Last year, during the FY18 NOFA for CoC funded projects, multiple agencies chose to consolidate their CoC contracts. This article will detail: how the consolidation process was done, how funds should be drawn and the expectations for APR Reporting.
How grants were consolidated
HUD combined the grants using the following rules:
- Projects had to be the same project types (e.g. a PSH project could not be combined with a RRH project)
- The number of beds and units from all the projects were added together to create the new consolidated grant project
- HUD used a formula to determine the term of the new consolidated grant that allows the project to remain "whole" when the operating years of each grant were not the same
Using the rules that were discussed, assume the grants above are seeking to be consolidated. XX0180L4H021705 is the “surviving grant” and the target project for the new consolidation. When the consolidation happens, the grants will be rolled into XX0180L4H021806.
The "surviving grant" can be determined by comparing the project IDs of the contracts to be consolidated to the project ID in the new consolidated contract number. In the example above, the four numbers following 'XX' are the project ID (0180). The project ID for the contracts in our CoC will be the four numbers following 'CA' (ie. CA0123L9D021800).
HUD calculated that the grant will have a 15 month grant term; this is so the consolidated grant is able to provide funds across all three expiring grant terms. The new consolidated project XX0180L4H021806 will be awarded funding to serve 38 units, 29 beds, of which 16 beds are dedicated for chronically homeless persons
How funds should be drawn
Unlike previous years, FY18 consolidations allowed the expiring grants to use up the full amounts of funds allocated to them. Draws should be made on all FY17 grants through the end of their operating year. At the end of the operating year, the FY17 grants are to be closed. The project will then begin make draws from the consolidated grant.
Note, that each previous grant is to continue to draw funds from it until the operating end date.
The Annual Performance Report (APR) is required to be submitted to HUD within 90 days of the end of the operating year. Expiring FY17 grants are to report on their full operating year for their APR, since they were drawing funds through the end of the operating year.
- Agencies are to continue to record all activity on active and new clients in HMIS in the project where their expiring grants reside UNTIL the Operating End Date.
- Agencies must generate the APR for EACH expiring grant (the grants that are being combined) as soon as possible after the operating end date. 211OC cannot move forward with consolidating the projects in HMIS until the APRs for all projects included in the consolidation have been submitted. *Review the APR carefully for errors/omissions because once the records are moved in HMIS the APR will NOT be able to be reproduced*
- The project in HMIS which will be associated with the surviving grant will become the "Home Project" for the new grant. After the APR for the expiring grants are reviewed and submitted, the HMIS team will move all open records (i.e. stayers who do not have an exit date prior to the operating end date of the grant) to the new "Home Project" in the system. The name of the "Home Project" in HMIS will also be updated to match the new consolidated project name. This is so all client data remains intact for length of stay, eligibility, time from start to move-in and other critical data.
- Agencies must notify the HMIS team when each of the APRs for every contract included in the consolidated project is submitted so active enrollments are moved over to the Home Project.