Balance of State Continuum of Care Written Standards Training (Long Version)

1. Balance of State Continuum of Care Written Standards Training(Long Version) • February 4, 2019 Tina Moore, CoC Program Coordinator

2. Goal of Written Standards • Make policy or recommendations for projects to serve people who are homeless with as few barriers as possible; • Projects have made much progress in this area, and the Written Standards are designed to: • continue that progress • be cognizant of the variance of the way projects are set up and what works locally across 152 counties • focus on client needs (rather than limited project design)

3. What are Written Standards? • Continuum of Care (CoC)-Specific Requirements (578.7(a)(9)): • The CoC must establish and follow written standards for recipients and subrecipients providing assistance with CoC Program funds. They must be developed in consultation with the ESG recipient(s) also funding projects within the CoC’s geographic area. • Policies and procedures for: • Evaluating individuals’ and families’ eligibility for assistance through the CoCProgram • Determining and prioritizing eligible individuals and families for Transitional Housing, Rapid Re-Housing, and Permanent Supportive Housing assistance • Determining the percentage and amount of rent program participants must pay while receiving rapid re-housing assistance • BoSCoC Governance Charter requires that we receive provider input and develop these standards for all project types

4. How do Written Standards relate to ESG? • In addition to CoC-funded recipients, Emergency Solutions Grants (ESG) recipients are required to develop similar policies and procedures for subrecipients to use when providing ESG assistance with ESG Program funds (see 24 CFR 576.400(d)). • Ideally, CoC and ESG recipient(s) collaborate to coordinate and/or align to ensure all populations eligible for assistance within the geographic area are assessed and prioritized for available assistance as consistently as possible.

5. ESG Written Standards • The written standards for providing ESG assistance must include policies and procedures that address the following: • Evaluating eligibility for ESG assistance; • Targeting and providing essential services related to street outreach activities; • Admission to, diversion from, referral to, and discharge from emergency shelters; • Assessing, prioritizing, and re-assessing the need for essential services related to street outreach; • Coordination among other emergency shelter, essential service, homelessness prevention, and rapid re-housing providers as well as with other mainstream housing and service providers; • Determining and prioritizing individuals and families for homelessness prevention and rapid re-housing assistance; • Determining the percentage and amount of rental assistance and utilities each program participant must pay while receiving homelessness prevention or rapid re-housing assistance; • Determining the amount and duration of rental assistance, including how the amount will be adjusted over time, as appropriate; and • Determining the type, amount, and duration of housing stabilization and/or relocation services.

6. Which Projects do these CoC Written Standards Impact? • Balance of State CoC-funded projects MUST follow the Balance of State CoC Written Standards • State ESG-funded projects/sub-recipients in the Balance of State MUST follow these Written Standards • For providers in areas where DCA ESG funds are used in conjunction with non-BoSCoC entitlement ESG funds and where written standards may conflict with DCA’s, the DCA minimum standards will take precedence. If the local standards are more stringent, they can be followed • The CoCSTRONGLY ENCOURAGES other projects that do not receive CoC funds to adhere to them as well.

7. Preparation of Written Standards • DCA staff worked with HUD TA Providers to assess alignment with federal requirements and priorities. • DCA staff reviewed the draft written standards with GA Balance of State CoC ESG Entitlements (Clayton County, Gwinnett County, Macon-Bibb County, and the State of Georgia). • In addition to consultation, we’ve worked with the State of Georgia, Clayton County, and Gwinnett County ESG program staff to incorporate HUD’s requirements of ESG recipients into the draft.  • DCA staff reviewed with a sub-committee of the Standards, Rating & Project Selection Committee. • DCA staff reviewed draft with a select group of providers to obtain provider input.

8. CoC Written Standards Approved • May 15, 2017 – Approved by Standards, Rating & Project Selection Committee (moved to Board) • May 24, 2017 – Approved by BoSCoC Board • To be updated annually or as data available (Approved as Updated on 5-23-18) • These standards tie into CE Written Standards • Next Steps: • Went into effect in 2017 (projects should have already updated policies & procedures for projects)

9. General Standards The written standards for providing assistance include policies and procedures that address the following: 1. HMIS Participation 2. Coordinated Entry Process (a/k/a Coordinated Assessment System) 3. Removal of Barriers 4. Termination of Assistance 5. Faith-based Activities 6. Fair Housing and Equal Opportunity 7. Language Access Plan 8. Allowable Family Limitations and Prohibition against Involuntary Family Separation 9. Equal Access Requirements 10. Violence Against Women Act (VAWA) Requirements

10. Street Outreach Projects

11. Street Outreach • Project Definition • HUD Eligibility Requirements (Category 1) • CoC Recommendations (policy on safety standards, engagement during times where reasonable expectation homeless w/no housing options) • Required Documentation of Homelessness • Assessment/Prioritization: • Assessment where they are/will be offered services of engagement, case management, emergency health and mental health, and transportation services (where not available in mainstream), • Must assess, prioritize, and re-assess need for services, and continuously engage even if services declined). • When appropriate based on individual’s needs and wishes, referral to permanent supportive housing or rapid re-housing as a priority over shelter. • Required to utilize Coordinated Entry Prosess as outlined on Coordinated Entry Written Standards.

12. Street Outreach Definition Street outreach projects are those activities that are undertaken to identify potential homeless project recipients for the purpose of providing them with immediate support and intervention activities.

13. Street Outreach • Eligibility • HUD Requirements • Recipients of these services must meet the HUD definition of homelessness under Category 1. These would be unsheltered homeless individuals and families, meaning those with a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings, including a car, park, abandoned building, bus or train station, airport, or camping ground.

14. Street Outreach • Eligibility • CoC Recommendations • Agencies administering Street Outreach Projects must have policies on safety standards and procedures. • Engagement should occur during times when there is a reasonable expectation to believe people have no housing options.

15. Street Outreach • Required Documentation Documentation must be included in the case file, and/or scanned into the HMIS client record that demonstrates eligibility as follows: • Literally Homeless (in order of preference) • Third party verification (HMIS print-out, or written referral/certification by another housing or service provider); or • Written observation by an outreach worker; or • Certification by the individual or head of household seeking assistance stating that (s)he was living on the streets or in shelter; • For individuals exiting an institution – one of the forms of evidence above and; • Discharge paperwork or written/oral referral, or • Written record of intake worker’s due diligence to obtain above evidence andcertification by individual that they exited institution If the provider is using anything other than a. Third Party Verification, the case file must include documentation of due diligence to obtain third party verification.

16. Street Outreach • Assessment/ Prioritization Individuals and families shall be assessed where they are and will be offered the following Street Outreach services, as needed and appropriate: • engagement, case management, emergency health and mental health, and transportation services where they are otherwise not available in the mainstream. • Based on the need of services population: • Street Outreach projects must assess, prioritize, and re-assess the need for essential services related to street outreach, and • Should continuously engage unsheltered persons and persons experiencing chronic homelessness (and most at risk of becoming chronically homeless), even if they repeatedly decline housing and services. • When appropriate/based on individual’s needs and wishes, the referral to permanent supportive housing or rapid re-housing that can quickly assist the individuals to obtain safe, permanent housing shall be prioritized over the provision of or referral to an emergency shelter. • Street Outreach Projects are required to utilize the Coordinated Entry Process as outlined in the Coordinated Entry Written Standards Policies and Procedures, which will provide information on prioritization and reassessment for services.

17. Emergency Shelters

18. Emergency Shelters • Project Definition • HUD Eligibility Requirements (Categories 1, 2, & 4) • CoC Recommendations (expedited admission policies, no initial ID requirement, no fees) • Required Documentation of Homelessness • Assessment/Prioritization (Coordinated Entry, priority for those with no or extremely low income (<30% AMI)

19. Emergency Shelters Definition Any facility or project (including hotel/motel voucher projects) where the primary purpose is to provide a temporary shelter for the homeless in general, or for specific populations of the homeless, which does not require occupants to sign leases or occupancy agreements.

20. Emergency Shelters • Eligibility • HUD Eligibility • Individuals and families entering the shelter system must be homeless per the HUD Homeless Definition, Category 1, literally homeless, Category 2, imminent risk of homelessness, Category 3, homeless under other federal statutes, or Category 4, fleeing or attempting to flee domestic violence (with documentation as detailed elsewhere in this document). • Shelter facilities may accept clients that are not HUD-defined homeless, but they must administratively separate those clients so that ESG funds are not used for non-HUD-defined homeless clients. • CoC Recommendations • Projects should have expedited admission processes, to the greatest extent possible, including providing assistance with obtaining necessary documentation. • Further, shelters should not require, upon admission, that residents have IDs or be entered into HMIS. Projects should also not require any fees.

21. Emergency Shelters • Required Documentation Documentation must be included in the case file, and/or scanned into the HMIS client record that demonstrates eligibility as follows: • Literally Homeless (in order of preference) • Third party verification (HMIS print-out, or written referral/certification by another housing or service provider); or • Written observation by an outreach worker; or • Certification by the individual or head of household seeking assistance stating that (s)he was living on the streets or in shelter; • For individuals exiting an institution – one of the forms of evidence above and; • Discharge paperwork or written/oral referral, or • Written record of intake worker’s due diligence to obtain above evidence and certification by individual that they exited institution If the provider is using anything other than a. Third Party Verification, the case file must include documentation of due diligence to obtain third party verification.

22. Emergency Shelters • Assessment /Prioritization Emergency Shelter projects are required to utilize the Coordinated Entry Process as outlined in the Coordinated Entry Written Standards Policies and Procedures. Domestic violence (DV) projects may utilize the coordinated entry system, but are not required to participate due to issues of confidentiality. Homeless youth (12 – 18 yrs. of age) may still access shelter through a Runaway & Homeless Youth Hot Line. Priority will be given to individuals and families with no income and to those who have extremely low income (30 percent of AMI) as dictated by Area Median Income.

23. Transitional Housing Projects

24. Transitional Housing (TH) • Project Definition • HUD Eligibility Requirements (Categories 1 & 4) • CoC Requirements (priority for those with no or extremely low income (30% AMI), removal of barriers, Entitlement jurisdictions may further restrict funding of TH projects to serve high barrier households and/or special needs populations as they determine) • CoC Recommendations: • Reserve for youth, safety for persons fleeing DV, and recovery projects • Individuals and families entering are not expected to be able to qualify for permanent housing. • Further, enrollment of a chronically homeless person into TH causes them to loose their chronically homeless determination making them ineligible for many programs • Coordination with PH. • Using TH beds as bridge housing where shelter isn’t available if PSH identified (NO enrollment in TH) • Required Documentation of Homelessness • Assessment/Prioritization (Coordinated Entry, priority for those with no or extremely low income (<30% AMI))

25. Transitional Housing (TH) Definition Transitional Housing Projects provide subsidized housing and supportive services, for a period not to exceed 24 months, to facilitate the movement of homeless individuals and families to permanent housing.

26. Transitional Housing (TH) • Eligibility • HUD Eligibility • Individuals and families must be homeless per the HUD Homeless Definition, Category 1, literally homeless or Category 4, fleeing or attempting to flee domestic violence as long as they meet category 1 requirements as well. • CoC Requirements • Priority should be given to individuals and families with no income and to those who have extremely low income (30 percent of AMI) as dictated by Area Median Income. Additional income limits may be set by additional funding sources of the transitional housing project. • The CoC will be assessing project level eligibility criteria in order to identify and remove barriers to accessing services and housing that are experienced by homeless individuals and families. Organizations should be working towards the removal of barriers to project entry, and barriers to remaining in projects, as these barriers both deny housing to individuals and families that really need intensive services and often result in low occupancy rates. Organizations may need to change their project design in order to address this. Entitlement jurisdictions within the CoC may further restrict funding of TH projects to require (and only fund) TH projects that serve high barrier households and/or special needs populations as they determine.

27. Transitional Housing (TH) • Eligibility • CoCRecommendations • While permanent housing is preferred, research does show that transitional housing may be an effective tool for addressing certain needs, such as housing for underage homeless youth experiencing homelessness, safety for persons fleeing domestic violence, and assisting with recovery from addiction. • Homeless individuals and families entering into TH are not expected to be able to qualify for permanent housing. Further, the enrollment of a chronically homeless client into a TH program causes that client to lose their chronically homeless determination making them ineligible for many programs. In cases where households become eligible for permanent housing, it is expected that TH providers will coordinate with organizations that administer these projects in their area. The provision of supportive services and case management are required to be available in transitional housing projects. Participants cannot be charged more than 30 percent of the total household income as rent. • In order to lower barriers to entry, reduce lengths of stay, and improve exits to permanent housing, the CoC supports the utilization of transitional housing beds as bridge housing for people who are homeless, where shelter beds are not available and permanent housing has been identified. It should be established at entry that they are chronically homeless and waiting to move into PSH, and the client should not be enrolled into the transitional housing project or be expected to follow service plans associated with the transitional housing project. Please note that there should be a reasonable expectation that the household will move into permanent housing within 30 to 90 days.

28. Transitional Housing (TH) • Required Documentation Documentation must be included in the case file, and/or scanned into the HMIS client record that demonstrates eligibility as follows: • Literally Homeless (in order of preference) • Third party verification (HMIS print-out, or written referral/certification by another housing or service provider); or • Written observation by an outreach worker; or • Certification by the individual or head of household seeking assistance stating that (s)he was living on the streets or in shelter; • For individuals exiting an institution – one of the forms of evidence above and; • Discharge paperwork or written/oral referral, or • Written record of intake worker’s due diligence to obtain above evidence and certification by individual that they exited institution • If the provider is using anything other than a. Third Party Verification, the case file must include documentation of due diligence to obtain third party verification

29. Transitional Housing (TH) • Assessment/ Prioritization Transitional housing projects are required to utilize the Coordinated Entry Process as outlined in the Coordinated Entry Written Standards Policies and Procedures. Participants may be referred from a broad range of social services including shelter and street outreach. Priority will be given to individuals and families with no income and to those who have extremely low income (30 percent of AMI) as dictated by current HUD limits. Additional income limits may be set by additional funding sources of the transitional housing project.

30. Rapid Re-Housing Projects (RRH)

31. Rapid Re-Housing Projects (RRH) • Project Definition • HUD Eligibility Requirements (Categories 1 & 4, ESG requires at or <50% AMI)) • CoCRequirements (removal of barriers, accept those with no income, case management and related services to be offered but not required for all receiving rental assistance and to those not receiving rental assistance at agency discretion) • CoC Recommendations (general limitations on time and amount of rental subsidy and documentation requirements) • RRH Client Contribution Policy as Required by HUD-declining subsidy goal • Rent Determination Procedures (Monthly subsidy amount evaluations, agency discretion on what client can contribute) • Required Documentation of Homelessness (and Income for ESG RRH) • Assessment/Prioritization (Coordinated Entry, priority for those with extremely low income (<30% AMI) and those with longer lengths of stay) • ESG RRH Requirements (monthly utility assistance determinations, agency discretion in determining what a family can contribute and what housing stabilization and/or relocation services financial assistance can be offered)

32. Rapid Re-Housing (RRH) Definition Rapid Re-Housing Projects (RRH) provide housing relocation and stabilization services and time limited rental assistance (short or medium term rental assistance) and supportive services to help homeless individuals or families move as quickly as possible to permanent housing and achieve stability in that housing.

33. Rapid Re-Housing (RRH) • Eligibility • HUD Eligibility* • Individuals and families must meet the Category 1 definition of homelessness (Literally Homeless). In addition, those who meet the Category 4 definition of homelessness (Fleeing/Attempting to Flee DV) may also qualify if the individual or family is literally homeless. *Please note that an additional eligibility requirement of ESG RRH is that individuals and families must have an annual income at or below 50% AMI. • CoC Requirements • The CoC will be assessing project level eligibility criteria in order to identify and remove barriers to accessing services and housing that are experienced by homeless individuals and families. Organizations should be working towards the removal of barriers to project entry, and barriers to remaining in projects, as these barriers both deny housing to individuals and families that really need intensive services and often result in low occupancy rates. Organizations may need to change their project design in order to address this. • Given that projects should be prioritizing employment assistance and increasing benefits as part of the case management plan, projects should be open to accepting people without current income. Agencies must offer case management and supportive services to all participants receiving rental assistance that are designed to lead them towards long-term stable housing. Case management and related services may be offered to clients not receiving rental assistance at the agency’s discretion.

34. Rapid Re-Housing (RRH) • CoC Recommendations • Agencies should have a goal of providing a 100% subsidy to participating households for no more than six months and to provide any amount of rental subsidy for no longer than twelve months total. • Assistance for households with no income or special circumstances could be extended to 18 months. An explanation of these special circumstances along with an evaluation of household needs must be documented in the client file.

35. Rapid Re-Housing (RRH) • Rapid Re-Housing Client Contribution Policy • It is the policy of Rapid Re-Housing (RRH) Projects to provide a declining rental assistance subsidy to households participating in the RRH Projects. For households with income, a percentage or amount of client contribution can be based on a reasonable percentage of a household’s income. • Rent Determination Procedures • Households will receive a declining subsidy for the duration of their participation in the project based on their ability to contribute to their rent. • Rental subsidy determinations will be evaluated no less than monthly in case management meetings. Case managers will review household budget and determine what, if any, amount of rent the household is responsible for contributing based upon the household’s needs and circumstances. The case manager will document the outcome of the subsidy determination in the client file. • There are many ways to determine the percentage or amount of rent, utilities, and additional financial assistance a household can contribute. Individual projects have discretion in determining how the subsidy will be reduced based on income, the needs of the household, and what is in the best interest of the household’s housing stability.

36. Rapid Re-Housing (RRH) • Required Documentation • Documentation must be included in the case file, and/or scanned into the HMIS client record that demonstrates eligibility as follows: • Literally Homeless (in order of preference) • Third party verification (HMIS print-out, or written referral/certification by another housing or service provider); or • Written observation by an outreach worker; or • Certification by the individual or head of household seeking assistance stating that (s)he was living on the streets or in shelter; • For individuals exiting an institution – one of the forms of evidence above and; • Discharge paperwork or written/oral referral, or • Written record of intake worker’s due diligence to obtain above evidence and certification by individual that they exited institution • If the provider is using anything other than a. Third Party Verification, the case file must include documentation of due diligence to obtain third party verification.

37. Rapid Re-Housing (RRH) • Assessment/Prioritization • Individuals or families may be referred from a broad range of social services including shelter and street outreach, but must follow the Balance of State CoC policy for the Coordinated Entry Process as outlined in the Coordinated Entry Written Standards Policies and Procedures. Priority shall be given to extremely low-income individuals and families (at or below 30 percent AMI) and to individuals and families that have longer length of stay in shelters or on the streets.

38. Homeless Prevention Projects

39. Homeless Prevention • Project Definition • HUD Eligibility Requirements (Categories 2 & 4 or meet “at risk” definition, income <30% AMI), no other resources or support network to prevent moving to shelter) • CoCRequirements (removal of barriers to project entry and barriers to remain in project) • CoC Recommendations (participants should receive case management plan, best practice agencies with ability to negotiate with landlords as first step and plan for participants to increase income, length of stay based on needs, goal of 100% subsidy no longer than 6 months, total assistance goal to be no longer than 12 months), with extensions up to 18 months for households with no income or special circumstances with evaluation of circumstances documented in file) • Prevention Client Contribution Policy (policy to provide declining rental assistance with reasonable percentage of contribution based on household’s income

40. Homeless Prevention (cont’d.) • Rent Determination Procedures (households will receive declining subsidy based on their ability to pay rent, subsidy determinations evaluated no less than monthly in case management meetings, flexibility in determining percentage and how subsidy will be reduced based on income, needs of household, and best interest of the household’s housing stability) • Required Documentation (lease in participant’s name, documentation of pending loss of housing can include eviction notice (or equivalent as allowed by law), a Notice to Quit, or Notice to Terminate issued under state law) • Assessment/Prioritization (Utilize Coordinated Entry Process as outlined in Coordinated Entry Written Standards) • ESG RRH Requirements (Monthly Utility assistance determinations, agency discretion in determining what a family can contribute and what Housing Stabilization and/or Relocation Services financial assistance can be offered)

41. Homeless Prevention • Definition • Homeless Prevention Projects provide assistance to individuals or families who are at the greatest risk of losing housing due to a legal eviction action that requires the individual or family to leave their residence no later than 14 days following the date of their application for homeless assistance.

42. Homeless Prevention • Eligibility • HUD Eligibility • Households receiving this funding must have an income level below 30% AMI and must demonstrate that they do not have sufficient resources or support networks to prevent them from moving to an emergency shelter or other place defined under Category 1 of the homeless definition. Recipients may be in categories 2-4 under the homeless definition or meet the “at risk” definition in order to qualify for this assistance. • CoC Requirements • The CoC will be assessing project level eligibility criteria in order to identify and remove barriers to accessing services and housing that are experienced by homeless individuals and families. Organizations should be working towards the removal of barriers to project entry, and barriers to remaining in projects, as these barriers both deny housing to individuals and families that really need intensive services and often result in low occupancy rates. Organizations may need to change their project design in order to address this.

43. Homeless Prevention • Eligibility • CoCRecommendations • Project participants receiving this assistance should receive a case management plan from the provider in order to ensure long term stability. Best practice agencies will be ones with the ability to negotiate with landlords as the first step in resolving eviction crises and that also demonstrate a plan to effectively increase household incomes for project participants. The length of stay should be based on the needs of individual households participating in the project. • Agencies should have a goal of providing a 100% subsidy to participating households for no more than six months and to provide any amount of rental subsidy for no longer than twelve months total. • Assistance for households with no income or special circumstances could be extended to 18 months. An explanation of these special circumstances along with an evaluation of household needs must be documented in the client file.

44. Homeless Prevention • Prevention Client Contribution Policy • It is the policy of Prevention Projects to provide a declining rental assistance subsidy to households participating in the Prevention Projects. For households with income, a percentage or amount of client contribution can be based on a reasonable percentage of a household’s income. • Rent Determination Procedures • Households will receive a declining subsidy for the duration of their participation in the project based on their ability to contribute to their rent. • Rental subsidy determinations will be evaluated no less than monthly in case management meetings. Case managers will review household budget and determine what, if any, amount of rent the household is responsible for contributing based upon the household’s needs and circumstances. The case manager will document the outcome of the subsidy determination in the client file. • There are many ways to determine the percentage or amount of rent, utilities, and additional financial assistance a household can contribute. Individual projects have discretion in determining how the subsidy will be reduced based on income, the needs of the household, and what is in the best interest of the household’s housing stability.

45. Homeless Prevention • Utilities (ESG) • Households will receive a declining subsidy for the duration of their participation in the project based on their ability to contribute to their utilities. • Utilities subsidy determinations will be evaluated no less than monthly in case management meetings. Case managers will review household budget and determine what, if any, amount of rent the household is responsible for contributing based upon the household’s needs and circumstances. The case manager will document the outcome of the subsidy determination in the client file. • There are many ways to determine the percentage or amount of rent, utilities, and additional financial assistance a household can contribute. Individual projects have discretion in determining how the subsidy will be reduced based on income, the needs of the household, and what is in the best interest of the household’s housing stability. • Housing Stabilization and/or Relocation Services (ESG) • The type, amount, and duration of financial assistance for housing stabilization and/or relocation services will be determined based on the needs of the household. The need for this assistance will be evaluated and documented in the client file.

46. Homeless Prevention • Required Documentation • Households receiving Homeless Prevention assistance must have a lease in the participant’s name. Documentation of the pending loss of housing can include an eviction notice, the equivalent notice under applicable state law, a Notice to Quit, or a Notice to Terminate issued under state law. • Assessment/ Prioritization • All homeless prevention projects are required to utilize the Coordinated Entry Process as outlined in the Coordinated Entry Written Standards Policies and Procedures.

47. Supportive Services Only Projects

48. Supportive Services Only • Project Definition • HUD Eligibility Requirements (Categories 1 & 4) • CoC Requirements (removal of barriers) • CoC Recommendations (expectation of projects to connect participants to permanent housing) • Required Documentation of Homelessness • Assessment/Prioritization (utilize Coordinated Entry Process as outlined on Coordinated Entry Written Standards)

49. Supportive Services Only • Definition • Supportive Services Only (SSO) projects provide services to sheltered and unsheltered homeless persons to whom the provider is not providing housing or housing assistance.

50. Supportive Services Only • Eligibility • HUD Eligibility • Participants must meet the HUD definition of homelessness under Category 1 (Literally Homeless) or they may fall under Category 4 (Fleeing/Attempting to Flee DV) if they also meet the definition in Category 1. • CoC Requirements • The CoC will be assessing project level eligibility criteria in order to identify and remove barriers to accessing services and housing that are experienced by homeless individuals and families. Organizations should be working towards the removal of barriers to project entry, and barriers to remaining in projects, as these barriers both deny housing to individuals and families that really need intensive services and often result in low occupancy rates. Organizations may need to change their project design in order to address this. • CoC Recommendations • SSO projects are expected to work with participants in order to connect them to permanent housing.