Is it permissible for a permanent supportive housing project that receives funding through both the CoC Program and the HOME Program to participate in a CoC’s coordinated entry process and receive for prioritized placement into vacant units designated for homeless persons?

Date Published: March 2015

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Provisions at 42 U.S.C. 12755 and HOME Program regulations at 24 CFR 92.253(d) require that persons assisted in housing funded through the HOME Program be selected from a waiting list in chronological order; however, the waiting list process for units may defer to the process allowed by other federal regulations. Under the CoC Program, CoCs are required to create written standards, which must include policies and procedures for determining and prioritizing which eligible individuals and families will receive PSH assistance funded with CoC Program funds (24 CFR 578.7(a)(9)(v)). The HOME Program requirement for selecting persons off of a waitlist in chronological order defers to this CoC Program requirement and allows for the establishment of a limited preference such as one for persons experiencing chronic homelessness with the longest histories of homelessness and the most severe service needs.

To implement a limited preference, owners of existing HOME Program-funded projects must update the tenant selection plans as required by 24 CFR 92.253(d). When providing HOME Program funding to new projects that will have a limited preference, the participating jurisdiction must describe the preference in its Consolidated Plan in accordance with 24 CFR 92.253(d)(3). The HOME Program requirement for the affirmatively marketing of units can be satisfied if a coordinated entry system includes all homeless providers in its system and provides a method for persons who decline assessment through the coordinated entry system to be placed on a HOME Program-funded project waiting list.

When establishing a limited preference, the project may further prioritize within that preference. For example, if a project establishes a limited preference for persons experiencing chronic homelessness, the project may further prioritize within that limited preference in a manner consistent with the Prioritization Notice.

The HOME Program-funded project’s existing waitlist does not get dissolved in order to implement the limited preference. Instead, the project-specific wait lists still must be maintained in chronological order, but those persons referred from the coordinated entry system, as long as they meet the criteria for the limited preference, may be moved up on the list and prioritized for housing placement. The HOME Program-funded project may choose to maintain one general wait list and a separate wait list for designated units, or it may maintain a combined wait list, within which persons who meet the qualifications of the limited preference are prioritized.

Tags: CoC Permanent Supportive Housing