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Rural Setaside Included in Major New HUD Homeless Funding Initiative – UPDATED 9/19/22

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Webinar recording and slides posted

A webinar titled Funding Opportunities: Learn More About HUD’s Special NOFO to Address Rural Homelessness and New Stability Housing Voucher Program, cosponsored by HAC, the National Alliance to End Homelessness, and the National Association of Housing and Redevelopment Officials, was presented on September 15, 2022. The webinar recording and slide presentations are now available online.

Introduction

On June 22, 2022, HUD released a Notice of Funding Opportunity (NOFO) titled “Continuum of Care Supplemental to Address Unsheltered and Rural Homelessness.” A total of $322 million in recaptured Continuum of Care (CoC) funds is available, comprised of $267.5 million for an “Unsheltered Homelessness Set Aside” and $54.5 million for a “Rural Set Aside.”

Any CoC that registered for the FY 2022 CoC program competition may apply under this NOFO. Projects under the Unsheltered Homelessness Set Aside may serve any geographic area within the CoC. A CoC whose service area includes places that meet the rural definition (below) may apply for either the Unsheltered Homelessness Set Aside or the Rural Set Aside, or both.

Projects that will serve places where CoCs have not previously worked are targeted for special attention within the Rural Set Aside. When HUD scores applications, 10 points out of the total 100 available are specifically for “projects that serve individuals and families in geographic areas that have high levels of homelessness, housing distress, or poverty, and are located where CoC services have until now been entirely unavailable, such as, for example, Trust Lands and Reservations.”

This Competition

CoC applications are due to HUD on October 20, 2022. Each CoC must design its own “collaborative process” to develop its proposal, including a process for project applications. A local organizations or government entity must apply to its area CoC to be included in the CoC’s application to HUD.

This competition is separate from the FY 2022 CoC program competition, which has not yet opened. Applications and awards for this competition will not impact those for the FY 2022 competition.

Eligible Project Applicants

Nonprofit organizations, states, local governments, instrumentalities of state and local governments, Indian Tribes, TDHEs, and PHAs are eligible to apply for project funding under either set aside in this competition. For-profit entities are not eligible to apply or to be subrecipients of grant funds.

Rural Definition

Counties and county equivalents where the Rural Set Aside can be used are listed in the NOFO’s Appendix B.

The rural definition used for this competition was adopted in the HEARTH Act, which provides that a rural area is a county that meets one of three criteria:

  1. It is completely outside of OMB-designated standard metropolitan statistical areas (i.e., it is nonmetropolitan).
  2. It is in an OMB-designated metropolitan statistical area and at least 75% of its population lives in census blocks classified as non-urban.
  3. It is located in a state that has a population density of less than 30 persons per square mile (as reported in the most recent decennial census), and that has at least 1.25% of its total acreage under federal jurisdiction, provided that no metropolitan city in such state is the sole beneficiary of the grant amounts awarded under this NOFO.

Funds Available

The maximum amount that each CoC can request is listed in the NOFO’s Appendix A. These amounts are calculated differently for the two set asides. For the Unsheltered Set Aside, each CoC is eligible for its Preliminary Pro Rata Need (PPRN) for the FY 2022 CoC Program Competition or $60 million, whichever is less. For the Rural Set Aside, the maximum is set at 150% of the combined PPRNs for the FY 2022 CoC Program Competition of all of the CoC’s rural areas.

Grant Terms

Grants under this NOFO will be for three-year terms. Grants for hard costs are not renewable. HUD expects that others will be renewable under regular CoC competitions, though they caution that they cannot guarantee what will happen in the future.

Eligible Activities

The Rural Set Aside can be used to finance more activities than the Unsheltered Set Aside, as summarized in the table below.

 

 

Unsheltered Set Aside

  

Rural Set Aside
 

Eligible activities

  

Permanent housing

Supportive services only

HMIS

Joint transitional housing and permanent housing-rapid re-housing

Planning costs (capped at 3% of maximum award amount)

Unified Funding Agency costs (capped at 3% of maximum award amount)

  

Permanent housing

Supportive services only

HMIS

Joint transitional housing and permanent housing-rapid re-housing

Rent or utilities in some situations

Emergency shelter costs

Repairs to make housing habitable

Capacity building activities (capped at 20% of total funds a CoC requests)

Emergency food and clothing

Costs to use federal inventory property

Staff and overhead directly related to carrying out activities in this list
 

Ineligible activities

  

Acquisition

New construction

Rehabilitation

  

Planning costs

Unified Funding Agency costs

 

Eligible Participants/Definition of “Homeless”

Characteristics of people who will be eligible to participate in projects funded under each set aside in this NOFO – i.e., those who are considered to be “homeless” – are listed in the table below.

 

 

Unsheltered Set Aside

  

Rural Set Aside
 

Eligible participants

  

People who are literally homeless, “except that persons coming from transitional housing must have originally come from places not meant for human habitation, emergency shelters, safe havens, or institutions where they resided for 90 days or less and originally came from places not meant for human habitation, safe havens, or emergency shelters”

Domestic violence victims

  

People who are literally homeless

People who are precariously housed

Domestic violence victims

Youth or families considered homeless under other statutes, if CoC obtains HUD approval, limited to certain types of projects, and capped at 10% of award

 
 

Ineligible participants

  

People who are precariously housed

Youth or families considered homeless under other statutes

  

None

 

Plan for Severe Service Needs

Each CoC applying under this NOFO must develop a “Plan for Serving Individuals and Families Experiencing Homelessness with Severe Service Needs.” For both the Unsheltered and Rural Set Asides, large portions of the application and the potential scoring points are based on these plans.

The NOFO defines Severe Service Needs as

any combination of the following factors: facing significant challenges or functional impairments, including any physical, mental, developmental or behavioral health disabilities regardless of the type of disability, which require a significant level of support in order to maintain permanent housing (this factor focuses on the level of support needed and is not based on disability type); high utilization of crisis or emergency services to meet basic needs, including but not limited to emergency rooms, jails, and psychiatric facilities; currently living in an unsheltered situation or having a history of living in an unsheltered situation; experiencing a vulnerability to illness or death; having a risk of continued or repeated homelessness; and having a vulnerability to victimization, including physical assault, trafficking or sex work.

Most of the plans’ components must be provided in applications for either Unsheltered or Rural funds. The outline of plan contents is provided in the table below, along with indications of where the requirements differ for Rural Set Aside applications.

 

 

Plan Component

  

Required for Unsheltered Set Aside

  

Required for Rural Set Aside
a. Leveraging housing resources
1. Development of new units and creation of housing opportunities Y Y
2. Landlord recruitment Y Y
b. Leveraging healthcare resources Y Y
c. CoC’s current strategy to identify, shelter, and house individuals and families experiencing unsheltered homelessness
1. Current street outreach strategy Y Y
2. Current strategy to provide immediate access to low-barrier shelter and temporary housing for individuals and families experiencing unsheltered homelessness Y N
3. Current strategy to provide immediate access to low barrier permanent housing for individuals and families experiencing unsheltered homelessness Y Y
d. Updating the CoC’s strategy to identify, shelter, and house individuals experiencing unsheltered homelessness with data and performance Y N
e. Identify and prioritize households experiencing or with histories of unsheltered homelessness Y Y
f. Involving individuals with lived experience of homelessness in decision making Y Y
g. Supporting underserved communities and supporting equitable community development Y Y

A different section of the NOFO contains a paragraph – which also appears in the FY 2021 CoC program NOFO – requiring applicants to identify steps they “will take” to ensure that traditionally marginalized populations (such as racial and ethnic minorities and persons with disabilities) will be able to meaningfully participate in “the planning process.” It is not clear whether, or how, this requirement would apply to the process of developing the severe needs plan, since this plan must be completed in order to be included in the application along with the proposal for steps applicants “will take” in developing future plans.

Application Scoring

For the Unsheltered Set Aside, HUD will select CoCs for awards based on the CoCs’ scores. All projects of the selected CoCs will be funded, up to the funding cap for those CoCs. For the Rural Set Aside, however, HUD will score the individual projects included in each application and select the highest scoring projects, up to the CoC’s maximum funding amount.

HUD will score the rural projects on a 100-point scale. Up to 50 points will correspond to HUD’s score for the CoC’s overall Rural Set Aside application. Up to 40 points will be based on the CoC’s ranking of the project (CoCs are required to rank all project applications for either set aside). Finally, another 10 points may be awarded to “projects that serve individuals and families in geographic areas that have high levels of homelessness, housing distress, or poverty, and are located where CoC services have until now been entirely unavailable, such as, for example, Trust Lands and Reservations.”

HUD may adjust its final project selections to ensure that at least one CoC in each HUD region is funded and that not more than 10 CoCs from a single state are funded.

Links for Additional Information

HUD email address for questions: SpecialCoCNOFO@hud.gov

HUD page where all information and supporting resources for this competition will be posted: https://www.hud.gov/program_offices/comm_planning/coc/specialCoCNOFO

HUD Continuum of Care program page: https://www.hud.gov/program_offices/comm_planning/coc

HUD page to locate a CoC serving a particular area: https://www.hudexchange.info/grantees/find-a-grantee/

HUD standard funding opportunity page for this NOFO: https://www.hud.gov/program_offices/spm/gmomgmt/grantsinfo/fundingopps/fy21coc_urh

Official grants.gov page for this NOFO: https://www.grants.gov/web/grants/view-opportunity.html?oppId=341301

Site where CoC applications will be entered: https://esnaps.hud.gov/

 

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New HUD Rural Homelessness Initiative Announced

On June 22 HUD announced a $365 million Initiative for Unsheltered and Rural Homelessness that will be distributed through Continuums of Care (CoC) and public housing authorities (PHAs) by means of two Notices of Funding Opportunity. The application deadline for CoCs is October 20. HUD is using recaptured CoC and Housing Choice Voucher funding from prior fiscal years to support the initiative.

The initiative includes $322 million in CoC program grants to be distributed by HUD’s Community Planning and Development division:

  • $267.5 million to fund homeless outreach, permanent housing, supportive services, and other costs as part of a comprehensive community approach to solve unsheltered homelessness in 20-40 communities with high incidences of unsheltered homelessness; and
  • $54.5 million targeted to rural communities, prioritizing those with high need but a history of being unable to access CoC grants. HUD is utilizing congressionally granted authority to expand the eligible uses for these funds beyond normal restrictions to enable rural communities to apply for grants to support capacity-building, transportation, and other needs more acutely felt in rural areas.

The division of Public and Indian Housing will distribute $43 million — approximately 4,000 new incremental vouchers — which will be allocated to PHAs with a priority for those that are partners in comprehensive community approaches to solve homelessness.

Manufactured Housing in the United States Map, 2018

Housing Assistance Council Statement on Proposed $500 Million Investment in Manufactured Housing

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The Housing Assistance Council (HAC) applauds Chairman David Price (D-4th-NC) and Ranking Member Mario Diaz-Balart (R-25th-FL) of the Transportation, Housing and Urban Development (THUD) Appropriations Subcommittee for their bipartisan and transformational investment in the Manufactured Housing Improvement and Financing Program.  The fiscal year (FY) 2023 budget bill passed this week by both the Subcommittee and the full Appropriations Committee includes $500 million to preserve and revitalize manufactured homes and manufactured housing communities, a long-underappreciated source of affordable housing for millions of Americans.

“The scale and scope of this bipartisan proposal, if enacted in the final FY 2023 HUD budget, would be a game-changer for families in need, HAC and our partners in this space.” – David Lipsetz, HAC CEO

This new program provides grants for a broad range of activities, from building affordable housing to building the capacity of local affordable housing organizations. The program will improve infrastructure, planning, resident and community services (including relocation assistance and eviction prevention), resiliency activities, and land and site acquisition.  The Department of Housing and Urban Development (HUD) would distribute the funds competitively to non-profits, CDFIs, resident-owned manufactured housing communities, states, local governments, Tribes, and other eligible entities.

“Manufactured housing represents the nation’s largest supply of affordable housing. Until this program, the poor, largely-rural families living in these homes have been denied access to the public programs that preserve and maintain housing for those that need it most. Nor have the non-profit and public sector entities who work with manufactured housing received federal funding commensurate with the preservation and revitalization challenge they face for this vital affordable housing stock,” said HAC President & CEO David Lipsetz. “The scale and scope of this bipartisan proposal, if enacted in the final FY 2023 HUD budget, would be a game-changer for families in need, HAC and our partners in this space.”

HAC is the only national non-profit intermediary dedicated to affordable housing in rural America. With a mission-focus on the most rural and poorest places, HAC has long prioritized manufactured housing given its disproportionate share of the rural housing stock.  Nationwide, approximately 6.7 million households live in manufactured or mobile homes, which is six (6) percent of the nation’s housing stock. Yet over 50 percent of all manufactured homes are located in rural areas.  which comprises 14 percent of all occupied homes in rural communities – more than twice the national rate.

The proposed program from Chairman Price and Ranking Member Diaz-Balart builds on the Subcommittee’s May 26th hearing “Manufactured Housing: Supporting America’s Largest Unsubsidized Affordable Housing Stock,” in which HAC’s Director of Research and Information Lance George testified on the challenges facing those seeking to maintain the quality of this essential affordable housing.  His testimony established that many manufactured housing residents lease the land on which their homes sit, leaving them vulnerable to evictions and predatory lot rents. And about two-thirds of manufactured home loans are classified as high cost—five times the national average for all homes.  His testimony concluded “manufactured housing is already a significant source of affordable housing in rural places, and it should continue to be a high-quality, affordable housing option.”  HAC strongly believes the Manufactured Housing Improvement and Financing Program would be a major step toward achieving just that.

Policy News from the Administration

HAC CEO Statement on Biden-Harris Housing Supply Action Plan

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by David Lipsetz

The Biden-Harris Administration released a Housing Supply Action Plan on May 16 that can bring the cost of housing back in line with families’ incomes. This is particularly important in small towns where incomes remain stubbornly low, while the cost of buying or renting a place to live is soaring. The Housing Assistance Council (HAC) applauds the Administration for designing and including several provisions specifically with rural markets in mind.

The Plan includes administrative and legislative proposals to improve existing housing finance mechanisms. It establishes new housing production programs. It calls for changes to the Low-Income Housing Tax Credit that will attract private investment in affordable rental housing. It provides grants—such as the HOME Investment Partnerships Program—to states, cities and towns to do what locals know will be best for their local housing market.  It calls on Congress to establish a Housing Supply Fund and incentivize zoning reform to accelerate the building of more housing across the Nation.

Critically, the Administration proposes reforms that prioritize homeowners living in the homes that they own. This is a welcome change for rural Americans who need high-quality affordable homes in which to live far more than they need high-priced vacation homes. For rental housing, the Administration focuses investment on small-scale 2–4-unit buildings instead of high-rise apartment complexes. It calls for new rentals where few are being built and recognizes the urgency of preserving affordable rentals that already exist. And for the first time in decades, an Administration released a housing plan that calls for improved financing for manufactured housing, an important resource in rural places.

The shortage of affordable housing in rural America is a serious issue. Rental units are being lost at an alarming rate. Single-family homes are significantly older than elsewhere in the Nation. The Administration’s framework recognizes the unique need for affordable housing and proposes solutions built to work in small town and rural America.

Many of the Administration’s actions just announced reflect HAC’s policy priorities. But it remains critical that these actions be complemented by initiatives to address another essential factor in improving housing for rural Americans—building the capacity of local organizations to improve their own communities. Because rural places often have small and part-time local governments, they often find it particularly difficult to navigate the complexities of federal programs and modern housing finance, and to compete for government resources. Philanthropy has not stepped in to address this inequity built into our systems, instead concentrating its resources in already-prosperous high-cost regions. Targeted capacity building through federal investments in training and technical assistance is how most local organizations build skills, tap information, and gain the wherewithal to do what they know needs to be done.

Rural communities hold vast potential to drive economic growth and improve the quality of life for all Americans. Access to quality, affordable housing is key to jumpstarting that potential. Building and preserving homes creates jobs, improves education and health outcomes, and provides much-needed financial and physical stability to families in need. We look forward to working with the Biden-Harris Administration and Congress to ensure that these initiatives move us closer to the day when every American has access to a safe, decent, and affordable place to call home.

Policy News from Congress

HAC Supports a Variety of Rural and Tribal Housing Funding Priorities

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HAC’s Fiscal Year 2023 Appropriations Priorities

As the Fiscal Year (FY) 2023 appropriations process gets underway, HAC is supporting a variety of rural and tribal housing funding priorities. This year, we saw the most robust Administration’s Budget for rural housing in recent memory, and we are hopeful that this will contribute to some momentum in the appropriations process. Among others, HAC supports the following rural housing funding priorities. (This list is not exhaustive and for Rural Housing Service programs not specifically mentioned, HAC supports the funding levels in the Administration’s FY23 Budget.)

USDA Multifamily Preservation:
  • $1 billion for USDA’s Multifamily Housing Preservation & Revitalization Demonstration (MPR) program
    • The cost to preserve the current USDA rental portfolio over the next 30 years is estimated to be over $30 billion. MPR is USDA’s most effective, and many times only feasible preservation funding tool. Applications have, however, been closed for four years as the Agency works through its waiting list, which is projected to take another four years.
  • $200 million for USDA Section 515, including new construction
    • This funding would allow for new construction to resume and is expected to be accompanied by a commensurate increase in Section 521 rental assistance to cover new units.
  • $350 million above the level needed for renewals to extend USDA Section 521 rental assistance to currently unassisted households
    • This funding would allow for the extension of rental assistance to cover all currently unassisted units. An estimated 67,000 households in USDA rental housing do not receive rental assistance from USDA, HUD or state sources (not including those that were covered by the American Rescue Plan). With an average annual income of only $13,500, these households are uniformly low income and often very or extremely low income. The vast majority also pay more than 30% of their income for rent. Providing this assistance will not only help families in need, but also shore up the finances of many developments, encouraging preservation.
  • $2 million for USDA Multifamily Housing Transfer & Prepayment Technical Assistance Grants
    • HAC is seeking to ensure that these funds support both transformational preservation research and the provision of technical assistance to improve transaction-level preservation deal flow.
  • $3 million for USDA’s Multifamily Housing Preservation Revolving Loan Fund Demonstration Program (PRLF)
    • PRLF was funded through appropriations for several years between 2005 and 2011 and provided loan capital to private non-profit organizations and state and local housing finance agencies to provide revolving loans for preservation.
Capacity Building:
  • $12 million for the Rural Community Development Initiative at USDA
    • The Rural Community Development Initiative (RCDI) is the sole capacity building resource provided through USDA’s Rural Development, and facilitates community development efforts in rural areas. Grants are competitively awarded to nonprofit housing and community development organizations, low-income rural communities and federally recognized tribes in order to support housing, community facilities, and economic development projects in rural areas.
  • $10 million for the Rural Capacity Building Program at HUD
    • The Rural Capacity Building Program (RCB) is a powerful and flexible program funded by HUD to build capacity of nonprofits and tribes to undertake affordable housing and community development activities in rural areas. Participating organizations are offered a suite of services for a comprehensive, customized approach of technical assistance, training, information products and resources, and low-cost rural housing development loans.
Rural & Tribal Homeownership:
  • $20 million for the Self-Help Homeownership Opportunity Program at HUD
    • Created in 1996, the Self-Help Homeownership Opportunity Program (SHOP) is a small but unique program that helps low-income families achieve homeownership through sweat equity. Competitively awarded SHOP funds from HUD go to a network of local nonprofits, distributed via intermediaries. SHOP funds can be used to acquire land, purchase foreclosed or abandoned properties, and improve the infrastructure of homes for lower-income homeowners. Often these are some of the most difficult items for local nonprofits to finance. Families invest a minimum of 100 hours of sweat equity into the construction of their homes, but many families invest much more — often in excess of 500 hours.
  • $50 million for the Section 502 Single Family Housing Direct Loan Relending Program for Native Americans
    • In 2018, the USDA and two Native community development financial institutions (Native CDFIs) in South Dakota implemented a successful $2 million demonstration which sought to improve the deployment rate of the 502 direct program in Native communities in South Dakota. The pilot made Native CDFIs eligible borrowers under the 502 direct loan program and enabled them to relend to qualified families for the construction, acquisition, and rehabilitation of affordable housing on trust land. Through this demonstration, the two Native CDFIs in partnership with USDA made nearly double the number of loans on these two reservations than USDA deployed on its own on the same two reservations during the previous ten years. The President’s FY 2023 Budget request includes funding for the continuation and expansion of the Native American 502 home loan relending program as part of the existing USDA 502 single family housing direct loan program.
HAC Names Jonathan Harwitz Director of Policy

Housing Assistance Council Names Jonathan Harwitz Director of Policy

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Contact: Dan Stern
(202) 842-8600
dan@ruralhome.org

Housing Assistance Council Names Jonathan Harwitz Director of Policy

Jonathan will manage HAC’s policy initiatives.

Washington, DC, March 1, 2022 – The Housing Assistance Council (HAC) is pleased to announce the hiring of Jonathan Harwitz as HAC’s new Director of Policy. He brings years of experience working with policymakers on affordable housing issues. Jonathan will spearhead and expand HAC’s place as the national source for independent, non-partisan policy solutions for rural housing and community development.

Jonathan joins HAC from his role as Director of Housing Community Development and Insurance Policy for the House Financial Services Committee.  Prior to that he served as Managing Director of Federal Policy and Government Affairs at the Low Income Investment Fund, a large national Community Development Financial Institution.  Earlier in his career, Jonathan served as: Deputy Chief of Staff for the US Department of Housing and Urban Development; Counsel to the Housing and Community Opportunity Subcommittee of the House Financial Services Committee; Professional Staff to the Housing and Transportation Subcommittee of the Senate Appropriations Committee; and in various policy-related positions at the Corporation for Supportive Housing. Prior to entering the field of federal policy, he clerked for two federal District Court judges and was a lawyer in private practice.

Jonathan was born and raised in Buffalo, NY. He earned a Bachelor’s degree with honors from Yale College, and a JD from Harvard Law School. He currently resides near Washington, DC with his wife and kids.

“Federal policy has an important and lasting impact on rural places,” said HAC CEO David Lipsetz. “We are incredibly excited to have Jonathan join the HAC team and help us make the case for equitable investment in rural areas across the country.”

For the last 50 years, HAC has been the voice for the poorest of the poor in the most rural places. HAC’s policy priorities are focused on the importance of capacity building, access to capital, and geographic equity in federal policymaking – with a specific lens on persistently poor and high-needs regions like the Mississippi Delta, rural Appalachia, farmworker communities, the Southwest border colonias and Indian Country. Our independent and non-partisan policy work ensures the most vulnerable rural populations have improved access to safe and affordable housing opportunities.

To learn more about HAC’s policy work, visit https://ruralhome.org/our-work/policy/.

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