Creating and Managing a Continuum of Care What to Know About Creating a New CoC Through a CoC Split

About HomeBase Nora Lally and Matt Olsson work as HUD technical assistance providers for HomeBase, a San Francisco-based nonprofit public interest firm dedicated to the social problem of homelessness. HomeBase works at the federal, state, and local levels to support communities address the root socioeconomic causes of homelessness and implement effective housing and service interventions. HomeBase was assigned by HUD’s Office of Special Needs Assistance Programs, in response to a request submitted through the HUD Exchange Tasking from HUD: Homebase would provide support around governance and the steps to recognize a split.  ICF would provide any HMIS support needed.

Impacts of a CoC Split Potential benefits: Potential drawbacks of dividing a CoC into more than one Continuum include: Improved local control and coordination regarding the community’s response to homelessness (i.e., program types, funding decisions, coordinated entry priorities, etc.) Reduced regional coordination Reduced economies of scale Ensure funding stays local Diminished capacity and competitiveness Increased competitiveness (potentially) Difficulty separating HMIS Potential imbalance of program types Reduced funding Necessary to establish new coordinated entry system

Process Newly formed CoCs are finalized through the CoC Program Competition Registration process, but require considerable planning beforehand. HUD considers merger requests during the CoC Program Registration process, but not later than 5 days before the end of the CoC Program Registration. Any changes now would impact FY2020 NOFA (or later) For SNAPS to acknowledge a CoC split, The jurisdiction(s) for the new CoC must document a formal vote by the stakeholders that will compose the CoC (this is more than a vote by elected officials).   The new CoCs must demonstrate that it notified the existing CoC of its intent to split (this is a minimum requirement – HUD expects that there will be many conversations with the CoC prior to making this decision).   The new CoCs must submit a governance charter that documents the new CoC’s governance structure and shows compliance with the CoC Program Interim Rule (24 CFR 578.7).   The new CoCs must submit evidence of an operating Homeless Management Information System (HMIS) that is consistent with HUD’s most recent HMIS data standards, and The new CoCs must provide evidence of efforts to establish a coordinated entry.

Basic Timeline Transitional Body The new CoC should develop a representative transitional body to investigate the merits and logistics of creating a new Continuum of Care, including the various elements of this basic timeline

Basic Timeline Transitional Body Consult The stakeholders that plan on participating in the new Continuum of Care (CoC) should hold a first vote to approve the investigation of a new CoC and maintain evidence of this vote (through meeting minutes) If the transitional body’s investigation results in a recommendation to split from the CoC, the stakeholders in the new CoC should hold another vote to approve the formation of a new CoC and maintain evidence of this vote (through meeting minutes) Key point – vote needs to be of CoC stakeholders – not just county/city staff that want this to happen. Regulation and question 18-1 of CoC application identifies who should participate (Demonstrate participation from a broad array of stakeholders, not limited to organizations listed in 24 CFR 578.5(a), within the geographic area, including at a minimum:  victim service organizations;  youth providers; and  homeless or formerly homeless). Representatives from relevant organizations within a geographic area shall establish a Continuum of Care for the geographic area to carry out the duties of this part. Relevant organizations include nonprofit homeless assistance providers, victim service providers, faith-based organizations, governments, businesses, advocates, public housing agencies, school districts, social service providers, mental health agencies, hospitals, universities, affordable housing developers, law enforcement, and organizations that serve Veterans and homeless and formerly homeless individuals. CoC Program Interim Rule 578.5(a) Vote does not have to be unanimous. Don’t have a rule on the % that must approve, but HUD typically says it has to be nearly unanimous (idea being that 51% is not good enough).

Basic Timeline Transitional Body Consult Notify The new CoC should notify the existing Continuum of Care of its intent to form a new Continuum of Care and maintain evidence of this communication

Basic Timeline Transitional Body Consult Notify Charter Prior to completion of a CoC split, the new CoC should develop a governance charter to manage the CoC, including (at a minimum): The jurisdictions included within the new Continuum of Care All other required components of a CoC Governance Charter

Basic Timeline Transitional Body Consult Notify Charter HMIS Prior to completion of a CoC split, the new CoC should have a new HMIS in place to manage the CoC’s data needs, including (at a minimum): The HMIS Policies and Procedures that will govern the new CoC’s HMIS data Identification of the HMIS vendor and HMIS Lead (can be a transitional entity until an RFP is issued or an interim agency until a selection process can be followed) Documentation of a selection process for a new HMIS Lead (can be contained in the CoC Governance Charter) The ability to draw data from the previous HMIS (can be either an MOU or direct administrative access) The ability to run system performance measures for the new CoC in the upcoming CoC Program Competition

Basic Timeline Transitional Body Consult Notify Charter HMIS CES The new CoC should take steps to implement a new coordinated entry system for the Continuum of Care and maintain evidence of this effort (e.g., within the Governance Charter, by assigning staff to ensure implementation, etc.)

Potential Impacts of a Split on Balance of State CoC Reduction in Annual Renewal Demand (ARD) tied to any projects that choose to go to the new CoC The decreased ARD also decreases a CoC’s available CoC Planning amount and any new funding that is based on the ARD amount(e.g., Permanent Housing Bonus) Possible adjustments to coordinated entry Governance/committee membership changes

FOR HUD to acknowledge a CoC SPLIT The jurisdiction(s) for the new CoC must document a formal vote by the stakeholders that will compose the CoC (this is more than a vote by elected officials).   The new CoCs must demonstrate that it notified the existing CoC of its intent to split (this is a minimum requirement – HUD expects that there will be many conversations with the CoC prior to making this decision).   The new CoCs must submit a governance charter that documents the new CoC’s governance structure and shows compliance with the CoC Program Interim Rule (24 CFR 578.7).   The new CoCs must submit evidence of an operating Homeless Management Information System (HMIS) that is consistent with HUD’s most recent HMIS data standards, and The new CoCs must provide evidence of efforts to establish a coordinated entry.