HUD Opens FY 2016 Continuum of Care Competition

Yesterday, HUD published the FY 2016 Continuum of Care (CoC) Program Competition Notice of Funding Availability (NOFA), making $1.9 billion available in funds available for continuums across the nation. For this competition, the total amount of funding available may not cover all anticipated eligible renewal projects and HUD continues to require CoCs to rank their projects into two tiers (Tier 1 and Tier 2). The submission deadline for this competition is Wednesday, September 14, 2016.

A few notable changes to this year’s NOFA include:

  • Changes to Tiers: Funding for Tier 1 this year is equal to 93 percent of the CoC’s Annual Renewal Demand (ARD). This is an increase from 85 percent last year, which means CoCs will have a the better opportunity to protect those higher priority projects and fewer projects will be in jeopardy of cut funds.
  • New Policy Priority: Creating a systematic response to homelessness is a new policy priority this year. According to a recent CoC Competition Focus message from HUD, having a systemic response to homelessness requires establishing a coordinated entry system, cohesive planning by the entire community, making assistance appealing and accessible, and using system performance measures.
  • Additional Points: System performance and reallocation will be worth more points in this NOFA. Beginning this year, CoCs are now required to report their system performance measures into HUD’s Homeless Data Exchange (HDX) by August 1, 2016. For this competition, a CoC could receive up to 10 points for attaching their system performance measures report to it’s application.

HUD’s announcement for the competition also included a message encouraging CoCs to reallocate funds from lower performing transitional housing projects serving households fleeing domestic violence to other types of projects serving people fleeing domestic violence. This would “ensure that CoC-funded projects serving people fleeing domestic violence are as effective as possible.” HUD will soon release further guidance on this issue.

NAHRO meets with HUD on Smoke-Free Rule and MTW Expansion; Briefing on SAFMRs

On June 29 and 30, NAHRO staff met with HUD staff to discuss the Moving to Work (MTW) Expansion that was included in the FY 2016 Omnibus and the upcoming smoke-free final rule. HUD also hosted a Small Area Fair Market Rent (SAFMR) proposed rule briefing.

Although HUD is still finalizing the MTW Expansion, they recently unveiled their MTW Expansion website, which contains information on the expansion process. HUD has also posted a MTW Expansion Frequently Asked Questions (FAQ) document.

According to HUD, a PIH notice should be published in the fall of 2016 soliciting applications for the initial cohort of new MTW PHAs. Additional cohorts of MTW PHAs will be added through separate notices through 2020 or until a total of 100 new MTW PHAs have been added. HUD has yet to determine the number of cohorts that will be included in the expansion nor specific policies to be tested through the expansion. The Secretary will weigh the advice of the MTW expansion advisory committee before determining both of these matters. For each cohort of new MTW PHAs, the specific policy proposals and methods of research and evaluation will be described in the PIH notice to be published in the fall of 2016. NAHRO’s policy proposals and recommended research evaluation methods for HUD regarding the MTW expansion can be found here (members only).

HUD plans to release the Instituting Smoke-Free Final Rule late summer or early fall. Although the rule is still undergoing the rule making process, NAHRO staff has learned HUD plans to submit the final rule to the Office of Management and Budget shortly. NAHRO was able to provide HUD staff with input on members concerns regarding the proposed rule. NAHRO’s comments on HUD’s proposed rule can be found here (members only).

HUD also hosted a briefing on the proposed SAFMR rule. The briefing went over the basics of the proposed rule and reviewed specific areas on which HUD was seeking comment. Comments and questions posed at the briefing from industry and advocacy groups included a question about the variability of all Fair Market Rents (FMRS) (to which HUD responded that they are working on a new methodology for FY 2017 FMRs); the current status of the SAFMR demonstration (it’s still going); and whether tenants who receive a subsidy cut in certain zip codes because of the SAFMR rule will be able to find housing in other zip codes because there are not enough available units or because landlords are not accepting vouchers (HUD does not know how to deal with this problem). Read our coverage of the proposed SAFMR rule here (members only).