FY21 Continuum of Care Competition.pdf

U.S. Department of Housing and Urban Development

Community Planning and Development

Notice of Funding Opportunity (NOFO) for Fiscal Year (FY) 2021 Continuum of Care Competition and Noncompetitive Award of Youth Homeless Demonstration Program Renewal and Replacement Grants

FR-6500-N-25

11/16/2021

Table of Contents

OVERVIEW

I. Funding Opportunity Description and Program Overview

II. HUD's Homeless Policy Priorities and Program Highlights

III. Continuum of Care Program Requirements

IV. Award Information

V. Eligibility Information

VI. APPLICATION AND SUBMISSION INFORMATION

VII. Application Review Information

VIII. Project Review and Selection Process

IX. Award Administration Information

X. Appeals

XI. Agency Contacts

XII. Other Information

OVERVIEW

The U.S. Department of Housing and Urban Development (HUD) issues this Notice of Funding Opportunity (NOFO) to invite applications from eligible applicants for the program and purpose described within this NOFO. Prospective applicants should carefully read all instructions in all sections to avoid sending an incomplete or ineligible application. HUD funding is highly competitive. Failure to respond accurately to any submission requirement could result in an incomplete or noncompetitive proposal.

During the selection process HUD is prohibited from disclosing 1) information regarding any applicant’s relative standing, 2) the amount of assistance requested by an applicant, and 3) any information contained in the application. Prior to the application deadline, HUD may not disclose the identity of any applicant or the number of applicants that have applied for assistance.

For Further Information regarding this NOFO - Please direct specific program requirements of this NOFO to the office contact identified in Section XI.

Paperwork Reduction Act Statement. The information collection requirements in this notice have been approved by OMB under the Paperwork Reduction Act of 1995 (44 U.S.C. 3501- 3520). In accordance with the Paperwork Reduction Act, HUD may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection displays a valid OMB control number. Each NOFO will identify its applicable OMB control number

OMB Approval Number(s):

2506-0112 I. Funding Opportunity Description and Program Overview

A. Program Description. The Continuum of Care (CoC) Program (24 CFR part 578) is designed to promote a community-wide commitment to the goal of ending homelessness; to provide funding for efforts by nonprofit providers, states, Indian Tribes or tribally designated housing entities (as defined in section 4 of the Native American Housing Assistance and Self- Determination Act of 1996 (25 U.S.C. 4103) (TDHEs)), and local governments to quickly rehouse homeless individuals, families, persons fleeing domestic violence, dating violence, sexual assault, and stalking, and youth while minimizing the trauma and dislocation caused by homelessness; to promote access to and effective utilization of mainstream programs by homeless individuals and families; and to optimize self-sufficiency among those experiencing homelessness.

The goal of the Youth Homelessness Demonstration Program (YHDP) is to support the development and implementation of a coordinated community approach to preventing and ending youth homelessness and sharing that experience with and mobilizing communities around the country toward the same end. The population to be served by the demonstration program is youth experiencing homelessness, including unaccompanied and pregnant or parenting youth.

B. Authority. The CoC Program is authorized by subtitle C of title IV of the McKinney-Vento Homeless Assistance Act, (42 U.S.C. 11381–11389) (the Act), and the CoC Program rule found in 24 CFR part 578 (the Rule). The Fiscal Year (FY) 2020 funds were authorized by the Further Consolidated Appropriations Act, 2020 (Public Law 116-94, approved December 20, 2019). The FY 2021 funds were authorized by the Consolidated Appropriations Act, 2021 (Public Law 116- 260, approved December 27, 2020). The renewal and replacement of YHDP grants is authorized by the Consolidated Appropriations Act, 2021.

C. Deadline. The deadline for submitting applications to HUD for the FY 2021 CoC Program Competition is 8:00 PM EST on November 16, 2021. Applicants must complete and submit their applications in e-snaps at https://esnaps.hud.gov/. See Sections VI.E and F of this NOFO for application submission and timely receipt requirements.

D. Available Funds. Approximately $2,656,000,000 is available in this FY 2021 CoC Program NOFO, including approximately $77,000,000, available for non-competitive YHDP renewal and replacement expiring grants, and up to $102,000,000 available for Domestic Violence (DV) Bonus projects (of which up to $50,000,000 is carried over from the Further Consolidated Appropriations Act, 2020), described in Section II.B.5 of this NOFO. HUD may add to the total amount with available funds that have been carried over or recaptured from previous fiscal years.

All requirements in the FY 2021 application process, including requirements for the entire CoC Consolidated Application and the total amount of funds available, are included in this NOFO. HUD will continue to require Collaborative Applicants to rank all projects, except YHDP renewal, YHDP replacement, CoC planning, and Unified Funding Agency (UFA) Costs in two tiers as described in Sections II.B.11.a and b of this NOFO.

E. Summary of the Application Process. The FY 2021 CoC Program Competition is administered under the FY 2021 CoC Program Competition NOFO and Rule. The FY 2021 YHDP non-competitive renewal and replacement of expiring YHDP grants is administered under the Consolidated Appropriations Act, 2021 which permits expiring YHDP projects to renew or https://esnaps.hud.gov/ replace non-competitively through the CoC Program. See Section II.B.7 of this NOFO for the requirements that apply to YHDP renewal and YHDP replacement projects. Applicants should review and follow the steps as outlined below to ensure applications are complete and submitted timely. Documents referenced in this section can be found on the CoC Program page of HUD's website: https://www.hud.gov/program_offices/comm_planning/coc.

1. CoC Registration.

Collaborative Applicants were required to complete the FY 2021 CoC Program Registration in accordance with Notice CPD-18-03: Continuum of Care Registration. If a Collaborative Applicant did not complete the FY 2021 CoC Program Registration, HUD moved the previous year's registration forward with no changes.

2. CoC Project Review and Ranking.

Project applications submitted to the CoC for inclusion on the FY 2021 CoC Priority Listing as part of the CoC Consolidated Application must be reviewed and either accepted and ranked, approved, or rejected by the CoC. All project applications approved by the CoC must be listed on the CoC Priority Listing in rank order, except project applications for YHDP renewal or replacement, CoC planning and UFA Costs projects which are not ranked. Higher ranked projects will be assigned to Tier 1 and lower ranked projects will be assigned to Tier 2 as described in Sections II.B.11.a and b of this NOFO. The purpose of this two-tiered approach is for CoCs to notify HUD which projects are prioritized for funding based on local needs and gaps.

3. CoC Consolidated Application Submission. Collaborative Applicants, including any Collaborative Applicant designated by HUD as a UFA, are responsible for submitting the CoC Consolidated Application in e-snaps on behalf of the CoC. The CoC Consolidated Application is made up of the following three parts:

a. FY 2021 CoC Application. The Collaborative Applicant must provide information about the CoC planning body, governance structure, overall performance, and the strategic planning process. This part of the application is scored and will determine the order in which CoCs are funded.

b. FY 2021 Project Application. Project applications must be completed by project applicants for all renewal, new, CoC planning, UFA Costs, and YHDP renewal or YHDP replacement including the population(s) and subpopulation(s) they will serve, the type of housing and services that will be provided, and the budget activities that are being requested. Collaborative Applicants applying for CoC planning and UFA Costs (if designated as a UFA by HUD) must provide a description of the activities that will be carried out with CoC Program grant funds. For more information on project applications, see Section V of this NOFO. Additionally, all project applicants must ensure their organization has a Code of Conduct that complies with the requirements of 2 CFR part 200 and is included on HUD’s website. If the organization's Code of Conduct does not appear on HUD's website, the project applicant must attach its Code of Conduct that includes all required information to its Project Applicant Profile in e-snaps.

c. FY 2021 CoC Priority Listing. The CoC Priority Listing includes:

https://www.hud.gov/program_offices/comm_planning/coc https://www.hud.gov/sites/dfiles/OCHCO/documents/18-03cpdn.pdf https://www.hud.gov/program_offices/spm/gmomgmt/grantsinfo/conductgrants

(1) The reallocation forms for CoCs to indicate which eligible renewal projects, if any, will be reduced or eliminated through the reallocation process.

(2) Six separate project listing forms:

(a) two project listings require that all project applications are ranked with unique number, New (reallocated, CoC Bonus, and DV Bonus) and Renewal, in order of priority and identify any project applications rejected by the CoC; and

(b) four project listings for non-ranked project applications, YHDP renewal, YHDP replacement, CoC planning, and UFA Costs (if applicable); and, Collaborative Applicants must ensure only one project application for CoC planning, and if the CoC's Collaborative Applicant is designated as a UFA by HUD, one UFA Costs project application is submitted by the CoC.

(3) Form HUD-2991, Certification of Consistency with the Consolidated Plan, which must be signed by the authorizing jurisdiction(s) and dated between August 17, 2021 and November 16, 2021. Additionally, applicants that propose to claim a reservation or trust land geographic area and to locate a project on a reservation or trust land must include a tribal resolution from the tribe authorizing the applicant to do so.

Tribes do not need to include a tribal resolution to claim their own reservation or trust land or to site a project on their own reservation or trust land. A tribal resolution is the formal manner in which the tribal government expresses its legislative will in accordance with its organic documents. In the absence of such organic documents, a written expression adopted pursuant to tribal practices will be acceptable.

Collaborative Applicants will also be required to certify there is a demonstrated need for all ranked permanent housing renewal projects and these projects comply with program requirements and appropriate standards of housing quality and habitability on the Renewal Project Listing. For more information on the CoC Priority Listing, see Section VI.E.3 of this

NOFO.

F. Eligible Applicants.

1. Collaborative Applicants. Only those CoCs with a valid registration for FY 2021 will have access to the FY 2021 CoC Consolidated Application, which includes the CoC Application, CoC Priority Listing, and the project application(s). CoCs should not attempt to change Collaborative Applicants during the FY 2021 CoC Program Competition without HUD's prior approval unless HUD replaces the CoC's designated Collaborative Applicant under the authority of Section 402(c) of the Act. HUD will approve Collaborative Applicant changes outside the annual CoC Program Registration process under the following circumstances:

a. the Collaborative Applicant made an error when entering the Collaborative Applicant name in the CoC Applicant Profile;

b. the Collaborative Applicant designated by the CoC is no longer in business;

c. the CoC selected a new Collaborative Applicant; or

d. a new Collaborative Applicant was selected by HUD as a remedial action under Section 402(c) of the Act.

In cases where the CoC needs to change the Collaborative Applicant approved during the FY 2021 CoC Program Registration process, the CoC must notify the local HUD CPD field office, in writing, stating the reason for the Collaborative Applicant change. The notice to

HUD must provide documentation of the CoC's approval of the change (e.g., a copy of the meeting minutes to include the date and attendees).

2. Project Applicants. Eligible project applicants for the CoC Program are identified in Section V.A of this NOFO. For-profit entities are ineligible, and applications submitted from these entities will not be reviewed.

G. Amendments to FY 2021 CoC Program Registration. A Collaborative Applicant that intends to apply for a project in a formula area that is not a metropolitan city, urban county, town, village, or other nonentitlement area and is not currently included in their CoC’s geographic area may add the formula area to the CoC’s geographic area by sending an email to HUD at CoCNOFO@hud.gov with the following information:

1. The name of the CoC; and

2. The name of the tribe(s) assigned to the formula area(s) that the Collaborative Applicant is seeking to add.

The message must be submitted to HUD by October 22, 2021. The formula area must be either contiguous to the CoC’s existing geographic area or the formula area must overlap with the CoC’s existing geographic area. HUD will review the request and respond to the Collaborative Applicant indicating whether the formula area indicated is eligible to be included in the CoC’s geographic area. Because the PPRN formula does not assign values to formula areas that are not metropolitan cities, urban counties, towns, villages, or other nonentitlement areas, there will be no changes to the CoC’s PPRN. Collaborative Applicants can find a list of formula areas on the CoC Program Competition page on HUD’s website. The addition of a formula area to the CoC’s geographic area will only affect this year’s CoC Program Competition. If a CoC wants to include the formula area to its geographic area for future CoC Program Competitions, the Collaborative Applicant must include the formula area in the next CoC Registration process.

H. Local Competition Deadlines. 24 CFR 578.9 requires CoCs to design, operate, and follow a collaborative process for the development of an application in response to a NOFO issued by HUD. As part of this collaborative process, CoCs should implement internal competition deadlines and notification processes to ensure transparency and fairness at the local level. The implementation of deadlines that meet the standards outlined in Section VII.B.2.g of this NOFO for FY 2021 project applications will be part of the scoring criteria.

I. CoC Review of Project Applications. HUD expects each CoC to implement a thorough review and oversight process at the local level for both new and renewal project applications submitted to HUD in the FY 2021 CoC Program Competition. It has been HUD’s experience that many project applications contain information resulting in conditions on the grant; or for more serious infractions, a project application being rejected. Deficient project applications prolong the review process for HUD, which results in delayed funding announcements, lost funding for CoCs due to rejected projects, and delays in funding to house and assist individuals and families experiencing homelessness. CoCs are expected to closely review the information provided in each project application, including YHDP renewal or YHDP replacement projects, to ensure:

mailto:CoCNOFO@hud.gov https://www.hud.gov/program_offices/comm_planning/coc/competition

1. all proposed program participants will be eligible for the program component type selected, including YHDP renewal or YHDP replacement projects;

2.the information provided in the project application and proposed activities are:

a. eligible and consistent with program requirements in the Rule; or

b. eligible YHDP renewal or YHDP replacement projects (see Sections II.B.7 and V.

B.3.g of this NOFO);

3. each project narrative is fully responsive to the question being asked and that it meets all the criteria for that question as required by this NOFO;

4. the data provided in various parts of the project application are consistent; and

5. all required attachments correspond to the list of attachments in e-snaps that must contain accurate and complete information that are dated between August 17, 2021 and November 16, 2021.

J. FY 2021 CoC Program Competition NOFO. CoCs and applicants should read this NOFO in its entirety in conjunction with the Rule to ensure a comprehensive understanding of and compliance with all CoC Program requirements. This NOFO frequently references citations from the Rule.

1. CoCs should consider the policy priorities established in this NOFO in conjunction with local priorities to determine the ranking of new and renewal project application requests. See Section II of this NOFO for more information on HUD's homelessness policy priorities and program highlights.

2. HUD will conduct threshold reviews of project applicants, subrecipients, and project applications for all CoC Consolidated Applications submitted by the application submission deadline as described in Section VIII.

3. HUD may issue more than one conditional funding announcement, including for those instances where a CoC has been affected by a disaster and for which HUD has extended the deadline for application submission.

4. HUD will score the FY 2021 CoC Application portion of the Consolidated Application in accordance with the criteria set forth in Section VII.B of this NOFO.

5. CoC planning and UFA Costs project applications are not ranked and will be selected provided they pass project eligibility and project quality threshold review.

6.YHDP renewal and YHDP replacement project applications are not ranked and will be selected for funding provided they pass project eligibility and project quality threshold review, and for YHDP renewals, project renewal threshold; as explained in Section V.C.3.c of this NOFO. YHDP replacement project applications will not be rejected during quality threshold review; however, HUD may need to work with the YHDP replacement recipients to correct or revise information submitted after the final FY 2021 award announcement.

7. New DV Bonus project applications passing project eligibility and project quality threshold may be selected:

a. with DV Bonus funds based on the CoC Application score and the responses to the domestic violence specific bonus questions in the CoC Application (Section II.B.11.e of this NOFO) which will remove the DV Bonus project application from the Tier 1 and Tier 2 ranking process; or

b. without DV Bonus funds as a new project where the project application will retain its ranked position in Tier 1 or Tier 2 and may be selected as outlined in Sections II.B.11. a or b of this NOFO.

8. Using the Tier 1 and Tier 2 ranking process in Sections II.B.11.a and b, HUD select:

a. new project applications, created through reallocation or CoC Bonus, and renewal project applications passing project eligibility, project quality threshold, and if applicable, project renewal threshold, based on ranked position in Tier 1 (Section II.B.11.a of this NOFO); and

b. new project applications, created through reallocation or CoC Bonus, and renewal project applications passing project eligibility, project quality threshold, and if applicable, project renewal threshold in Tier 2 based on the CoC Application score and the project application score outlined in Section II.B.11.b of this NOFO.

K. Changes from Previous NOFO.

1. The Consolidated Appropriations Act, 2021 (Public Law 116-260, approved December 27, 2020) amended title IV section 435 of the Act to allow Indian Tribes and Tribally Designated Housing Entities (TDHE) to be Collaborative Applicants, eligible entities, or subrecipients of the CoC Program in addition to amending title IV section 401 to add the terms “Formula Area” and “Indian Tribe.” These amendments mean that not only may Tribes and TDHEs apply for grants through other CoCs, but that formula areas, as that term is defined in the Indian Housing Block Grant program at 24 CFR 1000.302, are eligible to be added to the geographic areas of existing CoCs or may be included in newly formed CoCs. HUD has chosen to implement integration of Tribes and TDHEs into the CoC program in stages because tribal consultation is not yet complete. For the FY 2021 competition, Tribes and TDHEs will be eligible to apply for projects through existing CoCs only. Projects sited on trust land or reservations may be eligible if applicants obtain a certification that the projects are consistent with an approved Consolidated Plan. If a Collaborative Applicant is submitting an application for a project sited on trust land or reservations, they should follow the steps described in I.G. of this NOFO to update their CoC Geographic Area. HUD plans to publish PPRNs in FY 2022 for all formula areas and make formula areas available to be claimed by CoCs during the next Registration Process. Additionally, applicants that propose to claim a reservation or trust land geographic area and to locate a project on a reservation or trust land must include a tribal resolution from the tribe authorizing the applicant to do so. Tribes do not need to include a tribal resolution to claim their own reservation or trust land or to site a project on their own reservation or trust land. A tribal resolution is the formal manner in which the tribal government expresses its legislative will in accordance with its organic documents. In the absence of such organic documents, a written expression adopted pursuant to tribal practices will be acceptable. Beginning in the FY 2022 Competition, HUD will publish PPRNs for all formula areas and make formula areas available to be claimed by continuums CoCs during the FY 2022 CoC Program Registration process.

2. Using the Housing First model to prioritize rapid placement and stabilization in permanent housing without service participation requirements or preconditions is returning in the FY 2021 CoC Program Competition.

3. As required by the Consolidated Appropriations Act, 2021 (Public Law 116-260, approved December 27, 2020), HUD will incentivize CoCs that create projects that coordinate with housing providers and healthcare organizations to provide permanent housing and rapid rehousing services.

4. HUD increased the number of points in Section VII.B.1.g of this NOFO related to CoC coordination with Public Housing Agencies (PHAs) to:

a. add PHA-funded units to CoC coordinated entry;

b. apply for or implement funding provided for Housing Choice Vouchers dedicated to homelessness, including vouchers provided through the American Rescue Plan of 2021 (Pub. L. 117-2) (the "American Rescue Plan");

c. prepare and submit joint applications for funding specifically for individuals and families experiencing homelessness: and

d. established admission preferences for households experiencing homelessness.

5. HUD revised its evaluation of racial disparity from the FY 2019 CoC Program NOFO to place focus on racial equity and increased the number of points in Section VII.B.1.o of this NOFO related to whether people of different races or ethnicities are less likely to receive homeless assistance or positive outcomes, whether racial or ethnic disparities are present, and whether CoCs and homeless providers identified barriers that led to these disparities and have taken steps to eliminate these barriers to improve racial equity. Additionally, points were added to Section VII.B.2.e of this NOFO to determine if CoCs are promoting racial equity related to the local CoC competition related to rating factors; review, selection, and rank process; and rating and ranking projects based on the degree to which program participants mirror homeless population demographics.

6. A new category has been added to Section VII.B of this NOFO to promote inclusion in the local planning process of current and former homeless persons with lived experience to:

a. address homelessness;

b. determine how local policies may need to be revised and updated;

c. participate in CoC meetings and on committees as stakeholders;

d. provide input for decisions; and

e. provide input related to the local competition process.

7. Determining the impact of COVID-19 as CoCs faced challenges due to the outbreak of COVID-19 affecting individuals and families experiencing homelessness in congregate and non-congregate shelter or housing as well as increased risks for individuals and families experiencing unsheltered homelessness. Points were added to Section VII.B of this NOFO related to how CoCs addressed challenges resulting from the outbreak of COVID-19 affecting individuals and families experiencing homelessness, including increased calls due to domestic violence, the need for additional assistance related to mainstream benefits and other assistance, and changes needed to the CoC’s coordinated entry system.

8. Points are being awarded for coordination with Emergency Solutions Grants (ESG) regarding CARES Act funding and distribution with the CoC's geographic area and use of these funds to address homelessness and COVID-19.

9. Due to the COVID-19 pandemic, most communities could not conduct an unsheltered count in 2021 that is comparable to previous counts. For this year, HUD has determined that the sheltered count is a better reflection of overall changes of homelessness and is not evaluating unsheltered data in this year’s NOFO. HUD plans to measure sheltered and unsheltered populations in 2022.

II. HUD's Homeless Policy Priorities and Program Highlights A. Policy Priorities. This section provides additional context regarding the selection criteria found in Section VII.B of this NOFO and is included here to help applicants better understand how the selection criteria support the goal of ending homelessness:

1. Ending homelessness for all persons. To end homelessness, CoCs should identify, engage, and effectively serve all persons experiencing homelessness. CoCs should measure their performance based on local data that consider the challenges faced by all subpopulations experiencing homelessness in the geographic area (e.g., veterans, youth, families, or those experiencing chronic homelessness). CoCs should partner with housing, health care, and supportive services providers to expand housing options, such as permanent supportive housing, housing subsidies, and rapid rehousing. Additionally, CoCs should use local data to determine the characteristics of individuals and families with the highest needs and longest experiences of homelessness to develop housing and supportive services tailored to their needs.

2. Use a Housing First approach. Housing First prioritizes rapid placement and stabilization in permanent housing and does not have service participation requirements or preconditions.

CoC Program funded projects should help individuals and families move quickly into permanent housing, and the CoC should measure and help projects reduce the length of time people experience homelessness. Additionally, CoCs should engage landlords and property owners to identify an inventory of housing available for rapid rehousing and permanent supportive housing participants, remove barriers to entry, and adopt client-centered service methods. HUD encourages CoCs to assess how well Housing First approaches are being implemented in their communities.

3. Reducing Unsheltered Homelessness. In recent years, the number of people experiencing unsheltered homelessness has risen significantly, including a rising number of encampments in many communities across the country. People living unsheltered have extremely high rates of physical and mental illness and substance use disorders. CoCs should identify permanent housing options for people who are unsheltered.

4. Improving System Performance. CoCs should be using system performance measures (e.g., average length of homeless episodes, rates of return to homelessness, rates of exit to permanent housing destinations) to determine how effectively they are serving people experiencing homelessness. Additionally, CoCs should use their Coordinated Entry process to promote participant choice, coordinate homeless assistance and mainstream housing, and services to ensure people experiencing homelessness receive assistance quickly, and make homelessness assistance open, inclusive, and transparent. CoCs should review all projects eligible for renewal in FY 2021 to determine their effectiveness in serving people experiencing homelessness, including cost-effectiveness. CoCs should also look for opportunities to implement continuous quality improvement and other process improvement strategies. HUD recognizes the effects of COVID-19 on CoC performance and data quality and, compared to previous CoC NOFOs, reduces the points available for rating factors related to system performance. However, HUD plans to significantly increase the points available for system performance rating factors in the FY 2022 and subsequent CoC NOFOs.

5. Partnering with Housing, Health, and Service Agencies. Using cost performance and outcome data, CoCs should improve how all available resources are utilized to end homelessness. This is especially important as the CARES Act and American Rescue Plan have provided significant new resources to help end homelessness. HUD encourages CoCs to maximize the use of mainstream and other community-based resources when serving persons experiencing homelessness and should:

a. work closely with public and private healthcare organizations and assist program participants to obtain medical insurance to address healthcare needs;

b. partner closely with PHAs and state and local housing organizations to utilize coordinated entry, develop housing units, and provide housing subsidies to people experiencing homelessness. These partnerships can also help CoC Program participants exit permanent supportive housing through Housing Choice Vouchers and other available housing options. CoCs and PHAs should especially work together to implement targeted programs such as Emergency Housing Vouchers, HUD-VASH, Mainstream Vouchers, Family Unification Program Vouchers, and other housing voucher programs targeted to people experiencing homelessness. CoCs should coordinate with their state and local housing agencies on the utilization of new HOME program resources provided through the Homelessness Assistance and Supportive Services Program that was created through the American Rescue Plan;

c. partner with local workforce development centers to improve employment opportunities; and

d. work with tribal organizations to ensure that tribal members can access CoC-funded assistance when a CoC's geographic area borders a tribal area.

6. Racial Equity. In nearly every community, Black, Indigenous, and other people of color are substantially overrepresented in the homeless population. HUD is emphasizing system and program changes to address racial equity within CoCs. CoCs should review local policies, procedures, and processes to determine where and how to address racial disparities affecting individuals and families experiencing homelessness.

7. Persons with Lived Experience. HUD is encouraging CoCs to include in the local planning process people who are currently experiencing or have formerly experienced homelessness to address homelessness. People with lived experience should determine how local policies may need to be revised and updated, participate in CoC meetings and committees as stakeholders, provide input on decisions, and provide input related to the local competition process (e.g., how rating factors are determined). CoCs should seek opportunities to hire people with lived experience.

B. CoC Program Implementation. The following list highlights important information that applicants should consider as they are preparing the FY 2021 CoC Application and project applications(s). This is not an exhaustive list of considerations or requirements; therefore, all applicants should carefully review the Rule for comprehensive information.

1. Performance-Based Decisions. Consistent with the requirements of the Consolidated Appropriations Act, 2021, and the Further Consolidated Appropriations Act, 2020:

a. Requests for new project applications are not allowed, other than through reallocation unless the CoC evaluates and competitively ranks projects based on how they improve system performance as outlined in Section VII.B.2.b of this NOFO; and

b. HUD will prioritize funding for CoCs that have demonstrated the capacity to reallocate funding from lower to higher performing projects.

2. Indian Tribes or Tribally Designated Housing Entities (TDHE). The Consolidated Appropriations Act, 2021 amended title IV of the Act by adding section 435 so designated Indian Tribe or TDHEs (as defined in section 4 of the Native American Housing Assistance and Self-Determination Act of 1996 (25 U.S.C. 4103) may:

a. be a Collaborative Applicant, eligible project applicant, or subrecipient; or

b. receive grant amounts from another entity that receives a grant directly from HUD.

In FY 2021, Indian Tribes or TDHEs are eligible to apply for CoC Program funds as a project applicant or sub-recipient; and if approved by the CoC, may be designated as a Collaborative Applicant.

3. Transition Grants. See Section III.B.2.z of this NOFO for a definition of the transition grant and process.

4. Coordination with Housing and Healthcare. The Consolidated Appropriations Act, 2021 directs HUD to provide incentives to create projects that coordinate with housing providers and healthcare organizations to provide permanent supportive housing and rapid rehousing services. In the FY 2021 CoC Program Competition, CoCs may receive up to 10 bonus points on the CoC Application if the CoC Priority Listing includes new project applications created through reallocation or the CoC Bonus that utilizes housing vouchers and healthcare provided through an array of healthcare services providers. See Section VII.B.6 of this NOFO for additional details.

5. Domestic Violence (DV) Bonus. The Consolidated Appropriations Act, 2021 provides up to $52 million for “rapid re-housing projects and supportive service projects providing coordinated entry, and for eligible activities that the Secretary determines to be critical in order to assist survivors of domestic violence, dating violence, sexual assault, or stalking.” Additionally, up to $50 million is added to the amount from the Further Consolidated Appropriations Act, 2020 as HUD did not conduct an FY 2020 CoC Program Competition, but instead only awarded eligible renewal projects. Therefore, the total amount of DV Bonus funding is $102 million which will be used for new DV-specific project applications where 100 percent of the participants are or will be survivors of domestic violence, dating violence, sexual assault, or stalking. See Section II.B.11.e of this NOFO for additional information.

6. Consolidation Project. Project applicants can consolidate two but no more than ten eligible renewal projects during the application process. The projects being combined during a grant consolidation will continue uninterrupted. To be eligible for consolidation, the projects must have the same recipient and be for the same component; and will only be funded in this Competition with FY 2021 funds (meaning no funds recaptured from prior years will be awarded to the project). See Section V.B.4.a.(7) of this NOFO for additional information.

7. Youth Homeless Demonstration Program (YHDP). Consistent with the requirements of the Consolidated Appropriations Act, 2021, funding for the CoC Program may be used to competitively or non-competitively renew or replace grants for YHDP projects. HUD has decided to non-competitively renew or replace expiring YHDP grants; however, these project applications will be reviewed for compliance with project eligibility, project quality, and if applicable, project renewal thresholds. See Sections II.B.11.d, II.B.11.f, and V.B.4.a.(5) of this NOFO for additional information.

While YHDP projects can use the consolidation process as outlined in Section II.B.6 and V.B.4.a.(7) of this NOFO these projects cannot consolidate with a non-YHDP projects.

YHDP projects cannot use the expansion (Section III.B.2.j) or reallocation processes (Section III.B.2.w) outlined of this NOFO.

All YHDP renewal and replacement projects are subject to the following provisions of the Rule, as may be amended from time to time, except where they conflict with the NOFO requirements, with the special YHDP activities identified in Section V.B.4.a.(5) of this NOFO, or the requirement that grant funds may only be used to serve homeless youth, age 24 and younger: 24 CFR 578.3, 578.15, 578.23(a), 578.25, 578.27, 578.29, 578.37, 578.43, 578.45, 578.47, 578.49, 578.51, 578.53, 578.55, 578.57, 578.59, 578.61, 578.63, 578.73(c), 578.75, 578.77, 578.79, 578.81, 578.83, 578.85, 578.87, 578.89, 578.89, 578.91, 578.93, 578.95, 578.97, 578.99, 578.103(a)(3) - (18) and (b) – (e), 578.107 and 578.109. The requirements of 2 CFR 200.306, as may be amended from time to time, with the exception of 200.306(b)(5) apply.

8. Adjustments for Ineligible Projects. If an ineligible renewal project is submitted in this Competition or used in the reallocation process, or an ineligible YHDP renewal or YHDP replacement project is submitted, HUD will remove the ineligible project when calculating the final ARD amount for the CoC. To be eligible for renewal in FY 2021, a project must have an executed grant agreement by December 31, 2021, and have an expiration date in Calendar Year (CY) 2022 (between January 1, 2022, and December 31, 2022).

9. HMIS. As directed by Congress, HUD must provide an annual estimate of all individuals and families experiencing homelessness nationwide and within the territories. Therefore, all CoCs must have an HMIS that has the capacity to collect unduplicated counts of individuals and families experiencing homelessness and provide information to project subrecipients and applicants for needs analysis and funding priorities. Additionally, CoC and Emergency Solutions Grants (ESG) Program recipients must participate in the local HMIS; unless a recipient is a victim service provider or legal service provider, in which case it must use a comparable database and provide de-identified information to the CoC. For many communities, the inclusion of ESG recipients and subrecipients and other HUD federal partners (e.g., the Department of Health and Human Services and Department of Veterans Affairs) that require their programs to use the CoC’s HMIS, results in an increase in users that the HMIS must be able to accommodate. HUD expects communities to be able to use the HMIS information as well as aggregate data from comparable databases to review performance for the entire CoC geographic area, not just at the project level. The HMIS Lead should continue to consider any unique needs that the HMIS might be required to address to accommodate emergency shelter, street outreach, homelessness prevention, and other federal programs.

10. Review of CoC Rankings. CoCs will be required to rank all new reallocated, CoC Bonus, DV Bonus, and renewal project applications submitted by project applicants in e-snaps, except YHDP renewal, YHDP replacement, CoC Planning, and UFA Costs (if applicable) projects.

11. HUD Funding Process. HUD will continue the Tier 1 and Tier 2 funding selection process. CoCs and applicants should ensure there is a thorough understanding of the information provided in this NOFO. For CoC Collaborative Applicants designated as a UFA, HUD will use the selection process described in Section II.B.11 of this NOFO. HUD will establish each CoC’s Tier 1 and Tier 2 amounts based on the total amount of funds requested by eligible renewal project applications on the Renewal Project Listing combined with the eligible renewal project amount(s) that were reallocated as listed on the reallocation forms in the CoC Priority Listing. HUD will post a report that lists the available amounts for each CoC's PPRN, estimated ARD, Tier 1, CoC planning, CoC Bonus, and DV Bonus on HUD's website. The Grant Inventory Worksheets (GIWs) are also posted on HUD's website. Section VIII of this NOFO provides additional information regarding project selection.

a. Tier 1. Tier 1 is equal to 100 percent of the CoC’s Annual Renewal Demand (ARD) as described in Section III.B.2.a of this NOFO minus the Annual Renewal Amounts (ARAs) of YHDP renewal and YHDP replacement projects. Project applications in Tier 1 will be conditionally selected from the highest scoring CoC to the lowest scoring CoC, provided the project applications pass both project eligibility and project quality threshold review, and if applicable, project renewal threshold. Any type of new or renewal project application can be placed in Tier 1, except YHDP renewal or YHDP replacement, CoC planning, and if applicable, UFA Costs projects as these projects are not ranked. If a DV Bonus project ranked in Tier 1 is selected with DV Bonus funds, the project will be removed from this tier and the projects below it will move up one rank position. However, if a new DV Bonus project is not selected with DV Bonus funds, the project will retain its ranked position (see Section II.B.11.e of this NOFO). In the event insufficient funding is available to award all Tier 1 projects, Tier 1 will be reduced proportionately, which could result in some Tier 1 projects falling into Tier 2. Therefore, CoCs should carefully determine the priority and ranking for all project applications in https://www.hud.gov/program_offices/comm_planning/coc/competition/giws

Tier 1 as well as Tier 2, which is described below.

b. Tier 2. Tier 2 is the difference between Tier 1 and the maximum amount of renewal, reallocation, and CoC Bonus funds that a CoC can apply for, but does not include YHDP renewal or YHDP replacement projects, CoC planning projects, and if applicable, UFA Costs projects, or projects selected with DV Bonus funds. If a DV Bonus project ranked in Tier 2 is selected with DV Bonus funds, the project will be removed from this tier and the projects below it will move up one rank position. However, if a new DV Bonus project is not selected with DV Bonus funds, the project will retain its ranked position (see Section II.B.11.e of this NOFO). Project applications placed in Tier 2 will be assessed for project eligibility and project quality threshold requirements, and if applicable, project renewal threshold requirements, and funding will be determined using the CoC Application score as well as the factors listed in Section II.B.11 of this NOFO.

HUD will award a point value to each new and renewal project application that is in Tier 2 using a 100-point scale:

(1) CoC Score. Up to 50 points in direct proportion to the score received on the CoC Application; e.g., if a CoC received 81.5 out of 163 points on the CoC Application, the project application would receive 25 out of 50 points for this criterion.

(2) CoC Project Ranking. Up to 40 points for the CoC’s ranking of the project application(s). To consider the CoCs ranking of projects, point values will be assigned directly related to the CoCs' ranking of project applications. The calculation of point values will be 50 times the quantity (1-x) where x is the ratio of the cumulative funding requests for all projects or portions of projects ranked higher by the CoC in Tier 2 plus one half of the funding of the project of interest to the total amount of funding available in Tier 2. For example, if a CoC is eligible to apply for projects totaling $500,000 in Tier 2 and applies for 5 projects ranked in Tier 2 of $100,000 each: the highest-ranked project would receive 45 points, and then the subsequently ranked projects would receive 36 points, and then the subsequently ranked projects would receive 28, 20, 12, and 4 points.

(3) Commitment to Housing First. Up to 10 points based on the project application’s commitment to follow a housing first approach as defined in Section III.B.2.o of this NOFO. Dedicated HMIS projects and centralized or coordinated assessment system SSO projects will automatically receive 10 points.

c. Projects Straddling Tiers. If a project application straddles the Tier 1 and Tier 2 funding line, HUD will conditionally select the project up to the amount of funding that falls within Tier 1. Using the CoC score and other factors described in Section II.B.11 of this NOFO, HUD may fund the Tier 2 portion of the project. If HUD does not fund the Tier 2 portion of the project, HUD may award the project at the reduced amount, provided the project is still feasible with the reduced funding (e.g., is able to continue serving homeless program participants effectively).

d. Renewal and Replacement YHDP, CoC Planning, and UFA Costs Projects. As previously stated, YHDP renewal, YHDP replacement, CoC planning, and UFA Costs projects are not ranked; therefore, these project applications will not be included in Tier 1 or Tier 2. YHDP renewal, YHDP replacement, CoC planning, and UFA Costs projects that pass project eligibility, project quality, and if applicable, renewal project threshold will be conditionally selected using CoC scores from the highest scoring CoC to the lowest scoring CoC. CoCs may only submit one project application for CoC planning costs and, if applicable, one project application for UFA Costs. The project applicant for CoC planning and UFA Costs must be the Collaborative Applicant that is listed on the CoC Applicant Profile in e-snaps.

e. DV Bonus. For new projects the CoC indicates it would like considered as part of the DV Bonus, HUD will award a point value to each project application combining both the CoC Application score and responses to the domestic violence bonus specific questions in the CoC Application using the following 100-point scale:

(1) Rapid Rehousing and Joint TH and PH-RRH component projects:

(a) CoC Score. Up to 50 points in direct proportion to the score received on the CoC Application.

(b) Need for the Project. Up to 25 points based on the extent the CoC quantifies the need for the project in its portfolio, the extent of need, and how the project will fill that gap.

(c) Quality of the Project Applicant. Up to 25 points based on the previous performance of the applicant in serving survivors of domestic violence, dating violence, sexual assault, or stalking, and their ability to house survivors and meet safety outcomes.

Rapid Rehousing and Joint TH and PH-RRH component projects must follow a housing-first approach.

(2) SSO Projects for Coordinated Entry to implement policies, procedures, and practices that equip the CoC’s coordinated entry to better meet the needs of people experiencing homelessness who are survivors of domestic violence, dating violence, sexual assault, or stalking (e.g., to implement policies and procedures that are trauma-informed, client-centered or to better coordinate referrals between the CoC’s coordinated entry and the victim service providers coordinated entry system where they are different):

(a) CoC Score. Up to 50 points in direct proportion to the score received on the CoC Application.

(b) Need for the Project. Up to 50 points based on the extent to which the CoC demonstrates the need for a coordinated entry system that better meets the needs of survivors of domestic violence, dating violence, sexual assault, or stalking, and how the project will fill this need.

Only one SSO-CE project can be submitted per CoC; however, there is no limit on the number of PH-RRH and Joint TH and PH-RRH projects provided that each application is for at least $50,000. A project applicant may also apply to expand an existing renewal project, including one that was previously awarded with DV Bonus funding, in accordance with Section III.B.2.k of this NOFO, however, only the new project application for the expansion will be considered for DV Bonus funds through this process. DV Bonus funding may be used to expand an existing renewal project that is not dedicated to serving survivors of domestic violence, dating violence, sexual assault, or stalking who meet the definition of homeless in paragraph (4) of 24 CFR 578.3 so long as the DV Bonus funds for expansion are solely for additional units, beds, or services dedicated to persons eligible to be served with DV Bonus funding.

CoCs are required to rank all new DV Bonus project applications on the New Project Listing of the CoC Priority Listing with a unique rank number and the corresponding renewal project application must be on the Renewal Project Listing with a unique rank number. A new DV Bonus project that expands an existing renewal project will only be selected if the renewal project is conditionally selected in Tier 1 or 2. If the renewal project application is selected for conditional award with CoC Program funds and the new DV Bonus expansion project is approved for selection, HUD will only select the new DV Bonus project with DV Bonus funds and HUD will remove the new DV Bonus project from the New Project Listing and all other project applications ranked below the new DV Bonus project will move up one rank position.

HUD will conditionally select no more than $102,000,000 in new DV Bonus eligible projects. To be eligible to receive a new DV Bonus project, a CoC must demonstrate it ranks projects based on how they improve system performance as outlined in Section VII.B.2.b of this NOFO.