HomeMy WebLinkAbout2026-012 Federal Homelessness Funding Changes December 1, 2025 Report No. 2026-012
INFORMAL STAFF REPORT
TO MAYOR AND CITY COUNCIL
SUBJECT:
Federal homelessness funding changes
EXECUTIVE SUMMARY:
The US Department of Housing and Urban Development (HUD) announced on November 13,
2025, rapid, major changes to how homeless funding is allocated, shifting away from permanent
housing programs. Multiple agencies in Denton County received collectively $3.4 million in
funding for permanent housing programs in 2024 and anticipated guaranteed funding for two
years. With the recent announcement of the new approach, agencies are required to submit a
threshold application by Dec. 3 and a full application by Dec. 10. The largest anticipated local
impact is the limitation of funding dedicated to permanent housing programs to no more than 30%,
and historically 90% of funds have been awarded.
With a very short turnaround for applications under the new criteria the Housing and Homelessness
Leadership Team (HHLT) has called a special meeting for Tuesday, Dec. 2, at 4:00 p.m.
BACKGROUND:
On November 13, 2025, the U.S. Department of Housing and Urban Development (HUD)
announced a Notice of Funding Opportunity (NOFO) for its Continuum of Care (CoC) program.
The CoC program is the primary federal funding program for homeless services in the United
States. Recipients awarded in 2024 were expected to have funding guaranteed for two years,
however HUD is requiring all agencies to reapply to align with the administration's new approach
towards homelessness. Denton County is most likely to be impacted by the change in focus from
permanent housing (PH) programs, including Permanent Supportive Housing (PSH) and Rapid
Rehousing (RRH) programs, to transitional housing (TH) programs. Denton County received
almost $3.4 million in CoC funding for PH programs in 2024.
On December 1, 2025, the lead agency of Denton's CoC, Texas Homeless Network (THN),
released its Request for Proposals (RFP) for its local CoC application process and provided
deadlines for agencies to submit their applications for CoC funding.
The Denton Community Shelter and Our Daily Bread do not receive CoC funding and will not be
directly impacted by any funding changes.
DISCUSSION:
The largest anticipated local impact is the limitation of funding dedicated to permanent housing
programs (RRH and PSH) to no more than 30% of all CoC funding, historically incentivized and
prioritized for 90% of funds awarded. CoC funding application scoring areas previously focused
on equity, voluntary participation in services, and anti-criminalization. The new funding
application includes a 'Merit Review' that removes many prior criteria, adds scoring for required
service participation and local laws on drug use/camping, and ties 70% of funding to the overall
CoC's application score (previously only 10%). The National Alliance to End Homelessness
December 1,2025 Report No. 2026-012
developed a side-by-side comparison of the anticipated FY24/25 CoC NOFO with the new FY25
NOFO (Attachment 1).
Four housing agencies administer PH services in Denton County that are likely at risk, as outlined
in Table 1. According to the Housing Inventory Count(HIC)these programs provide the capacity
to house 268 individuals experiencing chronic and/or literal homelessness,at the greatest risk,with
the support of the CoC program. The number of individuals currently housed varies from the HIC
count.
Nonprofit Annual CoC
Organization
Program Type Funding Housing Inventory Count Capacity
Denton County Permanent 68 chronically homeless individuals
Supportive $1,407,284
MHMR living with a disability
Housing
Permanent
Giving Grace Supportive $546,052 35 chronically homeless adults and
children
Housing
Giving Grace Rapid Rehousing $463,617 53 adults and children
Friends of the
Family Rapid Rehousing $414,330 29 adults with children; limited to
(DCFOF) survivors of domestic violence
Christian
Community Rapid Rehousing $543,797 83 adults and children
Action
Denton County Total $3,375,080 268 individuals
Table 1:Denton County CoC Program Funding Recipients and HIC Count Data
On Nov 18, City Council approved a substantial amendment to the City's Action Plan that
allocated$639,000 of unprogrammed HOME Investment Partnership(HOME)Program funds for
Tenant Based Rental Assistance (TBRA) and Supportive Services. While the additional TBRA
funding may be able to address some of the need resulting from local RRH programs not being
renewed, for a short period of time, a significant gap is expected to remain.
Denton County agencies will submit CoC funding applications to THN, the lead agency for the
Texas Balance of State(BoS)CoC. THN has until Jan. 14,2026,to submit applications for funding
to the federal government. On Monday, Nov. 24, THN released a notification that the Texas BoS
CoC application will open Dec. 1, and close Dec. 10. On Monday, Dec. 1, THN conducted a
webinar for agencies and provided an update that our CoC would need to reduce PSH and RRH
December 1, 2025 Report No. 2026-012
programs by nearly $11 million across the state (Attachment 3). Denton County MHMR and
Denton County Friends of the Family would be allowed to reapply as PH renewal grants. Giving
Grace and Christian Community Action were directed to transition their PH programs to TH
programs to be eligible for continued funding. The situation is rapidly evolving; as of Monday
night, not all organizations are sure if they will seek continued funding.
The City intends to apply for Continuum of Care (CoC) funding under the Supportive Services
Only — Street Outreach activity. Staff are proposing funding for an enhanced street outreach
program, including diversion strategies, to expand capacity for addressing encampments and
targeted areas within the City.
The deadline for submitting threshold applications to the Texas Homeless Network (THN) is
December 3 at 9:00 p.m. Due to the short timeline,there will not be an opportunity to seek Council
direction prior to submission. However, Council will have the opportunity to review and discuss
the application at a future meeting. At that time, staff can receive direction to withdraw the
application if desired, prior to the City being obligated to perform under the grant.
The Denton County Housing and Homelessness Leadership Team (HHLT), at the request of the
City and United Way staff, has called for a special session for HHLT to receive an update from
backbone support and the homeless coalition (The Path Home) and to provide direction for its
working groups on a coordinated response. The City's appointed representatives on HHLT are
Mayor Hudspeth, Jesse Kent (Director of Community Services), and Deputy Chief Paul
Willenbrock.
EXHIBITS
Attachment 1 - Overall Side By Side Comparison of FY24 and FY 25 CoC Program Competition
NOFOs
Attachment 2—Texas Balance of State 2024 CoC Funding Awards
Attachment 3 —Texas Balance of State Dec. 1 Webinar Slides
STAFF CONTACT:
Jesse Kent
Director of Community Services
jesse.kent@cityofdenton.com
REOUESTOR: Staff initiated
STAFF TIME TO COMPLETE REPORT: Three hours
PARTICIPATING DEPARTMENTS: Community Services
rENational Alliance to
END HOMELES SNES S
Overall Side By Side Comparison of FY24 and FY 25 CoC Program Competition NOFOs
FY 2025 Continuum of Care Competition and youth Homelessness
Demonstration Program Grants
Youth Homelessness Demonstration Program (YHDP) projects renewing under Youth Homelessness Demonstration Program (YHDP) projects renewing under
the CoC Program awarded noncompetitively the CoC Program awarded competitively
Transitional housing and projects that deliver supportive services only permitted Permitted and encouraged to apply for Transitional housing and projects that
as renewal grants only deliver supportive services only as new projects (reallocated from existing
renewal project funding)
In accordance with the statute, incentives are provided for permanent housing In order to invest in more transitional housing and supportive services only
projects only projects, HUD is limiting the amount of permanent housing (PH and RRH) to 30
percent of eligible award amount
CoCs rank projects into two tiers and HUD selects projects based on how they CoCs rank projects into two tiers and HUD selects projects based on how they
rank individual projects and whether they are in tier 1 or 2. Depending on CoC rank individual projects and whether they are in tier 1 or 2. Depending on CoC
score,a CoC could lose some or all of projects ranked in Tier 2. score,a CoC could lose some or all of projects ranked in Tier 2.
Tier 1 =90%of funds"held harmless"and not dependent on CoC overall score. Tier 1 =30%of funds"held harmless"and not dependent on CoC overall score.
Tier 2=10%of funds dependent on CoC overall score. Ensures vast majority of Tier 2 =70%of funds dependent on CoC overall score.
renewal funding is protected to avoid disruption even if CoC does not receive a
high score. Depending on score,a CoC could lose
FY 2024 and FY 2025 Continuum of Care Competition and Renewal or FY 2025 Continuum of Care Competition and youth Homelessness
Replacement of Youth Homeless Demonstration Program Grants Demonstration Program Grants
Project eligibility threshold -pass/fail standard that assesses the extent in which Project eligibility threshold -pass/fail standard that assesses the extent in which
a project is eligible, meets financial and management capacity,submits all a project is eligible, meets financial and management capacity,submits all
required standard certifications,will serve only eligible populations,and will required standard certifications,will serve only eligible populations,and will
agree to participate in HMIS (unless DV) agree to participate in HMIS (unless DV) and certifies affirmatively that the
project applicant will not engage in racial preferences or other forms of
illegal discrimination and will not engage in any activities under the
pretext of"harm reduction."
Project quality threshold- HUD reviews all new projects to assess the extent in Project quality threshold- HUD reviews all new projects to assess the extent in
which it meets additional capacity standards and must receive a minimum which it meets additional capacity standards and must receive a minimum
number of points for rating criteria for relevant project type. number of points for rating criteria for relevant project type.In addition,HUD
has added new language that allows HUD to verify past performance and
reject a project if there is evidence that it has previously or currently
engaged or engages in racial preferences or other forms of illegal
discrimination,engaged or engages in in activities that"violate the sex
binary in humans,"and,engaged or engages in any activities under the
pretext of"harm reduction.Now this will be assessed is unclear.
Project Rating Criteria for eligible new project types consistent with years prior- Project rating criteria across project types include key differences. Examples
focus on assisting participants obtain and remain in housing,connecting with Include: New TH and PH (PSH and PPH)will be scored on the extent in which
mainstream benefits,supportive service participation is voluntary. service participation is required (with onsite services preferred). For TH projects,
applicants will be scored on the extent to which they will provide 40 hours of
customized services for each program participant. New grants for street
outreach are scored on the extent in they cooperate with law enforcement to
enforce local laws such as public camping and public drug use laws.
FY 2024 and FY 2025 Continuum of Care Competition and Renewal or FY 202b Continuum of Care Competition and youth Homelessness
Replacement of Youth Homeless Demonstration Program Grants Demonstration Program Grants
Project renewal threshold requires renewal project applications to meet the Project renewal threshold requires renewal project applications to meet the
minimum project eligibility,capacity,timeliness,and performance standards minimum project eligibility,capacity,timeliness,and performance standards
identified in this NOFO or be rejected from consideration. identified in this NOFO or be rejected from consideration.Added two
additional reasons for HUD to reject a renewal project from the
competition:evidence that the project has previously or currently engages or
engaged in racial preferences or other forms of illegal discrimination,engages
or engaged in activities that violate the"sex binary in humans",or engages or
engaged in activities under the pretext of"harm reduction."
CoC Application Scoring awards points to CoCs across 7 rating areas with no Now referred to as a Merit Review which is comprised of 3 rating areas with
significant differences from year prior. Focus on systemwide performance,the many significant differences. In addition to removing many of the previous
use of inclusive processes, racial equity and addressing disparities,the criteria upon which CoCs were scored,several new criteria were added that
promotion of client choice and voluntary services,and strategies that prevent will disadvantage the majority—if not all—CoCs and current recipients of
the criminalization of homelessness. funding because of how far they swing from past expectations.These include
rating factors tied to the extent in which existing projects require service
participation and the existence of state or local laws that cover the CoCs entire
geographic area that prohibit illicit drug use and camping. Historically, HUD has
given CoCs at least one year of notice of shifting priorities that allow time to
adopt and implement.Given that scoring will now determine 70%of award
decisions,this could result in many CoCs losing a large proportion of their
existing funding.
NOFO did not include any preference points associated with administration Includes initiative preference points:
initiatives. 1. If more than 50%of proposed activities happen within an Opportunity
Zone
2. If all non-profit applicants/recipients of funding voluntarily,thoroughly,
and demonstrably facilitate verification of immigration status using
SAVE directly or in coordination with state/local government
FY 2024 and FY 2025 Continuum of Care Competition and Renewal or FY 202b Continuum of Care Competition and youth Homelessness
Replacement of Youth Homeless Demonstration Program Grants Demonstration Program Grants
HUD may use a risk-based approach in reviewing projects and may consider Now referred to as a "risk review"with two distinct changes of significance.
factors tied to administrative requirements and performance requirements. There is a new criterion:"History of subsidizing or facilitating activities that
Examples of factors considered for past performance include accounting for use conflict with the purposes of this NOFO." Further, rather than incorporating this
of funds,timely submission of reports, meeting performance targets in grant as part of the scoring component, it is now a separate component in the
agreement, producing positive outcomes and results. HUD may reduce overall selection process.This would essentially allow HUD to target any
score based on past performance and could take additional remedies if there is organization that it deems to be not aligned with the administration—
an adverse finding. regardless of outcomes or performance at responding to homelessness—and
place any projects, new and renewal,that they request at risk of not being
funded.
In selecting projects for funding,there are certain project types that would be In selecting projects for funding,only CoC Planning (or UFA Costs projects, if
selected noncompetitively before looking at ranked projects in tiers.These applicable),will be selected before looking at ranked projects in tiers.This
include CoC Planning (or UFA Costs projects,if applicable),YHDP means all other project types—including YHDP and DV Bonus projects--will be
renewal/replacement projects,and DV Bonus projects. competitively awarded.
Projects ranked in Tier 1 are awarded first based on passing project eligibility, Projects ranked in Tier 1 are awarded first based on passing project eligibility,
quality,and threshold review.CoC score is only a factor if amount of funding quality,and threshold review.CoC score is only a factor if amount of funding
available under the NOFO is reduced.Equals 90%of all CoC funding. available under the NOFO is reduced.Equals 30%of all CoC funding.
Projects ranked in Tier 2 are awarded based on a project score that takes into Projects ranked in Tier 2 are awarded based on a project score that takes into
account the CoC score,the project ranking,and commitment to housing first. account the CoC score,the project ranking,and commitment to service
participation requirements.
FY 2024 and FY 2025 Continuum of Care Competition and Renewal or FY 2025 Continuum of Care Competition and youth Homelessness
Replacement of Youth Homeless Demonstration Program Grants Demonstration Program Grants
NOFO outlines all administrative, national,and departmental policy NOFO outlines all administrative, national,and departmental policy
requirements and terms that all projects must comply with.These include requirements and terms that all projects must comply with.These include
requirements associated with a broad range of statutes and regulations requirements associated with a broad range of statutes and regulations
including fair housing,the ADA,and Section 504,some departmental-specific including fair housing,the ADA,and Section 504,some departmental-specific
policy,and specific Executive Orders such as those focused on racial equity and policy,and specific Executive Orders. Removes requirements associated with
equity for LGBTQ+ populations.This is important to note because projects past HUD policy and prior Executive Orders. The NOFO also adds new
and CoCs will be penalized in FY2025 for participation in certain activities conditions which prohibit awardees from engaging in activities that:facilitate
which they were required to comply with. racial preferences or other forms of illegal discrimination—including the use of
'proxies for race'-or activities that violate the"sex binary in humans';fund
promote or encourage the use of illicit drugs or are done under the pretext of
harm reduction.
Solo Applicants are applicants that apply as an organization outside of the CoC Solo Applicants are applicants that apply as an organization outside of the CoC
process afterthey have attempted to participate but were not permitted to do process afterthey have attempted to participate but were not permitted to do
so. so.There may be different deadlines for solo applicants.
P.tMEW of
IIIIIIII Q��= HUD's 2024 Continuum of Care Program Funding Awards*
9egN DEVE'o
CoC Number: TX-607
CoC Name: Texas Balance of State CoC
Total Award: $21,620,316
Awards by Component:
# of New New Project #of Renewal Renewal Proj. #of Exp. Exp.Project #of YHDP YHDP Planning/UFA Total# Total %of CoC
Projects' Award Total Projects Award Total Projects' Award Total' Projects Award Total Award Total of Proj. Award Award
Permanent Housing
PH-Permanent Supportive Housing 2 $1,024,248 8 $5,645,588 0 $0 0 $0 n/a 10 $6,669,836 31%
PH-Rapid Re-housing 3 $1,680,819 16 $7,555,179 0 $0 0 $0 n/a 19 $9,235,998 43%
Joint TH-Rapid Re-housing 2 $1,220,307 3 $1,869,619 0 $0 0 $0 n/a 5 $3,089,926 14%
Supportive Services Only 0 $0 2 $425,986 0 $0 0 $0 n/a 2 $425,986 2%
HMIS 0 $0 1 $698,570 0 $0 0 $0 n/a 1 $698,570 3%
CoC Planning Grant 0 $0 0 $0 0 $0 0 $0 $1,500,000 1 $1,500,000 7%
GRAND TOTAL 7 $3,925,374 30 $16,194,942 0 $0 0 $0 $1,500,000 38 $21,620,316
%of Total Award 18.1% 74.9% 0% 0% 6.9%
Project level award summary:
Permanent Housing
PH-Permanent Supportive Housing
Recipient Name Project Name Project Type Awarded Amount
Lubbock Open Door Lubbock Open Door PSH Combined Renewal project $1,651,955.00
Denton County MHMR Connections PSH FY24 Renewal project $1,407,284.00
Mid-Coast Family Services Next Step Combined Renewal project $988,569.00
The Gulf Coast Center GCC Permanent Housing Renewal project $676,695.00
Grace Like Rain,Inc. GG Replacement PSH FY2024 New project $546,052.00
Abilene Regional MHMR Center dba Betty Hardwick Permanent Supportive Housing Plus New project $478,196.00
Center
Abilene Regional MHMR Center dba Betty Hardwick Permanent Supportive Housing Renewal project $281,704.00
*Specific project-level award information for Continuums of Care can be found at https://www.hudexchange.info/grantees/allocations-awards/
'Expansion Projects include the combined total for renewal projects being expanded and their expansion amounts,and are excluded from the separate renewal project awarded totals.
P.tMEW of
IIIIIIII Q��= HUD's 2024 Continuum of Care Program Funding Awards*
9egN DEVE�o
PH-Permanent Supportive Housing
Recipient Name Project Name Project Type Awarded Amount
Center
Neighborhood Development Corp Homeless to Homes Program Renewal project $249,062.00
The Salvation Army-Temple,TX The Salvation Army-Temple CoC Permanent Supportive Renewal project $197,146.00
Housing Program
The Salvation Army,a Georgia Corporation Transforming Lives FY2024 Renewal project $193,173.00
PH-Rapid Re-housing
Recipient Name Project Name Project Type Awarded Amount
Families In Crisis,Inc. FIC_RRH_DV2_FY24 Renewal project $1,331,125.00
Families In Crisis,Inc. FIC_RRH_DVl_FY24 Renewal project $1,135,950.00
Catholic Charities of the Archdiocese Galveston-Houston RRH Galveston FY 2024 New project $957,946.00
West Central Texas Regional Foundation New Housing Vision Renewal project $862,655.00
Christian Community Action Rapid Rehousing and Rescue Services FY24 Renewal project $543,797.00
Grace Like Rain,hic. GG Rapid Rehousing FY2024 Renewal project $463,617.00
Denton County Friends of the Family,Inc. Rapid Rehousing and Supportive Services for Domestic Renewal project $414,330.00
Violence Survivors
Odessa Links Project Hope FY2024 Renewal project $397,341.00
Good Neighbor Settlement House Restoring Futures through Rapid Rehousing New project $394,360.00
The Salvation Army,a Georgia Corporation Project Bridge Rapid Rehousing FY2024 Renewal project $374,004.00
Abilene Regional MHMR Center dba Betty Hardwick Rapid Rehousing Renewal project $328,581.00
Center
Salvation Army,The TSA Grayson,Fannin,and Cooke Counties Rapid Rehousing New project $328,513.00
CoC Project
City of Texarkana Texarkana Homeless Coalition:Doorways Home Renewal project $320,279.00
Housing Authority of the City of Laredo Laredo Housing Authority RRH FY 2024-2025 Renewal project $261,512.00
Resource and Crisis Center of Galveston County,Inc. RCCGC DV-RRH Project 2024 Renewal project $244,910.00
Sabine Valley Center Fredonia Homeless and Disabled Women and Children Rapid Renewal project $228,718.00
Rehousing
The Salvation Army-Temple,TX The Salvation Army-Temple CoC Rapid Rehousing Program Renewal project $223,849.00
Housing Authority of San Angelo COSA Rapid Rehousing Renewal project $216,144.00
Safer Path Family Violence Shelter,Inc. Rural Rapid ReHousing for Domestic Violence Survivors in Renewal project $208,367.00
Atascosa County
Joint TH-Rapid Re-housing
*Specific project-level award information for Continuums of Care can be found at https://www.hudexchange.info/grantees/allocations-awards/
'Expansion Projects include the combined total for renewal projects being expanded and their expansion amounts,and are excluded from the separate renewal project awarded totals.
P.tMEW of
IIIIIIII Q��= HUD's 2024 Continuum of Care Program Funding Awards*
9egN DEVE�o
Recipient Name Project Name Project Type Awarded Amount
Lubbock Open Door Survivor Housing TH-RRH Renewal project $1,258,303.00
The Heights Ellis County Family Resources,Inc. HIVE:Housing-Integrated Victim Empowerment New project $701,388.00
SAMARITAN WOMEN AT THE WELL GRACE TRANSITIONAL AND RAPID RE-HOUSING New project $518,919.00
Mid-Coast Family Services Pathways Renewal project $317,743.00
Friendship of Women,Inc. Pathways to Safe Housing Renewal project $293,573.00
Supportive Services Only
Recipient Name Project Name Project Type Awarded Amount
Homeless Network of Texas(dba Texas Homeless Network) TX BoS CoC SSO-CE FY24 Renewal project $295,300.00
United Way of Denton County FY2024 CoC SSO-CE Renewal project $130,686.00
HMIS
Recipient Name Project Name Project Type Awarded Amount
Homeless Network of Texas(dba Texas Homeless Network) TX BoS CoC HMIS Project FY2024 Renewal Renewal project $698,570.00
CoC Planning Grant
Recipient Name Project Name Project Type Awarded Amount
Homeless Network of Texas(dba Texas Homeless Network) TX-607 CoC Planning Project FY2024 Planning project $1,500,000.00
*Specific project-level award information for Continuums of Care can be found at https://www.hudexchange.info/grantees/allocations-awards/
'Expansion Projects include the combined total for renewal projects being expanded and their expansion amounts,and are excluded from the separate renewal project awarded totals.
2025 COC COMPETITION
OVERVIEW
L a i m"
For the TX BoS CoC F F , �
Presented by Jessica Sones
FRAMEWORK STRATEGIES I=RAMEWORI<
FY25 COC NOFO, FRAMEWORK STRATEGIES S T R A T E G 1 1E S
Please mute when not talking to
4X cut down on background noise
WEBINAR Feel free to type in questions or
unmute to ask questions during
LOGISTICS the question breaks
We'll have time for discussion &
Q&A at the end
FY25 COC NOFO,FRAMEWORK STRATEGIES 2
Intro to Continuum of Care + THN
High-Level CoC NOFO Overview
Key Changes in the FY24 CoC NOFO
HUD Policy Priorities
WEBINAR Funding and Tiering Information
AGENDA Scoring of the CoC-Level Application
New Projects
Renewal Projects
Resources
Q&A
FY25 COC NOFO,FRAMEWORK STRATEGIES 3
What is a CoC?
A CoC, as defined by the U.S. Department of Housing and Urban
Development (HUD) in the CoC Program Interim Rule at 24 CFR Part 578.3,
is the group organized to carry out the responsibilities required under the
CoC Program for a defined geographic area.
0
• A community-based planning network for homelessness assistance.
0'0
The geographic area covered by the community-based planning
network.
A program operated by the U.S. Dept. of Housing & Urban
Development (HUD).
TH N and the TX BoS CoC
• THN is the Collaborative Applicant for the
Texas Balance of State Continuum of Care
(TX BoS CoC)
• THN is also the HMIS Lead Agency for the
TX BoS CoC
• TX BoS CoC covers 214 of Texas' 254
counties (85% of Texas' land mass)
• Facilitates the application process forCoC
Program Funding in that geographic
HIGH =LEVEL •
NOFO OVERVIEW
FY25 COC NOFO, FRAMEWORK STRATEGIES 6
Continuum of Care or CoC
This can refer to the Continuum of Care Program, administered
by HUD
This can also refer to the local Continuum of Care
Notice of Funding Opportunity — NOFO
Renewal Projects — projects that currently receive CoC
Program funds that can be renewed
New Projects — projects that are not currently receiving
CoC Program funds and would be "new" to the
community
Reallocation — process by which funds are moved
from existing projects to new projects
Annual Renewal Demand — the amount of funds for a
CoC to renew all existing projects
FY25 COC NOFO,FRAMEWORK STRATEGIES 7
Who Can Apply?
Eligible Applicants include:
State governments
County governments
City or township governments
Special district governments
Native American tribal governments (Federally recognized)
Public housing authorities/Indian housing authorities
Native American tribal organizations (other than Federally
recognized tribal governments))
Nonprofits havinga 501 (c)(3) status with the IRS, other than
institutions of hig er education
Faith-based organizations may apply on the same basis as any
other organization. HUD does no enga a in any unlawful and
improper conduct, policies, or practices1hat target faith-based
organizations.
CoC Program and the NOFO
CoC Program Goals CoC Program NOFO
Move people from homelessness to HUD's primary competitive grant
housing with supportive services. program to fund local homeless
Promote community commitment to response systems.
ending homelessness. Goal is to maintain strong existing
programs; may include bonus funding for
Improve access to mainstream new projects.
programs.
Collaborative Applicant THN submits a
Support self-sufficiency. single consolidated application on behalf
Provide funding to quickly rehouse of TX-607 (TX BoS CoC).
and reduce trauma. Only way to apply for HUD CoC funding.
9
HIGH - LEVEL OVERVIEW
Local CoCs apply to HUD for CoC Program funding through the CoC
Notice of Funding Opportunity (NOFO) Competition.
CoC Program funds are competitive. Each CoC is eligible to apply for a
maximum amount of money, but only a portion of these funds is "safe".
As part of the CoC NOFO Competition, CoCs submit renewal project
applications (existing grantees that wish to renew their funding) and new
project applications.
FY25 COC NOFO, FRAMEWORK STRATEGIES 10
HIGH - LEVEL OVERVIEW
Prior to submitting the community's application to HUD for
funding through the CoC Program NOFO, the CoC facilitates a
local funding competition . This local competition includes:
Evaluating the performance of renewal projects (existing CoC grantees)
to determine which renewal projects will be submitted to HUD for
funding, and how they will be ranked.
Soliciting and selecting new projects. When HUD releases the NOFO,
they indicate how much new funding each CoC is eligible to apply for.
FY25 COC NOFO, FRAMEWORK STRATEGIES 11
HIGH - LEVEL OVERVIEW
HUD uses a 2-Tier system when awarding funding.
Tier 1 = "Safe" funds
Tier 2 = Competitive funds
All CoCs nationally compete for their projects in Tier 2.
Once the local CoC evaluates and selects the renewal project applications
and new project applications to be submitted to HUD, CoCs are required to
rank all projects.
Example: If the CoC is submitting 50 projects to HUD, projects are ranked 1 to 50.
Projects are ranked/prioritized by the CoC based on locally established funding
priorities and policies.
Once the CoC completes its ranking, some projects will fall into Tier 2.
FY25 COC NOFO, FRAMEWORK STRATEGIES 12
PARTS OF THE CoC CONSOLIDATED
APPLICATION SUBMISSION
Application
• Completed by the Collaborative Applicant (THN).
• Questions relate to how the operates, governance structure, overall performance, policies, and strategies.
• This part of the application is scored and will determine the amount of funding each CoC receives.
Project Applications
• Completed by renewal project applicants and new project applicants.
• These are the applications that describe what each project is requesting funding to do.
• Renewal project applicants and new project applicants must apply through their local CoC Competition and be
accepted by the CoC. If accepted, they then apply through e-snaps (HUD's application system).
77MMEM-s"
• Completed by the Collaborative Applicant (THN).
• This list includes all project applications.
• The CoC must rank all projects except the Planning project. This is also where the CoC tells HUD if it is planning
to reallocate funds (take funds from an existing grant and put toward new projects).
FY25 COC NOFO, FRAMEWORK STRATEGIES 13
HIGHLIGHTS & KEY
CHANGES IN THE
FY25 CoC NOFO
• FY25 Application : All materials due to HUD on January 14th,
2025
Internal deadlines: Refer to the RFP for a more detailed timeline
Issuance of RFP 12/1/2025 9:00:00 AM
Threshold Review and Full Application Open in Apply 12/1/2025 9:00:00 AM
Threshold Review Stage Closes in Apply 12/3/2025 8:59:59 PM
Full Applications(Preliminary&e-snaps)due 12/10/2025 4:59:59 PM
- Anticipated award date is May 1 , 2026
This means that FY25 projects with start dates before 5/1 /26 will not know
whether they are funded until after their grant start date.
,', IMPORTANT mv ,
DEADLINES/DATES
FY25 COC NOFO,FRAMEWORK STRATEGIES 15
• Changes to Tier 1 & Tier 2:
• Tier 1 is set at 30% Annual Renewal Demand (ARD) (90% in
FY24)
Formula to determine Tier 2 funding prioritizes Service Participation
requirements (prior years Housing First prioritized)
• Permanent Housing Cap: No more than 30% of a CoC's ARD can
be used for Permanent Housing projects, including Permanent
Supportive Housing (PSH), RRH (Rapid Rehousing) and Joint
SUMMARYTransitional Housing (TH) and RRH projects.
• New Projects:
OF KEY HUD is allowing and encouraging CoCs to create new TH and
Supportive Service Only (SSO) — including Street Outreach - projects
CHANGESDV Bonus can be used to create new TH projects.
TH-RRH renewals allowed but no new TH-RRH projects allowed
Significant changes to project quality threshold criteria for new
projects
• Major changes to the majority of the CoC Application
rating factors
• Emphasis on treatment/recovery, service participation requirements,
engagement with law enforcement, participant self-sufficiency
FY25 COC NOFO,FRAMEWORK STRATEGIES 16
CoCs can reallocate funding from any eligible grant, including grants
that have not been previously renewed under the CoC Program, as
long as the grant is expiring in CY2026.
To create a Transition Grant through the reallocation process, the
CoC must wholly eliminate one or more projects and use those funds
to create the single, new transition grant.
REALLOCATION Renewal Grants expiring in CY 2026 may submit a FY 2025
transition grant application to request a component type change.
ANThe transition grant's operating start date will be the day after the
TRANSITION
end of the previous grant term for the expiring component.
Transition grant applications awarded FY 2025 funds must fully
GRANTtransition to the new component by the end of the 1-year grant term.
DV Reallocation may be used for previously funded DV Bonus
projects to create new SSO-Coordinated Entry, Rapid Re-housing
(PH-RRH), and Transitional Housing (TH) projects that are DV-
dedicated. Projects previously funded under the DV Bonus cannot use
the transition process.
FY25 COC NOFO,FRAMEWORK STRATEGIES 18
HUD GOALS & OBJECTIVES
FY2024 CoC NOFO FY2025 CoC NOFO
1) Ending homelessness for all persons Ending the Crisis of
2) Using a Housing First Approach Homelessness on Our Streets
3) Reducing Unsheltered Homelessness Prioritizing Treatment and
4) Improving System Performance Recovery
5) Partnering with Housing, Health and Service
Agencies 3) Advancing Public Safety
6) Racial Equity
7) Improving Assistance to LGBTQ+ Individuals 4) Promoting Self-Sufficiency
8; Persons with Lived Experience/Expertise 5) Improving Outcomes
9) Building an Effective Workforce Increasing
Affordable Housing Supply 6) Minimizing Trauma
FY25 COC NOFO,FRAMEWORK STRATEGIES 19
FY25 COC NOFO, FRAMEWORK STRATEGIES 20
FUNDING & TIERING OF
PROJECTS
Tier 1 = 30 percent Annual Renewal Demand (ARD)
ARD = Total of all renewal projects
DV Bonus projects are competitive
Tier 2 = The difference between Tier 1 and the sum of each
CoC's ARD, CoC Bonus, and DV Bonus.
CoC Bonus = 20% of Final Pro Rate Need (FPRN), which is
the higher of ARD and Preliminary Pro Rata Need (PPRN)
In addition, HUD is awarding an additional $52M in bonus
projects specifically for survivors of domestic violence.
DV Bonus = 10% of PPRN
FY25 COC NOFO, FRAMEWORK STRATEGIES 21
FUNDING CHANGES MEAN
HARD CHOICES
CoCs will need to make two difficult sets of
decisions due to the changes HUD has
implemented :
Determine which PH projects will be included
in the 30% of ARD that can be submitted for
PH .
Determine which projects will be included in
Tier 1 , thereby prioritizing them for funding .
FY25 COC NOFO, FRAMEWORK STRATEGIES 22
What does this mean for the TX BoS CoC ?
The CoC may apply for up to $37,045,004.
This includes the ARD + CoC Bonus + DV Bonus + CoC Planning grant.
$5,136,017.40 is considered safe in Tier 1 .
The CoC Planning grant is non-competitive.
CoC Number Estimated
and Name • - D -
MOWTX-607 $66,674,731 $17,210,058 $5,163,017 $13,334,946 $5,000,000 $1,500,000
FY25 COC NOFO, FRAMEWORK STRATEGIES 23
What does this mean for the TX BoS CoC ?
- - • 30% of ARD is
Permanent *Of ARD $5, 136,017.40
Housing amount
(PH) In order to comply with
PSH 9 $5,017,881 29.16% HUD's limitations, the
RRH 19 $9,235,998 53.67%
CoC will have to
TH/RRH 4 $1 ,831 ,623 10.64%
TOTAL 32 $16,085,502 93% reduce PH by
$1039499485.
FY25 COC NOFO, FRAMEWORK STRATEGIES 24
THE SCORING OF
APPLICATION
FY25 COC NOFO, FRAMEWORK STRATEGIES 25
SCORING OF COC— LEVEL APPLICATION
ComparisonCategories, Change
wwww 2025
Project Ranking, Review, • • - 30 27 M� 9 MIN
System Performance 59 60 60 40 r
CoC-Coordination and - - 83 854W 81 low
Hometess Management Information System9 9 9 0* 01-9
Point-in-Time 5 5 5 0* -5
Coordination with Housing and HeaLthcare14 14 14 0* -14
• 200 200 200 130 -70
*While Homeless Management Information System, Point-in-Time Count, and Coordination with Housing and Healthcare are not a stand-alone
Rating Factor Categories this year, questions related to each of these remain and are incorporated into other categories. Notably, HUD will
award up to 4 points for Housing/Healthcare Leveraging, as in past years (this is part of the CoC Coordination and Engagement points above).
FY25 COC NOFO,FRAMEWORK STRATEGIES 26
NOFO provides a maximum of 4 policy initiative
preference points, which are added to the CoC's overall
application score, for the following:
Opportunity Zones:
CoCs may receive up to 4 points if proposed activities are
POLICY
within an Opportunity Zone.
Must use at least 50% of the award in Opportunity Zones
INITIATIVE
to receive preference points.
PREFERENCE
Verification of Immigration Status:
CoCs may receive up to 4 points if they can demonstrate
POINTS that all CoC projects that are non-profit charitable
organizations voluntarily, thoroughly, and demonstrably
facilitate immigration status verification before distribution
of benefits to all recipients using SAVE directly or in
coordination with a governmental entity.
FY25 COC NOFO,FRAMEWORK STRATEGIES 27
FY25 COC NOFO, FRAMEWORK STRATEGIES 28
The Project Eligibility Threshold requirements listed below apply to all
projects being submitted. HUD will use a pass/fail standard and if a
project fails, it will be rejected for funding consideration.
Project Eligibility Thresholds (p. 53 of the NOFO) for all projects include:
Project applicants and potential subrecipients must meet the eligibility
requirements of the CoC Program per the McKinney-Vento Act and
CoC Interim Rule and provide evidence of eligibility required in the
application (e.g., nonprofit documentation).
GENERAL 2) Project applicants and subrecipients must demonstrate
financial/management capacity and experience to carry out the project
and the capacity to administer federal funds.
PROJECTProject applicants must submit the required certifications specified in
the NOF p.
ELIGIBILITY The population to be served must meet program elZt,
bility
requirements as described in the McKinney ento the CoC
THRESHOLDS Interim Rule, and in the NOFO.
Project applicants (except for Planning funds) must agree to
participate in a local HM1S system. Victim service provider must use a
comparable database that meets the needs of the local HMIS.
Project applicants must certify affirmatively to the following:
The prol�ect applicant will not engage in racial preferences or other forms
of illegal discrimination.
The project applicant will not operate drug injection sites or "safe
consumption sites, knowingly distribute drug paraphernalia on or off of
property under their control, permit the use or distribution of illicit drugs
FY25 COC NOFO, FRAMEWORK STRATEGIES on propertyunder their controls or conduct any of these activities under
the pretext of harm reduction. 29
COORDINATED ENTRY AND HMIS
REQUIREMENTS
Coordinated Entry Participation — FY25 CoC NOFO states: "24 CFR 578.23(c)(9)
and (11 ) requires all CoC program recipients and subrecipients to use the
centralized or coordinated assessment system established by CoCs."
Exception for victim service providers: "Section 578.23(c)(9) of the CoC Program Rule
exempts victim service providers from using the CoC's coordinated entry process if victim
service providers use a coordinated entry process that otherwise meets HUD's
requirements."
HMIS Participation — Participation in HMIS, or a comparable database if a victim
service provider, is a project eligibility threshold requirement.
FY25 COC NOFO, FRAMEWORK STRATEGIES 30
FY25 COC NOFO, FRAMEWORK STRATEGIES 31
NEW PROJECTS
Eligible under CoC Bonus: Specific allowances:
Transitional Housing (TH) Transition Grants
Supportive Services Only (SSO) Standalone
SSO Street Outreach
All new projects will be reviewed by
Eligible under DV Bonus HUD to determine if they meet project
Transitional Housing (TH) quality threshold requirements
FY25 COC NOFO, FRAMEWORK STRATEGIES 32
New project applicants can apply for funds for the
following categories of eligible costs, also known as
Budget Line Items (BLIs):
Rental Assistance
Leasing
Operating
Supportive Services
FUNDING & HMIS
MATCH VAWA Costs
Rural Costs (if applicable)
Administrative Costs
"Acquisition, New Construction, and Rehabilitation
are allowable but not renewable. As such, most
CoCs do not allow for projects to submit for these
funds given the limited funding available.
FY25 COC NOFO,FRAMEWORK STRATEGIES 33
• There are various restrictions that apply to the eligible
costs/BLIs.
• 24 CFR Part 578 Subpart D;
https://www.ecfr.gov/current/title-24/subtitle-B/chapter-
V/subchapter-C/part-578/subpart-D
• CoC Binder: https://www.hudexchange.info/homelessness-
assistance/coc-esq-virtual-binders/
FUNDING & ' The CoC's New Project RFP/Solicitation will include more
information on what is allowed.
MATCH • Match: All CoC J ro'ects have a 25% match re uirement
p q
(minus the leasing budget line item), including new projects.
• 24 CFR 578.73: https://www.ecfr.gov/current/title-24/subtitle-
B/chapter-V/subchapter-C/part-578#578.73
• CoC Binder: https://www.hudexchange.info/homelessness-
assistance/coc-esq-virtual-binders/coc-match/coc-match-
overview/
FY25 COC NOFO,FRAMEWORK STRATEGIES 34
CoC funding requires a 25% match — either cash or
in-kind. The only exception is that leasing costs do
not require a match.
When submitting a new project application to
HUD, you must identify your sources of match
(organization providing match), type of match
(cash or in-kind), and amount. It is best to have
a commitment letter for the application.
If selected by HUD for a new project, match
documentation will be due to HUD before you
can enter into your grant agreement. This is
when you will develop a more formal MOU or
M OA.
FY25 COC NOFO,FRAMEWORK STRATEGIES 35
Cash Match — when the CoC recipient or subrecipient
spends actual funds on eligible CoC Program costs.
Cash Match examples
Grants from private, local, state, and federal
resources (if not statutorily prohibited by source)
Cash resources
Recipient or subrecipient staff working on grant
eligible activities who aren't paid from the CoC It
Program grant but are paid from other agency
resources
https://www.hudexchange.info/homelessness-
assistance/coc-esg_ -virtual-binders/coc-match/coc-match-
overview/
FY25 COC NOFO,FRAMEWORK STRATEGIES 36
In-Kind Match —The value of any real property, equipment,
goods, or services contributed to a CoC Program grant
that would have been an eligible CoC Program activity if the
recipient or subrecipient paid for them directly with CoC
Program funds.
Example: A commitment from a local partner organization to
provide supportive services to participants in your program.
If the supportive service being provided would have been Akk
eligible as a CoC supportive service, generally it would be
eligible as in-kind match.
If an activity is not an eligible cost of CoC Program funds,
then it is also not an eligible expense of match funds.
https://www.hudexchange:info/homelessness-assistance/coc-
esq-virtual-binders/coc-match/coc-match-overview/
FY25 COC NOFO,FRAMEWORK STRATEGIES 37
Allowed Budget Line Items (BLIs) related to housing costs:
Operating
Funds to operate a site owned or leased by your agency
Only specific costs are eligible
Leasing (of a single site or scattered-site housing units)
Under a Leasing model, the provider enters into the lease with the landlord
HOUSING and has a sublease or rental agreement with the program participant.
The provider pays 100% of the rent (up to Fair Market Rent) and the program
RELATED participant pays 30% of household income to the provider.
When calculating 25% match requirement, leasing dollars are excluded from
match requirement (i.e, total grant minus leasing * 25% = match
ELIGIBLE requirement).
COSTS Rental Assistance
Three types of Rental Assistance: Tenant Based (TBRA), Sponsor Based
(SBRA), or Project Based (PBRA)
Under Rental Assistance model, the program participant enters into the lease
with the landlord (TBRA, PBRA) or sublets from a sponsor agency (SBRA)
and pays 30% of their income to the landlord/sponsor with the provider
paying the balance of rent owed.
Rental Assistance CANNOT be combined with Operating
More info: https://www.hudexchange.info/homelessness-assistance/coc-esq-
virtual-binders/coc-eligible-activities/coc-eligible-activities-overview/
FY25 COC NOFO,FRAMEWORK STRATEGIES 38
How do you know whether to request Operating,
Leasing, or Rental Assistance for a project?
RRH — Only Tenant-Based Rental Assistance is
allowed
Does your organization own the building that the
HOUSING project will be operated out of? OPERATING
RELATEDDoes your organization plan to enter into a lease
directly with the landlord, then sublease to a
ELIGIBLE participant? LEASING
COSTSDoes your organization plan to have the participant
enter directly into a lease with the landlord? RENTAL
ASSISTANCE
FY25 COC NOFO,FRAMEWORK STRATEGIES 39
The CoC Interim Rule lists Supportive Services
eligible activities/costs as follows:
annual assessment of service needs,
assistance with moving costs,
case management,
SUPPORTIVE edludcation services,
SERVICES IN employment assistance and job training,
food,
THE CoC housing search and counseling services,
legal services,
INTERIM life skills training,
mental health services,
RULE outpatient health services,
outreach services,
substance abuse treatment services,
transportation,
utility deposits, and
costs related to direct provision of services
24 CFR 578.53: https://www.ecfr.gov/current/title-24/section-578.53
FY25 COC NOFO,FRAMEWORK STRATEGIES 40
VAWA COSTS BLI ( NEW AS OF 2023 )
In FY2023, HUD introduced the VAWA Costs Budget Line Item (BLI). Eligible activities
include:
costs related to facilitating and coordinating activities to ensure compliance with the CoC's
emergency transfer plan, such as assistance with moving costs, travel costs, security deposits,
utilities, housing fees, case management, housing navigation, and technology to make an available
unit safe
costs for ensuring compliance with VAWA confidentiality requirements
Please note that in your renewal application all renewal projects will automatically have
the VAWA funding checkbox selected for them, and this box cannot be unchecked.
This allows for funds to be moved into the new VAWA BLI upon request to your field office. Since
the costs associated with emergency transfers cannot be fully predicted and planned in advance,
this will allow grantees to work with their field office to move money into this BLI at a later time if the
need arises.
In general, HUD is allowing renewal projects to shift up to 10% from one BLI to another
BLI. This would include shifting funds to the VAWA Costs BLI from another BLI.
Applicants wishing to shift funds to this BLI should consult with their CoC prior to doing so.
FY25 COC NOFO, FRAMEWORK STRATEGIES 41
RURAL COSTS BLI ( NEW AS OF 2023 )
In FY2023, HUD introduced the Rural Costs Budget Line Item (BLI). Eligible activities
include:
Short-term emergency lodging, including in motels or shelters, directly or through vouchers
Repairs to units in which homeless individuals and families will be housed; or are currently not fit
for human habitation
Staff training, professional development, skill development, and staff retention activities
Applicants must serve rural geographies. The list of rural areas can be found here:
https://www.hud.gov/sites/dfiles/CPD/documents/CoC/FY25-CoC-Rural-Area-Geocode-
Report.pdf
Renewal projects may shift up to 10% to the Rural Costs BLI from another BLI.
Applicants wishing to shift funds to this BLI should consult with their CoC prior to doing so.
FY25 COC NOFO, FRAMEWORK STRATEGIES 42
FY25 COC NOFO, FRAMEWORK STRATEGIES 43
TRANSITIONAL HOUSING (TH
The TH program component is described by the CoC Program Interim Rule as follows:
"TH facilitates the movement of homeless individuals and families to PH within 24 months
of entering TH. Grant funds may be used for acquisition, rehabilitation, new construction,
leasing, rental assistance, operating costs, and supportive services."
There is no restriction stated in the FY25 NOFO regarding the allowed BLIs for TH
projects. Unlike with TH/PH-RRH projects, there is no restriction on the use of rental
assistance for TH.
The FY25 NOFO does not state TH projects must be site-based.
FY25 CoC NOFO: New TH projects may serve persons who qualify as homeless under
paragraphs (1 ), (2), or (4) of 24 CFR 578.3.
FY25 COC NOFO, FRAMEWORK STRATEGIES 44
TRANSITIONAL HOUSING
"Recipients and subrecipients may require the program participants to take
part in supportive services that are not disability-related services provided
through the project as a condition of continued participation in the program.
Examples of disability-related services include, but are not limited to, mental health
services, outpatient health services, and provision of medication, which are provided to a
person with a disability to address a condition caused by the disability.
Notwithstanding this provision, if the purpose of the project is to provide substance
abuse treatment services, recipients and subrecipients may require program participants
to take part in such services as a condition of continued participation in the program."
https://www.ecfr.gov/current/title-24/subtitle-B/chapter-V/subchapter-C/part-578/subpart-F#p-
578.75 h
FY25 COC NOFO, FRAMEWORK STRATEGIES 45
TRANSITIONAL HOUSING
TH projects can cover housing costs and accompanying supportive services for program
participants for up to 24 months.
Participants in a TH project must have a signed lease, sublease, or occupancy agreement
with the following requirements:
An initial term of at least one month
Automatically renewable upon expiration, except by prior notice by either party
A maximum term of 24 months
Per HUD: TH participants may remain in the project past 24 months if appropriate
permanent housing has not been identified or if more time is needed for the household to
achieve independence. However, HUD may discontinue TH funding if more than half of
the households have exceeded 24 months.
Specific maximum length of stay will be set by the CoC Written Standards.
FY25 COC NOFO, FRAMEWORK STRATEGIES 46
HUD project quality threshold for Transitional Housing projects - must receive
at least 7 out of 10 points to pass threshold.
2 points - Demonstrate that the project will provide and/or partner with other
organizations to provide eligible supportive services that are necessary to
assist program participants to obtain and maintain housing.
1 point - The applicant has prior experience operating transitional housing or
other projects that have successfully helped homeless individuals and families
exit homelessness within 24 months.
1 point - The applicant has previously operated or currently operates
transitional housing or another homelessness project, or has a plan in place to
TH : PASSING ensure, that at least 50 percent of participants exit to permanent housing within
24 months and at least 50 percent of participants exit with employment income
as reflected in HMIS or another data system used by the applicant.
HUD 1 point - The project will be supplemented with resources from other public or
private sources, that may include mainstream health, social, and employment
THRESHOLD programs such as Medicare, Medicaid, SSI, and SNAP.
2 points - Demonstrate that the proposed project will require program
participants to take part in supportive services (e.g. case management,
REVIEW
employment training, substance use treatment, etc) in line with 24 CFR
578.75(h) by attaching a supportive service agreement (contract, occupancy
agreement, lease, or equivalent).
2 points - Demonstrate that the proposed project will provide 40 hours per
week of customized services for each participant (e.g. case management,
employment training, substance use treatment, etc.). The 40 hours per week
may be reduced proportionately for participants who are employed. The 40
hours per week does not apply to participants over age 62 or who have a
physical disability/impairment or a developmental disability (24 CFR 582.5) not
including substance use disorder.
1 point - Demonstrate the average cost per household served for the project is
reasonable, consistent with 2 CFR 200.404.
FY25 COC NOFO, FRAMEWORK STRATEGIES 47
SUPPORTIVE SERVICES ONLY
STANDALONE (SSO
SSO program component is described by the CoC Program Interim Rule as follows: "Supportive
Service Only (SSO). Funds may be used for acquisition, rehabilitation, relocation costs, or leasing of
a facility from which supportive services will be provided, and supportive services in order to provide
supportive services to unsheltered and sheltered homeless persons for whom the recipient or
subrecipient is not providing housing or housing assistance. SSO includes street outreach."
Prior HUD documentation indicates "SSO projects may provide supportive services to households
living in emergency shelters. This includes emergency shelters operated by an organization that is
also a recipient of CoC Program SSO funds." Framework has submitted a question to HUD about
this.
Supportive services may be offered in a structure or structures at one central site, or in multiple
buildings at scattered sites where services are delivered. Projects may be operated independent of a
building (e.g., street outreach) and in a variety of community-based settings, including in homeless
programs operated by other agencies.
FY25 COC NOFO, FRAMEWORK STRATEGIES 48
SUPPORTIVE SERVICES ONLY
STANDALONE (SSO
New SSO projects may serve persons who qualify as homeless under paragraphs (1 ),
(2), or (4) of 24 CFR 578.3.
Must consult the CoC's Written Standards about serving Category 2/those as risk of
homelessness.
Additionally, SSO projects are designated as serving those experiencing unsheltered
and sheltered homelessness so it is unclear if Category 2 can be served in SSO.
https://files.hudexchange.info/resources/documents/coc-program-sso-housing-
component-decision-tool.pdf:
"Households at risk of homelessness who do not meet the definition of homelessness
may not be served by CoC Program-funded SSO projects."
FY25 COC NOFO, FRAMEWORK STRATEGIES 49
The CoC Interim Rule lists Supportive
Services eligible activities/costs as follows:
annual assessment of service needs,
assistance with moving costs,
case management,
childcare, SUPPORTIVE
education services,
employment assistance and job training, SERVICES
food, ONLY
housing search and counseling services,
legal services, STANDALONE
life skills training,
mental health services, (SSO)
outpatient health services,
outreach services,
substance abuse treatment services,
transportation,
utility deposits, and
costs related to direct provision of services.
FY25 COC NOFO, FRAMEWORK STRATEGIES 50
HUD project quality threshold for Supportive Service Only
(SSO) Standalone projects - must receive at least 4 out of 5
points to pass threshold.
1 point - The Supportive Services project is necessary to assist
people in exiting homelessness and increasing self-sufficiency
SS
O
and the Recipient will conduct an annual assessment of the
service needs of the program participants.
STAN DALQUL 2 points - The proposed project has a strategy for providing
supportive services to eligible program participants including
PASSING • ■ those with histories of unsheltered homelessness and those who
THRESHOLD
do not traditionally engage with supportive services.
1 point - The project will be supplemented with resources from
REVIEWother public or private sources, that may include mainstream
61 health, social, and employment programs such as Medicare,
Medicaid, SSI, and SNAP.
1 point - The services provided are cost-effective consistent with
44 2 CFR 200.404.
FY25 COC NOFO,FRAMEWORK STRATEGIES 51
For SSO Street Outreach projects, the NOFO references
the outreach services activities stated in the CoC Interim Pr
Rule as the allowed activities:
"(13) Outreach services. The costs of activities to engage SUPPORTIVE
persons for the purpose of providing immediate support
and intervention, as well as identifying potential program SERVICES
participants, are eligible.
ir
(i) Eligible costs include the outreach worker's ONLY
transportation costs and a cell phone to be used by the
individual performing the outreach. STREET
(ii) Component activities and services consist of: initial OUTREACH
assessment; crisis counseling; addressing urgent physical (SSOMSO)
needs, such as providing meals, blankets, clothes, or
toiletries; actively connecting and providing people with
information and referrals to homeless and mainstream
programs; and publicizing the availability of the housing
and/or services provided within the geographic area
covered by the Continuum of Care."
FY25 COC NOFO, FRAMEWORK STRATEGIES 52
HUD project quality threshold for Supportive Service Only (SSO)
Street Outreach projects - must receive at least 5 out of 6 points to
pass threshold.
1 point - The project will be supplemented with resources from other
public or private sources, that may include mainstream health, social, and
employment programs such as Medicare, Medicaid, SSI, and SNAP.
2 points - The proposed project has a strategy for providing supportive
services to eligible program participants including those with histories of
FFTSSO STREET unsheltered homelessness and those who do not traditionally engage with
supportive services.
OUTREACH : 1 point - Demonstrate that the applicant has a history of partnering with
first responders and law enforcement to engage people living in places
PASSINGnot meant for human habitation to access emergency shelter, treatment
programs, reunification with family, transitional housing or independent
THRESHOLDliving. The applicant must cooperate, assist, and not interfere or impede
with law enforcement to enforce local laws such as public camping and
REVIEWpublic drug use laws.
1 point - The applicant has experience providing outreach services
consistent with the activity description at 24 CFR 578.53(e)(13) and has
demonstrated effectiveness at helping people successfully exit from
places not meant for human habitation to emergency shelter, treatment
programs, transitional housing or permanent housing programs.
1 point - The services provided are cost-effective consistent with 2 CFR
200.404.1 point
FY25 COC NOFO,FRAMEWORK STRATEGIES 53
(RENEWAL REALLOCATES TRANSITION
TO CREATE NEW WITH
ONE YEAR TO GRANTS
TRANSITION)
TRANSITION GRANTS
A grant to fund a new project to transition an eligible renewal project being
eliminated through reallocation from one program component to another over a
1 -year period.
CoC Renewals can reallocate the existing eligible renewal component to one of
the eligible new project components: TH, SSO, or SSO for Street Outreach,
Must be the same recipient for the eligible renewal grant(s) being eliminated.
Total budget amount remains the same.
DV Renewal projects are not eligible to use the transition process.
FY25 COC NOFO, FRAMEWORK STRATEGIES 55
TRANSITION GRANTS
Will have one year to fully transition from the original component to the new
component and this will take place during the transition grants normal operating
year
To create a Transition Grant, the CoC must wholly eliminate one or more
projects and use those funds to create the single, new transition grant.
Transition grants in this Competition are eligible for renewal in subsequent fiscal
years for eligible activities of the new program component.
To be eligible to receive a transition grant, the renewal project applicant must
have the consent of its Continuum of Care and meet the standards.
FY25 COC NOFO, FRAMEWORK STRATEGIES 56
FY25 COC NOFO, FRAMEWORK STRATEGIES 57
DV BONUS : OVERVIEW
$52 million available. CoC may apply for up to 10 percent of its Preliminary
Pro Rata Need (PPRN), or a minimum of $50,000 to create DV Bonus
projects
DV Bonus projects will be selected using the same Tier1 and Tier 2 as all
other projects
A CoC may apply for the following type of projects:
Transitional Housing (TH) projects dedicated to serving survivors of domestic violence,
dating violence, sexual assault or stalking
FY25 COC NOFO, FRAMEWORK STRATEGIES 58
IDV BONUS : Additional Information
New standalone project
DV Bonus funding may not be combined with other new project funding, including
DV Reallocation, reallocation, or CoC Bonus in the new project.
Renewal projects originally awarded under a previous year's DV Bonus must
continue to serve survivors of domestic violence, dating violence, sexual assault,
and stalking.
Projects must enter data into their HMIS-comparable database. The project
budget may include HMIS funding to cover the cost of the HMIS-comparable
database.
FY25 COC NOFO, FRAMEWORK STRATEGIES 59
FY25 COC NOFO, FRAMEWORK STRATEGIES 60
What Does the CoC Program Application Look Like?
1. The CoC Application
a. THN submits on behalf of the TX BoS CoC
b. Many questions about how the CoC works, and what the CoC is doing
C. THN posts online prior to submission for stakeholder review
2. The Priority Listing (Ranking)
a. THN submits on behalf of the CoC
b. Approved by the CoC Board
C. THN posts online before submission
3. Individual Project Applications
a. Materials submitted by project applicants in a-snaps (HUD's grant
management platform)
b. Materials submitted by project applicants in the TX BoS CoC grant
management platform
NEW PROJECTS - TIMELINES
Please refer to the RFP for further details.
Activity FY25 Date Time
Issuance of RFP - New Project Applications 12/1/2025 9:00:00 AM
Applicant Webinar 12/1/2025 11:00 AM
Threshold Review and Full Application Open in Apply 12/1/2025 9:00:00 AM
Threshold Review Stage Closes in Apply 12/3/2025 8:59:59 PM
Threshold Review Is Complete 12/4/2025 4:59:59 PM
Full Applications (Preliminary&esnaps) due 12/10/2025 4:59:59 PM
FY25 COC NOFO, FRAMEWORK STRATEGIES 62
NEW PROJECTS - APPLICATION
OVERVIEW
Threshold Verification (SurveyMonkey Apply):
Basic questions about the applicant and proposed project to determine initial eligibility and
minimum threshold requirements as outlined in RFP
o Requires manual review by THN within 24 hours of submissions
o If approved, Applicants proceed to Full Application
o Due to the accelerated NOFO timeline and anticipated high volume of applicants, all New
Project Applicants will be permitted one opportunity to meet the Threshold Verification
requirements. Applicants who do not meet the minimum requirements in their initial
submission will not be provided an opportunity to revise their submission or resubmit
Full Application (if applicant passes Threshold Verification)
Short and opened-ended questions in SMA: Project Details, Agency Capacity, Budget,
Component-Specific Questions, Match & Monitoring, Leverage
Required uploads: esnaps Applicant Profile & Project Application, HUD Form 2991 , Supportive
Service Participation Agreements (TH only), Leveraged Commitments (as applicable)
FY25 COC NOFO, FRAMEWORK STRATEGIES 63
NEW PROJECTS : GUIDES
• If you are selected for a new project by your CoC, use HUD's
Navigational Guides and Detailed Instructions when completing your
e-snaps application.
https:Hwww.hud._ ov/program offices/comm plan ning/coc/competition
HUD has yet to post the updated Navigational Guides. They will be posted to the same
webpage when available.
Applicants should carefully review the instructional guides in order to
answer questions appropriately.
FY25 COC NOFO, FRAMEWORK STRATEGIES 64
Healthcare and
Housing Leveraging
Coordination with Housing and
Healthcare
As part of the national CoC NOFO Competition, CoCs
submit an application that is scored by HUD. One of the
areas HUD evaluates CoCs on during the annual
competition is housing and healthcare leveraging.
Coordination with Housing and
Healthcare
Because HUD is looking for CoCs to submit project
applications that leverage housing and healthcare
resources, THN ask new project applicants to try to identify
housing or healthcare leverages for their new project
applications.
Leveraging
CoCs must demonstrate to HUD that they have applied for a new Transitional
Housing project that includes a written commitment from a health care
organization for one of the following:
In the case of a substance The value of assistance
use treatment or recovery being provided by the health
provider, it will provide care organization is at least
access to treatment or an amount that is
recovery services for all • equivalent to 25% of the
project participants who funding being requested
68
qualify for those services. for the entire project.
Sources of healthcarn racnurces includr�
• Direct contributions from a public or private health
insurance provider to the project (e.g., Medicaid).
• Provision of health care services by a private or
public organization tailored to the program
Leveraging participants of the project.
Healthcare • Healthcare resources could include health,
Resources mental health, dental, or substance use services.
%=� =W,
• Eligibility for the project must comply with HUD
program and fair housing requirements.
• Eligibility for services cannot be restricted by the
eligibility requirements of the health care service
provider (must be available to all participants).
Leveraging Healthcare Resources
Some considerations:
Be aware that the CoC will need a formal written commitment of the healthcare leverage, so be prepared
to follow up with the healthcare leveraging partner organization regarding the written commitment.
The CoC can provide a template agreement as a starting point.
You/your healthcare leveraging partner will need to provide a justification for the leverage amount.
In-kind resources must be valued at the local rates consistent with the amount paid for services not
supported by grant funds.
Be prepared to provide some specifics regarding the types of healthcare services to be offered/provided.
Projects that are selected by HUD for funding will likely start in mid- to late-2026 and the leveraged
healthcare resources would be expected to be available at project start.
70
LeveragingHousingResources
CoCs must demonstrate to HUD that they have applied for a new Transitional Housing Project
project that utilizes housing subsidies or subsidized housing units not funded through the CoC
or ESG Programs. New project applicants must document the use of leveraged housing
resources with letters of commitment or formal contracts/documents.
In the case of TH, must
leverage housing resources
for at least 25% of the units
included in the project
71
LeveragingHousingResources
These housing resources may come Examples of leveraging housing
from: resources may include:
Private organizations, An allocation of Section 8/
Housing Choice Vouchers from
State/local government, your local Public Housing
Public Housing Agencies,
Authority in place of or to
supplement the use of CoC
including use of a set aside or Rental Assistance funds.
limited preference, An allocation of units at a Low-
Faith-Based organizations, and/or Income Housing Tax Credit
Federal rams ro other than the (LIHTC) building that provides
programs CoC or ESG Programs. subsidized housing.
72
Leveraging HousingResources
Some considerations:
Be aware that the CoC will need a formal written commitment of the housing leverage so
be prepared to follow up with the housing leveraging partner organization regarding the
written commitment.
The CoC can provide a template agreement as a starting point.
Be prepared to identify a general start date at which the housing resource would become
available. Projects that are selected by HUD for funding will likely start in mid- to late-2026
and the leveraged housing resources would be expected to be available at project start.
Explain to your housing partner that you will need to wait to hear from HUD as to whether this project
gets awarded funds, but they would need to be prepared to make the committed housing resources
available, if selected, once your agency goes under contract with HUD.
Prepare to provide some specifics regarding the source of the housing resource (e.g.,
HCV, LIHTC, HOME, local housing trust fund, etc.).
73
FY25 COC NOFO, FRAMEWORK STRATEGIES 74
RENEWAL PROJECTS - TIMELINES
Please refer to the RFP for further details.
Activity FY25 Date Time
Issuance of RFP - Renewal Project Instructions 12/1/2025 9:00:00 AM
Applicant Webinar 12/1/2025 11:00 AM
Threshold Review and Full Application Open in Apply 12/1/2025 9:00:00 AM
Threshold Review Stage Closes in Apply 12/3/2025 8:59:59 PM
Threshold Review Is Complete 12/4/2025 4:59:59 PM
Full Applications (Preliminary&esnaps) due 12/10/2025 4:59:59 PM
FY25 COC NOFO, FRAMEWORK STRATEGIES 75
RENEWAL PROJECTS APPLICATION
OVERVIEW
New in FY25, Renewal Projects that are eligible to renew will complete a simplified
process as outlined in the Renewal Project Instructions.
Only applicants who receive direct instruction to complete the Renewal Project Instructions
process will be permitted to do so.
Threshold Verification (SurveyMonkey Apply):
Basic questions about the applicant and renewal project details to verify eligibility of applicant
and renewal project
Requires manual review by THN within 24 hours of submissions
Full Application
Respond to limited narratives in SMA, and:
o Upload the completed esnaps Applicant Profile and Project Application, HUD Form 2991
FY25 COC NOFO, FRAMEWORK STRATEGIES 76
RENEWAL APPLICATIONS : GUIDES
USE THE GUIDES AND DETAILED INSTRUCTIONS. These documents
will provide you with the information you need.
You should be able to access them here when they are posted:
nttps://www.nua.gov/program ottices/comm planning/coc/competition
• Tip: Just focus on the few pages assigned to your project type!
Other renewals will be able to import information from last year's
application.
FY25 COC NOFO, FRAMEWORK STRATEGIES 77
FY25 COC NOFO,FRAMEWORK STRATEGIES 80
NEXT STEPS
Materials will be released as quickly as possible. Carefully read emails from
the CoC. Emails may come from txboscoc@thn.org
If you are not currently receiving emails directly from the CoC but would like to, please join
here: https://www.thn.org/texas-balance-state-continuum-care/continuum-care-
p rog ra m/#co m p-u pd ates
• Review the RFP released by THN and HUD's NOFO
Review supplemental resources on THN's CoC Competition Page (linked)
Start your Threshold Verification in THN's Local Competition system "Apply"
Ensure you have a log in to access the portal
Ensure you have a log in for HUD's application system, "esnaps" and update
the esnaps Applicant Profile
Collect your HUD 2991 , Certification of Consistency from your Consolidated
Planning Jurisdiction
See RFP for details
RESOURCES
Renewal : New Project
Applications
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FY25 COC NOFO, FRAMEWORK STRATEGIES 82
EXTERNAL RESOURCES
The CoC will post materials related to the FY25 CoC NOFO/ Application here:
ntips://www.in n.org/texas-balance-state-contin uum-care/contin uum-care-program/
HUD is posting materials to their website here: https://www.hud.gov/hud-
partners/community-coc
Note that for the HUD website, the FY2025 CoC NOFO materials are accessed by
clicking on the "FY 2025 Continuum of Care Competition" link which will open up the full
list of materials related to this funding competition.
NAEH has summary materials available here:
https://endhomelessness.org/resources/toolkits-and-training-materials/the-system-series
FY25 COC NOFO, FRAMEWORK STRATEGIES 83
RESOURCES FOR E-SNAPS
Visit HUD's a-snaps 101 Toolkit page: Visit HUD's a-snaps 201 Toolkit page:
https://www.hudexchange.info/resource/6170/ https://www.hudexchange.info/resource/6171/
esnaps-1 01-tool kit/ esnaps-201-toolkit/
Glossary & icons explanations Updating the Applicant Profile
Checklist for getting started Accessing project applications
Creating an e-snaps user profile Video
Requesting access to e-snaps Written Guide
Giving access to e-snaps to staff Common e-snaps issues
HUD will provide "Detailed Instructions" and "Navigational Guides" — be sure to review those documents:
Renewal and New Project Detailed Instructions and Navigational Guides are/will be posted here:
https://www.hud.gov/program_offices/comm plan ning/coc/competition
• Main a-snaps CoC application page: https://www.hudexchange.info/programs/e-snaps/
FY25 COC NOFO, FRAMEWORK STRATEGIES 84
E-SNAPS SUBMISSION TIPS
All applicants must complete the Applicant Profile. This is a crucial step that cannot
be skipped. If you are interested in applying for funds and do not have an Applicant
Profile set up or updated in e-snaps, work on this now.
When done, check the Submissions Summary page — if there are any red s, go back
and fix those.
Visit this page for the Project Applicant Profile Navigational Guide and instructions for
filling out HUD Form 2880:
https://files.hudexchange.info/resources/documents/Updating-the-Applicant-Profile.pdf
Code of Conduct: All applicants must have an updated Code of Conduct. Check your
profile to see if it is attached. Can also check the HUD list of approved Codes of
Conduct. https://www.hud.gov/program offices/spm/gmomgmt/grantsinfo/conductgrants
FY25 COC NOFO, FRAMEWORK STRATEGIES 85
E-SNAPS SUBMISSION TIPS
If there are multiple parts in one question, number/letter each response section.
Adequately answer all parts and stick just to what the question asks for.
Renewal projects: check your narrative descriptions to make sure they are accurate and up
to date, particularly if you have recently expanded or consolidated the renewal project.
Each application section is standalone, so if you are building on something
already mentioned, be sure to reference that specific question number.
If a narrative question requests "actions" or "strategies", you must identify
specific examples.
If you don't know what a question means, check the Detailed Instructions. HUD
often provides more specifics in the Detailed Instructions.
FY25 COC NOFO, FRAMEWORK STRATEGIES 86
WHO TO CONTACT
For questions related to the TX BoS CoC Competition Process:
txboscoc@thn.org
For questions about a specific HUD Notice of Funding Opportunity
(NOFO)
CoCNOFO@hud.gov
FY25 COC NOFO,FRAMEWORK STRATEGIES 87
QUESTIONS ?
FY25 COC NOFO,FRAME'J'VORf SIRATEGiL=S 88