Creating and Managing a Continuum of Care

1. Creating and Managing a Continuum of Care What to Know About Creating a New CoC Through a CoC Split

2. About HomeBase Nora Lally and MattOlsson work as HUD technical assistance providers for HomeBase, a San Francisco-based nonprofit public interest firm dedicated to the social problem of homelessness. HomeBase works at the federal, state, and local levels to support communities address the root socioeconomic causes of homelessness and implement effective housing and service interventions.

3. Impacts of a CoC Split Potential benefits: • Improved local control and coordination regarding the community’s response to homelessness (i.e., program types, funding decisions, coordinated entry priorities, etc.) • Ensure funding stays local • Increased competitiveness (potentially) Potential drawbacks of dividing a CoC into more than one Continuum include: • Reduced regional coordination • Reduced economies of scale • Diminished capacity and competitiveness • Difficulty separating HMIS • Potential imbalance of program types • Reduced funding • Necessary to establish new coordinated entry system

4. Process • Newly formed CoCs are finalized through the CoC Program Competition Registration process, but require considerable planning beforehand. • HUD considers merger requests during the CoC Program Registration process, but not later than 5 days before the end of the CoC Program Registration. • Any changes now would impact FY2020 NOFA (or later) • For SNAPS to acknowledge a CoC split, • The jurisdiction(s) for the new CoC must document a formal vote by the stakeholders that will compose the CoC (this is more than a vote by elected officials).   • The new CoCs must demonstrate that it notified the existing CoC of its intent to split (this is a minimum requirement – HUD expects that there will be many conversations with the CoC prior to making this decision).   • The new CoCs must submit a governance charter that documents the new CoC’s governance structure and shows compliance with the CoC Program Interim Rule (24 CFR 578.7).   • The new CoCs must submit evidence of an operating Homeless Management Information System (HMIS) that is consistent with HUD’s most recent HMIS data standards, and • The new CoCs must provide evidence of efforts to establish a coordinated entry.

5. Basic Timeline Transitional Body The new CoC should develop a representative transitional body to investigate the merits and logistics of creating a new Continuum of Care, including the various elements of this basic timeline

6. Basic Timeline Transitional Body Consult The stakeholders that plan on participating in the new Continuum of Care (CoC) should hold a first vote to approve the investigation of a new CoC and maintain evidence of this vote (through meeting minutes) If the transitional body’s investigation results in a recommendation to split from the CoC, the stakeholders in the new CoC should hold another vote to approve the formation of a new CoC and maintain evidence of this vote (through meeting minutes)

7. Basic Timeline Transitional Body Notify Consult Thenew CoC should notify the existing Continuum of Care of its intent to form a new Continuum of Care and maintain evidence of this communication

8. Basic Timeline Transitional Body Notify Charter Consult Prior to completion of a CoC split, the new CoC should develop a governance charter to manage the CoC, including (at a minimum): • The jurisdictions included within the new Continuum of Care • All other required components of a CoC Governance Charter

9. Basic Timeline Transitional Body Notify Charter HMIS Consult Prior to completion of a CoC split, the new CoC should have a new HMIS in place to manage the CoC’s data needs, including (at a minimum): • The HMIS Policies and Procedures that will govern the new CoC’s HMIS data • Identification of the HMIS vendor and HMIS Lead (can be a transitional entity until an RFP is issued or an interim agency until a selection process can be followed) • Documentation of a selection process for a new HMIS Lead (can be contained in the CoC Governance Charter) • The ability to draw data from the previous HMIS (can be either an MOU or direct administrative access) • The ability to run system performance measures for the new CoC in the upcoming CoC Program Competition

10. Basic Timeline Transitional Body Notify Charter HMIS CES Consult The new CoC should take steps to implement a new coordinated entry system for the Continuum of Care and maintain evidence of this effort (e.g., within the Governance Charter, by assigning staff to ensure implementation, etc.)

11. Potential Impacts of a Split on Balance of State CoC • Reduction in Annual Renewal Demand (ARD) tied to any projects that choose to go to the new CoC • The decreased ARD also decreases a CoC’s available CoC Planning amount and any new funding that is based on the ARD amount(e.g., Permanent Housing Bonus) • Possible adjustments to coordinated entry • Governance/committee membership changes

12. FOR HUD to acknowledge a CoC SPLIT • The jurisdiction(s) for the new CoC must document a formal vote by the stakeholders that will compose the CoC (this is more than a vote by elected officials).   • The new CoCs must demonstrate that it notified the existing CoC of its intent to split (this is a minimum requirement – HUD expects that there will be many conversations with the CoC prior to making this decision).   • The new CoCs must submit a governance charter that documents the new CoC’s governance structure and shows compliance with the CoC Program Interim Rule (24 CFR 578.7).   • The new CoCs must submit evidence of an operating Homeless Management Information System (HMIS) that is consistent with HUD’s most recent HMIS data standards, and • The new CoCs must provide evidence of efforts to establish a coordinated entry.