitate the coordination and delivery of supportive services. Recipients may require program participants to live in a specific area for their entire period of participation, in a specific structure for the first year, and in a specific area for the remainder of the period of participation. In addition, program participants receiving rental assistance in transitional housing may be required to live in a specific structure for their entire period of participation in transitional housing (see 24 CFR 578.51(c) for more information). When this occurs and the recipient defines the location where the program participant may rent, the project is considered leasing for purposes of the level of review. In this case, the project requires a “limited scope” Categorically Excluded Subject to 58.5 (CEST) environmental review. View format and instructions for completion of a limited scope CEST review.

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Regulations at 24 CFR Part 58 authorize units of general local government to conduct environmental reviews for projects funded with HUD money where permitted by program legislation. Local governments performing environmental review responsibilities under Part 58 are known as Responsible Entities (RE). When a HUD recipient is a unit of general local government, it must conduct the environmental review and does not have the option to push the respo...
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Regulations at 24 CFR Part 58 authorize units of general local government to conduct environmental reviews for projects funded with HUD money where permitted by program legislation. Local governments performing environmental review responsibilities under Part 58 are known as Responsible Entities (RE). When a HUD recipient is a unit of general local government, it must conduct the environmental review and does not have the option to push the responsibility of the review to HUD. Part 58 applies to all programs funded under the HEARTH Act, including the CoC Program. Review Section 100261 of the Moving Ahead for Progress in the 21st Century Act (MAP-21) for technical amendments to the HEARTH Act. 

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HUD has developed 2 forms which together complete the Part 50 environmental review for CoC Program leasing, Project Based Rental Assistance (PBRA), and Sponsor Based Rental Assistance (SBRA) projects. These include a form to be prepared by the recipient and submitted to HUD and a second form to be completed by HUD staff upon receipt of the recipient’s form. There should not be a need for Part 50 CENST reviews in the CoC Program.  The proce...
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HUD has developed 2 forms which together complete the Part 50 environmental review for CoC Program leasing, Project Based Rental Assistance (PBRA), and Sponsor Based Rental Assistance (SBRA) projects. These include a form to be prepared by the recipient and submitted to HUD and a second form to be completed by HUD staff upon receipt of the recipient’s form. There should not be a need for Part 50 CENST reviews in the CoC Program. 

The process for completion by HUD staff is as follows:

1. Request information for each site from the recipient using Environmental Review Information: Leasing or Project-Based Assistance under the Continuum of Care (CoC) Program Recipient
2. Review the information and documentation and confirm that project conforms to HUD's environmental policies.
3. Certify the review using the Finding of Compliance for Leasing or Project-Based Assistance under the Continuum of Care (CoC) Program (HUD Field Office)

HUD has made a determination in the CoC Program No Potential to Cause Effects Memorandum that CoC Program leasing and rental assistance projects with no associated repairs or rehabilitation have No Potential to Cause Effects under Section 106 of the National Historic Preservation Act. This finding should significantly streamline the Section 106 process, as Responsible Entities need only include the memorandum with this finding in their Environmental Review Records to document compliance with that section. No consultation under Section 106 is required for projects that conform to the requirements described in this memorandum.

NOTE: These steps DO NOT require HUD staff to be physically onsite of a CoC Program project.

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First, it is important to ensure that having HUD staff complete an environmental review under Part 50 is the appropriate action, as this should be the case only under very limited circumstances. Environmental reviews for CoC Program projects should be conducted by Responsible Entities under Part 58 by default. Before proceeding with the review under Part 50, work with HUD to find a Responsible Entity able to conduct the environmental review under...
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First, it is important to ensure that having HUD staff complete an environmental review under Part 50 is the appropriate action, as this should be the case only under very limited circumstances. Environmental reviews for CoC Program projects should be conducted by Responsible Entities under Part 58 by default. Before proceeding with the review under Part 50, work with HUD to find a Responsible Entity able to conduct the environmental review under Part 58. HUD will conduct these reviews only where all of the following apply:

1. The CoC Program recipient is not an unit of general local government,
2. The units of general local government with jurisdiction have refused to act as the Responsible Entity, and
3. HUD has determined that it must perform the environmental review under Part 50.

If the environmental review must be performed under Part 50, recipients must work with HUD to complete the environmental review. While HUD will compile the environmental review record and be legally responsible for the content of the environmental review, recipients must assist HUD by providing maps and any required analysis to support the environmental findings. For leasing or rental assistance projects, use the Environmental Review Information: Leasing or Project-Based Assistance Under the CoC Program form to supply HUD with information on each site requiring an environmental review.

Note that the environmental review is not complete until HUD has reviewed the information submitted with the Environmental Review Information form and certified the environmental review. Recipients cannot commit CoC Program funds to a project until HUD has confirmed that the environmental review is complete.

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24 CFR 58.35(b)(3) designates “operating costs including maintenance, security, operation, utilities, furnishings, equipment, supplies, staff training and recruitment and other incidental costs” as CENST. The HUD Memorandum: Guidance for Categorizing an Activity as Maintenance for Compliance with HUD's Environmental Regulations, 24 CFR Parts 50 and 58 will clarify the meaning of “maintenance.” All other listed activities should ...
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24 CFR 58.35(b)(3) designates “operating costs including maintenance, security, operation, utilities, furnishings, equipment, supplies, staff training and recruitment and other incidental costs” as CENST. The HUD Memorandum: Guidance for Categorizing an Activity as Maintenance for Compliance with HUD's Environmental Regulations, 24 CFR Parts 50 and 58 will clarify the meaning of “maintenance.” All other listed activities should be interpreted to apply to business expenses without physical or environmental impacts.

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The environmental regulations specify that tenant-based rental assistance is CENST (see 24 CFR 50.19(b)(11), 58.35(b)(1)) and that leasing is CEST (see 50.20(a)(4), 58.35(a)(5)). The environmental regulations are silent regarding project based rental assistance (PBRA) and sponsor-based rental assistance (SBRA), but they have long been interpreted as being equivalent to leasing because the funding is attached the unit or structure (like leasing) a...
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The environmental regulations specify that tenant-based rental assistance is CENST (see 24 CFR 50.19(b)(11), 58.35(b)(1)) and that leasing is CEST (see 50.20(a)(4), 58.35(a)(5)). The environmental regulations are silent regarding project based rental assistance (PBRA) and sponsor-based rental assistance (SBRA), but they have long been interpreted as being equivalent to leasing because the funding is attached the unit or structure (like leasing) and not to the program participant (like TBRA). Therefore, HUD includes PBRA and SBRA intothe leasing category listed in 50.20(a)(4) and 58.35(a)(5). 

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The recipient in a Balance of State CoC does not have to defer to an entitlement jurisdiction to perform the environmental review. Any unit of government may act as the Responsible Entity (RE) to complete the environmental review. If a recipient is a nonprofit organization and local government refuses to act as the RE, then the recipient may request the state to act as RE.

Environmental Review

HUD recommends a new review every five years or sooner if/when environmental conditions change.

Environmental Review

Yes, all CoC Program projects require environmental reviews. Reviews for TBRA, SBRA, and PBRA may be conducted by the CoC Program recipient under Part 58 if the recipient is a unit of government or HUD per Part 50 if the recipient is not of a unit of government and a Responsible Entity does not have the capacity to conduct an environmental review. Tenant-based rental assistance is Categorically Excluded Not Subject to 58.5 (CENST), because the re...
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Yes, all CoC Program projects require environmental reviews. Reviews for TBRA, SBRA, and PBRA may be conducted by the CoC Program recipient under Part 58 if the recipient is a unit of government or HUD per Part 50 if the recipient is not of a unit of government and a Responsible Entity does not have the capacity to conduct an environmental review. Tenant-based rental assistance is Categorically Excluded Not Subject to 58.5 (CENST), because the rental assistance is attached to the program participant and not the unit. CoC Program leasing, sponsor-based rental assistance, and project-based rental assistance are a higher level of review, Categorically Excluded Subject to 58.5 (CEST), because the rental assistance is attached to the unit.

If a CoC Program recipient is completing an environmental review for one of these activities under Part 58, consult with your Field Environmental Officer for information on how to conduct a limited scope review. Again, environmental reviews should cover the entire building or site, and are generally good for five years.

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Generally, yes; however, this is a very quick process. Environmental reviews should be based on the building and the surrounding geography, and not on the actual unit. Therefore, if a unit is located within a building where an environmental review was already conducted, then HUD or the Responsible Entity (RE) will only need to verify that a review was conducted within the last five years or if/when the environmental conditions change. If HUD...
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Generally, yes; however, this is a very quick process. Environmental reviews should be based on the building and the surrounding geography, and not on the actual unit. Therefore, if a unit is located within a building where an environmental review was already conducted, then HUD or the Responsible Entity (RE) will only need to verify that a review was conducted within the last five years or if/when the environmental conditions change. If HUD or the RE can verify that an environmental review has been conducted on the project site(s), then no new review is required.  

For example, if an environmental review was conducted on a multi-unit apartment complex within the last five years, a new unit in that building may be leased without completing a new environmental review. 

However, for any scattered-site leased (this also includes sponsor-based and project-based rental assistance) unit located in a building that has not received an environmental review within the last 5 years, a limited scope review is required prior to signing a new lease and committing CoC Program funds to the unit.

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Most reviews for CoC Program projects do not require an environmental review to be conducted onsite, since most projects only require a limited scope review. This includes: leasing, project-based, and sponsor-based rental assistance. Consult with your Field Environmental Officer for information on how to conduct a limited scope review. If a CoC Program project involves any activities beyond leasing or rental assistance, including repairs, rehabil...
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Most reviews for CoC Program projects do not require an environmental review to be conducted onsite, since most projects only require a limited scope review. This includes: leasing, project-based, and sponsor-based rental assistance. Consult with your Field Environmental Officer for information on how to conduct a limited scope review. If a CoC Program project involves any activities beyond leasing or rental assistance, including repairs, rehabilitation, demolition, or construction, a more intensive environmental review is required. 

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Yes. All CoC Program projects are required to have an environmental review. However, not all projects require the same level of review. Most CoC Program projects will be at the Categorically Excluded, Not Subject To Part §58.5 or Categorically Excluded Subject To §58.5, which do not require the reviewer to be physically onsite of a CoC Program project.

Environmental Review

There are 5 different levels of environmental review. However, CEST is the only level of review required by HUD CPD field office staff: CEST: Categorically Excluded, Subject To §58.5 (also subject to §58.6) Includes CoC Program leasing, sponsor-based and project-based rental assistance, minor rehabilitation The remaining 4 levels of review are: CENST: Categorically Excluded, Not Subject To §58.5 (still subject to §58.6) Includes CoC Pr...
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There are 5 different levels of environmental review. However, CEST is the only level of review required by HUD CPD field office staff:

• CEST: Categorically Excluded, Subject To §58.5 (also subject to §58.6)
  • Includes CoC Program leasing, sponsor-based and project-based rental assistance, minor rehabilitation

The remaining 4 levels of review are:

• CENST: Categorically Excluded, Not Subject To §58.5 (still subject to §58.6)
  • Includes CoC Program tenant-based rental assistance, operating costs, maintenance
• Exempt: Subject to §58.6 (applies to Part 58 only)
  • Includes planning, services, and administrative costs
• EA: Environmental Assessment
  • Includes new construction, demolition, and major rehabilitation 
• EIS: Environmental Impact Statement
  • Applies to projects affecting 2,500 or more units or where a Finding of Significant Impact was made

HUD has guidance and suggested formats, which may vary by region, for each level of review. Refer to the Environmental Review page and consult with your local Field Environmental Officer for local requirements.

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Per 24 CFR Part 50, HUD performs environmental reviews. Recipients of HUD funds will assist HUD with the preparation of the environmental review by supplying key documents and analysis; however, HUD is legally responsible for the content of the environmental review. Part 50 applies where program legislation does not permit the use of Part 58, if the Responsible Entity (RE) does not have capacity to conduct an environmental review, or if 24 CFR 58...
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Per 24 CFR Part 50, HUD performs environmental reviews. Recipients of HUD funds will assist HUD with the preparation of the environmental review by supplying key documents and analysis; however, HUD is legally responsible for the content of the environmental review. Part 50 applies where program legislation does not permit the use of Part 58, if the Responsible Entity (RE) does not have capacity to conduct an environmental review, or if 24 CFR 58.11(d) applies. Per 24 CFR 58.11(d), a local government that is not the direct recipient of HUD funds may refuse to act as Responsible Entity. In the CoC Program, Part 50 only applies in cases where a unit of government is not the direct recipient of grant funds.

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Yes, CoC Program recipients may use project administrative funds to pay any costs associated with the environmental review responsibilities. See Section 578.59(a)(3) of the CoC Program interim rule for more information.

Environmental Review

An environmental review is an analysis of the impact of a project on the surrounding environment and vice versa. This ensures that HUD-funded projects provide decent, safe, and sanitary housing. Environmental reviews MUST be conducted BEFORE funds are committed to a project.

Environmental Review

The total number of stakeholder respondents for your CoC should be at least 6 and no more than 20. There are four required respondent types (CoC Lead, HMIS Lead, ESG/HPRP Grantee(s), and CoC Provider). If no one from these categories completes a self-assessment tool the overall CoC Check-up self-assessment will be considered incomplete.

Accessing and Submitting the Self-Assessment

Yes, this is the CoC’s tool. Please remember that there is a minimum requirement of 6 respondents in order to complete the Check-up. Four of the respondent types must be the CoC Lead, HMIS Lead, ESG/HPRP Grantee, and one CoC Provider.

Accessing and Submitting the Self-Assessment

The CoC Lead will only be able to generate reports reflecting an aggregate of all the respondents’ answers.

Accessing and Submitting the Self-Assessment

Once the survey is submitted it cannot be edited or accessed again. The respondent will have the option to print the completed self-assessment once they submit the survey by selecting “OK”.

Accessing and Submitting the Self-Assessment

When you finish the last question of the Self-Assessment, you will be taken to a screen where you can “Return” to the survey or “Submit” the survey. Once you click “Submit”, a message will pop-up reminding the respondent that once the Self-Assessment is submitted it cannot be edited or accessed again. If you are sure you are ready to submit, click “Ok”. Once the survey is submitted you will be able to print the survey or save it a...
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When you finish the last question of the Self-Assessment, you will be taken to a screen where you can “Return” to the survey or “Submit” the survey. Once you click “Submit”, a message will pop-up reminding the respondent that once the Self-Assessment is submitted it cannot be edited or accessed again. If you are sure you are ready to submit, click “Ok”. Once the survey is submitted you will be able to print the survey or save it as a pdf to your computer.

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No, respondents can click “Previous” to navigate to a previous screen.

Accessing and Submitting the Self-Assessment

Yes, the respondent must answer all questions on the screen in order to move forward.

Accessing and Submitting the Self-Assessment

Yes, the system will bookmark on the screen the respondent last entered an answer. When a respondent logs back in, he or she will be taken to this page.

Accessing and Submitting the Self-Assessment

No, the comment box is for comments across the specific domain.

Accessing and Submitting the Self-Assessment

Public reporting burden for this collection of information is estimated to average 1.5 hours per respondent, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.

Accessing and Submitting the Self-Assessment

Once in the CoC Lead Portal, CoC Leads can choose to “Enter Respondents” by listing contact information for each respondent and then selecting the “Send Invitation” button. An email will immediately be sent to each person listed with a link to access the survey.

Accessing and Submitting the Self-Assessment

CoC stakeholders who are invited to complete the assessment will receive an email with a link to the survey from their CoC Lead. If the respondent does not complete the survey in one session they will use the same link to re-enter the site. The system will bookmark where they stopped the survey and when they reenter they will be taken to that page.

Accessing and Submitting the Self-Assessment

Yes, the whole Final CoC Self-Rating must be completed by each CoC. The final CoC Self-Rating is not the same as the CoC Lead rating provided during stage 1 of the CoC Check-up process. The self-rating survey represents the ratings for each indicator that the CoC lead decision-making group believes best reflect the CoC's performance.   The final self-ratings may be the same as or different than the mean/median rating across all stakeholders,...
↓ Read More. Final CoC Self-Rating

Yes, the whole Final CoC Self-Rating must be completed by each CoC. The final CoC Self-Rating is not the same as the CoC Lead rating provided during stage 1 of the CoC Check-up process. The self-rating survey represents the ratings for each indicator that the CoC lead decision-making group believes best reflect the CoC's performance.  

The final self-ratings may be the same as or different than the mean/median rating across all stakeholders, which can be viewed by generating a CoC Summary and Detail Report,  or what the CoC lead entered as a stakeholder. CoC decision-making groups are encouraged to review the aggregate score for each indicator and make adjustments as appropriate. These scores should then be entered in the CoC Lead portal as the final self-rating.

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No, The CoC Check-up is not associated with the application process. HUD will not have access to individual CoC responses or reports.HUD will only see aggregated data at the regional and national level.

General Technical

All CoCs are encouraged to participate in the CoC Check-up process. While it is not mandatory, completion of the CoC Check-up is required to request HUD-funded Technical Assistance (TA).

General Technical

The Check-up is an opportunity for CoCs to assess how they function across a wide cross-section of CoC accountabilities. These accountabilities are organized into the following four domains, each with their own sub-elements and corresponding indicators:  CoC Governance and Structure CoC Plan and Planning Process CoC Infrastructure and Administrative Capacity CoC Housing and Services Survey questions will measure elements related to each of...
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The Check-up is an opportunity for CoCs to assess how they function across a wide cross-section of CoC accountabilities. These accountabilities are organized into the following four domains, each with their own sub-elements and corresponding indicators: 

• CoC Governance and Structure
• CoC Plan and Planning Process
• CoC Infrastructure and Administrative Capacity
• CoC Housing and Services

Survey questions will measure elements related to each of the above domains.

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No, participation in the CoC Check-up is not mandatory, but completion is required to request HUD-funded Technical Assistance (TA).

General Technical

The CoC Check-up serves multiple purposes:  To determine the current functional capabilities of each CoC, and the degree to which CoCs are prepared for HEARTH implementation. To help CoCs identify areas for improvement. To serve as a tool for continuous improvement by helping CoCs identify (and track progress against) specific goals and action steps that will be documented in a CoC Action Plan. To help identify areas for possible technical ...
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The CoC Check-up serves multiple purposes: 

• To determine the current functional capabilities of each CoC, and the degree to which CoCs are prepared for HEARTH implementation.
• To help CoCs identify areas for improvement.
• To serve as a tool for continuous improvement by helping CoCs identify (and track progress against) specific goals and action steps that will be documented in a CoC Action Plan.
• To help identify areas for possible technical assistance.

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Recipients/subrecipients may use program income on any eligible costs in Subpart D of the CoC Program Interim Rule, in accordance with the requirements of the CoC Program, even if the cost was not documented in the approved grant agreement. However, recipients/subrecipients must document that the program income was expended in accordance with the requirements of the CoC Program. Therefore, recipients/subrecipients are prohibited from using progra...
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Recipients/subrecipients may use program income on any eligible costs in Subpart D of the CoC Program Interim Rule, in accordance with the requirements of the CoC Program, even if the cost was not documented in the approved grant agreement. However, recipients/subrecipients must document that the program income was expended in accordance with the requirements of the CoC Program. Therefore, recipients/subrecipients are prohibited from using program income on any costs that would not be eligible to charge to the CoC Program grant.

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No. Section 578.87(d) of the CoC Program Interim Rule prohibits recipients/ subrecipients from charging program participants any charges other than occupancy charges or rent. Section 578.77 further explains how to calculate rent and occupancy charges; the amount that a program participant must pay varies depending on the type of assistance provided by the recipient/subrecipient. ...
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No. Section 578.87(d) of the CoC Program Interim Rule prohibits recipients/ subrecipients from charging program participants any charges other than occupancy charges or rent. Section 578.77 further explains how to calculate rent and occupancy charges; the amount that a program participant must pay varies depending on the type of assistance provided by the recipient/subrecipient. 

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An HPC is a CoC that meets all of the requirements found in Subpart E of 24 CFR part 578. To be considered for HPC designation, the Collaborative Applicant, on behalf of the CoC, must complete the HPC forms in e-snaps, as well as attach the required documents for HUD review. As indicated in the Notice CPD-18-06: CoC Program High Performing Community (HPC) Registration Notice, certain types of information will be confirmed against the information...
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An HPC is a CoC that meets all of the requirements found in Subpart E of 24 CFR part 578. To be considered for HPC designation, the Collaborative Applicant, on behalf of the CoC, must complete the HPC forms in e-snaps, as well as attach the required documents for HUD review. As indicated in the Notice CPD-18-06: CoC Program High Performing Community (HPC) Registration Notice, certain types of information will be confirmed against the information provided by the CoC to the Homelessness Data Exchange (HDX).

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For the purpose of defining employment income for reporting in the Homeless Management Information System (HMIS), HUD relies on the Internal Revenue Service’s (IRS) definition of wages, salaries, tips, and business income. The IRS requires people to report all income received from a business, unless it is excluded by law, and any income paid as compensation for employment. The income may come in regular increments (e.g., through a regular paych...
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For the purpose of defining employment income for reporting in the Homeless Management Information System (HMIS), HUD relies on the Internal Revenue Service’s (IRS) definition of wages, salaries, tips, and business income. The IRS requires people to report all income received from a business, unless it is excluded by law, and any income paid as compensation for employment. The income may come in regular increments (e.g., through a regular paycheck for a full- or part-time job) or be paid in irregular increments (e.g., for day labor or occasional contract work like construction). It is important to note that the employment income is collected as a monthly income amount. Irregular increment payments should only be included in they are received with some frequency. For instance, if a homeless person does regular seasonal work the worker should try to assess what that amount would be per month over the year. Recipients should include income from sources even if it is not reported to the IRS (i.e., under the table work).  

In the event that a person is receiving an education or employment stipend to cover the cost of living, the amount of money associated with those living costs should be counted as employment income. This would not include the cost of paying for school related expenses (for an education stipend) or business expenses, like uniforms or tools (for employment stipends). Money received from tax refunds, including the earned income tax credit, should not be counted as employment income.

This definition of employment income is intended to assist persons entering data into HMIS in determining what employment income means. For the purpose of reporting, HUD does not require documentation that verifies employment income, such as tax documentation. This response is not intended to answer every question regarding all possible sources of income. Rather, this response is intended to provide persons entering income data into HMIS with the basic parameters and guidelines whereby they can decide how to characterize various income sources that their clients present with.  

Please note that this guidance is limited to HMIS data entry only and does not replace or supersede any income eligibility requirements, including documentation a particular program may require and does not relate to rent calculation income or documentation. For further information about income eligibility requirements, recipients should refer to the regulations and guidance documents for the program funds that they are receiving.

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The HMIS Lead is responsible for managing the HMIS for the CoC's geographic area, in accordance with the requirements of the CoC Program Interim Rule and any HMIS requirements prescribed by HUD. Any additional responsibilities assigned to the HMIS Lead should be documented in the CoC's governance charter, but may also be clarified in a separate, more detailed written agreement that is incorporated by reference into the CoC’s governance charter....
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The HMIS Lead is responsible for managing the HMIS for the CoC's geographic area, in accordance with the requirements of the CoC Program Interim Rule and any HMIS requirements prescribed by HUD. Any additional responsibilities assigned to the HMIS Lead should be documented in the CoC's governance charter, but may also be clarified in a separate, more detailed written agreement that is incorporated by reference into the CoC’s governance charter.

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The HMIS Lead is the eligible applicant designated by the CoC, in accordance with the CoC Program Interim Rule, to manage the CoC‘s HMIS on the CoC's behalf.

General

The exit destination for persons attending college will depend on the specifics of the exit situation, but it is important to select a destination response category that reflects both the true nature of the situation and the fact that continuing education is a positive outcome for the client.  In some cases, a client may be exiting to live with his or her family or with friends with the expectation that they will live there while they are in...
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The exit destination for persons attending college will depend on the specifics of the exit situation, but it is important to select a destination response category that reflects both the true nature of the situation and the fact that continuing education is a positive outcome for the client. 

In some cases, a client may be exiting to live with his or her family or with friends with the expectation that they will live there while they are in school. In this case, project staff should select “living with family (or friends, as appropriate), permanent tenure.” Although the student may be expected to move out after graduation or completing the education program, this response category is most consistent with the general understanding that the client is expected to live with family or friends for a prolonged period. 

In other cases, a client is exiting to live in a dormitory operated by the school. In this case, the housing is only available for the time the student is enrolled in school. The response category selected should again be consistent with the notion that the young person moving into a dormitory will be there for a prolonged period of time. In this case, the client can be considered to be in rental housing, consistent with the terms of the agreement between the student and the school. Similar to rental housing, dorms are not owned by their tenants and students in dorms have certain rights and responsibilities, including the requirement to pay for their housing. If a person is entering a dorm, the recipient should indicate that the client’s destination is “rental by client, no ongoing housing subsidy,” unless there is a subsidy directly tied to the dorm. For example, if a person gets financial aid, and uses that aid to pay for their dorm room, then the exit destination is “rental by client, no ongoing housing subsidy.” However, if a person gets a free dorm room as part of their financial aid package, then the recipient should indicate “rental by client, with other ongoing housing subsidy.” In other words, a subsidy only counts if there is funding that specifically goes to pay for the housing and that subsidy in some way goes directly from the payor to the housing provider. If a student will be living off campus and using a typical housing subsidy such as Housing Choice Voucher, then the recipient should select “rental by client, with other ongoing housing subsidy” as the exit destination.

The bottom line is that HUD considers continuing education, including attending a formal college degree program, to be a positive outcome for clients and wants to encourage programs to include attending college as a positive exit for their youth. However, recipients should continue to accurately reflect clients’ actual destinations where a specific response category exists (e.g., emergency shelter, place not meant for human habitation, halfway house), regardless of the educational plans. As long as the exit is to housing (i.e. not living in their car, on the streets, in an abandoned building, etc., while pursuing education) and regardless of the length of the educational program’s semester, the exit should be recorded as positive by using the categories described above.

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A subrecipient in the CoC Program is a private nonprofit organization, State or local government, or instrumentality of a State or local government, or a public housing agency that receives a subgrant from a recipient to carry out all or part of a CoC Program project. 

General

A CoC Program recipient is an applicant of CoC Program funds that executes a grant agreement with HUD for those CoC Program funds. To be eligible to apply for CoC Program funds, an applicant must be a private nonprofit organization, State, local government or instrumentality of State or local government, or a public housing agency.  

General

The Collaborative Applicant is the eligible applicant (State, unit of local government, private, nonprofit organization, or public housing agency) designated by the CoC to: Collect and submit the required CoC Application information for all projects the CoC has selected for funding, and Apply for CoC planning funds on behalf of the CoC. The CoC may assign additional responsibilities to the Collaborative Applicant so long as these responsibiliti...
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The Collaborative Applicant is the eligible applicant (State, unit of local government, private, nonprofit organization, or public housing agency) designated by the CoC to:

1. Collect and submit the required CoC Application information for all projects the CoC has selected for funding, and
2. Apply for CoC planning funds on behalf of the CoC.

The CoC may assign additional responsibilities to the Collaborative Applicant so long as these responsibilities are documented in the CoC's governance charter.

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The CoC board is the collective of individuals designated to provide oversight and governance on behalf of the CoC. The CoC Board’s responsibilities are defined by the CoC and must be described in the CoC’s governance charter. The CoC Board must be representative of the relevant organizations and of projects serving homeless populations and subpopulations within the CoC's geographic area. The CoC Board must also include at least one homeless ...
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The CoC board is the collective of individuals designated to provide oversight and governance on behalf of the CoC. The CoC Board’s responsibilities are defined by the CoC and must be described in the CoC’s governance charter.

The CoC Board must be representative of the relevant organizations and of projects serving homeless populations and subpopulations within the CoC's geographic area. The CoC Board must also include at least one homeless or formerly homeless individual.

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A Continuum of Care (CoC) is the group organized to carry out the responsibilities prescribed in the CoC Program Interim Rule for a defined geographic area. A CoC should be 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...
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A Continuum of Care (CoC) is the group organized to carry out the responsibilities prescribed in the CoC Program Interim Rule for a defined geographic area. A CoC should be 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.

Responsibilities of a CoC include operating the CoC, designating and operating an HMIS, planning for the CoC (including coordinating the implementation of a housing and service system within its geographic area that meets the needs of the individuals and families who experience homelessness there), and designing and implementing the process associated with applying for CoC Program funds.

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The purpose of the CoC Program is to: 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; Promote access to and effective utilization of mainstream programs by homeless individ...
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The purpose of the CoC Program is to:

1. Promote community-wide commitment to the goal of ending homelessness;
2. 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;
3. Promote access to and effective utilization of mainstream programs by homeless individuals and families; and
4. Optimize self-sufficiency among individuals and families experiencing homelessness.

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The way UFA grants are setup are different than grants funded under a Collaborative Applicant. Because the UFA renewal grant encompasses all renewal projects, the UFA has unique ability to move funds across all projects, regardless of component type, within the grant. The UFA must work with its local HUD field office to make changes to the projects under the UFA grant. All budget changes will be reflected in eLOCCS via the local HUD field office....
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The way UFA grants are setup are different than grants funded under a Collaborative Applicant. Because the UFA renewal grant encompasses all renewal projects, the UFA has unique ability to move funds across all projects, regardless of component type, within the grant. The UFA must work with its local HUD field office to make changes to the projects under the UFA grant. All budget changes will be reflected in eLOCCS via the local HUD field office. However, per 24 CFR 578.105(a), the only budget changes that require a grant amendment are shifts of more than 10 percent of the total grant award amount from one approved eligible activity category to another activity in a single year.

Provisions at 24 CFR 578.105(a)(2), further clarifies that:

“…Approval of shifting funds between activities…is contingent on the change being necessary to better serve eligible persons within the geographic area and ensuring that the priorities established under the NOFA in which the grant was originally awarded, or the most recent NOFA, are met.”

Below are specific scenarios where HUD would allow for the shifting of funds–these shifts only require an amendment if they exceed 10 percent of the total grant award amount per 24 CFR 578.105(a).

UFAs may:

1. Shift funds from one existing project to another, regardless of component type; or
2. Eliminate funding for a single project by moving funds to another project.

If a UFA makes these changes it must also ensure that the projects where funds were reduced continue to meet the scope of work originally committed to in the executed grant agreement. If a budget change results in a significant change to the grant, specifically a reduction in units or a change in subpopulations, the UFA may only make this change through a HUD-approved grant amendment. If a UFA has received permanent housing bonus or Samaritan bonus projects in the past, the UFA must ensure that it continues to meet all requirements of the NOFA under which the project was originally awarded and current regulations. For instance, if a recipient received funding for 10 beds dedicated to chronically homeless persons the recipient must continue to meet that obligation. However, a UFA may choose to move funds between projects and designate a different subrecipient to carry out the responsibilities originally committed to in the executed grant agreement.

Per 24 CFR 578.11(c)(4), prior to making any significant changes requiring a grant agreement amendment or changes that involve eliminating projects, the UFA must obtain approval from the Continuum of Care, and then it may submit such request to HUD for approval.

Because UFAs have the authority to determine the best course of action to fulfill their obligations under the terms of the grant agreement, HUD expects them to meet those terms and obligations. HUD encourages UFAs to use their unique authority to make changes that will make their homeless response system more effective for serving homeless persons.

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UFAs are unique for many reasons, some of which directly affect reporting requirements. UFAs receive two grants: one for all renewal projects, UFA costs, and Continuum of Care (CoC) planning funds; the other for new projects. UFAs are required to report on their outputs and outcomes for all projects. Because funding for several projects is combined in the single renewal grant it is important to clarify that UFAs are not required to submit a separ...
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UFAs are unique for many reasons, some of which directly affect reporting requirements. UFAs receive two grants: one for all renewal projects, UFA costs, and Continuum of Care (CoC) planning funds; the other for new projects. UFAs are required to report on their outputs and outcomes for all projects. Because funding for several projects is combined in the single renewal grant it is important to clarify that UFAs are not required to submit a separate APR for each project. UFAs are required to submit at least one APR for each program component and subcomponent funded under the renewal grant. Program components include permanent housing, transitional housing, supportive services only, HMIS, and homelessness prevention as listed in 24 CFR 578.37(a). Program subcomponents for permanent housing include permanent supportive housing and rapid rehousing as listed in 24 CFR 578.37(a)(1).

For example, if a UFA has 10 renewal transitional housing projects, the UFA may submit a single APR that covers all 10 transitional housing projects. The UFA has the discretion to submit multiple APRs for each component, but HUD only requires that at least one APR be submitted that covers all of its projects for each component and subcomponent.

Currently, e-snaps produces a unique APR for each project submitted during a CoC Program Competition. To submit their APRs in e-snaps, UFAs must select one project per component. HUD prefers that UFAs submit all reporting data under the project’s APR that receives the highest amount of funding for each component type. The UFA should indicate in Q42 all of the project numbers that are being reported under that APR.

Per 24 CFR 578.103(e), UFAs must submit APRs within 90 days of the expiration of the grant. If any UFA believes it will not be able to meet this deadline, it may request an extension for good cause to the local HUD field office. HUD will determine if the request states good cause and if the requested extension date is reasonable.

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No - UFAs are not required to use subrecipients for their grants. The UFA is ultimately responsible for carrying out all of the activities as listed in the project application(s) and grant agreement.

Unified Funding Agencies

If a UFA must replace a subrecipient because the subrecipient is not compliant or it no longer has the capacity or desire to continue carrying out the activities of the project, the UFA may find another subrecipient that has the capacity or the UFA may administer the project itself. HUD expects the UFA to have the capacity to ensure that the project continues with or without the subrecipient.

Unified Funding Agencies

Yes - UFAs may impose remedial actions and sanctions on subrecipients that are not in compliance with CoC Program regulation. Per 24 CFR 578.107(a)-(b), remedial actions and sanctions include: Requiring the subrecipient to submit and comply with proposals for action to correct, mitigate, and prevent noncompliance with program requirements; Changing the method of payment to a reimbursement basis; Suspending payments to the extent the UFA determin...
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Yes - UFAs may impose remedial actions and sanctions on subrecipients that are not in compliance with CoC Program regulation. Per 24 CFR 578.107(a)-(b), remedial actions and sanctions include:

• Requiring the subrecipient to submit and comply with proposals for action to correct, mitigate, and prevent noncompliance with program requirements;
• Changing the method of payment to a reimbursement basis;
• Suspending payments to the extent the UFA determines necessary to preclude the further expenditure of funds for affected activities or projects;
• Continuing the grant with an eligible substitute subrecipient of the UFA’s choosing;
• Denying credit for a matching contribution for all or part of the cost of the affected activities and requiring the recipient to make further matching contributions to make up for the contribution determined to be ineligible;
• Requiring the subrecipient to reimburse the recipient’s line of credit in an amount equal to the funds used for the affected activities;
• Reducing or terminating the remaining grant of a subrecipient;
• Conditioning a future grant; and
• Taking other remedies that are legally available.

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As a recipient, the UFA will be monitored by HUD via the local HUD field office. As described in 24 CFR 578.11(b)(3), the UFA is responsible for monitoring all of its subrecipients. 24 CFR 578.23(c)(8) states that recipients and subrecipients must be monitored annually. Remember, the UFA is the only recipient of grant agreements for the CoC and 24 CFR 578.7(a)(6) establishes that one of the responsibilities of the CoC is to monitor its recipient(...
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As a recipient, the UFA will be monitored by HUD via the local HUD field office. As described in 24 CFR 578.11(b)(3), the UFA is responsible for monitoring all of its subrecipients. 24 CFR 578.23(c)(8) states that recipients and subrecipients must be monitored annually.

Remember, the UFA is the only recipient of grant agreements for the CoC and 24 CFR 578.7(a)(6) establishes that one of the responsibilities of the CoC is to monitor its recipient(s) and subrecipient(s), which includes the UFA.

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The HEARTH Act repealed the "Safe Havens for Homeless Individuals Demonstration Program". HUD will not fund any new Safe Haven projects under the CoC Program. However, HUD will continue to renew funding for an existing Safe Haven project as long as: The project continues to operate within the scope of the grant in effect on August 30, 2012, serving the same population, same number of persons or assisting the same number of units in the same type...
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The HEARTH Act repealed the "Safe Havens for Homeless Individuals Demonstration Program". HUD will not fund any new Safe Haven projects under the CoC Program. However, HUD will continue to renew funding for an existing Safe Haven project as long as:

1. The project continues to operate within the scope of the grant in effect on August 30, 2012, serving the same population, same number of persons or assisting the same number of units in the same type of housing, and operating within the same budget;
    
2. The project remains in compliance with the Safe Haven definition and all regulatory requirements in place on August 29, 2012, the last effective date of the prior Supportive Housing Program regulations; and
    
3. The CoC continues to request funding for the Safe Haven project by requesting funding for the Safe Haven project in the CoC Program Competition.

For additional information about Safe Havens, please refer to the Safe Haven Fact Sheet.

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Yes, a Continuum of Care (CoC) may choose to incorporate specific factors into its Coordinated Entry (CE) process that will assist to identify and prioritize persons most at risk of severe illness from COVID-19. The processes of assessment, scoring, prioritization, and determining eligibility comprise four distinct elements of the CE process that connect CE participants to potential housing and services. In particular, prioritization must be base...
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Yes, a Continuum of Care (CoC) may choose to incorporate specific factors into its Coordinated Entry (CE) process that will assist to identify and prioritize persons most at risk of severe illness from COVID-19. The processes of assessment, scoring, prioritization, and determining eligibility comprise four distinct elements of the CE process that connect CE participants to potential housing and services. In particular, prioritization must be based on a specific and definable set of criteria that are:

1. Made publicly available through written prioritization standards
2. Conducted according to the CoC's written prioritization policies and procedures
3. Applied consistently throughout the CoC to all households being prioritized

Given the significant public health crisis and the unique circumstances of the COVID-19 pandemic, it may be appropriate for CoCs to prioritize households who are at increased risk for severe illness from COVID-19 based on objective factors.

Based on currently available information, the CDC has identified that older adults and people of any age who have certain underlying medical conditions are at increased risk for severe illness from COVID-191. The specific populations served by the CE process – individuals who are homeless, chronically homeless, or at risk of homelessness – who are also in high risk categories for severe illness from COVID-19 face unique challenges that must be urgently addressed.

Given the urgency of the present situation and taking into account the specific subpopulations served by HUD’s homelessness programs and the demonstrated impact homelessness has on aging, it may be permissible to prioritize the following categories of persons for assistance within a CE process, provided that the persons in these categories are eligible for programs receiving CE referrals and the process is applied consistent with federal nondiscrimination requirements:

1. People 50 years and older
2. People of all ages with the following underlying medical conditions:
   • Cancer
   • Chronic kidney disease
   • Chronic obstructive pulmonary disease (COPD)
   • Immunocompromised state (weakened immune system) from solid organ transplant
   • Obesity (body mass index [BMI] of 30 or higher)
   • Serious heart conditions, such as heart failure, coronary artery disease, or cardiomyopathies
   • Sickle cell disease
   • Type 2 diabetes mellitus

If the CDC’s guidance is updated to reflect available data, HUD will update this FAQ accordingly.

Additional Guidance on Prioritization

For CoCs that choose to prioritize these high-risk groups, the CoC must prioritize all identified subgroups. In other words, the CoC must prioritize households who meet the identified age factor as well as households where any household member has any of the identified underlying medical conditions.

With respect to people with underlying medical conditions, any inquiry in the CE process must be focused on the presence of the medical condition, without asking intrusive or detailed questions. Extensive documentation of medical conditions should not be sought and certain individuals cannot be held to stricter documentation standards. For example, an acceptable form of documentation would be for an intake worker may use the above list of underlying medical conditions and ask whether the person has any conditions that fall under any of those categories.

Keep in mind that it is the responsibility of the project receiving referrals from CE to document a household’s eligibility for the project, including documenting homeless or at-risk of homelessness status and any additional Notice of Funding Availability (NOFA) criteria. Not every household that is at increased risk of severe illness for COVID-19 will be eligible for each project.

Additional Objective CE Factors to Address the Impact of COVID-19

In addition, CoCs may also choose to incorporate additional objective factors into their CE process to address the impact of COVID-19 on individuals and families who are homeless or at risk of homelessness. Permissible factors may include any of the following factors:

• Elevated risk of transmission at the location where the person is currently living (e.g., on the street, in a congregate setting such as a shelter, jail, or prison, or other arrangements)
• Inability to take steps to avoid transmission where the person lives or works (e.g., multiple people sharing a sleeping space, work or living environment with close physical interactions and inadequate personal protective equipment (PPE), or living in a place without access to running water)
• Lack of access to healthcare (e.g., lack of health insurance, lack of primary care provider, or use of ER for all medical care)

A CoC that chooses to incorporate any of these additional objective factors must clearly identify and incorporate the specific factors into its CE process and work with its providers to ensure uniform questions are asked consistently of all potential clients.
It may be appropriate for CoCs to prioritize for assistance persons who fall under any of the categories identified in this FAQ as long as the process meets all CE program requirements, including:

• Ensuring that the criteria are applied uniformly throughout the CoC to all households being prioritized
• The process is applied consistent with federal nondiscrimination requirements

CoCs are prohibited from using the prioritization process to discriminate based on protected classes as defined by federal civil rights laws and requirements. These protected classes include race, color, religion, national origin, sex, age, familial status, or disability, as well as compliance with HUD’s Equal Access Rule. For example, CoCs and housing providers must provide reasonable accommodations for individuals with disabilities. Recipients of HUD funding must also ensure that designated accessible units are prioritized for individuals with mobility or sensory impairments who need the accessibility features of these units. For more information on the prioritization stage and fair housing requirements more generally, see FAQ ID 3464 (“My CoC needs to prioritize households to meet the requirements of HUD's Notice CPD-17-01, but we are concerned that we might inadvertently violate federal civil rights laws and requirements, including the Fair Housing Act. How do we prioritize related to vulnerability/need in a non-discriminatory way?“).

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1 HUD is relying on the CDC’s guidance for People with Certain Medical Conditions (dated July 17, 2020) as the basis for identifying certain persons who are at increased risk of severe illness from COVID-19. If the CDC's guidance is subsequently revised, HUD will update this FAQ.

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The assessment and prioritization process must be based on an individual’s vulnerability or need level according to a Continuum of Care’s (CoC) standardized prioritization criteria. In the prioritization stage, the Coordinated Entry (CE) staff person uses assessment data to compare the participant’s level of need with the needs of others on the priority list and prioritizes the person for housing and supportive services based on the CoC’s...
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The assessment and prioritization process must be based on an individual’s vulnerability or need level according to a Continuum of Care’s (CoC) standardized prioritization criteria. In the prioritization stage, the Coordinated Entry (CE) staff person uses assessment data to compare the participant’s level of need with the needs of others on the priority list and prioritizes the person for housing and supportive services based on the CoC’s prioritization standards. Prioritization must be based on a specific and definable set of criteria that are made publicly available through written prioritization standards, conducted according to the CoC’s written prioritization policies and procedures, and applied consistently throughout the CoC to all households being prioritized.

CoCs are prohibited from using the prioritization process to discriminate based on protected classes as defined by Federal Civil Rights laws and requirements. These protected classes include race, color, religion, national origin, sex, age, familial status, or disability. Additionally, the CoC’s policies must be consistent with HUD’s Equal Access requirements, including that (1) housing and shelters funded under CoC, Emergency Solutions Grants (ESG), Housing Opportunities for Persons With AIDS (HOPWA), and other HUD housing programs must be made available to otherwise eligible individuals without regard to sexual orientation, gender identity, or marital status; and (2) equal access to CPD programs, shelters, other buildings and facilities, benefits, services, and accommodations must be provided in accordance with an individual’s gender identity.

For example, a CoC’s CE prioritization determination may not be based on whether an individual has a disability, or a specific type of disability or diagnosis, or another protected characteristic. It must be based on an individual’s vulnerability or need level according to the specific and definable set of prioritization criteria. HUD understands that a person’s vulnerability or need level may be impacted by their lived experience of having a disability, and to the extent that a person’s disability has impacted their vulnerability or need level, the prioritization process may consider those factors, but it would not be appropriate for a Coordinated Entry staff person to assume a person has a particular need based solely on their protected characteristics.  For example, frequency of hospitalizations, difficulties that would limit the type of housing one could access or make it hard to live independently, barriers to securing or maintaining stable employment, needed services, etc., would be appropriate to consider in assessing someone’s vulnerability or need level. Accordingly, it is important that the assessment process captures this type of information about one’s level of need. However, it would not be appropriate to assume, for example, that someone with a physical disability has greater needs or is more vulnerable than persons with a different type of disability. Likewise, it would be inappropriate for an intake or assessment staff person to make generalizations or assumptions that a person with a specific type of disability or illness would prefer to live in a particular setting, or that the person would be unsuccessful or unable to live in a particular setting. Therefore, in assessing a person’s vulnerability or need level, it would be inappropriate to “score” or produce a vulnerability or need “result” based on a disability diagnosis since a diagnosis itself does not indicate how that disability is impacting an individual’s ability to maintain housing or end their current homeless crisis.

It is not appropriate to make presumptions about a person’s needs, without facts regarding actual vulnerability. Assessment and prioritization must be based on an individual’s vulnerability or need level according to the specific and definable set of nondiscriminatory prioritization criteria.

Please refer to Notice CPD-17-01 II.B.11 and III.A for more information about participant autonomy and person-centered approaches to all parts of the Coordinated Entry process.

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Notice-CPD-17-01 states that CoCs covering a large geographic area may design their coordinated entry to include multiple referral zones in order to avoid making persons travel or move long distances in order to be assessed or served. HUD wants to clarify that this is only an option where there are actually housing and service resources available within each referral zone. In the event that resources are concentrated exclusively in particular cou...
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Notice-CPD-17-01 states that CoCs covering a large geographic area may design their coordinated entry to include multiple referral zones in order to avoid making persons travel or move long distances in order to be assessed or served. HUD wants to clarify that this is only an option where there are actually housing and service resources available within each referral zone. In the event that resources are concentrated exclusively in particular counties within the CoC, this type of approach would not be appropriate because persons experiencing homelessness throughout the CoC would not have fair and equal access to available resources. It is important to remember that the CoC is ultimately responsible for addressing the needs of all persons experiencing homelessness within its geographic area. Therefore, when available resources are not broadly distributed throughout the geographic area, HUD expects the CoC to design its coordinated entry in a manner that would allow the same type of access to available resources to all persons experiencing homelessness within the CoC, regardless of which county they are presenting for assistance. Client choice must still be considered when making referrals and persons experiencing homelessness cannot be forced to move to other geographic areas.

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An inclusive and responsive coordinated entry (CE) process for all youth can only be achieved through widespread stakeholder participation in planning and implementing CE. To ensure that the CE process incorporates the needs of youth, the planning and implementation process needs to include: Youth experiencing homelessness; Youth homeless assistance providers including those funded by the Runaway and Homeless Youth Act; Child welfare systems and...
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An inclusive and responsive coordinated entry (CE) process for all youth can only be achieved through widespread stakeholder participation in planning and implementing CE. To ensure that the CE process incorporates the needs of youth, the planning and implementation process needs to include:

• Youth experiencing homelessness;
• Youth homeless assistance providers including those funded by the Runaway and Homeless Youth Act;
• Child welfare systems and their providers including independent living programs;
• School district McKinney-Vento liaisons;
• Representatives from the juvenile and adult justice systems;
• Employment programs;
• Human trafficking providers;
• Law enforcement;
• Health providers;
• Out-of-school time programs; and
• Early childhood providers for pregnant and parenting youth.

Early and ongoing participation by these organizations in communities that have successfully integrated youth experiencing homelessness into their CE processes is credited with building trust in CE for youth-serving providers and other key stakeholders, and with sharing critical knowledge among youth and non-youth stakeholders that has ensured the entire process is youth-appropriate. Continuums of Care (CoCs) should also consider taking inventory of local youth resources beyond traditional homelessness housing and services as there may be more youth resources available to the community than the CoC realizes, including family reunification services and youth homelessness prevention services.

Many stakeholders may not be solely focused on youth homelessness, but will still play an important role. Stakeholders such as child welfare agencies, school district McKinney-Vento liaisons, and juvenile justice programs should be key partners in the development of CE, and once implemented, their roles within the CE process will vary widely based on the program’s specific interactions with youth and the programs’ specific population focus. The key is to generate a mutual understanding between CoCs and community stakeholders early on regarding how youth access CE from non-homelessness dedicated programs and how these programs' resources are accessed by youth through the CE process. In general, programs and system partners will fall into three categories:

• Programs that can connect youth to the CE process - Programs that ask basic questions about housing status and have a protocol for connecting youth to the CE process when a housing or homelessness service need is identified that cannot be provided by the provider or program. These programs may vary greatly in their capacity to connect youth. For example, a program may have limited capacity to add questions to their intake and use a single indicator or observation to trigger a phone call to the CE access point. Another program may have extensive capacity to identify youth experiencing homelessness and at-risk youth and so may ask a series of questions concerning housing status to increase their referral accuracy to the CE process, which is made electronically and seamlessly.
   
• Programs to which the CE process connects youth - Programs that offer resources that are relevant for youth experiencing homelessness and for whom a protocol has been established to connect youth from CE to the intake process for those resources. Programs will vary in their capacity to make themselves available to the CE process. Some may have a simple protocol that allows for a coordinated connection from CE to their services, whether through an electronic connection or even a warm hand off made with the help of staff navigators. Another program with a lot of flexibility may be able to co-locate programming with CE operations ensuring youth can go through the referral and intake process for their services at the same location and time as they go through the CE process.
   
• Programs that are fully integrated into the CE process - Programs that are fully integrated into the CE process where they either participate as an access point for all CE resources or their resources are accessed directly through CE referrals without an additional intake. Full integration for mainstream services will be rare as their expanded population focus and mission often makes full integration burdensome for both parties; although in some circumstances and in some communities it may still be appropriate.

Involving systems and programs that serve youth early in the development process of CE and in an ongoing manner is the best way to ensure that these partners are both identifying and referring youth from their programs to the CE process and that CE process is able to refer to their programs when appropriate.

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No - HUD is not currently requiring reports for coordinated entry. However, HUD is working on guidance specific to coordinated entry and HMIS for both project set-up and reporting, which it will issue in the near future. Communities should ensure that their HMIS is programmed to the 2014 HMIS Data Standards.

Coordinated Entry

Yes - However, it is important to note that data collected for assessment—which could be as simple as scores from assessment tools or something more complex—is not necessarily the same as data collected for HMIS. To the extent that the data overlaps and if your CoC plans to import the data into the HMIS at any point, the CoC must ensure that the module meets all HMIS data and technical standards (i.e., the data collected complies with th...
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Yes - However, it is important to note that data collected for assessment—which could be as simple as scores from assessment tools or something more complex—is not necessarily the same as data collected for HMIS. To the extent that the data overlaps and if your CoC plans to import the data into the HMIS at any point, the CoC must ensure that the module meets all HMIS data and technical standards (i.e., the data collected complies with the 2014 HMIS Data Standards, HUD security policies, and meets any other requirements).

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No - HUD does not require CoCs to use their HMIS as part of their coordinated entry process. However, many communities recognize the benefit of using this option and have incorporated HMIS into their coordinated entry process. HUD is encouraging communities to consider using HMIS but recognizes that other systems might be better or more quickly able to meet the community’s coordinated entry needs, which is acceptable so long as the co...
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No - HUD does not require CoCs to use their HMIS as part of their coordinated entry process. However, many communities recognize the benefit of using this option and have incorporated HMIS into their coordinated entry process. HUD is encouraging communities to consider using HMIS but recognizes that other systems might be better or more quickly able to meet the community’s coordinated entry needs, which is acceptable so long as the community’s coordinated entry meets HUD’s requirements in 24 CFR 578.7(a)(8).

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Depends - HUD recognizes that many HMIS implementations are closed and do not share data across providers. While it is possible to use a closed HMIS as a tool in your coordinated entry process, functionality will vary by system. Your organization should work with the HMIS Lead and HMIS vendor to determine if using the HMIS for the coordinated entry process is possible in your community.

Coordinated Entry

Yes - HMIS funds in the CoC and ESG Programs may be used to pay for coordinated entry, but only to the extent that the coordinated entry is integrated in the CoC’s HMIS. Per 24 CFR 576.107(a)(2) and 24 CFR 578.57(b) HMIS Leads may use funds to pay to customize or enhance the CoC’s HMIS to integrate coordinated entry. Additionally, per 24 CFR 576.107(a)(1) and 24 CFR 578.57(a), all recipients and subrecipients contributing data to the HMIS may...
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Yes - HMIS funds in the CoC and ESG Programs may be used to pay for coordinated entry, but only to the extent that the coordinated entry is integrated in the CoC’s HMIS. Per 24 CFR 576.107(a)(2) and 24 CFR 578.57(b) HMIS Leads may use funds to pay to customize or enhance the CoC’s HMIS to integrate coordinated entry. Additionally, per 24 CFR 576.107(a)(1) and 24 CFR 578.57(a), all recipients and subrecipients contributing data to the HMIS may use funds to pay for entering data into an HMIS that is also used for coordinated entry.

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The primary purpose of the coordinated entry (CE) standardized assessment process is to gather information necessary to determine the severity of a youth’s needs and their eligibility for housing and services in a way that utilizes their strengths and is based on evidence of the risk of becoming or remaining homeless. The CE assessment should gather information on factors that can help systems prevent youth from experiencing homelessness or end...
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The primary purpose of the coordinated entry (CE) standardized assessment process is to gather information necessary to determine the severity of a youth’s needs and their eligibility for housing and services in a way that utilizes their strengths and is based on evidence of the risk of becoming or remaining homeless. The CE assessment should gather information on factors that can help systems prevent youth from experiencing homelessness or end their current homelessness experience as quickly as possible. This is in contrast to a clinical assessment common within the youth-serving field that looks at more in-depth service needs on an ongoing basis throughout a youth’s involvement in the homelessness system. The CE standardized assessment may be a phased assessment utilizing more than one assessment tool, allowing the assessment process to occur over time and only as necessary. For example, a standardized screening and assessment process may have separate tools to:

• Screen for diversion or prevention (such as supportive services, early intervention, and family reunification support)
   
• Assess shelter and other emergency needs
   
• Identify housing and service resources and barriers
   
• Evaluate vulnerability to prioritize for assistance (which may include evaluating risk and protective factors to make placements as effective as possible)
   
• Screen for program eligibility
   
• Facilitate connections to mainstream resources (including adult resources when appropriate)

The CE assessment will likely occur over a period of days or weeks, as needed, depending on the progress a youth experiencing homelessness is making. The different assessments build on each other so a participant does not have to repeat their story. Periodic ongoing assessment should occur to ensure interventions are meeting a youth’s needs, particularly if a youth remains homeless for a long period of time. Federal partners are working together to release more detailed guidance later in 2016 on the use of youth screening and assessment tools within the CE process that can help guide placement decisions for housing and services.

Once youth receive a housing and service intervention through CE, a service provider may assess for additional or more intensive service needs on an ongoing basis while youth are being served in the youth homelessness system. Utilizing screening and assessment is equally as important after a youth has entered into a homelessness program in order to determine if the placement and services are meeting youth needs, or to determine if the youth needs other types of interventions and services.

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Yes. In many situations, family reunification is an appropriate referral within coordinated entry (CE), provided that the family home is a safe and stable environment. Family reunification should be a primary referral option for youth under 18, where only a small percentage may be most appropriately served by an independent, safe, and stable housing situation, and many youth 18 and older will also benefit from family reunification services. The C...
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Yes. In many situations, family reunification is an appropriate referral within coordinated entry (CE), provided that the family home is a safe and stable environment. Family reunification should be a primary referral option for youth under 18, where only a small percentage may be most appropriately served by an independent, safe, and stable housing situation, and many youth 18 and older will also benefit from family reunification services. The CE assessment process should consider family dynamics and the possibility of youth reuniting with family members or caring adults in a safe and stable environment; and “family” options should be broadly defined to include adults who may not be biological parents or biologically related, but whom youth consider to be family members. The CE process should also have access to family reunification service referral options, including non-HUD funded projects, for those youth who are identified as having the potential of returning home before entering the crisis response system or who may quickly exit with the assistance of family interventions. The need for access to family reunification and a broad array of family engagement services in the community is another example of why it is important for the CE process to be linked to mainstream services and other non-HUD funded services.

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RHY programs, whether they are funded federally or privately, are an integral part of many communities’ efforts to prevent and end homelessness. It is therefore vitally important for all RHY providers to be integrated into their community’s Continuum of Care (CoC), to be at the table to provide input, and to help ensure that the coordinated entry (CE) process is fully responsive to the needs of youth experiencing homelessness. In addition to ...
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RHY programs, whether they are funded federally or privately, are an integral part of many communities’ efforts to prevent and end homelessness. It is therefore vitally important for all RHY providers to be integrated into their community’s Continuum of Care (CoC), to be at the table to provide input, and to help ensure that the coordinated entry (CE) process is fully responsive to the needs of youth experiencing homelessness.

In addition to their experience working with youth experiencing homelessness in their respective programs, RHY providers bring with them a wealth of knowledge about the network of social, behavioral health, and other community services vital to ensuring youth experiencing homelessness are able to transition to stability and independence. Because of this specialized knowledge and experience, RHY providers should be involved in general needs assessment planning committees, in addition to the planning, development, and implementation of the CE process. RHY providers should fully participate in: 1) the decision-making process to identify access procedures and locations; 2) designing and informing youth-appropriate screening and assessment tools and related staff training; 3) the development of the prioritization process to ensure vulnerable youth have access to resources; and 4) the development of the referral process, particularly around matching youth needs and strengths to appropriate housing and services.

RHY providers contribute invaluable homelessness prevention and intervention resources to the community through the Basic Center, Transitional Living, Maternity Group Home, and Street Outreach Programs. RHY resources should be fully integrated in the implementation of the CE process by aligning their access, assessment, and prioritization processes with the policies and procedures developed by the full community of stakeholders through CE. Integrating RHY resources is critical to creating a single CE process for youth experiencing homelessness. Beyond the specific CE process, RHY providers can continue to help ensure that resources offered to youth are developmentally appropriate, promote positive youth development, incorporate trauma-informed care, and are culturally and linguistically competent. Federal partners are working together to release more detailed guidance later in 2016 on the important role of RHY providers in the CE process.

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Under current regulations, coordinated entry (CE), at a minimum, must serve youth defined as homeless and at-risk of homelessness by HUD. However, HUD and HHS strongly encourage communities to also include youth considered homeless or runaway by other federal definitions*. The CE process will encounter youth when they are in various stages of experiencing a housing-related crisis and should be designed to accommodate a broad range of youth who ar...
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Under current regulations, coordinated entry (CE), at a minimum, must serve youth defined as homeless and at-risk of homelessness by HUD. However, HUD and HHS strongly encourage communities to also include youth considered homeless or runaway by other federal definitions*. The CE process will encounter youth when they are in various stages of experiencing a housing-related crisis and should be designed to accommodate a broad range of youth who are experiencing homelessness, have runaway, and who are at-risk of homelessness. Through the CE process, Continuums of Care (CoCs) can coordinate non HUD-funded housing and supportive services, as well as HUD-funded Emergency Solutions Grants (ESG) and non-homelessness dedicated HUD programs that may be able to serve those youths who are considered “homeless,” “runaway,” or “at-risk” by other federal definitions. It is important for CoCs to work towards building a broad range of resources that include homelessness prevention, family interventions, an array of housing interventions that include supportive services, and connections to mainstream resources in order to best serve a broad range of youth who are experiencing homelessness, have runaway, and are at-risk of homelessness. The inclusion of a broad range of stakeholders in the CoC, and the implementation and development of the CE process, will help ensure this goal is met.

When working with the broad range of youth, communities may pay particular attention to the unique needs of vulnerable subpopulations including youth who are either overrepresented in the unaccompanied homeless youth population or are particularly vulnerable to the effects of homelessness, such as:

• Youth under the age of 18
• Pregnant and parenting youth
• Youth involved or formerly involved in the child welfare system
• Youth involved or formerly involved in the juvenile justice system
• Youth fleeing or attempting to flee from trafficking or other unsafe living environments
• Youth who identify as lesbian, gay, bisexual, transgender, or questioning (LGBTQ)
• Native American youth
• Youth with special needs or disabilities, including severe behavioral and mental health needs
• Youth who are sharing the housing of others due to loss of housing or economic hardship
• Youth who have run away from home without parental consent
• Youth of color

Coordination with non-youth partners is critical when considering subpopulation approaches as their resource and support needs overlap with non-youth specific providers. For example, pregnant and parenting youth should have access to and may be better served by family-specific resources and youth fleeing unsafe situations may be better served by domestic violence or trafficking-specific resources.

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*View the Definition of Runaway and Homeless Youth as defined by the Runaway and Homeless Youth Act. View the Definition of Homeless Children and Youths as defined by Subtitle VII-B of the McKinney-Vento Homeless Assistance Act.

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Regardless of whether it is through a youth-specific coordinated entry (CE) process or a single CE process serving all populations, including youth, there are critical youth factors for communities to consider when developing a CE process to ensure it is appropriate for youth. Several of these considerations are: Youth-Centered: The CE process should be built on relationships between adults and youth that are empowering to youth and based on pos...
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Regardless of whether it is through a youth-specific coordinated entry (CE) process or a single CE process serving all populations, including youth, there are critical youth factors for communities to consider when developing a CE process to ensure it is appropriate for youth. Several of these considerations are:

• Youth-Centered: The CE process should be built on relationships between adults and youth that are empowering to youth and based on positive youth development principles.
   
• Safe, Inviting, and Accessible Access Points: Access point locations–physical and virtual–should be safe, inviting, and easily accessible for youth, taking into account where youth congregate and other important aspects of local youth culture. Continuums of Care (CoCs) must decide whether they will operate a youth-specific access point for CE with dedicated and specially trained staff or make sure that all general access points have the cultural and linguistic competency to meet youth needs. The important decisions involved in establishing access points highlight why a broad range of stakeholders, including youth providers, should be involved in the CoC and in the planning and implementation of the CE process.
   
• Comprised of Knowledgeable and Trained Staff: Any staff involved in the CE process who will interact with youth – whether at a standalone access point, emergency shelter, or through street outreach – should be adequately trained, meaning they are knowledgeable about topics such as, developmentally appropriate solutions, the eligibility and documentation requirements for the dedicated homeless resources and applicable mainstream resources available through a referral from the CE process.
   
• Developmentally-Appropriate and Trauma-Informed: The CE process and those working directly with youth should be aware of youth brain development, positive youth development frameworks, and trauma frameworks in order to ensure that the CE process as a whole is developmentally appropriate and trauma informed.
   
• Culturally-Appropriate and Inclusive: The CE process, including any assessment tool used with youth, should be responsive to the characteristics and needs of youth, including age, race, ethnicity, sexual orientation, gender identification, and language. The definition of “culturally appropriate” for all youth includes youth who have been victims of human trafficking or domestic violence, LGBTQ youth, and pregnant or parenting youth.
   
• Built on Provider Expertise and Capacity: The CE process for youth should be informed by the expertise and capacity of all youth-serving providers and organizations in a community. Stakeholder engagement in the development, implementation, and process improvement of CE is critical for success.
   
• Informed by the Youth Intervention Model: The CE process, should be grounded in risk and protective factors as noted in the USICH Youth Framework’s Preliminary Intervention Model.

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In order to ensure that youth are referred to appropriate housing and services, a broad array of youth focused housing and services need to be included among all of the resources available to the coordinated entry (CE) process. Youth who have been assessed for housing and services need to know exactly which program they are being referred to, what will be expected of them, and what they should expect from the program. Providers and caseworkers kn...
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In order to ensure that youth are referred to appropriate housing and services, a broad array of youth focused housing and services need to be included among all of the resources available to the coordinated entry (CE) process. Youth who have been assessed for housing and services need to know exactly which program they are being referred to, what will be expected of them, and what they should expect from the program. Providers and caseworkers knowledgeable of a youth’s experiences should provide input on referrals most appropriate for their developmental stage, needs, and strengths, through processes such as case conferencing. The CE process should also incorporate individual project eligibility requirements and current availability because project participants must be eligible for the projects to which they are referred, and the participants may need to meet additional project-specific eligibility requirements that are independent of the assessment and prioritization process. For example, a transitional housing project may be funded to serve individuals with HIV/AIDS. In order for the dedicated project to accept the youth being referred, the youth must meet the priority population that the project is funded to serve, in addition to being prioritized for the type of resource through the CE process. Armed with the best available information, youth can make an informed and supported choice to enroll in their preferred intervention among a comprehensive array of available options that address their needs and for which they are eligible.

CE referrals may occur throughout a young person’s involvement with the homelessness system, usually connected with ongoing assessment. For example, a youth living on the streets may be connected to emergency shelter after an initial triage interaction with a street outreach worker. The youth may receive a more comprehensive assessment once in shelter, and based on the prioritization process described in FAQ 2933, be referred to an intervention that can help to resolve their homelessness, such as family reunification, transitional living programs, rapid re-housing, or other placements and supportive services. Additional referrals may occur after a young person begins participation in a homelessness program if they need additional or different housing and supports to address their homelessness, and may include connections to mainstream services.

HUD and the U.S. Department of Health and Human Services (HHS) acknowledge that the description above for a youth-focused CE process has not been fully realized by many communities and that communities are in different stages of planning and implementing youth processes in their CE. The hope is that these FAQs, as well as upcoming detailed guidance and technical assistance, will enable communities to develop a more robust CE process that is responsive to the needs and strengths of homeless youth and is inclusive of all youth providers.

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Prioritization ensures that youth with the most severe service needs and levels of vulnerability are prioritized for limited housing and homeless assistance resources that meet their needs and strengths and is the process by which a youth is placed in a relative order for referral to different types of housing and services. As discussed in FAQ 2940, runaway and homeless youth (RHY) and other youth providers should play an active role in the Conti...
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Prioritization ensures that youth with the most severe service needs and levels of vulnerability are prioritized for limited housing and homeless assistance resources that meet their needs and strengths and is the process by which a youth is placed in a relative order for referral to different types of housing and services. As discussed in FAQ 2940, runaway and homeless youth (RHY) and other youth providers should play an active role in the Continuum of Care’s (CoC) development of the prioritization process to ensure vulnerable youth have access to resources. Prioritization principles must be consistently applied and may reflect the following vulnerability factors:

• Significant health or behavioral health challenges or functional impairments which require a significant level of support in order to maintain permanent housing;
   
• High utilization of crisis or emergency services, including emergency rooms, jails, and psychiatric facilities to meet basic needs;
   
• The extent to which people, especially youth and children, are unsheltered;
   
• Vulnerability to illness or death;
   
• Risk of continued homelessness;
   
• Vulnerability to victimization, including physical assault, trafficking, or sex work; or
   
• Other factors determined by the community and based on severity of needs.

Assessment tools will capture some of these factors and yield an “assessment score.” The other factors identified by the community, including those that account for the unique experiences and vulnerabilities of youth, will be combined with the assessment score to determine a prioritization “ranking” for housing and services. It is important to note that the “ranking” does not necessarily equal the “assessment score” produced by popular assessment tools. CoCs can choose to prioritize a certain vulnerability factor over another, which would allow an individual to be placed at a higher priority for the next available and appropriate resource than their assessment score dictates. For example, a pregnant or parenting youth might have a moderate risk and vulnerability “assessment score” based on the assessment tools used in the community, but their CoC may determine that all pregnant and parenting youth should be considered at higher risk. Therefore, a pregnant or parenting youth in that community with only a moderate assessment score would be ranked as a higher priority for the next available, appropriate resource. If a youth meets multiple factors prioritized by the community (e.g. a youth is pregnant or parenting, has serious behavioral health needs, and is fleeing domestic violence), the multiple vulnerabilities should contribute to a higher prioritization ranking than if the youth only meets a single factor prioritized by the community. These examples emphasize the importance of setting priorities that consider the vulnerabilities of youth and the limitations of assessment tools. Prioritization ranking must ensure that coordinated entry (CE) prioritizes youth for housing and supportive services when they meet the factors prioritized by the community, even when assessment scores do not indicate a relatively high risk.

Communities should incorporate processes to connect youth who are not ranked high enough for a dedicated homelessness resource to other types of resources in the community. Referrals to services not targeted exclusively to homeless and runaway youth should include family counseling, community-based mental health services, Temporary Assistance to Needy Families (TANF), early childhood supports, education-based supports, and other mainstream services that may be able to help address youths’ needs. RHY providers have experience in making these types of youth-appropriate referrals and links, and can help CoCs develop methods that ensure these types of connections are made through the CE process. Finally, the prioritization process should not limit access to emergency services such as HUD funded emergency shelter or RHY Basic Center Programs, and every attempt should be made to ensure that young people are off the streets as quickly as possible.

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There are several models for access points which include, but are not limited to, the following: “Single point of access” at one central community location, sometimes referred to as centralized intake;   “Multisite centralized access” at several locations in a community, sometimes referred to as hubs or a hybrid approach, that can serve all or certain special populations;   “No wrong door” available on location at any commu...
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There are several models for access points which include, but are not limited to, the following:

• “Single point of access” at one central community location, sometimes referred to as centralized intake;
   
• “Multisite centralized access” at several locations in a community, sometimes referred to as hubs or a hybrid approach, that can serve all or certain special populations;
   
• “No wrong door” available on location at any community provider but still standardized and coordinated through one community-wide process; and
   
• “Virtual or phone access” which allows for mobile access (e.g. 2-1-1, mobile app) to CE and can be combined with any of the processes above.

Youth providers and other community partners can work with their local Continuum of Care (CoC) to serve as an access point in any one of the above models, helping to ensure youth access in a space or manner that is culturally and developmentally appropriate for youth. In communities where a youth provider may not serve as an access point, they can still be an important partner in planning for the most appropriate access point or points for youth in their community.

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A coordinated entry (CE) process standardizes and coordinates the way youth access the community’s homelessness crisis response system and connect with the appropriate resources they need to achieve safety and stability. The process should ensure that youth receive the housing and service supports they need to resolve their homelessness crisis as quickly as possible, with the lowest possible barriers. The CE process should be able to answer the...
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A coordinated entry (CE) process standardizes and coordinates the way youth access the community’s homelessness crisis response system and connect with the appropriate resources they need to achieve safety and stability. The process should ensure that youth receive the housing and service supports they need to resolve their homelessness crisis as quickly as possible, with the lowest possible barriers. The CE process should be able to answer the homeless system’s guiding question, “Which housing and supportive services best meet the needs of each youth?” The core elements of this process include (1) access, (2) screening and assessment for housing and services, (3) prioritization, and (4) referral, and should be developed by each Continuum of Care (CoC) through a community-wide planning process.

View a chart of the guiding question, “Which housing and supportive services best meet the needs of each youth?” and its four key elements.

• Step 1: Standardized access: Ensures all youth seeking access to their community’s homelessness system engage the system through the same coordinated and standardized process regardless of where or how they present for services.
• Step 2: Standardized screening and assessment: Uses a standardized approach for all youth presenting for homelessness assistance to gather information on factors that can prevent and end their homelessness and inform the types of services and housing that meet their needs and strengths.
• Step 3: Standardized prioritization: Ensures that youth with the most severe service needs and levels of vulnerability are prioritized for limited housing and other non-emergency homelessness assistance resources (does not include emergency shelter, basic centers, street outreach, etc.) that meet their needs.
• Step 4: Coordinated referral: Ensures that youth can be referred to any homelessness dedicated housing and services for which they qualify and are prioritized for across the entire community.

For a more detailed explanation of the core elements of a CE process please refer to HUD’s Coordinated Entry Policy Brief and to HUD’s CoC 2.0 Training Material – Coordinated Assessment.

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Yes. As described in the February 2015 HUD Coordinated Entry Policy Brief, it may be appropriate, though not required, for communities to establish processes, “including different access points and screening and assessment tools,” for four specific groups only: Youth;   Families;   Individuals; and   Victims of Domestic Violence (including trafficked youth, victims of other forms of abuse and exploitation, and youth fleeing or...
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Yes. As described in the February 2015 HUD Coordinated Entry Policy Brief, it may be appropriate, though not required, for communities to establish processes, “including different access points and screening and assessment tools,” for four specific groups only:

1. Youth;
    
2. Families;
    
3. Individuals; and
    
4. Victims of Domestic Violence (including trafficked youth, victims of other forms of abuse and exploitation, and youth fleeing or attempting to flee abuse and exploitation).

Continuums of Care (CoCs) are not required to have separate processes and there are many good reasons based on a community’s geographic size, population, characteristics of the local crisis response system, etc., for choosing single or separate processes. However, HUD and the U.S. Department of Health and Human Services (HHS) both recognize that the cultural competencies, resources, safety protocols, service models, and rules and regulations are different enough for these populations that having separate processes may be necessary. For example, youth may have a separate access point, dedicated staff to conduct assessments, special questions and protocols, and a unique prioritization system that accounts for the differences in the experiences of homelessness for youth versus adults. Separate CE processes should be accounted for in the CoC’s policies and procedures related to CE, be consistently implemented across each of the four permissible subpopulations, and follow the community’s established assessment guidelines.

It is important for all subpopulation-specific systems to align their access and referral processes to account for the significant overlap between populations being served and the resources that should be available to them. For instance, while CE may primarily refer youth to youth-specific resources, there are typically additional non-youth-specific resources to which youth experiencing homelessness should have access. These resources include mainstream services aimed at a broader population than youth and housing interventions that may not specifically target youth, but from which some youth may still benefit. Similarly, a community with a process for families and a separate process for youth needs to be aware that young families may need to access both youth- and family-appropriate housing and services without having to go through two separate processes. Most importantly, the CE process should be developed with the full participation of all stakeholders so that the entire process is appropriate for the full breadth of populations.

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Federal partners have recently identified coordinated entry (CE) as a key component of the coordinated community response to prevent and end youth homelessness in 2020. CE is also required for all housing programs receiving HUD Continuum of Care (CoC) and Emergency Solutions Grants (ESG) funding and strongly recommended for all of a community’s homelessness-dedicated resources. In order for these community-wide processes to appropriately serve ...
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Federal partners have recently identified coordinated entry (CE) as a key component of the coordinated community response to prevent and end youth homelessness in 2020. CE is also required for all housing programs receiving HUD Continuum of Care (CoC) and Emergency Solutions Grants (ESG) funding and strongly recommended for all of a community’s homelessness-dedicated resources. In order for these community-wide processes to appropriately serve youth, CoCs need to address the developmental and service needs of unaccompanied homeless youth and ensure that all community stakeholders, including Runaway and Homeless Youth (RHY) providers, child welfare agencies, school systems, systems of justice, workforce systems partners, and other youth-serving organizations, come together for both the planning and implementation of a youth-inclusive CE process.

A youth-inclusive CE process requires CoCs to implement a systems-level, youth-focused approach for youth access, screening and assessment*, prioritization, and referral to housing and supportive services. The intent of CE is to standardize and streamline the process for youth access to homelessness-dedicated resources across the entire homelessness crisis response system, and to lower the overall burden on youth to receive needed housing and supportive services. This process allows a CoC to make decisions based on the availability of resources across an entire community, not just at an individual program or project, expanding a youth’s access to needed community resources. Youth should also be screened and assessed with the same standardized, culturally competent tools as their peers, regardless of who the assessor may be, and expect to be referred according to the same prioritization factors that are used for all youth in the community. An effective, youth-centered process also reduces the number of interviews that require repeating highly personal information, often involving traumatic experiences, and reduces the amount of time it takes to receive housing and supportive services.

Included in the CE process is the implementation of an initial housing-focused assessment of youth needs and strengths, which is used in conjunction with a process (which may be specific to youth) to prioritize housing and supportive services in a timely manner. Prioritization helps to ensure that the highest need, most vulnerable youth, with the most risk factors and fewest protective factors across the community, are prioritized for housing services (see FAQ 2934 for what “Assessment” means in the CE context and FAQ 2935 for more detail on prioritization factors for vulnerable youth and the preliminary intervention model of the Federal Framework to End Youth Homelessness). Prioritization is critical because the homelessness crisis response system for youth is under-resourced and CoCs need to make tough decisions around prioritizing limited homelessness-dedicated housing and services. The tough decisions that a CoC must make around prioritization are a prime example of why it is critical for a broad set of community stakeholders to be actively involved in the CoC and in the design and implementation of CE.

It is important to note that HUD and the U.S. Department of Health and Human Services (HHS) believe that no individual should have to sleep on the streets. Therefore, the CE process should never be a barrier to accessing emergency services, such as emergency shelter, respite, and crisis residential assistance. Communities should work to ensure that all individuals seeking emergency services have access to those services without barriers.

The CE process also gives a community a more complete and up-to-date vacancy, turn-away, and overall utilization picture that allows community planners to make better decisions about resource allocation and funding requests. More accurate, research-informed placements and refined pathways to well-coordinated housing and services can reduce burden and redundancies and connect youth experiencing homelessness to mainstream services. The CE development and feedback processes have the potential to serve as a powerful vehicle for additional youth systems-building and innovative collaboration in the community. CE can give your community the power to make more efficient use of the beds and services currently available and the data to argue for new targeted resources.

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*The terms screening and assessment are being used in this document in a few different ways. In the context of CE, the terms screening and assessment involve tools that specifically measure an individual’s vulnerability to harm and continued homelessness and need for housing and related services. In contrast, behavioral assessment follows behavioral screening if the screening results are positive for a particular behavior or symptom. Ongoing assessment can occur both for behavioral services, such as mental health or addiction services, and for other types of services and supports, such as more intensive rental assistance, throughout a youth’s involvement in the homelessness system.

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Although HUD does not endorse or require the use of any specific assessment form, tool, or approach, it has described some universal qualities that should be incorporated into any form, tool, or approach used by a Continuum of Care (CoC) for its coordinated entry process. See HUD’s Coordinated Entry Policy Brief for a full description of these qualities and criteria. HUD recognizes the need for further guidance as both the process and the tools...
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Although HUD does not endorse or require the use of any specific assessment form, tool, or approach, it has described some universal qualities that should be incorporated into any form, tool, or approach used by a Continuum of Care (CoC) for its coordinated entry process. See HUD’s Coordinated Entry Policy Brief for a full description of these qualities and criteria.

HUD recognizes the need for further guidance as both the process and the tools continue to evolve; therefore, some of the qualities reflected in the Coordinated Entry Policy Brief may be modified over time to reflect HUD’s evolving understanding of the assessment process and what is determined to be most effective. In February, 2015, HUD released a brief, “Assessment Tools for Allocating Homeless Assistance: State of the Evidence,” which summarizes the observations of a panel of experts on existing assessment tools that are being used by communities to allocate homeless assistance, and considers the evidence base for the questions included in the tools. The brief provides helpful context concerning what we know about the power and limitations of assessment tools currently available for communities to employ.

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If the Continuum of Care (CoC) chooses to create a separate coordinated entry process for people fleeing domestic violence, including separate access points, that process must be developed in coordination with local victim service providers, adhere to the same requirements as the broader coordinated entry process, and be designed according to the qualities outlined in the Coordinated Entry Policy Brief, with the only difference being that it is t...
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If the Continuum of Care (CoC) chooses to create a separate coordinated entry process for people fleeing domestic violence, including separate access points, that process must be developed in coordination with local victim service providers, adhere to the same requirements as the broader coordinated entry process, and be designed according to the qualities outlined in the Coordinated Entry Policy Brief, with the only difference being that it is targeted to individuals and families fleeing domestic violence. Any separate process must ensure that victims of domestic violence have equal access to homeless services and housing programs that are provided to those using the primary access point. One promising practice is to use a virtual domestic violence access point. Virtual access points include internet and phone-based systems (e.g. 211) that can quickly be accessed from any location where the household seeking assistance feels safe.

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Continuums of Care (CoCs) will find the victim service providers and state domestic and sexual violence coalitions in their communities to be excellent resources in developing a coordinated entry process that has protocols in place to ensure the safety of the individuals seeking assistance. CoCs should engage with these organizations as well as other experienced stakeholders and providers to determine the best options for victims fleeing domestic...
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Continuums of Care (CoCs) will find the victim service providers and state domestic and sexual violence coalitions in their communities to be excellent resources in developing a coordinated entry process that has protocols in place to ensure the safety of the individuals seeking assistance. CoCs should engage with these organizations as well as other experienced stakeholders and providers to determine the best options for victims fleeing domestic violence. Protocols to protect the safety of households seeking assistance should be in place for every phase of the coordinated entry process, including addressing safety concerns associated with the coordinated entry access point(s).

Communities may choose to use the same coordinated entry access point or points for all populations or may choose to establish a separate access point or points for households fleeing domestic violence. Similarly, the domestic violence access point(s) can be one or more physical location or virtual, such as a 211 line. Each scenario requires different protocols to ensure safety. For instance, if using a common access point that has a physical location, assessment staff should treat all persons presenting for assistance with strict confidentiality and privacy, conducting their assessments out of sight and ear shot of other persons at the physical location. If using a separate access point for households fleeing domestic violence, that access point should be a virtual or phone-based access point to protect the household’s physical safety. Communities should strongly consider using a local domestic violence hotline as an access point, even if other access points are available, to ensure the safety of households fleeing domestic violence. In all cases, whether a common access point or a separate access point is used to assess victims of domestic violence, data must be collected in accordance with the confidentiality requirements established in the CoC and Emergency Solutions Grants (ESG) Program interim rules (24 CFR 578.103(b) and 24 CFR 576.500(x)) and data collected by a victim service provider must be collected in accordance with the Violence Against Women Act (VAWA), which prohibits victim service providers from entering client-level data into HMIS.

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Domestic violence is often very traumatic for households, including children exposed to domestic violence. It is imperative that coordinated entry processes be designed to prevent further trauma and to provide households with control over the process and referrals. Trauma-informed practices that are sensitive to the lived experience of all people presenting for services need to be incorporated into every aspect of the coordinated entry process. T...
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Domestic violence is often very traumatic for households, including children exposed to domestic violence. It is imperative that coordinated entry processes be designed to prevent further trauma and to provide households with control over the process and referrals. Trauma-informed practices that are sensitive to the lived experience of all people presenting for services need to be incorporated into every aspect of the coordinated entry process. The assessment tool and process should not re-traumatize the individual or family, must inform the person up-front about how the information will be used, and must allow them the option to refuse to answer questions or choose not to disclose personal information.

The coordinated entry process must also include protocols to ensure the safety of all individuals and families seeking assistance, and these protocols must specifically address how individuals and families fleeing domestic violence will have safe and confidential access to the coordinated entry process along with safe and secure referrals to appropriate housing and services. Further, the process must include procedures for how referrals will be made to victim service providers that are not participating in the coordinated entry process. CoCs should work with victim service providers in their community to determine the most appropriate procedures to implement.

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Individuals and families fleeing or healing from domestic violence or trauma should have access to the full range of housing and service intervention options available in their community, including prevention, diversion, rapid re-housing, and other housing and mainstream services. However, special consideration must be given to their unique and often complex physical and emotional safety needs. In particular, they might benefit from participation...
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Individuals and families fleeing or healing from domestic violence or trauma should have access to the full range of housing and service intervention options available in their community, including prevention, diversion, rapid re-housing, and other housing and mainstream services. However, special consideration must be given to their unique and often complex physical and emotional safety needs. In particular, they might benefit from participation in housing programs that offer trauma-informed and culturally-relevant services.

All coordinated entry staff should be trained on the complex dynamics of domestic violence, privacy and confidentiality, and safety planning, including how to handle emergency situations at an access point(s), whether a physical or virtual location. Continuums of Care (CoCs) should also partner with their local victim service provider agencies to ensure that trainings for relevant staff are provided by informed experts in the field of domestic violence, dating violence, sexual assault, stalking, and human trafficking. If a household is determined to be at risk of harm when an assessment is being conducted, then the coordinated entry staff should refer the household to a victim service provider using referral criteria established for that community based on system design, program capacity, resource limitations, and placement and geography considerations. The coordinated entry process should also have a procedure to safely refer the household to the identified victim service provider, preferably with a warm hand-off including a phone call, transportation, or other transition to the victim service provider. Communities should consult with their local victim service providers or state coalitions against domestic violence to develop models for building a quality assessment process, including screening questions around domestic and sexual violence. Finally, coordinated entry staff should have up-to-date information on domestic violence shelters and general homeless shelters and housing options that are best equipped to serve households experiencing domestic violence based on their location, program model, and linkages to other supportive services.

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Yes - HUD allows and actively promotes the full participation and integration of victim service providers into the Continuum of Care (CoC) coordinated entry process. The form this integration takes will vary by community, but the overarching goal is for individuals and families presenting to the homeless and victim services system to have full and complete access to the housing and service resources available through both systems. Specifical...
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Yes - HUD allows and actively promotes the full participation and integration of victim service providers into the Continuum of Care (CoC) coordinated entry process. The form this integration takes will vary by community, but the overarching goal is for individuals and families presenting to the homeless and victim services system to have full and complete access to the housing and service resources available through both systems. Specifically, HUD encourages CoCs to work with victim service providers within the CoC’s geographic area to establish client-driven, trauma-informed and culturally-relevant assessment and screening tools, as well as referral policies and procedures, to ensure that the coordinated entry process addresses the physical and emotional safety, and privacy and confidentiality needs of participants. This includes separate access points, if necessary and appropriate, and access to all available and appropriate housing options and related supportive services, regardless of whether the individual or family presents for intake at a victim services access point or at a more general access point.

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HUD defines a victim service provider to mean a private nonprofit organization whose primary mission is to provide direct services to victims of domestic violence. This term includes permanent housing providers—including rapid re-housing, domestic violence programs (shelters and non-residential), domestic violence transitional housing programs, dual domestic violence and sexual assault programs, and related advocacy and supportive services programs.

Coordinated Entry

Yes - While victim service providers are prohibited from entering personally identifying information into HMIS, HUD is encouraging CoCs to work with their victim services providers to establish either a process for their participation in the CoC’s coordinated entry process or establish their own coordinated entry process outside of the HMIS. It is important that this process provides access to all available housing and services regardless of wh...
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Yes - While victim service providers are prohibited from entering personally identifying information into HMIS, HUD is encouraging CoCs to work with their victim services providers to establish either a process for their participation in the CoC’s coordinated entry process or establish their own coordinated entry process outside of the HMIS. It is important that this process provides access to all available housing and services regardless of whether the individual or family presents for intake at a victim-specific access point or a mainstream homeless service access point.

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Yes - All households, regardless of their domestic violence (DV) status, have the right to refuse to share their information among providers within the Continuum of Care (CoC). In fact, all service providers are prohibited from denying assistance to program applicants and program participants if they refuse to permit the provider to share their information with other providers. However, some information may be required by the project, or by publi...
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Yes - All households, regardless of their domestic violence (DV) status, have the right to refuse to share their information among providers within the Continuum of Care (CoC). In fact, all service providers are prohibited from denying assistance to program applicants and program participants if they refuse to permit the provider to share their information with other providers. However, some information may be required by the project, or by public or private funders to determine eligibility for housing or services, or to assess needed services, so it must be collected. In cases where a client does not consent to having their information shared, the information must still be collected by the service providers to determine whether the individual or family is eligible, but it must not be shared via the HMIS if the program participant objects. For instance, if a provider needs to verify the presence of a disability in the process of determining eligibility for Permanent Supportive Housing (PSH), the information itself must be collected but not shared via HMIS.

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The recordkeeping requirements included in the Final Rule on Defining “Chronically Homeless” are meant to ensure that, when applicable, permanent supportive housing (PSH) that is dedicated to serving persons experiencing chronic homelessness is being used to serve persons that meet the definition. It was never HUD’s intention that these requirements act as a barrier to housing those most in need of PSH as quickly as possible. In fact, ...
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The recordkeeping requirements included in the Final Rule on Defining “Chronically Homeless” are meant to ensure that, when applicable, permanent supportive housing (PSH) that is dedicated to serving persons experiencing chronic homelessness is being used to serve persons that meet the definition. It was never HUD’s intention that these requirements act as a barrier to housing those most in need of PSH as quickly as possible. In fact, HUD believes that its final recordkeeping requirements for the definition of chronically homeless strike the appropriate balance and do not create a level of documentation that is too burdensome. This is part of the reason that HUD permitted each project to serve up to 25 percent of the individuals and families in a given operating year who do not have at least 9 months of their stays in a place not meant for human habitation, safe haven, or emergency shelter documented by third-party documentation.

However, even with this 25 percent allowance, HUD has received comments that some additional time is often needed by recipients and subrecipients to obtain the appropriate documentation of an individual or head of household’s chronic homeless status. Therefore, although the final rule requires documentation of eligibility at intake to the project, it does not require that all third-party documentation be acquired at the point of intake. HUD recognizes that it may take a little bit more time to obtain third-party documentation for documenting chronic homeless status in accordance with the final rule for prior months or occasions. Therefore, HUD has determined that although the recipient must follow the order of priority for obtaining evidence as required in the final rule, written self-certification at the point of intake for up to the full period of time homeless required by the definition of chronically homeless is sufficient (if no other documentation can be obtained at that point in time) for the recipient to enroll the household into the project. The recipient then must work to obtain the required third-party documentation within 180 days from the point in which the project participant is enrolled in the project. Project participants that have been enrolled in the project for less than 180 days may be excluded from the calculation for determining whether or not at least 75% of program participants have at least 9 months of third-party documentation.

Following the first 180 days from the point of a program participant’s enrollment, if the recipient or subrecipient has not been able to obtain third-party documentation for at least 9 months of the individual or head of household’s residence in a place not meant for human habitation, a safe haven, or an emergency shelter, then one of the following applies:

1. If the recipient or subrecipient has not already reached their 25 percent cap, the program participant can continue to be assisted in the project and the recipient or subrecipient must consider this program participant as counting towards their 25 percent allowance; or
    
2. If the recipient or subrecipient has already reached their 25 percent allowance, no additional CoC Program funds can be used to continue serving this household in that project. For this reason, HUD encourages recipients that are currently at their 25 percent allowance to use this additional time carefully and only for program participants where they are fairly certain that the required third-party documentation can be obtained. It is also for this reason that HUD encourages recipients and subrecipients to continue to obtain at least 9 months of third-party documentation for program participants, even after a program participant has been enrolled in the program for some time, because if a recipient is ultimately able to obtain 9 months of third-party documentation of a head of household’s homeless status, then that household can be removed from the 25 percent calculation.

Example: Henry is a program participant that entered a project on June 1st. He reports that he has been living in a place not meant for human habitation, a safe haven, or an emergency shelter for the last 12 months. At the point of intake, there was only 2 months of third-party documentation of Henry residing in one of these locations. The recipient of PSH may obtain a self-certification from Henry for the remaining 10 months in order to enroll Henry in the program and get him into housing. The recipient then has up to 180 days from the point of his enrollment to obtain at least 7 additional months of third-party documentation (to add to the 2 months that had been obtained at the point of intake) to get to the 9 months of required third-party documentation. At any point in time, the program will calculate whether or not they are meeting the requirement that at least 75 percent of program participants have third-party documentation for at least 9 months of their homelessness history based on program participants that enrolled after January 15, 2016 and had been enrolled in the program for 180 days or more. If the recipient is not able to do so, and is not at their 25 percent allowance, then they could continue to serve Henry, but must count him towards their 25 percent allowance. But, if the recipient was already at their 25 percent allowance, the recipient could no longer serve Henry in that project.

Please note, recipients must continue to obtain third-party documentation of the head-of-household’s disability within 45 days, as required by the final rule.

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Under the definition of chronically homeless, the head of household (either an adult or a minor if there is no adult present) must have the qualifying disability and meet all of the other criteria (i.e., length of time homeless) in order for a family to be considered chronically homeless. Where there is no adult member of the family, then a minor can be identified as the head of household and that individual is who must meet the criteria. Note: w...
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Under the definition of chronically homeless, the head of household (either an adult or a minor if there is no adult present) must have the qualifying disability and meet all of the other criteria (i.e., length of time homeless) in order for a family to be considered chronically homeless.

Where there is no adult member of the family, then a minor can be identified as the head of household and that individual is who must meet the criteria.

Note: when there are multiple adults in the presenting family, or multiple minors in a family with no adult, HUD does not specify which adult or minor must be the head of household and relies upon the family to self-determine which adult is the head of household.

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The Final Rule on Defining “Chronically Homeless” clarifies that the order of priority for obtaining documentation of an individual or head of household’s history of residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven is first third-party documentation, followed second by the written observation of an intake worker, and third by the self-certification of the individual or head of household seeking...
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The Final Rule on Defining “Chronically Homeless” clarifies that the order of priority for obtaining documentation of an individual or head of household’s history of residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven is first third-party documentation, followed second by the written observation of an intake worker, and third by the self-certification of the individual or head of household seeking assistance.

The following are examples of what may be considered documentation for the second and third orders of priority.

• Written Observation of an Intake Worker: A written observation from an intake worker would count as this second order of priority and not as third-party if their only encounter with the individual or head of household is at the current point in which they are seeking assistance and the intake worker has not physically observed where the individual or head of household is currently residing. The intake worker may provide a written observation of why, based on their professional judgment, they believe that the individual or head of household has been living in a place not meant for human habitation, in an emergency shelter, or in a safe haven for the months in which they have not personally encountered the individual or head of household. This could include months in which the individual or head of household could not remember but where the intake worker believes, based on their professional judgment that it is reasonable to assume that the individual or head of household had been residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven.
  
  The intake worker should exercise due diligence to obtain third-party documentation and the written observation must include what attempts were made to obtain third-party documentation. This documentation does not count towards the requirement that at least 9 months of the individual or head of household’s period of homelessness be documented based on third-party documentation. For all program participants in an operating year, up to 3 months of the documentation could be based on a written observation of an intake worker as described here. Only up to 25 percent of program participants that were admitted after January 16, 2016 in an operating year could have more than 3 months (up to the full period of homelessness) documented exclusively through written observation from an intake worker.


• Written Certification from the Person Seeking Assistance: Where no other documentation is available, the individual or head of household seeking assistance may provide a written self-certification of the specific months in which they report that they had been residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven.
  
  The self-certification must be accompanied with documentation of the intake workers attempts to obtain third-party documentation. This documentation does not count towards the requirement that at least 9 months of the individual or head of household’s period of homelessness be documented based on third-party documentation. For all program participants in an operating year, up to 3 months of the documentation could be based on a self-certification from the individual or head of household seeking assistance. Only up to 25 percent of program participants that were admitted after January 16, 2016 in an operating year could have more than 3 months (up to the full period of homelessness) documented through self-certification alone.

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HUD understands that in order to implement the definition outlined in the Final Rule on Defining “Chronically Homeless,” it will require that communities exercise due diligence to identify and engage all persons experiencing homelessness with chronic homelessness within the CoC’s geographic area. Therefore, HUD encourages CoCs to establish policies and procedures for identifying and serving chronically homeless households including, but not...
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HUD understands that in order to implement the definition outlined in the Final Rule on Defining “Chronically Homeless,” it will require that communities exercise due diligence to identify and engage all persons experiencing homelessness with chronic homelessness within the CoC’s geographic area. Therefore, HUD encourages CoCs to establish policies and procedures for identifying and serving chronically homeless households including, but not limited to, the development and implementation of an active list, coordinated entry system, and/or outreach worker engagement.

If there were no chronically homeless persons identified as chronically homeless at the point in time in which a program has a vacancy, it would be acceptable to serve a non-chronically homeless household in a vacant unit. At no point should beds be held vacant waiting for people to age into chronicity. Serving a non-chronically homeless household in a vacant unit would also be acceptable if there are individuals that are not ready or willing to be housed in permanent supportive housing (PSH). In both situations, however, you will need to document very carefully what attempts were made to locate persons that met the definition of chronically homeless, and what the outreach strategy was (e.g., if your community has a by-name list or prioritized list through your coordinated entry).

The CoC and recipient of PSH must maintain records to document what efforts have been made to locate persons experiencing chronic homelessness. Ideally, the CoC should have data on all households that are currently presenting for assistance within the CoC which should include whether or not the household meets the definition of chronically homeless and that is informed by a comprehensive outreach strategy. It is recommended that CoCs document what their outreach strategy consists of that recipients of CoC Program-funding are able to keep on file. To justify serving a non-chronically homeless household, that documentation should demonstrate that outreach is occurring regularly and that the CoC is making reasonable efforts to locate and identify all persons experiencing homelessness within the community. If there are no households that meet the definition of chronically homeless at the time in which a vacancy is available, this will serve as sufficient documentation to demonstrate that there are no identified chronically homeless households within the CoCs geographic area.

FAQ 1835 clarifies that recipients of dedicated or prioritized PSH funded under the CoC Program are not required to hold beds vacant indefinitely while trying to identify persons that meet the highest priority.

Please review the final rule for the most accurate information on recordkeeping requirements for all recipients of CoC Program-funded PSH for persons experiencing chronic homelessness.

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A single record of a stay in an emergency shelter or a safe haven or an outreach contact of an individual or head of household residing in a place not meant for human habitation in a single month is sufficient documentation to consider the individual or head of household as residing in that location for the entire month unless there is clear evidence of a break such as an HMIS record of an exit to permanent housing. Where data is available, the i...
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A single record of a stay in an emergency shelter or a safe haven or an outreach contact of an individual or head of household residing in a place not meant for human habitation in a single month is sufficient documentation to consider the individual or head of household as residing in that location for the entire month unless there is clear evidence of a break such as an HMIS record of an exit to permanent housing. Where data is available, the intake worker could document the individual or head of household’s entire period of homelessness based on records contained in HMIS or a comparable database. It should be noted that self-reported data contained in HMIS or a comparable database does not qualify as third-party documentation.

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Acceptable forms of third-party documentation based on the recordkeeping requirements that were established in the Final Rule on Defining “Chronically Homeless” include: An individual record of a stay in an emergency shelter, a safe haven, or from a street outreach contact from an HMIS, or comparable database used by victim service or legal service providers; A written observation by an outreach or intake worker of encounters with the indivi...
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Acceptable forms of third-party documentation based on the recordkeeping requirements that were established in the Final Rule on Defining “Chronically Homeless” include:

1. An individual record of a stay in an emergency shelter, a safe haven, or from a street outreach contact from an HMIS, or comparable database used by victim service or legal service providers;
2. A written observation by an outreach or intake worker of encounters with the individual or head of household that includes a description of the conditions where the individual or head of household was living or is currently living;
3. A written observation by a community member that has observed where the individual or head of household was living or is currently living; and
4. A written referral by another housing or service provider.

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An individual or head of household with a qualifying disability can be considered chronically homeless if they are coming directly from an institution where they have resided for fewer than 90 days and resided in a place not meant for human habitation, an emergency shelter, or a safe haven immediately prior to entering the institution and were either: Residing in one of these locations for at least the last 12 months continuously or 12 months cu...
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An individual or head of household with a qualifying disability can be considered chronically homeless if they are coming directly from an institution where they have resided for fewer than 90 days and resided in a place not meant for human habitation, an emergency shelter, or a safe haven immediately prior to entering the institution and were either:

1. Residing in one of these locations for at least the last 12 months continuously or 12 months cumulatively over a period of at least four occasions in the last three years prior to entering the institution; or
    
2. Where the time spent residing in the institution (of fewer than 90 days) plus the time spent residing in one of these locations totals at least 12 months continuously or 12 months cumulatively over a period of at least for occasions in the last three years prior to entering the institution.

For example, if an individual or head of household has a qualifying disability and had continuously resided in a place not meant for human habitation, in an emergency shelter, or in a safe haven for 14 months and then entered an institution for 2 months, upon exit they can be considered chronically homeless. Alternatively, if, for example, an individual or head of household has a qualifying disability had continuously resided in a place not meant for human habitation, an emergency shelter, or a safe haven for 10 months and then entered an institution for 2 months, upon exit they can be considered chronically homeless.

This is because stays in an institution of less than 90 days do not constitute as a break, meaning that the total length of time homeless can include periods of fewer than 90 days in an institution where the individual or head of household resided in a place not meant for human habitation, in an emergency shelter, or in a safe haven immediately prior to entering the institution. For example, if an individual or head of household resided in an emergency shelter for 4 months, entered an institution for 2 months, and then spent 6 months on the streets immediately after exiting the institution, that full 12 months would count as one continuous occasion of homelessness. If the individual or head of household remains in the institution for 90 days or longer, the entire period in the institution would constitute as a break.

However, in no instance can an individual or head of household be considered chronically homeless if they are exiting an institution where they resided for 90 days or longer, even if they met all of the criteria of the definition of chronically homeless prior to entering the institution because that entire period residing in the institution is considered a break. This means the individual or head of household would not be considered chronically homeless immediately upon discharge.

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To be considered chronically homeless, the individual or head of household must be a “homeless individual with a disability” as defined by the McKinney-Vento Act as amended by the HEARTH Act. An individual or head of household’s qualifying disability must be documented by one of the following: Written verification of the disability from a professional licensed by the state to diagnose and treat the disability and his or her certification t...
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To be considered chronically homeless, the individual or head of household must be a “homeless individual with a disability” as defined by the McKinney-Vento Act as amended by the HEARTH Act. An individual or head of household’s qualifying disability must be documented by one of the following:

• Written verification of the disability from a professional licensed by the state to diagnose and treat the disability and his or her certification that the disability is expected to be long-continuing or of indefinite duration and substantially impedes the individual’s ability to live independently;
• Written verification from the Social Security Administration;
• The receipt of a disability check (e.g., Social Security Disability Insurance check or Veteran Disability Compensation);
• Intake staff-recorded observation of disability that, no later than 45 days from the application for assistance, is confirmed and accompanied by evidence above; or
• Other documentation approved by HUD.

Further, acceptable evidence of a disability for an individual with HIV/AIDS would include written verification from a professional licensed by the state to diagnose and treat HIV/AIDS. There would not be an expectation that the licensed professional would also certify that the condition is expected to be of long-continuing or indefinite duration and substantially impede the individual's ability to live independently.

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As established in the Final Rule on Defining “Chronically Homeless”, stays in institutions of fewer than 90 days are not considered a break. In addition, so long as the individual or head of household was residing in a place not meant for human habitation, an emergency shelter, or a safe haven immediately prior to entering the institution, the amount of time spent in the institution counts towards the individual or head of household’s tota...
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As established in the Final Rule on Defining “Chronically Homeless”, stays in institutions of fewer than 90 days are not considered a break. In addition, so long as the individual or head of household was residing in a place not meant for human habitation, an emergency shelter, or a safe haven immediately prior to entering the institution, the amount of time spent in the institution counts towards the individual or head of household’s total time residing in one of these locations. However, stays in institutions of 90 days or more are considered breaks and time spent in an institution where the stay was 90 days or more does not count towards an individual or head of household’s total time residing in a place not meant for human habitation, an emergency shelter, or a safe haven.

Regarding documentation requirements, where the stay is fewer than 90 days and, therefore, will be counted towards an individual or head of household’s total time residing in a place not meant for human habitation, emergency shelter, or safe haven, the final rule requires one of the following:

1. Discharge paperwork or a written or oral referral from a social worker, case manager, or other appropriate official of the institutional care facility; or
    
2. Where the evidence in number 1 above is not available, a written certification of the individual or head of household stating the time he or she spent in the institution along with a record of the intake worker’s due diligence in obtaining the aforementioned evidence.

Where the stay is for 90 days or more and, therefore, counts as a break from an individual or head of household’s time spent in a place not meant for human habitation, emergency shelter, or safe haven, the documentation may include the evidence described above; however, it is not required to. As established in the final rule, all breaks may be documented through the individual or head of household’s own written certification that that is where they were residing during that time period.

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Another housing or service provider may provide a referral of the individual or head of household’s current or prior residence in an emergency shelter, safe haven, or place not meant for human habitation. HUD considers other housing or service providers to include members of law enforcement, a healthcare professional within the community, an educator, or another person that has encountered the individual or head of household while in their offi...
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Another housing or service provider may provide a referral of the individual or head of household’s current or prior residence in an emergency shelter, safe haven, or place not meant for human habitation. HUD considers other housing or service providers to include members of law enforcement, a healthcare professional within the community, an educator, or another person that has encountered the individual or head of household while in their official capacity and not simply as a member of the community. If the other housing or service provider is not able to provide a written referral or observation, the intake worker may document their conversation with the housing or service provider. The housing or service provider’s written referral or observation may only qualify as third-party documentation for the specific months in which they encountered the individual or head of household.

For example:

• An emergency shelter that does not participate in the CoC’s HMIS may provide a written observation stating that the individual or head of household resided there from May 4th through June 20th. That record would count as two months of residing in an emergency shelter.
   
• A member of law enforcement witnessed the individual or head of household residing in a place not meant for human habitation in the months of January and September. The member of law enforcement could provide a written or oral statement detailing those encounters, including the approximate date in which each encounter occurred. That record would count as two months of residing in a place not meant for human habitation.
   
• A healthcare professional has been treating the individual or head of household in their office for the last six months but the individual or head of household has only been there four times during that time period. On those four visits, the individual or head of household stated to the healthcare professional that they were residing in a place not meant for human habitation. The healthcare professional can provide a written or oral statement detailing that to the best of their knowledge and based on their professional judgment, the individual or head of household had been residing in a place not meant for human habitation at the time of each of the four appointments. The written or oral statement must include the dates in which the healthcare professional met with the individual or head of household and why they believe the person was residing in a place not meant for human habitation. The healthcare professional cannot qualify as a third-party source for months in which they did not personally encounter the individual or head of household. The record would count as four months of residing in place not meant for human habitation.

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An intake worker may accept as third-party documentation, the oral or written observation of someone in the community, including but not limited to, a shopkeeper, a building owner, or a neighborhood resident (regardless of relationship with the household) that has physically observed where the individual or head of household is or has been residing. If the community member is unwilling to provide a written observation, the intake worker may docum...
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An intake worker may accept as third-party documentation, the oral or written observation of someone in the community, including but not limited to, a shopkeeper, a building owner, or a neighborhood resident (regardless of relationship with the household) that has physically observed where the individual or head of household is or has been residing. If the community member is unwilling to provide a written observation, the intake worker may document their conversation with the community member. The community member must indicate which specific months they physically observed the individual or head of household residing in a place not meant for human habitation. The intake worker must use their professional judgment to determine if the source is reliable.

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To document where the individual or head of household is currently coming from, the outreach worker or intake worker, if applicable, must have physically observed where the individual or head of household is currently residing. The written observation must include the intake or outreach worker’s own encounter of the individual or head of household in that location. To document where the individual or head of household has been residing for pri...
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To document where the individual or head of household is currently coming from, the outreach worker or intake worker, if applicable, must have physically observed where the individual or head of household is currently residing. The written observation must include the intake or outreach worker’s own encounter of the individual or head of household in that location.

• To document where the individual or head of household has been residing for prior months, the outreach worker or intake worker, if applicable, may document their encounter(s) with the individual or head of household which may have been in the location where the individual or head of household had been residing or in another setting such as a soup kitchen or a drop-in-center. Where the outreach worker or intake worker did not physically observe the location in which the individual or head of household was residing, the written observation must state why they believe, to the best of their knowledge and based on their professional judgment, that the individual or head of household was residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven at during one or more month. The written documentation will have to specify each month in which they encountered the individual or head of household as well as the nature of the conversations in those months that indicated that the individual or head of household was residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven.
   
• The outreach worker or intake worker observation may only count for the specific month(s) in which they encountered the individual or head of household. The outreach worker or intake worker cannot provide third-party documentation for months in which they did not encounter the individual or head of household, either in the place in which they were residing or in another location as described above. This means, for example, if an outreach worker observed the individual or head of household residing in an encampment in the month of June, the outreach worker can only provide third-party documentation of that individual’s residence of a place not meant for human habitation for the month of June even if the individual or head of household states that they have been residing there for the past three months. Another example would be if the organization where the intake worker is employed also operates a drop-in center where the individual or head of household has come in for services in the months of March, August, and September and reported to the intake worker that they were residing in a place not meant for human habitation, the intake worker could document those conversations for those specific months only.

Note: Where an intake worker’s only encounter with the individual or head of household is at the current point in which they are seeking assistance, the intake worker’s observation will not qualify as third-party documentation. Instead this would qualify as the second order or priority for written intake procedures and would not count towards the requirement that at least 9 months of the individual or head of household’s period of homelessness be documented based on third-party documentation.

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The Final Rule on Defining “Chronically Homeless” establishes recordkeeping requirements for the following criteria, which must be documented for the individual or head of household presenting for assistance: The history of residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven, including where the individual or head of household is coming from currently; Stays in institutions; Breaks of seven nights ...
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The Final Rule on Defining “Chronically Homeless” establishes recordkeeping requirements for the following criteria, which must be documented for the individual or head of household presenting for assistance:

• The history of residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven, including where the individual or head of household is coming from currently;
• Stays in institutions;
• Breaks of seven nights or more residing in a place meant for human habitation; and
• The qualifying disability.

For each of the criteria above, with the exception of documenting breaks of seven nights or more in a place meant for human habitation, the final rule requires that recipients maintain and follow written intake procedures which establish the order of priority for obtaining evidence as third-party documentation first, intake worker observation second, and written certification from the person seeking assistance third. Breaks between occasions may be documented entirely by the individual or head of household’s written certification that they resided in a place meant for human habitation, such as in the home of a friend or in a hotel paid for by the household, for at least seven consecutive nights.

The definition of chronically homeless in the final rule requires that an individual or head of household be coming directly from a place not meant for human habitation, an emergency shelter, or a safe haven and that they have been residing in one of these locations in a place not meant for human habitation, an emergency shelter, or a safe haven for a period of at least 12 months either continuously or cumulatively over a period of at least four occasions over the last three years.

In general, HUD expects recipients to document at least 9 of the 12 months the individual or head of household resided in a place not meant for human habitation (e.g., under a bridge, a car), in an emergency shelter, or in a safe haven with third-party documentation. The remaining months can be documented by the individual or head of household’s own written certification that they had resided in one of these locations. For up to 25 percent of program participants served by the project in an operating year, recipients may document up to the full 12 months through the individual or head of household’s written certification of where they were living, but this must be accompanied by the intake workers notes that demonstrate that they have exercised due diligence to obtain a higher level of documentation. It should be noted that the final rule clarifies that a single encounter in a month is sufficient documentation to consider the individual or head of household as residing in that location for the entire month unless there is clear evidence of a break (such as an HMIS record of a stay in transitional housing where the household is not also enrolled in permanent supportive housing and actively seeking a unit) of more than seven nights.

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The amended definition as found in the Final Rule on Defining “Chronically Homeless” does not establish a minimum number of days that each occasion must total and instead defines the end of an occasion as a break of at least seven nights where the individual or head of household is not residing in an emergency shelter, safe haven, or is residing in a place meant for human habitation (e.g., with friends or family) or a period of 90 days or lon...
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The amended definition as found in the Final Rule on Defining “Chronically Homeless” does not establish a minimum number of days that each occasion must total and instead defines the end of an occasion as a break of at least seven nights where the individual or head of household is not residing in an emergency shelter, safe haven, or is residing in a place meant for human habitation (e.g., with friends or family) or a period of 90 days or longer in an institution.

While third-party documentation may be available to document a break in an individual or head of household’s time residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven, it is not required. All breaks can be documented through a written certification of the individual or head of household seeking assistance. However, please note that when there is evidence of a break (such as in an HMIS record) it must be counted.

Stays of less than seven nights in one of these places is not considered a break and instead counted toward the total time residing in a place not meant for human habitation, an emergency shelter, or a safe haven. Additionally, stays in institutions of fewer than 90 days are not considered a break and instead the time spent in the institution is counted towards the total time residing in a place not meant for human habitation, an emergency shelter, or safe haven.

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The Final Rule on Defining “Chronically Homeless” went into effect for the CoC Program on January 4, 2016 and HUD expected Permanent Supportive Housing (PSH) providers to begin using it for all new admissions as of January 16, 2016. This means, beginning January 16, 2016, any PSH projects required to serve persons that are chronically homeless (either dedicated or prioritized) may only accept new program participants that meet this definition...
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The Final Rule on Defining “Chronically Homeless” went into effect for the CoC Program on January 4, 2016 and HUD expected Permanent Supportive Housing (PSH) providers to begin using it for all new admissions as of January 16, 2016. This means, beginning January 16, 2016, any PSH projects required to serve persons that are chronically homeless (either dedicated or prioritized) may only accept new program participants that meet this definition. Dedicated permanent supportive housing is that which is targeted exclusively to the chronically homeless (unless there are no chronically homeless persons within the geographic area, as described in FAQ 1895). These beds are reported as dedicated to the chronically homeless in the Housing Inventory Count (HIC). Prioritized permanent supportive housing is that which is not specifically targeted for the chronically homeless but is prioritized for use by this population as beds become available through turnover. Recipients of CoC Program-funded permanent supportive housing that is either dedicated or prioritized are required to serve the chronically homeless in at least as many beds as indicated in the most recent grant application. These are the projects that are required to document a household’s status as chronically homeless before filling a dedicated or prioritized vacancy.

Please note that the definition of chronically homeless established by this final rule does not apply retroactively to program participants who were admitted to a CoC Program-funded permanent supportive housing program prior to January 16, 2016. This includes both households that are already housed as well as those that were admitted and enrolled into a permanent supportive housing program but who have not yet located a suitable unit. Persons that were on a waiting list prior to January 16, 2016 but who have not yet been enrolled into a permanent supportive housing program will have eligibility assessed at the point in which they are enrolled into a program and will be required to meet the definition of chronically homeless included in the final rule.

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The following is a summary of the most significant changes between the definitions of chronically homeless previously in effect and the definition included in the CoC Program interim rule as amended by the Final Rule Defining “Chronically Homeless”: To be considered chronically homeless, an individual or head of household must meet the definition of “homeless individual with a disability” from the McKinney-Vento Act, as amended by t...
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The following is a summary of the most significant changes between the definitions of chronically homeless previously in effect and the definition included in the CoC Program interim rule as amended by the Final Rule Defining “Chronically Homeless”:

• To be considered chronically homeless, an individual or head of household must meet the definition of “homeless individual with a disability” from the McKinney-Vento Act, as amended by the HEARTH Act and have been living in a place not meant for human habitation, in an emergency shelter, or in a safe haven for the last 12 months continuously or on at least four occasions in the last three years where those occasions cumulatively total at least 12 months;
• The term “disabling condition” was replaced with “homeless individual with a disability” from the Act. While the types of conditions that can be considered are the same, the definition of “homeless individual with a disability” also requires that the condition be of long and continuing duration; substantially impedes the individual’s ability to live independently; and, is expected to improve with the provision of housing. To be eligible for permanent supportive housing generally, an individual or family member must be considered a “homeless individual with a disability”, therefore, HUD adopted this term into the definition of chronically homeless to ensure consistency;
• Occasions are defined by a break of at least seven nights not residing in an emergency shelter, safe haven, or residing in a place meant for human habitation (e.g., with a friend or family). Stays of fewer than seven nights residing in a place meant for human habitation, or not in an emergency shelter or safe haven do not constitute a break and count toward total time homeless; and
• Stays in institutions of fewer than 90 days where they were residing in a place not meant for human habitation, in an emergency shelter, or in a safe haven immediately prior to entering the institution, do not constitute as a break and the time in the institution counts towards the total time homeless. Where a stay in an institution is 90 days or longer, the entire time is counted as a break and none of the time in the institution can count towards a person’s total time homeless.

The final rule also establishes recordkeeping requirements for documenting chronically homeless status, as further described in FAQ 2755.

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Yes, as long as they meet all of the other requirements of category 2 of the homeless definition. The second category of the definition of homeless includes individuals and families who are within 14 days of losing their housing, including housing they own, rent, are sharing with others, or are living in without paying rent. It also includes individuals and families who are living in hotels and motels that they are paying for using their own reso...
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Yes, as long as they meet all of the other requirements of category 2 of the homeless definition. The second category of the definition of homeless includes individuals and families who are within 14 days of losing their housing, including housing they own, rent, are sharing with others, or are living in without paying rent. It also includes individuals and families who are living in hotels and motels that they are paying for using their own resources.  

Any individual or family who will lose their housing within 14 days – including those who are within one week of losing their housing – who have not identified a subsequent residence, and who lack the resources or support networks needed to obtain other permanent housing, qualifies as “homeless” under category 2 of the homeless definition.

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The regulatory text found on page 76016 and page 76019 contain the correct requirements. These sections indicate that acceptable evidence of a disability includes: Written verification of the disability from a professional licensed by the state to diagnose and treat the disability and his or her certification that the disability is expected to be long-continuing or of indefinite duration and substantially impedes the individual’s ability to li...
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The regulatory text found on page 76016 and page 76019 contain the correct requirements. These sections indicate that acceptable evidence of a disability includes:

• Written verification of the disability from a professional licensed by the state to diagnose and treat the disability and his or her certification that the disability is expected to be long-continuing or of indefinite duration and substantially impedes the individual’s ability to live independently; OR
• Written verification from the Social Security Administration; OR
• The receipt of a disability check; OR
• Intake staff-recorded observation of a disability that, no later than 45 days of the application for assistance, is confirmed and accompanied by evidence in this; OR
• Other documentation approve by HUD.

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No, not all individuals and families currently residing in transitional housing will be eligible for permanent supportive housing. Permanent housing projects must continue to abide by the limitations and requirements included in the NOFA under which they were funded, including the limitation on eligibility. Projects funded in the FY 2011 CoC Competition must continue to abide by the limitation on Permanent Supportive Housing set forth in the NOFA...
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No, not all individuals and families currently residing in transitional housing will be eligible for permanent supportive housing. Permanent housing projects must continue to abide by the limitations and requirements included in the NOFA under which they were funded, including the limitation on eligibility. Projects funded in the FY 2011 CoC Competition must continue to abide by the limitation on Permanent Supportive Housing set forth in the NOFA in Section III.E.2.d(3), which states, "The only persons who may be served by permanent housing projects are those who come from the streets, emergency shelters, Safe Havens, or transitional housing. Persons coming from transitional housing must have originally come from the streets or emergency shelter. As participants leave currently operating projects, participants who meet this eligibility standard must replace them."

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No, the HEARTH Act revised definition did not amend the definition of homeless used in the Section 8 Moderate Rehabilitation Program for Single Room Occupancy Dwellings for Homeless Individuals.  These projects will continue to use the following definition of homeless: "An individual who lacks a fixed, regular, and adequate nighttime residence; and an individual who has a primary nighttime residence that is — A supervised publicly or priv...
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No, the HEARTH Act revised definition did not amend the definition of homeless used in the Section 8 Moderate Rehabilitation Program for Single Room Occupancy Dwellings for Homeless Individuals.  These projects will continue to use the following definition of homeless:

"An individual who lacks a fixed, regular, and adequate nighttime residence; and an individual who has a primary nighttime residence that is —

• A supervised publicly or privately operated shelter designed to provide temporary living accommodations (including welfare hotels, congregate shelters, and transitional housing for the mentally ill);
• An institution that provides temporary residence for individuals intended to be institutionalized; or
• A public or private place note designed for, or ordinarily used as, a regular sleeping accommodation for human beings."

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No. Youth who are within 14 days of exiting the foster care system who have not identified other permanent housing and who have no other resources or support networks to obtain permanent housing are not defined as homeless under Category 2 of the definition of homeless. This is different than how HUD operationalized eligibility for Transitional Housing and Supportive Service Only projects under the Supportive Housing Program. The HEARTH...
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No. Youth who are within 14 days of exiting the foster care system who have not identified other permanent housing and who have no other resources or support networks to obtain permanent housing are not defined as homeless under Category 2 of the definition of homeless. This is different than how HUD operationalized eligibility for Transitional Housing and Supportive Service Only projects under the Supportive Housing Program.

The HEARTH Act amendments changed the definition of homeless for HUD’s Homeless Assistance programs and HUD began implementing the changes through the FY2011 Homeless Assistance Grants Program competition. In most instances, the definition was broadened; however, in this one instance, the definition was narrowed.

The statutory language in Section 103(5), which HUD further clarified through the regulations, defines as homeless, “An individual who resided in a shelter or place not meant for human habitation and who is exiting an institution where he or she temporarily resided.”  Through the regulation, HUD further clarified that individuals exiting systems of care, including institutions and foster care, are no longer defined as homeless if they have resided there for more than 90 days and were not previously living on the streets or in emergency shelter prior to entering the institution or system of care. This means that unaccompanied youth being emancipated from the foster care system are not defined as homeless under Category 1, unless they are residing on the streets or in an emergency shelter at the point of intake.

Additionally, HUD has determined that individuals exiting institutions, or systems of care, are not defined as homeless under paragraph (2) of the definition of homeless even if they are within 14-days of discharge an no subsequent residence has been identified. This means that unaccompanied youth who are being emancipated from the foster care system are not defined as homeless under Category 2, and are therefore not eligible for those projects that serve Category 2 in the CoC Program.

These youth, however, may be defined as Category 3 of the homeless definition if the following conditions are met:

• The youth is under the age of 25
• The youth meets another federal definition of homeless
• The youth has not had a lease, ownership interest, or occupancy agreement in permanent housing during the 60 days prior to the homeless assistance application
• The youth has experienced persistent instability as measured by two moves or more during the preceding 60 days
• The youth can be expected to continue in such status for an extended period of time due to special needs or barriers

A youth who is defined as homeless under Category 3 of the homeless definition may only be eligible for transitional housing if the CoC has received approval from HUD to serve this population. If the youth does not meet criteria described above, then he or she could be considered at-risk of homelessness. To meet the “at-risk of homelessness” definition, an individual must have an annual income below 30 percent of the median family income for the area, as determined by HUD, not have sufficient resources or support networks to prevent him or her from moving to an emergency shelter or other place not intended as a regular sleeping accommodation for human beings, and is exiting a publicly funded institution, or system of care (such as a mental health facility). A person who is defined as "at risk of homelessness" may be eligible for a homelessness prevention program under the Emergency Solutions Grants program.

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Yes. Program participants that are receiving Rapid Re-Housing Assistance through programs such as the Emergency Solutions Grants (ESG) Program, the Continuum of Care (CoC) Program, the Supportive Services for Veterans Families (SSVF) Program, or the Veterans Homelessness Prevention Demonstration Program (VHPD) maintain their chronically homeless status for the purpose of eligibility for other permanent housing programs dedicated to serving the ch...
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Yes. Program participants that are receiving Rapid Re-Housing Assistance through programs such as the Emergency Solutions Grants (ESG) Program, the Continuum of Care (CoC) Program, the Supportive Services for Veterans Families (SSVF) Program, or the Veterans Homelessness Prevention Demonstration Program (VHPD) maintain their chronically homeless status for the purpose of eligibility for other permanent housing programs dedicated to serving the chronically homeless, such as HUD-VASH and CoC-funded permanent supportive housing (so long as they meet any other additional eligibility criteria for these programs). Program participants maintain their chronically homeless status during the time period that they are receiving the rapid re-housing assistance. Rapid re-housing is a model for helping homeless individuals and families obtain and maintain permanent housing, and it can be appropriate to use as a bridge to other permanent housing programs.

It is important to note that although the program participants in rapid re-housing are considered chronically homeless for purposes of eligibility for other programs, the housing itself is still considered permanent housing; therefore, these program participants are not considered chronically homeless (or homeless) for counting purposes, and must not be included in the CoC's sheltered point-in-time count.

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Yes. Program participants that are receiving Rapid Re-Housing Assistance through programs such as the Emergency Solutions Grants (ESG) Program, the Continuum of Care (CoC) Program, the Supportive Services for Veterans Families (SSVF) Program, or the Veterans Homelessness Prevention Demonstration Program (VHPD) maintain their homeless status for the purpose of eligibility for other permanent housing programs, such as HUD-VASH and CoC-funded perman...
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Yes. Program participants that are receiving Rapid Re-Housing Assistance through programs such as the Emergency Solutions Grants (ESG) Program, the Continuum of Care (CoC) Program, the Supportive Services for Veterans Families (SSVF) Program, or the Veterans Homelessness Prevention Demonstration Program (VHPD) maintain their homeless status for the purpose of eligibility for other permanent housing programs, such as HUD-VASH and CoC-funded permanent supportive housing (so long as they meet any other additional eligibility criteria for these programs). Program participants only maintain their homeless status during the time period that they are receiving the rapid re-housing assistance. Rapid re-housing is a model for helping homeless individuals and families obtain and maintain permanent housing, and it can be appropriate to use as a bridge to other permanent housing programs.

It is important to note that although the program participants in rapid re-housing are considered homeless for purposes of eligibility for other programs, the housing itself is still considered permanent housing; therefore, these program participants are not considered homeless for counting purposes, and must not be included in the CoC's sheltered point-in-time count.

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Holistic case management for persons experiencing homelessness is not housing counseling as defined in the Final Rule. Therefore, if an activity provided under the CoC program is part of holistic case management for persons experiencing homelessness, it is not housing counseling and certification is not required. However, there may be instances where housing counseling, as defined in the Final Rule, is being provided under the CoC program. For ex...
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Holistic case management for persons experiencing homelessness is not housing counseling as defined in the Final Rule. Therefore, if an activity provided under the CoC program is part of holistic case management for persons experiencing homelessness, it is not housing counseling and certification is not required. However, there may be instances where housing counseling, as defined in the Final Rule, is being provided under the CoC program. For example, if a program participant is receiving housing counseling, as defined in the Final Rule, as a separate specialized service, then the housing counseling has to be provided by a HUD certified housing counselor working for an agency approved to participate in HUD’s Housing Counseling Program, as of August 1, 2021, the Final Compliance Date. The Final Rule defines housing counseling as:

“Independent, expert advice customized to the need of the consumer to address the consumers’ housing barriers and achieve their housing goals and must include the following process: intake; financial and housing affordability analysis; an action plan, except for reverse mortgage counseling; and a reasonable effort to have follow-up communication with the client when possible. The content and process of housing counseling must meet the standards outlined in the regulations and policies that govern HUD’s Housing Counseling Program including but not limited to 24 CFR Part 5, 24 CFR part 214, and HUD Handbook 7610.1REV-5. Homeownership counseling and rental counseling are types of Housing Counseling.”

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Housing counseling is an eligible supportive service under the CoC program. If a recipient or subrecipient chooses to fund housing counseling activities under their program, the housing counseling must be provided by HUD certified housing counselors working for an agency approved to participate in HUD’s Housing Counseling Program, by August 1, 2021, the Final Compliance Date.

Eligible Activities

When CoC Program grant funds are used for acquisition, rehabilitation, new construction, operating costs, or supportive services, the recipient/subrecipient must demonstrate that it has control of the assisted site (i.e., site control) within 12 months of the award announcement. The recipient/subrecipient has 24 months to prove site control if the CoC Program funds will be used for acquisition, rehabilitation, or new construction. Where there is ...
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When CoC Program grant funds are used for acquisition, rehabilitation, new construction, operating costs, or supportive services, the recipient/subrecipient must demonstrate that it has control of the assisted site (i.e., site control) within 12 months of the award announcement. The recipient/subrecipient has 24 months to prove site control if the CoC Program funds will be used for acquisition, rehabilitation, or new construction. Where there is a 12-month deadline, the 12-month deadline may be extended for up to 12 additional months if a recipient provides documentation demonstrating compelling reasons for the delay due to factors beyond the control of the recipient or subrecipient.

Acceptable documentation of site control is a deed or lease. If CoC Program grant funds will be used for acquisition, a purchase agreement is acceptable evidence of site control. The owner, lessee, and purchaser shown on these documents must be the selected recipient or intended subrecipient identified in the project application.

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Yes, under certain conditions. 24 CFR 578.53(e)(17) makes the costs of supplies and materials incurred by the recipient or subrecipient when directly providing supportive services to program participants an eligible supportive service cost. To qualify as an eligible supply and material cost the cell phone must be owned by the recipient/subrecipient and the wireless service plan must be the recipient/subrecipient's, but the phone may be loaned to...
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Yes, under certain conditions. 24 CFR 578.53(e)(17) makes the costs of supplies and materials incurred by the recipient or subrecipient when directly providing supportive services to program participants an eligible supportive service cost. To qualify as an eligible supply and material cost the cell phone must be owned by the recipient/subrecipient and the wireless service plan must be the recipient/subrecipient's, but the phone may be loaned to program participants as needed to enable provision of supportive services necessary to obtain and retain housing, such as case management, mental health services, and outpatient health services. The phone and phone service may be loaned to the participant while stay-at-home or social distancing orders are in effect in the community in which the program participant resides, and must be returned to the recipient/subrecipient when those orders are lifted.

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Yes. 24 CFR 578.59(a)(2) permits the use of project administrative costs for training on Continuum of Care (CoC) requirements and attending HUD-sponsored CoC trainings. If CoCs have established standards or recommended procedures on how to deliver services during the COVID-19 pandemic (including how to recognize symptoms, how to protect recipient staff from infection, and how to protect against spreading the virus while providing assistance to pr...
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Yes. 24 CFR 578.59(a)(2) permits the use of project administrative costs for training on Continuum of Care (CoC) requirements and attending HUD-sponsored CoC trainings. If CoCs have established standards or recommended procedures on how to deliver services during the COVID-19 pandemic (including how to recognize symptoms, how to protect recipient staff from infection, and how to protect against spreading the virus while providing assistance to program participants) recipients may use administrative cost funds for training on those standards and/or recommended procedures. If HUD sponsors CoC training on the subject, recipients may also use program administrative cost funds to register and attend that training.

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Scheduled payments to a reserve fund for the repair of major building systems are an eligible cost for recipients of transitional or permanent supportive housing projects where the recipient or subrecipient owns or operates the building(s). The repayment schedule, the total amount to be placed in reserve over the grant term and the scheduled payment amount, the system or systems to be replaced and the useful life/lives of the system(s) must be su...
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Scheduled payments to a reserve fund for the repair of major building systems are an eligible cost for recipients of transitional or permanent supportive housing projects where the recipient or subrecipient owns or operates the building(s). The repayment schedule, the total amount to be placed in reserve over the grant term and the scheduled payment amount, the system or systems to be replaced and the useful life/lives of the system(s) must be submitted as part of your project application and must be approved by HUD. The HUD-approved amount is the limit on how much of your grant funds can be put in reserve. The total amount to be deposited in the reserve and the scheduled payments must be based on the remaining useful life of the system the recipient that will be replaced and the expected replacement cost of that system, reduced by the interest income expected to be earned on the reserve account before the end of the useful life of the system (taking into account expected future deposits and cash disbursements).

Recipients must draw down these funds from LOCCS in accordance with the HUD-approved repayment schedule included in the application. Payments must be scheduled no less frequently than quarterly, as required by 24 CFR 578.85(c)(3). A recipient must maintain separate accounting records for the reserve (e.g., an accounting “fund”) that will segregate the accounting for deposit of grant funds and expenditure of amounts held in the reserve for replacement of the asset). When the major system for which the reserve was created must be replaced (e.g., the HVAC system), the recipient may use funds in the reserve account to pay for the replacement without prior approval from HUD, but must maintain documentation to support the expenditure of funds and the replacement of the system.

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No, gift cards are considered a form of cash. Under the CoC Program, recipients/subrecipients are prohibited from making direct cash payments to program participants.

Eligible Costs

No. In order for building security to be an eligible operating cost under the CoC Program, more than 50% of the units or building area must be paid for with grant funds. If 50% or less of the units or building area is paid for with grant funds, even if the building is used 100% for housing for the homeless, then no costs for building security may be charged to the CoC Program grant. Note: this also means that any funds used on building secur...
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No. In order for building security to be an eligible operating cost under the CoC Program, more than 50% of the units or building area must be paid for with grant funds. If 50% or less of the units or building area is paid for with grant funds, even if the building is used 100% for housing for the homeless, then no costs for building security may be charged to the CoC Program grant. Note: this also means that any funds used on building security may not count as match for the grant since the cost would not have been eligible to be paid with grant funds.

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No. Section 578.105 of the CoC Program interim rule sets forth the parameters for grant and project changes. Paragraph (b) defines significant changes as: a change of recipient, a change of project site, additions or deletions in the types of eligible activities approved for a project, a shift of more than 10 percent from one approved eligible activity to another eligible activity, a reduction in the number of units, and a change in the subpopula...
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No. Section 578.105 of the CoC Program interim rule sets forth the parameters for grant and project changes. Paragraph (b) defines significant changes as: a change of recipient, a change of project site, additions or deletions in the types of eligible activities approved for a project, a shift of more than 10 percent from one approved eligible activity to another eligible activity, a reduction in the number of units, and a change in the subpopulation served. 

Because a change in program component is not listed as a significant change, it is not something that may be changed through a grant agreement amendment. This is because a project that is changing its program component is actually changing the entire structure and design of its project; thus, creating a new project. New projects may only be created through a CoC Program competition either through (1) a CoC’s available Final Pro Rata Need Amount or (2) a new project created through reallocation. 

Note that the prohibition of a program component change through a grant agreement amendment also includes a subcomponent change. Therefore, a project cannot change from PH:PSH to PH:RRH or TH to PH:RRH through a grant agreement amendment.

The CoC Program interim rule does state that recipients may make other changes that do not require a grant amendment (see Section 578.105(c) of the CoC Program interim rule). However, this category also does not include a program component change. This category is meant to include grant and project changes that do not require a grant agreement amendment, such as a shift of less than 10 percent of funds from one approved eligible activity to another approved activity. These types of changes must be documented in the recipient’s and/or subrecipient’s records. HUD should be notified so it can update project files and LOCCS, as necessary.

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Interpreters are not listed as an eligible cost under supportive services. However, interpreters may be a part of other supported services such as education and so may be counted as a subcategory of another supported service eligible cost. It may be possible to list interpreters as an administrative or operating cost, depending on how the interpreters are used.

Eligible Costs

In HUD's CPD Memorandum: Guidance for Determining Eligibility for Permanent Supportive Housing for Persons Participating in Certain Department of Veteran's Affairs Programs, footnote 2 on page 3 says that HUD recognizes that the Department of Veteran's Affairs (VA) determines chronic homeless status at the initial intake into VA services and that veterans served by the VA can maintain that chronic status throughout their episode of care with the ...
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In HUD's CPD Memorandum: Guidance for Determining Eligibility for Permanent Supportive Housing for Persons Participating in Certain Department of Veteran's Affairs Programs, footnote 2 on page 3 says that HUD recognizes that the Department of Veteran's Affairs (VA) determines chronic homeless status at the initial intake into VA services and that veterans served by the VA can maintain that chronic status throughout their episode of care with the VA.

HUD recognizes the chronic status of veterans who were identified as chronically homeless by the VA at initial intake and are still in that episode of care with the VA for all PSH programs, not limited to HUD-VASH. HUD recognizes that the way the VA serves its homeless veterans is to conduct an initial verification of status but that the subsequent services are all considered part of a single service package, even when services are provided by different providers and in different programs, referred to as an episode of care. Thus, HUD allows a veteran to maintain his/her chronic status for the purpose of those in VA’s homeless response system. If a veteran was identified as chronically homeless through the VA’s initial intake and continues to be served under a single episode of care, HUD would recognize that veteran’s chronically homeless status for eligibility into its HUD permanent housing programs.

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Under the CoC Program, persons presenting together for assistance regardless of marital status, actual or perceived sexual orientation, or gender identity are considered a family and can be served as a family. When determining whether a family where the individual members are not residing together when they present for intake to the project is eligible, the recipient must determine eligibility based on the status of: The adult head of household ...
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Under the CoC Program, persons presenting together for assistance regardless of marital status, actual or perceived sexual orientation, or gender identity are considered a family and can be served as a family.

When determining whether a family where the individual members are not residing together when they present for intake to the project is eligible, the recipient must determine eligibility based on the status of:

1. The adult head of household (in cases where more than one adult is present in the family, HUD allows the family to choose which adult will be the head of household, for application purposes); or
    
2. The minor head of household when no adult is present.

This means that the head of household must:

1. Meet the disability eligibility requirement; and
    
2. Reside in a place that makes the head of household eligible for PSH.

If both of the above requirements are met, HUD considers all other family members that presented with the head of household eligible for PSH.

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Under HUD's Homeless Assistance Programs, persons presenting together for assistance regardless of marital status, actual or perceived sexual orientation, or gender identity are considered a family and can be served as a family in the ESG and CoC programs. In general, when determining the homeless status of families where the individual members are not residing together when they present for intake into the project (e.g. one parent is staying in ...
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Under HUD's Homeless Assistance Programs, persons presenting together for assistance regardless of marital status, actual or perceived sexual orientation, or gender identity are considered a family and can be served as a family in the ESG and CoC programs.

In general, when determining the homeless status of families where the individual members are not residing together when they present for intake into the project (e.g. one parent is staying in an emergency shelter and the other parent is staying with a child at a friend’s house), eligibility must be assessed using:

1. The adult head of household (in cases where more than one adult is present in the family, HUD allows the family to choose which adult will be the head of household, for application purposes); or
    
2. The minor head of household when no adult is present.

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The Equal Access Rule defines family as follows: Family includes, but is not limited to, regardless of marital status, actual or perceived sexual orientation, or gender identity, the following: A single person, who may be an elderly person, displaced person, disabled person, near-elderly person, or any other single person; or, A group of persons residing together, and such group includes, but is not limited to: A family with or without children...
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The Equal Access Rule defines family as follows:

Family includes, but is not limited to, regardless of marital status, actual or perceived sexual orientation, or gender identity, the following:

1. A single person, who may be an elderly person, displaced person, disabled person, near-elderly person, or any other single person; or,
2. A group of persons residing together, and such group includes, but is not limited to:
   1. A family with or without children (a child who is temporarily away from the home because of placement in foster care is considered a member of the family);
   2. An elderly family;
   3. A near-elderly family;
   4. A disabled family;
   5. A displaced family; and,
   6. The remaining member of a tenant family.

In general, this definition of “family” applies to both the ESG and CoC Program rules. However, the McKinney-Vento Act, as amended by the HEARTH Act, distinguishes individuals from families. Therefore, paragraph (1) of the definition of family under the Equal Access Rule is considered an individual under the CoC and ESG programs and the definition of family for these programs is defined as follows:

Family includes, but is not limited to, regardless of marital status, actual or perceived sexual orientation, or gender identity, any group of persons presenting for assistance together with or without children and irrespective of age, relationship, or whether or not a member of the household has a disability. A child who is temporarily away from the home because of placement in foster care is considered a member of the family.

What this means is that any group of people that present together for assistance and identify themselves as a family, regardless of age or relationship or other factors, are considered to be a family and must be served together as such. Further, a recipient or subrecipient receiving funds under the ESG or CoC Programs cannot discriminate against a group of people presenting as a family based on the composition of the family (e.g., adults and children or just adults), the age of any member’s family, the disability status of any members of the family, marital status, actual or perceived sexual orientation, or gender identity.

Here are two examples of how this might apply:

1. An emergency shelter, transitional housing project, or permanent housing project that serves households with children. While it is acceptable for a shelter or housing program to limit assistance to households with children, it may not limit assistance to only women with children. Such a shelter must also serve the following family types, should they present, in order to be in compliance with the Equal Access rule:
   • Single male head of household with minor child(ren); and
   • Any household made up of two or more adults, regardless of sexual orientation, marital status, or gender identity, presenting with minor child(ren).
      

   In this example, the emergency shelter or housing program would not be required to serve families composed of only adult members and could deny access to these types of families provided that all adult-only families are treated equally, regardless of sexual orientation, marital status, or gender identity.

2. A permanent supportive housing project under the CoC Program rule that serves chronically homeless families. A permanent supportive housing program that serves families must serve all types of families and cannot discriminate against any family based on marital status, actual or perceived sexual orientation of the family members, or gender identities of the family members. Therefore, if two adults present together as a family, the recipient or subrecipient must serve the two adults as a family and may not require proof of marriage and may not limit assistance to couples in a heterosexual relationship.

This policy applies to any recipient and subrecipient of funding under ESG or the CoC Program, including faith-based organizations that accept funds through these programs.

All recipients and subrecipients are encouraged to review their current policies and procedures to ensure that they are compliant with this rule.

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Legal services providers that are recipients or subrecipients under the CoC Program are required to collect client-level data, consistent with HMIS data collection requirements. To protect clients, legal services providers may choose instead to enter data into a comparable database that complies with HMIS requirements. They may use CoC Program funds to establish and operate a comparable database. Legal services providers who do not use the CoC’...
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Legal services providers that are recipients or subrecipients under the CoC Program are required to collect client-level data, consistent with HMIS data collection requirements. To protect clients, legal services providers may choose instead to enter data into a comparable database that complies with HMIS requirements. They may use CoC Program funds to establish and operate a comparable database. Legal services providers who do not use the CoC’s HMIS, MUST provide aggregate data to the CoC for reporting purposes.

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Victim services providers that are recipients or subrecipients under the CoC Program are required to collect client-level data consistent with HMIS data collection requirements, BUT they must not directly enter data into an HMIS. To protect clients, victim services providers must enter required client-level data into a comparable database that complies with HMIS requirements. They may use CoC Program funds to establish and operate a comparable da...
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Victim services providers that are recipients or subrecipients under the CoC Program are required to collect client-level data consistent with HMIS data collection requirements, BUT they must not directly enter data into an HMIS. To protect clients, victim services providers must enter required client-level data into a comparable database that complies with HMIS requirements. They may use CoC Program funds to establish and operate a comparable database. Information entered into a comparable database must not be entered directly into or provided to an HMIS. Victim services providers MUST provide aggregate data to the CoC for reporting purposes.

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The staff time dedicated to eligible HMIS-funded costs can be calculated as a proportion of that staff’s overall time, and billed accordingly.

HMIS Eligible Costs

HMIS is an eligible cost under all CoC Program components. CoC recipients and subrecipients who contribute data to an HMIS, but are not the HMIS lead, may use funds under the HMIS eligible cost to pay the expenses related to contributing data to the HMIS designated by the CoC for the area.  A project funded under the transitional housing program component, for example, can apply for funds for costs related to contributing data to the HMIS de...
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HMIS is an eligible cost under all CoC Program components. CoC recipients and subrecipients who contribute data to an HMIS, but are not the HMIS lead, may use funds under the HMIS eligible cost to pay the expenses related to contributing data to the HMIS designated by the CoC for the area. 

A project funded under the transitional housing program component, for example, can apply for funds for costs related to contributing data to the HMIS designated by the CoC. Only the HMIS lead agency can apply for HMIS costs that are unique to the HMIS program component.

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Only HMIS leads are eligible to apply for funds under the CoC HMIS program component. While other applicants can apply for HMIS costs under the other component types, the following costs are unique to the HMIS component:  Hosting and maintaining HMIS software or data; Backing up, recovering, or repairing HMIS software or data; Upgrading, customizing, and enhancing the HMIS; Integrating and warehousing data, including development of data war...
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Only HMIS leads are eligible to apply for funds under the CoC HMIS program component. While other applicants can apply for HMIS costs under the other component types, the following costs are unique to the HMIS component: 

1. Hosting and maintaining HMIS software or data;
2. Backing up, recovering, or repairing HMIS software or data;
3. Upgrading, customizing, and enhancing the HMIS;
4. Integrating and warehousing data, including development of data warehouse for use in aggregating data from subrecipients that use several software systems;
5. Administering the HMIS;
6. Reporting to providers, the CoC, and HUD; and
7. Conducting training in use of the HMIS or a comparable database, including travel to the training.

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Under the CoC Program, HMIS can be funded as a program component and an eligible cost. Program components establish the overall purpose and nature of the project that is being funded, whereas eligible costs specify what may be funded by the grant. Each program component is associated with eligible costs. There are five CoC Program components. All CoC projects must fit into one of these components. A project cannot include multiple components. Whe...
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Under the CoC Program, HMIS can be funded as a program component and an eligible cost.

Program components establish the overall purpose and nature of the project that is being funded, whereas eligible costs specify what may be funded by the grant. Each program component is associated with eligible costs. There are five CoC Program components. All CoC projects must fit into one of these components. A project cannot include multiple components. When preparing a grant application, an applicant must first choose the program component that they want to apply under, and then it must specify the eligible costs it is seeking to be funded by the grant.

Allowable CoC Program Components include:

1. Permanent housing (which includes permanent supportive housing for people with disabilities and rapid re-housing)
2. Transitional housing
3. Supportive services only
4. HMIS
5. Homelessness prevention

Only an HMIS lead may apply for an HMIS dedicated project (i.e., HMIS component), whereas any project applicant may include HMIS eligible costs in their grant applications under the other program components. Eligible costs under the HMIS component are broader than those allowed under other program components. 

For example, the Homeless Coalition, the HMIS lead for the CoC, receives a CoC Program grant under the HMIS program component to fund its CoC-wide HMIS system, including leasing its offices, staffing the CoC-wide system, and other costs associated with operating the HMIS. A different agency within the CoC receives a CoC Program grant under the permanent housing program component, which includes HMIS eligible costs to fund HMIS licenses and other costs associated with contributing data to the HMIS.

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Staff and overhead costs directly related to contributing data to HMIS are considered HMIS eligible costs and are not eligible project administrative costs.

HMIS Eligible Costs

HUD does not consider mainstream benefits provided directly to program participants match in the CoC Program because the benefits are not committed to the recipient/subrecipient for the activities funded through the project. Generally, such benefits are provided to the program participant and are based on program participant eligibility for that respective program. However, if funds from mainstream resources (e.g., TANF or Medicaid) are provided ...
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HUD does not consider mainstream benefits provided directly to program participants match in the CoC Program because the benefits are not committed to the recipient/subrecipient for the activities funded through the project. Generally, such benefits are provided to the program participant and are based on program participant eligibility for that respective program. However, if funds from mainstream resources (e.g., TANF or Medicaid) are provided directly to an organization for use in a CoC Program project, then the mainstream resources may be counted as match so long as the other funding source does not prohibit their funds from being used as match for the CoC Program. 

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A memorandum of understanding (MOU) is a written document that must establish unconditional commitment, upon selection to receive a grant, by the third party to provide the services, the specific service to be provided, the profession of the persons providing the service, and the hourly cost of the service to be provided. At a minimum, a MOU must be executed between a recipient and/or subrecipient and a third party service provider and inclu...
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A memorandum of understanding (MOU) is a written document that must establish unconditional commitment, upon selection to receive a grant, by the third party to provide the services, the specific service to be provided, the profession of the persons providing the service, and the hourly cost of the service to be provided. At a minimum, a MOU must be executed between a recipient and/or subrecipient and a third party service provider and include the following information:

1. Agency Information:
   • Recipient’s/subrecipient’s identifying information with point(s) of contact
   • Service provider’s identifying information with point(s) of contact
2. Unconditional Commitment of Third Party Provider to Provide the Service
3. Description of Services to Be Provided
4. Scope of Services to Be Provided and by Whom
   • Specific contract to be matched
   • Length of time services provided/term of contract
   • Point-in-time number of clients receiving service
   • Total clients receiving service over grant term
   • Qualification of persons providing service
   • Estimated value of services provided (such as hourly rate)
5. Documentation of Services Match
   • Documentation requirements and responsibilities of service provider and recipient
   • Timeliness standards of service provider and recipient for providing services to individuals

A copy of the MOU must be provided to HUD prior to grant agreement execution to document the required match for the grant.

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Documentation of in-kind service match requires a different approach than documentation of in-kind goods and equipment. The recipient/subrecipient must enter into a formal memorandum of understanding (MOU) with the agency providing the in-kind service(s) and must establish a system to document the actual value of services provided during the term of the grant. A recipient or subrecipient may use a letter from the partner agency to document t...
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Documentation of in-kind service match requires a different approach than documentation of in-kind goods and equipment. The recipient/subrecipient must enter into a formal memorandum of understanding (MOU) with the agency providing the in-kind service(s) and must establish a system to document the actual value of services provided during the term of the grant. A recipient or subrecipient may use a letter from the partner agency to document the commitment to provide the in-kind service in advance of executing a formal MOU, for instance, if the recipient/subrecipient opts to wait to execute an MOU upon receipt of notification of award from HUD. The MOU may be between a recipient or a subrecipient and another agency, but the terms must be described in the MOU.

If match is provided to multiple recipients by a third-party service provider, the CoC may consider documenting standardized rate information for all local recipients to use as part of in-kind service match documentation. Service providers may use these pre-set rates for their match calculations. For instance, match documentation resources could include preventive medical service fees or free medical services made available to a recipient’s/subrecipient’s program participants by an area health care provider, or the salary of a maintenance worker provided to the recipient for the property.

Services provided by individuals must be valued at rates consistent with those ordinarily paid for similar work in the recipient’s/subrecipient’s organization. If the recipient/subrecipient does not have employees performing similar work, the rates must be consistent with those ordinarily paid by other employers for similar work in the same labor market. Therefore, recipients/subrecipients must document standardized local rates for specific types of services as a basis for match commitments. Common in-kind services include outpatient mental health visits, medications, alcohol and substance abuse therapeutic sessions, and employment training/day programs.

Recipients/subrecipients should periodically check with providers of in-kind match, not only to ensure that they are providing adequate documentation, but also to determine if:

1. Their fee structure and/or standardized pricing has changed; and/or
2. The type(s) of services provided to program participants has changed.

For more information on the documentation requirements for match in the CoC Program, review the CoC 2.0 podcast titled The Importance of Documenting Match Under the CoC Program.

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When the source of match is in-kind goods and/or equipment, written documentation must conform to the OMB Circular requirements in 24 CFR Parts 84 and 85 and the standards described below. Written documentation of the donation of in-kind goods and/or equipment must be provided on the source agency's letterhead, signed and dated by an authorized representative of the source agency, and must, at a minimum, include the following: Value of donated g...
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When the source of match is in-kind goods and/or equipment, written documentation must conform to the OMB Circular requirements in 24 CFR Parts 84 and 85 and the standards described below.

Written documentation of the donation of in-kind goods and/or equipment must be provided on the source agency's letterhead, signed and dated by an authorized representative of the source agency, and must, at a minimum, include the following:

1. Value of donated goods to be provided to the recipient for the project;
2. Specific date the goods will be made available;
3. The actual grant and fiscal year to which the match will be contributed;
4. Time period during which the donation will be available;
5. Allowable activities to be provided by the donation; and
6. Value of commitments of land, buildings, and equipment–the value of these items are one-time only and cannot be claimed by more than one project or by the same project in another year.

Documentation of match must be provided to HUD prior to grant agreement execution.

For more information on the documentation requirements for match in the CoC Program, review the CoC 2.0 podcast titled The Importance of Documenting Match Under the CoC Program.

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When the source is cash, written documentation should be provided on the source agency's letterhead, signed and dated by an authorized representative, and, at a minimum, should include the following:  Amount of cash to be provided to the recipient for the project; Specific date the cash will be made available; The actual grant and fiscal year to which the cash match will be contributed; Time period during which funding will be available; an...
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When the source is cash, written documentation should be provided on the source agency's letterhead, signed and dated by an authorized representative, and, at a minimum, should include the following: 

1. Amount of cash to be provided to the recipient for the project;
2. Specific date the cash will be made available;
3. The actual grant and fiscal year to which the cash match will be contributed;
4. Time period during which funding will be available; and
5. Allowable activities to be funded by the cash match.

Recipients/subrecipients must provide HUD with match documentation prior to grant agreement execution. For more information on the documentation requirements for match in the CoC Program, review the CoC 2.0 podcast titled The Importance of Documenting Match Under the CoC Program.

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Allowable in-kind match resources may be from public (not statutorily prohibited by the funding agency from being used as a match) or private resources and may include the value of any real property, equipment, goods, or services contributed to the project. The recipient must ensure that any funds used to satisfy the in-kind matching requirements are eligible under the laws governing the services in order to be used as match for a grant awarded u...
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Allowable in-kind match resources may be from public (not statutorily prohibited by the funding agency from being used as a match) or private resources and may include the value of any real property, equipment, goods, or services contributed to the project. The recipient must ensure that any funds used to satisfy the in-kind matching requirements are eligible under the laws governing the services in order to be used as match for a grant awarded under the CoC Program.

In general, program participant mainstream benefits are not considered match in the CoC Program because the benefits are not committed to the recipient/subrecipient for the activities funded through the project. Instead, benefits are provided to the program participant and are based on program participant eligibility for that program.

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Recipients/subrecipients may use funds from any source, including any other federal sources (excluding Continuum of Care Program funds), as well as state, local, and private sources, provided that funds from the source are not statutorily prohibited to be used as a match. The recipient must ensure that any funds used to satisfy the cash match requirements are not prohibited from being used as a match under the laws governing those funds. In gener...
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Recipients/subrecipients may use funds from any source, including any other federal sources (excluding Continuum of Care Program funds), as well as state, local, and private sources, provided that funds from the source are not statutorily prohibited to be used as a match. The recipient must ensure that any funds used to satisfy the cash match requirements are not prohibited from being used as a match under the laws governing those funds.

In general, program participant mainstream benefits are not considered match in the CoC Program because the benefits are not committed to the recipient/subrecipient for the activities funded through the project. Instead, benefits are provided to the program participant and are based on program participant eligibility for that program.

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Leverage is the non-match cash or non-match in-kind resources committed to making a CoC Program project fully operational. This includes all resources in excess of the required 25 percent match for CoC Program funds as well as other resources that are used on costs that are ineligible in the CoC Program. Leverage funds may be used for any program related costs, even if the costs are not budgeted or not eligible in the CoC Program. Leverage may be...
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Leverage is the non-match cash or non-match in-kind resources committed to making a CoC Program project fully operational. This includes all resources in excess of the required 25 percent match for CoC Program funds as well as other resources that are used on costs that are ineligible in the CoC Program.

Leverage funds may be used for any program related costs, even if the costs are not budgeted or not eligible in the CoC Program. Leverage may be used to support any activity within the project provided by the recipient or subrecipient. 

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Cash match is actual cash contributed to a CoC Program grant provided that the cash contribution is spent on eligible CoC Program costs outlined in Subpart D of the interim rule (see Section 578.73(b) for more information) in accordance with the requirements of the CoC Program Interim Rule. For more information on the documentation requirements for cash match in the CoC Program, review the CoC 2.0 podcast titled The Importance of Documenting Matc...
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Cash match is actual cash contributed to a CoC Program grant provided that the cash contribution is spent on eligible CoC Program costs outlined in Subpart D of the interim rule (see Section 578.73(b) for more information) in accordance with the requirements of the CoC Program Interim Rule.

For more information on the documentation requirements for cash match in the CoC Program, review the CoC 2.0 podcast titled The Importance of Documenting Match Under the CoC Program.

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In-kind match is the value of any real property, equipment, goods, or services contributed to a CoC Program grant that would have been eligible costs under the CoC Program if the recipient/subrecipient was required to pay for such costs with CoC Program grant funds.   For more information on the documentation requirements for in-kind match in the CoC Program, review the CoC 2.0 podcast titled The Importance of Documenting Match Under the CoC...
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In-kind match is the value of any real property, equipment, goods, or services contributed to a CoC Program grant that would have been eligible costs under the CoC Program if the recipient/subrecipient was required to pay for such costs with CoC Program grant funds.  

For more information on the documentation requirements for in-kind match in the CoC Program, review the CoC 2.0 podcast titled The Importance of Documenting Match Under the CoC Program.

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Match is actual cash or in-kind resources contributed to the grant. All costs paid for with matching funds must be for activities that are eligible under the CoC Program, even if the recipient is not receiving CoC Program grant funds for that activity. All grant funds must be matched with an amount no less than 25% of the awarded grant amount (excluding the amount awarded to the leasing budget line item) with cash or in-kind resources. Match reso...
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Match is actual cash or in-kind resources contributed to the grant. All costs paid for with matching funds must be for activities that are eligible under the CoC Program, even if the recipient is not receiving CoC Program grant funds for that activity. All grant funds must be matched with an amount no less than 25% of the awarded grant amount (excluding the amount awarded to the leasing budget line item) with cash or in-kind resources. Match resources may be from public (not statutorily prohibited by the funding agency from being used as a match) or private resources.

According to section 578.73 of the CoC Program Interim Rule, in CoCs where there is more than one recipient, the recipient must provide match on a grant-by-grant basis. In CoCs in which there is there is a UFA or a sole recipient for the Continuum, matching funds may be provided by the recipient on a Continuum-wide basis.

Examples A and B are calculations of match with and without a leasing budget line item.

EXAMPLE A
Total amount requested from HUD (without leasing)

• Rental Assistance funding = $95,000
• Project Administration funding = $5,000
• Total amount requested = $100,000

Total amount requested from HUD x .25 = Minimum Match Requirement

• $100,000 x .25 = $25,000

EXAMPLE B
Total amount requested from HUD (with leasing)

• Leasing funding = $40,000
• Supportive Services funding = $55,000
• Project Administration funding = $5,000
• Total amount requested = $100,000

Total amount requested from HUD, excluding amount requested for leasing

• $100,000 (Total Amount Requested) - $40,000 (Leasing Funding) = $60,000

Total amount requested from HUD x .25 = Minimum Match Requirement

• $60,000 x .25 = $15,000

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In general, all recipients/subrecipients receiving CoC Program grant funds for acquisition, rehabilitation, or new construction must operate the housing or provide supportive services, in compliance with the McKinney-Vento Act and the CoC Program regulation, for at least 15 years from the date of initial occupancy by a program participant or the date of initial service provision by the recipient/subrecipient. ...
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and Prevention of Undue Benefits

In general, all recipients/subrecipients receiving CoC Program grant funds for acquisition, rehabilitation, or new construction must operate the housing or provide supportive services, in compliance with the McKinney-Vento Act and the CoC Program regulation, for at least 15 years from the date of initial occupancy by a program participant or the date of initial service provision by the recipient/subrecipient. 

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and Prevention of Undue Benefits

HUD believes that housing placement is in fact a very important measure and also one that we have asked CoCs to measure even before the system performance measures. Our ultimate goal is, and has been, to help people exit homelessness to a stable housing situation. Keep in mind that “successful” for 7a.1 includes sheltered or temporary situations and not just permanent housing, while the latter two metrics—7b.1 and 7b.2—focus on permanent ...
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HUD believes that housing placement is in fact a very important measure and also one that we have asked CoCs to measure even before the system performance measures. Our ultimate goal is, and has been, to help people exit homelessness to a stable housing situation. Keep in mind that “successful” for 7a.1 includes sheltered or temporary situations and not just permanent housing, while the latter two metrics—7b.1 and 7b.2—focus on permanent housing exits in a way that is familiar to CoCs already. We have seen communities with difficult housing challenges overcome the issue of limited housing affordability and availability to accomplish great things. That certainly is not to say that it is not a challenge, but this measure captures a critical set of metrics related to ending homelessness for households.

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At this time, camps are not counted as a separate project type and HUD is not considering adding them as a project type. Camps will continue to be viewed as unsheltered situations for measurement purposes, as indicated in the language in the HEARTH “Homeless” Definition final rule. HUD will continue to learn what it can and provide guidance and technical assistance where needed to assist communities to address encampments, sanctioned or other...
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At this time, camps are not counted as a separate project type and HUD is not considering adding them as a project type. Camps will continue to be viewed as unsheltered situations for measurement purposes, as indicated in the language in the HEARTH “Homeless” Definition final rule. HUD will continue to learn what it can and provide guidance and technical assistance where needed to assist communities to address encampments, sanctioned or otherwise.

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HUD is not lumping Safe Haven (SH) with Emergency Shelter (ES) but does include it in the first metric under Measure 1, Length of Time Homeless, because SH and ES are the project types that map to the chronically homeless definition. SH is a unique and important program model, and HUD understands that SH stays may be longer than ES stays. SH projects that did not previously reclassify as Transitional Housing (TH) or Permanent Supportive Housing (...
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HUD is not lumping Safe Haven (SH) with Emergency Shelter (ES) but does include it in the first metric under Measure 1, Length of Time Homeless, because SH and ES are the project types that map to the chronically homeless definition. SH is a unique and important program model, and HUD understands that SH stays may be longer than ES stays. SH projects that did not previously reclassify as Transitional Housing (TH) or Permanent Supportive Housing (PSH) are considered a form of shelter and people in SH projects are considered literally homeless.

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The lookback date refers to the earliest date that data from the Homeless Management Information System (HMIS) will be used in order to complete reporting for this reporting year. The relevance of 10/1/2012 is related primarily to the method for calculating Measure 2. This measure begins with clients who exited to a permanent housing destination in the date range two years prior to the report date range. Of those clients, the measure reports on h...
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The lookback date refers to the earliest date that data from the Homeless Management Information System (HMIS) will be used in order to complete reporting for this reporting year. The relevance of 10/1/2012 is related primarily to the method for calculating Measure 2. This measure begins with clients who exited to a permanent housing destination in the date range two years prior to the report date range. Of those clients, the measure reports on how many of them returned to homelessness as indicated in the HMIS system for up to two years after their initial exit. For the reporting period from 10/1/2014 - 9/30/2015, the date range two years prior is 10/1/2012-9/30/2013.

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Yes. All clients assisted through PATH street outreach projects and entered in the CoC’s Homeless Managements Information System (HMIS) are included in this measure and should be treated like any other street outreach project for calculation purposes. PATH clients who are in ES when initially enrolled should still have their Destination data (data element 3.12) collected and entered in HMIS. If such client exits PATH and still remains in ES, th...
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Yes. All clients assisted through PATH street outreach projects and entered in the CoC’s Homeless Managements Information System (HMIS) are included in this measure and should be treated like any other street outreach project for calculation purposes. PATH clients who are in ES when initially enrolled should still have their Destination data (data element 3.12) collected and entered in HMIS. If such client exits PATH and still remains in ES, this would be considered a positive outcome per the calculation. Ideally, PATH clients who are enrolled while in ES will be assisted to move to permanent housing by the PATH project and other local assistance sources. Keep in mind that it is possible for one PATH funded project to serve two separate populations of focus. In such cases, the PATH project must have two projects set up in their HMIS – one as a Street Outreach project type for the street homeless clients and another as a Supportive Services Only (SSO) project type for the sheltered or at risk homeless clients.

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For this question, consider an example where a client exited from both an outreach project and an emergency shelter (ES) project, both with a permanent housing (PH) destination. The Homeless Management Information System (HMIS) programming specifications address many such issues. Generally, HUD discourages having persons in multiple projects at the same time. While this is not always possible, it often is. For instance, with regard to the example...
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For this question, consider an example where a client exited from both an outreach project and an emergency shelter (ES) project, both with a permanent housing (PH) destination.

The Homeless Management Information System (HMIS) programming specifications address many such issues. Generally, HUD discourages having persons in multiple projects at the same time. While this is not always possible, it often is. For instance, with regard to the example in the question, many projects require a person to be exited from street outreach at the time they enter ES. This is not always the case and it often depends on the nature of the ES or the Outreach program but such local protocols can address this issue. If you do not see the answer to this specifically addressed in the HMIS programming specifications please submit a question to the HUD Exchange Ask A Question (AAQ) portal with some specific examples.

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The HMIS Programming Specifications clarify that the length of time goes to either the longest continuous length of time beyond 365 days from the reporting period or to the “lookback” date. CoCs do not include time prior to the lookback date for system data. That means that any time homeless before October 1, 2012, will not be included. When CoCs begin using data from 3.17 (this data element will be renamed 3.9.17 starting 10/1/2016), HUD pla...
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The HMIS Programming Specifications clarify that the length of time goes to either the longest continuous length of time beyond 365 days from the reporting period or to the “lookback” date. CoCs do not include time prior to the lookback date for system data. That means that any time homeless before October 1, 2012, will not be included. When CoCs begin using data from 3.17 (this data element will be renamed 3.9.17 starting 10/1/2016), HUD plans to include all time reported in that field, even if that time extends further in the past than October 1, 2012. HUD anticipates releasing more information after October 2016 to clarify any questions as they relate to reporting data from the 3.17/3.9.17 data elements. HUD is not requiring data from these fields in this initial submission in the Homelessness Data Exchange (HDX). When HUD eventually does require the inclusion of 3.9.17 data, the Length of Time Homeless measure will be reported with and without it so CoCs will still be able to compare their data from year to year, and not compare a year without 3.9.17 to a year with 3.9.17.

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Victim service provider projects do not enter client-level data into their Homeless Management Information System (HMIS). These projects must enter their data into a comparable database, and therefore will not be included in any calculation of system coverage or in any of the data for the system performance measures. Please note that this only applies to projects that are defined as “victim service providers” under the Violence Against Women ...
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Victim service provider projects do not enter client-level data into their Homeless Management Information System (HMIS). These projects must enter their data into a comparable database, and therefore will not be included in any calculation of system coverage or in any of the data for the system performance measures. Please note that this only applies to projects that are defined as “victim service providers” under the Violence Against Women Act (VAWA) Act. Data is included from projects that serve victims of domestic violence but who are not considered “victim service providers.” For more information on “victim service providers,” please go to FAQ 2686, “How does HUD define victim service provider?”.

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HUD will take into account Homeless Management Information System (HMIS) bed coverage and data quality in reviewing the system performance measures, and while data collection and quality challenges will be considered in reviewing the measures, it remains a priority to have the most complete data as possible, both through high bed coverage and good data quality. As CoCs strategically plan to meet the needs of persons seeking homeless services, it ...
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HUD will take into account Homeless Management Information System (HMIS) bed coverage and data quality in reviewing the system performance measures, and while data collection and quality challenges will be considered in reviewing the measures, it remains a priority to have the most complete data as possible, both through high bed coverage and good data quality. As CoCs strategically plan to meet the needs of persons seeking homeless services, it is critical that they have information about all of their providers. Without data from all projects dedicated to serving persons who are homeless, the CoC will not be able to understand the systemic efforts to end homelessness in their community, or to present HUD with a complete picture of homelessness. Many CoCs have successfully been able to increase their system coverage by working with local or state funders to integrate HMIS into their requirements with agencies, or by creating local incentives for HMIS participation. Many CoCs have been successful showing providers that the data is useful to them - it helps them to better serve people and even get more funding. If a CoC would like more guidance on this topic, they should request Technical Assistance (TA) from HUD’s TA Portal.

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The concept of system performance is that all members involved with the effort of ending homelessness are coordinated to end homelessness. HUD believes that CoCs must see their efforts to end homelessness as a united effort. Most of the system performance measures rely on the use of Homeless Management Information System (HMIS) data that reflects the full system of homeless assistance available in each community, and not just those projects that ...
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The concept of system performance is that all members involved with the effort of ending homelessness are coordinated to end homelessness. HUD believes that CoCs must see their efforts to end homelessness as a united effort. Most of the system performance measures rely on the use of Homeless Management Information System (HMIS) data that reflects the full system of homeless assistance available in each community, and not just those projects that are CoC Program funded. If the project is of one of the types included in the measure calculation, it should be included, regardless of the funding source. CoCs and HMIS Leads should understand their current system, identify projects not participating in HMIS, and work closely with those projects to encourage their participation in HMIS, as they are a valuable member of the overall system of homeless assistance. HUD is aware that some partners are not anxious to participate in data collection and reporting, as well as other functions associated with HMIS. HUD encourages you to continue to work with them to show their participation is important. However, please note that victim service provider projects cannot be entered into HMIS. These projects must enter their data into a comparable database, and therefore will not be included in any calculation of system coverage.

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After running the System Performance Measure report out of your vendor’s Homeless Management Information System (HMIS) software, CoCs will enter that data into HUD’s Homelessness Data Exchange (HDX). For the FY 2016 CoC Program NOFA, the data submission deadline was originally Monday, August 1, 2016 at 7:59:59 PM EDT. However, on July 26, 2016, HUD announced that the deadline has been extended to August 15, 2016 at 7:59:59 PM EDT. View the ne...
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After running the System Performance Measure report out of your vendor’s Homeless Management Information System (HMIS) software, CoCs will enter that data into HUD’s Homelessness Data Exchange (HDX). For the FY 2016 CoC Program NOFA, the data submission deadline was originally Monday, August 1, 2016 at 7:59:59 PM EDT. However, on July 26, 2016, HUD announced that the deadline has been extended to August 15, 2016 at 7:59:59 PM EDT. View the news posting for more information.

Instructions on how to submit data in HDX can be found on the 2016 Data Submission Guidance page.

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Users should leave a note of explanation for each validation warning received or any other field they wish. A note of explanation should be completed for each warning received by clicking on the field with the warning and entering a note. Click on the “Save Notes” box on the bottom left of the notes box to save your explanation.

System Performance Measures

No. The submission by the CoC will be considered final.

System Performance Measures

Data can be overwritten, whether manually entered or imported, until the point of submission. Once you have submitted your data, you may request assistance via the HUD Exchange Ask A Question (AAQ) portal if you wish to resubmit prior to the due date.

System Performance Measures

In 2016, the PIT Count data is auto-populated from the final PIT submission from the January 2015 count. The previous year’s data is populated from the 2014 count, unless no street count was conducted that year. In that case, the 2013 street count is used.

System Performance Measures

The reporting period for the System Performance Measures report that will be submitted in HDX in summer 2016 is 10/1/2014 - 9/30/2015. You do not need to submit data to populate the previous period fields. In future years, these fields will be auto-populated with your submissions from prior years.

System Performance Measures

In order to be able to access the System Performance Measures (Sys PM) reporting module in the Homelessness Data Exchange (HDX), each CoC must designate a Primary Contact in HDX. The Primary Contact is the contact person for the HUD approved Collaborative Applicant and that individual is responsible for ensuring that HUD receives complete and accurate System Performance Measures data from the CoC. To achieve this, the Collaborative Applicant ofte...
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In order to be able to access the System Performance Measures (Sys PM) reporting module in the Homelessness Data Exchange (HDX), each CoC must designate a Primary Contact in HDX. The Primary Contact is the contact person for the HUD approved Collaborative Applicant and that individual is responsible for ensuring that HUD receives complete and accurate System Performance Measures data from the CoC. To achieve this, the Collaborative Applicant often allows other CoC staff to access to the Sys PM, Point-in-Time (PIT) Count, Housing Inventory Count (HIC), and Annual Homeless Assessment Report (AHAR) HDX modules as authorized users.

The CoC HDX Primary Contact must individually assign or modify rights to each HDX module for each user by checking the box that corresponds to the appropriate level of access.

If you are having issues seeing the Submit buttons, before submitting your data, please confirm that you have input notes for all Validation Warnings and corrected all errors. If there are errors preventing your data submission, the Submit Data button on the Reporting Status page will be gray.

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For this measure, HUD does not have a timeframe requirement. Historically, the retention requirement was 6 months. One of the reasons HUD is not focusing on this is because it did not have access to data on returns to homelessness. The data on returns in Measure 2 will capture data on people who do not retain their permanent supportive housing as well as other forms of permanent housing, so together, Measure 2 and 7 cover the cycle of ending home...
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For this measure, HUD does not have a timeframe requirement. Historically, the retention requirement was 6 months. One of the reasons HUD is not focusing on this is because it did not have access to data on returns to homelessness. The data on returns in Measure 2 will capture data on people who do not retain their permanent supportive housing as well as other forms of permanent housing, so together, Measure 2 and 7 cover the cycle of ending homelessness – from getting a household permanently housed and ensuring that they don’t return to homelessness.

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Measure 6 is not applicable to CoCs in 2016, as no CoC has exercised the authority provided by the HEARTH Act to serve homeless families with children and youth defined as homeless under other Federal statutes (see section 422(j)). In future years, if a CoC exercises that flexibility, their baseline year for this measure will be established at that point.

System Performance Measures

The HEARTH Act defined the selection criteria that are the basis for the System Performance Measures. The criterion related to income is “jobs and income growth for homeless individuals and families.” HUD is aware that this system-level measure is different from the project-level measures in the APR.

System Performance Measures

No. The APR is still required of all CoC Program recipients, and is a grantee-level report that allows HUD to understand how grant funds were expended and the outcome of those efforts. The System Performance Measures are system-level data that allow HUD to understand how a CoC’s entire system of homeless assistance is performing.

System Performance Measures

While it is useful to look within your CoC at different regions for your own analysis and planning, for HUD purposes, you will submit a single set of data in the Homelessness Data Exchange (HDX) for the entire CoC. We encourage communities to carefully document the details of their challenges when they submit their data.

System Performance Measures

HUD will be comparing communities to themselves, and will limit the amount of comparison done across CoCs. HUD wants to see positive changes for the entire CoC (such as declines in length of time homeless), but it does not yet have enough data on these measures to know what reasonable benchmarks or targets for improvement would be for any of the measures. HUD will carefully analyze the System Performance Measure data that is submitted to get a be...
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HUD will be comparing communities to themselves, and will limit the amount of comparison done across CoCs. HUD wants to see positive changes for the entire CoC (such as declines in length of time homeless), but it does not yet have enough data on these measures to know what reasonable benchmarks or targets for improvement would be for any of the measures. HUD will carefully analyze the System Performance Measure data that is submitted to get a better understand of what benchmarks or targets would be appropriate.

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CoCs should only include data on projects within their CoC boundaries. This may involve prorating some projects where there are not clear boundaries. This is most relevant when working with projects funded by other sources, including the U.S. Department of Veterans Affairs (VA). The first place where this would show up is the Housing Inventory Count (HIC). There should be a fairly close relationship between the projects included in the system per...
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CoCs should only include data on projects within their CoC boundaries. This may involve prorating some projects where there are not clear boundaries. This is most relevant when working with projects funded by other sources, including the U.S. Department of Veterans Affairs (VA). The first place where this would show up is the Housing Inventory Count (HIC). There should be a fairly close relationship between the projects included in the system performance measures and those entered in the HIC.

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For the short term, no thresholds have been set. Unlike the AHAR, HUD expects every community to report the System Performance Measure data. HUD may impose data quality factors in its CoC Program NOFA criteria in the future. This would likely apply to both the data quality and bed coverage. For bed coverage, HUD set a standard of 86 percent in the FY 2016 CoC Program NOFA. However, data quality and bed coverage standards will evolve over time as ...
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For the short term, no thresholds have been set. Unlike the AHAR, HUD expects every community to report the System Performance Measure data. HUD may impose data quality factors in its CoC Program NOFA criteria in the future. This would likely apply to both the data quality and bed coverage. For bed coverage, HUD set a standard of 86 percent in the FY 2016 CoC Program NOFA. However, data quality and bed coverage standards will evolve over time as HUD receives more information on how systems are working. HUD is looking at various ways to gauge data quality. As this evolves, HUD will provide more information.

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The reporting period follows the Federal Fiscal Year, which is October 1st through September 30th. For the FY 2016 CoC Program Competition, CoCs will submit data for October 1, 2014 through September 30, 2015. The timeframe allows HUD to gather data in a uniform fashion across all CoCs and the projects in those CoCs, regardless of individual project grant periods.

System Performance Measures

For the FY 2016 CoC Program Competition, HUD will focus on a CoC’s ability to produce the System Performance Measures data. This is intended to be a test for whether CoCs can run the data. However, data quality is and will continue to be important in producing data and measuring against the CoC’s baseline. HUD expects CoCs to incorporate this data into their larger system improvement activities. Additionally, HUD is aware that this first roun...
↓ Read More. System Performance Measures

For the FY 2016 CoC Program Competition, HUD will focus on a CoC’s ability to produce the System Performance Measures data. This is intended to be a test for whether CoCs can run the data. However, data quality is and will continue to be important in producing data and measuring against the CoC’s baseline. HUD expects CoCs to incorporate this data into their larger system improvement activities. Additionally, HUD is aware that this first round of submissions will have data quality issues. HUD will take into account these data quality issues and strongly encourages communities to carefully document any data quality challenges.

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