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Housing the homeless: the “traditional approach” versus “housing first” for grant writers

We’ve been writing grant proposals for housing and supportive services for people experiencing homelessness (this is the PC phrase, but “homeless” is used in the rest of this post) since 1993, so we’ve been at it for long enough to see changing funder and client preferences around approaches come and go. For many reasons that are beyond the scope of this post, homelessness remains a growing and in some respects an intractable challenge in much of urban and rural America; essentially, homelessness is a housing shortage problem. Until we address housing abundance, we’re not going to be able to solve or substantially ameliorate homelessness as a problem.

Recently, we wrote a post on the emerging trend toward harm reduction instead of traditional SUD/OUD treatment. A similar phenomenon is going on with respect to providing housing and supportive services for homeless folks. This is the concept of “Housing First:”

Housing First is a homeless assistance approach that prioritizes providing permanent housing to people experiencing homelessness, thus ending their homelessness and serving as a platform from which they can pursue personal goals and improve their quality of life. This approach is guided by the belief that people need basic necessities like food and a place to live before attending to anything less critical, such as getting a job, budgeting properly, or attending to substance use issues.

At first glance, Housing First looks like a reasonable and compassionate approach. In the 1980s, when homelessness as an issue entered public discourse, the sentiment was that Mary and her two kids live in their car because she got laid off from the Piggly Wiggly and was evicted from her apartment. While there are many people who find themselves in this sort of predicament, the majority of homeless have SUD/OUD and, in many cases, are co-diagnosed with serious and persistent mental illness (SPMI). But homelessness is easier to avoid, even for people with SUD, OUD, and/or SPMI, when rents are low. That’s why “it’s not the case that homelessness is high where vacancy rates are high. Indeed, it’s the opposite — the vacancy rate is lower in places with more homelessness.”

Housing for the homeless initiatives have traditionally focussed on a step-down approach similar to that which we described in the post on OUD/SUD treatment versus harm reduction. In the traditional paradigm, homeless people receive housing and other services along a continuum of care starting with a high level of care, and then they “step down” to lower care levels in increments, leading to eventual independent living. Following engagement, referral, or self-presentation and development of an individual housing assistance plan (“IHTP”), the step-down levels often proceed something like:

  • Detoxification/stabilization (if needed)
  • Shelter bed in an emergency shelter (usually limited to 30 to 60 days). Significantly, most shelters are “dry,” meaning that drinking and drugging aren’t allowed in the facility. Still, after breakfast, most people living in shelters spend their days out of the shelter on the street, with the idea that they’ll look for a job, attend treatment sessions, etc., and return at night to sleep. While this is more or less “two hots and a cot,” treatment and other supportive services are sometimes provided in-house and/or by referral.
  • Placement in a single room occupancy (SRO) hotel, transitional housing, or supportive housing unit with in-house and referral supportive services (e.g. SUD/OUD and SPMI treatment, legal assistance, workforce development, primary/dental care, etc.) usually provided in the latter two. In supportive housing, such services are usually case-managed and these facilities are usually dry. While there is typically no length of residency cap for SRO units, there is usually a 12 to 24 month max for transitional and supportive housing facilities. Unfortunately, SROs are largely illegal under the modern zoning regime, which may forces many precariously housed people on the street.
  • Independent living, usually with a Housing Choice Voucher (formerly called Section 8) or in another subsidized housing development, or with family.

The levels can be broken down further, but the above was the common approach and was formalized in the 1987 passage of the McKinney–Vento Homeless Assistance Act (McKinney-Vento), administered by HUD. The problem is, though, is that even if a person gets clean and sober, if he or she can’t afford rent, that person is likely to end up back on the street—and thus in high-stress, difficult situations that encourages coping via substance abuse. Covering $700/month in rent is much easier for a person with mental illness and substance abuse challenges than $2,000 a month.

Although McKinney-Vento funds 15 programs with a spectrum of services, the most significant ones are Supportive Housing, Shelter Plus Care (provides site-specific HCVs for the housing development and on-site services), SRO, and Emergency Shelter. One of the first large funded grants S + A wrote was a $4M Shelter Plus Care proposal for a nonprofit in Northern California to convert a vacant motel into a supportive housing facility in 1994. Over the years, McKinney-Vento has disappeared from public view, as these programs have been folded into HUD’s very confusing Continuum of Care (CoC) system. McKinney-Vento programs still form the structure for most federal efforts to help the homeless, but applications are made to the local CoC agency, not directly to HUD—which means local politics come into play, along with typical quiet deals cut among local players. Good luck breaking into CoC funding without an “in.” Well-meaning people in a given community often want to find something to do to help with the issue of homelessness, and they try to find sustainable for it, only to run into the local power structure.

For our first 20 years, most of the proposals we wrote for homeless housing and supportive services followed the above model: the emphasis was always on working with the homeless people to get them clean and sober, with SPMI under control, before moving from a shelter to longer term housing. About 10 years ago, we began to work with clients who wanted to use the Housing First approach: in this approach, underlying SUD/OUD and SPMI challenges are addressed, to an extent, but the overall goal is to provide fast housing—hence the term “Housing First.” This paradigm treats housing as the first step for life improvement and enables access to housing without conditions beyond those of a typical renter. Although supportive services are usually offered, participation is not required. This means the formerly homeless can continue to drink and drug and/or not comply with the SPMI treatment protocols. Utah was the first major state proponent of this approach, in part because Utah allows housing to be built relatively easily, but even Utah has run into problems.

This shift to the Housing Fist model has created something of a battle between the traditional homeless services providers like the faith-based “missions” that are found in most major cities, and the new Housing First kids on the block. This battle is being played out on social media and, most importantly, in public hearings and applications for CoC and other grants. Like any local structured grant system, such as CoC, Ryan White grants for people living with HIV/A, or Title 10 family planning, a “mafia” soon emerges. The mafia is composed of the existing agencies being funded, advocacy groups, and local politicians who have an interest in making sure favored nonprofits get funded. The mafia structure makes it harder for new, innovative agencies to secure a spot at the grant feeding trough. We’ve heard from some of our clients that the Housing First crowd has taken over CoC processes to the detriment of traditional providers. Housing First is clearly the church of what’s happening now.

We’re just grant writers, so we don’t have an immediate opinion as to whether the traditional approach or Housing First is more efficacious, though neither is likely to be highly effective without land-use reform that increases the total number of housing units. Without an abundance agenda, we’re merely reallocating slices of the pie, rather than increasing the pie’s size. Extensive homelessness is a symptom of deeper problems, and it can’t be effectively addressed without dealing with the root cause. Most studies on the subject of “traditional” and “Housing First” are somewhat questionable. While I’ve been in many shelters and other homeless housing settings over the years, I’ve never been in a Housing First facility, but I imagine that things might get a bit out of control come Saturday night. I also don’t know how housekeeping is handled. Also, most people with SUD/OUD and/or SPMI will relapse multiple times, which may send them back to the streets, jail, or residential treatment/hospitalization, meaning that their Housing First unit is actually their Housing Last unit.

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The federal budget in the age of Trump: Round up the usual suspects

The New York Times says that “Popular Domestic Programs Face Ax Under First Trump Budget.” Those listed include the Corporation for Public Broadcasting, Legal Services Corporation, AmeriCorps, National Endowment for the Arts (NEA), and National Endowment for the Humanities (NEH). With the exception of AmeriCorps, which wasn’t yet born, the rest are the usual suspects, which have been proposed for the chopping block on and off since David Stockman* was Director of the Office of Management and Budget in 1981. I’ve seen this movie before, and I’m highly confident that, after the Congressional inquisition is over, NEH, NEA and the rest will ride off from Capitol Hill like Keyser Söze at the end of The Usual Suspects.

You might be surprised to learn that Congress last passed an actual Federal budget in 1998! Since then, Congress has used a variety of legislative tricks to “pass” non-budget budgets, including Continuing Resolutions (CRs), department budget authorization bills, and budget reconciliation bills to enable senators and representatives to avoid going on the record voting for or against an actual budget. This whole mess is tied up with the headache-inducing need to pass a bill increasing the Federal debt limit every six months or so.

In March, we’ll get to experience this exercise in political theater again, as the Trump administration will likely propose a revised FY ’17 budget (not to be confused with FY ’18 budget coming along later in the year). As reported by the NYT and others, this revised budget will likely propose a decrease in FY ’17 budget authorizations for selected discretionary domestic Federal spending agencies/programs like NEA and its pals. This is opposed to the usual practice of “budget hawks” to propose reductions in the rate of increase in Federal spending, due to the Feds using baseline budgeting (another headache-inducing concept) rather than zero-based budgeting.

My guess is that few discretionary programs will receive actual cuts and none will be eliminated (see one of our most popular posts, “Zombie Funding—Six Tana Leaves for Life, Nine for Motion,” to learn how Federal programs usually return from the dead). That’s because every Federal discretionary funding/grant program has constituencies in every Congressional District—along with an army of lobbyists.

Let’s use NEA as an example. NEA funds symphonies, theater groups, art museums, etc., everywhere. These are nonprofits, the boards and docent corps of which are composed mostly of well-off locals, who might be married to Congresspeople or their donors. They’re likely to be members of the same country clubs, churches/synagogues, and Chambers of Commerce as Congresspeople. That means Congressman Horsefeathers is not only going to be beaten up by lobbyists and donors but is going to an earful at the breakfast table.

As a young grant writer during the Reagan ascendancy, I learned that—despite the fevered rhetoric you’re going to soon hear and the attempt of the Trump administration to cut something—most grant programs will squeeze through. In contemplating Federal budget cuts, I use the Economic Development Administration (EDA) as my yardstick. EDA, the most overtly political of Federal grant-making agencies, has been around since 1965. Every so often, an administration or Congress threatens this small nimble dinosaur with a budget meteor, but EDA always dodges. I won’t take the latest budget battle seriously until EDA dies. I won’t bring up the real budget brontosauruses like HUD and the Department of Education. They’ve survived Presidents Reagan and Bush the Younger, as well Speaker Newt.


* Stockman now shows up in infomercials hawking various doomsday economic books (or gold), but he actually wrote a terrific political autobiography, The Triumph of Politics: Why the Reagan Revolution Failed. I read this in the mid-80s and it’s relevant once more.

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HUD Gets Back in the Job Training Biz: “Jobs Plus Pilot Program” NOFA Released

HUD just issued a NOFA (Notice of Funding Availability, which is HUD-speak for RFP) for the Jobs Plus Pilot Program. There’s $24 million up for grabs, with grants to $3 million, for Public Housing Authorities/Indian Housing Authorities (PHAs/IHAs). While the issuance of a new HUD NOFA is not usually all that interesting, this one is because it represents a shift in HUD’s priorities.

As I wrote last February, job training is one of the current favored project concepts in grant making. There are at least 47 federal job training programs, or possibly 48 including the newly minted Jobs Plus. You may not remember, though I do, that President Obama made a big fuss about job training in his most recent State of the Union address and vowed to unleash Vice President Biden to study federal job training initiatives in hopes of simplifying things.

Right.

That was the last I heard of this noble quest, and, as far as I can tell, the herd of federal job training programs continue to thunder across the plain. It’s job training business as usual, with the random new program tossed in for good measure.

This is not, however, what made me notice this notice.

At one time HUD had several competitive job training programs, including our old friend YouthBuild, which HUD managed for about 12 years. Suddenly, in the waning days of the reign of George Bush the Younger, Congress got the bright idea that maybe it isn’t such a good approach to have HUD, which is supposed to be involved in housing, fund job training programs. Not a bad reform, since HUD’s job training grant programs were not coordinated with other federal job training programs, particularly the ones operated by the Department of Labor. YouthBuild and other HUD job training programs were eventually transferred to DOL in a previous effort to “simplify things.” Now that eight years or so of DOL running former HUD job training programs have passed, it seems perfectly appropriate to make things more complex again by having HUD manage yet another job training program.

A cursory look at the Jobs Plus Pilot reveals that there’s not much new here, since it’s more or less a rehash of the “workfare” job training concept that emerged from the 1996 compromise Welfare Reform legislation negotiated by President Clinton and Speaker Gingrich. The basic idea was (and is) to tie public income supports, like TANF, to job training. This naturally works better when the economy is producing lots of entry-level jobs.

In the case of Jobs Plus, the target population is residents of the 250 or so remaining large public housing projects* that survived the lunacy of the now almost forgotten HOPE VI program that funded the demolition of thousands of public housing units across America. Even though we wrote some HOPE VI proposals, it always struck me as incredibly stupid to tear down the housing of last resort for the poorest Americans. The good news now is that, if your public housing development still stands, HUD is willing to toss you a job training bone. Of course, there’s nothing to prevent public housing residents from accessing the myriad of job training programs surrounding them. As a grant writer, however, I agree and have to ask, “why have 47 job training programs when 48 will do?”


* When writing a grant proposal about public housing, never use the term “housing project.” Instead, these are always referred to by the more PC “housing development.” Of course, I’m a geezer who grew up in the very poor North Minneapolis neighborhood adjacent to the huge Sumner Field Homes and associated public housing high rises.

I used to play at the Sumner Field park and kid and adults referred to this area as “the projects.” I’ve been to re-education camp since then and banished “projects” from my proposals. By the way, if you follow this link you’ll learn that a huge HOPE VI grant was used to destroy the entire Sumner Field Homes and associated buildings in 1998, displacing 97% of the over 3,300 poor residents in the name of the “new urbanism.” Not to worry: a much smaller mixed-use development replaced it, but there is no word on what happened to the thousands of residents who were tossed out.

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A Report from the Front: Close Reading This Year’s DOL YouthBuild Solicitation for Grant Applications (SGA)

We wrote the very first funded YouthBuild grant for a Southern California client in 1994 and have written funded YouthBuild proposals for virtually every funding round since, which means that we have an unusually nuanced perspective on changes over time.* We’ve noticed two big changes and one minor change in this year’s SGA: market labor market information (LMI) data is out, green construction skills training is out, and the SGA is less structured.

Why?

First, LMI data has been a prominent feature of every YouthBuild SGA since the program was transferred from HUD to DOL about ten years ago. Applicants were supposed to demonstrate that construction skills were in high demand in their area, usually using phantom data, since the LMI data provided by states—the only source for such info—lags the real market by at least a couple years.

Those of you who have been alive and reading any news in the period from 2009 – 2013 know that Bad Things happened to the housing market. Household formation dropped like my Manhattan off a rooftop bar,** housing prices plummeted, and developers stopped building new housing or rehabilitating existing housing. Some went bankrupt. Today’s labor market data probably indicates that there is little support for the need for more construction workers. Requiring data that won’t support need anywhere makes YouthBuild as a program look stupid, and as all political observers know the ideal way to avoid information that makes you look stupid is to pretend it doesn’t exist.

LMI data has always been dubious because no one has a crystal ball; macro data doesn’t tell you much. Forward projections rarely work, and as Nassim Taleb points out (in colorful language) in The Black Swan, no one knows what’s going to happen in markets, labor or otherwise. It’s inherently not possible to know.

Jobs are growing at the low end (in healthcare, service, etc.) and, to a lesser but real extent, the very high end (technology, engineering). But no one can really take a large number of low-income high school dropouts and get them ready to work for Facebook or build the next WhatsApp. Entry-level jobs in fast food or caring for old folks, however, don’t demand a lot of training.

Secondly, green construction training is missing. Training for so called “green jobs” and “green construction skills” first appeared in YouthBuild SGAs about five or six years ago, more or less corresponding with the start of the Obama administration and the Stimulus Bill. As best we can tell, nobody’s talking about green jobs after the A123 Battery debacle and the like, and “green jobs” were never well-defined; “green practices” make more sense, but they really mean energy efficiency, which has been around since the energy shocks of the mid 1970s: double or triple-paned windows, high-efficiency appliances, and perhaps most importantly multi-family housing.

As Edward Glaeser points out in Triumph of the City, multi-family housing is by far the greenest way to live by all sorts of metrics. I’m living in New York on the 22nd floor of an apartment building; because New York’s density means that public transportation works, I don’t own a car. No one lives a greener lifestyle than me (I enjoy patting myself on the back).

To tie points one and two together, I’ll note that Isaac lives in Downtown Santa Monica, where many new multifamily buildings are going up. He got to talking to a foreman on one of the projects, and the foreman said that the buildings aren’t even really built on-site anymore: components come in larger and larger pieces, and then they’re assembled like Tinker Toys. The real greening of those building isn’t happening on-site; it’s happening in distant factories. And these buildings just don’t require as many people to build because so much is done off-site.

In much of the U.S., the real need for housing choice and affordable housing starts at the regulatory level, not the worker level. Matt Yglesias’s The Rent is Too Damn High observes that, in many places, permitting and local development rules hold back affordable housing because they restrict supply in the face of growing demand. New York and Seattle need to be able to create new housing before they need more construction workers. The Federal government has limited control over local land-use practices.

Finally, the SGA’s narrative section is less structured than it used to be. This is mostly a grant wave. Any program narrative can be more structured or less structured. The more structured program narratives will say things like “2. Program Design” then “a. Education and Occupational Skills Training” and then “Factor one: The evidence that the type of academic instruction offered…” Less structured program narratives will say things like, “What’re you going to do once you get all those damn kids in a room?” and let the applicant bloviate as long or as short as the applicant wishes.

We tend to like the latter version better, both because it’s more fun to write and because the resulting proposal tends to be more fun to read. Funders, however, can’t resist meddling and directing, so they tend to like to tell applicants what to do.


* If I live long enough maybe I’ll write the very last YouthBuild funded grant application.

** It was an accident.

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Why HUD Hasn’t Released the Total Funding Amount for the Lead-Based Paint Hazard Control (LBPHC) and Demonstration Program NOFAs?

HUD just announced the Lead-Based Paint Hazard Control (LBPHC) Program and its sister program, Lead Hazard Reduction Demonstration Grant (LHRD) Program NOFA. The NOFA, however, doesn’t list how much money is available or the maximum grant amounts for either program—instead, it has highlighted “XX” and “XXX” variables:

I sent a note to Michelle Miller, the Director of HUD’s Programs Division, noting the absence of the funding amount and maximum grant amount, under the assumption that it was a mistake. She promptly (always a pleasant surprise) wrote back:

Actually it is correct Jake. Since federal budgets have not been appropriated we do not know the total dollars available. That will be announced as soon as we know. However, does affect anyone putting in an application since the award amounts are listed

And now we’re sharing her answers with those of you who are wondering the same thing I was. As of this writing,* Congress hasn’t passed a FY ’13 budget or yet another Continuing Resolution, so HUD is stuck in budgetary limbo. But HUD assumes, probably correctly, that Congress will eventually authorize LBPHC and LHRD money.

Smart organizations are going to start their applications now, since the NOFA has been published.

In past years, the two programs have had more than $100 million available, which makes them an excellent source of funding for cities and community development agencies; we’ve written seven funded LBPHC grants over the years and so are very familiar with the program. For a primer, see Isaac’s post, “HUD’s Lead-Based Paint Hazard Control Program (LBPHC) Program Explained.”

Despite the frustration of not knowing exactly how much money will be allocated to these programs, we have to give HUD credit for two things: first, it’s breaking the increasingly common pattern of offering only thirty-day deadlines; very short deadlines make it much harder for nonprofits to prepare their best application. Second, Michelle replied to my e-mail. I know we’ve written many posts that castigate bureaucrats for various misdemeanors and kinds of incompetence, but we do want to praise responsive bureaucrats who do come through.


* Free proposal phrase.

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HUD’s Confusing Continuum of Care (CoC) Program Explained

HUD just released the FY ’13 Continuum of Care (CoC) Program NOFA, with $1.6 billion available for an array of housing and related services for the homeless. But the process of trying to access that money is deliberately confusing. We’re going to explain how it works in this post, mostly for our own amusement but also in an attempt to educate readers.

“CoC” is the acronym for the federal Continuum of Care program. But “CoC” is also the acronym used for local Continuum of Care programs, as well as local or regional Continuum of Care bodies. To access federal CoC grant funds to help implement the local CoC program, potential applicants—like garden-variety nonprofits—have to go through the local CoC body, which is usually a joint powers authority set up to access federal CoC dollars by local governments, or, in some cases, the state itself. That’s a lot of CoCs, any way you look at it.

Since there is no shortage of acronyms, it would have been nice if the GS-15s at HUD had done a little CoC differentiation to reduce the confusion. Regardless of the nomenclature confusion, most nonprofit or public agencies (which are eligible CoC grantees) cannot apply directly to HUD. Rather, the CoC application has to be first submitted to the local CoC and approved for inclusion in the master CoC application sent in by the CoC.*

Astute readers who know anything about bureaucratic processes are now thinking that the CoC local body system created by HUD sounds like a recipe for confusion and potential collusion, at best.

Those readers are correct. The CoC system has become, in effect, a cartel, with each local CoC able to encourage local providers it likes and discourage ones it doesn’t like, or discourage ones that are not part of the current service delivery system. HUD has in effect created a class of self-perpetuating apparatchiks. This is the flip-side of mandating collaboration: your putative collaborators can easily take you out at the kneecaps, and it’s an example of the problems we’ve written about in “What Exactly Is the Point of Collaboration in Grant Proposals?” and “Following up on Collaboration in Proposals and How to Respond to RFPs Demanding It.”

The fundamental problem here is that the local CoC can stifle subsidiary organizations, and that stifling is mandated by the CoC NOFA itself:

24 CFR 578.9 requires CoCs to design, operate, and follow a collaborative process for the development of an application in response to a NOFA issued by HUD. As part of this collaborative process, CoCs should implement internal competition deadlines to ensure transparency and fairness at the local level.

If you, a potential applicant, didn’t hear about the “internal competition deadline,” you can’t apply. And those deadlines aren’t published in any regularized way or forum, like, say, the Federal Register. Because you have to do the local submission to be part of the CoC’s HUD submission, it makes it more complicated for a garden variety nonprofit to get a CoC grant. Though we’d definitely be interested in working for some malcontent organization that wants to submit a local proposal at the risk of rejection, then appeal to HUD with a claim that the local organization is failing to perform its duties, no one has called us with this proposition yet, though the situation is probably common in the CoC / homeless services world. These are the kinds of stories that, if we had any real reporters left in America, would be covered in the media.

We have some history with CoC, which was originally part of the Reagan era McKinney-Vento Homeless Assistance Act.” Congress passed it in 1987. The original CoC program consisted of three separate grant programs: the Supportive Housing Program, the Shelter Plus Care Program, and the Single Room Occupancy Program. When Seliger + Associates was getting started, one of the first funded proposals we wrote was a $3,000,000 Supportive Housing grant for a nonprofit in Northern California. This was a direct HUD submission, as it was before the local CoC body infrastructure was created.

For reasons that are not clear to us, during the tenure of Andrew Cuomo, or Frankenstein as we used to refer to him around the office because of his uncanny resemblance to our bolt-necked friend, these programs were pumped up as part of Clinton-era response to the “homeless problem” of that time and the CoC system was birthed. As a result, a new layer of bureaucracy began to be consolidated, running parallel to the city, county or state level (in this respect, CoCs are a bit like Community Action Agencies).

We’ve interacted with this new layer of bureaucracy. Although we have written CoC applications in many states, we are most familiar with Los Angeles’s CoC—the Los Angeles Homeless Services Authority (LAHSA). This bureaucratic gem sprung forth fully grown from LA City and County at the behest of HUD about 15 years ago like Athena from the head of Zeus. It now has a $73,000,000 budget and over 100 steely-eyed bureaucrats, but LAHSA is virtually unknown outside of the homeless services provider community.

When HUD changed the rules, there had to be a Continuum of Care Plan for a local area in order for an applicant to be eligible (LAHSA is in charge of the plan in most of L.A. County). And the applicant had to fit into the Plan. Isaac actually wrote a nominal statewide Continuum of Care Plan for Arkansas around 1997 for a housing authority applicant, because Arkansas didn’t want to do one, but our client couldn’t apply without one. So, we just wrote a CoC Plan to enable our client to apply.

Eventually, the local-level CoCs got consolidated in the late 1990s. Unfortunately, if you weren’t part of the Continuum of Care syndicate in the mid-90s, you might still not be. But almost no one understands this, and the only people who do are the people working for the local CoCs. In the case of LAHSA, only three of of the 88 municipalities in Los Angeles County—Long Beach, Glendale, and Pasadena—have opted out of LHASA and have their own CoC bodies. In Pasadena, it’s the Pasadena Housing and Homeless Network. We assume an interest in the administrative overhead that is gleaned from being designated as a CoC has something to do with the three LAHSA outliers in the LA County CoC ecosystem.

By now, CoC operates somewhat like passthrough funds, except that it isn’t part of the two other federal Block Grant systems: Community Development Block Grant (CDBG) from HUD and the Community Services Block Grant (CSBG) from the Office of Community Services (OCS).

This raises the obvious question: Why isn’t the CoC grant program part of either CDBG or CSBG? For example, every jurisdiction that receives a CDBG Block Grant must prepare a Consolidated Plan every five years, with annual Action Plan updates. If you browse through any Consolidated Plan, you’ll notice an emphasis on homelessness and homeless programs. But, instead of using the existing system, a parallel system has been legislated into existence, with the usual set of costs and confusions. This post is designed to dispel some of the confusions. But we don’t have the power to dispel the costs.


* I wrote this sentence to see how many times I could work “CoC” into it.