HUD is in the process of sending the FY 2014 Grant Inventory Worksheets (GIWs) to the Collaborative Applicants designated by each Continuum of Care (CoC) with a copy to the appropriate HUD field office. If your CoC has not received the FY 2014 GIW by today, July 17, 2014, please contact your local HUD field office immediately.

Important Notes Regarding the FY 2014 GIWs:

• Each CoC must include ALL eligible renewal projects in the FY 2014 GIW. Project funds expiring in calendar year 2015 (January 1, 2015 through December 31, 2015) are eligible for renewal and must be included on the GIW. If the CoC is unsure if a project is eligible to apply for renewal funds in FY 2014, the CoC must contact the local HUD CPD field office.
   
• All GIWs must be sent to the local HUD CPD field office no later than Friday, July 25, 2014.
   
• The final HUD-approved GIWs will be sent from the SNAPS desk officer to the CoCs on Wednesday, August 13, 2014.
   
• It is extremely important that all CoCs carefully review the GIWs with both project applicants listed on the GIW and local HUD field office to ensure:
   
  • All projects eligible for renewal are listed and all requested information is provided.
     
  • Any projects listed that are NOT renewing in the FY 2014 CoC funding process are NOT included in the CoC’s Annual Renewal Demand (ARD).
     
  • CoC planning and UFA costs are NOT eligible for renewal; therefore, these types of projects should not be included on the GIW. If these types of projects are included on the GIW submitted to HUD, HUD will remove the projects.
     
• The final HUD-approved GIW will not be a required attachment for the modified FY 2014 CoC Registration. However, the ARD amount from the FY 2014 GIW is a required field in Registration; therefore, it is imperative that this amount be as accurate as possible.
   
• The final HUD-approved GIW will be a required attachment to the FY 2014 CoC Priority Listing.
   
• CoCs without renewal projects should attach a blank GIW stating “No Renewals” in the “Comment” column. A blank GIW may be obtained from the local HUD CPD field office.

Important Note for Projects with Budgets for Supportive Services Only:

HUD is aware that there are some projects that request supportive service funding but do not request housing funding from the CoC Program that are currently incorrectly classified – either as a housing component or as an SSO component. Therefore, projects that do not request any funding for housing under the CoC Program should review Is my Project a Supportive Services Only (SSO) or a Housing Project? Tool for CoC Program Projects. If after reviewing this tool, a recipient determines that is it incorrectly classified, the recipient should contact its local HUD CPD field office.

If a component change is approved by the local HUD CPD field office, working with HUD Headquarters, the recipient must notify the Collaborative Applicant and CoC of the component change to ensure this is accurately reflected on the GIW. This process must be completed before the final GIW is submitted to ensure that projects are appropriately considered in the selection criteria prior to the opening of the competition for FY 2014 funds. After that no changes will be permitted – projects must apply as they were approved on the GIW.

The Consolidated Appropriations Act of 2014 (Public Law 113-76, approved January 17, 2014)

This Act authorized nonprofit organizations to administer rental assistance in permanent housing under the CoC Program. The following FAQs provide information to recipients of CoC Program funds about how the language in the 2014 Appropriations Act impacts their projects funded under the CoC Program.

I am a recipient of funds for rental assistance under the CoC Program. What effect does the language in the Consolidated Appropriations Act of 2014, which authorizes nonprofit organizations to administer permanent housing rental assistance, have on my project?

The Consolidated Appropriations Act of 2014 (Public Law 113-76, approved January 17, 2014) authorized nonprofit organizations to administer rental assistance in permanent housing under the CoC Program. This means, as a recipient of funds for rental assistance for a permanent housing project, you have the option of contracting with a State, local government, Public Housing Authority (PHA), or nonprofit organization to administer the rental assistance under your project effective immediately. Remember, to award contracts, you must comply with applicable procurement procedures. Alternatively, any of these entities – State, local government, PHA, or nonprofit organizations – may choose to administer the rental assistance themselves.

However, you should be aware that this authorization under the Consolidated Appropriations Act of 2014 was limited to permanent housing rental assistance funded with Fiscal Year (FY) 2012, FY 2013, and FY 2014 CoC Program funds. The ability for nonprofit organizations to administer permanent housing rental assistance with FY 2015 CoC Program funds and beyond is dependent on the renewal of this authority or a permanent statutory fix. If, at any time, Congress discontinues the authority allowing nonprofit organizations to administer permanent housing rental assistance under the CoC Program, any State, local government, PHA, or nonprofit organization contracting with a nonprofit organization to administer rental assistance will be required to cancel the contract with the nonprofit organization and contract with a State, local government, or PHA to administer the rental assistance, and any nonprofit organization administering its own rental assistance would be required to contract with a State, local government, or PHA to administer the rental assistance. If the recipient is a State, local government, or PHA, it may choose to administer the rental assistance itself.

I am a recipient of funds for leasing under the CoC Program. What effect does the language in the Consolidated Appropriations Act of 2014 that authorizes nonprofit organizations to administer rental assistance in permanent housing have on my project?

The Consolidated Appropriations Act of 2014 (Public Law 113-76, approved January 17, 2014) authorized nonprofit organizations to administer rental assistance in permanent housing funded with fiscal year (FY) 2012, FY 2013, or FY 2014 CoC Program funds. This means, as a recipient of funds for leasing for a permanent housing project, your existing grant is not affected by this language.

However, 24 CFR 578.105 states that recipients may make certain changes to their grants, through a grant agreement amendment, including a shift in funds from one budget line item to another budget line item. If you would like to shift funds from leasing to rental assistance through a grant agreement amendment, please contact your local HUD CPD field office, which will consider your request using the standards applied to any other such request under 24 CFR 578.105.

I am a recipient of funds for transitional housing under the CoC Program. What effect does the language in the Consolidated Appropriations Act of 2014 that authorizes nonprofit organizations to administer rental assistance in permanent housing have on my project?

The Consolidated Appropriations Act of 2014 (Public Law 113-76, approved January 17, 2014) authorized nonprofit organizations to administer rental assistance only for permanent housing under the CoC Program. This means, as a recipient of funds for transitional housing, you may only use a State, local government, of Public Housing Authority (PHA) to administer rental assistance under your transitional housing project. This is because 24 CFR 578.51(b) requires rental assistance under both permanent and transitional housing to be administered by a State, unit of general local government, or PHA. The Consolidated Appropriations Act of 2014 only addressed rental assistance administration in permanent housing.

If you would like to amend your grant to move your funds to Permanent Housing: Rapid Re-housing, or, if you believe that your project is not appropriately categorized as TH, meaning it should be a Permanent Housing: Rapid Re-housing project, please contact your local HUD CPD Field Office which will consider your request using the standards applied to any other such request under 24 CFR 578.105.

Questions?

HUD will notify Collaborative Applicants, CoCs, and stakeholders once the modified FY 2014 CoC Registration Notice is posted and e-snaps is available.
 
If you have questions pertaining to e-snaps technical issues or the FY 2014 GIW, please submit your questions to the e-snaps Ask A Question (AAQ) portal. To submit a question to the e-snaps AAQ portal, select “e-snaps” from the “My question is related to” drop down list on Step 2 of the question submission process.

If you have questions related to the CoC Program Interim Rule or a policy related question, please submit your questions to the CoC Program Ask A Question (AAQ) portal. To submit a question to the CoC Program AAQ portal, select “CoC Program” from the “My question is related to” drop down list on Step 2 of the question submission process.