Our CoC wants to adopt the orders of priority established in the Prioritization Notice but has CoC Program-funded PSH projects with existing waiting lists. In such cases, how do CoCs create a single prioritized list, as encouraged by HUD in the Prioritization Notice?

Date Published: March 2015

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HUD encourages CoCs to incorporate into their operating policies and procedures (which are included in the CoC’s governance charter) a requirement that all CoC-funded PSH only accept referrals through a single prioritized list that is created through the CoC’s coordinated entry process. This will allow recipients of CoC Program-funded PSH to maintain their own project-level waiting lists, if necessary, provided that all households are referred to the project-level waiting list based on where they fall on the CoC’s single prioritized list and not on the date in which they first applied for housing assistance.

The CoC Program interim rule does not include any requirement that CoCs or recipients of CoC Program funds establish or maintain waiting lists. HUD recently published a policy brief on coordinated entry and the waiting list process. HUD strongly encourages CoCs and recipients of PSH to limit project-level waiting lists to the maximum extent feasible, however, when a waiting list cannot be avoided CoCs and recipients of PSH must consider the following:

  1. Where a CoC adopts the order of priority established in the Prioritization Notice, recipients and subrecipients must only take referrals from a single prioritized list–each CoC and its providers, may determine the most effective way to address existing project-level waiting lists.
  2. CoCs may, for example, decide to reassess all persons currently on a projects waiting list or eliminate the existing waiting list altogether. The CoC and recipients must notify all persons on the existing project-level waiting list(s) of such actions and ensure a transparent and open process.
  3. The CoC’s single prioritized list must not exclude eligible persons from housing (e.g., only prioritizing persons with a specific disability type).

This specific guidance only applies to projects that are funded with CoC Program funds where there are no other funding sources whose regulations prohibit the intended treatment of existing project-level waiting lists. HUD is working with other program offices (e.g., HOME Program) to develop guidance around how PSH receiving other sources of funding from HUD can participate in a meaningful way. See FAQ 1901 for specific information regarding projects that receive funding through both the CoC Program and the HOME Program. 

Tags: CoC Permanent Supportive Housing

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