Continuum of Care Application

By Gilbert Evans,2014-03-19 03:50
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    Getting Ready_

1. Question: How do applicants organize and submit their application?

    Response: The CoC must assemble all the information and submit the complete application package in the following order:

(I) CoC Exhibit 1 section

    (a) 2004 Application Summary Form.

    (b) Exhibit 1, the CoC plan with all required forms, including HUD-27300, Questionnaire

    for HUD’s Initiative on Removal of Regulatory Barriers.

(II) Applicant Documentation section

    (a) SF-424 Application for Federal Assistance. An SF-424 is not included with each

    project. Each applicant must attach the following documentation (i-iv) to its SF-424:

    (i)A typed list of all the applicant’s projects by priority number order, project name

    and requested amount.

    (ii) HUD-424-B Applicant Assurances and Certifications. This should be

    accompanied by an SF-LLL, Disclosure of Lobbying Activities, where applicable.

    (iii) Documentation of Applicant Eligibility. Only applicants for new projects must

    include documentation of eligibility as defined in the chart in Section III.A.3.

    (iv) Special Certifications for homeless programs, located in Attachment 8 of this


    - Applicant Certification

    - Coordination and Integration of Mainstream Programs

    - Discharge Policy (Only State and local government applicants)

    Note: Each SF-424 must also include the applicant’s DUN and Bradstreet Data Universal Numbering System (DUNS) number. (Please see the General Section of the SuperNOFA for more information on obtaining a DUNS number.)

(III) Project Documentation section.

    Each project applying under Exhibits 2-4 must be submitted in its priority list order with all required forms for that exhibit. The following certifications must be included after each project submission:

    (a) Documentation of Sponsor Eligibility. Only sponsors for new projects must include

    documentation of eligibility as defined in the chart in Section III.A.3.

    (b) HUD-2991, Certification of Consistency with the Consolidated Plan;

    (c) HUD-2992, Certification Regarding Debarment and Suspension;

    (d) HUD-2880, Applicant/Recipient Disclosure/Update Report; and

    (e) HUD-424-SUPP, Survey on Ensuring Equal Opportunity for Applicants (for nonprofit

    applicants or sponsors only).


    2. Question: On applicants’ SF-424, the instructions in the 6/22 technical correction say

    each applicant submits only one SF-424, with a page following listing all their projects. There are many items on the SF-424 that are project specific. Should applicants ignore the project-specific information on the SF-424? Should I include all the project-specific information on the page following that lists all their projects?

    Response: Yes, project specific info will not be included on the SF-424 itself, but an applicant with multiple projects should attach a list of all projects by priority number order, project name and the requested amount.

    3.Question: Where can we find guidance about margins, font size, single space versus double space, block style, etc. or is this up to each Continuum to decide? In several of the charts, the text defaults to various font sizes. Is there guidance on font size for the charts or can we use our discretion? Also, can we use landscape page format for the charts?

    Response: The exact format presentation is not specified in the NOFA. However, each CoC should try to respond in a format as close as possible to the application format, balancing the need the stay within the 30-page limit for Exhibit 1 with overall readability of the response. And landscape format is acceptable for the charts.

    4. Question: We understand that the application should delete all instructions. Should we also delete examples in the charts and chart reference numbers (e.g. HUD 40076 CoC-E)?

    Response: You may delete the examples within the charts, but do not delete the form numbers, e.g., form HUD 40076 CoC-E.

    5. Question: If a field office holds CoC training, is it possible to get copies of the application to pass out?

Response: Yes, copies of the application are available for download on or or by calling the SuperNOFA

    Information Center at 800-483-8929.

    6. Have there been any corrections or changes to the NOFA published in the Federal Register on May 14, 2004?

    Response: Yes, on June 22, 2004, a Technical Correction notice to the SuperNOFA was published in the Federal Register. For the CoC Homeless Assistance Programs, the following changes have been made, with reference to the location in the May 14, 2004 CoC program NOFA:

    a. CoC application assembly order instructions are revised. Please see question #1 at the

    beginning of these Q&As, or it can be accessed on the 2004 SuperNOFA CoC Homeless

    Assistance Programs web page at


    b. Field Office Copies, under section IV.C.1.b., is revised to refer to the Submission

    instructions in the General Section on use of the HUD Field Office copy when a portion of an

    applicant’s application to HUD Headquarters may be missing.

    c. Exhibit 3, Project Component/Information/Participant/Major Milestones (Form HUD

    40076 CoC-3C), a correction is made to remove the reference to grant being renewed grant

    number. Since this exhibit is for new projects, reference to renewals is not needed, and was


    Continuum of Care Application

1. Question: Where does the Logic Model fit into the application process?

    Response: The Logic Model is not currently required in the Continuum of Care application process, but it will be beginning next year.

    2. Question: Is HUD requiring all submissions to be a consolidated application with one lead agency, which will be the contracting party with HUD, thereby making individual applicants subcontractors with the lead agency?

    Response: NO. The consolidated application is a packaging mechanism only. It does not alter the legal relationship in any way.

    Continuum of Care: Exhibit 1


    1. Question: In determining the permanent housing bonus for our CoC, must we use the Preliminary Pro Rata Need or the Renewal Hold Harmless Amount?

Response: Every CoC must use the Preliminary Pro Rata Need for calculating the size of the

    permanent housing bonus they are eligible to apply for. Remember that only housing costs and administration qualify for the permanent housing bonus in the number one project.

    2. Question: We have 2 projects that are up for their one-year renewal. Can a project apply for a multi-year renewal, when the original contract was only for one year? How does a change in renewal year from 1 to 3 years, impact the jurisdiction’s ability to fund

    each renewal, as renewals exceed the pro rata need?

    Response: Yes. A project can apply for a multi-year renewal when the contract was only for one year. However, be aware of the impact such a change could have regarding the computation of Pro Rata Need, especially the renewal hold harmless amount.


    3. Question: Several CoCs are considering “swapping” new housing project applications for existing supportive service only projects in order to increase their housing emphasis points. If renewal projects are deleted from the continuum, what consequence does it have on the Pro Rata Need, and especially the renewal hold harmless amount bonus?

    Response: If an existing renewal project is deleted from the priority list entirely, then it cannot be utilized in calculating a possible renewal hold harmless amount to Pro Rata Need. However, renewal projects could be placed below the Pro Rata Need line to permit their dollars to be counted for the renewal adjustment while still allowing their dollars to be used for a new project above the Pro Rata Need line.

    4. Question: When discussing the SHP Permanent Housing Bonus, you distinguished that operations costs are those eligible when connected with housing. Would the bonus cover costs of a permanent housing program director or a permanent housing program case management supervisor who might not be directly working with clients?

    Response: The project director or supervisor will likely have time split between the supervision of the supportive service providers and the maintenance staff of a facility. The time spent supervising the actual operations of the housing (maintenance, equipment, insurance, etc) can be allocated to the operations line item, but the time spent supervising the service providers would be included in the supportive services line item.

    5. Question: Are administrative costs included under housing activities for the purpose of the Permanent Housing Bonus?

    Response: Yes. SHP administrative costs for an eligible PH bonus project will be included together with all housing activities in determining what is countable towards the PH bonus. Housing activities include: rental assistance, acquisition, new construction, rehabilitation, leasing and operating costs.

    6. Question: What part of the SHP administrative costs will be covered by the permanent housing bonus: 5% of the total project budget, or 5% of the housing costs only?

    Response: The total amount (the 5% included on the line item in the budget) will be counted toward the Permanent Housing bonus.

    7. Question: If I qualify for the $750,000 new housing bonus money, is there a standard that HUD expects for the number of beds to be projected with that amount of money?

    Response: No. However, HUD would expect that the number of beds proposed would be cost effective when compared to the dollars requested.

    8. Question: We have not raised the amount we request for leasing in our renewal project in 5 years. Will HUD allow us to do so?


    Response: There is no cost of living increase provision for SHP activities contained in the NOFA.

    9. Question: How many need points will a project receive if it is beyond the PRN? Could such projects be funded?

    Response: Projects within PRN receive 40 need points. The next tier of projects receives 10 need points. Remaining projects receive 5 need points. Projects (excluding S + C renewals) that do not receive 40 needs points will not be funded.

    10. Question: How do you rank a new Permanent Housing Supportive project for bonus funding when the project includes both a SHP application and SPC application?

    Response: Only one project (the top priority project) is eligible for the permanent housing bonus. The Supportive Housing Program (SHP) and the Shelter Plus Care Program (S+C) are

     separate programs and can never be combined as one project.

    Housing Emphasis

    1. Question: Is there going to be a sliding scale for the "Housing Emphasis" score of 10 points?

    Response: The NOFA indicates that the scoring on the “Housing Emphasis” will be done on a sliding scale.

    2. Question: Can you please review how the housing emphasis points will be assigned? 1) In terms of whether administrative costs are included as housing expenses for all projects, or just for the Permanent Housing bonus scenario; and 2) in terms of the number of points that are assigned for different ratios of housing to services.

    Response: The Housing Emphasis points are based upon the ratio of all requested costs for housing activities (rental assistance, acquisition, construction, leasing and housing operating costs) compared to supportive services activities among projects assigned 40 need points. (S+C renewals are not included in this calculation). Administration and HMIS costs are not counted for the purpose of determining the Housing Emphasis points.

    3. Question: Since HUD will be awarding points for Housing Emphasis, can a renewal project propose changes in its renewal budget to move some supportive service funds to operating activities or housing activities?

    Response: Yes. Proposed changes in renewal projects must be legitimate and meet program requirements. However, shifts from services to housing activities that have a program basis may be made up to 10 percent of a line item without prior HUD approval during the renewal process or, if greater than 10 percent, with HUD Field Office approval prior to application submission.



1. Question: Does the document attached to HUD’s Policy Priority for Removal of

    Regulatory Barriers to Affordable Housing count against the 30-page limitation?

    Response: The form and any documentation required for submission counts as one page.

    2. Question: What or how much documentation may be needed to demonstrate “removal of regulatory barriers”?

    Response: Most of the questions in Parts A and B simply ask if the applicable jurisdiction does or does not address the given activity in regard to the development of affordable housing. For most of these questions, (if answered in the affirmative) you may simply provide a brief description of how the jurisdiction addresses the issue with a source where the documentation of that activity can be located. For example, if the applicant answers Yes to question 19. Part A, “Does your jurisdiction have an explicit policy that adjusts or waives existing parking

    requirements for all affordable housing developments?”, it should be accompanied by a brief description of their policy and how more detailed information may be accessed, for example by giving the web address for the county zoning Department’s web page.


    1. Question: The first performance measure requires information on the length of stay in permanent housing. The application asks for, among other things, the number of participants who did NOT leave the project during the operating year who stay for more than 6 months. This information is available in the new APR but not the older version. For renewal projects in a CoC that did not report on the new APR, can another source for information be used?

    Response: Yes. These renewal projects can use their HMIS database or other project information available to respond to the performance section.

    2. Question: Regarding CoC project performance, what if a renewal project has not yet submitted an APR?

    Response: The instructions on Page 27533 specifically states that if you are not submitting any renewals for this year’s competition, state “No applicable renewal projects.”

    3. Question: Will the scoring of this performance section be based on percentages or numbers of persons served?

    Response: The Project Performance section will be scored based on percentages in application instead of the number of participants or units.


    4. Question: Where APR related responses are called for in Exhibit 1, is the info required for just one, most recent, APR filing or APR data accumulated for the life of a project?

Response: HUD will be assessing the information based on the APR most recently

    submitted for all the appropriate renewal project(s) on the 2004 Priority Chart submitted by the CoC. See instructions on Page 27533 and 27534 for more information. None of the responses require accumulated APR data for the life of a project.


1. Question: The NOFA Q&A section on common mistakes notes that using the correct

    Form SF-424 is important. Is there more than one form 424 and if so, where can it be accessed?

    Response: As the revised Assembly Order section explains, each entity applying to be a grantee must submit one SF-424, Application for Federal Assistance, which will cover all the projects it is applying for. Attached to each SF-424 must be the Form HUD-424-B, Applicant Assurances and Certifications. Please note that these are two different forms and that the HUD-424-B is attached to the SF-424. The SF-424 is found either in the General Section of the SuperNOFA, or on the HUD web page for Targeted Housing and Homeless Assistance Programs at:

    This frequent error refers to either a sponsor filling out the SF-424 for their project (a sponsor does not submit a SF-424), or the applicant filling out the SF-424 for a request for renewal when they are not the current grantee. Only the current grantee may request renewal and therefore

    only the current grantee should complete the SF-424.

     2. Question: Does the applicant need to include info supporting their eligibility to apply and is this requirement only for new projects, but not for renewals? Also, where do we find out what documentation is required for applicant eligibility?

    Response: Applicant eligibility for each program is listed in Section III.A.3 of the NOFA. The documentation that supports an applicant’s eligibility as, for example a private or public nonprofit is listed in the NOFA Glossary in Section I.A.7.k and l of the NOFA. New this year, a project sponsor must meet the same eligibility standards as applicants. A nonprofit organization

    must submit supporting documentation. All applicants for new or renewal projects must submit a SF-424. Only the current grantee can be the applicant for a renewal. Experience narrative is not required.

    3. Question: The applicant is to submit only one SF-424. If an applicant is submitting more than one project, how do they respond to questions on the form that are specific to the individual project? For example, how would they answer the "Type of Application" if there are new and renewal projects being submitted by the same applicant?

    Response: An applicant with multiple projects will submit only one SF-424. Therefore, an applicant should only respond to the following boxes on the SF-424 which are addressed to the applicant itself:


    #5. Applicant Information

    #6. Employer Identification Number (EIN)

    #7. Type of Applicant

    #18. Authorized Representative

    The Congressional District for the project should be included along with the project name and amount requested on the list attached to the SF-424.

4. Question: Is the form SF-LLL Disclosure of Lobbying Activities required for

    applicants? If so, which section should it be in?

Response: The SF-LLL should accompany the HUD 424-B Applicant Assurances and

    Certifications where applicable (applicant has engaged in lobbying activity in relation to the grant being applied for). This should be included in the Applicant Documentation Section.


    1. Question: What is the appropriate entry for State and local governmental entities and businesses in the chart on community process concerning subpopulation representation when these entities serve all homeless?

    Response: The column does not need to be completed if the entity is generally representing all homeless persons. A CoC participant should only use the subpopulation to identify a specific claim of representation for one or two subpopulations.



    1. Question: In the instructions, it indicates that we should not count people who are doubled up in conventional housing. However, we have quite a few people that jump from one place to another and just happen to have shelter with friends on the night of the survey.

    Response: We are most interested in getting a point-in-time count of how the homeless service system is being utilized. In an effort to get this, we are only looking for data from a point-in-time: who is in an emergency shelter, transitional housing, or sleeping on the street at that given point-in-time. When we look at these numbers we understand that they are numbers from a point-in-time count and differ from the kind of results that we might see in a longer count done over several days or weeks. For our purposes, we are not looking for this count to cover those who are doubled up.

    2. Question: The slide describing the Housing Activities chart indicates that the data should be from a 1-night survey. Are Continuums now required to do multiple PIT surveys each year to complete this form?

    Response: No. For the 2004 Housing Activity Chart, Continuums must provide data from a


    1-night survey of their inventory. For 2004, the night is one of your choice.


    1. Question: For the chart identified as "Continuum of Care: Homeless Population and Subpopulations Chart” could you please provide a definition and/or the method that should be used to fill out this chart for the count?

    Response: HUD has not specified a correct or preferred methodology for completing the chart. We obviously believe an actual count is the best data. You are required to both use the codes to describe the kind of data collection used to fill in each cell of the table and to describe your methods in a narrative section.

    2. Question: What is the difference between “Homeless Families with Children” and “Persons in Homeless Families with Children”?

Response: The difference is between a “family household” and the “members of the family

    household.” For example, the Nelson family (a count of “1” in the Homeless Families with Children) could have several persons in the Nelson family (father, mother, son, daughter) that would count as four persons in the “Persons in Homeless Families with Children”.

    3. Question: Are youth the same as homeless children in Part II of the “Homeless Populations and Subpopulations” Chart?

Response: For the purposes of this chart, "Youth" are considered to be unaccompanied persons

    less than 18 years of age. Children in families are not covered in this subpopulation.

    4. Question: How do we include those not living in emergency or transitional housing, but in rooming houses, etc?

    Response: We are only asking for the number of persons in emergency shelters and transitional housing. Our definition of homelessness does not cover those in other situations (e.g., doubled up, in rooming houses, etc).

5. Question: Does Part II of the “Homeless Population and Subpopulation” Chart allow

    double counting among the Homeless Subpopulations?

    Response: Yes, double counting may occur when indicating the homeless subpopulations when completing Part 2 of this Chart.

    6. Question: In the Homeless Population and Subpopulations Chart, we are asked to provide a point-in-time number of sheltered and unsheltered persons. Does this mean that if there are vacancies in beds, our total sheltered numbers should not match Housing Activity and Housing Gaps Charts?


Response: The Housing Activity and Housing Gaps charts ask you to measure your bed

    capacity at a point-in-time. The Homeless Population and Subpopulation Chart is a point-in time measure of the number of persons unsheltered (living on the streets) and sheltered in emergency and transitional housing. Therefore, it is possible that your sheltered population at a point-in-time can be less than capacity of the shelters because of vacancies.

    7. Question: Our most recent point-in-time count is September 2003. Should we do a new one?

    Response: For the 2004 Homeless Population and Subpopulations Chart, you may use data from a point-in-time that was conducted within the last three years; therefore, a point-in-time count performed in September 2003 is acceptable.


1. Question: How do you define “episode” in the definition of chronically homeless?

    Response: An episode is an event that is distinct and separate, although part of a larger series, occurring at usually irregular intervals. In this instance, episodic homelessness is two or more homeless events interspersed between or among periods of time when the individual lives in housing appropriate for human habitation. There is a space of time between events.


    1. Question: Can you specify where the requirement is for participating in the HMIS and what percentage of applicants must agree to meet the standard?

    Response: The NOFA sets conditions of project eligibility at Section III (C)(2)(a)(8) for accepting a project. The specific requirement for HMIS participation states: “…An applicant agrees to participate in a local HMIS system when implemented. The standards for participation in an HMIS will soon be published.” HUD will include a provision in each grant agreement

    concerning this obligation. Thus, every grantee of 2004 CoC funding will be obligated to follow the HUD standards when their community implements an HMIS. The proposed HUD standards will provide for priority implementation of the HMIS among the various types of CoC grantees.

    2. Question: Is the HMIS cost for software licensing an eligible project administration cost where the grantee is not involved in the overall HMIS project implementation and management, but is involved in the providing data into the system and is receiving reports for HUD reporting?

    Response: Grantees can use project administration funds for HMIS because it can help prepare reports to HUD

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