HUD AAQ #81439: Serving PSH Clients from Outside CoC

Question Related To: Continuum of Care Program

Question ID: 81439

Question Subject: Serving CoC PSH Clients from Outside CoC

Question Text:
Does HUD have any docs that state it is ok to serve formerly homeless clients from outside our CoC?  Occassionally, we may serve some homeless clients that originally came from another CoC prior to porject entry, and we wanted to ensure we have documentation that allows this.  The only reference I could find online was related to TBRA, but we were not sure if it applied to CoC funded PSH projects, as well.

Response:
Thank you for your question.

HUD does not impose residency requirements as an eligibility standard in its Homeless Assistance Grants Program. Therefore, so long as the individual meets the definition of homeless in section 578.3 of the CoC Program interim rule and meets any additional eligibility requirements of your project, HUD would permit you to serve this individual even though he or she currently resides outside of your normal service area.

Please note that it is possible that your your local Continuum of Care (CoC) may impose residency requirements or preferences; therefore, you should check with your CoC for more information.

Regardless of whether the individual is ultimately eligible for your project and is permitted to be served given your CoC's residency requirements (if any), HUD encourages you to work with this individual to ensure he or she wants to move and would not prefer to wait for services that are otherwise available within the community in which he or she currently resides.

Please note that formal guidance that explains HUD does not impose residency requirements as an eligibility standard in its Homeless Assistance Grants Programs has not been published on the HUD Exchange; However, in June 2016, HUD published an amendment to § 578.51(c) of the CoC program regulations that allows individuals and families to choose housing outside of a CoC's geographic area, subject to certain conditions, and to retain the tenant-based rental assistance under the CoC program. The amended regulation specifies that program participants may choose housing outside of the Continuum of Care’s geographic area if the recipient or subrecipient, through its employees or contractors, is able to meet all requirements of §578.51 in the geographic area where the program participant chooses housing.

As a reminder, to be eligible for any assistance under the CoC Program, an individual or family must meet the definition of homeless as set forth in section 578.3 of the CoC Program interim rule. In addition, to be eligible for PSH, the CoC Program interim rule states that the household must be homeless, and that one adult or child member of the household has a disability (see section 578.37(a)(1)(i) for more information). Each year, HUD may set additional eligibility criteria in the NOFA through which projects are funded.

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