2007 HUD Continuum of Care Homeless Assistance Programs Summary

This information is form Alison Recca-Ryan, Director, of the new Jersey office of the Corporation for Supportive Housing and is CSH’s response to summary of the SuprNOFA for the Continuum of Care Homeless Assistance Programs.

On Tuesday, March 13, 2007, the U.S. Department of Housing and Urban Development (HUD) published its Fiscal Year 2007 Super Notice of Funding Availability (the “SuperNOFA”), a notice that makes available approximately $2.4 billion in funding through 38 individual grant programs, including approximately $1.25 billion for the Continuum of Care Homeless Assistance Programs (sometimes also referred to as the McKinney-Vento Homeless Assistance Act programs).

Please Note: CSH is offering the information in this Summary based on our current best understanding and interpretation of the Continuum of Care Homeless Assistance Programs within the 2007 SuperNOFA. This summary is not meant to represent “official” advice under HUD authority. For more information about this year’s SuperNOFA, visit the HUD website. CSH has previously released a Summary of the General Section of HUD’s SuperNOFA (which was released on January 18, 2007 – see pages 2395 through 2420 of the January 18, 2007 Federal Register), and that summary is available here.

The General Section lays out the general requirements for applications to all of the SuperNOFA programs – this Summary focuses specifically on the requirements for applications to the Continuum of Care Homeless Programs, as described on pages 11742 through 11757 of the Federal Register for March 13, 2007, including:

The Supportive Housing Program (CFDA No. 14.235);
The Shelter Plus Care program (CFDA No. 14.238); and
The Section 8 Moderate Rehabilitation Single Room Occupancy for Homeless Individuals program (CFDA No. 14.249).

Please also Note: At the time this Summary is being prepared, the CoC Application Materials have not yet been posted to the HUD website, but are expected to be available at on or before Monday, March 19, 2007. A Questions and Answers Supplement is also expected to be made available at that location in the near future. Once those materials are available, CSH will review those documents and provide additional summary information as soon as possible.

Funds Available:
Approximately $1.25 billion is being made available for the CoC competition in FY 2007, up from approximately $1.2 billion in FY 2006.

Deadline and Format for Applications:

The application submission deadline for the Continuum of Care Homeless Assistance is June 8, 2007. Applicants should note that HUD will continue to require electronic submission for all program applications except for the Continuum of Care Programs, which will remain a paper application process. For FY 2008, HUD intends that the Continuum of Care will need to submit via electronic application. The General Section notes on page 2396:

“Therefore, it is in the interest of Continuum of Care applicants to complete the Grants.gov registration process in anticipation of moving to electronic application submission in 2008. Continuum of Care agencies would benefit from becoming familiar with the Grants.gov filing requirements so that they do not limit their ability to apply for funding from federal sources. HUD recommends that all prospective applicants take the time to carefully read the Federal Register notice published on October 31, 2006, entitled ‘‘Notice of Opportunity to Register Early and other Important Information for Electronic Application Submission via Grants.gov’’ and register prior to the publication of the Program Sections of the FY2007 SuperNOFA. The early registration notice can be found on HUD’s Web site (See page 2396 of the General Section.) The Federal Register notice contains detailed instructions on the electronic submission process from early registration through submission and validation (page 2396 and pages 2402 through 2408 of the General Section).

Highlights of Changes from Last Year:

There is really only one major change this year to the Continuum of Care programs NOFA and that is to the “Hold Harmless Reallocation Process.” The new process allows for Continuums to put in new permanent housing projects without the risk of losing the reallocated amount from their Continuum’s pro rata share. In the past a Continuum ran the risk of losing funds overall if their Continuum did not meet the ever increasing threshold for funding—the FY 2006 threshold was a score above 86. Please see the Hold Harmless Provisions and Project Priorities section below for more details.

HUD has also continued to refine the Logic Model required for all applications. This year, HUD has made additional changes to the Logic Model format, including: adding drop-down menus for HUD Strategic Goals and Policy Priorities; added tabs for Year 1, Year 2, and Year 3 activities, as well as a tab for Total; and included a new tab for reporting instructions. Please see the Logic Models and Return on Investment Statements section below for more details.

This year’s SuperNOFA also provides additional clarifying information regarding project quality threshold requirements – see the Additional Threshold and Scoring Guidance section below for more information.

Bonus Funding for Permanent Supportive Housing for Chronically Homeless Persons:

The Samaritan Housing Initiative (renamed in 2005, formerly called the Permanent Housing bonus) remains largely unchanged from last year.
Projects seeking Samaritan Initiative funds must rank the project #1 and the project must be a permanent housing project that will exclusively serve people meeting the definition of “chronic homelessness.”
While bonus funding must be used to exclusively serve the chronically homeless, this funding can be used as part of a larger project or building that serves other populations as well, but other funding would be needed for costs associated with units serving people who are not chronically homeless.

The amount of bonus funding available to each CoC under this Initiative is based on the same formula as 2006. The Samaritan Initiative bonus amount for each CoC is up to 15% of its preliminary pro-rata share, with a cap of $6 million for the largest CoCs.

Only housing activities count toward the Samaritan Initiative bonus; SHP projects may use up to 20% of the bonus funding for case-management costs.

Excess initial pro rata need can be added to a #1-ranked Samaritan Housing Initiative project.

A Samaritan Housing Initiative project may apply under any of the McKinney programs—SHP, Section 8 Moderate Rehab or Shelter Plus Care.

Hold Harmless Reallocation Process Provisions:

The hold harmless pro rata need is the total one-year amount of all of a Continuum’s SHP projects eligible for a renewal in a given year—each COC is eligible to receive the GREATER of their initial pro-rata need or the total amount of all SHP one-year renewals. Should a jurisdiction determine that one or more renewal projects will be eliminated or that one or more renewal project’s funding requests will be reduced, the one-year funding amounts that these projects represented will still be counted as part of the hold harmless amount, which is used to calculate the CoC’s final pro rata need. The savings from the eliminations/reductions may be reallocated to create a new permanent housing project. Projects that are reduced should proportionally reduce the project scope and number of persons served when completing their Exhibit 2 submission. Important points to continue to keep in mind:

To qualify as an SHP renewal project, the contract must expire between January 1 and December 31, 2008;

Shelter Plus Care renewals do NOT count against a COC’s pro rata need;
While the elimination/reduction amounts are based on one year renewal funding, all new SHP projects must be submitted for either 2-3 year grant terms; and

If a SHP renewal is being eliminated, and that project originally received funding for acquisition, rehabilitation, and/or construction, the 20-year “term of commitment” requirement remains in effect as stipulated under the statute (Section 423.b) and the grantee must continue to operate the housing for homeless persons for the remainder of that term.
Under last year’s NOFA, a CoC risked losing the reallocated funds if the CoC did not score above the “full funding line” that made the CoC eligible for funding for any new projects (in 2006, that threshold was a score of above 86 points). This year, HUD has significantly changed the hold harmless requirements to provide greater flexibility to CoCs, and to facilitate a greater emphasis on permanent housing, by allowing a CoC to eliminate or reduce renewal SHP projects in order to fund new permanent housing projects with minimized risk to the CoC of losing any funding. More specifically:

This year, HUD will fund a new permanent housing project under the “hold harmless reallocation process” (even if it is a lower-rated project) as long as the overall Continuum of Care application score is at least 65 points.
This 65 point threshold is significantly below the 2006 full funding cut-off line of a score of above 86 points, so under these new provisions, a CoC could likely still receive funding for the new project using the reallocated funds even if the CoC’s application does not score enough points to qualify for other new projects or new funding (such as the funding made available under the Samaritan Housing Initiative).

Continuums that choose this reallocation option, must explain the process they used to make these determinations in Exhibit 1 under the Priorities/Reallocation section. In addition to the narrative, a Reallocation Chart is also part of the Exhibit.

Application Scoring Criteria:

There are no major changes to the criteria used to score applications this year.

The threshold of 65 points (described above in relation to the Hold Harmless Provisions) is also the determinant if CoCs will be asked to participate in the Annual Homeless Assessment Report (AHAR) that will begin being submitted to Congress annually starting this year. The information utilized to determine the 65 point threshold will be gathered through a CoC’s HMIS tracking.

The overall maximum score for Exhibit One of the CoC application is still 60 points, as follows:

Part I: CoC Organizational Structure (worth up to 8 points)
No changes from 2006.

Part II: CoC Housing and Service Needs (worth up to 12 points)
No changes from 2006.

Part III: CoC Strategic Planning (worth up to 10 points)
No changes from 2006.

Part IV: CoC Performance (worth up to 18 points)
Applicants must include some form of documentation, where requested, and identify a point of contact on their completed HUD Form 27300 (Questionnaire for HUD’s Removal of Regulatory Barriers.)

Part V: Emphasis on Housing Activities (worth up to 12 points)
As described in more detail above, if a CoC reallocates a portion of its pro rata need to an eligible new permanent housing project, the project will be funded, as long as it is in a CoC receiving at least 65 points. HUD made this change to make it easier for CoCs to choose to fund new permanent supportive housing units (i.e. the “hold harmless reallocation process”).

In addition to scoring of Exhibit One, HUD will review the priority project list submitted with the application, and will award up to 40 points for projects that fall within the final pro rata need range.

Additional Threshold and Scoring Guidance:

In the 2007 NOFA, HUD has articulated the project quality threshold requirements for all projects. HUD states that it will evaluate all projects to ensure that the housing and services are appropriate to the needs of the participants and community. Renewals are assumed to meet the threshold requirements unless otherwise notified. Page 11747 outlines the seven threshold criteria. HUD also emphasizes the importance of meeting timeliness standards in the NOFA (pages 11749-11750). The timeliness standards include requirements that projects:

Demonstrate site control for SHP grants within 1 year of the grant award and beginning construction within 18 months of grant award and completing activities within 36 months;

Begin all SHP activities that may proceed independent of construction within 12 months of the grant award; and

Ensure timely expenditure of SPC tenant-based, sponsor-based, and project-based assistance.

All applicants should be aware that many CoCs failed to receive the minimum of over 86 points (Exhibit One scoring and need points combined) required in 2006 to qualify for funding for new projects. On pages 11751 – 11754 of the NOFA, HUD provides guidance regarding the criteria used in awarding points under each of the scoring categories. More information regarding the scoring of 2006 applications will be made available via a national debriefing web cast scheduled for March 27, 2007 – see the web cast schedule below. Every CoC will also receive a written scoring breakdown of their application, but are not expected to be able to request an individualized debriefing with HUD. Many CoCs likely need to pay special attention to improving their scoring under CoC Performance (including accessing mainstream resources) and Emphasis on Housing Activities.

Logic Models and Return on Investment Statements:

A Logic Model is a required element of a Project Application. Last year, HUD instituted a standardized Logic Model format (or eLogic Model, form HUD 98010), a Microsoft Excel workbook containing instructions and incorporating program-specific master lists of: statements of need; service or activity/output(s) and their associated units of measure; and outcomes and their associated units of measure. This year, HUD has made changes to the Logic Model format, including: adding drop-down menus for HUD Strategic Goals and Policy Priorities; added tabs for Year 1, Year 2, and Year 3 activities, as well as a tab for Total; and included a new tab for reporting instructions. (See pages 2413 through 2415 of the General Section of the SuperNOFA for more details regarding Logic Models.) With the March 13, 2007 release of the program sections of the SuperNOFA, HUD corrects the instructions for the Logic Model form to clarify that all applicants must (not should) include all activities and outcomes expected per year of the performance period. (see page 2414 of General Section of SuperNOFA.)

Once conditionally selected applications advance to full award and execution of a grant agreement, grantees are required to submit an Annual Progress Report (APR) and a completed Logic Model showing outputs and outcomes achieved for the year to both HUD Headquarters and the respective Field Office each year. In addition, grantees must also respond to a standard set of management questions contained in the Logic Model form and included within the evaluation process. In addition, the SuperNOFA indicates that “For FY 2007, HUD is considering a new concept for the Logic Model. The new concept is a Return on Investment (ROI) statement. HUD will be publishing a separate notice on the ROI concept.”

As with the rest of the application forms, the Logic Model format for CoC Project Applications should be made available at on or before Monday, March19, 2007. In addition, HUD’s website links to the Carter-Richmond Methodology™ website for more information about the Logic Model, and a web cast regarding Logic Models will be held on March 20, 2007.

SuperNOFA Web Cast Schedule:

Logic Model Training: March 20th @ 1:30-4:00pm EST

Continuum of Care: March 27th @ 1:30-5:00pm EST (Note: This Web Cast will include the 2006 CoC competition debriefing)

Continuum of Care Follow-up: April 19th @ 2:00-3:30pm EST