Loading...
HomeMy WebLinkAboutDraft FY2021 FMCoC Competition Policies July 1, 2021 APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 FRESNO/MADERA CONTINUUM OF CARE 2021 [DRAFT] REVIEW AND RANK POLICIES OVERVIEW The federal Department of Housing and Urban Development (HUD) provides over $2 billion per year in funding for homeless housing and services. This funding is distributed through Continuums of Care (CoCs), which are regional organizations that meet regularly to improve project performance and build community support for responding to homelessness. Every year, HUD requires each CoC to review the performance of homelessness projects within that CoC’s region, and to use their performance to rank those projects in order of their funding priority. Projects that are eligible for funding and that rank near the top of the list or in the middle of the list (known as “Tier 1”) will receive federal funding unless the government shuts down. Projects that are near the bottom of the list (known as “Tier 2”) may or may not receive funding, depending on the exact size of the Congressional budget and on how the CoC as a whole performs relative to other CoCs in the national competition. Projects that are excluded from the list altogether will not receive federal funding. Because many of the people who are closely involved with the Fresno/Madera CoC also receive funding that is distributed through the CoC, the CoC’s leadership does not directly review projects’ performance. Instead, project performance is evaluated by an independent Review and Rank Panel. Using a variety of objective and subjective data, the Panel prepares a Recommended Ranked List showing the recommended score and rank of all of the projects in Fresno County and Madera County. The Recommended Ranked List may be subject to minor edits if a project files a successful technical appeal or if the CoC determines that edits are required based on urgent community needs. Then, the CoC officially adopts the Approved Ranked List and submits it to HUD as part of the annual Notice of Funding Availability (NOFA) competition. GATHERING DATA FOR REVIEW AND RANK 1. SOURCES OF DATA There are five sources of data for the Review and Rank process: A. Annual Performance Reports (APR) are generated automatically from the data that each project enters into the Homeless Management Information System (HMIS) database during the course of the year. For example, an APR would include statistical data on the percent of clients in each project who have increased their income, who have obtained permanent housing, and who have obtained health insurance. APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 B. Supplemental Questions are short-answer essay questions that help fill in the gaps in the APR. Supplemental Questions allow applicants to describe their successes in their own words, and provide explanations for the objective project performance data contained in the APR. For example, a Supplemental Question might ask a provider to talk about what kinds of supportive services they offer, or about how they respond to the needs of challenging clients. C. The eSNAPS Application is a federal application form that HUD requires all projects to complete in order to apply for HUD funding. Some of the information in the eSNAPS application may be considered and reviewed by the Panel. For example, the Panel might look at the number of beds listed in your eSNAPS application to help evaluate your budget. The Panel is not required to read any particular project’s eSNAPS application, but they may choose to do so. D. Other Attachments, such as a budget, a job description, or a copy of one of a program’s policies, may be requested by the instructions for an application or by the Review and Rank Panel. Any attachments submitted during the Review and Rank process become part of a project’s application. The Panel is not required to read any particular project’s attachments (except for threshold factors), but they may choose to do so. E. Oral Interviews may be conducted by telephone at the Review and Rank Panel’s discretion if they have questions that they want to ask about a particular project. Your agency should make sure that at least one knowledgeable staff person is available to answer questions from the Panel from 9 am through 5 pm on the day of Review and Rank. (If your agency has more than one knowledgeable staff person, you may provide the Panel with up to three phone numbers, and divide up coverage so that each staff person is covering the phone for a different part of the day.) If the Panel calls your agency and a knowledgeable staff person is not available, then you may be bound by your written answers, even if these answers do not make sense or do not fully reflect your agency’s achievements. The Review and Rank Panel is not required to interview any particular agency or program. 2. HOW DATA IS USED In order to streamline the data collection process and ensure a fair competition, all APR data will be treated as final and authoritative. Projects may use their Supplemental Questions and Oral Interviews to explain the context for their data, but not to suggest that some other data would be more appropriate. For example, suppose a project’s APR shows that it only filled 60 out of its 100 beds. The project would be allowed to explain why it was difficult to fill those beds, but the project would not be allowed to argue that the true number of beds filled was really closer to 75 out of 100 beds. The data in the final APR that is sent to the Panel is binding on both the projects and the Panel. Because the APR is treated as authoritative, the CoC’s technical assistance provider will work with all applicants to help them clean and verify their APR data in advance of the competition. On or about July 9, 2021, all projects will receive an APR report from the TA APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 provider, along with a “mini-PRESTO” report that helps visually illustrate the information in the APR. Projects can also generate an unlimited number of APRs for themselves, at any time, using the Reports screen of the Homeless Management Information System (HMIS). The TA provider will help demonstrate how to do this upon request. Ultimately, it is each project’s responsibility to read their APRs, confirm that the data is correct, and fix any incorrect data by making the appropriate changes in HMIS. Note that APRs are only used for renewal housing project applications that have a full 12 months of data during the competition period (see the next section, below). New projects, projects with less than 12 months of data, coordinated entry projects, and HMIS projects do not use APRs as part of the competition. Final APRs are due on July 23, 2021 at 5:00 pm Pacific time. On the evening of July 23rd, the HMIS Lead will generate an APR for all renewal projects that will be used as the official APR for this year’s NOFA competition. A project that needs to modify its APR after this date is considered to have missed a competition deadline, and may lose points in the competition as a result. Changes to the APR that are made after July 23rd will be accepted only at the discretion of the competition organizers. The final APR that is accepted will be considered authoritative; all Supplemental Questions must be answered with reference to the final APR data. The one exception to the policy that APR data is considered authoritative is when there is clear and convincing evidence that a project’s APR data exaggerates the project’s accomplishments. For example, if a project’s APR data is internally inconsistent, inconsistent with information in the project’s e-SNAPs application, inconsistent with other HMIS data, or otherwise implausible, then the Review and Rank Panel has discretion to disbelieve the project’s APR in order to lower the project’s score. If the Panel is able to accurately and confidently identify the project’s true performance, then the Panel may lower the project’s score based on that performance. If the Panel is unable to confidently identify the project’s true performance because of poor-quality data, then the Panel may assign a score of zero for the relevant scoring factor(s). The Panel has no discretion to raise a project’s score based on errors in the project’s APR. 3. THE COMPETITION PERIOD The period of time that will be measured and evaluated during the NOFA competition is called the official “competition period”. The official competition period is May 15, 2020 through May 14, 2021. Unless otherwise specified, all Supplemental Questions are referring to events and outcomes that took place during the official competition period. All APRs will be generated using 5/15/20 as their start date and 5/14/21 as their end date. If a project had not yet started operations as of May 15, 2020, then it will not have 12 full months of data for the competition period, and so it will not be scored in this year’s competition. Instead, the project will be automatically ranked at the bottom of Tier 1. A project has “started operations” if it has signed a contract with HUD, drawn down funding from eLOCCs, or housed at least one client. The fact that a project may still be “ramping up” does not mean that the project has not yet started operations. APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 HUD’s data quality regulations allow projects to conduct annual assessments at any time between 11 months and 13 months after a client’s anniversary of entering a project. For example, a client who joined a project on 5/8/2019 could have their annual assessment conducted anytime between 4/8/2020 and 6/8/2021. Unfortunately, because of the way Annual Performance Reports (APRs) are designed, APRs will ignore any annual assessments that are conducted after the close of the APR’s measurement period. For example, an APR with a period of 5/15/20 – 5/14/2021 will not award credit for an assessment conducted on 6/3/2021, even though HUD would accept such an assessment during an audit. Assessments that are marked as “missing” because of this effect can sometimes reduce a project’s score. To prevent this type of reduction, projects may wish to conduct all pending assessments within only 12 months of their clients’ anniversaries, even if this means conducting some assessments a few weeks before HUD’s deadline. The Review and Rank Panel will be instructed to score projects based on their data as reflected on the APR, and will be discouraged from rounding projects’ scores up based on the projects’ statements that they conducted assessments for their clients after 5/14/2021. Because each project has its own unique contract end date, an exception must be made for evaluating grant spenddown. If available, the Review and Rank Panel will look at spending data from the most recent quarterly e-LOCCs report issued by the HUD field office – either the 3/31/2021 report, or the 6/30/2021 report, depending on the timing of the competition. Otherwise, the Review and Rank Panel will look at e-LOCCs printouts submitted by each renewal project. In either case, the goal will be to determine what fraction of the project’s funds were spent down during the project’s most recently completed contract. For example, if spenddown is based on the 3/31/2021 report, then a project whose FY2019 contract ended on 2/15/2021 would use its FY2019 spenddown. A project whose FY2019 contract did not end until 3/10/2021 would use its FY2018 spenddown. If a project has not completed any contracts that could be fully evaluated using this method, then the project’s spenddown will be measured on an ad hoc basis that attempts to provide the fairest possible measurement period. DESIGN OF SCORING TOOLS The Review and Rank Panel will be guided in their scoring by a series of Scoring Tools that summarize the priorities and targets chosen by HUD and by the local community. To help cope with the fast pace of the competition, these Scoring Tools are typically drafted before HUD releases the final rules of each year’s competition. Upon publication of the CoC Program NOFA, the Collaborative Applicant will review the currently adopted scoring tools for all project types and ensure they comply with the NOFA. In the event the scoring tools do not comport with the NOFA, changes will be made and adopted prior to the use of the tools in the competition. All changes will be presented to and approved by the CoC in accordance with the Governance Charter, with input from the Review and Rank Committee members and project applicants encouraged. APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 NOFA TECHNICAL ASSISTANCE WORKSHOP Upon publication of the CoC NOFA, the Collaborative Applicant will schedule and announce a time and date for a Technical Assistance Workshop where details about the funding opportunity and the process are provided. These details will be distributed to the entire CoC via listserv, email, posting, and any other method appropriate to ensure full distribution to the CoC. All applicants/potential applicants are strongly encouraged to participate in the NOFA Technical Assistance Workshop or to watch the recording and submit questions to fmcoc@homebaseccc.org within two weeks of the date of the Workshop. Remote participation is acceptable due to the pandemic. A. At the workshop, attendees will receive an overview of the HUD CoC Program NOFA, including details about available funding and any major changes in the application from previous years. B. Applicants will also be oriented to the process for reviewing and ranking applications. C. Applicants will also have the opportunity to ask any questions they have about both the local and HUD application processes. D. A portion of the Workshop will be dedicated to orienting potential new applicants to the funding opportunity to prepare them for the application process and provide all necessary information about the Continuum of Care program. Any Applicant who neither attends nor watches the Technical Assistance Workshop will be held strictly accountable for complying with all competition requirements. An applicant who submits an application with an error in it that could have been prevented by attending or viewing the TA Workshop may be summarily disqualified from the competition. If they are submitting a new project, the application may be rejected based on the error, and if they are submitting a renewal project, their funding may be involuntarily reallocated based on the error. Projects may be excused from the TA Workshop for emergencies which prevent the program from sending a representative staff member to the TA Workshop. However, the Collaborative Applicant must be notified of the emergency as soon as possible. SELECTING THE REVIEW AND RANK PANEL 1. REVIEW AND RANK PANEL MEMBER QUALIFICATIONS Review and Rank Panel members shall be: • Knowledgeable about homelessness and housing in the community and are broadly representative of the relevant sectors, subpopulations, and geographic areas APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 • “Neutral,” meaning that they are not employees, staff, or otherwise have a business/financial or specific personal conflict of interest with the applicant organizations; • Familiar with housing and homeless needs within the CoC; and • Willing to review projects with the best interest of homeless persons in mind. Review and Rank Panel members agree to: • Dedicate time for application review and Review and Rank Panel meetings • Sign a statement declaring that they have no conflict of interest and a confidentiality agreement. 2. REVIEW AND RANK PANEL SELECTION Review and Rank Panel members for the Continuum of Care Competition Review and Rank shall be chosen by the Collaborative Applicant subject to the membership qualifications above. The Panel shall be announced to the Continuum of Care Competition applicants no later than two weeks before the Review and Rank meeting. The Review and Rank Panel shall consist of three to five members. 3. CONFLICTS OF INTEREST If a person or an organization believes there is a conflict of interest that would exclude a Review and Rank Panel Member, it needs to be brought to the attention of HomeBase staff within four calendar days of the announcement of the Review and Rank Panel membership. The concerned person/organization would need to provide specific and substantial information regarding the alleged conflict to allow the Collaborative Applicant to conduct a fair evaluation. 4. THE PANEL’S PREPARATION A. The Panel shall receive a training from HomeBase on the use of the PRESTO system, the CoC Program and local competition, and their responsibilities as Review and Rank panelists. This training may be conducted via videoconference at the convenience of the Panel. B. The Panel shall review the PRESTO reports and supplemental project information prior to the scheduled Review and Rank meeting. C. The Panel shall meet in person or by teleconference to discuss the applications submitted as part of the Continuum of Care Competition. 5. THE PANEL’S INTERVIEWS APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 All scored projects will be required to be on call on the day of the Review and Rank Meeting in order to answer questions from the Panel as required. Failure to make a knowledgeable staff person reasonably available by phone on the scheduled day may force the Panel to rely solely on written application materials, which may in some cases result in a lower score and/or in a loss of funding. 6. EMERGENCY REPLACEMENTS If one or more Panel members are unable to attend the Review and Rank meeting or otherwise unable to discharge their duties, then the Chair or Vice-Chair of the Fresno/Madera Continuum of Care may appoint one or more suitable emergency replacements, or may continue the Review and Rank process with a smaller Review and Rank Panel, at their discretion. ASSIGNING SCORES TO PROJECTS 1 . IN GENERAL The Review and Rank Panel will use the information it receives to decide on a score for each project for each of the scoring factors listed in the Scoring Tools. Panelists are encouraged to candidly share their reasoning with each other and to listen carefully to each other’s reasoning, but each Panel member is entitled to his or her own opinion: there is no requirement that the Panelists agree about how to score a project. An individual Panelist may have a tendency to score projects more harshly or more leniently as long as that tendency is consistently applied to all projects. After scoring is over, the scores assigned by each Panelist will be averaged to calculate the program’s final score. Except as specifically indicated, all scoring factors have a minimum of 0 points. Panelists may not assign a project a negative number of points. Similarly, Panelists may not assign “extra credit” that goes above the maximum score listed for a scoring factor in the Scoring Tool. Panelists may use decimal scores (e.g., 2.5 points) when necessary. 2 . SCALED SCORES Some scoring factors in the scoring tools include “scales” that instruct panelists on how to translate performance into points. For example, PSH projects that place at least 95% of their clients into permanent housing should receive 24 points, and projects that place between 90% and 95% of their clients into permanent housing should receive 18 points. Each Panelist has some discretion to adjust a scaled score up or down within the boundaries set by the scoring tool based on their understanding of the context of the project’s performance. For example, if a project placed only 92% of its clients into permanent housing, but the main reason why some clients did not enter permanent APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 housing is that their home was destroyed in an earthquake, then the Panel might choose to award 21 points, or even to award the full 24 points, rather than following the scale’s recommendation of awarding 18 points. However, absent a truly extraordinary circumstance, Panelists should not adjust a score by more than 20% of the maximum possible value for that scoring factor. For example, placement into permanent housing is worth 24 points. 20% of 24 points is 4.8 points, so the Panel should not normally adjust a project’s score on placement into permanent housing up or down by more than 4.8 points. This 20% discretion is above and on top of any discretion that is explicitly provided for in the scoring tool. E.g., if the scoring tool says that a project may be awarded 2 additional points for a specific reason, the Panel may use its discretion to add 2 points and to add 20% on top of that. The Review and Rank Panel may never award more than 100% of the maximum score allowable for a particular category. For example, if a scoring factor says to award up to 5 points, then the Panel cannot award more than 5 points for that factor. Moreover, Panelists should not adjust scores based on personal feelings about the value of a project, nor should Panelists adjust scores based on a general sense of the difficulty of a project’s work. Panelists are not allowed to adjust scores based on an applicant’s arguments about what the data “should have shown” or “really shows” – the data in the Annual Performance Report (APR) must be treated as authoritative. It is each applicant’s responsibility to correct any errors in the APRs before the Review and Rank Panel meets. 3 . MISSING, LATE, OR INCOMPLETE APPLICATIONS If the competition facilitators receive part or all of an application up to 72 hours late, this fact will be noted in the competition documents so that the Review and Rank Panel can assign an appropriate penalty (up to 5 points out of 100) using the Scoring Tool. If an application is missing, is more than 72 hours late, or is seriously incomplete as of the date that the Review and Rank Panel would begin reviewing applications, then at its discretion, the Review and Rank Panel may choose to automatically exclude the project from the competition, and to reject that application without assigning it a score. 4. DV BONUS PROJECTS Projects that are dedicated to serving survivors of domestic violence, dating violence, stalking, and/or sexual trafficking may opt to apply for HUD’s domestic violence (DV) bonus funding. Projects that are applying for DV bonus funding are scored using a slightly modified scoring tool that accounts for the project’s ability to promote the safety of its residents and for the project’s contribution to the Continuum of Care’s analysis of Fresno County and Madera County’s DV-specific needs and resources. The highest scoring DV bonus project in each APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 component type (e.g. DV-specific Rapid Re-Housing, or DV-specific Coordinated Entry) will be nominated by the Continuum of Care to receive bonus funding. If HUD awards the bonus funding to the project, then it will be separately funded using a national pool of DV-specific money. If HUD does not award bonus funding to the project, or if the project is not the highest-scoring DV bonus project of its type within the CoC, then the project will still be eligible to compete as normal for ordinary HUD CoC bonus funding. The Review and Rank Panel has discretion to alter the ranking of projects that have applied for DV Bonus funding in order to protect programs that have a higher priority for the community and that would otherwise appear lower than the DV Bonus projects on the Priority Listing. For example, HMIS and Coordinated Entry projects are sometimes automatically ranked at the bottom of Tier 1, but it may be undesirable to rank these projects at the very bottom of Tier 1, because the bottom projects in Tier 1 could be moved to the top of Tier 2 (and become vulnerable to losing funding) if a DV Bonus project is ranked in Tier 1 and then fails to receive DV Bonus funding. To prevent this type of problem, the Review and Rank Panel may adjust the rank of DV Bonus projects as needed. 5. UNSCORED PROJECTS Certain projects are not assigned scores in the competition. As explained in the next section, these projects will be automatically assigned a spot in the Recommended Ranked List based on community policies. ASSIGNING RANKS TO PROJECTS After all projects have been scored, the Review and Rank Panel will assemble a list of their recommendations for how each project should be ranked in order of funding priority. The list will be guided by the scores that the Panel has already assigned. 1. TIER 1 Most projects will be ranked in “Tier 1.” In a typical competition, Tier 1 includes roughly 90% of the funding available to the CoC. Projects that are ranked in Tier 1 are expected to receive federal funding unless the government shuts down or the project is deemed legally ineligible by HUD. CoC staff work closely with all applicants to help review their applications and ensure that their projects will not be disqualified by HUD. Although HUD requires each project to be assigned a unique place in the Ranked List, it typically makes no practical difference to an agency whether they are ranked, e.g., first or sixth in the list – all projects in Tier 1 can reasonably expect to receive funding. 2. TIER 2 APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 Some projects will be ranked in “Tier 2.” This means that the community would like those projects to receive funding, but that it is unclear whether HUD will allocate enough money to the community to fund those projects. If the community performs well in the national competition, or if Congressional appropriations stretch further than expected, then most of Tier 2 will be funded. If the community performs poorly in the national competition, it is possible that a significant portion of the projects in Tier 2 will lose their federal funding. Projects that are ranked toward the top of Tier 2 are somewhat more likely to receive funding than projects at the bottom of Tier 2. 3. STRADDLING PROJECT Because of the way HUD structures the NOFA competition, there is almost always one project that “straddles” the line between Tier 1 and Tier 2. Theoretically, this project could receive its Tier 1 funding while being denied the share of its funding that falls within Tier 2. In the unlikely event that this occurs, the project and/or HUD could decide that the share of funding remaining is insufficient to successfully continue the project, and the project could be entirely de-funded. Alternatively, the project and HUD could decide that the remaining funding is enough to continue operating the project at a reduced level of coverage (e.g., by serving fewer clients) or to continue operating the project at the same level of coverage (e.g. by increasing local funding). 4. UNSCORED PROJECTS A. Renewal HMIS projects are not scored. Instead, they are automatically placed at the bottom of Tier 1, just above the ‘straddling’ project. This reflects the community’s commitment to ensuring that it can continue to provide mandatory HMIS services, without which other CoC programs would not be eligible to receive funding. B. Renewal projects with less than one year of operating data will be automatically ranked near the bottom of Tier 1, immediately above the Renewal HMIS projects. The relative ranking of these projects will be alphabetical. C. The community has determined that its Coordinated Entry projects are of high priority for securing the overall operation of the Continuum of Care. Moreover, it is difficult to evaluate the performance of Coordinated Entry renewal applications, because different Coordinated Entry projects are focused on different services and subpopulations, e.g., street outreach vs. assessment and referral. The CoC is in the process of conducting a detailed evaluation of the performance of the Coordinated Entry System as a whole and expects that this process will result in opportunities for improved data quality and additional clarity around the community’s expectations for Coordinated Entry performance. After the evaluation, Coordinated Entry renewal projects that are seriously under-performing will be considered for reallocation. However, this year, all renewal Coordinated Entry projects will be ranked near the bottom of Tier 1, where they are expected to be renewed. APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 D. New Coordinated Entry projects and new HMIS projects that are being proposed as new project applications will be scored as normal using custom scoring tools that account for the unique goals of these types of projects. They will be ranked in accordance with their scores. E. If a program includes data from two different projects (e.g., as the result of consolidation, or as the result of expansion), and a single APR is available that contains data from both projects, then that APR will be used to score the project as normal. In accordance with the scoring tools, the project may have its score on utilization factors adjusted upward if the younger portion of the project has less than one full year of operating data. The fact that part of the project did not have a full year of operating data will not cause the entire project to remain unscored. F. If a program includes data from two different projects (e.g. as the result of consolidation, or as the result of expansion), and there is no single APR that adequately reports the data for the pair of projects, then CoC staff will use their best efforts and discretion to find an appropriate basis for objectively evaluating the project(s). This could include merging the APRs, separating the APRs and scoring only the project(s) that have a full year of operating data, separating the APRs and scoring all projects and then averaging their scores, or other reasonable solutions based on the available data. 5. VOLUNTARY AND INVOLUNTARY REALLOCATION Some agencies may decide to voluntarily reallocate part or all of one of their projects, i.e., to release that funding back into the common pool for the entire CoC. Agencies might choose to reallocate their funding because they are no longer able or willing to continue their program, because they have more funding than they need to operate the program, or because they believe that the funding could be better spent on alternative uses. A project that is entirely reallocated will not receive a spot in the Ranked List. A project that is partially reallocated can still receive a spot in the Ranked List; that project’s spot will simply reflect that the project is now applying for a reduced amount of money. Alternatively, the Review and Rank Panel has the discretion to recommend projects for involuntary reallocation. The Review and Rank Panel determines if any renewal project should receive a decrease in funding (or an elimination of funding) due to substandard performance in outcomes and/or utilization of funds. Any funding captured from an existing project will be made available for reallocation to a new project that meets the requirements in the NOFA. All projects must meet certain threshold requirements (as detailed on the scoring tool) in order to be included in the ranked list. CoC staff will provide technical assistance to all projects to attempt to help them meet these threshold requirements. Special consideration will be made for reviewing New Project applications for eligibility determinations in order to provide technical assistance prior to the Review and Rank convening in order to encourage successful applications by new projects. Nevertheless, it is ultimately each APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 applicant’s responsibility to ensure that their application meets all threshold criteria. If the Review and Rank Panel is concerned that a project may not be able and willing to meet threshold criteria even after receiving short-term technical assistance, then the Review and Rank Panel should reallocate that project’s funding. HUD expects CoCs to reallocate funds from non- and/or under-performing projects to higher priority community needs that align with HUD priorities and goals. Reallocation involves using funds in whole or part from existing eligible renewal projects to create one or more new projects. In the recent competitions, HUD allowed CoCs to use the reallocation process to create: • New permanent supportive housing projects that serve chronically homeless individuals and families, including unaccompanied youth. • New rapid rehousing projects for homeless individuals and families, including unaccompanied youth, coming directly from the streets or emergency shelter or fleeing domestic violence. • New projects for dedicated HMIS. • New Supportive Services Only (SSO) projects for centralized or coordinated entry systems. HUD expects that CoCs will use performance data to decide how to best use the resources available to end homelessness within the community. CoCs should reallocate funds to new projects whenever reallocation would reduce homelessness. Communities should use CoC approved scoring criteria and selection priorities to determine the extent to which each project is still necessary and address the policy priorities listed in the NOFA. The FY2018 NOFA stated that HUD would prioritize funding for CoCs that have demonstrated the ability to reallocate resources to higher-performing projects. HUD assigned four points in the Collaborative Applicant Application to reallocation. The Fresno/Madera County CoC has identified the need for additional permanent housing options within Fresno and Madera County. The lowest performing projects may be reallocated to support new permanent supportive housing or rapid re-housing projects that emphasize serving the Chronically Homeless or Transition Aged Youth. The CoC also recognizes the need for an efficient Coordinated Entry system. 6. DISCRETION OF PANEL TO PRESERVE RENEWAL PSH The Fresno Madera Continuum of Care prioritizes the preservation of existing permanent housing to maintain critical supportive housing inventory and prevent the loss of housing for existing program participants. The Review and Rank Panel has discretion to adjust the Priority Listing with this goal in mind. 7 . NOTIFICATION OF RANKINGS APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 Project applicants will be notified as to whether they were recommended for funding (and, if so, in what tier) within 72 hours of the Review and Rank Meeting. Projects who are eligible to appeal will receive a more detailed report that includes a full list of project scores along with a scoring breakdown for their project(s) at least 24 hours before Technical Appeals are due. Projects that are not eligible to appeal will receive this more detailed report at a later date consistent with the needs of the competition. TECHNICAL APPEALS The Review and Rank Panel reviews all applications and ranks them for funding recommendations to HUD. Applicants may appeal the decision on technical grounds by following the process set forth below. 1. MEMBERS OF THE APPEAL PANEL The Appeal Panel shall consist of three members. These members may be selected from non-profits, foundations, consumers, government, and private agencies with experience in grant administration and homelessness projects. The Appeal Panel will be selected by the neutral facilitator of the Review and Rank process. Appeal Panel members must not have a conflict of interest with any of the agencies or parties applying for CoC Program funding as defined by the existing Review and Rank Panel conflict of interest rules. 2. APPEAL ELIGIBILITY A project may only appeal if: 1. The Review and Rank panel recommends the project for full or partial reallocation; 2. The project is placed in Tier 2; 3. The project is straddling Tier 1 and Tier 2, or; 4. The project is placed immediately above the unscored renewal projects, so that if one other project’s appeal is successful, then this project could be moved down into Tier 2. If the project was submitted by a collaboration of agencies, only one joint appeal may be made. 3. SUBJECTS FOR APPEAL Appeals may be made only on the following bases: APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 • Inaccuracy in information provided to the Review and Rank Panel (by entities other than the applicant) resulting in a reduced score • A failure to follow the Review and Rank process resulting in a reduced score NOTE: Appeals based on policy considerations, funding priorities, or other subjective criteria will not be considered and are not eligible for technical appeal. 4. APPEALS PROCESS Any Project Applicant seeking to appeal must adhere to the included timeline. Failure to meet a deadline in the timeline voids the Project Applicant’s appeal. A. Project Applicants must provide notice to the CoC of an intent to appeal. The due date for this notice will be contained in the official CoC Competition Timeline. This notice must include: i. A statement as to why the project is eligible to appeal. ii. The basis for the appeal iii. A brief statement of the facts upon which the Project Applicant bases its appeal. These facts need not be complete, but must give the CoC a sufficient understanding for the basis of the appeal. B. The CoC will contact the appealing Project Applicant in an attempt to clarify the scoring decision and determine if the appeal can be resolved without requiring a formal hearing. C. If a resolution is not possible, the Project Applicant will submit a formal appeal pursuant to the official CoC Competition Timeline. i. The Formal Appeal must consist of a short, clear, written statement no longer than two pages of the basis for the Project Applicant’s appeal of the Review and Rank Panel’s decision. ii. The Formal Appeal must be sent as an attachment to the Collaborative Applicant. D. Upon timely receipt of the Formal Appeal, the Collaborative Applicant will convene the Appeal Panel and set a time and date for the Appeal Hearing. E. The Appeal Hearing shall be conducted according to the following procedure: i. The Appeal Hearing will be conducted telephonically. ii. The Appeal Panel will join the call with the neutral facilitator and a representative of the Review and Rank Panel. iii. The neutral facilitator will explain the facts of the appeal and answer any procedural questions. iv. The Appeal Panel may ask the Review and Rank Panel member questions about the Review and Rank Process to clarify what occurred during Review APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 and Rank and what information the Panel considered in evaluating the Project Applicant. v. The appealing Project Applicant will then join the phone call. The appealing Project Applicant will be allotted a few minutes to explain their appeal. The Appeal Panel may then ask any questions of the appealing Project Applicant. The appealing Project Applicant would then leave the phone call. vi. The Appeal Panel would conduct a discussion of the appeal and take a formal vote. F. The Appeal Panel may consider the effect of its decision on other Project Applicants and may include those project applicants in the appeals discussion. The decision of the Appeal Panel is final and will be transmitted to the CoC Board without further debate. SUPPLEMENTAL PROJECT FUNDING In some circumstances there may be an opportunity after the application deadline for programs to submit application materials for additional funding. The Collaborative Applicant will issue a Supplemental Project Application when: 1. After receiving all project applications it appears there is additional funding available; or, 2. After conducting the threshold review of the submitted project applications it appears there is additional funding available; or, 3. After conducting the review and rank, the Panel has recommended a program for reallocation and there are not adequate new project applications for those funds. In the event that Supplemental Applications are required, the Collaborative Applicant will: • Email the CoC and other interested parties (all homeless service and housing providers in the CoC area) with specifics regarding how much money is available and which type of programs qualify. • The Collaborative Applicant will provide technical assistance and guidance, as needed, to ensure applicants understand the funding requirements. • Any additional applications for these funds will be due as soon as possible after this email is distributed, as determined by the NOFA submission deadline. • The Review and Rank Panel will reconvene either via telephone, video conference, or in person depending on availability and convenience to evaluate the applications. For this type of process, the timeline will be extremely short and may make an application burdensome; however, a simplified application process, expanding an already submitted application, applying in collaboration, or a community consensus on how to spend the funds are also viable options. APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 The Review and Rank Panel is not required to use the formal scoring factors to evaluate supplemental applications. Instead, the Review and Rank Panel may recommend one or more supplemental application(s) for funding based on an intuitive evaluation of the supplemental applications, provided that no supplemental application may be ranked higher than a regular application. APPROVED by the Fresno/Madera Continuum of Care in xxx, 2021. Homebase | Advancing Solutions to Homelessness | fmcoc@homebaseccc.org 12 APPROVAL OF THE RANKED LIST AND SUBMISSION TO HUD A. All technical appeals shall be concluded within no more than ten days of the Review and Rank Panel Meeting. B. Once the technical appeals are complete and the Supplemental Competition (if any) is concluded, the Recommended Priority List will be submitted to the CoC Board and General Membership for review and approval. C. If a majority of the CoC Board and a majority of the CoC General Membership agree on specific change(s), then together they have the discretion to alter the Recommended Priority List in order to meet urgent community needs, but alterations are strongly discouraged because they tend to result in a lower score for the Fresno/Madera CoC in the national competition, which means that less funding will be available for the entire community. D. Once a majority of the CoC Board and a majority of the CoC General Membership have approved the Recommended Priority List, the Review and Rank Process is complete. These votes may be obtained electronically and/or in person, in any order. The majority of the CoC Board may be obtained as part of a vote held during a CoC General Membership meeting, without the need for a separate Board meeting. E. The Approved Priority List shall be publicly posted on the CoC website in accordance with the timeline stated in the Continuum of Care Program NOFA, and shall be used to fill in the appropriate application forms for the Collaborative Applicant to submit to HUD as part of the national competition.