Cancelling the 2020 Continuum of Care Notice of Funding Availability

U.S. House bill: H.R. 6800 — The Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act

Committees:

House Appropriations Committee

Status:

The bill was passed by the House on May 15, 2020.

Impact

Sentiment continues to grow that there should NOT be a Continuum of Care (CoC) Notice of Funding Availability (NoFA) in 2020 in order to allow CoCs to focus on meeting the daunting challenge posed by the COVID-19 pandemic.  Instead, next year’s money should be distributed to the same grantees which won awards in 2019.   

And the House Democratic leadership agreed, including language in The HEROES Act (H.R. 6800), which would do just that.  The House Democratic leadership, at the urging of House Financial Services Committee Chairwoman Maxine Waters (D-CA-43), included language in the Heroes Act, which would cancel the 2020 CoC NoFA and award the 2020 funding to 2019 grantees.  

This provision has a long way to go before it can become law.  It reamins to be seen if cancelling the 2020 NoFA will be opposed by Senate Republicans.  Indeed, their position will likely depend on the position the Department of Housing and Urban Development (HUD) decides to take on the cancellation provision. 

HUD’s Congressional affairs office told a friendly lawmaker’s office in late March: “The Office of Community Planning and Development has received this suggestion (i.e., cancellation) from a number of stakeholders and is evaluating it along with other options to best meet the needs of the homeless community and service providers during the COVID-19 response.” 

The Alliance has heard from providers across the nation–rural, suburban, and urban–that running a NoFA during these extraordinary times doesn’t make any sense.  In providing $4 billion in homelessness funding with new flexibilities, Congress made it clear that CoCs are expected to get the job done, rather than fritter away time cutting through red tape.  Moreover, HUD’s own staff is likely to be stretched extremely thin in providing guidance to CoCs and others in using stimulus funding wisely. 

The Alliance is assisting folks in the field who believe that the NOFA should be cancelled so that the homeless system can focus exclusively on serving clients.  

On April 8, 2020, Nan Roman, the Alliance’s President and CEO, presented NAEH’s own letter in support of a cancellation of the 2020 CoC NoFA to Secretary Carson’s Chief of Staff, who promised to bring it up with his boss.  The consensus is that, given constraints on HUD’s resources, there is no guarantee that a 2020 NoFA would be completed in time to prevent interruptions in funding. 

And here is the Alliance’s letter:

Secy Carson re NOFA

Summary

The House Democratic leadership, at the urging of House Financial Services Committee Chairwoman Maxine Waters (D-CA-43), included language in The Heroes Act which would cancel the 2020 CoC NoFA and award the 2020 funding to 2019 grantees.  But this is only the first step of the process.  It is not clear whether HUD will oppose cancellation.  The position of Senate Republicans will likely be heavily influenced by the position taken by the Administration.  It’s up to the Alliance and the providers with whom it works to make sure Republican Senators understand that the exhausting and exhaustive NoFA process should not be conducted during a pandemic.

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