What is the Potential Impact of Recently Designated “DedicatedPlus” Project Beds on California’s Chronically Homeless Population?

More Time on the Streets May Mean
Less Available Beds for Those Left Languishing

The table at the end of this report shows that last year California Continuums of Care (CoCs) designated 2,552 permanent supportive housing beds as DedicatedPlus out of the total number of permanent supportive housing beds that were submitted to the U.S. Department of Housing and Urban Development (HUD) for funding in their 2017 Continuum of Care Program applications.

In the application, HUD asked each CoC to provide the total number of DedicatedPlus beds for all of the project applications submitted for funding. HUD, however, did not ask the total number of beds for all projects to be included. As a result, the percentage of beds that were designated as DedicatedPlus is unknown.

The end table also notes the number and percent of permanent supportive housing beds changed to DedicatedPlus beds for each California CoC. Many California CoCs did not change any of their permanent supportive housing beds to DedicatedPlus beds. A few California CoCs, however, changed several hundred of their permanent supportive housing beds to DedicatedPlus beds.

What are DedicatedPlus beds?

The U.S. Department of Housing and Urban Development (HUD) first introduced a DedicatedPlus project last year during the 2017 Continuum of Care Program application. The Notice of Funding Availability stated “that some or all of the persons assisted by a DedicatedPLUS project at any given time may be chronically homeless.”

Each of the 400+ Continuums of Care (CoCs) throughout the United States had an opportunity to allow a permanent supportive housing renewal project where 100 percent of the beds were dedicated to chronically homeless individuals and families to become a DedicatedPlus project. Specifically, DedicatedPlus projects do not require all residents to be chronically homeless as defined in 24 CFR 578.3 of the Continuum of Care Interim Rule. CoCs also had an opportunity to create new DedicatedPlus projects through the Permanent Housing Bonus.

What is the difference between projects in which 100% of the beds are dedicated to chronically homeless households and DedicatedPlus projects?

The difference between a permanent supportive housing project in which 100% of the beds are dedicated to chronically homeless households and DedicatedPlus beds may seem slight but it can be significant when it comes to length of time of chronic homelessness and access to a limited number of permanent supportive housing beds.

In 24 CFR 578.3 of the Continuum of Care Interim Rule, a chronically homeless person is primarily someone who has been

  • “living or residing in a place not meant for human habitation, a safe haven, or in an emergency shelter continuously for at least one year or on at least four separate occasions in the last 3 years;” and
    • Can be diagnosed with one or more of the following conditions: substance use disorder, serious mental illness, developmental disability (as defined in section 102 of the Developmental Disabilities Assistance Bill of Rights Act of 2000 (42 U.S.C. 15002)), post-traumatic stress disorder, cognitive impairments resulting from brain injury, or chronic physical illness or disability.”

The Final Rule Defining Chronically Homeless stated “at least four occasions in the last three years where those occasions cumulatively total at least 12 months” and that a person with a disability “requires that the condition be of long and continuing duration; substantially impedes the individual’s ability to live independently; and, is expected to improve with the provision of housing.

The Final Rule Defining Chronically Homeless also noted chronically homeless families as

  • “families with adult heads of household who meet the definition of a chronically homeless individual. If there is no adult in the family, the family would still be considered chronically homeless if a minor head of household meets all the criteria of a chronically homeless individual. A chronically homeless family includes those whose composition has fluctuated while the head of household has been homeless.”

DedicatedPlus projects, as permanent supportive housing projects, must also serve an individual with a disability and families in which one adult or child has a disability.

DedicatedPlus projects, however, can allow a person who was chronically homeless into the project after receiving permanent housing assistance as noted by HUD under the following circumstances:

  • “Residing in a place not meant for human habitation, emergency shelter, or safe haven; but the individuals or families experiencing chronic homelessness as defined by 24 CFR 578.3 had been admitted and enrolled in a permanent housing project within the last year and were unable to maintain a housing placement;” and
  • “Residing in transitional housing funded by a Joint TH (Transitional Housing) and PH-RRH (Permanent Housing-Rapid Rehousing) component project and who were experiencing chronic homelessness as defined at 24 CFR 578.3 prior to entering the project.”

DedicatedPlus projects can also allow a person who was chronically homeless into the project under the following circumstances established by HUD:

  • “Residing in a transitional housing project that will be eliminated and (the person) meet the definition of chronically homeless in effect at the time in which the individual or family entered the transitional housing project;” and
  • “Receiving assistance through a Department of Veterans Affairs (VA)-funded homeless assistance program and met one of the above criteria at initial intake to the VA’s homeless assistance system.”

Lastly, DedicatedPlus projects can also allow a chronically homeless person, as described by HUD as

  • “Residing and has resided in a place not meant for human habitation, a safe haven, or emergency shelter for at least 12 months in the last three years, but has not done so on four separate occasions,” whereas the Final Rule requires at least four separate occasions in the last 3 years.

Potential impact of recently designated DedicatedPlus projects

Through DedicatedPlus projects, CoCs are now able to serve households that were chronically homeless in the past but that no longer fit the chronically homeless definition in the Final Rule.

However, households that still meet the definition of chronic homelessness under the Final Rule likely exceed the number of permanent supportive housing beds in a given California CoC.

The most recent homeless count data reveals that the number of chronically homeless persons has increased significantly (18.5%) in California between 2016 and 2017 (2018 data is not yet available), which is in contrast to previous years as noted in the following table.

Table 1. Number of Chronically Homeless Persons Counted in California: 2014 – 2017

Year # of Chronically
Homeless Persons
Difference
#
%
2014 31,078
2015 32,227 +1,149 +3.7
2016 31,535 -692 -2.1
2017 37,360 +5,825 +18.5

During 2014 and 2017, the number of permanent supportive housing beds also increased significantly as shown in the next table. The average increase was 28%.

Table 2. Number of Permanent Supportive Housing Beds in California: 2014 – 2017

Year # of Permanent
Supportive Housing Beds
Difference
#
%
2014 12,226
2015 15,590 +3,364 +27.5
2016 19,110 +3,520 +22.6
2017 25,571 +6,461 +33.8
Average: 18,124 +4,448 +28.0

Increasing the 2017 number of permanent supportive housing beds by 28% a year for the next three years would result in a little more than 20,000 beds, which may keep pace with the current annual increase in the number of chronically homeless persons based on 18.5%.

However, many persons who are currently chronically homeless persons may remain languishing on the streets creating an increased demand for permanent supportive housing when combined with others who become chronically homeless during the next few years, which in turn far exceeds the increasing number of permanent supportive housing beds.

Next steps concerning DedicatedPlus projects

California CoCs should look closely at their data prior to their submission of the 2018 CoC Program application to HUD to help determine if DedicatedPlus beds are needed in their communities. The table below reveals that many CoCs did not designate any of their permanent supportive housing beds dedicated to only serving individuals and families experiencing chronic homelessness as DedicatedPlus beds in 2017. A few CoCs designated 50% or more.

If the CoC determines that DedicatedPlus beds are needed, the next question should be “how many?” Several California CoCs designated DedicatedPlus beds last year. Is that enough or are more needed?

If a CoC did not designate any DedicatedPlus beds last year, is there a need to do so this year. If there is, how many?

Last year, the CoC Renewal Project Application Detailed Instructions required permanent supportive housing project applicants to answer a new question, which was answered by indicating if the project was going to remain “100% Dedicated,” where 100% of the beds are dedicated to individuals and families experiencing chronic homelessness or “DedicatedPlus.”

Permanent supportive housing project applicants that were not 100% Dedicated were also required to answer the new question by selecting “N/A” if wanting to continue to serve current project eligible applicants, 100% Dedicated if wanting to convert the project, or DedicatedPlus if wanting to convert the project.

CoCs were also able to create DedicatedPlus projects “by making funds available through reallocation or by using amounts available through the permanent housing bonus,” according to HUD.

Hence, next steps concerning DedicatedPlus projects should include a process set up by the CoC that allows the CoC to determine if any, or if any more, DedicatedPlus beds are needed within the communities served by the CoC. Decisions should be made collectively by the CoC before project applicants are required to answer the question again to ensure that answers are not made in isolation from the CoC and unplanned.
_____________________________

Table 3. Total # of Designated DedicatedPlus Beds by California CoC in 2017

Continuum of Care Total # of Beds Designated
as Dedicated Plus
CA-500 San Jose/Santa Clara City & County CoC 57
 CA-501 San Francisco CoC  0
 CA-502 Oakland, Berkeley/Alameda County CoC  938
 CA-503 Sacramento City & County CoC  0
 CA-504 Santa Rosa, Petaluma/Sonoma County CoC  71
 CA-505 Richmond/Contra Costa County CoC  32
 CA-506 Salinas/Monterey, San Benito Counties CoC  0
 CA-507 Marin County CoC  0
 CA-508 Watsonville/Santa Cruz City & County CoC  0
 CA-509 Mendocino County CoC  0
 CA-510 Turlock, Modesto/Stanislaus County CoC  19
 CA-510 Stockton/San Joaquin County CoC  42
 CA-512 Daly City/San Mateo County CoC  0
 CA-513 Visalia/Kings, Tulare Counties CoC  0
 CA-514 Fresno City & County/Madera County CoC  0
 CA-515 Roseville, Rocklin/Placer, Nevada Counties  81
 CA-516 Redding/Shasta County CoC  30
 CA-517 Napa City & County CoC  0
 CA-518 Vallejo/Solano County CoC  4
 CA-519 Chico, Paradise/Butte County CoC  0
 CA-520 Merced City & County CoC  0
 CA-521 Davis, Woodland/Yolo County CoC  0
 CA-522 Humboldt County CoC  0
 CA-523 Colusa, Glen, Trinity Counties CoC*  –
 CA-524 Yuba City/Sutter County CoC  0
 CA-525 El Dorado County CoC  0
 CA-526 Tuolumne, Amador, Calaveras, Mariposa Counties CoC  0
 CA-527 Tehama County CoC  0
 CA-529 Lake County CoC*  –
 CA-530 Alpine, Inyo, Mono Counties CoC*  –
 CA-600 Los Angeles City & County CoC  798
 CA-601 San Diego City and County CoC  26
 CA-602 Santa Ana, Anaheim/Orange County CoC  0
 CA-603 Santa Maria/Santa Barbara County CoC  35
 CA-604 Bakersfield/Kern County CoC  336
 CA-606 Long Beach CoC  4
 CA-607 Pasadena CoC  79
 CA-608 Riverside City & County CoC  0
 CA-609 San Bernardino City & County CoC  0
 CA-611 Oxnard, San Buenaventura/Ventura County CoC  0
 CA-612 Glendale CoC  0
 CA-613 Imperial County CoC  0
 CA-614 San Luis Obispo County CoC  0
 Total:  2,552

*CoC did not submit a 2017 CoC Program application to HUD.

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