How Many California Continuums of Care Demonstrated the Ability to Reallocate Lower Performing Projects to Create New Higher Performing Projects Based on Performance Review of Existing Projects?

-Table 1 Lists Those That Did and Those That Did Not-

As part of the 2018 Continuum of Care (CoC) Program competition, the U.S. Department of Housing and Urban Development (HUD) asked CoC applicants to

• “Demonstrate the ability to reallocate lower performing projects to create new higher performing projects that is based on performance review of existing projects;” and
• “To indicate whether the CoC has cumulatively reallocated at least 20 percent of the CoC’s ARD (Annual Renewal Demand) between the FY 2014 and FY 2018 CoC Program Competitions.

“Reallocation is a process that CoCs use to shift funds in whole or part from existing eligible renewal projects to create one or more new projects without decreasing the CoC’s ARD,” as defined in the 2018 CoC application.

Annual Renewal Demand (ARD) was defined in the 2018 CoC application as

“The total amount of all the CoC’s projects that will be eligible for renewal in the FY 2018 CoC Program Competition, before any required adjustments to funding for leasing, rental assistance, and operating budget line items based on FMR changes. The ARD will be calculated by combining the total amount of funds requested by eligible renewal projects on the Renewal Project Listing and the combined eligible renewal project amount(s) that were reallocated.”

Table 1 lists the response for each California CoC as to whether the CoC

• Demonstrated the ability to reallocate lower performing projects to create new higher performing projects that is based on performance review of existing projects; and/or
• cumulatively reallocated at least 20 percent of the CoC’s ARD between the FY 2014 and FY 2018 CoC Program Competitions. HUD stated that it will “verify the response to this question if applicants select Yes.”

Guidance from HUD concerning reallocation noted that

• “CoCs should use the reallocation process to create new projects that improve their overall performance and better respond to their needs;”
• “CoCs should measure their performance based on local data that consider the challenges faced by all subpopulations experiencing homelessness in the geographic area (e.g., veterans, youth, families, or those experiencing chronic homelessness);”
• “CoCs should use local data to determine the characteristics of individuals and families with the highest needs and longest experiences of homelessness to develop housing and supportive services tailored to their needs;”
• “Using cost, performance, and outcome data, CoCs should improve how resources are utilized to end homelessness;” and
• “CoCs should review project quality, performance, and cost effectiveness.”

Of the 41 California CoCs that submitted a 2018 CoC Program application to HUD,

• Nearly 100% demonstrated the ability to reallocate lower performing projects to create new higher performing projects that is based on performance review of existing projects; and
• 16 or 39% indicated that their CoC did reallocate reallocated at least 20 percent of the CoC’s ARD (Annual Renewal Demand) between the FY 2014 and FY 2018 CoC Program Competitions and 25 or 61% did not.

Table 1. CoC has a process in place to determine low performing projects and if cumulatively reallocated at least 20 percent of the CoC’s ARD (Annual Renewal Demand) between the FY 2014 and FY 2018 CoC Program Competitions.

Continuum of Care		Has Process in Place to Determine Low Performing Projects	Reallocated at least 20 percent of the CoC’s ARD
			Yes	No
CA-500	San Jose/Santa Clara City & County CoC	x	x
CA-501	San Francisco CoC	x		x
CA-502	Oakland, Berkeley/Alameda County CoC	x	x
CA-503	Sacramento City & County CoC	x	x
CA-504	Santa Rosa, Petaluma/Sonoma County CoC	x	x
CA-505	Richmond/Contra Costa County CoC	x		x
CA-506	Salinas/Monterey, San Benito Counties CoC	x		x
CA-507	Marin County CoC	x	x
CA-508	Watsonville/Santa Cruz City & County CoC	x	x
CA-509	Mendocino County CoC	x		x
CA-510	Turlock, Modesto/Stanislaus County CoC	x		x
CA-511	Stockton/San Joaquin County CoC	x		x
CA-512	Daly City/San Mateo County CoC	x		x
CA-513	Visalia/Kings, Tulare Counties CoC	x		x
CA-514	Fresno City & County/Madera County CoC	x	x
CA-515	Roseville, Rocklin/Placer, Nevada Counties	x		x
CA-516	Redding/Shasta County CoC	x		x
CA-517	Napa City & County CoC	x		x
CA-518	Vallejo/Solano County CoC	x	x
CA-519	Chico, Paradise/Butte County CoC	x		x
CA-520	Merced City & County CoC	x		x
CA-521	Davis, Woodland/Yolo County CoC	x	x
CA-522	Humboldt County CoC	x		x
CA-524	Yuba City/Sutter County CoC	*		x
CA-525	El Dorado County CoC	x		x
CA-526	Amador, Calaveras, Mariposa, Tuolumne Counties CoC (Central Sierra)	x	x
CA-527	Tehama County CoC	**		x
CA-530	Alpine, Inyo, Mono Counties CoC	x		x
CA-600	Los Angeles City & County CoC	x	x
CA-601	San Diego City and County CoC	x	x
CA-602	Santa Ana, Anaheim/Orange County CoC	x		x
CA-603	Santa Maria/Santa Barbara County CoC	x	x
CA-604	Bakersfield/Kern County CoC	x		x
CA-606	Long Beach CoC	x		x
CA-607	Pasadena CoC	x		x
CA-608	Riverside City & County CoC	x	x
CA-609	San Bernardino City & County CoC	x		x
CA-611	Oxnard, San Buenaventura/Ventura County CoC	x	x
CA-612	Glendale CoC	x	x
CA-613	Imperial County CoC	x		x
CA-614	San Luis Obispo County CoC	x		x
Total:		41	16	25
%:			39	61

*CoC noted that it “only receives planning grant funds.”

**CoC noted that it “currently has no CoC Program-funded projects from which funds can be reallocated.”

Next Steps

HUD required all CoCs that answered “no” to

“describe how the CoC actively reviews performance of existing CoC Program-funded projects to determine whether to reallocate low performing projects to create new higher performing projects, reallocate projects that are no longer needed to create another project type that has a greater need, etc.; or

provide an explanation for not reallocating 20 percent of the CoC’s ARD between the FY 2014 and FY 2018 CoC Program Competitions.”

A cursory look at the answers shows that CoCs have a process in place to actively review performance of projects to determine if projects are low performing and should be reallocated as indicated in Table 1.

Explanations for not reallocating 20% of the CoC’s ARD within the given 5-year period include:

• determined that all renewal projects were high-performing and/or performing well;
• provided projects with technical assistance designed to improve performance and client performance and allow time to note improvement before reallocating projects;
• decided that all renewal projects filled a gap in the CoC;
• feared that reallocation of projects would result in residents becoming homeless once again; and
• concluded that there would not be any applicants to apply for the reallocated funds if made available.

Next steps for CoCs to ensure that low performing projects are reallocated should include:

• confirming that all measures are incorporated in their reallocation process including cost effectiveness; spending rates and unspent funds; match requirements; HUD designated system performance measures; monitoring findings including the involvement of ineligible activities; rate of occupancy if applicable; data quality and timeliness in Homeless Management Information System (HMIS); improved outcomes; and accepting priority placements through the local coordinated entry system;
• following up with projects that were given time to improve to see if they are no longer low performing and reallocating those that continue to be low performing;
• continuing to complete, or begin conducting, an annual gaps analysis based on local data that includes determining if each CoC funded renewal project fills a gap, which is encouraged by HUD in the application process;
• ensuring that there is a coordinated CoC adopted plan in place to guarantee that residents of reallocated projects do not become homeless because of the reallocation; and
• recruiting potential applicants throughout the year, which HUD queries about in another question in the annual CoC Program application.