Continuum of Care (CoC)

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Continuum of Care (CoC)

• ?Promotes community-wide commitment to the goal
• of ending homelessness.
• ?Provides funding for efforts by nonprofit
  providers
• and State and local governments to quickly
  re-house
• homeless individuals and families to minimize
• trauma and dislocation.
• ?Promotes access to and effective utilization of
• mainstream programs.
• ?Optimizes self-sufficiency among individuals and
• families experiencing homelessness.

2
A CoC is.

• Simply stated, a Continuum of Care is established
  by representatives of relevant organizations
  within a geographic area to carry out the
  responsibilities set forth in the CoC Program
  Interim Rule.

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Establishing a Continuum of Care

• - CoC Program Interim Rule requires
• communities to establish a CoC in order to
• receive CoC Program Funding
• - The CoC must meet minimum requirements
• for CoC Structure, governance and
• responsibilities.
• The rule requires collaboration between CoC
• and ESG recipients on certain responsibilities

4
CoC Membership

• Membership should ensure
• - Communitywide commitment to ending and
• preventing homelessness
• - Representation of the relevant organizations
• within the entire CoC

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Examples of CoC Membership

• Nonprofit homeless Assistance providers
• Victim Service Providers Mental
  Health Agencies
• Faith Based Organizations Hospitals
• Governments
  Universities
• Businesses
  Affordable Housing Developers
• Advocates
  Law Enforcement
• Public Housing Agencies
  Organizations that serve
• School Districts
  homeless veterans
• Social Service providers
  Formerly homeless persons

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What governs the CoC Program?

• 24 CFR Part 578 - CoC Final Interim Rule
• July 31, 2012
• 24 CFR Parts 91, 582, and 583 - Homeless
  Emergency Assistance and Rapid Transition to
  Housing (HEARTH) Defining Homeless
• December 5, 2011
• OMB Circulars, notices, etc. (A-84, A-102, A-110)

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CoC and ESG Coordination

• Key elements
• - Centralized/coordinated assessment
• Consolidated Plan homelessness strategy and goals
• Allocation of ESG funding
• ESG Performance standards
• ESG subrecipent participation in HMIS
• ESG and CoC written standards

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Emergency Solutions Grant (ESG)

• The ESG Interim Rule revised sections of the
  Consolidated Planning regulations at 24 CFR part
  91.
• Consolidated Plan Regulation as Amended by ESG
  Interim Rule and Homeless Definition Final Rule
• This version of 24 CFR Part 91, Consolidated
  Submissions for
• Community Planning and Development Programs
  as
• Amended by ESG Interim Rule and Homeless
  Definition
• Final Rule, explains Consolidated Submissions
  for Community
• Planning and Development Programs as amended
  by the Emergency
• Solutions Grants Program interim rule and
  Homeless definition final
• rule.
• Date Published November 2011

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ESG Annual Action Plan

• Consultation with Continuums of Care
• The rule requires ESG recipients to consult with
  Continuums of Care in
• Allocating funds for eligible activities
• Developing performance standards
• Evaluating outcomes of ESG-assisted projects and
  developing funding
• Policies and procedures for the administration
  and operation of the HMIS.
• ESG recipients must also coordinate and integrate
  ESG activities with other homelessness and
  mainstream programs.

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ESG Annual Action Plan

• Consolidated Plan Revisions
• The rule requires increased collaboration between
  ESG recipients and CoC programs, and other
  mainstream programs. CoCs are required to
  participate in the local Con Plan process and
  evaluate outcomes for ESG projects. Also, ESG
  recipients must consult with CoCs about the
  allocation of ESG funds and participation in
  HMIS.

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ESG Annual Action Plan
ESG Annual Action Plan

• In the Action Plan, local governments are
  required to specify the standards under which
  homelessness prevention and rapid re-housing
  assistance will be administered and to describe
  the assessment systems that will be used. The
  interim rule recognizes a different approach for
  states

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ESG Annual Action Plan - State

• The requirement for states differ slightly from
  those that apply to local governments, in order
  to accommodate the states restrictions on
  states use of ESG funds and the variety of areas
  of Continuums of Care their programs encompass.
  Under the state programs, the written standards
  for providing ESG assistance may vary by
  subrecipient, Continuum of Care, or the
  geographic area over which services are
  coordinated.

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ESG Checklist

• ESG Checklist of Requirements for the
  Homelessness Portions of Consolidated Plan Annual
  Action Plan
• This checklist, which focuses on the
  homelessness-related sections of the Annual
  Action Plan, can assist recipients in drafting an
  accurate and complete submission in accordance
  with the regulations. Please note that only the
  elements of the Annual Action Plan specifically
  related to homelessness planning and ESG are
  included in this checklist.
• Date Published December 2012
• Onecpd.info/esg

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ESG CAPER
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What if I am not an ESG recipients, what happens
then?

• CAPER must address Affordable Housing (91.520(b)
• - Must include the number and types of families
  serviced.
• - Must include the number of homeless persons
  served, in addition to the numbers of extremely
  low, low-mod, and middle income persons served.

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Continued.

• Homelessness - 91.520(c)
• Must include a narrative evaluation of the
  progress in meeting specific objectives for
  reducing and ending homelessness through
• Outreach (especially un-sheltered)
• Emergency and Transitional Shelter
• Helping homeless person transition to PH
• Helping Low Income Persons to avoid homelessness.

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Centralized or Coordinated Assessment CoC
Program What does this mean for an ESG
recipient?

• The Continuum of Care program requires that all
  communities develop and implement a centralized
  or coordinated assessment system. According to
  this interim rule, ESG recipients (including
  states ) will be required to participate in the
  system to initially assess the eligibility and
  needs of each household seeking homeless
  assistance.
• ESG recipients will be expected to implement this
  provision after a final CoC rule has been
  published and the CoC has implemented such an
  assessment system.
• Date of compliance August 30,2014

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Written Standards for the CoC Assistance

• CoC must work with ESG Recipient to develop
  written standards for providing CoC assistance
• - Eligibility policies and procedures
• Determining and prioritizing eligible persons for
  TH, RRH, and PSH resources (reflect standards in
  coordinated assessment system)
• Determining levels of RRH assistance and
  participant rent contribution (across projects)
• Additional standards for designated HPCs (high
  performing communities)

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CoC Planning

• Consult with ESG recipients
• - Plan for allocation ESG Recipients
• Reporting on and evaluating performance of
• ESG recipients and subrecipients.

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CoC Program Applicant Eligibility

• Private nonprofit organizations
• States, local governments, and instrumentalities
  of state and local governments are eligible to
  apply if they have been selected by the Continuum
  of Care for the geographic area in which they
  operate.

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Program Components for the CoC Program

• Permanent Housing (PH)
• - Permanent Supportive Housing (PSH)
• - Rapid Re-housing (RRH)
• Transitional Housing (TH)
• Supportive Services Only (SSO)
• HMIS
• Homelessness Prevention (HPC only)

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Eligible Activities

• Acquisition/Rehabilitation/New Construction
• Leasing
• Rental Assistance
• Supportive Services
• Operating Costs
• HMIS
• Project Administration

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Rental Assistance

• The CoC regulations, at 24 CFR 578.51(b) require
  rental assistance to be administered by a State,
  unit of general purpose local government, or a
  public housing agency. Nonprofits may not
  administer rental assistance unless the grant was
  originally awarded under the Shelter Plus Care
  program and the nonprofit administered the rental
  assistance under that program

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Eligible Costs Program Components
Permanent Housing Permanent Housing TH SSO HMIS
Eligible Costs PHPHS PHRRH ? ?
Acquisition ? ? ?
Rehabilitation ? ?
New Construction ? ?
Leasing ? ? ?
Rental Assistance ? ? ?
SS ? ? ? ?
Operating ? ?
HMIS ? ? ? ? ?
Project Administration ? ? ? ? ?
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2013 NOFA and Future Funding

• At this time, the SNAPS office is working
  diligently to complete the work that was
  interrupted during the shutdown and get the
  competition open as soon as possible.
• Information regarding the final step for the CoC
  Registration process, as well as additional
  schedule updates, in the coming days.
• We know there are not funds to fully fund all
  renewals grants in the 2013 competition.

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Resources

• httpswww.onecpd.info/coc
• - CoC Program Interim Final Rule
• Establishing and Operating a CoC Guide
• CoC Governance Crosswalk of Changes CoC
  Program, SHP, and SC Program Regulations
• https.www.onecpd.info/esg
• - Learn about ESG Requirements
• - View ESG Law, Regulations, and Notices
• - View the SNAPS weekly focus
• - View SNAPS-Shots
• - View Other ESG Program Information