Moving The Needle: Leveraging the CoC Program Competition NOFO for Justice and Equity

Ensuring the homeless system is just and equitable should be at the core of its design and infused through all aspects of year-round implementation and analysis.

The 2022 Continuum of Care (CoC) Program Competition Notice of Funding Opportunity (NOFO) continues the work of past NOFOs by incorporating equity as a top priority, evident by the increase of available points in the 2022 CoC NOFO. Historically, CoC NOFOs have encouraged communities to examine their disaggregated outcomes and identify policies and interventions that create disparate outcomes.

This year’s NOFO looks at moving beyond analysis toward identifying disparate outcomes, and toward making a meaningful impact and equitable implementation. This will ensure persons experiencing homelessness are provided with individualized resources, ensuring their experience is not compounded with overt or implicit racism.

Demonstrating Equity

As mentioned, the 2022 CoC NOFO continues to make equity one of its top priorities by giving a maximum of 9 points in the competition if you can demonstrate: Promoting Racial Equity in Homelessness Response (7 points) and Promoting Racial Equity in the Local CoC Process (2 points). See more specifics around how your CoC can demonstrate these priorities in your system below:

Promoting Racial Equity in Homelessness Response

Data analysis: Demonstrate how your system analyzed its data using either the U.S. Department of Housing and Urban Development (HUD)’s CoC Analysis Tool on Race and Ethnicity, the Alliance’s Racial Equity Network’s Toolkit, HUD’s Stella P, or other methods to analyze disaggregated Homeless Management Information System (HMIS) data. Ensure the review includes analysis of all program data points with an equity lens.

System examination: Understanding that structural racism permeates all institutions, we must examine our systems to find where attention should be focused. As a part of this response, CoCs must show the findings of their disaggregated system-wide analysis. With this analysis, communities should utilize an intersectional lens grounded in racial justice but guided by the understanding that holding multiple identities can increase vulnerability (e.g., disaggregating data by characteristics like race, disability status, LGBTQIA+, and age to identify disparities within your system).

Implementation: Unlike past years, the 2022 CoC NOFO prioritizes taking the step beyond analyzing data to actual implementation of its findings, and moving the needle to a more effective, efficient, and equitable system. Based on your findings, what actions have you taken? Here are a few examples:


  • Analyze internal decision making and power sharing by asking the questions:
    • Who is in leadership on the CoC governance board? Has the CoC taken steps to ensure the representation mirrors the individuals served?
    • How are the voices of individuals who are disproportionally overrepresented within the homeless population, and hold lived experience, being incorporated and/or uplifted in the system and program design?
  • Change policies/practices that have disparate impact. For example:
    • Remove criminal barriers to entry. Review or change existing practices, especially if bans or restrictions are in place.
    • Ensure street outreach includes zip codes that match the areas where individuals who disproportionally experience homelessness come from.
  • Investigate and implement changes to the CoC’s Coordinated Entry System with the following:
    • Examine and align your prioritization process by replacing or revising your prioritization tool or processes, if disparate outcomes are shown. Incorporate historically under-resourced communities in prioritization (e.g., incorporating zip codes or common themes based on your data analysis). Target ZIP codes that match the communities disproportionately impacted.
    • Demonstrate meaningful connections to providers who are embedded in the communities with found disparities (e.g., Urban Leagues, NAACP, sororities/fraternities, churches, YWCAs, ethnic or racially-specific organizations, etc.).

System and community goals: the CoC should ask itself:


  • How has this process been baked into your overall system analysis (not just CoC NOFO planning)?
  • Have you developed a diverse team of key community stakeholders focused on finding and addressing disparities?
  • Has there been a plan developed with time limited and measurable goals?
  • Has the CoC demonstrated ongoing education with a racial justice focus?

Here are some community examples of communities that have moved beyond the analysis stage. See the Alliance’s Racial Equity Network’s Action Steps for some additional steps that communities can use to demonstrate steps taken.

Promoting Racial Equity in the Local CoC Competition Process

  • Ask yourself who is at the table creating the rank and review process. Have your rating factors been developed with a racial equity lens? How is a program’s commitment to internal and external equity measured in the review process?
  • Does the rank and review committee represent the makeup of the individuals served in your system?
  • How does your review and rank process identify programs that:
    • effectively address barriers to cover historically underserved communities?
    • identify and address racial inequities both internally and externally (i.e. service delivery)?

Things to Keep in Mind

The CoC NOFO process is time-consuming – at a time when providers are already overstretched and exhausted. To ensure you make the most of your application (and the time spent completing it), keep these key points in mind while crafting your application:


  • Ensure you are not just checking a box; instead, ensure the commitment to equity and justice work is ongoing.
  • Answer all parts of the questions to ensure your CoC receives all points available.
  • Please read the entire CoC NOFO for more information.
  • Some of the information above will help you score well in other priorities that indirectly mention equity.
  • Any actions taken must be consistent with the federal nondiscrimination requirement.
  • Ensure individuals with lived experience are compensated for their time and experience and/or hired to be a part of the ongoing work.