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August 19, 2019

Cathy Alderman, VP of Communications and Public Policy
Colorado Coalition for the Homeless

by John Parvensky, Acting Executive Director, National Coalition for the Homeless

Washington, DC--Across the country, agencies and communities providing housing to homeless families and individuals with federal HUD funding are beginning the annual ritual referred to as the SuperNOFA.  This is not some astrological event.  Rather, it is the funding equivalent of a cross between Survivor and the Hunger Games.  Agencies receiving HUD homeless funding are required to compete with each other each year to renew their grants for supportive housing.  The losers will be defunded and essentially “voted off the island.”

While competition for funding can be beneficial to ensure funding for the most worthy projects, HUD’s NOFA (Notice of Funding Availability) is structured in such a complex and convoluted way that it traumatizes not only agencies serving the homeless, but the very people the funding is designed to help -- those are currently residing in housing funded by these grants.

The funding process requires local “continuum of care” entities designated by HUD to hold local competitions for new and renewal projects, and submit a collaborative application which ranks projects based on HUD and locally determined criteria.  The collaborative applications are then ranked by HUD, and projects will be funded or not based on how HUD has ranked their continuum and how the continuum has ranked the project.

The process involves a three-month scramble that starts with an 83 page NOFA which changes each year, the issuance of local scoring criteria, writing new and renewal applications, ranking of those applications by the local continuums, and submission of the collaborative application to HUD.  HUD then takes approximately three months to review, rank, and make announcements as to which projects will be renewed and which limited new projects will be awarded.

Thus, half of each year, agencies housing the homeless with federal funding are working on getting their grants renewed or worried about the prospects of their grants not being renewed.

This might be chalked up to just the “cost of doing business” if it were not for the fact that the final funding decisions are really not about which agencies are funded and not funded, but whether the families and individuals being housed through these programs will continue to be housed or not.  Indeed, the non-renewal of homeless housing by HUD over the past ten years has led to significant reoccurrence of homelessness by thousands of people previously housed in HUD funded programs.

Simply put, families and individuals housed in supportive housing programs funded by HUD should not have their continued housing put at risk for the sake of HUD managing a competitive renewal process.

A yearly national competition for funding might be justified if there were significant funding for new projects each year.  However, the vast majority of HUD funding is needed just to renew existing projects housing formerly homeless persons.  In the 2018 competition, 91.3% (totaling $2 billion) of projects funded were renewal projects, with only 5.8% ($126 million) being new housing or service projects to serve those currently living on the streets. 

No other funding process in the federal government places the housing of people in need at risk through a competitive renewal process.  Can you imagine if HUD required Public Housing Authorities housing millions of people through Section 8 housing choice vouchers to annually compete to continue receiving such funding and keeping those currently housed from losing their housing?

To make matters even worse, HUD has devised scoring criteria for that penalizes communities that are experiencing increases in homelessness due to factors outside of their control. 

While there is certainly merit in rewarding communities for improving outcomes, penalizing communities that are struggling with increased homelessness due to affordable housing shortages, increased population, increased rents, decreased employment opportunities, and other factors out of their control is not only counterproductive -- it exacerbates the problem by reducing the very resources these communities need to reduce homelessness.

In what world would it make sense for the Centers for Disease Control to reduce vaccines to communities for treating HIV-AIDS or TB because there were more people in those communities needing such treatment?  That is essentially what HUD is doing with its scoring process.

To truly help communities reduce and end homeless, Congress needs to appropriate significantly more federal funding to help leverage state, local and community efforts.  To rely on only 5.8% of funding to provide new housing for people currently on the streets will not end homelessness.  HUD should also end its practice of requiring annual renewals for desperately needed homeless housing and services, and allow agencies to focus on housing the homeless rather than competing for funding.