Understanding the Continuum of Care Program: A Comprehensive Guide

The Continuum of Care (CoC) Program stands as a cornerstone initiative by the U.S. Department of Housing and Urban Development (HUD) to combat homelessness across the nation. Designed to be a community-wide effort, the CoC Program is not just about providing shelter; it’s a strategic framework aimed at creating lasting solutions for individuals and families experiencing homelessness. This article delves into the intricacies of the CoC Program, exploring its purpose, components, and how it empowers communities to address homelessness effectively.

What is the Continuum of Care Program?

At its core, What Is The Continuum Of Care Program? It’s a program designed to support communities in their efforts to end homelessness. More specifically, the CoC Program is structured to assist individuals and families, including unaccompanied youth, who are experiencing homelessness. The primary goal is to provide the necessary services and housing solutions to help them transition into transitional and ultimately permanent housing, fostering long-term stability and self-sufficiency.

Beyond direct assistance to individuals, the CoC Program takes a holistic approach to addressing homelessness. It emphasizes:

Community-wide Planning: Encouraging collaborative strategies at the local level to address homelessness comprehensively.
Strategic Resource Utilization: Promoting the efficient and targeted use of available resources to maximize impact.
Enhanced Coordination: Improving the integration of homelessness programs with mainstream resources and other relevant services to provide a seamless support system.
Data-Driven Approach: Focusing on better data collection and performance measurement to understand the scope of homelessness and evaluate program effectiveness.
Community Tailored Solutions: Empowering each community to customize its programs based on its unique strengths, challenges, and the specific needs of its homeless population.

In essence, the Continuum of Care Program is not a one-size-fits-all solution, but rather a flexible framework that enables communities to build and refine their local homelessness response systems.

Who Can Apply for CoC Program Funding?

To ensure responsible and effective use of funds, the CoC Program has specific eligibility criteria for applicant organizations. As outlined in the CoC Program interim rule, eligible applicants include:

Nonprofit Organizations: Community-based nonprofits with a mission to serve the homeless population.
State Governments: State-level agencies involved in housing and community development.
Local Governments: City, county, and other local governmental bodies.
Instrumentalities of State or Local Governments: Public housing authorities and other government-related entities.

It’s important to note that for-profit entities are not eligible to apply for CoC Program grants, either directly or as subrecipients of grant funds.

The funding process is competitive and annual. Organizations seeking CoC Program funds must apply through a designated Collaborative Applicant organization within their local Continuum of Care. Each CoC designates a single Collaborative Applicant, which is responsible for compiling and submitting the complete application package to HUD. This package includes the CoC application itself, along with individual project applications and their prioritized rankings determined at the local level. This competitive structure ensures that funding is directed towards the most effective and well-planned projects within each community.

Key Components of the CoC Program

The CoC Program is structured around five core program components, each designed to address different aspects of homelessness and provide a comprehensive range of assistance. These components, as defined in the CoC Program interim rule, are:

Permanent Housing (PH)
Transitional Housing (TH)
Supportive Services Only (SSO)
Homeless Management Information System (HMIS)
Homelessness Prevention (HP) (in specific cases)

These components are intentionally aligned with those of the Emergency Solutions Grants (ESG) program where feasible. This consistency streamlines administration for organizations that receive funding from both programs and ensures standardized reporting and data quality across similar project types. However, it’s crucial to recognize distinctions, particularly in the rapid re-housing component, which has unique eligible activities and administrative requirements under the CoC Program.

Let’s examine each of these components in detail:

1. Permanent Housing (PH)

Permanent Housing (PH) is designed to offer long-term housing solutions for individuals and families who have experienced homelessness. It’s defined as community-based housing without a set time limit on residency, where residents can live as independently as possible. Key features of Permanent Housing include:

Tenant Rights: Program participants must be the leaseholder (or sub-leaseholder) with an initial lease term of at least one year, renewable and terminable only for cause.
Lease Renewability: Leases must be renewable for a minimum term of one month thereafter, ensuring housing stability.

The CoC Program funds two primary types of Permanent Housing:

Permanent Supportive Housing (PSH): This model is specifically for individuals with disabilities and families with a disabled adult or child member. PSH combines permanent housing with ongoing supportive services. The aim is to help these individuals and families achieve and maintain housing stability alongside addressing their specific needs related to their disabilities. The rental assistance and leases in PSH are indefinite, providing long-term security.
Rapid Re-housing (RRH): Rapid Re-housing is designed to quickly move individuals and families experiencing homelessness – with or without disabilities – into permanent housing. RRH emphasizes housing search and relocation services, along with short- to medium-term rental assistance. The focus is on minimizing the time spent homeless and facilitating a swift transition to stable housing.

2. Transitional Housing (TH)

Transitional Housing (TH) serves as an intermediary step for individuals and families on their journey to permanent housing. TH projects provide temporary housing combined with supportive services, with the goal of equipping residents with the stability and resources needed to successfully move to and maintain permanent housing. Key aspects of Transitional Housing include:

Interim Stability: Offering a safe and supportive environment for up to 24 months.
Supportive Services: Providing services tailored to help residents overcome barriers to housing and employment, such as job training, counseling, and healthcare linkages.
Lease or Occupancy Agreement: Program participants must have a lease (or sublease) or occupancy agreement while residing in transitional housing, ensuring a degree of tenant rights and responsibilities.

Transitional housing is particularly valuable for individuals and families who may require more intensive support and time to prepare for independent living in permanent housing.

3. Supportive Services Only (SSO)

The Supportive Services Only (SSO) component of the CoC Program plays a vital role in system coordination and access. Funding under this component is primarily directed towards the entity designated by the CoC to lead its coordinated entry process.

Coordinated Entry is a HUD-mandated approach designed to streamline access to homelessness assistance resources within a community. It aims to:

Improve Efficiency: Optimize the local crisis response system for homelessness.
Enhance Accessibility: Make it easier for people experiencing homelessness to connect with available resources, including mainstream services.

SSO-Coordinated Entry (SSO-CE) grants can fund a range of supportive services directly related to carrying out coordinated entry activities. These services may include:

Outreach: Actively reaching out to sheltered and unsheltered homeless individuals and families.
Initial Assessment: Conducting assessments to understand the needs and circumstances of individuals seeking assistance.
Crisis Counseling: Providing immediate support and counseling in crisis situations.
Addressing Urgent Needs: Meeting basic physical needs, such as food, clothing, and hygiene.
Housing and Resource Connection: Connecting individuals and families with appropriate housing options and other supportive services.

While general SSO grants are no longer available to entities that are not the Coordinated Entry Lead Agency, recipients and subrecipients can still receive supportive service funds to provide assistance to homeless individuals and families who are not residing in their housing facilities. These services can be delivered in centralized locations, scattered sites, or even through street outreach, offering flexibility in service delivery models.

4. Homeless Management Information System (HMIS)

The Homeless Management Information System (HMIS) component is critical for data collection and program management within a CoC. Funds under this component are exclusively for HMIS Lead Agencies, which are designated by each CoC to operate the local HMIS.

The HMIS is a vital tool for:

Data Collection: Collecting standardized data on homelessness in the community, including demographics, service utilization, and housing outcomes.
Performance Measurement: Tracking program performance and identifying areas for improvement.
System Planning: Providing data to inform community-wide planning and resource allocation efforts.

HMIS funds can be used for various purposes related to operating the HMIS, such as:

Leasing and Operating HMIS Facilities: Covering costs associated with physical spaces where HMIS operations are housed.
HMIS Establishment and Operation: Funding the setup, maintenance, and ongoing operation of the HMIS.
HMIS Customization: Tailoring the HMIS to meet the specific needs of the CoC.

While other recipients and subrecipients cannot directly apply for HMIS component funds, they can include HMIS-related costs within their projects under other components (PH, TH, SSO, or HP). This ensures that all funded projects contribute to the CoC’s data collection efforts through the HMIS.

5. Homelessness Prevention (HP)

The Homelessness Prevention (HP) component is a proactive approach to addressing homelessness by intervening before it occurs. Currently, CoC Program funds for homelessness prevention are specifically targeted towards recipients and subrecipients located in HUD-designated High Performing Communities (HPCs). The annual CoC Program Notice of Funding Opportunity (NOFO) provides details on how CoCs can apply for HPC designation.

Homelessness prevention services aim to help individuals and families at risk of homelessness maintain their current housing or transition to new permanent housing. Eligible services under this component include:

Housing Relocation and Stabilization Services: Assistance with moving costs, housing search, and ensuring housing stability.
Short- and Medium-Term Rental Assistance: Temporary rental subsidies to prevent eviction and housing loss.

Homelessness prevention activities must be administered in accordance with 24 CFR part 576, ensuring compliance with relevant regulations and guidelines.

Components No Longer Eligible for New Projects

It’s important to note that some program components, while historically part of homelessness assistance efforts, are no longer eligible for new funding under the CoC Program. However, existing projects under these components may be eligible for renewal. These components include:

Safe Havens: Safe Havens were designed to provide housing and services to individuals with severe mental illness who were living on the streets and resistant to traditional shelter or services. While new Safe Haven projects are not funded, existing ones can be renewed.
Section 8 Moderate Rehabilitation SRO (Single Room Occupancy): This program provided rental assistance for single room occupancy units that were moderately rehabilitated. New SRO projects are no longer funded, but existing projects continue to be renewed under separate legislation (Multifamily Assisted Housing Reform and Affordability Act of 1997).

Understanding Eligible Costs

The CoC Program interim rule clearly defines the types of costs that are eligible for funding under each program component. It’s crucial for applicants and recipients to understand these eligible costs to ensure proper utilization of grant funds. Not all costs are eligible under every component, and certain cost combinations within a single unit or structure may be restricted. However, costs related to contributing data to the CoC’s HMIS are eligible across all components.

Here’s a summary of the key eligible cost categories:

Acquisition: Funds can be used to purchase real property for Permanent Housing, Transitional Housing, and Supportive Services Only projects. Grants can cover up to 100% of acquisition costs.
Rehabilitation: Rehabilitation of existing structures is eligible for PH, TH, and SSO projects. This includes costs for energy-saving measures and bringing properties up to health and safety standards. Rehabilitation of leased properties is not eligible.
New Construction: New construction is eligible under PH and TH components, including building new facilities or significant additions. Projects must demonstrate that new construction is more cost-effective than rehabilitation. Similar to acquisition, grants can cover up to 100% of new construction costs, provided match requirements are met. New construction on leased properties is not allowed.
Leasing Costs: Leasing of individual units or entire structures is eligible for PH, TH, SSO, and HMIS projects. Rents must be reasonable and within HUD Fair Market Rent limits. Leasing from related parties (recipient, subrecipient, parent organizations, etc.) is generally prohibited without HUD authorization. Leases are typically between the recipient/subrecipient and the landowner, with a sublease or occupancy agreement for the program participant.
Rental Assistance Costs: Rental assistance is a core component of PH and TH projects. It can be tenant-based (TBRA), sponsor-based (SBRA), or project-based (PBRA), depending on the component type. Rental assistance can be short-term (up to 3 months), medium-term (3-24 months), or long-term (over 24 months).
- Tenant-Based Rental Assistance (TBRA): Participants can choose housing units anywhere within the CoC’s area.
- Sponsor-Based Rental Assistance (SBRA): Housing is provided in properties owned or leased by a sponsor organization.
- Project-Based Rental Assistance (PBRA): Rental assistance is tied to specific units in a project, and participants must reside in those units.
Supportive Services Costs: Supportive services are eligible costs under PH, TH, and SSO components. The CoC Program interim rule provides a comprehensive list of eligible services, and any service not listed is ineligible. Services must be offered throughout the residency period in PSH and TH. RRH programs require at least monthly case management. Services can continue for up to six months after a participant exits homelessness, including after leaving transitional housing.
Operating Costs: Operating costs are eligible for PH, TH, and HMIS projects. These cover day-to-day expenses for facilities or housing units, such as maintenance, repairs, security (if CoC funds cover over 50% of the facility), utilities, furniture, insurance, and taxes. Operating costs cannot be combined with rental assistance within the same unit or structure and are not eligible under the SSO component.
HMIS Costs: Costs related to contributing client data to or maintaining data in the CoC’s HMIS are eligible across all components (PH, TH, SSO, HMIS). This includes hardware, software, training, staffing, and overhead related to HMIS participation.
Project Administration: Recipients and subrecipients can use up to 10% of their grant (excluding CoC planning and UFA costs) for project administration. This covers costs related to grant management, coordination, monitoring, evaluation, and environmental review.
CoC Planning Costs: CoC Planning funds are exclusively for the Collaborative Applicant and are awarded through a separate CoC Planning grant. These funds support activities such as community planning, coordinated entry design (not implementation), outcome evaluation, application preparation, and recipient monitoring.
Unified Funding Agency (UFA) Costs: UFA costs are available only to Collaborative Applicants designated as UFAs by HUD. These funds support costs associated with ensuring sound financial management and compliance within the CoC program, including audits and financial reviews of subrecipient projects.

Conclusion

The Continuum of Care Program is a vital resource for communities striving to end homelessness. By understanding what is the continuum of care program, its structure, components, and eligible costs, organizations and communities can effectively leverage this program to create meaningful and lasting solutions for individuals and families experiencing homelessness. The CoC Program’s emphasis on community-driven strategies, data-informed decision-making, and a comprehensive range of housing and services makes it a powerful tool in the ongoing effort to ensure that everyone has a safe and stable place to call home.