By Michael Livingston
The Mid-Willamette Valley Homeless Alliance (the Marion and Polk counties' Continuum of Care, or CoC) board adopted a strategic plan at its June 11 meeting. The plan includes many elements outside the requirements of the federal CoC Program. The discussion below outlines the CoC Program's core elements, identifies problems with the adopted plan, and explains how to align the two.
HUD’s CoC Program
What a CoC is
HUD’s CoC Program is designed to provide services to help homeless individuals and families move into transitional and permanent housing, with the goal of long-term stability.
What is unique about the CoC Program -- and will be particularly challenging for the Alliance -- is that HUD expects a community participating in the CoC Program to think of its homeless services delivery system as a “continuum of care,” rather than an array of individual homeless assistance programs that operate independently from one another.
The model continuum of care includes all public and private programs in the continuum's geographic area that address homelessness, regardless whether the programs apply for HUD CoC funding, and CoC Program participation requires community-wide planning and the strategic use of all of those resources.
HUD expects that, in addition to analyzing the performance of individual projects and programs, CoC communities also measure their performance as a coordinated system. For details, see CoC Program -- Introductory Guide.
Measuring a CoC's progress in housing the homeless
HUD assesses both the performance of individual projects funded with CoC Program dollars, and the performance of the continuum as a whole, by application of seven System Performance Measures (SPMs):
(1) Length of time persons remain homeless;
(2) The extent to which persons who exit homelessness to permanent housing destinations return to homelessness;
(3) Number of homeless persons;
(4) Jobs and income growth for homeless persons in CoC Program-funded projects;
(5) Number of persons who become homeless for the first time;
(6) Homelessness prevention and housing placement of persons defined by Category 3 of HUD’s homeless definition in CoC Program-funded projects; and
(7) Successful housing placement.
For more information see CoC System Performance Measures in context
NOTE: HUD wants CoCs to focus strategically on housing those who are literally homeless, at imminent risk of homelessness, or fleeing domestic violence. HUD therefore does not measure, and will not fund, programs aimed at prevention/Category 3 homeless (SPM #6) unless the CoC has applied for and received HUD approval. To date, no CoC has that approval. For more information see Introductory Guide to the SPMs and Determining "homeless" status of youth.
Where the System Performance Measure data comes from and how it is used
Because SPMs are system-level measures, they reveal significant information about how well homelessness assistance programs are functioning and where improvements are necessary. That's why HUD bases funding decisions on SPM data. Communities can also use SPM data to evaluate and improve the performance of their homeless services delivery system.
Coordinated Assessment and Entry
Consistent with the expectation that CoCs engage in community-wide planning and ensure the strategic use of resources, HUD requires each CoC to establish a coordinated assessment and entry system. The coordinated assessment and entry process uses a comprehensive, standardized assessment tool to prioritize the individuals who are most in need of assistance and then, based on the assessment results, refers them in a timely manner to appropriate housing and other services through a centralized, or coordinated, protocol. Basically, it’s a “no wrong door” or “central waiting list” approach, in which a homeless person can go to any homeless services provider in the continuum and be assessed through the same tool and methodology so that referrals are consistently made and promptly completed across the community, and the most vulnerable move to the head of the line. For more information see Coordinated Assessment and Entry.
The HUD CoC Program's 4-category definition of "homeless"
"Category 1" -- "Literally Homeless": An "[i]ndividual or family who lacks a fixed, regular and adequate nighttime residence, meaning: (i) Has a primary nighttime residence that is a public or private place not meant for human habitation; (ii) Is living in a publicly or privately operated shelter designed to provide temporary living arrangements * * *; or (iii) Is exiting an institution where (s)he has resided for 90 days or less and who resided in an emergency shelter or place not meant for human habitation immediately before entering that institution."
"Category 2" -- "Imminent Risk of Homelessness": An "[i]ndividual or family who will imminently lose their primary nighttime residence, provided that: (i) Residence will be lost within 14 days of the date of application for homeless assistance; (ii) No subsequent residence has been identified; and (iii) The individual or family lacks the resources or support networks needed to obtain other permanent housing."
"Category 3" -- "Homeless under other Federal statutes": Unaccompanied youth under 25 years of age, or families with children and youth, who do not otherwise qualify as homeless under this definition, but who: (i) Are defined as homeless under the other listed federal statutes; (ii) Have not had a lease, ownership interest or occupancy in permanent housing during the 60 days prior to the homeless assistance application; (iii) Have experienced persistent instability as measured by two moves or more in the preceding 60 days; and (iv) Can be expected to continue in such status for an extended period of time due to special needs or barriers."
"Category 4" -- "Fleeing [or] Attempting to Flee DV": "Any individual or family who: (i) Is fleeing, or is attempting to flee domestic violence; (ii) Has no other residence; and (iii) Lacks the resources or support networks to obtain other permanent housing."
NOTE: for the reason cited in the above note, the Alliance should strategically target those populations described in Categories 1, 2 and 4.
The plan adopted by the Alliance
The opening sentence of the “PURPOSE” statement of the Alliance's Governance Charter commits the Alliance "to carry out the purposes of the U.S. Housing and Urban Development (HUD) Continuum of Care program as defined 24 CFR Part 578." The CoC Program requirements discussed above make it clear that the initial primary goal of a strategic plan for our new and untested CoC is to build an effective homeless services delivery system and a competitive CoC by: (a) establishing full geographic coverage; (b) rigorous application of the SPMs; (c) strict adherence to HUD’s definition of “homeless”; (d) continuum-wide participation in HMIS and Coordinated Assessment & Entry; and (e) a continuum-wide commitment to data quality. It also follows from the PURPOSE statement that the Alliance’s priority endeavors should be those that directly align with both the SPM framework and HUD’s definition of “homeless.” Application of these standards to the plan adopted by the board demonstrates that the plan is substantively deficient in a number of respects and that those deficiencies are not likely to be cured by any future "work plans" the Alliance's consultants may develop.
The plan's failure to align with the SPM framework and purpose
Because HUD assesses the performance of a CoC's individual projects and the performance of the continuum as a whole by application of the System Performance Measures (SPMs), what can be measured and assessed by the SPM data determines, in effect, both the goals CoCs should pursue and the kind of programs and homeless services delivery system HUD expects CoCs to develop. It is essentially for these reasons that, on May 20, Jimmy Jones (Executive Director of the Mid-Willamette Valley Community Action Agency and a member of the Alliance's Board) sent an email to his fellow Board members, which began with the following observation:
In that email, he recommended that the Alliance "work backward" from the "priorities" in the NOFA that HUD issued in 2019, when our region was part of the Rural Oregon Continuum of Care (ROCC), and, "while taking a hard look at our systems," "create an improvement plan" that "becomes the heart of our strategic plan." (For more information, see 2019 NOFA , pages 50-67.) The ROCC (“Your CoC”) scores on its 2019 NOFA application are set out and assessed in the HUD charts below.
The issue of our strategic plan came up at the Collaborative Committee meeting today. I’m an ex-officio member of this Board, and I see my primary role as providing technical assistance to inform the Board on the choices in front of us. I was deeply involved in ROCC planning, and I want us to avoid making the same mistakes that the ROCC made in previous years. Their biggest failure, in my view, was that they failed to take the single most important goal and work backward from that goal to create an action plan.
In that email, he recommended that the Alliance "work backward" from the "priorities" in the NOFA that HUD issued in 2019, when our region was part of the Rural Oregon Continuum of Care (ROCC), and, "while taking a hard look at our systems," "create an improvement plan" that "becomes the heart of our strategic plan." (For more information, see 2019 NOFA , pages 50-67.) The ROCC (“Your CoC”) scores on its 2019 NOFA application are set out and assessed in the HUD charts below.
The board did not consider the approach Jones recommended. The board's plan takes a very broad approach, setting out a number of goals and "objectives" that do not align with the SPM framework, including: (a) “[s]ustain” the Marion County LEAD program; (b) “[i]ncrease access and expand affordable housing units * * *”; and (c) “[s]upport * * * efforts to create a sobering center in the Salem area.” (Plan, pages 14, 21). These goals and objectives may benefit the community and contribute indirectly to housing homeless individuals, but, their outcomes cannot be measured and assessed by SPM data. For example, the CoC could never demonstrate by reference to aggregate SPM data from HMIS that those endeavors, in fact, had assisted identified individuals and families who are “homeless” under HUD’s definition to move into stable permanent housing. Statements in the plan to the effect that they are “related” to one or more of the SPMs do not change that reality, and they are based primarily on unidentified and unsupported assumptions (e.g., Plan at pages 9, 21). Indeed, the plan's use of the undefined term "related" is a tacit acknowledgment of that fact. Instead of starting with goals and objectives that have been predetermined and then trying to make the SPMs fit them, the Alliance should have used SPMs to decide what the goals and objectives should be.
According to Jan Calvin, the consultant who seems to have done most of the work on the plan, the goal of increasing the number of affordable housing units is included in the plan in order to satisfy HUD's expectation that CoCs collaborate with public and private entities in the community, which -- unlike the Alliance -- do have the authority and capacity to develop affordable housing. See CoC 101, pages 10, 11, 14. If fulfilling that collaboration responsibility is the intent of the affordable housing goal, it is important to make that clear. The plan simply states, "AFFORDABLE HOUSING. Increase access and expand affordable housing units to help fill the 15,000-household gap." (Plan at page 5). Other sections of the plan appear to confirm what that statement implies -- i.e., that the Alliance itself is taking on the task of developing affordable housing units. (e.g., Plan at pages 8, 14, 15). It is obvious that the problem with the framing and articulation of the affordable housing goal could be resolved by making it clear that the goal is to collaborate, and by assigning a priority to that goal that takes into account the more pressing tasks the Alliance must undertake in these early years.
The plan's failure to align with the HUD CoC Program's definition of "homeless"
The Alliance's target populations are effectively limited to those described in Categories 1, 2 and 4 of the HUD CoC Program’s definition of “homeless.” The target population references and descriptions in the Alliance’s strategic plan should both express and be consistent with that limitation. As consultant Jan Calvin admitted in response to a question from board member Dan Clem during the June 11 meeting, the plan does not do that. (e.g., Plan at pages 8, 12, 14, 15, 21, 22).
Corrective Action
Many of the problems with the plan the board has adopted stem from the fact that it is based on a plan that was developed several years ago in a different context and for another purpose. They could have been avoided by developing a new strategic plan, the framework for which is built from the ground up based on the HUD CoC Program’s requirements and the System Performance Measures. The board still could do that, using the approach Jones recommended.
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