**QUESTIONS AND ANSWERS**

**A Supplement to the**

**2008 Continuum of Care**

**Homeless Assistance**

**NOFA and Application**

**Office of Community Planning and Development**

**U.S. Department of Housing and Urban Development**

**2008**

**Table of Contents**

  ------------- ---------------------------------------------------- ----------
  **Section**   **Subject Title**                                    **Page**

  A.            Major Changes for 2008                               2

  B.            Application Format in *e-snaps*                      3

  C.            Eligible Persons to be Served                        4

  D.            SHP Administrative Costs                             6

  E.            Match Requirements                                   7

  F.            Application                                          9

  G.            Housing Inventory Chart                              10

  H.            Project Priorities                                   11

  I.            Pro Rata Need and Need Scores                        12

  J.            Special Initiatives                                  14

  K.            Projects                                             17

  L.            Serving Veteran Needs                                21

  M.            Housing Requirements                                 22

  N.            Renewal Funding                                      23

  O.            Homeless Management Information Systems (HMIS)       29

  P.            Performance                                          32
  ------------- ---------------------------------------------------- ----------

**Questions and Answers**

**A Supplement to the 2008 Continuum of Care Homeless Assistance**

**NOFA and electronic Application**

**To assist you in preparing your 2008 Continuum of Care (CoC) Homeless
Assistance electronic application, HUD developed the following questions
and answers. For your convenience, they are grouped together by topic
headings.**

**Additional information and training modules on the *e-snaps* system
will be available at <http://esnaps.hudhre.info/training/>. CoCs may
also contact the *e-snaps* Help Desk at
[*esnaps@hud.hre.info*](mailto:esnaps@hud.hre.info) or by calling
1-877-esnaps (1-877-637-6277).**

######## A. [Major Changes for 2008]{.underline}: {#a.-major-changes-for-2008 .unnumbered}

**There have been some modifications to the Continuum of Care
application this year.**

-   CoCs and project applicants will be required to apply for the 2008
    CoC competition through HUD's *e-snaps* system. *e-snaps* is not a
    part of Grants.gov. Training on the *e-snaps* system is available at
    <http://esnaps.hudhre.info/training/>. CoCs may also contact the
    *e-snaps* Help Desk at
    [*esnaps@hud.hre.info*](mailto:esnaps@hud.hre.info) or by calling
    1-877-esnaps (1-877-637-6277).

-   CoCs were required to register their CoC in *e-snaps*, the
    electronic application system, prior to the beginning of the
    competition.

-   CoCs may create multiple Samaritan Housing Bonus Initiative projects
    as long as the total amount of funding requested for all Samaritan
    Bonus projects does not exceed 15 percent of the CoC's Preliminary
    Pro Rata Need (PPRN) or \$6 million, whichever is the lesser amount.

-   HUD will implement a Rapid Re-Housing for Families Demonstration
    Program in 2008. This demonstration program will serve homeless
    households with children.

-   Safe Havens (SH) will no longer be given Transitional Housing (TH)
    or Permanent Housing (PH) classifications and grantees seeking
    renewal will have an opportunity through the 2008 CoC application
    process to change the classification of their project without a
    grant amendment. In addition, under the newly defined Safe Haven SHP
    program type, any chronically homeless person entering a Safe Haven
    will maintain his/her status as chronically homeless, and will
    therefore be eligible for entrance into Samaritan Housing Initiative
    projects.

-   Continuum of Care Scoring

    -   HUD will continue to score CoC Homeless Assistance applications
        on a 100 point scale; however, the 40 need points previously
        allocated to projects will be redistributed into the existing
        point score structure. Need to be distributed through the higher
        of the formulas that determine Preliminary Pro Rata Ned or Hold
        Harmless Need for the CoC.

> CoC Exhibit 1 scoring will be based on 5 major sections:

-   CoC Housing, Services, and Structure 14 Points

-   Homeless Needs and Data Collection 24 Points

-   CoC Strategic Planning 16 Points

-   CoC Performance 28 Points

-   Housing Emphasis (includes S+C renewals) 18 Points

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-   Shelter Plus Care (S+C) and new SRO grants may not exceed 100
    percent of the Fair Market Rent (FMR) for the Metropolitan
    Statistical Area (MSA) and unit size in which the unit is located.

-   CoCs that are in Hold Harmless Need Status may seek to use the
    reallocation process to create new dedicated Homeless Management
    Information System (HMIS) projects.

-   There may only be one applicant for HMIS-dedicated grants within a
    CoC.

-   HMIS funds contained in the Training and Technical Assistance line
    item of the HMIS budget may be used for travel, hotel, and per diem
    costs associated with the provision of technical assistance and
    training sessions by local HMIS staff; attendance at training
    sessions provided by local HMIS staff and/or outside trainers;
    attendance at HUD-sponsored HMIS training sessions or symposiums;
    attendance at HMIS vendor-sponsor meetings; and attendance at other
    HMIS-related events as qualified and pre-approved by HUD
    Headquarters. Applicants may be asked to identify the number and
    type of HMIS training sessions for which they are requesting SHP
    funds prior to grant agreement. The approved budget will be limited
    to the reasonableness of travel expenses as listed in 24 CFR Parts
    84 and 85.

-   HUD may, after selection and subject to funding availability and as
    supported by a lease or leases evidencing the rent increase, provide
    SHP renewal projects up to a 4% increase in leasing line item not to
    exceed local FMR amounts.

-   HUD will no longer require that applicants/grantees funded for
    Tenant-based Rental Assistance, Sponsor-based Rental Assistance, and
    Project-based Rental Assistance without rehabilitation begin rental
    assistance within twelve (12) months of the date of HUD's grant
    award letter.

**B. [Application Format in *e-snaps*:]{.underline}**

Although the format of the Exhibit 1, SF-424, and Exhibit 2 is different
than in previous years, most of the information requested is the same.
To ensure that the exhibits are completed correctly, CoCs and project
applicants should carefully review all instructions available to them
before beginning their applicable Exhibits. In both Exhibit 1 and
Exhibit 2 there are three different types of instruction: on-screen,
hide/show, and detailed. Not all screens have additional instruction;
however, be sure to review all instructions that are available for each
screen before proceeding.

In addition to the instruction available in the *e-snaps* system,
detailed training modules are also available at
**<http://esnaps.hudhre.info/training/>.** CoCs and project applicants
are strongly encouraged to review each training module either before or
while they are completing the applicable portion of Exhibit 1 or Exhibit
2.

**C. [Eligible Persons to be Served]{.underline}:**

1.  **Who can receive assistance from the projects proposed in an
    application?**

A person is considered homeless only when he/she resides in one of the
three places described below. For new and renewal projects, persons
assisted with **Permanent Housing** must be homeless and come from:

1.  places not meant for human habitation, such as cars, parks,
    sidewalks, and abandoned buildings;

2.  an emergency shelter; or

3.  transitional housing for homeless persons and who originally came
    from the streets or emergency shelter.

> If a person is in one of the three categories listed above, but most
> recently spent less than 30 days in a jail or institution, he/she
> continues to qualify as coming from one of these categories.
>
> In addition to coming from the above three categories, projects
> providing **Transitional Housing, Safe Havens, or Supportive Services
> Only** may also serve populations experiencing the following
> circumstances:

4.  eviction within a week from a private dwelling unit and no
    subsequent residence has been identified and the person lacks the
    resources and support networks needed to obtain housing; or

5.  discharge within a week from an institution in which the person has
    been a resident for 30 or more consecutive days and no subsequent
    residence has been identified and he/she lacks the resources and
    support networks needed to obtain housing.

> Please Note: For Permanent Housing projects that are applying for
> renewal funding, the eligibility criteria above apply to the screening
> process as units become vacant after grant execution. This does not
> mean that current residents are to be removed from housing if they
> entered on the basis of 4) or 5) listed above.

2.  **Can a project serve persons at risk of becoming homeless?**

> No, except for situations 4 and 5 described in Question 1 of this
> section. By law, only those persons who are homeless may be served by
> the programs under the NOFA. If your organization wants to serve
> persons at risk of becoming homeless, persons who are "doubled up," or
> persons who are "near homelessness," it would need to use another
> funding source. HUD administers the Emergency Shelter Grants (ESG)
> program that can fund homelessness prevention activities. A variety of
> other programs, such as Section 8, Community Development Block Grant
> (CDBG) and HOME, serve low-income persons who may be at risk of
> becoming homeless due to poor housing conditions, overcrowding or
> other reasons. Contact your local HUD field office for more
> information on these and other programs.

3.  **Can a project serve a person being discharged from a state mental
    health institution in a state that requires housing to be provided
    upon the person's release?**

    If your state has a law requiring housing as part of a discharge
    plan, HUD does not consider those persons eligible for assistance
    since they will be placed in housing arranged by the state. Contact
    your state department of mental health or similar state agency for
    information on its discharge policy. If your state does not require
    housing as part of discharge planning, then those persons being
    discharged may be served as long as they meet the eligibility as
    described in Question #1 of this section. Please note that
    applicants must submit project applications that target individuals
    being discharged from these institutions.

    As a condition for award in the competition, any governmental entity
    serving as an applicant must agree to develop and implement, to the
    maximum extent practicable and where appropriate, policies and
    protocols for the discharge of persons from publicly-funded
    institutions or systems of care (such as health care facilities,
    foster care or other youth facilities, or correction programs and
    institutions) in order to prevent such discharge from immediately
    resulting in homelessness for such persons.

4.  **Can a project serve a homeless youth after he/she becomes a ward
    of the state?**

    Project funding may not substitute for the assistance a state is
    required to provide a youth while in foster care. Youth who run away
    from home are considered homeless if they meet the criteria in
    Question #1 of this section, are without resources and support, and
    are not considered wards of the state.

5.  **Can a homeless person moving into Permanent Housing receive
    services under SHP for an extended period of time?**

A person living in McKinney-Vento SHP Permanent Housing may receive
supportive services for the entire time he/she is living in the project.
Upon leaving the program and moving into housing not funded by McKinney
--Vento, they are no longer eligible to receive our supportive services.
A person living in Transitional Housing, is eligible to receive
supportive services for up to six months after leaving and moving into
permanent housing not subsidized by McKinney-Vento.

6.  **Who does HUD consider to be chronically homeless?**

> A person who is "chronically homeless" is an unaccompanied homeless
> individual with a disabling condition who has either been continuously
> homeless for a year or more OR has had at least four (4) episodes of
> homelessness in the past three (3) years. In order to be considered
> chronically homeless, a person must have been sleeping in a place not
> meant for human habitation (e.g., living on the streets) and/or in an
> emergency homeless shelter." A disabling condition is defined as "a
> diagnosable substance use disorder, serious mental illness,
> developmental disability, or chronic physical illness or disability,
> including the co-occurrence of two or more of these conditions." A
> disabling condition limits an individual's ability to work or perform
> one or more activities of daily living. An episode of homelessness is
> a separate, distinct, and sustained stay on the streets and/or in an
> emergency homeless shelter. A chronically homeless person must be
> unaccompanied and disabled during each episode.

### The definition of a person who is chronically homeless indicates that the person must have been continuously homeless for a year or more or has had at least four episodes of homelessness in the past three years. If the person has had four episodes of homelessness in the last three years but is currently in transitional housing, does he/she meet the definition of chronically homeless? 

> No. To be defined as chronically homeless, a person must be living on
> the street or in emergency shelter at the time of the count or
> eligibility determination. The definition does not include those
> currently in transitional housing.

8.  **What specific documentation is required to substantiate a homeless
    person's disability for any PH project?**

The grantee or project sponsor must have written verification from a
state licensed qualified source that the person has such a disability.
Qualified sources include medical service providers, certified substance
abuse counselors, physicians or treating health care provider.

**D. [SHP Administrative Costs]{.underline}**

1.  **What is the requirement regarding splitting SHP administrative
    costs?**

This requirement is applicable only to states and units of general local
governments who are the applicants for SHP funding for individual
projects that will be operated by nonprofit organizations. If SHP funds
for administrative costs are awarded to a state or unit of general local
government where the projects will be operated by nonprofit
organizations, some of these funds must be passed on to the nonprofit
sponsor organization(s). As stated in the NOFA, this requirement is NOT
applicable to the SRO and S+C programs, nor does it apply to applicants
that are not government entities.

2.  **How much of SHP administrative funds referred to in Question #1 of
    this section must be passed on to the nonprofit organization(s) who
    will operate the homeless assistance project(s)?**

Administrative funds provided as part of the SHP grant should be split
with the nonprofit organization(s) in proportion to the administrative
burden borne by them for the SHP project(s). However, HUD will consider
states or units of general local government that pass on at least 50
percent of the administrative funds as having met this
Congressionally-mandated requirement.

**E. [Match Requirements]{.underline}**

1.  **Under the SHP, what is the operating cost match requirement? Is
    this a cash match?**

SHP funds may be used to pay for up to 75 percent of the total operating
costs of supportive housing for all years of the grant. For example, if
the annual operating costs are \$100,000, SHP funds may be used to pay
up to \$75,000, or 75 percent, of these costs in each year of the grant
term and the grantee would be required to pay \$25,000, or 25 percent,
each year.

> The operating costs match to be paid by the grantee is a cash match.
> For new SHP projects documentation of firm commitments of cash
> resources for the first year of the grant term and certification that
> cash resources must be provided in the second and third year of the
> grant term, if applicable, must be submitted as part of the technical
> submission application (the form and content requirements of the cash
> match documentation and certification are explained in the applicable
> exhibits of the SHP Technical Submission document). In addition, for
> new and renewal SHP projects, the cash match must be verified in the
> Annual Progress Report. In-kind contributions do not count toward
> meeting this match.
>
> Resident rent and fees may be used to meet cash match requirement for
> transitional housing, safe haven, and permanent housing providers.
> However, match requirements must be met by funds used to cover costs
> associated with eligible SHP activities. If resident rents are used to
> fund ineligible SHP costs, then other sources must be used to meet the
> annual SHP match obligations.

2.  **Is the SHP operating costs match requirement applicable to
    projects submitted for renewal funding?**

Yes. Projects submitted for renewal must meet the same match
requirements as new SHP projects

3.  **What is the supportive services match requirement for SHP? Is this
    a cash match?**

Beginning in the Appropriations Act for fiscal year 1999, Congress has
required SHP grantees to provide a cash match to supportive services
funding. The match provision applies to all recipients of SHP funds,
regardless of whether the grantee originally received supportive service
funds before the provision was instituted. SHP grantees can request no
more than 80 percent of the total cost for the provision of supportive
services in a project in their application for funding. Grantees are
required to match the remaining 20 percent of the total costs with funds
from other sources. All matching funds must be used for eligible service
costs identified on the supportive services budget, and included in the
application and/or the technical submission.

> For new SHP projects, documentation of firm commitments of cash
> resources for the first year of the grant term and certification that
> cash resources must be provided in the second and third year of the
> grant term, if applicable, must be submitted as part of the Technical
> Submission (the form and content requirements of the cash match
> documentation and certification are explained in the applicable
> exhibits of the SHP Technical Submission). In addition, for new and
> renewal SHP projects the cash match must be verified in the Annual
> Progress Report. In-kind services do not count toward meeting this
> match.

4.  **What if we have a renewal project that is requesting supportive
    services funds? Do those funds need to be matched?**

Yes. A renewal project requesting supportive services funds must also
meet the match requirement as described in question #3 of this section.

**5. My project received funding through a two-year demonstration
program (2005 Housing for People who are Homeless and Addicted to
Alcohol) that had modified match requirements. What are the match
requirements for this grant since the project is now eligible for
renewal through the CoC competition?**

> Upon renewal of these projects, the standard SHP requirements for
> match will be applicable. These grants originally allowed leasing,
> housing search (a supportive service) and administration. Under the
> CoC competition, the supportive services match requirement applies.

**F. [Application]{.underline}**

**1. What are the leveraging requirements in the application?**

> The total leveraging amount for the CoC will be automatically
> calculated based on the leveraging information submitted in each
> applicable Exhibit 2 application. Written commitments are not
> submitted at the time of application. However, they must be submitted
> for verification by HUD prior to grant agreement execution. Only the
> value of contributions to a project for which the applicant has a
> written commitment at the time of application will be counted toward
> points for leveraging of other resources.
>
> The written commitment must be documented on letterhead stationery,
> signed and dated by an authorized representative, and must, at a
> minimum, contain the following elements: the name of the organization
> providing the contribution; the type of contribution (e.g., cash,
> child care, case management, etc.); the value of the contribution; the
> name of the project and its sponsor organization to which the
> contribution will be given; and, the date the contribution will be
> available. Written agreements could include signed letters, memoranda
> of agreement, and other documented evidence of a commitment. The value
> of commitments of land, buildings and equipment are **one-time only**
> and cannot be claimed by more than one project in another year. For
> example, the value of donated land, buildings or equipment claimed in
> 2007 or before for a project cannot be claimed as leveraging by that
> project or any other project in subsequent competitions.

**2. The NOFA says that HUD will perform a "threshold" review of my
application. What does this mean? What should I be aware of when
preparing my application?**

HUD reviews your application to ensure that the applicant and any
project sponsor is eligible to apply for the program it selected and has
the requisite capacity to carry it out. It also reviews the capacity of
all other organizations involved with the proposed project. It is
imperative, therefore, to demonstrate that applicants and any sponsors
or other organizations involved have sufficient capacity. Be sure to
answer all of the questions in Exhibit 2 for the applicable program and
component type. It is also imperative that nonprofit applicants include
documentation demonstrating their eligibility.

> HUD also reviews your Exhibit 2 to ensure that your project will only
> serve eligible people, that what you propose is eligible, and, in the
> case of new projects and S+C renewals, that your project meets
> threshold quality standards. You can help ensure that your project
> passes the quality review by completely answering all of the
> applicable questions in the project application. These questions
> relate directly to the NOFA threshold standards so it is important
> that you address each and every applicable factor in the exhibit and
> complete all applicable sections for the program for which you are
> applying.
>
> Under SHP and S+C, renewal projects are considered to have met most of
> the threshold requirements through their previously approved grant
> applications. However, threshold reviews will be done on renewal
> projects to determine: (1) the eligibility of proposed activities; (2)
> the eligibility of the population to be served; and (3) the capacity
> of the applicant and project sponsor, including specific progress data
> contained in the Annual Progress Report (APR).

**3. Are renewal projects required to submit the "Code of Conduct" again
if they submitted their code in a previous competition?**

> Renewal applicants that submitted an application during the FY 2005,
> FY 2006, or FY 2007 competition, and included a copy of the code of
> conduct are not required to submit another copy unless the information
> has been revised.
>
> To verify HUD's receipt of your code of conduct, please check the HUD
> website at
> <http://www.hud.gov/offices/adm/grants/codeofconduct/cconduct.cfm>
>
> New applicants are required to submit the code of conduct by uploading
> the document in the *e-snaps* system.

# G. [Housing Inventory Chart]{.underline}

**1. What information can we use to complete the electronic Housing
Inventory Chart?**

> A CoC must complete an annual survey of its emergency, transitional,
> safe haven, and permanent supportive housing inventory to complete the
> electronic Housing Inventory Chart. The survey must be for a single
> point-in-time count of the inventory, and completed in the last ten
> days of January 2008.

2.  **Are CoCs required to use the Housing Inventory Chart that is
    available in the Exhibit 1 or can CoCs use a different version?**

> CoCs must [not]{.underline} copy and paste old information from
> previous Housing Inventory Charts into the 2008 Housing Inventory
> because the columns and reporting requirements have changed.
> Additionally, CoCs must not attempt to alter this version in any way.
> CoCs that use the correct version will have their housing inventory
> uploaded into *e-snaps* and it will be made available for updates in
> 2009. CoCs that use the wrong version of the Housing Inventory Chart
> will not receive credit for this section of Exhibit 1 and will be
> required to manually enter all housing inventory data in 2009.

**3. If a Continuum of Care has units that are funded by HUD and units
that are funded from other (non-HUD) sources, should these units be
included on the Housing Inventory chart?**

> Yes. All beds and units in place or under development (funded but not
> yet serving homeless persons) in 2008 should be included for each
> provider/facility in the Housing Inventory Chart. Please note that
> Permanent Supportive Housing units should include only units funded by
> McKinney-Vento or units targeted for homeless persons.

4.  **In the Housing Inventory Chart, how does the Continuum determine
    the number of family units in programs with congregate living (e.g.,
    dormitory-style)?**

> The term "Family Unit" in the Housing Inventory Chart refers to the
> actual physical housing units for serving families. Programs providing
> congregate housing (e.g., barracks style) for families would not
> complete the Family Units column of the Housing Inventory Chart.

**H. [Project Priorities]{.underline}**

1.  **Why is HUD asking communities to prioritize their projects
    Continuum of Care (CoC) Project Listing in Exhibit 1? Who sets the
    priorities in a community?**

> Prioritizing projects should be a logical outcome of the development
> of a community\'s CoC strategy and driven by the community\'s gaps
> analysis. This means that all organizations in the process have a
> voice in determining the community\'s priorities for funding.
> Priorities should be established through a fair and open process using
> objective criteria. How the selecting the entity (or entities) that
> facilitates or leads the selection process, is determined completely
> by the community. Different entities will take the lead in different
> communities.

As stated in the application and the NOFA, HUD expects your community\'s
CoC strategy to be developed by and coordinated with an as inclusive
group as possible. Organizations involved in this process should include
nonprofit organizations as well as community and faith-based entities,
government agencies, public housing authorities, housing developers and
service providers, businesses and business associations, law enforcement
agencies, hospitals, funding providers, and homeless and formerly
homeless persons. These and other organizations should represent and
address the specific needs of each homeless sub-population: the jobless,
veterans, persons with serious mental illnesses, persons suffering from
substance abuse, persons living with HIV/AIDS, victims of domestic
violence, runaway youth and others.

**I. [Pro Rata Need and Need Scores]{.underline}**

1.  **What is Preliminary Pro Rata Need (PPRN)?**

    Preliminary Pro Rata Need is the term used to describe the relative
    portion of national homeless assistance need assigned to a community
    or group of communities in HUD's CoC competition. The PPRN amount is
    the expression of relative homeless assistance need in dollar terms
    for use in a CoC competition. To determine the homeless assistance
    need of a particular jurisdiction, HUD will use nationally available
    data, including the following factors as used in the Community
    Development Block Grant (CDBG) program: data on poverty, housing
    overcrowding, population, age of housing, and growth lag. The
    universe of geographies is defined by the universe of jurisdictions
    used in the CDBG allocation process. Applying those factors to a
    particular jurisdiction provides an estimate of the relative need
    index for a jurisdiction compared to other jurisdictions applying
    for assistance under this program section of the SuperNOFA. Each
    year HUD publishes the PPRN for each jurisdiction. A CoC's PPRN is
    determined by adding the published PPRN of each jurisdiction within
    the HUD-approved CoC. In 2008 there were 4,115 metro cities, urban
    counties and all other counties that received a Preliminary Pro Rata
    Need dollar amount. See sections on Samaritan Housing Bonus and
    Rapid Re-Housing Family Demonstration for details on how a CoC's
    PPRN is used in calculating the maximum amount of funds a CoC may
    apply for under each initiative.

    The PPRN amount for a CoC is determined as a part of the CoC
    registration process.

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2.  **What is Hold Harmless Need (HHN)?**

> Hold Harmless Need (HHN) is calculated by every CoC as a part of its
> determining the CoC's Final Pro Rata Need (FPRN) for the 2008
> competition. HHN is calculated by summing up the Average Renewal
> Amount (ARA) for all SHP renewal grants expiring January 1, 2009 and
> ending December 31, 2009 (see NOFA definition for method for
> determining ARA). If there are no SHP renewals in 2009 the HHN is \$0.
> Shelter Plus Care Renewal are not included in HHN.
>
> The HHN amount of a CoC is determined as part of the CoC registration
> process.

3.  **What is Final Pro Rata Need (FPRN)?**

-   FPRN is the higher of PPRN and HHN. 

    -   "PPRN status" is when the FPRN is equal to PPRN

    -   "HHN status" is when FPRN is equal to HHN

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-   The following projects are not included in calculating FPRN:

    -   Shelter Plus Care renewals projects

    -   Samaritan Housing Bonus projects

    -   Rapid Re-Housing projects

4.  **What happens to SHP renewal projects that are submitted outside
    the FPRN amount?**

> SHP renewal projects submitted outside a CoC's FPRN will not be
> reviewed by HUD and will automatically be rejected.

5.  **Does HUD's updating of Shelter Plus and Section 8 SRO projects
    FMRs affect a CoC's FPRN?**

No, HUD will apply FMR changes after project selection, and any such FMR
changes

will not impact the Final Pro Rata Need amount.

6.  **What is Hold Harmless Need (HHN) Reallocation?**

> A CoC whose Final Pro Rata Need is based on its Hold Harmless Need
> amount may reallocate funds in whole or part from SHP renewal projects
> to create one or more new permanent housing projects and/or a new
> dedicated HMIS projects. The HHN Reallocation process allows eligible
> CoCs to fund new permanent housing or dedicated HMIS projects by
> transferring all or part of funds from existing SHP grants eligible
> for renewal in 2009 (those expiring between January 1, 2009 and
> December 31, 2009).
>
> These new permanent housing projects may be for SHP (one, two or three
> years), S+C (five or ten years) and Section 8 Moderate Rehabilitation
> (ten years). New HMIS projects may be for one, two or three years.
>
> New permanent housing projects and dedicated HMIS SHP projects being
> created through this process will be funded under the conditional
> renewal standards described in Section 5.B.2.a.(iii) (i.e., for
> competitive selection purposes they will be treated as renewals). Like
> all projects submitted under the 2008 CoC NOFA, these projects must
> meet eligibility and quality standards established by HUD in order to
> be conditionally selected for funding. In addition, these projects
> must be prioritized within a CoCs Final Pro Rata Need Amount.
>
> These reallocated funds may not be used to supplement a new Samaritan
> Housing Initiative project or a Rapid Re-Housing for Families
> Demonstration Project.
>
> This Hold Harmless Need Reallocation Process is not available to a CoC
> in Preliminary Pro Rata Need Status.

7.  **If our CoC is in Hold Harmless Need (HHN) status, must we use the
    Reallocation Chart to identify new permanent housing projects
    (non-Samaritan project) listed on the CoC Project Listing? And, how
    should we document all the renewal project(s) that are reduced or
    eliminated to fund these projects?**

> CoCs in HHN status must use the reallocation process to create new
> permanent housing or dedicated HMIS projects. In *e-snaps*, screens 3F
> thru 3I will be used to document those SHP projects that are being
> reallocated through elimination or reduction as well as the new
> projects that will be created. CoCs must identify a**ll** the one-year
> renewal SHP projects that were reduced or eliminated to fund in order
> to create the new permanent housing or dedicated HMIS projects through
> the reallocation process on screens 3G and 3H. Renewal projects that
> are eliminated in favor of new permanent housing or new dedicated HMIS
> projects cannot be placed on the CoC Project Listing and are no longer
> eligible for any future funding as a renewal. 

8.  **Are there limitations on the types of SHP renewal projects that
    may be reduced or eliminated?**

> There are numerous reasons for possible reductions or eliminations of
> renewal projects. For example, projects may be under-performing, or
> there may be a reduced need for the particular type of project, or
> mainstream program funding may now be covering a supportive service
> that was previously funded from a HUD homeless grant. When completing
> the Reallocation forms in *e-snaps* it is important that CoCs take
> special care to ensure that the total dollar amount that was reduced
> and/or eliminated is equal to the dollar amount requested in the new
> permanent housing project(s) on this chart.
>
> Communities should note that if renewal projects are reduced, then a
> proportional reduction in the project scope and the number of persons
> served can be included as part of the reduced renewal project's
> exhibit. Additionally, communities are reminded that if a Supportive
> Housing Program renewal project is being eliminated, and it originally
> received funding for acquisition, rehabilitation, and/or new
> construction, the 20-year "term of commitment" requirement remains in
> effect as stipulated under the statute (Section 423.b), and the
> grantee must continue to operate the housing for homeless persons
> according to this section.

**J. [Special Initiatives]{.underline}**

1.  **[Samaritan Housing Initiative]{.underline}:**

This special initiative to promote permanent supportive housing for
chronically homeless persons is provided to CoC systems that designate a
new permanent housing project *exclusively serving the chronically
homeless* as a Samaritan Housing project, then:

-   The CoC will be eligible to receive the full amount of that
    project\'s eligible activities, up to a maximum fifteen (15) percent
    of the CoC's preliminary pro rata need (PPRN), or \$6 million,
    whichever is less.

-   The only eligible activities that will be counted toward this
    incentive are housing activities and up to 20 percent of the total
    eligible program activities (grant total minus administration costs
    up to five percent) may be used for case management.

-   For SHP, administration costs count toward the housing bonus.

-   For the SHP program, housing activities include acquisition, new
    construction, rehabilitation, leasing of housing and operating costs
    when used in connection with housing.

-   S+C and SRO rental assistance are defined as housing activities and
    are eligible under the incentive as well.

-   If your CoC is under hold harmless need (HHN) status, you **cannot**
    reallocate funds to a Samaritan Housing project; these funds must be
    allocated to other new projects on your CoC Project Listing.

-   If your CoC is under Preliminary Pro Rata Need status (PPRN), you
    **cannot** add additional available funds to a Samaritan Housing
    project.

2.  **[Rapid Re-Housing Initiative]{.underline}**

This special incentive to promote the rapid re-housing of homeless
households with dependent children will be awarded to a limited number
of CoCs as a demonstration program through the 2008 NOFA. Each CoC may
submit in *e-snaps* no more than one RRH project application.  

-   That project must have a grant term of three-years and may request
    up to 30 percent of the CoC's PPRN or \$2 million, whichever is
    less.  CoCs may view the exact amount of the maximum request for
    which they are eligible to apply in their approved CoC Registration
    submission.  

-   Grants awarded under the RRH will be administered in accordance with
    the requirements of the SHP program, TH component, with the
    exception that the eligible activities are limited to
    administration, leasing (up to 18 months), and supportive services;

-   The grantee must participate in the evaluation phase

-   Grantees must comply with all RRH program requirements established
    in the 2008 NOFA.  No more than 30 percent of the total eligible
    program activities (grant total minus administration costs up to
    five percent) may be used for supportive services, including case
    management. 

-   Eligible supportive services are limited to housing placement, case
    management, legal assistance; literacy training, job training,
    mental health services, childcare services, and substance abuse
    services.

-   Eligible housing activities include leasing only.

-   If your CoC is under hold harmless need (HHN) status, you **cannot**
    reallocate funds to a Rapid Re-Housing project; these funds must be
    allocated to other new projects on your CoC Project Listing.

-   If your CoC is under Preliminary Pro Rata Need (PPRN) status, you
    **cannot** use add additional available funds to a Rapid Re-Housing
    project.

a.  **What is the Rapid Re-Housing Initiative?**

> HUD will implement a Rapid Re-Housing for Families (RRH) Demonstration
> Program through the 2008 CoC NOFA.  This demonstration program will
> serve homeless households with dependent children. Twenty five million
> dollars will be used to fund the demonstration program projects, of
> which \$23.75 million will be available for the 2008 competition. The
> remaining \$1.25 million will be used to assess the effectiveness of
> rapid re-housing for families with dependent children. A CoC may
> submit no more than one RRH project application in *e-snaps*.  That
> project must have a grant term of three-years and may request up to 30
> percent of the CoC's PPRN or \$2 million, whichever is less. 
>
> Grants awarded under the RRH will be administered in accordance with
> the requirements of the SHP program, TH component, with the exception
> that the eligible activities are limited to administration, leasing
> (up to 18 months), and supportive services; that the grantee must
> participate in the evaluation phase; and that they must comply with
> all RRF program requirements established in the 2008 NOFA.  No more
> than 30 percent of the total eligible program activities (grant total
> minus administration costs) may be used for supportive services. 
> Eligible supportive services are limited to housing placement, case
> management, legal assistance; literacy training, job training, mental
> health services, childcare services, and substance abuse services. The
> only eligible housing activity is leasing. All RRH projects must meet
> standard SHP requirements, including match.

b.  **What criteria should families who are applying to the Rapid
    Re-Housing for Families Demonstration program meet?**

> Families who are applying to the program **[must]{.underline}** have
> at least one moderate barrier to housing: A temporary financial
> strain, inadequate employment, inadequate childcare, a head of
> household with low level education or low command of the English
> Language, legal problems, mental health diagnosis, history of
> substance abuse (without active use), poor rental history, and poor
> credit history.
>
> It is very important that project applicants accept only families who
> are able to sustain housing after short-term housing assistance has
> ended. This is why the program is designed to accept only families
> that have **[moderate barriers to housing]{.underline}**. For example
> families being selected for this program should **[NOT]{.underline}**
> be severely mentally ill or chronic substance abusers.

**K. [Projects]{.underline}**

1.  **If my project has several structures and we are also providing
    supportive services, including outreach, how would I include the
    supportive service on the budget screens?**

> New projects should include a comprehensive budget for each of the
> structures in the submitted project. If supportive services are also
> included, then distribute the services costs across the structure
> budgets so that the total of the structure budgets add up to the total
> project budget.

**2. Under what condition may SHP funds be used in public housing
facilities?**

> An SHP project may use public housing units only after the PHA
> disposes of the units, through deed or lease, to the SHP grantee and
> obtains HUD/PIH approval of the disposition. After the disposition,
> these units can receive no public housing capital or operating
> subsidy.

**3. How do HUD's requirements for timely implementation of projects
affect my project?**

> Recipients conditionally awarded funds in the 2008 CoC funding round
> must have a fully executed grant agreement or, in the case of the SRO
> Program, Annual Contributions Contract, by September 30, 2010. If a
> grant agreement or ACC is not executed by that date, the award will be
> withdrawn. These funds will remain available for expenditure for five
> years from the date of grant execution, except that SRO and S+C
> project based with rehabilitation funds will be available until
> expended.

4.  **In what situations would I identify my project as new?**

You would use the "new" section in the following situations:

-   if you are proposing a brand new project that has not provided
    services or supportive housing for homeless persons;

-   if you are expanding an existing non-SHP funded project in order to
    increase the number of homeless persons served (only [the
    expansion]{.underline} is considered eligible for funding);

-   if you are making an expansion an existing SHP funded project in
    order to increase the number of homeless persons served (only [the
    expansion]{.underline} is considered eligible for funding; see
    Section N, question #4, regarding how to apply for renewal and
    expansion of the same project);

-   if you are bringing your project up to code (only activities which
    are code-related are eligible);

-   if you are replacing non-renewable Federal or private funds in an
    existing project; or

-   if you are re-starting an SHP project which received SHP funding in
    the past, but the SHP funding ended when the project term expired,
    and the project did not continue to provide services or supportive
    housing for homeless persons. Please note that development costs can
    not be requested under these circumstances.

**5. What are the Lead-Based Paint or Environmental review
requirements?**

> Under the Tenant-based Rental Assistance Component for new Shelter
> Plus Care Projects, an environmental review and clearance must be
> performed prior to grant agreement.
>
> The changes in the Lead-Based Paint regulations, which became
> effective for recipients of funding in the 2001 competition, are
> extensive. The regulations set hazard reduction requirements that give
> much greater emphasis than existing regulations on reducing lead in
> house dust. Scientific research has found that exposure to lead in
> dust is the most common way young children become lead poisoned.
> Therefore, the regulation requires dust testing after paint is
> disturbed to make sure the home is lead-safe. Specific requirements
> depend on whether the housing is being disposed of or assisted by the
> Federal Government, and also on the type and amount of financial
> assistance, the age of the structure, and whether the dwelling is
> rental or owner-occupied. It is also subject to regulations if the
> population to be served by the project will include children under the
> age of 6. For additional information, contact your local Field Office.
>
> In regard to environmental reviews, an important statutory change now
> provides that for recipients who are private nonprofit organizations
> or public housing authorities (PHA), the environmental review may be
> performed by responsible entities (units of general local government
> in whose jurisdiction the activity is located or states) in accordance
> with 24 CFR Part 58 - "Environmental Review Procedures for Entities
> Assuming HUD Environmental Responsibilities" whether or not the
> grantee is itself a unit of local government or state.
>
> If a responsible entity is either unwilling or unable to perform an
> environmental review for grantees who are public housing agencies or
> private nonprofit organizations (Section 58.11), or if HUD determines
> that the responsible entity should not perform the environmental
> review on the basis of performance, timing or compatibility of
> objectives, HUD may designate another responsible entity to conduct
> the review under Part 58 or may itself conduct the environmental
> review based on Part 50.
>
> Not every project is subject a full environmental review but every
> project must be in compliance with the National Environmental Policy
> Act and other federal and state environmental laws.
>
> If the program is for the provision of scattered site leasing or
> exclusively for the provision of services and the services provided
> meet the requirements of an exemption or exclusion listed at 24 CFR
> 58.34 or 58.35(b), the responsible entity may determine and record
> that no further environmental review is required, citing the
> appropriate exemption or exclusion.

**6. State and local governments funded in previous competitions were
required to certify that they would develop policies and protocols for
people being discharged from publicly-funded institutions. How do state
and local grantees identify their efforts toward implementing the
requirements of that certification?**

> Project applicants that are state or local governments awarded funds
> in previous competitions are asked in Exhibit 2 to verify that they
> have policies and protocols they have developed/implemented regarding
> discharges from publicly-funded institutions.

7.  **Can Section 8 project-based assistance (PBA) or Section 8
    tenant-based assistance (TBA) be used in a SHP funded transitional
    housing program?**

> HUD's policy is to not fund **new** projects mixing Section 8
> assistance in SHP-funded transitional projects. Experience with such
> funding has resulted in many complex operating issues when the two
> subsidy streams are combined. Section 8 is intended to be a permanent
> housing resource and should be integrated into the CoC in that manner.

**8. If my project is a new "Supportive Services Only" project, do I
still have to answer all of the narrative questions?**

> Applicants for the Supportive Services Only component of the SHP must
> answer all appropriate items in Exhibit 2. In *e-snaps* applicants
> will only be asked those questions that are relevant to the applicant
> type, program type, and component type of the project for which they
> are applying.

9.  **Can Shelter Plus Care new and renewal and new SRO project request
    rents above the published FMR applicable at the time of the
    application due date?**

> No. Shelter Plus Care (S+C) and new SRO grants may not exceed 100
> percent of the applicable Fair Market Rent (FMR) for the Metropolitan
> Statistical Area (MSA) and unit size. Although awards are based on the
> number of units and the FMR amounts for those units, S+C funds can be
> used to pay *actual* rents which could be above or below the published
> FMR. If a grantee draws down rents higher than the awarded FMR, it is
> still obligated to lease the number of units specified in the
> application.

10. **Can Shelter Plus Care new and renewal and new SRO project request
    rents below the published FMR applicable at the time of the
    application due date?**

> Yes. Shelter Plus Care (S+C) and new SRO grants may request rents that
> are below the published FMR. Grantees that request an amount that is
> 1-99% of the published FMR will be locked in to the requested amount
> and will not receive any update when the 2009 FMR amounts are
> published. It should also be noted that if a grantee requests a lower
> amount for any single unit size, the rent amount will be locked for
> all unit sizes in the application.

13. **Our community has a project that was originally awarded as a Safe
    Haven-TH. How will the new definition of Safe Havens impact us?**

> Safe Havens (SH) will no longer be given Transitional Housing (TH) or
> Permanent Housing (PH) classifications. Grantees seeking renewal will
> have an opportunity through the 2008 NOFA to change the classification
> of their project without a grant amendment, if necessary. Grantees
> that are currently operating a HUD funded Safe Haven (TH or PH) should
> review the required SH characteristics that are defined in the 2008
> NOFA to determine if their project still qualifies as a SH or if it
> needs to be reclassified to either a TH or a PH project. If a grantee
> determines that its project meets all of the characteristics of a SH,
> the grantee should identify itself as such in its Exhibit 2
> application. For those projects that are identified as a Safe Haven,
> any chronically homeless person entering the project will maintain
> his/her status as chronically homeless, and will therefore be eligible
> for entrance into Samaritan Housing Initiative projects.
>
> If a grantee determines that its current Safe Haven project [does
> not]{.underline} meet all of the Safe Haven requirements listed above,
> it must decide whether or not the Safe Haven project would more
> appropriately be identified as a transitional supportive housing
> program or a permanent supportive housing program. Grantees should
> work with their local field offices to determine the correct SHP
> component of their projects. If reclassification to a SHP-TH or SHP-PH
> is required, the grantee can make the change during the 2008 CoC
> application round without completing a grant amendment.
>
> Projects that are currently classified as either SH-TH or SH-PH that
> are not eligible for renewal in 2008, can either reclassify through a
> grant amendment or wait until time of renewal and reclassify in the
> renewal application. Reclassifying to a SH project (from SH-TH or
> SH-PH) through a grant amendment will allow chronically homeless
> participants entering these projects to maintain their status, which
> will allow them to be eligible for Samaritan Housing projects.
>
> Safe Haven-TH or Safe Haven-PH projects that choose to wait until the
> time of renewal to reclassify, however, will continue to follow
> requirements listed in the NOFA year that they were funded and
> participants will not maintain a chronically homeless status

12. **What happens if our community submits a project seeking Samaritan
    Housing Initiative funds but does not meet HUD's criteria for
    permanent housing or for exclusively serving the chronically
    homeless?**

> If the CoC requests a new Samaritan Housing Initiative project and HUD
> determines that it is [not]{.underline} a permanent housing project
> and/or is not exclusively serving chronically homeless individuals,
> HUD reserves the right to not award funds to that project rather than
> reclassify the component. CoCs may create multiple Samaritan Housing
> Initiative projects in 2008 as long as the total amount of funding
> requested for all bonus projects does not exceed 15 percent of the
> CoCs Preliminary Pro Rata Need or \$6 million. All Samaritan Housing
> Initiative projects will be funded in order, starting with the project
> with the highest rank. It is no longer a requirement that a Samaritan
> Housing project be ranked number one.

13. **Can a sponsor for a Supportive Housing Program project be a
    "for-profit" entity?**

> No. For-profit entities are not eligible to be project applicants or
> sponsors.

14. **Can SHP rehabilitation funds be used to rehab leased properties?**

> Yes. For the 2008 competition, HUD has provided additional conditions
> as follows: To rehabilitate a leased property, certain conditions must
> be met during the Technical Submission and if they are not, the award
> will be withdrawn. The recipient must have a lease for 25 or more
> years with a landowner that is not the applicant, project sponsor, a
> parent or affiliated organization and must submit it to HUD for
> approval. The landowner must execute and record against the land the
> lease, and the HUD form Use and Repayment Covenant. Under certain
> circumstances where there is the useful life of the improvements is
> greater than 25 years, the recipient must be required to repay the
> residual value of the improvements.

15. **May a Supportive Services Only (SSO) Project convert to a TH or PH
    program?**

> No. By definition, the SSO program can not provide housing and the
> conversion to a housing program is an entirely new project requiring a
> new submission under competitive rules so that the statutorily
> required quality of the project can be evaluated.

**L.  [Serving Veteran Needs]{.underline}**

1.  **The NOFA mentions veterans groups.  How should veteran's
    organizations be involved in the CoC?**

            Your community process for developing and implementing a CoC
system should be comprehensive and inclusive.  This means the needs of
all homeless sub-populations in your community should be represented in
your CoC planning process and project implementation.  Because studies
show that a significant segment of the homeless population are veterans,
it's especially important to involve veterans organizations so that the
needs of homeless veterans are addressed appropriately and effectively.

**2.   Is there any guidance available on developing programs to address
the needs of homeless veterans?**

> In 2002, HUD released two technical assistance resources addressing
> the needs of homeless veterans.  The first report, [A Place at the
> Table: Homeless Veterans and Local Homeless Assistance Planning
> Networks]{.underline}, was updated in December 2005 and is designed to
> help organizations serving homeless veterans to more effectively
> participate in the homeless assistance program planning networks in
> their communities and, in particular, to access resources through the
> Continuum of Care planning
> process. <http://www.hud.gov/offices/cpd/about/hudvet/library/index.cfm>)
>
> The second report, [Coordinating Resources and Developing Strategies
> to Address the Needs of Homeless Veterans]{.underline}, provides
> information on promising practices for effectively coordinating HUD
> funding with other resources in order to address the special needs of
> homeless veterans.  Both reports can be found at
> <http://www.hud.gov/offices/cpd/about/hudvet/library/index.cfm>.
> Printed versions of the second report only are available from
> Community Connections at 1-800-998-9999. 
>
> HUD strongly encourages each local Continuum of Care to examine the
> identified unmet needs for supportive services and housing of homeless
> veterans by examining appropriate local community data contained in
> the Department of Veterans Affairs CHALENG (Community Homelessness
> Assessment, Local Education and Networking Groups) for Veterans
> report.  This report can be accessed via the web at
> <http://www1.va.gov/homeless/page.cfm?pg=17>.

**M. [Housing Requirements]{.underline}**

***[National Funding Priorities]{.underline}***

1.  **What exactly is the 30 percent permanent housing requirement in
    this year's competition?**

> The FY 2008 HUD Appropriations Act specifies that 30 percent of the
> appropriation (not including S+C renewal grants) must be awarded to
> permanent housing programs. HUD is not requiring each community to
> submit 30 percent of its projects as permanent housing. However, in
> order to meet this statutory requirement, HUD may have to skip over
> higher scoring non-permanent housing projects in order to fund lower
> scoring permanent housing projects or, within a continuum, skip over
> higher priority non-permanent housing projects in order to fund lower
> priority permanent housing projects. In order to reduce the chances
> that one of your non-permanent housing projects will be skipped over
> for funding, every effort should be made to improve your CoC
> narrative.
>
> Projects now meeting the definition of permanent housing for this
> purpose are projects under the following programs:

-   S+C (new);

-   SRO; and

-   the SHP/Permanent Housing component (new and renewal);

2.  **Residents served in projects under the Samaritan Housing
    Initiative must all be chronically homeless. Could these units be in
    a building with other non-chronically homeless units?**

> Yes. Units for the chronically homeless may be located in a building
> with units for non-chronically homeless persons as long as it is clear
> that there are two separately funded projects.

**N. [Renewal Funding]{.underline}**

1.  **What is a renewal grant?**

A renewal grant is a grant that continues assistance to a project that
received funding in the past. For the 2008 competition, a grantee may
request renewal funding if it was previously funded under one of the
following programs and its grant will expire in calendar year 2009. The
following are eligible:

a.  SHP projects, including those renewed before, that are expiring in
    2009;

b.  S+C projects that are expiring in 2009 or that have been previously
    extended but which are projected to run out of funds in 2009.

c.  Projects awarded under the 2004 "Collaborative Initiative to Help
    End Chronic Homelessness" and "Ending Chronic Homelessness Through
    Employment and Housing Initiative" and the 2006 "Housing for People
    Who are Homeless and Addicted to Alcohol" that have an expiration
    date in 2009.

**2. Who can apply for a renewal?**

> Only the current grantee (the entity that has executed the grant
> agreement with HUD) can be an applicant for a renewal. In order to
> identify the current grantee as the applicant in this year's
> competition, a SF-424 must be included as part of the application. If
> in doubt, please check with your local HUD field office. Please note
> that project sponsors and other entities that are not the grantee
> cannot apply for renewal. The law allows only the grantee to apply.

***[Supportive Housing Program Grants]{.underline}***

3.  **A current SHP grantee decides to add new activities or expand the
    level of an existing approved activity to its existing SHP funded
    project (i.e., expand the project) and submits an application
    requesting funding for these new activities. Would this be
    considered a renewal grant?**

    No. In order to be considered an SHP renewal, a project must not
    include either a new activity or an expansion of an existing
    activity. An expansion of an existing project is considered a new
    effort and must be submitted as a new project.

    **4. Do I have to submit separate project applications to both renew
    and expand my SHP project?**

    Yes. If a project is eligible for renewal and the grantee wants to
    apply for funds to both renew the existing project and to add new
    activities or expand existing activities to the same project, a
    separate Exhibit 2 must be submitted for each. That is, an Exhibit 2
    should be submitted requesting the renewal of the existing project
    and another Exhibit 2 should be submitted requesting funding for
    only the additional new or expanded activities. In addition, both
    projects should be listed as separate projects on the CoC Project
    Listing in Exhibit 1.

    **5. How do I determine if my project is eligible for SHP renewal?**

    To be eligible for a 2008 SHP renewal, your current HUD grant must
    expire during calendar year 2009. A grant is expiring in calendar
    year 2009 if its term ends during that year. Many grants begin with
    acquisition, rehabilitation, or new construction which must be
    completed before term activities can begin. Term activities are
    those that are funded for a period of time specified in the NOFA,
    grant agreement, or HUD renewal guidance under which the grant was
    funded -- such as one, two or three years. Term activities are
    leasing, operations, HMIS, and supportive services. The term of a
    grant begins when the grantee begins to serve participants -- this
    is the basis for establishing the operating start date for the
    project, and is established by the grantee in LOCCS.

    The term ends when the specified time period for the grant elapses.
    For example, a 2005 SHP grant was awarded a three-year term. The
    term ends three years from the operating start date, not three years
    from the first draw of SHP development (acquisition/rehab) funds.

> Review your CoC's Supportive Housing Program Grants Inventory
> Worksheet which has been approved by HUD and confirm whether your
> project is eligible for renewal in this competition. If the grant is
> not on the approved SHP Grants Inventory Worksheet, it can not be
> submitted for renewal.

**6. How much money can I request for my SHP renewal?**

> The amount an applicant may request for activities eligible for
> renewal in an existing project (i.e., leasing, operations, supportive
> services, *and administration*) is based on the average annual amount
> of the grant being renewed, as approved by HUD for these activities in
> the existing grant's Technical Submission. Renewal funds can only be
> requested for continuing a previously approved project at the same
> level of housing and/or services provided in the previous grant. The
> amount requested for operations may not exceed 75 percent of the total
> operations budget and the amount requested for supportive services may
> not exceed 80 percent of the total supportive services budget (see
> Section E of this supplement regarding match requirements for these
> activities). Cost of living increases are not eligible for renewal
> projects.

###### 7. If my application for renewal of an SHP project is not funded in a competition, what sources of funds can I use to continue my project? {#if-my-application-for-renewal-of-an-shp-project-is-not-funded-in-a-competition-what-sources-of-funds-can-i-use-to-continue-my-project .unnumbered}

To continue a renewal SHP project that was unsuccessful in seeking
renewal in a prior competition, you may use any type of funds --
Federal, state, local, or private funds. New this year, these types of
projects can no longer be approved to come back into any future CoC
competitions. However, these projects can come in as new projects, as
long as the project is in compliance with 24 CFR 583.150(a).

**8. Can a CoC that is in preliminary pro rata need (P/PRN) status
decide not to request renewal funds for existing projects, or to give
these projects a relatively low priority ranking?**

Yes. The need for the continuation of previously funded projects should
be considered in the local needs analysis process and a decision should
be made locally on the priority to assign to the continuation of a
project. HUD does not require that existing projects be renewed or given
a higher priority than other projects. However, HUD is very concerned
that the ongoing housing needs of persons currently being served by
existing projects be taken into account as part of the decision-making
process. The CoC should review each project at the time it seeks renewal
to determine if the project is performing satisfactorily and is meeting
the needs of persons it proposed to serve or whether local needs have
changed and other subpopulations or types of assistance should be given
preference.

**9. What level of detail is needed to complete the Supportive Services
and Operations Charts for renewal projects?**

The charts enable you to include detailed information you already have
available for renewal projects at the time of application, rather than
at second submission. This eliminates the need for the Technical
Submission package and streamlines your planning and eliminates
duplication of effort following the conditional award.

***[Shelter Plus Care Grants]{.underline}***

## Are Shelter Plus Care renewal projects a part of the 2008 CoC Competitive Process?

Under the 2008 HUD Appropriations Act, eligible Shelter Plus Care
Program grants whose terms are expiring in FY 2009 and Shelter Plus Care
Program grants that have been extended beyond their original five-year
terms but which are projected to run out of funds in FY 2009 will be
renewed for one-year provided that they are determined to be needed by
the Continuum of Care and meet other programmatic and financial
standards. Shelter Plus Care renewals are submitted as part of a
Continuum of Care submission but are funded non-competitively. All
Shelter Plus Care renewal applications should be submitted by the
deadline and in accordance with the other submission requirements
described in the NOFA). A renewal project may include no more than one
component \[i.e., TRA, SRA, PRA, and SRO\].

11. **How do I determine if my project is eligible for a S+C renewal?**

    Any S+C project whose grant term is expiring in calendar year 2009
    is eligible for renewal. (In addition, S+C grants that received a
    5-year extension previously but which are projected to run out of
    funds in 2009 are also eligible.) The effective date of the grant is
    the date used to determine whether the grant (including all of its
    TRA, PRA, SRA, and SRO component projects) is expiring.

    If your initial five (5)- year grant term is expiring in 2009 but
    you do not expect to run out of funds during that year, you may
    apply to your HUD field office for an extension. This extension
    process is independent from the CoC competition. In such a case,
    contact your HUD field office for information on seeking an
    extension of your project.

**12. What are the standards for the first renewal of a Shelter Plus
Care Project?**

For TRA, SRA, PRA, and SRO projects, you may request up to the amount
determined by multiplying the number of units under lease at the time of
your application for renewal funding by the applicable current Fair
Market Rent(s) by 12 months (FMR as published in the Federal Register on
October 1, 2007.) *Example*: A S+C grant originally awarded for 50 units
was able to lease an additional 5 units and had 55 units under lease
when it applied for its first renewal. They may apply for 55 units in
the renewal grant.

For the S+C/SRO component, use the same FMR method as other renewing S+C
project components, the FMR is 75 percent of the 0-bedroom rate. Upon
renewal, the unspent balance of funds at the end of the previous grant
period will be recaptured. The one-year term of non-competitively
awarded Shelter Plus Care renewal projects may not be extended.

**13. What are the standards for second renewal and subsequent renewal
of Shelter Plus Care projects?**

For Shelter Plus Care grants having been awarded one-year of renewal
funding in 2007, the number of units requested for renewal in 2008 may
not exceed the number of units funded in 2007. (Please be advised that
the actual FMRs used in calculating your grant will be those in effect
at the time the grants are selected which may be higher or lower than
those found in the October 1, 2007 FR Notice.) One year S+C renewal
grants can not be extended.

# [Number of units renewable from a one-year contract:]{.underline} The number of units eligible for renewal is limited to the number of units applied for in the initial one-year renewal contract. *Example:* A S+C grant was renewed for the first time for 55 units, as in the previous example. All subsequent renewals are limited to 55 units. If the grantee was able and willing to lease two additional units covering a total of 57 units during the year, the renewal of this grant will still be limited to 55 units. The grantee must ensure that it has sufficient funds to cover the additional 2 units for the longer of either the term of the grant or the voluntary tenancy of the residents of these units. Any shortfall in funding for units not under contract must be provided by the grantee.

14. **How does a S+C project change the unit sizes during the contract
    and at renewal?**

> Reasonable changes to a mix of unit sizes may be undertaken during the
> grant period for Tenant Based (TRA) or scattered site Sponsor Based
> (SRA) component projects. A program may apply for the actual unit mix
> under lease at the time of application renewal. *Example:* A TRA grant
> for 50 one-bedroom units has 5 participants who each reunited with
> their child and now each require two-bedroom units. The grant may be
> renewed for 45 one-bedroom and 5 two-bedroom units, for a total of 50
> units. This authority does not extend, however, to wholesale changes
> in the nature of the project. A grantee may not change a TRA or SRA
> project, for example, from all one-bedroom units (singles) to all
> three-bedroom units (families), or vice versa. Additionally, projects
> that were initially awarded as a Samaritan Housing project must
> continue to exclusively serve chronically homeless individuals;
> therefore, unit sizes for these projects cannot increase and must
> remain either SRO, 0-bedroom, or 1-bedroom units. Please Note: Project
> Based (PRA) or Single Room Occupancy (SRO) components may not change
> the unit configuration.

**15. In the NOFA Continuum of Care application announcement under
Threshold Requirements states that S+C non-competitive renewals must
meet minimum threshold requirements, which include performance
standards. What are these performance standards, or where does it state
what the minimum performance standards are?**

> If you or the project sponsor is a current or past recipient of
> assistance under a HUD McKinney-Vento Act program, there should be no
> serious unresolved HUD/SNAPS monitoring findings, and no outstanding
> audit finding of a material nature regarding the administration of the
> program. S+C non-competitive renewals will be funded for one year
> provided that they are determined to be needed by the CoC as evidenced
> by their placement on the CoC Project Listing.

**16. Since we may consolidate S+C grants from the 2007 round, how
should they be listed for the 2008 round?**

> If the 2007 S+C grants have already been consolidated prior to the CoC
> submission of the S+C Grants Inventory Worksheet, they should be
> listed as the one consolidated grant for 2007. HUD encourages the
> consolidation of appropriate S+C renewal grants when the grants are
> under the same grantee, same component and expire in the same year.
> However, renewal requests for expiring S+C grants that have not been
> consolidated should still be submitted as separate Exhibit 2's in
> *e-snaps* and will be awarded as individual renewal grants. Where the
> grantee wishes to consolidate the renewal grants, this action may be
> subsequently accomplished by the field office at the point of renewal
> grant agreement execution. The field office will receive instructions
> for this process in the S+C Operating Procedures guidance for 2008
> awards.
>
> ***[Chronic Initiatives]{.underline}***

**17. My project was initially awarded funds through a separate
competition (e.g. the Collaborative Initiative to End Chronic
Homelessness, Ending Chronic Homelessness Through Employment and
Housing, or Housing for People who are Homeless and Addicted to Alcohol)
and is now eligible (i.e., expires in 2009) for renewal through the
Continuum of Care process. How will the CoC determine the priority of
this project for renewal?**

The need for the continuation of any previously funded project - whether
funded initially through the CoC competition or a special initiative --
is determined by the localities through its CoC planning process. The
CoC should review each project at the time it seeks renewal to determine
if the project is performing satisfactorily and if it still meets the
needs of the chronically homeless persons it proposed to serve.
Placement of the project on the CoC Project Priority list is based on
the local jurisdictions' planning/prioritization process.

**18. Under the Housing for People who are Homeless and Addicted to
Alcohol competition, supportive services costs could be no more than 5%
of the grant. Does this limit still apply, or can I ask for additional
supportive services for the participants in my permanent supportive**
**housing project?**

In this instance, the supportive services costs for the renewal project
should be no more than 5% of the grant. Any changes to this amount will
need to be negotiated through the local HUD Field Office after the
renewal is conditionally awarded funds.

19. **If my project was funded under a special initiative, how much
    money can I request for a renewal?**

Renewal funds can only be requested for continuing a previously approved
project at the same level of housing and/or services provided in the
previous grant. These grants originally allowed leasing, housing search
(supportive service) and administration. Upon renewal of this project,
the SHP requirements for match will be in effect. Under the CoC
competition, supportive services match requirement apply.

O.  **[Homeless Management Information Systems (HMIS)]{.underline}**

**1. What is a Homeless Management Information System (HMIS) and how can
communities use HUD competitive funds to develop them?**

A number of communities and states have a long-standing comprehensive
HMIS that brings computer technology to client intake procedures and
permit the tracking and reporting of a client's use of shelter and
social services over time. Many other communities are in various stages
of implementing such client-level systems. Beginning in 2001, HMIS
activities became eligible under SHP to help facilitate the
implementation and operation of a CoC-wide HMIS. The HMIS match
requirement applies to HMIS activities.

2.  **What elements of an HMIS are eligible for funding in the
    competition?**

    The law specifies that the costs of implementing and operating an
    HMIS are eligible. The three major eligible HMIS costs are: 1)
    purchasing HMIS software; 2) leasing or purchasing needed computer
    equipment for providers and the central server; and 3) staffing
    associated with operating the HMIS, including training providers,
    day-to-day administration of the HMIS, analyzing HMIS data and
    preparing reports for providers, the continuum and HUD using HMIS
    data.

    HMIS funds contained in the Training and Technical Assistance line
    item of the HMIS budget may be used for travel, hotel, and per diem
    costs associated with the provision of technical assistance and
    training sessions by local HMIS staff; attendance at training
    sessions provided by local HMIS staff and/or outside trainers;
    attendance at HUD-sponsored HMIS training sessions or symposiums;
    attendance at HMIS vendor-sponsor meetings; and attendance at other
    HMIS-related evens as qualified and pre-approved by HUD
    Headquarters. Applicants may be asked to identify the number and
    type of HMIS training sessions for which they are requesting SHP
    funds prior to grant agreement. The approved budget will be limited
    to the reasonableness of travel expenses as listed in 24 CFR Parts
    84 and 85.

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3.  **What elements of an HMIS are not eligible?**

    Planning and development of HMIS systems are not eligible. Planning
    includes all costs incurred prior to implementation. In addition to
    planning activities, SHP funds may not be spent on the development
    of entirely new software systems. There are now sufficient vendors
    in the marketplace with quality software so that individual
    communities do not need to finance the development of new software.
    Finally, SHP funds may not be used to replace state and local
    government funding for an existing HMIS.

4.  **Is HMIS a separate eligible funded activity?**

    Yes. Dedicated HMIS projects are categorized as their own type or
    component, and they have a separate budget line item in the SHP
    project budget summary.

5.  **Will HMIS projects count against my housing total in the Continuum
    of Care exhibit when calculating the "Housing Emphasis" points?**

> No. HMIS is a line item this year that is separate and apart from
> supportive services. Only housing activities and supportive services
> are used in calculating the "Housing Emphasis" points. As such, HMIS
> requests will not be included in this calculation.

6.  **How can we use HUD McKinney-Vento competitive funds to implement
    and operate a community-wide HMIS?**

> Beginning in 2008, HUD will only allow one applicant for dedicated
> HMIS projects. This requirement only applies to dedicated HMIS
> projects and does not apply to non-HMIS dedicated projects that
> contain HMIS costs. Additionally, CoCs will be able to use the
> reallocation process to create new dedicated HMIS projects. The CoC is
> responsible for HMIS software selection, implementation and
> administration. Through its planning process, the CoC will make the
> determination of whether or not a new dedicated HMIS is warranted and
> which renewal projects will be reduced or eliminated to provide
> funding for a new HMIS project.

The reallocation option is being offered in an effort to assist the CoC
in better managing and centralizing all HMIS activities in its CoC-wide
system into one dedicated HMIS project. This option will allow CoCs to
remove the HMIS line items from the non-dedicated HMIS projects and
consolidate these costs into a new dedicated HMIS project. If an
existing dedicated HMIS project already exists within a CoC, that
provider must also be the applicant for the new reallocated project,
which will serve as an expansion of the existing project.

The classification of dedicated HMIS projects as their own component is
shown in the Exhibit 2. In the past, HMIS projects were classified as
SSO projects. In order to accurately portray the purpose of these
projects, they will be categorized independently from SSO projects. If
your project was funded as an SSO HMIS and you are requesting renewal
funding, you should classify your project as an HMIS, not an SSO
project.

7.  **What standards will be used for assessing the cost-effectiveness
    of a proposed new or expanded HMIS?**

> HUD has not placed any limits on the size of the grant to fund a new
> or expanded HMIS, given the different number and size of homeless
> providers, the size of the geography involved, and the varying
> administrative arrangements required for implementing and operating a
> CoC-wide HMIS. However, HUD will look at the scope and reasonableness
> of the proposed activities compared to other communities in the
> cost-effectiveness review.

8.  **How do I shift *existing HMIS shared costs* from the current
    supportive services budget to the new HMIS budget?**

> If the renewal applicant merely wants to shift the existing HMIS
> activities from the supportive services category to the new HMIS
> activity in the renewal application submission, it does not need to
> obtain a grant amendment or approval from the Field Office. This is
> because HUD has reclassified HMIS costs from the former supportive
> service category to a new, stand-alone HMIS category. You need to
> briefly describe the change in Exhibit 2.

9.  **Can HMIS costs be shifted within the existing grant amount? For
    example, in the initial grant we had one time costs for computers,
    etc. and we now need to spend additional money for training.**

> Yes, you may shift costs to other line items if they are reasonable
> and necessary to install the HMIS and operate it. Examples of reasons
> this may be necessary are if you have new providers coming into the
> system and need to purchase new licenses or should you find you need
> additional staff training resources. These could be added if
> reasonable. However, you cannot increase the amount of the overall
> renewal grant. If additional funds are needed for the project, you
> would have to propose a new expansion project or have your providers
> use the shared cost option. You need to briefly describe the change in
> Exhibit 2.

10. **We have several transitional housing projects up for renewal, and
    we would like to request funding for HMIS activities. Since there is
    no dedicated source of funding for HMIS activities, we are assuming
    that we can shift funds from an existing project budget (such as
    supportive services) into a new HMIS budget, to pay for equipment
    and salaries for HMIS activities. Can we shift funds out of a
    renewal project's supportive services budget into a new HMIS budget
    in the same project?**

> Yes, SHP renewals seeking to add new HMIS shared costs can shift
> funds. If the renewal applicant merely wants to shift the existing
> supportive services and/or operations activities, Field Office
> approval is not needed if the amount is less than 10 percent of either
> the supportive services or operations activities. The change may be
> made in the application. If the amount exceeds 10 percent of either
> activity, then the Field Office must approve the change through a
> grant amendment. In either case, the proposed change must be described
> in Exhibit 2.

11. **Who is responsible for implementing the HMIS, is it the Continuum
    of Care (CoC), the HMIS administering agency or the
    applicant/sponsor of a SHP Dedicated HMIS project grant?**

> The CoC is at the core of planning and service delivery for homeless
> individuals and families within any given community or geographic
> area. Each CoC is responsible for HMIS implementation, including
> planning, software selection, setting up and managing the database
> according to HUD standards.
>
> HUD will only allow one applicant for dedicated HMIS projects. The
> HMIS administering agency and/or the applicant /sponsor of a SHP
> Dedicated HMIS project grant is an agent of the CoC, manages HMIS
> operations on behalf of the CoC and provides HMIS administration
> functions at the direction of the CoC. Through the experience of
> successful HMIS implementations, we have learned that active
> participation by CoC members, either through Committee/sub-committee
> structure or other meetings, in the management of the HMIS process,
> including establishing policies, procedures and protocols for privacy,
> data sharing protocols, data analysis, reporting, data
> integrity/validity, etc. are essential to the viability and success of
> the HMIS.

P.  **[Performance]{.underline}**

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1.  **Do those Supportive Services Only (SSO) projects that are exempted
    from Question 11 in the APR have to be included in the Exhibit 1, on
    screen 4D. Mainstream Programs and Employment Information?**

> No, SSO outreach, hotline, transportation, medical, dental, and other
> **single, short duration services projects** do not need to be
> included in the Exhibit 1 in *e-snaps*, on screen 4D. Mainstream
> Programs and Employment Information. In the APR under
>
> "Special Instruction for Supportive Service Only Projects" these types
> of SSOs are allowed to skip to the applicable APR question. For these
> types of SSOs it is expected to have no data (zeros) in all parts of
> that question and therefore these zeros would have no effect to the
> totals in the Mainstream Programs and Employment Information screen.
> Many SSO projects, however, may collect these numbers, and report on
> this question in the APR.

**2. For renewal projects in a CoC that did not report on the new APR,
can another source for information be used?**

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