Last week, the U.S. Department of Housing and Urban Development (HUD) posted the 2019 CoC Program Notice of Funding Availability (NOFA), and, like many of you, the Alliance staff spent a good portion of the holiday weekend reviewing it to see how it will impact our work to end homelessness.
The programs funded by this NOFA continue to be our most important tools for building local systems that identify everyone who becomes homeless, keeps them safe, and helps them get back into housing quickly. In the coming weeks, the Alliance will release resources on the NOFA, but here’s an overview of key issues.
Some aspects of the NOFA have people wondering about the importance of Housing First. Housing First is still the primary approach recommended for the interventions that provide homeless assistance. It’s important to be specific about what points are available for which practices.
Most importantly, HUD continues to give better scores to Continuums of Care (CoCs) and recipients that use Housing First principles. In particular, HUD incentivizes reducing barriers to entry throughout the NOFA, which allows people to access housing and other services without preconditions. This remains a major opportunity for applicants to be more competitive. Under the Alliance’s view, that’s one of the most important aspect of Housing First and communities can (and should) continue to operate projects under a Housing First approach.
It’s also worth noting that HUD has established a new priority on using evidence-based approaches in the new NOFA. Of course, Housing First is among the very most thoroughly established examples of an evidence-based approach to ending homelessness.
What About Service Participation Requirements?
It is true that HUD has granted some flexibility to CoCs and providers that wish to add service participation requirements for people who are stably housed in Housing First programs.
There are three important points on this:
- Requiring service participation that results in people exiting the program to homelessness will harm your system performance. When people fail in housing, they become homeless again. And that means that your system is failing. Systemwide performance measures, including returns to homelessness, will be more and more important in future years so programs that evict people will not be helpful to your community’s score or efforts in ending homelessness overall.
- There are no direct points to be earned by doing this.
- In light of HUD’s priority on evidence-based practices, we remind everyone that there is no evidence to support the use of compulsory service requirements. In fact, the evidence shows that people are more likely to succeed when they can choose the services that they want, and that they are more likely to fail when they are forced to participate in services they don’t want.
Suffice it to say, the Alliance doesn’t see an upside to imposing mandatory service requirements.
This year, there is a strong emphasis on employment strategies. This is a newer policy emphasis for HUD, and it focuses on establishing connections to help households increase income so that they can afford stable housing.
This is not the same as arbitrary work requirements, which have proven ineffective. In a best case scenario, this represents an opportunity to keep people stably housed, build more effective partnerships with workforce investment boards, and generally has the potential to boost systems collaboration and performance, as well as income for participants.
The Alliance noted with disappointment – as did many of you – that this year’s NOFA removes specific incentives for partnering with LGBTQ-serving organizations. In fact, this year’s NOFA contains not one mention of LGBTQ populations.
Yet, the fact is that HUD’s Equal Access Rule remains in effect, and programs are still expected to be complaint with it. In fact, there are points to be lost for communities that are not ensuring equal access to HUD’s shelter and housing programs.
One of the more encouraging new developments this year is incentives for communities for addressing racial disparities in their systems. This has been a priority for the Alliance, and we encourage everyone to consult our new Racial Equity Network Toolkit as a resource in this effort.
While there are still points for reducing the number of people experiencing chronic homelessness, HUD will allow CoCs more flexibility to allocate Permanent Supportive Housing based on need, so that they have the option to target some people who might not meet the full definition of chronic homelessness, but face the highest vulnerability. Of course with this new flexibility, it will be essential that each community’s coordinated entry system is doing its part to ensure that people placed into PSH are truly those most in need. And the points for reducing chronic homelessness should keep communities focused on those who do have that combination of disabling condition and time spent homeless.
More to Come
Each of these points could be a blog post to itself, so, of course, there’s more to come. Please stay tuned as the Alliance continues to offer resources and guidance to help you submit a competitive application that will have the greatest possible impact.