1. Reallocation and Prioritization
Indianapolis COC webinar

2. Call to Action of the HEARTH Act
“Transform homeless services into
crisis response systems
that prevent homelessness
and rapidly return people
who experience homelessness
to stable housing.”

3. No person or family homeless more than 30 days
Federal Goal
No person or family homeless more than 30 days
Federal goal in HEARTH

4. Strategy Shift Required
Program centric System:
“Should we accept this household into our program?” 
Client centric/ System Driven:
“What housing /service assistance is best for each household and quickly ends their housing crisis permanently?”
Program-Centric
Unique forms and assessment processes to each organization
Does not necessarily ensure match between need and service received
Uneven knowledge about available housing and service interventions in the CoC
Client-Centric and System Driven
Standard forms and assessment processes used by every program for every client
Coordinated referral process across the CoC
Accessible information about available housing and service interventions in the CoC
HEARTH act, system performance and coordinated entry requires a strategy shift from thinking and asking “should this person be accepted into our program” to “what assistance is best for each household and what ends their housing crisis quickly and permanently”

5. Understand the Components
Very Vulnerable, chronically homeless
PSH
Non-disabled, high barrier
Requiring structured treatment TH
Most homeless families
Newly homeless
RRH
Target those at-risk who actually enter system
Prevention
Interim housing <30 days while waiting for Housing ES
Program components- we know now through research and study what interventions generally work best for the various segments that make up the homeless population. We target specific interventions for the populations that they work well for, give their unique characteristics.

6. HUD Performance Measures
Reduce length of homelessness
Reduce the number who become homeless
Reduce return to homelessness
Reduce overall homelessness
Increase jobs and income
Other accomplishments
Thoroughness in reaching homeless population
LOT, total # of people, recidivism, overall # of people experiencing hmlsns, other goals that you may want to work toward- veterans, CH- thoroughness- outreach, coverage, working as a system and active list/case conferencing processes
This is what communities are being measured on, as well as many other elements of sys performance (which we will talk about more on Thursday)

7. Look at your system as a whole
“Analyze your portfolio of grants to determine if you have the right mix of housing and services to meet the needs of the homeless households that present for assistance. CoCs should begin considering whether funding for some projects, in whole or in part, should be reallocated to make resources available for new efforts.” -Ann Oliva, Asst. Deputy Sec.- HUD

8. Reallocation
Reallocation refers to the process by which a CoC shifts funds in whole or in part from existing CoC–funded projects that are eligible for renewal to create one or more new projects.

9. What can a COC reallocate?
Can reallocate all or part of projects

10. Reallocation
FROM: Permanent Housing Transitional Housing Supportive Services Only
TO: Permanent housing HMIS Coordinated Assessment (if reallocating from SSO)

11. What qualifies?
A reallocated project must be a new project that serves new participants and has either a rapid re-housing or permanent supportive housing program design.
A new reallocated project may use resources from an existing project, including staff, but it is not simply a continuation of an existing project that serves existing participants
NOFA determines what is permissible for reallocation.

12. Reallocation pluses
Benefit of Reallocation--allows you to create a new project that is treated like a renewal for scoring purposes.

13. Reallocation Process
Contact your Collaborative Applicant (CoC Lead Agency)
Contact Your Field Office
-Before the NOFA Is Published, Read Instructions From Previous NOFA and Other Guidance From HUD
-After the NOFA Is Published, Read the NOFA Carefully (Obviously)
Identify Potential Reallocation Projects During the Registration Process
Can develop a process to have agencies volunteer for reallocation as a first step, define what new projects should include, target populations, etc.

14. 2 ways changes can be made to programs
Reallocation- only done during open COC competition period
Repurposing- Happens any time of year through grant amendment
Most HUD FO will ask that amendments not be attempted during the open COC competition and application however.

15. 2 ways changes can be made to programs
Reallocation
Can change program types
Significantly change population targeted
Repurposing
Can make minor changes to program to make it more effective

16. Other ways to make project changes
Can make through grant amendment:
PSH shifting funds within the grant from services costs to rental assistance costs to serve more people
TH project wants to reduce the length of time they serve people in the project from 24 months to 6 months (e.g.)

17. What cannot be done through grant amendment?
Changing a project type or component such as TH changing to PSH
Major population changes such as moving from serving families with children to those that experience chronic homelessness
That is considered a major change and would possibly affect the scoring when the project was awarded funding.

18. Considerations in Reallocation
Does this project help the community perform well on the HEARTH performance measures?
Projects not only need to perform on their own, they need to perform as a whole and help the system improve, be effective –meets the needs of the individuals and score well as part of the system. Are they in keeping with best practices- serving those most in need, low barrier, housing first, etc.?

19. Should this project be reallocated?
Does the project:
Return funding?
Draw down on a quarterly basis?
Has it had HUD monitoring findings or concerns?

20. Should this project be reallocated?
Does it meet community needs?
Is there another way to fund this?
Is it better than the alternatives?
Determine what your data and analysis are telling you about the needs in the community- where are the gaps? What is missing and how would the system be improved with another type of program?

21. Theoretical examples of reallocation
Convert underperforming Permanent housing projects
Create a Coordinated Access/Entry Process by reallocating an SSO
Can convert all or parts of projects

22. Theoretical examples of reallocation
Convert Transitional Housing
Convert SSO projects

23. Clear Metrics
Becoming more data driven as an industry- Using HMIS data to help make decisions

24. Prioritization

25. HUD Prioritization notice
HUD Prioritization notice and FAQ on HUD exchange.info CPD notices, 2014
Under resources/documents/CPD

26. What is Prioritization?
From Merriam Webster dictionary:
to organize (things) so that the most important thing is done or dealt with first
to make (something) the most important thing in a group

27. HUD’s goals on Prioritization
1. Establish an order of priority for dedicated and prioritized PSH beds, which CoCs are encouraged to adopt, to ensure that those persons with the most severe service needs are given first priority.
HUD goals for the COC program

28. HUD’s goals on Prioritization
2. Inform the selection process for PSH assistance not dedicated or prioritized for chronic homelessness to prioritize persons who do not yet meet the definition of chronic homelessness but are most at risk of becoming chronically homeless.

29. HUD’s goals on Prioritization
3. Provide uniform recordkeeping requirements for all recipients of CoC Program-funded PSH for documenting chronically homeless status of program participants when required to do so, as well as provide guidance on recommended documentation standards that CoCs may require of its recipients of CoC Program-funded PSH if the priorities included in the Notice are adopted by the CoC.

30. Dedicated vs. Prioritized
Dedicated PSH
A PSH bed is considered to be “dedicated” when the project recipient has committed to exclusively serving the persons experiencing chronic homelessness for the duration of the grant. Usually through the COC application process NOFA, as part of a requirement or not.
A CoC Program-funded PSH project with beds that are specifically targeted to
persons experiencing chronic homelessness are considered to be either dedicated or prioritized.
Samaritan bonus is an example of required PSH that was required to be dedicated. Other years it was the bonus that specified.

31. Dedicated vs. Prioritized
Prioritized PSH
A PSH bed is considered to be “prioritized” when a project recipient has prioritized persons experiencing chronic homelessness in some or all of its beds even though this was not the target population identified in the original project application.
In FY13 and going forward, the COC program application allowed for a field that asked if beds were prioritized for a CH target population and that info was incorporated into the grant agreement. Recipients are able to prioritize more than the number stated in the application as part of the ongoing work without a grant amendment, but cannot do less than that.

32. Ways to Prioritize
There are two significant ways in which CoCs can increase progress towards ending chronic homelessness in their communities using only their existing CoC Program-funded PSH:
Increase the number of CoC Program-funded PSH beds that are dedicated to persons experiencing chronic homelessness.
Prioritize non-dedicated PSH beds for use by persons experiencing chronic homelessness.

33. Best practice - Prioritization
HUD strongly encourages CoCs to incorporate the orders of priority described in the Prioritization Notice into their written standards.
Don’t have to follow line by line the order in HUD’s notice, but the COC should have it in their written standards for all COC funded and community partner agencies to follow. The notice and FAQ lay out the order of priority for dedicated, prioritized and all other COC funded PSH- generally after CH status, the priority is placed on eligibility for PSH- disability, length of time homeless, severity of service needs. The FAQ includes some charts that are helpful to visually see the categories. As well, HUD considers best practice to also be evidence of standardized assessment tools, evidence that written standards are incorporated into CE policies and procedures

34. How do you factor in Veterans?
Prioritize Veterans not eligible for VA housing (VASH) and services
Prioritize Veteran households over others if both fall under the same order of priority (i.e., both are CH, or homeless with severe service needs)
CoCs and CoC Program-funded PSH projects targeting homeless veterans should generally prioritize homeless veterans that are not eligible for VA housing and services.
Further, where CoCs have adopted the orders of priority described in the Prioritization Notice, HUD encourages CoCs to further prioritize veteran households. Essentially this means that if two households present for assistance and both fall under the same
order of priority (i.e. both chronically homeless and fall under order of priority number 1 for dedicated and prioritized PSH) but one is a veteran household and the other is not, the veteran household should be prioritized first.

35. What about Wait lists? Tools?
COCs are encouraged to use a single referral process along with CE
Adopt policies on CE, referrals through the COC governance charter
Wait Lists are generally discouraged at the project level (unless required by another source of funding). HUD is working with other programs (HOME) on this
Assessment tools are one piece of info, but should not be used exclusively or in isolation of prioritization policies
This is a simplification on these topics and you are urged to look at the notice and FAQ for more info, especially if you have other funding in your project like HOME that requires a chronological wait list- guidance is there.

36. Questions What does that look like?
What do you think of this indicator?
Can your housing do it?
Is participation in services in any type of agreement at your housing?
What does that look like?
What happens when someone breaks that agreement?
If you don’t have an agreement, how do you get people to participate?

37. Resources