I. Introduction and Background
A. Regulatory Mandate
The Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act of 2009 reauthorized the McKinney-Vento Homeless Assistance programs. Through the enactment of the HEARTH Act, the Department of Housing and Urban Development (HUD) published the new Continuum of Care (CoC) Program interim rule. The CoC Program interim rule requires that the CoC must establish and consistently follow written standards for providing CoC assistance, in consultation with recipients of the Emergency Solutions Grant program (ESG). At a minimum, these written standards must include:
Policies and procedures for evaluating individuals’ and families’ eligibility for assistance in the CoC Program
Policies and procedures for determining and prioritizing which eligible individuals and families will receive assistance for permanent supportive housing assistance, transitional housing assistance, and rapid re-housing assistance
B. Goals of the Written Standards
The South Carolina Upstate Continuum of Care recognizes and supports HUD’s goals for its local written standards and strives to meet its obligations under the HEARTH Act in a way that helps to enhance its systemic response to people. These standards hereby:
Establish community-wide expectations on the operations of projects within the community
Ensure that the system is transparent to users and operators
Establish a minimum set of standards and expectations in terms of the quality expected of projects
Make the local priorities transparent to recipients and subrecipients of funds and all community stakeholders
Create consistency and coordination between recipients' and subrecipients' projects within the Upstate CoC.
The Upstate CoC agrees that these standards must be applied consistently across the entire Upstate CoC defined geographic area while also taking into consideration individual county-specific needs and resources. Additionally, the Upstate CoC recipients and subrecipients agree to administer their assistance in compliance with the Upstate CoC written standards. Recipients and subrecipients of CoC and local funds may develop additional standards for administering program assistance, but these additional standards cannot be in conflict with those established by the Upstate CoC or the CoC Program interim rule. Other CoC providers and stakeholders are strongly encouraged to adopt the standards and practices discussed in this document.
Furthermore, these standards recognize the unique geography of the Upstate CoC and accommodate the unique needs and service availability of each respective county as well as the policy of allowing individuals and families choices in where and how they receive services and housing resources.
C. Guiding Principles
The Upstate CoC commits to the following Guiding Principles as part of its overall approach to ending and preventing homelessness throughout the CoC. This Guiding Principles shall inform all program and policy decisions of the CoC and its funded or affiliated housing and providers.
1. Housing First
Housing First is a programmatic and systems approach that centers on providing people who are homeless with housing quickly and then providing services as needed. Upstate CoC hereby implements a Housing First model that provides a range of housing services to persons experiencing or at-risk of homelessness, including outreach and engagement, emergency and transitional housing, rapid re- housing, homelessness prevention and permanent supportive housing. Through these standards, the Upstate CoC formally incorporates the Housing First approach as well as non-discrimination policies into the coordinated entry system and its funding priorities.
Housing is not contingent on compliance with services with the exception of program requirements for the rapid re-housing program that requires supportive services be provided at least once per month.
Participants are expected to comply with a standard lease or occupancy agreement and are provided with services and supports to help maintain housing and prevent eviction.
Services are provided in housing to promote housing stability and well-being.
All programs are expected to ensure low barriers to program entry for program participants.
The Upstate CoC commits to a policy of non-discrimination for all CoC projects and activities.
Elements of this principle include:
Providers must have non-discrimination policies in place and reach out to people least likely to engage in the homeless system.
Providers must comply with all federal statutes including the Fair Housing Act and the Americans with Disabilities Act.
Upstate CoC practices a person-centered model that strongly incorporates participant choice and inclusion of subpopulations present in Upstate CoC service area, including, but not limited to, homeless veterans, youth, families with children, and victims of domestic violence.
Upstate CoC is committed to abiding by the Equal Access to Housing in HUD Programs – Regardless of Sexual Orientation or Gender Identity Final Rule published in 2012 and the subsequent Final Rule under 24 CFR 5 General HUD Program Requirements; Waivers, September 2016.
3. Client Choice
Given the geography of the Upstate CoC, the CoC strives to ensure that clients seeking assistance are provided choice in the types and duration of services they receive, dependent on available resources. This choice is limited to the prioritization strategies outlined in this document, with fair discretion where possible. To the degree possible based on resources and the prioritization mechanisms described in this document, and where safety is not compromised, clients are given choice in:
The type of services they receive by whom and over what time period
The location and type of housing they access
The elements and goals of their housing stability plans
For the full Continuum of Care Written Standards please click here.
HUD Housing First
Housing First is a homeless assistance approach that prioritizes providing permanent housing to people experiencing homelessness, thus ending their homelessness and serving as a platform from which they can pursue personal goals and improve their quality of life. This approach is guided by the belief that people need basic necessities like food and a palce to live before attending to anything less critical.
Coordinated Entry System (CES)
The Coordinated Entry is a process designed to coordinate participant intake, assessment, provision of referrals and housing placement. It covers a geographic area, is easily accessed by individuals and families seeking housing services, is well advertised and includes a comprehensive and standard entry tool.
When implemented correctly, Coordinated Entry moves beyond the "first come, first served" approach to one that looks across the community to serve those in most need.
HUD Rent Reasonableness
HUD's rent reasonableness standard is designed to ensure that rents being paid are reasonable in relation to rents being charged for comparable unassisted units in the same market. Under the CoC Program, all units and structures for which rent is paid must be reasonable.
Monitoring Notification Letter
Please mail or email the following documents prior to the Continuum of Care Monitoring Committee's annual visit to perform on-site monitoring of programs funded under the CoC Program.
1. Letter certifying that Federal Funding either did or did not trigger the A-133 Audit requirements – letter should be signed by your Chief Financial Officer or your Executive Director
2. Copy of most recent audit, if applicable, or the 990 statement
3. Articles of Incorporation
4. Agency Bylaws
5. Current Roster of Board of Directors and each member’s duties
HUD CoC Monitoring Instrument
This is a MANDATORY review for Continuum of Care Program (CoC) grants. This Exhibit is divided into three sections: General Recordkeeping Requirements; Specific Recordkeeping Requirements for the Definition of Homeless; and Specific Recordkeeping Requirements for the Definition of At-Risk of Homelessness. It is intended to be used to determine whether the appropriate documentation has been maintained by a recipient/subrecipient and is designed to augment the review of the recipient’s or subrecipient’s projects to determine whether program participants’ eligibility has been adequately documented in terms of their homeless or at-risk of homelessness status upon entry into the program. This Exhibit is not intended to determine program participant eligibility. To determine whether an individual or family is eligible for a particular activity, the HUD reviewer must review the CoC Program regulation, the Fiscal Year (FY) Notice of Funds Availability (NOFA) under which the project was funded, the grant agreement, and the applicable written standards of the CoC.
To monitor this area:
1. Request a listing from the Homeless Management Information System (HMIS) of project program participants (current and former), including their entry dates.
2. Select a random sample from both current and former program participants (use items other than program participant names, i.e., initials, case file numbers; apartment numbers, to identify program participants).
3. Review these program participant files to complete the questions in this Exhibit, supplemented by recipient staff interviews.
The HUD reviewer is responsible for determining whether sufficient supporting documentation is included in or is missing from the program participant relevant files to support conclusions, including any finding(s) and/or concern(s) noted in the final monitoring report.
Upstate CoC Monitoring Policy and Procedure
This document outlines how CoC funded programs are monitored. According to HUD, the overriding goal of monitoring is to determine compliance, prevent/identify deficiencies and design corrective actions to improve or reinforce program participant performance. Monitoring also provides opportunities to identify program participant accomplishments as well as successful management/ implementation/evaluation techniques that might be replicated by other Community and Planning Development (CPD) program participants.
Please Note: The Written Standards is a working document and subject to change as necessary or appropriate to address changes indicated by the Department of Housing and Urban Development and the Upstate CoC.