Date Published: April 2016
HUD understands that in order to implement the definition outlined in the Final Rule on Defining “Chronically Homeless,” it will require that communities exercise due diligence to identify and engage all persons experiencing homelessness with chronic homelessness within the CoC’s geographic area. Therefore, HUD encourages CoCs to establish policies and procedures for identifying and serving chronically homeless households including, but not limited to, the development and implementation of an active list, coordinated entry system, and/or outreach worker engagement.
If there were no chronically homeless persons identified as chronically homeless at the point in time in which a program has a vacancy, it would be acceptable to serve a non-chronically homeless household in a vacant unit. At no point should beds be held vacant waiting for people to age into chronicity. Serving a non-chronically homeless household in a vacant unit would also be acceptable if there are individuals that are not ready or willing to be housed in permanent supportive housing (PSH). In both situations, however, you will need to document very carefully what attempts were made to locate persons that met the definition of chronically homeless, and what the outreach strategy was (e.g., if your community has a by-name list or prioritized list through your coordinated entry).
The CoC and recipient of PSH must maintain records to document what efforts have been made to locate persons experiencing chronic homelessness. Ideally, the CoC should have data on all households that are currently presenting for assistance within the CoC which should include whether or not the household meets the definition of chronically homeless and that is informed by a comprehensive outreach strategy. It is recommended that CoCs document what their outreach strategy consists of that recipients of CoC Program-funding are able to keep on file. To justify serving a non-chronically homeless household, that documentation should demonstrate that outreach is occurring regularly and that the CoC is making reasonable efforts to locate and identify all persons experiencing homelessness within the community. If there are no households that meet the definition of chronically homeless at the time in which a vacancy is available, this will serve as sufficient documentation to demonstrate that there are no identified chronically homeless households within the CoCs geographic area.
FAQ 1835 clarifies that recipients of dedicated or prioritized PSH funded under the CoC Program are not required to hold beds vacant indefinitely while trying to identify persons that meet the highest priority.
Please review the final rule for the most accurate information on recordkeeping requirements for all recipients of CoC Program-funded PSH for persons experiencing chronic homelessness.