Grantwriting help series: HUD's confusing Continuum of Care (CCC) system explained
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HUD just released the FY ’13 Continuum of Care (CoC) Program NOFA, with $1.6 billion available for an array of housing and related services for the homeless. But the process of trying to access that money is deliberately confusing. We’re going to explain how it works in this post, mostly for our own amusement but also in an attempt to educate readers.
“CoC” is the acronym for the federal Continuum of Care program. But “CoC” is also the acronym used for local Continuum of Care programs, as well as local or regional Continuum of Care bodies. To access federal CoC grant funds to help implement the local CoC program, potential applicants—like garden-variety nonprofits—have to go through the local CoC body, which is usually a joint powers authority set up to access federal CoC dollars by local governments, or, in some cases, the state itself. That’s a lot of CoCs, any way you look at it.
Since there is no shortage of acronyms, it would have been nice if the GS-15s at HUD had done a little CoC differentiation to reduce the confusion. Regardless of the nomenclature confusion, most nonprofit or public agencies (which are eligible CoC grantees) cannot apply directly to HUD. Rather, the CoC application has to be first submitted to the local CoC and approved for inclusion in the master CoC application sent in by the CoC.*
Astute readers who know anything about bureaucratic processes are now thinking that the CoC local body system created by HUD sounds like a recipe for confusion and potential collusion, at best.
Those readers are correct. The CoC system has become, in effect, a cartel, with each local CoC able to encourage local providers it likes and discourage ones it doesn’t like, or discourage ones that are not part of the current service delivery system. HUD has in effect created a class of self-perpetuating apparatchiks. This is the flip-side of mandating collaboration: your putative collaborators can easily take you out at the kneecaps, and it’s an example of the problems we’ve written about in “What Exactly Is the Point of Collaboration in Grant Proposals?” and “Following up on Collaboration in Proposals and How to Respond to RFPs Demanding It.”
The fundamental problem here is that the local CoC can stifle subsidiary organizations, and that stifling is mandated by the CoC NOFA itself:
24 CFR 578.9 requires CoCs to design, operate, and follow a collaborative process for the development of an application in response to a NOFA issued by HUD. As part of this collaborative process, CoCs should implement internal competition deadlines to ensure transparency and fairness at the local level.
If you, a potential applicant, didn’t hear about the “internal competition deadline,” you can’t apply. And those deadlines aren’t published in any regularized way or forum, like, say, the Federal Register. Because you have to do the local submission to be part of the CoC’s HUD submission, it makes it more complicated for a garden variety nonprofit to get a CoC grant. Though we’d definitely be interested in working for some malcontent organization that wants to submit a local proposal at the risk of rejection, then appeal to HUD with a claim that the local organization is failing to perform its duties, no one has called us with this proposition yet, though the situation is probably common in the CoC / homeless services world. These are the kinds of stories that, if we had any real reporters left in America, would be covered in the media.
We have some history with CoC, which was originally part of the Reagan era McKinney-Vento Homeless Assistance Act.” Congress passed it in 1987. The original CoC program consisted of three separate grant programs: the Supportive Housing Program, the Shelter Plus Care Program, and the Single Room Occupancy Program. When Seliger + Associates was getting started, one of the first funded proposals we wrote was a $3,000,000 Supportive Housing grant for a nonprofit in Northern California. This was a direct HUD submission, as it was before the local CoC body infrastructure was created.
For reasons that are not clear to us, during the tenure of Andrew Cuomo, or Frankenstein as we used to refer to him around the office because of his uncanny resemblance to our bolt-necked friend, these programs were pumped up as part of Clinton-era response to the “homeless problem” of that time and the CoC system was birthed. As a result, a new layer of bureaucracy began to be consolidated, running parallel to the city, county or state level (in this respect, CoCs are a bit like Community Action Agencies).
We’ve interacted with this new layer of bureaucracy. Although we have written CoC applications in many states, we are most familiar with Los Angeles’s CoC—the Los Angeles Homeless Services Authority (LAHSA). This bureaucratic gem sprung forth fully grown from LA City and County at the behest of HUD about 15 years ago like Athena from the head of Zeus. It now has a $73,000,000 budget and over 100 steely-eyed bureaucrats, but LAHSA is virtually unknown outside of the homeless services provider community.
When HUD changed the rules, there had to be a Continuum of Care Plan for a local area in order for an applicant to be eligible (LAHSA is in charge of the plan in most of L.A. County). And the applicant had to fit into the Plan. Isaac actually wrote a nominal statewide Continuum of Care Plan for Arkansas around 1997 for a housing authority applicant, because Arkansas didn’t want to do one, but our client couldn’t apply without one. So, we just wrote a CoC Plan to enable our client to apply.
Eventually, the local-level CoCs got consolidated in the late 1990s. Unfortunately, if you weren’t part of the Continuum of Care syndicate in the mid-90s, you might still not be. But almost no one understands this, and the only people who do are the people working for the local CoCs. In the case of LAHSA, only three of of the 88 municipalities in Los Angeles County—Long Beach, Glendale, and Pasadena—have opted out of LHASA and have their own CoC bodies. In Pasadena, it’s the Pasadena Housing and Homeless Network. We assume an interest in the administrative overhead that is gleaned from being designated as a CoC has something to do with the three LAHSA outliers in the LA County CoC ecosystem.
By now, CoC operates somewhat like passthrough funds, except that it isn’t part of the two other federal Block Grant systems: Community Development Block Grant (CDBG) from HUD and the Community Services Block Grant (CSBG) from the Office of Community Services (OCS).
This raises the obvious question: Why isn’t the CoC grant program part of either CDBG or CSBG? For example, every jurisdiction that receives a CDBG Block Grant must prepare a Consolidated Plan every five years, with annual Action Plan updates. If you browse through any Consolidated Plan, you’ll notice an emphasis on homelessness and homeless programs. But, instead of using the existing system, a parallel system has been legislated into existence, with the usual set of costs and confusions. This post is designed to dispel some of the confusions. But we don’t have the power to dispel the costs.
* I wrote this sentence to see how many times I could work “CoC” into it.