(Tools) HUD AAQ #141088 - Priority for HUD CoC PSH Projects
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Question Related To: Continuum of Care Program
Question ID: 141088
Question Subject: Priority for HUD CoC PSH Projects
We currently have an agency in our CoC with 2 HUD CoC PSH projects that serve a specific target population of CH (chronically homeless) persons with a long term mental health disability and/or a long term substance abuse disability. This agency made this a mandatory requirement for entry into their 2 HUD CoC PSH projects many years ago when these same projects were funded under the former HUD Shelter Plus Care Program. This is a government behaviorial mental health agency. For this AAQ case, I will call them Agency A
We recently discovered that when there are vacancies at Agency A, and they are not able to locate any persons that meet their specific target population, that they are leaving the beds vacant. For example, a CH person that has a long term physical disability, but not a long term mental health disability and/or not a long term substance abuse disability, is not allowed entry. Non-CH persons are also not allowed entry at Agency A.
Our CoC has been operating our other 8 HUD CoC PSH projects in a different manner. For the most part, we prioritize all types of CH persons (and other vulnerable population types) from our Coordinated Entry PSH Wait List. If there are no CH persons on our Coordinated Entry PSH Wait List, then we prioritize by the next most vulnerable non-CH population type to fill vacancies (based on our vulnerability scale). HUD has informed us this is the proper method, regardless if some of these projects were at one time funded by the former HUD Shelter Plus Care Program, and that we must properly document priority and vulnerability, especially when PSH vacancies with filled with non-CH persons.
Is Agency A permitted to continue serving only a specific target population while leaving beds vacant when there are many persons still in need of PSH on our Coordinated Entry PSH Wait List?
Please call me at any time if you need more clarity. Thank you.
Thank for you your question.
Based on the details you provided in your question, it sounds like the recipient you are referring to is having difficulty filling vacancies in their dedicated PSH project because of the project's eligibility requirements, which intended to serve chronically homeless persons with a long term mental health disability and/or a long term substance abuse disability.
Note that HUD has provided guidance in this circumstance regarding what CoCs, recipients, and subrecipients should do in the event there are no chronically homeless persons within the CoC at the point in which there is a vacancy for a dedicated PSH project. This guidance can be found in HUD's FAQ 2754: https://secure-web.cisco.com/1LjAxx7FdTIlxahRKcQz8KnK4mXMMlLqV3mgmSn0XGbVhbbg1e80S3xe1urWqR9W7vetBcTj6-z0X78J0rMy6F9NJcf4WblgCHIvEacatA9fh2aXuZHrji51qXRsv6sZzjf00D2mXspNgPX1blQATLrw0CtAndbXW2-Pqe7eiaQn2UTnzz4nESu94zLPSPBlf4-on_7RPql_ht9BniSZywD7s1hHWvg14cKgS9Hb0YEk2-wblTQZKgB5yq2vcvLYkEouqTc0pUu54kPMlE1nRIHK3JQj00XEk9uLU5y6a9Hm6iyQBBLY2ox2E1Q6-xRgwOhQR_wEmZcbOxb206JAMZ1Uhlx__u-YZWriOybOVIzbJ7-EtIq_cGcbIZf2YHeLXXT0NEBGdQ_odmtZYyPZfby-gsug6Cgk9851tGl8k0DL91w8yJkmmxZDQLaQi68ducwxCBdFIUoQHfUFHYoriSSwrIFweM1p4cY5NIapRLd8/https%3A%2F%2Fwww.hudexchange.info%2Ffaqs%2F2754%2Fwith-regard-to-the-final-rule-on-the-definition-of-chronically-homeless-if%2F. As described in the FAQ, HUD does not expect recipients of dedicated or prioritized CoC Program-funded PSH to hold vacant beds open indefinitely while waiting to locate chronically homeless persons with the longest histories of homelessness and most severe service needs and who have a long term mental health disability and/or a long term substance abuse disability. Instead, when a bed turns over and becomes vacant again, the recipient must seek to fill the vacancy in accordance with the the CoC's written standards and CE policies and procedures. In the event there is a vacancy in the dedicated PSH project and there are no persons that meet the eligibility criteria who can be located, the recipient may do one of two things:
- Prioritize non-chronically homeless persons with a long term mental health disability and/or a long term substance abuse disability in accordance with the CoCs prioritization guidelines, which should be incorporated into the CoC written standards and CE policies and procedures; or
- Serve other chronically homeless persons that do not have that specific disability type in accordance with the CoCs prioritization guidelines.
As described in HUD's FAQ 2754, the recipient will need to carefully document what attempts were made to locate chronically homeless persons within their targeted subpopulation. It is recommended that this documentation include a letter from the CoC that documents the CoC's outreach efforts. Ideally, the CoC should have data on all households that are currently presenting for assistance at its coordinated entry access points (including street outreach, if applicable). The 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 CoC's geographic area.
It is important to keep in mind that all housing referrals for CoC and ESG-funded projects (TH, RRH, and PSH) must go through the CoC's coordinated entry process as required in HUD's Notice Establishing Additional Requirements for a Continuum of Care Centralized or Coordinated Assessment System and based on the policies documented in the CoC's coordinated entry policies and procedures and CoC written standards.
For more information, view the Defining "Chronically Homeless" Final Rule and accompanying FAQs. You may also access a recording of a webinar and supporting materials related to the definition of chronically homeless for more detailed information.
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