A Wonkish First Read of the Continuum of Care NOFA

written by Norm Suchar
November 27, 2013

HUD's Continuum of Care NOFA came out November 22, and it includes some interesting changes and features. Here are my initial impressions, and I'll have a more detailed analysis in a couple weeks. 

First of all, the NOFA covers two years. The score that CoCs receive on their collaborative application will be used for both 2013 (this NOFA) and 2014 (the next one). However, CoCs will have to submit new project priorities and project applications for 2014. 

The NOFA is slowly continuing HUD's trend toward rewarding good performance and achieving goals related to ending homelessness. Of the 156 points available (150 regular points plus 6 possible bonus points), 59 are dedicated to measuring and improving performance and outcomes. Major goals include reducing chronic homelessness, increasing housing stability, increasing income and benefits, and increasing rapid re-housing. 

The NOFA is more direct than in previous years regarding the types of programs that CoCs should consider funding. A total of 29 points are dedicated to increasing or better targeting permanent supportive housing for people experiencing chronic homelessness (19 points) and rapid re-housing for families with children (10 points).

The overall amount of funding is extremely tight, and as a result, the only new projects that will be allowed are projects created through reallocation, CoC planning grants, and funding for Unified Funding Agency costs. Reallocation can only be used to convert projects to either new permanent supportive housing projects serving people experiencing chronic homelessness or new rapid re-housing projects serving families with children. In the registration process, HUD had indicated that reallocating to rapid re-housing might only be allowed in certain circumstances, however, the NOFA allows it (and in fact encourages it) for all CoCs. 

The tiering process that was introduced last year will be in effect again this year. The tier one threshold is essentially 95 percent of the funding necessary to renew all projects (last year it was 96.5 percent). CoCs will have tough decisions to make again about which projects to include in tier one, and which to include in tier two. 

HUD changed the project rankings within the tiers from last year. In tiers one and two, renewal of permanent housing (including PSH and RRH) will be top priority, followed by reallocated PSH, reallocated RRH, transitional housing, CoC planning, UFA costs, Supportive Services Only projects for Coordinated Assessment, renewal HMIS, all other Supportive Services Only, and finally projects that were not on the GIW. The main implication of this rank order is that reallocating transitional housing and supportive services only projects to permanent housing, either permanent supportive housing or rapid re-housing, will maximize the resources a CoC could potentially receive. Although reallocation can often be a challenging process, the NOFA provides a large incentive to reallocate this year. 

The other opportunity that jumps out relates to the targeting of permanent supportive housing units. Several points are available for CoCs that target more of their existing permanent supportive housing units to people experiencing chronic homelessness. The simplest way to do this is to dedicate units to chronic homelessness as they turn over. 

I'll have some more analysis of the NOFA in the coming weeks. I wanted to share some initial impressions and also hear your take. Feel free to leave additional thoughts or questions in the comments section.