Treasure Coast Homeless Services Council CoC FL 509 Continuum of Care GOVERNANCE & GUIDELINES

TREASURE COAST HOMELESS SERVICES COUNCIL, INC. 2525 St. Lucie Avenue Vero Beach, FL 32960 irhsclh@aol.com www.tchelpspot.org 772-567-7790 Treasure Coast Homeless Services Council CoC FL 509 Continuum of Care GOVERNANCE & GUIDELINES Approved by the Board of Directors April 9, 2014 1

Contents I. CoC Governance... 4 A. Geographic Area of the Continuum of Care... 4 B. Purpose... 4 C. Mission... 4 D. Continuum of Care General Membership... 5 E. Continuum of Care Charter... 5 F. Board Composition... 5 G. Board Selection... 7 H. Minimum Requirements of Board Members... 7 I. Board Terms... 7 J. Board Leadership... 7 K. Conflict of Interest and Recusal... 8 L. Meetings... 8 M. Committees... 9 N. Selection of the Collaborative Applicant... 10 O. Selection of the HMIS Lead Agency... 10 P. Continuum of Care Policies and Procedures... 10 II. CoC Program Grants... 11 A. Collaborative Applicant... 11 B. Grant Inventory Worksheet... 11 C. Project Evaluation, Monitoring and Performance Reporting... 11 D. Quarterly Continuum of Care Annual Performance Reports... 11 E. Monthly Program Evaluation Policy... 12 F. Annual Performance Reports (APR)... 12 G. APR Approval Procedures... 13 H. Actions against Poor Performance... 13 I. Application for CoC Program Grant Funds... 14 J. Reallocation Process... 14 K. Ranking and Review of Project Applications... 15 L. Conflicts of Interest... 17 III. CoC Program Regulations... 18 A. Nondiscrimination and Equal Opportunities... 18

B. Housing First... 19 C. Coordinated Entry Participation... 19 D. Prioritization of Chronically Homeless and Other Vulnerable Homeless Persons... 20 E. Recordkeeping Requirements... 21 IV. CoC Coordinated Entry System... 22 A. Overview... 22 B. Nondiscrimination and Equal Opportunity... 23 C. Reasonable Accomodations... 24 D. Privacy Protections & Participant Autonomy... 24 E. Assessment... 25 F. Rapid Rehousing Services... 26 G. Homeless Prevention Services... 27 H. Supportive Services for Veteran Families (SSVF)... 27 I. Street Outreach... 27 J. Housing Specialists... 27 K. By-Name List (BNL) Committee... 28 L. Assessor Training... 29 M. Training Protocols... 29 N. Ongoing Planning and Stakeholder Consultation... 30 O. Appeal Process... 30 3 P a g e

I. CoC Governance A. Geographic Area of the Continuum of Care The geographic area of the Treasure Coast Homeless Services Council Continuum of Care FL 509 named Ft. Pierce/St. Lucie, Indian River, Martin Counties CoC is Indian River, St. Lucie, Martin Counties, FL. Including the Cities of Ft. Pierce, and Port St. Lucie. B. Purpose The CoC Board shall develop policies and procedures conforming to the U.S. Department of Housing and Urban Development (HUD) requirements detailed in 24 CFR part 578.1 to: a. Designate a CoC Lead Agency to serve as the Collaborative Applicant to operate the Continuum of Care; b. Designate an Administrator of the Homeless Management Information System; c. Conduct year round Continuum of Care planning of homeless and homeless prevention housing and services. C. Mission The mission of the continuum of care is to end and prevent homelessness by empowering, leading and supporting people who are homeless or at risk of homelessness, local homeless services providers and any other interested individuals and groups to accomplish our mission through the conduct of a duly constituted and recognized Continuum of Care. 4 P a g e

D. Continuum of Care General Membership Applications for Continuum of Care Membership is available on the Agency website. The CoC Meetings will be open to the public and any new organization can present their program during Clearinghouse at every meeting. Members in good standing will have attended at least four Continuum of Care meetings a year as documented through sign in or registration. The calendar year for the Continuum of Care General Membership will be January through December. The Collaborative Applicant shall be responsible for conducting an annual meeting of the CoC General Membership with a published agenda that focuses exclusively on reviewing the Continuum of Care s business, structure, progress and operations. Results of this annual meeting will be reported to the CoC Board of Directors. E. Continuum of Care Charter The Continuum of Care shall elect a Board of Directors, governed by Charter. The Charter shall provide procedures for: d. Invitation, selection, term and conduct of Continuum of Care Board membership and leadership e. Establishment of committees and the appointment and duties of members f. Board meeting frequency, reporting and public participation requirements The Continuum of Care Charter will be reviewed by the board at least once every five years. The Charter can be amended by a vote of 75% of the then sitting CoC Board. F. Board Composition The CoC Board shall include community representatives within the geographic area of the Continuum of Care who are: a. Homeless or formerly homeless individual(s). i. Representatives of the relevant organizations and projects serving homeless subpopulations such as: ii. Persons with substance use disorders iii. Persons with HIV/AIDS 5 P a g e

iv. Veterans v. Persons who are chronically homeless vi. Families with children vii. Unaccompanied youth viii. Persons who are seriously mentally ill ix. Persons who are victims of domestic violence, dating violence, sexual assault, and/or stalking. b. Appointed representatives from local government entities: i. Indian River County ii. St. Lucie County iii. Martin County iv. City of Port St. Lucie v. City of Ft. Pierce Other governmental entities may request of the CoC Board the right to appoint a member. c. Individual and Organizational members that advocate for and provide outreach, prevention, shelter, transitional housing, rapid rehousing and permanent supportive housing for people who are homeless or at risk of homelessness, such as: i. Faith based organizations ii. Business iii. Public Housing Agencies iv. School districts v. Mental health care providers vi. Health care providers vii. Universities viii. Affordable Housing Developers ix. Foundations x. Law Enforcement d. Representative of the Continuum of Care Collaborative Applicant as an ex officio member. 6 P a g e

G. Board Selection Other than those members that are appointed by the governmental entities as set forth above, there will be an annual call for nominations from the public to fill any vacancies then existing on the board. The existing CoC Board will elect new members to fill such vacancies by majority vote. The CoC Board will be comprised of at least nine (9) and no more than twenty- four 24 voting members. Vacancies may be filled immediately or through the annual nominating process. H. Minimum Requirements of Board Members CoC Board members will demonstrate a commitment to the goals and objectives of the Continuum of Care Strategic Plan and shall attend no less than 70% of called CoC Board meetings as evidenced by signature on the CoC Meeting Sign-In Sheet. CoC Board members are also required to reside within the geographic area of the CoC. I. Board Terms Other than those members that are appointed by the governmental entities, membership on the board is limited to two (2) three year terms. The board terms shall be staggered so as to insure continuity of the board. Members serving a complete six year term are not eligible for re appointment. After the passage of one year from the expiration of their term such individual can be considered for re election to the board. J. Board Leadership The President shall be the principal Executive Officer of the Board and shall coordinate and facilitate all business and affairs of the Council in collaboration with the Executive Committee. The Executive Vice President shall, in the absence of the President or in the event of the President inability to act, perform the duties as the President. The Treasurer shall perform all duties incident to the office of Treasurer and other duties as may be assigned by the President. Officers will serve one year terms. The CoC Board shall appoint a Secretary whose responsibilities will include ensuring minutes of all meeting are taken. Minutes shall be 7 P a g e

maintained for public review upon request. The Secretary shall maintain the CoC Board roster and attendance records. K. Conflict of Interest and Recusal Continuum of Care Board members with actual or perceived conflicts of interest must identify them as they arise. Individuals with a conflict of interest may participate in all discussion but shall recuse themselves from voting on any issue in which they may have a conflict. No member of the CoC Board shall vote upon any matter which shall have a direct financial bearing on the organization that the member represents or sits as a board member on the organization. This includes all decisions with respect to funding, awarding contracts, and implementing corrective actions as a result from CoC Collaborative Applicant monitoring activities of CoC and ESG activities. L. Meetings The Continuum of Care Board of Directors shall conduct at least six public meetings per year; a majority of the CoC Board membership shall constitute a quorum for the transaction of business. It will be the responsibility of the appointed Collaborative Applicant to provide prior reasonable notice and a published agenda of all CoC Board meetings and such notices shall be published on the CoC Collaborative Applicant website. Each public meeting shall have on its agenda the opportunity for members of the public to provide comment. The CoC Board will review and approve the minutes and consider recommendations from Clearinghouse and subsequent committees during its Board proceedings. The CoC will hold an annual meeting of the CoC Board, with a published agenda, on the Collaborative Applicant website, that shall focus exclusively on reviewing and updating the CoC s system performance, business, structure, data quality and operations. Results of this annual meeting will be communicated to the CoC General Membership by the Collaborative Applicant and reporting will be made available on the website, in public media and to partner member agencies for their use in public relations, 8 P a g e

planning, grant solicitations, services reporting and other general public and private communications. M. Committees The Continuum of Care Board may create and dissolve any standing committees as determined appropriate and necessary by the Board of Directors for purposes of managing internal affairs and addressing external issues. Either the Board or Executive Committee may create and dissolve ad-hoc committees as necessary. Each committee should have at least one (1) currently or recently homeless individual as a member of advisor. The following committees are currently utilized by the CoC: e. HMIS Committee The HMIS Committee was developed to train and monitor compliance with HMIS data standards and coordinated intake and assessment tools in the HMIS system. The committee will be represented by HMIS end users and HMIS administrator staff. f. Shelter Committee The Shelter Committee was developed to provide planning, capacity building and monitoring of shelter projects in the CoC. This committee will be represented by shelter providers, school liaisons, police, homeless individuals, private philanthropy and lead agency staff. g. Veteran Committee The Veteran committee was developed to develop policy and programs to end veteran homelessness. This committee will be represented by SSVF grantees, VASH Case Managers, homeless or formally homeless veterans, Local Veteran Service Officers, Public Housing Authorities (VASH Administrators) and private non-profit agencies. h. PSH Committee The PSH Committee was developed to provide planning, evaluating, and monitoring of participants in the CoC funded PSH beds. Utilizing coordinated intake and assessment tools in HMIS to serve clients when beds become available and to prioritize the most vulnerable service needs, this committee will be represented by homeless or formally homeless individuals, local governments, grantee representatives, clinical staff, PATH outreach workers, and lead agency staff. 9 P a g e

N. Selection of the Collaborative Applicant The Continuum of Care Board of Directors has selected Treasure Coast Homeless Services Council, Inc. as the Lead Agency and Collaborative Applicant. O. Selection of the HMIS Lead Agency The Continuum of Care Board of Directors has selected Treasure Coast Homeless Services Council, Inc. as the HMIS Lead Agency. Terms and provisions of The Treasure Coast Homeless Services Council, Inc. serving as the HMIS lead agency are hereby referenced and incorporated in this governance documents by reference: Lead Agency Treasure Coast Homeless Services Council, Continuum of Care, HOMELESS MANAGEMENT INFORMATION SYSTEM, (HMIS) POLICIES AND PROCEDURES, For Indian River, St. Lucie and Martin County, Florida. P. Continuum of Care Policies and Procedures The Continuum of Care Board is responsible for setting the policies and procedures for the governance, operations, written standards for assistance and coordination of the Continuum of Care. Policies and Procedures will be approved by the CoC Board by majority vote. The CoC Board will review written standards on an annual basis, considering: a. Provider feedback on the current written standards b. Program participant feedback on the intake process c. The effectiveness and appropriateness of housing and services for current program participants d. The CoC s success at meeting the performance standards in Section 427 of McKinney Vento Act e. Changes in the characteristics of the homeless population within the CoC f. Changes in the housing and service resources available 10 P a g e

II. CoC Program Grants A. Collaborative Applicant The Continuum of Care Board of Directors has selected Treasure Coast Homeless Services Council, Inc. as the Lead Agency and Collaborative Applicant. B. Grant Inventory Worksheet In consultation with each of the CoC s Program project applicants and the local HUD Community Planning and Development field office, the Collaborative Applicant is responsible to assure the timely submission and accuracy of the Grant Inventory Worksheet (GIW). The GIW is used to calculate the CoC s Annual Renewal Demand for funding to be considered for the annual CoC Program Grant Competition. C. Project Evaluation, Monitoring and Performance Reporting The Collaborative Applicant will utilize its Continuum of Care Planning Grant to provide program monitoring, evaluation and reporting of programs funded under the CoC Program Grant. The Collaborative Applicant will maintain and review HMIS, Annual Performance Reports, PIT, HIC, System Performance Reports and other documentation, as necessary, to measure the Continuum of Care s progress in meeting HUD CoC Program Grant goals and objectives. The Continuum of Care Board of Directors may establish additional performance measurement requirements as necessary to report progress on local goals and objectives. Collaborative Applicant staff will communicate with CoC Program Recipient Agencies throughout each program year to ensure that they are aware of expected performance measures required by HUD and the Continuum of Care Board of Directors. D. Quarterly Continuum of Care Annual Performance Reports The Collaborative Applicant will provide the CoC Membership with quarterly reporting of aggregate performance of all CoC Program Grant Projects through a quarterly Annual Performance Report to measure progress in the annual performance goals established in the Continuum of Care Program Grant. 11 P a g e

Quarterly reports will be presented to HUD and the CoC Membership and will include: (1) occupancy rates measured in the HUD Housing Inventory Chart, (2) Annual Performance Report (APR) (3) System Performance Reports and (4) quarterly occupancy rates measured in the Annual Homeless Assessment Report (AHAR): E. Monthly Program Evaluation Policy The Collaborative Applicant will provide monthly project evaluations of CoC Program projects to measure individual Recipient Agency progress in achieving project goals established in the CoC Program Application and the Recipient Agency Project. This evaluation assistance will be performed after six months of a program year for all program grants including one year renewals or multi year projects. i. Collaborative Applicant will contact agency monthly to determine HMIS data is correct. ii. The Collaborative Applicant will conduct monthly reviews of Annual Performance Report from the HMIS system, inclusive of program data and communicate quality performance issues to executive staff of participating programs and Shelter Plus Care Committee on a monthly basis. iii. The Collaborative Applicant will conducts monthly reviews of spending balances and draw down of funds, in accordance with the grant budget. iv. The Collaborative Applicant will maintain records of all program monitoring, evaluation and technical assistance for recipients and sub recipients and will maintain copies of all reports and correspondence in the official CoC project files. F. Annual Performance Reports (APR) The Collaborative Applicant will work with each CoC Recipient in the preparation of their Annual Performance Report. Final APRs will be reviewed and approved by the Collaborative Applicant prior to submission in the HUD electronic reporting system esnaps in order to confirm that data being reported to HUD is consistent with data reported in the local HMIS system. Annual Performance Reports will be utilized to measure performance of each PSH project. APR measures including, but not limited to: (1) Employment and nonemployment income of stayers (2) Employment and non-employment income of leavers 12 P a g e

(2) Housing destination of Leavers and (3) Any other outcomes related to CoC-wide achievements in meeting HUD Goals and Objectives. G. APR Approval Procedures The Collaborative Applicant will contact the CoC Program Recipient Agency within one week of the expiration of each program year to initiate an APR data review and confirm APR due date. At initial APR data review, the Collaborative Applicant will provide a first draft APR to agency staff through the HMIS System and will include a report of any findings to be adjusted by agency staff. Examples of findings include missing data or data not consistent with agency targets as outlined in the program s original agency Continuum of Care Program application. The Collaborative Applicant will consult with Recipient Agency to determine a planned submission date of the APR to SAGE which will be set prior to the HUD submission deadline. This planned submission date will take into consideration time allotted for any corrections that need to be made to HMIS data prior to submission in SAGE. The Collaborative Applicant will conduct a final data review no later than the first week of the month of the HUD submission deadline to ensure that any necessary findings were corrected in HMIS and will send a final HMIS APR version to agency staff to be used for SAGE APR Upload. The Recipient Agency will complete their APR in SAGE and will send a final version of the generated APR to the Collaborative Applicant for the official CoC Planning files. The APR will be utilized to provide performance measurements, which will be utilized to rank projects for the CoC competition. H. Actions against Poor Performance CoC Program recipients who do not meet local and/or HUD performance targets and/or do not meet expectations and compliance of program and grant management of their CoC programs, as documented in the Program Projects Score Card or monitoring and evaluation reports, may be subject to having their projects reduced in whole or in part and reallocated to other projects during the Projects Review process conducted at the full CoC membership meeting as part of the local competition renewal process as allowed in a HUD Notice of Funding Availability. 13 P a g e

I. Application for CoC Program Grant Funds Upon HUD issuance of the CoC Program Grant Notice of Funding Availability, the Collaborative Applicant will prepare a master timeline of the CoC Program Grant process and will conduct the following steps to assure a well communicated process for organizations to make application for CoC Program Funds to include, but not limited to: a. Establish all application, review and announcement deadlines sufficient to achieve reasonable public participation in the grant process and allow for timely submission to HUD b. Issue the local request for proposals for CoC Program Funds c. Publicize the request for proposal announcement through the Collaborative Applicant website. d. Conduct training and information sessions, as needed, regarding the CoC Program Grant Application process in advance of deadlines e. Assist project applicants in the submission of applications to the Collaborative Applicant in Esnaps. f. Provide all Ranking and Review Committee decisions to Project Applicants, providing for ample time for any appeal. J. Reallocation Process As part of the annual Continuum of Care (CoC) competition, CoC s have the opportunity to reallocate funds from existing projects to create new projects that better meet the needs of the community. Treasure Coast Homeless Services Council Continuum of Care will reallocate HUD CoC program funds as needed, in accordance with the CoC's strategic plan, to improve CoC system-wide performance, to serve the most vulnerable clients, reduce homelessness and promote housing stability. Funds can be reallocated on a voluntary or involuntary basis in accordance with the criteria below. a. Voluntary Reallocation: Any current CoC grantee can voluntarily reallocate its existing project by reducing the project's annual renewal demand either in whole or in part. Any grantee wishing to reallocate funds must notify Treasure Coast Homeless Services Council within the timeline outlined in that year's competition 14 P a g e

process. Upon notification of the intent to reallocate, TCHSC will notify the community that new funding is available, specifying the amount available and type of projects that can be considered. b. Involuntary Reallocation: The CoC has set a threshold score of 85% for acceptance in the CoC competition during the ranking and review process. If a project is identified as being low performing by scoring poorly during the CoC ranking and review process, has unsatisfactory project performance measures, does not align with CoC priorities, and/or has a pattern of under expenditures, the Collaborative Applicant will contact the Project Applicant to discuss voluntary reallocation. If the Project Applicant does not wish to voluntarily reallocate, the committee or CoC Board may vote to reallocate the project completely or provide the Project Applicant with a project improvement plan. If the project applicant has not made significant changes to improve its performance or meet set targets in the agreed upon timeframe, the CoC reserves the right to reallocate funding, either in whole or in part, and make it available through a competitive process in the next CoC Competition. All funding made available through either voluntary or involuntary reallocation will be awarded via a competitive application process. Providers wishing to apply for funds made available through reallocation must submit a new project application and supporting materials in accordance with the CoC Competition instructions. New funding requests will be considered by the Ranking and Review Committee during the annual competition and will be ranked as part of the CoC prioritization process. K. Ranking and Review of Project Applications The Continuum of Care Ranking and Review Committee shall conduct a Projects Review Process to prepare the project ranking and funding priority decisions for the Continuum of Care Program local competition. 15 P a g e

The Ranking and Review Committee will review information about each project to take into account the vulnerability of the clients being served, as described by supportive services providers in the system. Vulnerability includes but is not limited to: chronic status, income of the clients being served, potential exploitation of the clients being served, mental health and health status including substance abuse history of the clients being served and special priorities set by HUD or the CoC. The Ranking and Review Committee will utilize appropriate data to score each project based on outcomes. The Projects Score Card will utilize data from the APR, Systems Performance Report, Coordinated Entry System Enrollments, HMIS, HIC and the Project Application. Grantee Name: Project Name/Number: PROJECTS SCORE CARD Returns to Homelessness %Individuals exiting to homelessness or other APR Q36.a.1. % Exit to PH but return to homelessness within 2 Systems Performance Serving Population with the Most Vulnerability % Entries from CE System CE System % Entries as chronically homeless HMIS Income Growth % Increased Total Income (leavers and stayers) Systems Performance %Increased Earned Income ( leavers and stayers) Systems Performance Exits to PH/Housing Stability % Maintained or Exit to Permanent Housing APR Q36.a.1 Program Model Issues Occupancy HIC Cost per PH Stay Program Budget /Clients Data Quality HMIS Housing First Model Other Scoring Criteria for Potential Domestic Violence Projects Since Domestic Violence Projects are exempted from entering client level data into the HMIS system, the ranking and review committee will not utilize the data elements identified in the Projects score card above. Projects submitted by the Domestic Violence Service provider will be evaluated for its potential to meet the current level of identified need within the Continuum of Care for 16 P a g e

the specific type of service identified in the potential project, as determined by key variables, including but not limited to the following: 1. The number of individuals and/or families who attributed their homeless status on the night of the PIT count to domestic violence. (increase, decrease) 2. The number of individuals and or families who self-identified or were referred for assistance to the Homeless Resource Center or other hub facilities of the Continuum of Care during the same reporting time as systems performance report. (increase, decrease) 3. The potential for the proposed project to address or eliminate victimization, vulnerability to further victimization, potential exploitation or coercion to engage in risky behaviors.(safety planning, housing supports, supports for children of victims including educational needs) 4. Adherence to the CoC program model including Housing First wherever possible including: Linkages to support services Occupancy Rates Cost per LOS Compliance with CoC Regulations Nondiscrimination policies Income Growth Fair Housing Practices Systems Performance Bed Utilization Budget Governance Governance Employment/ Entitlement Performance Governance The Ranking and Review Committee will prepare the project ranking. This ranking order will be presented to all Project Applicants with the process to Appeal. The ranking will be posted on the Agency Website, along with the appeal process. If the Collaborative Applicant receives an appeal by the deadline, the full CoC Membership will be polled for a final vote. The full CoC membership vote will be the final determination for the selection of projects, priorities and funding levels. L. Conflicts of Interest The Ranking and Review Committee may not be employees, contractors, or serve in any representative capacity of an applicant or a sub recipient agency. 17 P a g e

III. CoC Program Regulations A. Nondiscrimination and Equal Opportunities Treasure Coast Homeless Council CoC requires service providers to practice a personcentered model that incorporates participant choice and inclusion of all homeless subpopulations present in the CoC, including homeless veterans, youth, and families with children, individual adults, seniors, victims of domestic violence, and Lesbian, Gay, Bisexual, Transgender, Queer or Questioning, and Intersex (LGBTQI) individuals and families. All CoC service providers must ensure that all people have fair and equal access to the coordinated entry process and all forms of assistance regardless of race, ethnicity, national origin, age, sex, familial status, religious preference, disability, type or amount of disability, gender identity, perceived gender identity, marital status, sexual orientation, or perceived sexual orientation. All providers of housing or services in the CoC are expected to develop and operate under an agency or program culture which promotes respect for diversity and inclusion. This expectation of an inclusive philosophy and culture extends to all staff and management at every level of program and administration. Programs in the CoC providing emergency shelter, transitional housing or other direct services are encouraged to provide welcoming environment and respectful interaction which enforces the CoC policy of non-harassment and antidiscrimination in all programs. All programs in the CoC are expected to require all staff and personnel to improve their ability to understand the perspectives of LGBTQ people and communicate effectively with them, including LGBTQ and RHY youth. CoC program staff should work operate under the same agency or program culture which promotes respect for diversity. This includes efforts to identify and address youth with the name or gender pronouns they prefer and to link youth to appropriate services and sources of social support especially those organizations which are competent in providing services, health care and employment assistance to LGBTQ youth. Wherever feasible, agencies should 18 P a g e

also cultivate partnerships and access training and services offered by programs with expertise and cultural competency in serving LGBTQ youth. B. Housing First Treasure Coast Homeless Services Continuum of Care has adopted the Housing First Model. Housing First is a programmatic and systems approach that centers on providing people who are homeless with housing quickly and then providing services as needed. Housing is not contingent on compliance with services. Supportive services are voluntary, but can and should be used to persistently engage participants to ensure housing stability. Participants are expected to comply with a standard lease agreement and are provided with services and supports to help maintain housing and prevent eviction. Services are provided post-housing to promote housing stability and well-being. All programs are expected to ensure low barriers to program entry for program participants and there should be few to no programmatic prerequisites to permanent housing entry. As such, projects must allow entry to program participants regardless of their income, current or past substance use, criminal records, or history of domestic violence. C. Coordinated Entry Participation Treasure Coast Homeless Services Continuum of Care has adopted a Coordinated Intake and Assessment System. All clients should be triaged utilizing the Coordinated Assessment prescreen document. Individuals scoring the highest would be the highest priority. All chronically homeless individuals and families should be referred to the full SPDAT for assessment for PSH assessment. All CoC Funded and ESG Funded Projects are required to participate in the Coordinated Entry System Participation requires following all established procedures Projects should refer to the CoC's Coordinated Entry System Policy for additional information. 19 P a g e

D. Prioritization of Chronically Homeless and Other Vulnerable Homeless Persons All CoC Permanent Supportive Housing Projects must accept referrals from the Coordinated Entry system. The CE system will prioritize individuals for PSH beds in accordance with the Department of Housing and Urban Development s CPD 16-11 Notice dated July 25, 2016 regarding prioritizing persons experiencing chronic homelessness and other vulnerable homeless persons in Permanent Supportive Housing. Treasure Coast Homeless Services Council CoC FL-509 fully adopts this Notice and incorporates it as part of its written procedure. The CoC has dedicated 100% of its PSH beds to those experiencing chronic homelessness. This notice immediately follows this policy standard and should be reviewed by all CoC funded project applicants, as this guidance must be followed. PERMANENT SUPPORTIVE HOUSING Priority 1 2 3 4 5 Description Individuals and families who are chronically homeless with the longest histories of homelessness, disabilities and most severe service needs. Of these, veterans, families and unaccompanied youth shall have the highest priority within this category. Individuals and families who are chronically homeless with disabilities and service needs. Of these, veterans, families and unaccompanied youth shall have the highest priority within this category. Individuals and families who are chronically homeless with disabilities. Of these, Veterans, families and unaccompanied youth shall have the highest priority within this category. Individuals and families who are homeless with the longest history of homelessness, disabilities and most severe service needs. Of these, veterans, families and unaccompanied youth shall have the highest priority within this category. Individuals and families who are homeless with disabilities and service needs. Of these, veterans, families and unaccompanied youth shall have the highest priority within this category. 20 P a g e

6 Individuals and families who are homeless with disabilities. Of these, veterans, families and unaccompanied youth shall have the highest priority within this category. E. Recordkeeping Requirements All CoC Funded Project Applicants will maintain evidence through recordkeeping and documentation that individuals accepted into their PSH Projects follow the adopted orders of priority implemented in accordance with HUD Notice CPD 16-11. 1. Evidence of Cumulative Length of Occasions. For recipients providing assistance to households using the selection Priority One through Four for both dedicated and non dedicated PSH beds, the recipient must maintain the evidence of each occasion of homelessness as required, which establishes how evidence of each occasion of homelessness, when determining whether an individual or family is chronically homeless, may be documented. However, to properly document the length of time homeless, it is important to document the start and end date of each occasion of homelessness and these occasions must cumulatively total a period of 12 months. In order to properly document the cumulative period of time homeless, at least 9 months of the 12 month period must be documented through third party documentation unless it is one of the rare and extreme cases described above 2.b.ii. (Evidence that the household experienced at least four separate homeless occasions over 3 years). For purposes of this selection priority, a single encounter with a homeless service provider on a single day within one month that is documented through third party documentation is sufficient to consider an individual or family as homeless for the entire month unless there is any evidence that the household has had a break in homeless status during that month (e.g., evidence in HMIS of a stay in transitional housing). 2. Evidence of Severe Service Needs. Evidence of severe service needs is that by which the recipient is able to determine the severity of needs using data driven methods such as an administrative data match or through the use of a standardized assessment conducted by a qualified professional. 21 P a g e

IV. CoC Coordinated Entry System A. Overview The Treasure Coast Homeless Services FL-509 CoC has developed the Coordinated Assessment System to be utilized by all members of the CoC to triage participants and provide services to those at highest need. The Coordinated Entry Prescreen document is available on the Treasure Coast Homeless Services Council website. This CoC prescreen document scores callers for vulnerability and highest risk assessment points, including: homeless status, very low or no income, households with children, length of time homeless, disability, domestic violence, criminal background, and DCF involvement. It also prioritizes families with children, unaccompanied youth, and elderly disabled. During the prescreen, case managers assist with identifying mainstream resources in the community that the client may be eligible for and assisting the client in obtaining assistance through these and other resources. Diversion and prevention is key to reducing homelessness, any support that can be provided to reduce the number of new admissions into the homeless system should be provided. The prescreen identifies those individuals who are disabled and have been homeless for over a year or who have had several incidents of homelessness in the past 3 years. Individuals and families who are or may be chronically homeless are immediately referred to a clinical outreach worker who can complete the full SPAT to determine eligibility and prioritization for all permanent supportive housing programs in the CoC. The SPDAT and Family-SPDAT are utilized for all CoC funded programs. This assessment tool is available to all end users in the HMIS System. The SPDAT identifies additional risk factors, including: 1. History of housing and homelessness identifying those individuals who have been homeless the longest. 2. Mental Health/Health Status identifying vulnerability based on past interaction with police, medical or mental health hospitals, and current health or mental health crisis that needs immediate intervention. 22 P a g e

3. Risky Behaviors identifying vulnerability related to drug or alcohol use, prostitution, sex trafficking, domestic violence, current or past coercion to commit illegal acts or other risky behaviors. 4. Socialization and Daily Functioning identifying those who are unable to provide their own care. The PSH By-Name List identifies those who have been homeless the longest and have the highest vulnerability in their current situation. All CoC funded programs must participate in the coordinated entry system. Programs that do not take 100% of new intakes in through the coordinated entry system will lose points in the ranking and review procedure and may be subject to reallocation. B. Nondiscrimination and Equal Opportunity Treasure Coast Homeless Services Council CoC operates the coordinated entry system in accordance with all federal statutes including, but not limited to: the Fair Housing Act, Title VI of the Civil Rights Act, Section 504 of the Rehabilitation Act, and Title II and Title III of the Americans with Disabilities Act. All service providers, where assistance is provided through Community Planning and Development (CPD) programs, including assistance under the: HOME Investment Partnerships program (24 CFR part 92), Housing Trust Fund program (24 CFR part 93), Community Development Block Grant program (24 CFR part 570), Housing Opportunities for Persons With AIDS program (24 CFR part 574), Emergency Solutions Grants program (24 CFR part 576), Continuum of Care program (24 CFR part 578), or Rural Housing Stability Assistance Program (24 CFR part 579)., must ensure equal access to the HUD-assisted program in accordance with all General HUD Program requirement as specified in 24 CFR Part 5. Treasure Coast Homeless Council CoC requires service providers to practice a person- centered model that incorporates participant choice and inclusion of all homeless subpopulations present in the CoC, including homeless veterans, youth, and families with children, individual adults, seniors, victims of domestic violence, and Lesbian, Gay, Bisexual, Transgender, Queer or 23 P a g e

Questioning, and Intersex (LGBTQI) individuals and families. All CoC service providers must ensure that all people have fair and equal access to the coordinated entry process and all forms of assistance regardless of race, ethnicity, national origin, age, sex, familial status, religious preference, disability, type or amount of disability, gender identity, perceived gender identity, marital status, sexual orientation, or perceived sexual orientation. C. Reasonable Accomodations Treasure Coast Homeless Services Council CoC ensures that persons with disabilities have equal access to the Coordinated Entry System through compliance with the requirements of Title II and Title III of the Americans with Disabilities Act. Treasure Coast Homeless Services Council CoC does not discriminate against individuals with disabilities on the basis of disability in the County's services, programs or activities. The CoC Written Standards require all CoC and ESG service providers have written non-discrimination polices in place. All coordinated entry access p o i n t s must be accessible for persons with disabilities, include those who use wheelchairs and those who are least likely to access homeless assistance. Upon request, all agencies must provide appropriate and reasonable accommodations for persons with disabilities and/or Limited English Proficiency (LEP) so they can participate equally in the Coordinated Entry process, including qualified language interpreters, and other ways of making information and communications accessible to people who have speech, hearing or vision impairments, disabilities, or those with LEP. D. Privacy Protections & Participant Autonomy Treasure Coast Homeless Services Council HMIS Privacy Notice describes the privacy policy of Treasure Coast Homeless Services Council HMIS and the agencies participating in the Homeless Management Information System (HMIS). The notice outlines that personal information is collected only when appropriate, and no information may be used or disclose for any purpose other than for that of the program. Information may only be used or disclosed to comply with legal and 24 P a g e

other obligations. Before conducting a Coordinated Entry, the Client Informed Consent and Release of Information Authorization form must first be signed, and the client must give consent to the exchange of information. Individuals are free to decide what information they provide during the assessment process, and agencies are prohibited from denying assessment or services to individuals who refuse to provide specific information, unless that information is necessary to establish program eligibility according to the program regulation. Individuals shall be allowed to refuse to answer assessment questions and to refuse housing and service options without retribution or limitations on their access to assistance. Should an individual reject a housing or service option they will maintain their prioritization for the next available housing or service option. The housing or service option that was rejected shall be provided to the next individual according to the prioritizations outlined in the CoC Written Standards. Individuals who do not sign the release of information should not have a Coordinated Entry completed, and shall not be denied services unless Federal statute requires collection, use, storage, and reporting of the individuals personally identifiable information as a condition of program participation. No individual may be denied access to the coordinated entry process on the basis that an individual is or has been a victim of domestic violence, dating violence, sexual assault or stalking. Victims of domestic violence, dating violence, sexual assault, stalking or human trafficking are not maintained in HMIS within Treasure Coast Homeless Services Council CoC. 25 P a g e

E. Assessment Treasure Coast Homeless Services Council CoC participating agencies making client referrals into the system will be required to first complete the prescreen document. The coordinated entry prescreen will determine the client s needs and eligibility for rapid rehousing or homeless prevention funding. All chronically homeless individuals will be screened utilizing the full SPDAT to determine eligibility for PSH programs. The Coordinated Entry Prescreen document is available on the Treasure Coast Homeless Services Council website. This CoC prescreen document scores callers for vulnerability and highest risk assessment points, including: homeless status, very low or no income, households with children, length of time homeless, disability, domestic violence, criminal background, and DCF involvement. It also prioritizes families with children, unaccompanied youth, and elderly disabled. During the prescreen, case managers assist with identifying mainstream resources in the community that the client may be eligible for and assisting the client in obtaining assistance through these and other resources. Diversion and prevention is key to reducing homelessness, any support that can be provided to reduce the number of new admissions into the homeless system should be provided. The prescreen identifies those individuals who are disabled and have been homeless for over a year or who have had several incidents of homelessness in the past 3 years. Individuals and families who are or may be chronically homeless are immediately referred to a clinical outreach worker who can complete the full SPAT to determine eligibility and prioritization for all permanent supportive housing programs in the CoC. 25 P a g e

The SPDAT and Family-SPDAT are utilized for all CoC funded programs. This assessment tool is available to all end users in the HMIS System. The SPDAT identifies additional risk factors, including: 1. History of housing and homelessness identifying those individuals who have been homeless the longest. 2. Mental Health/Health Status identifying vulnerability based on past interaction with police, medical or mental health hospitals, and current health or mental health crisis that needs immediate intervention. 3. Risky Behaviors identifying vulnerability related to drug or alcohol use, prostitution, sex trafficking, domestic violence, current or past coercion to commit illegal acts or other risky behaviors. 4. Socialization and Daily Functioning identifying those who are unable to provide their own care. The assessment tools may not produce a complete body of information necessary to determine household prioritization. For this reason, case workers or others working with homeless households may gather additional information relevant to the factors listed in the CoC Written Standards to make decisions. Information gathered and prioritizations made must be consistent with CoC Written Standards, which have been established in accordance with 24 CFR 576.400(e) and 24 CFR 578.7(a)(9). F. Rapid Rehousing Services The Coordinated Entry Process will be utilized for homeless persons receiving rapid rehousing services funded with the ESG, CoC Program, and SSVF Programs in accordance with the CoC Written Standards, which have been established in accordance with 24 CFR 576.400(e) and 24 CFR 578.7(a)(9). 26 P a g e

G. Homeless Prevention Services The Coordinated Entry Process will be utilized for persons seeking homelessness prevention services funded with the ESG Program in accordance with the CoC Written Standards, which have been established in accordance with 24 CFR 576.400(e) and 24 CFR 578.7(a)(9). Treasure Coast Homeless Services Council CoC is not currently designated as a high-performing community and therefore does not feature a homelessness prevention program funded with CoC funds. The CoC Written Standards outline the basic requirements for homelessness prevention programs funded with other funds such as ESG (State and Federal Entitlement), and Challenge Grant, and for other Homeless Prevention Services. H. Supportive Services for Veteran Families (SSVF) Veterans will be referred directly to SSVF. SSVF will continue to prioritize placements based on the vulnerability analysis scores, and continue to work with providers to streamline processes in order to make progress towards accepting referrals. I. Street Outreach PATH, SSVF and other nonprofit Outreach staff must continue to meet with hard to engage clients, whether they want services. Treasure Coast Homeless Services Council CoC will ensure that outreach workers have adequate access to both paper and electronic methods of administering a coordinated assessment survey with the same standardized processes offered at site-based access points. J. Housing Specialists Housing specialists are those who currently work for agencies participating in Coordinated Entry. Housing specialists will be aware of landlords in the community to quickly house individuals experiencing homelessness, despite any barriers to housing (including criminal or eviction history). The housing specialist will help the client in obtaining available housing through keeping appropriate lists of good 27 P a g e

landlords who work with the CoC programs, follow fair housing laws, provide housing that is within FMR rates and provide housing that will meet inspection standards. K. By-Name List (BNL) Committee The BNL Committee reviews particularly high risk individuals and those where the tool did not reveal the full depth and/or urgency of the situation. Assessors/case managers utilize the CoC Written Standards and professional judgment to evaluate housing and service options. In the context of the coordinated entry process, determining eligibility is a project-level process governed by written standards as established in 24 CFR 576.400(e) and 24 CFR 578.7(a)(9). Coordinated entry processes incorporate mechanisms for determining whether potential participants meet project-specific requirements of the projects for which they are prioritized and to which they are referred. The process of collecting required information and documentation regarding eligibility may occur at any point in the coordinated entry process as long as that eligibility information is not being used as part of prioritization and ranking (e.g. using documentation of a specific diagnosis or disability to rank a person). Projects or units may be legally permitted to limit eligibility, e.g., to persons with disabilities, through a Federal Statute which requires that assistance be utilized for a specific population, e.g.., the HOPWA program, through State or local permissions in instances where Federal funding is not used and Federal civil rights laws are not violated. The BNL Committee strives to be person-centric, not program-centric (i.e., the end result will not always be PSH placement, but rather to match a highly vulnerable person to the appropriate housing resource). The BNL Committee will make every effort to consider the individuals strengths, goals, risks, lived experiences, and choices in the referral process. 28 P a g e