Date Published: September 2013
No. Section 578.105 of the CoC Program interim rule sets forth the parameters for grant and project changes. Paragraph (b) defines significant changes as: a change of recipient, a change of project site, additions or deletions in the types of eligible activities approved for a project, a shift of more than 10 percent from one approved eligible activity to another eligible activity, a reduction in the number of units, and a change in the subpopulation served.
Because a change in program component is not listed as a significant change, it is not something that may be changed through a grant agreement amendment. This is because a project that is changing its program component is actually changing the entire structure and design of its project; thus, creating a new project. New projects may only be created through a CoC Program competition either through (1) a CoC’s available Final Pro Rata Need Amount or (2) a new project created through reallocation.
Note that the prohibition of a program component change through a grant agreement amendment also includes a subcomponent change. Therefore, a project cannot change from PH:PSH to PH:RRH or TH to PH:RRH through a grant agreement amendment.
The CoC Program interim rule does state that recipients may make other changes that do not require a grant amendment (see Section 578.105(c) of the CoC Program interim rule). However, this category also does not include a program component change. This category is meant to include grant and project changes that do not require a grant agreement amendment, such as a shift of less than 10 percent of funds from one approved eligible activity to another approved activity. These types of changes must be documented in the recipient’s and/or subrecipient’s records. HUD should be notified so it can update project files and LOCCS, as necessary.