COVID-19 Resources

1. Do I still have to complete monthly data uploads to HMIS?
   Yes. Please contact the CoC HMIS team or Foothold Technology if you need assistance completing your monthly upload.


2. Do I still need to submit the APR?
   Yes. Contact your local HUD Field Office to discuss any needed extensions for APR submissions. If you request an extension for your APR submission, please communicate the request with the CoC and document the reasons for your timeliness issues.


3. Do I still need to submit the annual assessment?
   HUD has not provided any waivers for annual assessments, therefore at this time, your annual assessment timeline will continue as normal. These assessments can be done with the clients over the phone or via video conferencing to adhere with COVID-19 physical distancing guidelines.


4. Are there any available CoC Waivers to help mitigate economic impacts caused by COVID-19?
   Yes. The following waivers are available for the CoC Program:
   • Fair Market Rent for Individual Units and Leasing Costs
   • Disability Documentation for Permanent Supportive Housing (PSH) 
   • Limit on Eligible Housing Search and Counseling Services
   • Permanent Housing-Rapid Re-housing Monthly Case Management
   • Housing Quality Standards (HQS) – Initial Physical Inspection of Unit
   • HQS – Re-Inspection of Units
   • One Year Lease Requirement, Definition of Permanent Housing
   Please notify your local CPD Director, by email, expressing your intent to utilize a specific waiver two days before you anticipate using the flexibility.
   
   It is strongly recommended that you establish a set of emergency policies and procedures for use during the COVID situation. This should outline the waivers you plan to utilize and describe the records you will maintain to support those waivers
   
   For more information on available CoC Waivers please visit the HUD Exchange.


5. Can I amend my 2018 and 2019 grant agreements to meet client health and safety needs in response to COVID-19?
   Currently, FY 2018 executed grant agreements are available for amendment. If you cannot find your grant pre-populated in the grant agreement amendment package for your CoC, contact your CPD Representative.
   Soon, FY 2019 grants will be available for amendment.
   
   The expedited changes you can make to your grant to enable you to meet immediate client health and safety needs are as follows:
   • Add eligible activities not originally part of your grant, such as Supportive Services.
   • Move funding between budget line items, including from Rental Assistance.


6. Can I extend the operating year for my 2018 grant to fully spend remaining dollars (i.e.: Extend to Spend)?
   Yes. You may extend the operating year of your current grant to fully utilize all awarded funding. The latest extended operating end date allowed for 2018 grants is December 31, 2020. This change will impact future renewals by permanently changing the grant’s operating start date. For more information please visit the HUD Exchange.


7. Do I need to update my polices and procedures to reflect emergency changes to our operations? 
   Yes. HUD has said they will be flexible with providers on changes to their operations if they can show updates were made to the project’s policies and procedures (e.g. standard operating procedures).


8. Can I use CoC funds under Operating, Admin, & Supportive Services to pay for COVID-related costs?
   Yes. See HUD Guidance on using Continuum of Care Program Funds for Infections Disease Preparedness and Response for more information.


9. Should I be worrying about my project’s performance?
   During the weekly HUD SNAPS Office “Office Hours,” HUD has stated that the priority for all providers now must be responding to the COVID-19 emergency and ensuring the safety and welfare of residents and staff. As a result, it is inevitable that regular project performance will likely be affected.
   
   The HUD SNAPS Office asks that providers request APR submission extensions if needed, update their policies and procedures (e.g. standard operating procedures, written standards, etc.) with COVID-19 related changes in practice, and do your best to keep up with necessary client documentation. Please be sure to read HUD COVID-related guidance and request relevant sections of the HUD Mega Waiver referenced above as needed.


10. When does my newly funded project awarded in the 2019 NOFA need to be up and running?
    COVID-19 response has slowed regular HUD Field Office business, causing delays in contract execution for 2019 new and renewal grants. For new projects awarded in the 2019 NOFA, you are not expected to begin work until your signed contract is in place. Once the contract is signed, the project must commence within 24 months. However, in keeping with the NYC CoC RFP requirements, the CoC expects new projects to be fully up and running within 12 months.  

Can ESG funds be used to train staff on how to deliver services during the COVID-19 pandemic, including how to recognize symptoms, how to protect recipient staff from infection, and how to protect against spreading the virus while providing assistance? Visit this Q&A here.

Can CoC project administrative funds be used to train recipient staff to safely deliver assistance during the COVID-19 pandemic? Visit this Q&A here.

May recipients and subrecipients of CoC Program funds purchase cell phones and wireless service plans for program participants to use when receiving supportive services? Visit this Q&A here.