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.
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3 Comments

  1. Connie Mitchell on December 4, 2018 at 7:38 am

    I wonder if reallocating for the sake of reallocating to meet HUD expectations could have resulted in using new resources to simply rehouse some who would otherwise have lost housing. But it seems that the threat of funding cuts if no allocation took place was enough to force some tough decisions that may not have been in the best interest of some CoCs.

    Program rules need to be less rigid to accommodate greater ability to.house more people and to taper assistance when household is ready to do to.

  2. Christopher Weare on December 4, 2018 at 4:46 pm

    It is possible that HUD’s policy of encouraging reallocations could have unintended and negative effects on system performance. It is not certain, a priori, that an existing, sub optimal project is better or worse than a proposed project. To the extent that it could take several years to perfect how a project is run, this policy could have the effect of pulling funding from a young, though improving project. Another more pernicious unintended effect is that reallocations are more likely to target small projects. A small program that serves just a few clients will have much more variable outcomes on objective measures such as exits to permanent housing. Thus, the small projects are susceptible to having very poor outcomes in a single year simply because they had a few difficult-to-serve clients.

    I have been working on testing these ideas using NOFA allocation data, but it will be a while before I can that project completed.

  3. Kathleen Baushke on December 5, 2018 at 10:46 am

    The report misrepresents the reality in the Santa Maria-Santa Barbara continuum, and perhaps in other CoCs as well. While renewal projects lost money to new project applications, it wasn’t because those renewals were low performing. It is because HUD’s focus on low barrier, housing-first projects has resulted in family shelters and transitional housing programs that require sobriety and program participation to lose funds. In Santa Maria-Santa Barbara, three programs that lost money during the report’s time frame were all family programs; the program I represent, Transition House in Santa Barbara, is very high performing (up to 80% of our clients move to permanent housing) and has been since it began receiving HUD CoC funding in 1993. But because it is a supportive services grant (low priority) and not housing first (high priority for HUD), our renewal application did not rank high enough last year to get funding. The new project application that was funded is not a high performing program as it is new and does not have outcomes data to compare to.

    Across the country, family programs are losing money because of scenarios like the one in Santa Maria-Santa Barbara. As Transition House’s CoC funding runs out, we will no longer be participating in HMIS and as a result, our CoC could report less families experiencing homelessness in our area next year. But, of course, that won’t be accurate in the least.

    It is time for CoC’s across the country to recognize the flaws in HUD’s “one size fits all” priorities and how those priorities are hurting children. You can learn more about how HUD’s definition of homelessness and its priorities are leaving families out in the cold at http://www.solvefamilyhomelessnessusa.org.

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