Appendix A clean 4.12.23.docx

Appendix A: Project Selection Process This Appendix establishes the funding criteria for projects under the Youth Homelessness Demonstration Program (YHDP). HUD is making available approximately $60 million in Fiscal Year (FY) 2022 funds to demonstrate how a coordinated community approach to serving homeless youth, age 24 and younger, can dramatically reduce homelessness.

Overview A. Program Description. As discussed in further detail in the full text of the YHDP NOFO, the YHDP was funded by Congress to implement projects that demonstrate how a comprehensive approach to serving homeless youth, age 24 and younger, can dramatically reduce homelessness. This includes a variety of approaches, eligible activities and types of projects. This Appendix provides information to Project Applicants in selected communities about how they can apply for projects to support their community’s Coordinated Community Plan (CCP) (as described in Section III.F.b. of the YHDP NOFO).

While this Appendix is the primary source of information for Project Applicants, Project Applicants should read the full YHDP NOFO in its entirety in conjunction with the Continuum of Care (CoC) Program interim rule (24 CFR part 578). All projects awarded through the YHDP must be administered in accordance with CoC Program requirements, except as otherwise provided in the YHDP NOFO including section I.A., this appendix, or as specifically authorized by HUD waiver. However, HUD will not waive any regulations pertaining to fair housing, civil rights, or environmental requirements. HUD strongly encourages Project Applicants to review Notices and HUD guidance provided in relation to the CoC Program.

B. Overview of Application Process.

1. Community Selection Process. To be awarded projects under the YHDP, the community must have been selected by HUD to participate in the YHDP. See the main text of the YHDP NOFO for more information about how to apply to be a selected community.

2. Project Selection Process. All project applications must be submitted through e-snaps following the process outlined in this Appendix.

C. Highlights.

1. Program Flexibility. YHDP projects may choose to take advantage of the special YHDP activities and other options listed at I.C.1. The following options would not meet CoC program requirements but may be used to carry out YHDP projects. As authorized by the FY 2022 Appropriations Act, projects that use these options (and other YHDP projects) can be renewed with available FY 2022 or prior FY funding for the CoC program. If similar authorization appears in future acts, projects that use these options (and other YHDP projects) could also be renewed with CoC program funding provided under those acts. As stated in I.C.9 of this Appendix, however, HUD will not renew any planning projects.

a. The following YHDP activities may be exercised by YHDP recipients with notice to the Deputy Assistant Secretary for Special Needs, subject to requirements governing grant agreement amendments at 24 CFR 578.105:

(1) YHDP housing projects may have leases for a minimum term of 1 month under rental assistance budget line items.

(2) YHDP recipients may use leasing, sponsor-based rental assistance, and project-based rental assistance in Rapid Rehousing projects.

(3) Up to 10 percent of the total YHDP funding made available to the community may be used for planning grants. As outlined in I.C.9 of this Appendix, planning grants are nonrenewable.

(4) YHDP planning grants and administrative funds may be used for capacity building activities for Youth Action Board members or recipient staff who are also youth with lived experience.

(5) In addition to the eligible costs listed in 24 CFR 578.59(a), YHDP recipients may use project administrative funds to support costs associated with involving youth with lived experience in project implementation, execution, and improvement.

(6) Recipients of YHDP funds can use project administrative funds to attend conferences and trainings that are not HUD-sponsored or HUD-approved, provided that the subject matter is relevant to youth homelessness.

(7) YHDP recipients may employ youth who are receiving services, including housing, from the recipient organization. Recipients that utilize this special YHDP activity must maintain documentation that discloses the nature of work that the youth does, and that the youth is not in a position that creates a conflict of interest.

(8) YHDP recipients may use habitability standards in 24 CFR 576.403(c) rather than Housing Quality Standards in 24 CFR 578.75 for short or medium term (up to 24 months) housing assistance. Recipients implementing this special YHDP activity must keep documentation of which standards are applied to the units and proof that the units complied with the standards before assistance is provided for every unit funded by YHDP.

(9) YHDP recipients may provide moving expenses more than one time to a program participant.

(10) YHDP recipients may provide payments of up to $500 per month for families that provide housing under a host home and kinship care model in order to offset the increased costs associated with having youth housed in the unit.

(11) YHDP recipients may continue providing supportive services to program participants for up to 12 months after the program participant exits homelessness, transitional housing or after the end of housing assistance.

(12) YHDP grant funds may be used for the following if they are necessary to assist program participants to obtain and maintain housing. Recipients and subrecipients must maintain records establishing how it was determined paying the costs was necessary for the program participant to obtain and retain housing and must also conduct an annual assessment of the needs of the program participants and adjust costs accordingly.

(a) Security deposits for units in an amount not to exceed 2 months of rent;

(b) The costs to pay for any damage to housing due to the action of a program participant, which may be paid while the youth continues to reside in the unit. The total costs paid for damage per program participant may not exceed the cost of two-months’ rent.

(c) The costs of providing household cleaning supplies to clients.

(d) Housing start-up expenses for program participants, including furniture, pots and pans, linens, toiletries, and other household goods, not to exceed $300 in value per program participant.

(e) The one-time cost of purchasing a cellular phone and service for program participant use, if necessary for the participant to obtain or maintain housing

(f) The cost of internet in a program participant’s unit.

(g) Payment of rental arrears consisting of a one-time payment for up to 6 months of rent in arrears, including any late fees on those arrears.

(h) Payment of utility arrears of up to 6 months per service.

(i) Up to three months of utilities for a program participant, based on the utility costs schedule for the unit size and location.

(j) In addition to transportation costs eligible in 24 CFR 578.53(e)(15), a recipient may pay gas and mileage costs for a program participant’s personal vehicle for trips to and from medical care, employment, childcare, or other services eligible under 24 CFR 578.53(e).

(k) Legal fees, including court fees, bail bonds, and required courses and equipment.

(l) Program participant’s past driving fines and fees that are blocking a young person from being able to obtain or renew a driver’s license and impacting their ability to obtain or maintain housing. Additionally, recipients may pay for program participants’ costs for insurance and registration for personal vehicles if the personal vehicle is necessary to reach medical care, employment, childcare, or other services eligible under this section.

b. Under the conditions specified below, YHDP recipients may make use of the following built-in exceptions to this NOFO’s requirements, subject to approval by the Deputy Assistant Secretary for Special Needs and requirements governing grant agreement amendments at 24 CFR 578.105:

(1) A recipient may provide up to 36 months of Rapid Rehousing rental assistance to a program participant if the recipient describes (1) the method it will use to determine which youth need rental assistance beyond 24 months and (2) the services and resources that will be offered to ensure youth are able to sustain their housing at the end of the 36 months of assistance.

(2) Recipients may continue providing supportive services to program participants for up to 24 months after the program participant exits homelessness, transitional housing or after the end of housing assistance if the recipient describes: 1) the proposed length of extended services to be provided; 2) the method it will use to determine whether services are still necessary; and 3) how those services will result in self-sufficiency and ensure stable housing for the YHDP program participant.

Recipients may continue providing supportive services to program participants for up to 36 months after the program participant exits homelessness, if the services are in connection with housing assistance, such as the Foster Youth to Independence initiative, or if the recipient can demonstrate that extended supportive services ensures continuity of case workers for program participants.

(3) Recipients will not be required to meet the 25% match requirement provided for in III.C of the YHDP NOFO and 24 CFR 578.73 if the recipient is able to identify multiple non-YHDP resources in the community that assist youth experiencing homelessness and can provide a narrative description of 1) how the resources will assist youth who are clients under the YHDP project and 2) how the recipient will facilitate connections to these resources to ensure that youth are aware of them and able to access the resources.

(4) Recipients will not be required to meet the 25% match requirement provided for in III.C of the YHDP NOFO and 24 CFR 578.73 if the recipient does not have other currently active CoC or YHDP grants. If permitted by future Appropriations Acts, HUD will continue the match exemption for the YHDP grant funded under this NOFO under the first and second renewal or replacement of the project under the Continuum of Care competition.

(5) Rental assistance may be combined with leasing or operating funds in the same unit, provided that the recipient submits a project plan that includes safeguards to ensure that no unit receives a double-subsidy, defined as rent in excess of the pro-rata reasonable rent for the unit.

(6) YHDP recipients may provide payments of up to $1000 per month for families that provide housing under a host home and kinship care model, provided that the recipient can show that the additional cost is necessary to recruit hosts to the program.

(7) YHDP recipients may pay for short-term (up to three months) emergency lodging in motels or shelters as the transitional housing component in a Joint transitional housing-rapid rehousing (TH-RRH) project, provided that the recipient can demonstrate that use of the hotel or motel room is accessible to supportive services.

(8) In addition to the specific activities authorized above or in 24 CFR part 578, other innovative activities to reduce youth homelessness may be carried out using YHDP funds, provided that the recipient can demonstrate that the activity meets the following criteria:

a) The activity is supported by both the Youth Action Board and the Continuum of Care, as evidenced by letters of support from each organization;

b) The activity will be testing or likely to achieve a positive outcome in at least one of the four core outcomes for youth experiencing homelessness (stable housing, permanent connections, education/employment, and well-being);[footnoteRef:2] [2: https://www.usich.gov/resources/uploads/asset_library/USICH_Youth_Framework__FINAL_02_13_131.pdf]

c) The activity is cost effective; and

d) The activity is not in conflict with fair housing, civil rights, or environmental regulations.

YHDP recipients may carry out the YHDP activities listed in I.C.1.a upon notice to the Deputy Assistant Secretary for Special Needs, unless a grant amendment is required by 24 CFR 578.105. If a grant amendment is required, the recipient cannot carry out the activities listed in I.C.1.a until it has provided notice to HUD and HUD has signed a grant amendment. Project Applicants can submit notices to HUD with their project applications, and project applicants (or recipients) can also submit notices to HUD after projects are approved.

In order to receive any of the exceptions listed in I.C.1.b, Project Applicants must submit a request to the Deputy Assistant Secretary for Special Needs at the time of or prior to the project application submission. Project Applicants (or recipients) may also request any of the exceptions listed in I.C.1.b after projects are approved, however, the recipient cannot make use of the exception until notified that HUD has received and approved the request. In addition to HUD approval, if a grant amendment is required by 24 CFR 578.105, the recipient cannot make use of any requested exceptions until HUD has signed the grant amendment.

Notices and requests for exceptions should be emailed to the Deputy Assistant Secretary for Special Needs at youthdemo@hud.gov and, if made prior to or at the time of project application submission, the request should also be attached to the project application. Project applicants can obtain a copy of the McKinney Vento Homeless Assistance Act (“the Act”) and 24 CFR part 578 on HUD.gov.

2. Coordinated Community Plan. HUD’s central requirement of the YHDP is that each selected community will develop a community plan to prevent and end youth homelessness. More information is provided in Appendix B of the YHDP NOFO on the community plan; however, for purposes of the project application, it is required that all projects submitted are consistent with the community plan.

3. CoC Involvement. In addition to the involvement described in the full text of the YHDP NOFO, as it relates particularly to the project applications, HUD requires each CoC to implement a thorough review and oversight process at the local level for project applications submitted to HUD as part of the YHDP for projects proposed in their geographic area. Youth receiving services or assistance, either previously or currently, from one or more YHDP project applicants may participate in YHDP project selection. HUD requires Collaborative Applicants or its designee to closely review information provided in each project application to ensure that:

a. All proposed program participants will be eligible for the program component type selected;

b. The proposed activities are eligible under 24 CFR part 578, except as otherwise stated in this Appendix;

c. All proposed activities meet the criteria stated in II and III of this Appendix;

d. Each project narrative is fully responsive to the question being asked and that it meets all the criteria for that question as required by the YHDP NOFO;

e. The data provided in various parts of the project application are consistent and accurate; and

f. All required attachments correspond to the attachments list in this Appendix, and the attachments contain accurate and complete information.

4. Youth Action Board Approval. It is important to HUD that youth, including homeless and formerly homeless youth, are involved in every step of the implementation of the YHDP at the local level, and it is for this reason that HUD is requiring selected communities to have a Youth Action Board. For purposes of the project applications, HUD requires that the Youth Action Board have an opportunity to review all project applications thoroughly and that any input the Board provides will be implemented to the extent that it is feasible within statutory and regulatory guidelines. Youth receiving services or assistance, either previously or currently, from one or more YHDP project applicants may participate in YHDP project selection. Additionally, HUD requires that the Youth Action Board submit a letter of support for all projects submitted to HUD for review and consideration.

5. Serving Households Who Are Homeless Under Other Federal Laws. Project Applicants may request that up to 10 percent of the funding awarded to their selected community under this demonstration be approved to serve youth who do not meet paragraph 1 or 2 of the homeless definition at 24 CFR 578.3, do not qualify as homeless under section 103(b) of the McKinney-Vento Homeless Assistance Act, and are not living in unsafe situations, but are homeless under another Federal statute in paragraph 3 of the definition of homeless at 24 CFR 578.3. The decision to request to serve this population must be reflected and supported in the CCP and must show that the grant funds to serve such persons is an equal or greater priority than serving persons defined as homeless under paragraphs 1 or 2 of the homeless definition at 24 CFR 578.3, section 103(b) of the McKinney-Vento Act or are living in unsafe situations.

6. Serving Households Who Lack 3rd Party Documentation or Live in Unsafe Situations. Youth aged 24 and under must not be required to provide third-party documentation that they meet the homeless definition in 24 CFR 578.3 or section 103(b) of the McKinney-Vento Homeless Assistance Act as a condition for receiving services funded under the YHDP NOFO. Additionally, any youth-serving provider funded under the YHDP NOFO may serve unaccompanied youth aged 24 and under and families headed by youth aged 24 and under who are living in unsafe situations. HUD interprets “youth-serving provider” as a private nonprofit organization whose primary mission is to provide services to youth aged 24 and under and families headed by youth aged 24 and under. HUD interprets “living in unsafe situations” as having an unsafe primary nighttime residence and no safe alternative to that residence. These requirements supersede any conflicting requirements under the YHDP NOFO, this appendix, the Act, or the CoC Program rule.

7. Project Types. Project Applicants can apply for all projects permitted under the CoC Program so long as the projects meet the threshold criteria in III of this Appendix.

8. Project geography: Planning grants may be used for planning activities, including developing the CCP, that extend to the entire geographic area of the CoC, even if the selected YHDP community does not cover the entire geographic area of the CoC. For all other projects funded by YHDP, funding must only be used to serve youth and young adults experiencing homelessness in the geographic area identified in the YHDP application.

9. Grant terms. Projects awarded under YHDP will have an initial term of 24-30 months unless extended. All grants besides planning may be renewed for a 1-year grant term under the CoC program as outlined in section I.C. of this Appendix.

10. Fair Market Rent (FMR). Funds awarded for rental assistance will be awarded using the most recent FMRs published by HUD at the time of each award.

11. Resubmitting Previously Rejected Projects. There is nothing in this Appendix that prohibits a Project Applicant from resubmitting a project application that has been previously rejected or not funded by HUD in the YHDP competition. However, the Project Applicant should carefully review the reasons that HUD rejected the project and make necessary revisions to ensure that the project passes the quality and threshold review, including that the project meets all requirements laid out in this appendix and the YHDP NOFO. Applicants must submit all project applications, including resubmitted project applications, by the application deadline (see Section VI.A. of this Appendix).

D. Definitions and Concepts. The definitions contained in this section include terms that are important for all Project Applicants to understand in order to complete all parts of the Project Application in e-snaps.

1. Definitions from 24 CFR 578.3

a. Centralized or coordinated assessment system

b. Collaborative applicant

c. Continuum of Care

d. Eligible applicant

e. Homeless

f. Homeless Management Information System (HMIS)

g. Permanent Housing

h. Permanent Supportive Housing (PSH)

i. Private Nonprofit Organization

j. Recipient

k. Subrecipient

l. Transitional Housing

m. Unified Funding Agency (UFA)

2. YHDP Project Selection Process Definitions. The following terms are not found in 24 CFR part 578 but are used in this YHDP NOFO and Appendix to define concepts that specifically apply to the project selection process for the YHDP.

a. Capacity building activities. Capacity building activities are activities that maintain or improve the skills of youth involved in youth homelessness planning or project implementation. Eligible capacity building activities for youth include employee education, job training, staff retention activities such as financial incentives to staff, paying for continuing education opportunities, cross training within an organization, staff training and professional licensing or certification, and other professional development activities.

b. Coordinated community plan. The plan developed by a selected community includes the components outlined in Appendix B and addresses the issues identified in Section III.F.b. of the YHDP NOFO.

c. Host Home and Kinship Care. A model in which a family agrees to permit a youth to reside with them. Recognizing that the addition of another person in the home may increase costs to the family, HUD will entertain applications that propose to house youth with families and to subsidize the additional costs attributable to housing the youth, including recruitment of hosts. The residence is in a community-based setting. The family could be related to the youth and the length of stay may be time-limited or without time limits.

d. Housing First. A model of housing assistance that prioritizes rapid placement and stabilization in permanent housing that does not have service participation requirements or preconditions (such as sobriety or a minimum income threshold). Transitional housing and supportive service only projects can be considered to be using a Housing First model for the purposes of this NOFO if they operate with low-barriers, work to quickly move people into permanent housing, do not require participation in supportive services, and, for transitional housing projects, do not require any preconditions for moving into the transitional housing (e.g., sobriety or minimum income threshold).

e. Joint TH and PH-RRH Component Project. The Joint TH and PH-RRH component project combines two existing program components–transitional housing and permanent housing-rapid rehousing–in a single project to serve individuals and families experiencing homelessness.

f. Positive Youth Development (PYD) Model. Defined by the Federal Interagency Working Group on Youth Programs as an intentional, pro-social approach that engages youth in a manner that is productive and constructive; recognizes, utilizes, and enhances youths’ strengths; and promotes positive outcomes for young people by providing opportunities, fostering positive relationships and furnishing the support needed to build on their leadership strengths. PYD programs are generally focused on the following six youth outcomes: Confidence; Character; Connection; Competence; Caring; and Contribution. See the page entitled “Positive Youth Development” at: http://youth.gov/youth-topics/positive-youth-development.

g. Program Participant. A person assisted under a YHDP project.

h. Project. A group of eligible activities, identified as a project in an application to HUD for YHDP funds and includes a structure (or structures) that is (are) acquired, rehabilitated, constructed, or leased with assistance provided under this part or with respect to which HUD provides rental assistance or annual payments for operating costs, or supportive services.

i. Selected Community. A community that is selected by HUD to participate in the YHDP.

j. Shared Housing. A model of housing assistance where rental assistance is provided for a youth to reside with a family or another unrelated person. The youth leases from the property owner and shares the unit with the family or unrelated person. The unit may be a house or an apartment.

· YHDP rental assistance cannot be provided to a youth to reside in a unit occupied by an immediate family member. For this Demonstration “immediate family member” is defined to mean parents, grandparents, and legal guardians.

· YHDP rental assistance cannot be provided to a youth in a shared housing unit if the landlord is an immediate family member of the youth.

· YHDP rental assistance may only be provided to a youth if the youth can enter into a valid, binding, and enforceable lease under applicable state or local law. This includes a legally appointed guardian executing a lease on behalf of a youth or an emancipated youth entering into a lease.

k. Trauma Informed Care (TIC) Model. An approach that recognizes the widespread impact of trauma and understands potential paths for recovery, recognizes the signs and symptoms of trauma in clients, families, staff, and others involved with the system, responds by fully integrating knowledge about trauma into policies, procedures, and practices and seeks to actively resist re-traumatization. TIC models generally include a focus on the following: Safety; Trustworthiness and Transparency; Peer Support; Collaboration and Mutuality; Empowerment; Voice and Choice; and Cultural, Historical, and Gender Issues.

Eligibility Information A. Eligible Applicants. Eligible Applicants for YHDP project funding (Project Applicants) are outlined in section III.A of the YHDP NOFO. To be considered for funding, Project Applicants must complete the information required by HUD, receive the approval of the YAB for their project(s) through a letter of support, and receive the approval of the CoC to apply for funding, as indicated by a letter of support from the Collaborative Applicant or its designee.

All subrecipients must also meet the eligibility standards for Eligible Applicants in section III.A. of the YHDP NOFO. HUD will review project subrecipient eligibility as part of the threshold review process. Project Applicants are required to submit documentation of their subrecipients’ eligibility with the application.

Collaborative Applicants that are not UFAs may designate an Eligible Applicant to apply for and be the recipient of a planning grant. UFAs must apply for and be the recipient of all grants for their Community.

For a dedicated HMIS grant, the application must either be from the UFA (when there is a UFA for the Community) or the HMIS Lead (when there is no UFA for the Community) that will be the grant recipient.

B. Matching. Provisions at 24 CFR 578.73 apply to grants unless the recipient receives approval for build-in exception outlined at I.C.1.b.3 or I.C.1.b.4 of Appendix A.

C. Program Income. The recipient may choose to use program income as a source of matching funds. If program income is used as a source of matching funds, the project applicant must describe this in the project application.

D. Indirect Costs. Normal indirect cost rules under 2 CFR part 200 apply. Project applicants that intend to charge indirect costs to the award must clearly state in the project application(s) the rate and distribution base the recipient intends to use, and if applicable, the rate and distribution base to be used by any sub-recipient(s). If the rate is a Federally negotiated indirect cost rate, the project application must include the corresponding negotiated indirect cost rate agreement signed by the cognizant agency. A government department or agency unit that receives no more than $35 million in direct federal funding per year and has developed and maintains an indirect cost rate proposal and supporting documentation in accordance with 2 CFR part 200, appendix VII, may use the rate and distribution base specified in that indirect cost rate proposal, unless the cognizant agency requires the proposal to be submitted for negotiation.

For each applicant or intended sub-recipient that meets the conditions for the de minimis rate under 2 CFR 200.414(f) and will use that rate to charge indirect costs, the project application must clearly state the intended use of the de minimis rate of 10 percent of Modified Total Direct Costs (MTDC). As described in 2 CFR 200.403, costs must be consistently charged as either indirect or direct costs but may not be double charged or inconsistently charged as both. Once an organization elects to use the de minimis rate, the organization must apply this methodology consistently for all Federal awards until the organization chooses to negotiate for a rate, which the organization may apply to do at any time. Documentation of the decision to use the de minimis rate must be retained on file for audit.

E. Other Project Eligibility Requirements

1. Grant Terms. All grants for projects will be for an initial 2-year grant term unless the applicant requests an initial grant term of up to 30-month. The grant term may be extended consistent with 2 CFR 200.308 and 2 CFR 200.309.

2. Eligible Program Participants and 3rd Party Documentation of Eligibility.

Funds awarded under the YHDP must only be used to serve:

a. Youth, as defined in I.A.4 of the NOFO, who initially qualify as homeless under paragraph (1) or (2) of the homeless definition in 24 CFR 578.3 or section 103(b) of the McKinney-Vento Homeless Assistance Act, or

b. Youth who initially qualify to be served as stated in I.C.5 of this Appendix.

Notwithstanding the above, youth-serving providers (defined in I.C.6 of Appendix A) funded under this NOFO may serve unaccompanied youth (defined in I.A.4 of the NOFO) who are living in unsafe situations or families headed by youth who are living in unsafe situations (defined in I.C.6 of Appendix A).

As explained in I.C.6 of this Appendix, youth aged 24 and under must not be required to provide third-party documentation that they meet the homeless definition in 24 CFR 578.3 or section 103(b) of the McKinney-Vento Homeless Assistance Act as a condition for receiving services funded under the YHDP NOFO.

3. Eligible Components and Costs. Since the purpose of the YHDP is to demonstrate how a comprehensive approach to serving homeless youth can dramatically reduce homelessness, HUD will also allow selected communities to apply for projects that are not eligible through the CoC Program Competition in order to implement their CCP to prevent and end youth homelessness consistent with the requirements in I.C.1 of this Appendix or as specifically authorized by HUD waiver. The project application must demonstrate to HUD’s satisfaction why the program design should be tested. All projects funded under YHDP are subject to requirements outlined in section I of this Appendix, including the requirement in I.C.1 for projects taking advantage of the special YHDP activities and other options listed there.

In addition to grants for Planning projects, Project Applicants may apply for the following new projects:

a. Eligible costs listed in 24 CFR 578.43 through 578.63 when used to establish and operate projects under the following program components established at 24 CFR 578.37:

(1) Permanent housing, including PSH and RRH

(2) Transitional housing, including Crisis Residential transitional housing

(3) HMIS

(4) Supportive Service Only (SSO), including, but not limited to, projects dedicated to coordinated entry, housing search and placement services, case management, drop-in centers, legal services, or street outreach;

In addition to funding projects that use these components, Collaborative Applicants may apply for Joint TH and PH-RRH component projects.

b. Projects or activities that are fundable under the Demonstration include:

(1) Host Homes and Kinship care. YHDP funds may be used to subsidize the increased costs to the family that are attributable to housing the youth. An example of eligible costs would be additional food or transportation costs, which are eligible supportive services under 24 CFR 578.53(e)(7) or 24 CFR 578.53(e)(15). The project application must describe how the costs will be determined by the project applicant.

(2) Shared housing. YHDP funds may be used to provide rental assistance for a youth to reside with a family or another unrelated person. All CoC requirements that apply to rental assistance would apply to rental assistance provided in shared housing. These requirements include the following:

i. There must be a rental assistance agreement between the recipient or the subrecipient and the owner;

ii. The housing meets CoC housing quality standards, or habitability standards if permitted under I.C.1.a.7 of this appendix;

iii. The rental assistance is provided in accordance with applicable written standards;

iv. Rental assistance is not provided to a program participant who is receiving project-based rental assistance or operating assistance, through other public sources; and

v. The shared housing must meet the rent reasonableness standards.

FMR will be adjusted to the youth’s pro-rata share of the FMR for the shared housing unit size. For example, in the case of a single youth who will occupy one bedroom in a 4-bedroom house, the FMR used would be the youth’s pro-rata share of the 4-bedroom FMR (i.e. ¼ of the 4-bedroom FMR).

4. Environmental Requirements. Notwithstanding provisions at 24 CFR 578.31 and 24 CFR 578.99(a) of the CoC Program interim rule, and in accordance with Section 100261(3) of MAP-21 (Pub. L. 112-141, 126 Stat. 405), activities under the YHPD NOFO are subject to environmental review by a responsible entity under HUD regulations at 24 CFR part 58.

a. Additionally, HUD has clarified two requirements for projects categorized as Categorically Excluded from review under the National Environmental Policy Act and not subject to the laws and authorities at 58.5 (CENST):

i. All scattered-site projects, where participants choose their own unit and are not restricted to units within a pre-determined specific project site or sites, are categorized in 24 CFR 58.35(b)(1) as CENST. This includes both tenant-based rental assistance and scattered-site leasing projects where the program participant chooses their unit.

ii. An exempt or CENST environmental review is only required for each project, not each unit.

b. For activities under a grant to a Project Grant Recipient other than a responsible entity (a State, Tribe, or unit of general local government) that generally would be subject to review under part 58, HUD may reject the use of a responsible entity to conduct the environmental review on the basis of performance, timing, or compatibility with objectives in accordance with 24 CFR 58.11 and perform the environmental review under the provisions of 24 CFR part 50.

c. Irrespective of whether the responsible entity, in accordance with 24 CFR part 58, or HUD, in accordance with 24 CFR part 50, performs the environmental review, the Project Grant Recipient must supply all available, relevant information necessary for the responsible entity (or HUD, if applicable) to perform an environmental review for each activity, including information for each property when applicable. The Project Grant Recipient also must carry out mitigating measures required by the responsible entity (or HUD, if applicable) or select alternative property.

d. The Project Grant Recipient, its project partners, and their contractors are prohibited from taking any choice limiting actions under 24 CFR 58.22, such as acquiring, rehabilitating, converting, leasing, repairing, disposing of, demolishing, or constructing property for a project under the YHPD NOFO, or committing or expending HUD or non-HUD funds for such eligible activities under this NOFO, until the responsible entity (as defined by 24 CFR 58.2(a)(7)) has completed the environmental review procedures required by 24 CFR part 58 and the environmental certification and Request for Release of Funds (RROF) have been approved, if applicable, or HUD has performed an environmental review under 24 CFR part 50 and the Project Grant Recipient has received HUD approval of the proposed activity. HUD will not release grant funds if the recipient or any other party commits grant funds (i.e., incurs any costs or expenditures to be paid or reimbursed with such funds) before the recipient submits and HUD approves its RROF, where such submission is required.

Threshold Criteria.

With the exception of the initial planning grant, outlined in section II.D of the NOFO, HUD will only select projects for funding that pass the following threshold criteria. If a project does not originally pass threshold criteria and is rejected by HUD, the Project Applicant may resubmit the project application to HUD; however, the Project Applicant and the selected community should review the project carefully prior to resubmitting and address all deficiencies. Initial planning grant recipients do not need to submit project applications for the initial planning grant, but they must mee the criteria listed in III.A, III.B, and III.C in order to enter a grant agreement with HUD. Initial planning grant recipients must also follow the Project Eligibility Thresholds outlined below at III.D.1, III.D.4, and III.D.8; recipients must retain records indicating compliance with these requirements.

A. Ineligible Applicants. HUD will not consider an application from an ineligible Project Applicant. All project applications for grants, including planning grants, in communities with a UFA must be from the UFA. For a dedicated HMIS grant, the application must either be from the UFA (when there is a UFA for the Community) or the HMIS Lead (when there is no UFA for the Community) that will be the grant recipient.

B. UEI Requirement. As of April 4, 2022, entities doing business with the federal government must use the UEI created in SAM.gov. Also, you must provide a valid UEI, registered and active at www.sam.gov/ in the application. For more information, see: https://www.gsa.gov/about-us/organization/federal-acquisition-service/office-of-systems-management/integrated-award-environment-iae/iae-systems- information-kit/unique-entity-identifier-update

C. Active Registration in SAM. All Project Applicants seeking funding under the YHDP NOFO must have an active SAM registration. HUD will not issue a grant agreement for awarded funds to a Project Applicant until it verifies that its SAM registration is active.

D. Project Eligibility Threshold. HUD will review all projects, with the exception of the initial planning grant, to determine if they meet the following eligibility threshold requirements on a pass/fail standard. If HUD determines that the applicable standards are not met for a project, the project will be rejected. However, there is nothing to prohibit a project that has been rejected from addressing the deficient project application and resubmitting it to HUD, with the approval of the Collaborative Applicant or its designee, for consideration. HUD requires that the Youth Action Board, and the Collaborative Applicant or its designee, submit updated letters of support for all projects submitted to HUD, including those resubmitted after rejection. A determination that a project meets the project eligibility threshold is not a determination by HUD that a recipient is in compliance with applicable fair housing and civil rights requirements. Project Applicants are required to submit documentation of their subrecipients’ eligibility under these threshold requirements.

1. Project Applicants and potential subrecipients must meet the criteria for Eligible Applicants outlined in section III.A of the YHDP NOFO and provide evidence of eligibility required in the project application (e.g., nonprofit documentation).

2. Project Applicants and subrecipients must demonstrate the financial and management capacity and experience to carry out the project as detailed in the project application and to administer Federal funds. Demonstrating capacity may include a description of the Project Applicant or subrecipients experience with similar projects and with successful administration of CoC Program funds or other Federal funds.

3. The population to be served must meet the criteria for “Eligible Program Participants” in II.D.2 of this appendix.

4. The project must be cost effective, including costs of construction, operations, and supportive services with such costs not deviating substantially from the norm in that locale for the type of structure or kind of activity.

5. Project Applicants, for anything other than SSO grants for coordinated entry and for Planning costs, must agree to participate in a local HMIS system. However, in accordance with Section 407 of the Act, any victim service provider that is a recipient or subrecipient must not disclose, for purposes of HMIS, any personally identifying information about any client. Victim service providers must use a comparable database.

6. Dedicated HMIS grants may only be used for recipient costs of implementing or expanding youth specific HMIS system components (e.g., adding youth-specific data standards, evaluating this program, or to develop YHDP specific reports) or to add youth organizations to the HMIS.

7. SSO grants specifically for coordinated entry process may only be used to implement the youth specific component of a community’s coordinated entry process.

8. Grants for planning funds may only be used for the costs of activities that are described in 24 CFR 578.39 and are specific to preventing and ending youth homelessness (e.g., developing youth specific guidance for the next PIT Count or developing the Youth Action Board).

9. Projects providing supportive services or housing assistance to program participants must incorporate Positive Youth Development (PYD) and Trauma Informed Care (TIC) models of housing and service delivery.

10. All projects, with the exception of HMIS and Planning projects, must participate in coordinated entry, and the selection of program participants must be consistent with the CoC's coordinated entry process. A victim service provider may choose not to use the Continuum of Care's coordinated assessment system, provided that victim service providers in the area use a coordinated assessment system that meets HUD's minimum requirements and the victim service provider uses that system instead.

11. As required in section III.F of the YHDP NOFO, all projects that directly serve youth (all eligible YHDP project types except HMIS and Planning) must submit a narrative demonstrating that the applicant:

Analyzed the racial composition of the persons or households who are expected to benefit from the proposed grant activities;

Identified any potential barriers to persons or communities of color equitably benefiting from the proposed grant activities;

Detailed the steps it will take to prevent, reduce or eliminate these barriers; and Has measures in place to track progress and evaluate the effectiveness of efforts to advance racial equity in the grant activities.

12.

1.

2.

3.

4.

5.

6.

7.

8.

9.

E. Project Quality Threshold. With the exception of the initial planning grant outline in section II.D of the NOFO, HUD will review all project applications to determine if they meet the following project quality threshold requirements. As specified below, not all the criteria in paragraphs E.2 through E.6 must be shown for conditional selection of a project. If awarded, however, each project must meet all the criteria that applies to its project type. A determination that a project meets the project quality threshold is not a determination by HUD that a recipient is in compliance with applicable fair housing and civil rights requirements. HUD will reject projects that do not meet the minimum point requirements described in this section. Project Applicants are required to submit documentation of their subrecipients’ eligibility under these threshold requirements.

1. All projects must meet the following criteria related to project eligibility, capacity, timeliness, and performance:

a. Project Applicants and potential subrecipients must have satisfactory capacity, drawdowns, and performance for any existing grant(s), as applicable, that are funded under the CoC Program, as evidenced by timely reimbursement of subrecipients (as applicable), quarterly drawdowns, and timely resolution of monitoring findings; and

b. Project Applicants must demonstrate that they will be able to meet all timeliness standards established at 24 CFR 578.85.

2. Joint transitional housing-rapid rehousing (TH-RRH) projects must meet the 7 criteria below if awarded YHDP funds but will pass threshold if they receive at least 5 out of the 7 points available. All other housing projects (i.e., permanent housing, transitional housing) must meet the first 5 criteria below if awarded YHDP funds but will pass threshold if they receive at least 3 out of the 5 points for those criteria.

a. The type, scale, and location of the housing fits the needs of the program participants (1 point);

b. The type and scale of the supportive services fits the needs of the program participants–this includes all supportive services regardless of funding source (1 point);

c. The proposed project has a specific plan to coordinate and integrate with other mainstream health, social services, and employment programs and ensure that program participants are assisted to obtain benefits from the mainstream programs for which they may be eligible (e.g., Medicare, Medicaid, SSI, Food Stamps, local Workforce office, early childhood education) (1 point);

d. Program participants are assisted to obtain and remain in housing in a manner that fits their needs (1 point);

e. 100 percent of the proposed program participants meet the criteria for “Eligible Program Participants” in II.D.2 of this appendix (1 point);

f. The proposed project has enough rapid re-housing slots to ensure that at any given time a program participant may move from transitional housing to permanent housing. This may be demonstrated by identifying a budget that has twice as many resources for the rapid re-housing portion of the project than the TH portion, by having twice as many RRH units at a point in time as TH units, or by demonstrating that the budget and units are appropriate for the population being served by the project (1 point; only for TH-RRH projects); and

g. The project uses a Housing First approach (1 point; only for TH-RRH projects).

3. SSO projects–except for SSO projects specifically for coordinated entry–must meet the following three criteria if awarded YHDP funds but will pass threshold if they receive at least 2 out of the 3 points available.

a. The type, scale, and location of the supportive services fit the needs of program participants (1 point);

b. The supportive services are clearly designed to help youth quickly exit homelessness by obtaining or retaining housing (1 point); and

c. 100 percent of the proposed program participants meet the criteria for “Eligible Program Participants” in II.D.2 of this appendix (1 point).

4. SSO projects specifically for coordinated entry must meet the 5 criteria below if awarded YHDP funds but will pass threshold if they receive at least 3 out of the 5 points available.

a. The coordinated entry process is easily available for all youth within the CoC’s geographic area, and is accessible for youth with disabilities, who are seeking information regarding homeless assistance (1 point);

b. There is a strategy for advertising the coordinated entry process that is designed to specifically reach youth experiencing homelessness with the highest barriers within the CoC’s geographic area (1 point);

c. The coordinated entry process has a standardized assessment process that is appropriate for youth (1 point);

d. The coordinated entry process ensures that youth are directed to appropriate housing and services that fit their needs (1 point);

e. The specific plan for ensuring that program participants will be individually assisted to obtain the benefits of the mainstream health, social, and employment programs for which they are eligible to apply meets the needs of the program participants (e.g., Medicare, Medicaid, SSI, Food Stamps, local Workforce office, early childhood education).

5. Dedicated HMIS projects must meet the 4 criteria below if awarded YHDP funds but will pass threshold if they receive at least 3 out of the 4 points available for the following criteria:

a. The HMIS funds will be expended in a way that furthers the CoC’s implementation concerning youth (1 point);

b. The HMIS collects all Universal Data Elements as set forth in the HMIS Data Standards (1 point);

c. The HMIS un-duplicates client records (1 point); and

d. The HMIS produces all HUD required reports, and provides data as needed for HUD reporting (e.g., APR, quarterly reports, data for CAPER/ESG reporting) and HHS/RHY reporting as applicable (1 point).

6. Projects for Planning funds must meet the 4 criteria below if awarded YHDP funds but will pass threshold if they receive at least 3 out of 4 points using the following criteria:

a. The CoC conducts meetings that are inclusive and open to all members, including youth (1 point);

b. The CoC has CoC-wide planning committees, subcommittees, or workgroups that are tasked with specifically addressing the needs of youth experiencing homelessness in the CoC’s geographic area and that recommend or set policy priorities for the CoC (1 point);

c. The proposed planning activities that will be carried out with grant funds are described at 24 CFR 578.39 and specific to preventing and ending youth homelessness (1 point); and

d. The funds requested will improve the ability to evaluate the CoC’s success at preventing and ending youth homelessness in the selected community (1 point).

F. Resolution of Outstanding Civil Rights Matters.

Outstanding civil rights matters must be resolved before the application submission deadline.