Introduction and Background
The U.S. Department of Housing and Urban Development (HUD) released a Supplemental Notice of Funding Opportunity (NOFO) for the Continuum of Care Program (CoC) to address unsheltered and rural homelessness on June 22, 2022. The purpose of this Special NOFO is to target efforts to reduce unsheltered homelessness, particularly in communities with very high levels of unsheltered homelessness and homelessness in rural areas. Through the Special NOFO, HUD will award funding to communities to implement coordinated approaches grounded in Housing First and public health principles to reduce the prevalence of unsheltered homelessness, and improve services engagement, health outcomes, and housing stability among highly vulnerable unsheltered individuals and families. HUD expects communities to partner with health and housing agencies to leverage mainstream housing and healthcare resources.
As stated in Section I.D of the Special NOFO, approximately $322 million is available in the Special NOFO. Of this amount $54,500,000 is available only for projects that serve rural areas as defined in section III.C.2.K and $267,500,000 is available for projects as part of the Unsheltered Homelessness Set Aside. All requirements for the application process, including requirements for the entire CoC Consolidated Application and the total amount of funds available, are included in the Special NOFO. HUD will require the Continuum of Care to rank all projects, including CoC planning and UFA Costs in order of priority.
Continuum of Care Service Area
Total Care for the Homeless Coalition (TCHC) is the HUD designated Continuum of Care for the upper eastern region of South Carolina. The counties included in the CoC service area include Sumter, Clarendon, Lee, Darlington, Dillon, Florence, Marlboro, Kershaw, Chesterfield, Georgetown, Williamsburg, Marion, and Horry.
Available Funding, Eligible Projects, and Bonus Projects
The following table provides the maximum award amount for the Unsheltered Homelessness Set Aside and the Rural Set Aside. See Section III.J. a & b of the Special NOFO for the methodology HUD used to determine the Unsheltered Homelessness Set Aside and Rural Set Aside award amounts for each CoC.
CoC Number and Name
Maximum Unsheltered Homelessness Set Aside Amount
Maximum Rural Set Aside Amount
SC-503 – Sumter City & County CoC
Up to 3% of awarded amount for Unsheltered Homelessness Set Aside
Eligible Projects & Participants
The initial grant term for all projects awarded by HUD through the Special NOFO will be for 3 years, including CoC Planning and UFA costs. Grant terms may be extended, consistent with 2 CFR 200.308 and 2 CFR 200.309.
The following types of project applications will be eligible for submission in the Special NOFO Competition:
- Permanent Supportive Housing (PH-PSH) projects;
- Rapid Rehousing (PH-RRH) projects;
- Joint TH and PH-RRH projects;
- Supportive Services Only;
Projects funded through the Unsheltered Homelessness Set Aside must have the following eligibility criteria for program participants:
- Meet the criteria of paragraph (1) of the definition of homeless at 24 CFR 578.3, except that persons coming from transitional housing must have originally come from places not meant for human habitation, emergency shelters, safe havens, or institutions where they resided for 90 days or less and originally came from places not meant for human habitation, safe havens, or emergency shelters; or
- Meet the criteria of paragraph (4) of the definition of homeless at 24 CFR 578.3.
- All TCHC counties are eligible for this funding set aside.
Projects funded through the Rural Homelessness Set Aside may serve any program participant meeting the criteria of the definition of “homeless” in 24 CFR 578.3, except individuals and families meeting the criteria of paragraph (3) of the definition.
All projects must participate in Coordinated Entry. Additionally, all projects must operate consistently with the CoC Plan for Serving Individuals and Families Experiencing Homelessness with Severe Service Needs described in Section VII.B.4 of the Special NOFO.
TCHC counties eligible under the rural set aside includes: Chesterfield, Clarendon, Dillon, Georgetown, Lee, Marion, Marlboro, and Williamsburg Counties.
Unsheltered Homelessness Set Aside:
For the Unsheltered Homelessness Set Aside, 24 CFR 578.37 through 578.63 identify the eligible costs, except that projects applying for funds under the Unsheltered Homelessness Set Aside may not request funds for acquisition (24 CFR 578.43), rehabilitation (24 CFR 578.45), or new construction (24 CFR 578.47). HUD will reject any requests for ineligible costs and HUD will reject any projects that request funds for acquisition, new construction, or rehabilitation.
Rural Homelessness Set Aside:
(a) In general. For the Rural Set Aside, eligible activities are those identified in the CoC Program regulations at 24 CFR 578.37 through 578.63, and those listed in paragraph (b) when they are part of an SSO, PH, or Joint TH and PH:RRH Component project. Additionally, staff and overhead costs directly related to carrying out the eligible activities in paragraph (b) of this section are eligible as part of those activities.
(b) The eligible activities authorized under section 491 that are eligible under this Special NOFO are:
- Rent or utility assistance after 2 months of nonpayment of rent or utilities to prevent eviction or loss of utility service. Funds may be used to pay rent or utility arrear payments up to 6 months on behalf of program participants residing in permanent housing.
- Short-term emergency lodging in motels or shelters, either directly or through vouchers. Eligible costs include lodging costs in motels or hotels for program participants; pro-rata share of sheltering program participants in existing shelters so long as the costs are actual costs of creating new and temporary beds in emergency shelters and not to permanently increase the capacity of the shelter. No funds may be used to shelter program participants in existing shelter beds.
- Repairs, (such as insulation, window repair, door repair, roof repair, and repairs) that are necessary to make housing habitable to be used for transitional or permanent housing by people experiencing homelessness. The total cost of repairs may not exceed $10,000 per structure.
- Capacity building activities. Capacity building activities are those activities that maintain or improve the skills of recipients. Eligible capacity building activities include employee education, job training, staff retention activities such as financial incentives to staff, paying for continuing education opportunities, cross training within an organization, staff training and professional licensing or certification, and other professional development activities. An applicant may apply for up to 20% of funds requested as part of the project, including project administrative costs, for capacity building activities.
- Emergency food and clothing assistance. The cost of providing meals or groceries and clothing to program participants are eligible costs.
- Costs associated with making use of Federal Inventory property programs to house homeless individuals and families. Federal Inventory property programs means the Use of Federal Real Property to Assist the Homeless program authorized by title V of the Act, and implemented by 24 CFR part 581, and the Single Family Property Disposition Program authorized by section 204(g) of the National Housing Act (12. U.S.C. 1710(g)) and implemented at 24 CFR part 291. Eligible costs are: preparing and submitting applications to obtain ownership of the real property; transfer taxes; recording fees; closing costs; building permit and zoning fees; attorney’s fees; rehabilitation of buildings and structures on the property necessary to bring them into compliance with local building codes and to convert them to the intended homeless assistance use; water, sanitation, sewer and utility hook-up fees and deposits and bringing lines to the property; wells; septic systems; and improving access to the real property from public roads.
Local Competition Deadlines
The CoC is requesting new project applications that meet the criteria for the Unsheltered Homelessness set aside and the Rural Homelessness set aside. The following timeline will be implemented for the CoC’s Local Competition:
- Unsheltered NOFO Applicant Meeting. All applicants interested in applying for funds through the local competition are encouraged to attend the Special NOFO meeting on August 12, 2022 at 2:00PM. The meeting will consist of a brief overview of the Special NOFO, the local competition timeline and process, and a question-and-answer period. Participants can join the virtual zoom meeting by following the link below:
Meeting ID: 494 621 4139
- Project Applications Due for Rating and Ranking. All new project e-snaps project applications are required to be submitted in e-snaps on or before September 9, 2022. Email a copy of the project application exported from e-snaps and the following documents to [email protected]:
- Organization Policy and Procedure/Operational Manual
- Financial Policies and Procedures (if not included in the above-mentioned documents)
- Organizational Bylaws
- Board Roster – identify any board members that have lived experience with homelessness
- Organizations most recent audit or financial statement
- Technical Review and Rating/ Ranking. The CoC Grant Technical Review Committee will technically review applications and send their findings to the HUD Grant Application Selection Committee who will score and rank all submitted applications that meet the CoC Threshold requirements from September 15, 2022 – September 30, 2022.
- Special CoC Board Meeting. The CoC Board will hold a special Board Meeting on September 30, 2022 to approve the Ranked Project listing presented by the HUD Grant Application Selection Committee.
- Project Applicant Notification. Applicants will be notified through written notification outside of e-snaps by October 7, 2022. The notification will indicate if your project(s) will be included in the CoC Application to HUD, the ranked position of your project(s), and the funding amount the project is being submitted for.
- Appeal Process: Applicants will have three (3) business days to appeal a TCHC decision as described herein, (close of business on October 12, 2022). The CoC will respond to the applicant making the appeal by close of business October 14, 2022.
- Revised Project Applications Due. Revised project applications submitted in e-snaps are due to the CoC on or before October 20, 2022.
Review and Oversight
HUD expects each CoC to implement a thorough review and oversight process at the local level for new project applications submitted to HUD in this Special CoC Program Competition. To meet this expectation, the CoC closely reviews information provided in each project application in order to ensure that:
- All proposed program participants will be eligible for the program component type selected;
- The proposed activities are eligible under the 24 CFR part 578 and the Special NOFO;
- Each project narrative is fully responsive to the question being asked and that it meets all of the criteria for that question as required by the Special NOFO and included in the detailed instructions provided in e-snaps;
- The data provided in various parts of the project application are consistent; and
- All required attachments correspond to the attachments list in e-snaps and the attachments contain accurate and complete information, and are dated between June 22, 2022 and October 20, 2022.
Each New Project application submitted will be rated against the criteria articulated in the Department of Housing and Urban Development’s Rating and Ranking Tool and Special NOFO. An overview of the rating criteria that will be considered during the rating and ranking process is provided below. Additionally, the CoC Rating and Ranking tool will be published prior to the submission date of project applications. According to guidance from HUD, CoCs should use objective, performance-based scoring criteria and selection priorities that are approved by the CoC to determine the extent to which each project addresses HUD’s policy priorities.
CoC Threshold Criteria
The CoC has established five threshold criteria. If an applicant does not meet these threshold requirements, their application will not be rated and submitted for consideration.
These threshold criteria are:
- Coordinated Entry Participation
- Housing First and/or Low Barrier Implementation
- Documented, secured minimum match
- Application is complete and data are consistent
- Project Costs are eligible (24 CFR 578 Subpart D and Special NOFO)
- Acceptable organizational audit/financial review
- Active participation in CoC
HUD Threshold Criteria
The HUD threshold requirements can be found in the Special NOFO Section V.C.3.
CoC Local Criteria
The CoC local criteria ensure that applicants are responsive to local needs and requirements, while also meeting the standards laid out in the Special NOFO. This is a high-level overview of the local criteria. The detailed Rating and Ranking tool will be made available to all project applicants and posted on the CoC’s website at a later date.
For new projects these criteria address:
- Design of housing and supportive services
- Documented organizational financial stability
- Project effectiveness
- Financial feasibility of project
- Cost per exit to permanent housing
- Application is complete and data are consistent
- Service to a high needs population
- Strategy to address those at risk of becoming homeless
- Strategy to reduce rate of returns to homelessness
- Identification of common factors of individuals that return to homelessness
- Street outreach
- Strategy to support underserved populations
- Strategy to further fair housing and market housing and supportive services
- Assistance to clients to increase access to employment and non-employment cash resources
- Leveraging Healthcare Resources
Additionally, rating criteria for specific new project types are included to ensure that HUD’s minimum requirements for new projects are met.
The Rating and Ranking Committee may also review information in the Line of Credit Control System (LOCCS); Annual Performance Reports (APRs); and information derived from monitoring, including monitoring reports and A‐133 audit reports as applicable, as well as performance standards on prior grants.
Denied or Decreased Funding
If an applicant wishes to appeal rating and ranking outcomes that resulted in denied or decreased funding, they must submit a letter of appeal to the chair of the CoC within 3 days of receiving their official notice outside of e-snaps. The governing body of the CoC will be convened to review any such appeal prior to October 14, 2022 and will notify the appellant in writing of the results of the appeal.
Project applicants whose project was rejected may appeal the local CoC competition decision to HUD if the project applicant believes it was denied the opportunity to participate in the local CoC planning process in a reasonable manner by submitting a Solo Application in e-snaps directly to HUD prior to the application deadline on October 20, 2022. The CoC’s notification of rejection of the project in the local competition must be attached to the Solo Application. If the CoC fails to provide written notification outside of e-snaps, the Solo Applicant must attach evidence that it attempted to participate in the local CoC planning process and submitted a project application that met the local deadlines, along with a statement that the CoC did not provide the Solo Applicant written notification of the CoC rejecting the project in the local CoC competition. See Section X.C. in the Special NOFO for more information.