Public Comments received in response to proposed score sheets for 2019 LA-505 Competition

REQUEST FOR PUBLIC COMMENT POSTED ON WEBSITE: Please review the proposed score sheets (new portions in yellow) for this year’s new and renewal project applications. These will be used by those reviewing and scoring the project applications that are submitted for funding during the 2019 competition. Score determines how each project is ranked. Projects ranked near the bottom are less likely to be funded than those ranked higher. Reasons for proposed changes to the points available are shown at end of last page. Please submit comments via email to homecoalition@gmail.com no later than Wed. Aug. 21st. Comments will be posted publicly on this website.

BELOW ARE COMMENTS RECEIVED AND RESPONSES TO THEM:

Based on input from the organizations throughout the state who have indicated they will submit applications to our competition, I’d like to recommend that we extend the deadline for applications to Monday, Aug. 26th at noon (extended from Fri. Aug. 23 at midnight). The extension will not really impact the review process at all and will provide needed time for applicants who are doing double duty providing client services and preparing applications. RESPONSE: Deadline extended to Mon. Aug. 26 at 12:00 pm (noon).

COMMENT: On the renewal score sheet, question 6b. there are 5 preference points for a renewing permanent supportive housing project that “provides client housing by rental assistance rather than leasing.” A commenter provided a review of HUD rules that shows that PSH projects that currently provide client housing by leasing simply cannot realistically make this change during the renewal process. Thus, applying this criteria to such projects is holding them responsible for something they cannot by law do.

RESPONSE: Score sheet changed: 6b. Not applicable to renewal PSH projects that currently provide client housing through leasing.

COMMENT: On renewal score sheet, Question 14 provides points for coordinated entry portal usage. Last year this was not applicable to domestic violence programs as their portal process was still under development. That exception was not in this year’s proposed score sheet. A comment notes that, while the CE process for domestic violence programs has advanced, the process still uses a method that is documented qualitatively and not as quantitatively as the non-DV projects use the VI-SPDAT. The DV projects do not presently document their CE use in the same quantified way that the non-DV projects do. Applying this criteria for something that, while done consistently and effectively, is not  numerically comparable and will make qualifying for the points impossible for DV projects. It is anticipated that the CE process for DV projects will be fully transitioned to the quantified method by 2020, so this standard can be applied to DV projects in that year’s competition. RESPONSE: Score sheet changed: 14. Coordinated entry usage is not applicable to domestic violence projects (carried forward from 2018 competition).

Additional background info for Comment on item 6b:

The criteria specified in 6b. is not a possibility for PSH projects that currently provide leasing. HUD’s Ask A Question Desk in Question ID 143395 directs that a renewing project can no longer make that change in their annual renewal application. To do so by the application deadline, the project would have to reach out to the field office and ask them to approve and implement a contract change in less than 6 weeks. Experience has shown that such changes typically take several months at minimum. Expecting such a change is not fair to either the renewal applicant nor the field office staff.  HUD AAQ Question ID 143395: “HUD no longer allows recipients to convert leasing projects to rental assistance through the NOFA competition. However, on a case-by-case basis – that usually requires a HUD Headquarters review in collaboration with the Field Office – HUD does permit switching from leasing to rental assistance through a grant agreement amendment process. In order to request an amendment, a recipient should prepare a written request to the local HUD Field Office. The request should indicate what the change is and the circumstances causing the need for the change. In order for HUD to approve the change and execute a grant agreement amendment, the recipient must prove that the change is necessary to better serve eligible persons within the geographic area and ensure that the priorities established under the NOFA in which grant was originally awarded, or the most recent NOFA, are met. Please contact your Field Office and see if they a) approve of the amendment, and b) are able to process the amendment prior to the September 30th application deadline. If the Field Office is unable to process the amendment before the application deadline, then the project would renew “as is” and would be amended upon conditional award. Note: Before you move to switch from leasing to rental assistance, please make sure you understand the differences in the two funds. The www.hudexchange.info/coc<http://www.hudexchange.info/coc> site is a good source in general, and the  Leasing and Rental Assistance Tool: Transition Guidance for Existing SHP Grantees Using Leasing Funds for Transitional or Permanent Housing will provide you with a side-by-side comparison.”

<https://www.hudexchange.info/resources/documents/LeasingandRentalAssistance_TransitionGuidanceforSHPGrantees.pdf>

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