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.

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.

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

CoC Membership

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

Examples of CoC Membership

Nonprofit homeless Assistance providersVictim Service Providers Mental Health AgenciesFaith Based Organizations HospitalsGovernments UniversitiesBusinesses Affordable Housing DevelopersAdvocates Law EnforcementPublic Housing Agencies Organizations that serveSchool Districts homeless veteransSocial Service providers Formerly homeless persons

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)

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

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

ESG Annual Action Plan

Consultation with Continuums of Care The rule requires ESG recipients to consult with Continuums of Care in:1. Allocating funds for eligible activities2. Developing performance standards3. Evaluating outcomes of ESG-assisted projects and developing

funding4. 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.

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.

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:

ESG Annual Action Plan

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.

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

ESG CAPER

Notice CPD-13-06: Guidance for Submitting the Portions of the Consolidated Annual Performance and Evaluation Report (CAPER) Related to Homelessness and the Emergency Solutions Grants (ESG) Program

This notice provides guidance for completing the Emergency Solutions Grants (ESG) portions of the Consolidated Annual Performance and Evaluation Report (CAPER) using the Integrated Disbursement and Information System (IDIS). This notice also provides information on completing homelessness-related portions of the CAPER, which is relevant for all States, local governments, and territories that receive ESG, Community Development Block Grants (CDBG), HOME Investment Partnerships (HOME), and/or Housing Opportunities for Persons With AIDS (HOPWA) formula funding (referred to collectively in this notice as Consolidated Plan (Con Plan) jurisdictions).

Date Published: August 2013

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.

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.

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

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)

CoC Planning

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

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.

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)

Eligible Activities

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

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

Eligible Costs – Program Components

Permanent Housing TH SSO HMIS

Eligible Costs PH:PHS PH:RRH

Acquisition

Rehabilitation

New Construction

Leasing

Rental Assistance

SS

Operating

HMIS

Project Administration

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.

Resources

• https:www.onecpd.info/coc- CoC Program Interim Final Rule- Establishing and Operating a CoC Guide- CoC Governance Crosswalk of Changes: CoC Program, SHP,

and S+C 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