Lesson 7: Additional HUD Requirements

1. CoC programs require the participation of homeless persons on the organization's board of directors or other policy decision-making bodies. The recipient and sub-recipient must maintain records to document their compliance with the homeless participation requirements.​

​2. Service Requirements: ​ CoC projects must conduct ongoing and annual assessments of program participants’ service needs and should adjust services accordingly.

Following these assessments allows the project to: ​

• Construct, renovate, rehabilitate, maintain, and operate the project​ & provide supportive services to program participants​

3. CoC projects are required to follow and use the Housing First​ Approach.

​4. Faith-based Organizations​ - If an organization conducts religious activities, it must:​

• Offer the activities separately, in time or location, from the programs or services funded under the CoC or ESG Program​

• Ensure that participation is voluntary for CoC or ESG program participants​

• Comply with restrictions on using CoC or ESG Program funds to acquire, construct, or rehabilitate structures of faith-based organizations​

• Organizations may not discriminate against current or prospective program participants/beneficiaries on the basis of religion, a religious belief, refusal to hold a religious belief, or refusal to attend or participate in a religious practice.​

• If a current or prospective program participant objects to the religious character or religious belief of a CoC-funded organization, it is the responsibility of the organization to undertake a reasonable effort to identify and refer the program participant to an alternative service provider.​

​5. Participant Termination​ - CoC projects termination policy must include the process for providing​:

• A written notice to the program participant containing a clear statement of the reason(s) for termination​

• A review of the decision, in which the program participant is given the opportunity to present written or oral objections before a person other than the person (or subordinate of that person) who made or approved the termination decision​

• Prompt written notice of the final decision to the program participant​

6. Conflict of Interest​: An individual conflict of interest arises when individuals with specific relationships to a CoC project directly or indirectly benefits financially or otherwise by the activities carried out using grant funds. This includes any decision or activity made by a CoC project that gives the appearance of impropriety. Identifying and documenting actual and perceived conflicts of interest is a mechanism used to ensure accountability of program funds. The types of individuals covered are:

• Employee, officer, board member, volunteer, or any representative of the CoC-funded organization​

• Organizational Conflict​- When a board member of an applicant organization participates in the CoC’s decision concerning the award of a grant or provision of other financial benefits, to that applicant organization that the board member represents​. When the recipient or subrecipient participates in making rent reasonableness determinations and housing inspections on units that the recipient, subrecipient, or related entity owns.​

• It is required that there is a policy focused on conflict of interest and there must be written records of all actual and perceived conflicts of interest for CoC project employees, officers, board members, volunteers, and representatives of the organization.

7. Fair Housing & Equal Access- CoC projects are required to follow:

• Disability Requirements – Fair Housing Act, Americans with Disabilities Act, Rehabilitation Act of 1973​

• Accessible Requirements​ - Fair Housing Accessibility First

• Reasonable Accommodations​ - Reasonable Accommodations Under the Fair Housing Act

• Reasonable Modifications​

• Applicant Inquiries​

• Assessment Tools​

• Equal Access​

• Criminal History - Projects are required to provide housing opportunities to individuals or families without basing eligibility on criminal history, including sex offenders. HUD requires only that all program participants meet the minimum eligibility criteria and that recipients comply with all local and federal requirements. Further, HUD strongly encourages recipients to adopt Housing First practices and remove unnecessary barriers to receiving assistance, including criminal histories. ​