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Training
Continuum of Care (CoC) conducts monthly VI-SPDAT training for all new HMIS users and current HMIS users who want a refresher. Trainings are held monthly every fourth Wednesday.
Sign up for VI-SPDAT training
See training events on CoC events calendar
See CoC training materials
Reference guides
The Santa Clara County CoC quality assurance standards have been developed with the expectation of providing quality, standardized services to people who have become homeless and facilitate their successful re-entry back into their communities.
All Santa Clara County Continuum of Care member agencies should use these standards as a benchmark and model for agency-and program-level policies and procedures.
- Required program policies and procedures
- CoC eligible program expenses
- Eligible certifiers of disability
- ESG eligible program expenses
- Federal requirements related to allocation of shared costs - decision tree
- Federal requirements related to allocation of shared costs - overview
- Lead-based paint policy
- Rent reasonableness
- Sample grievance policy
- Transferring a CoC program to another agency
- Transferring a client to another program
- Rapid Rehousing operations manual
- Homelessness prevention system operations manual
- Employment pathway initiative operation manual
- Pedro Street property management operations plan
- Pedro Street operating plan (Draft)
This Draft Operating Plan is intended to be an extension of the standard operating practices to the Property Operations Plan.
All Continuum of Care (CoC) grant funded activities require some level of environmental review. The level of review differs based on the eligible activity or cost. Commonly undertaken CoC-funded activities include leasing, rental assistance, operations, HMIS, and administration.
The County of Santa Clara's Office of Supportive Housing is available as the Responsible Entity for CoC recipients that need to complete the environmental review and clearance process. While you can review more information on environmental review requirements provided by the U.S. Department of Housing and Urban Development (HUD), the Santa Clara County CoC has summarized the requirements for CoC grant projects that do not include rehabilitation, new construction, or other physically impacting activities. For more information about environmental reviews for rehabilitation, new construction, or other physically impacting activities, contact us at the Office of Supportive Housing, County of Santa Clara.
HUD resource
Tools
- SCC CoC Level of review flow chart
- This document provides guidance on which level of review a project needs to complete.
- EPA - Envirofacts toxics report
- FEMA - Flood insurance rate map (FIRM)
CoC program basics
Find explainers about program eligibility, rent, homelessness verification and more.
Covered by CoC funds |
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Covered by CoC funds with qualification |
Exception may apply to leasing programs depending on the lease term. If the lease term is for a year, then rent must be paid for the entire year regardless of whether the unit is occupied. If the lease is written in such a way that the lease ends when the program participant vacates, then no other rent should be paid. |
Not covered by CoC funds |
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Prorating for move-ins that do not cover the entire month
CoC regulations do not comment on how prorated rent should be calculated and therefore the governing law for prorating rent for tenants in CoC programs in the County of Santa Clara should come from the California landlord-tenant law provisions in the California Civil Code and local governing municipal law.
The convention on proration of rent in California is to calculate the rate based on a 30-day month, regardless of the actual days in a given month. It is done this way because the California Civil Code states that tenancies default to month-to-month arrangements, and 30 days is how the code defines the month notice required to terminate these tenancies (See CA Civil Code Sections 1945 and 1946).
1 Per Interim Rule at § 578.51 indicating how CoC rental assistance funding may be used.
Non-rent expenses covered by CoC funds |
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1 Per Interim Rule at § 578.51 indicating how CoC rental assistance funding may be used.
2 For leasing contracts, property insurance is an eligible Operating Cost per Interim Rule § 578.55(b). For other contracts - general liability insurance is eligible as administrative costs per Interim Rule § 578.59(a)(1)(iv).
3 Per 24 CFR § 578.53(e)(16)
4 Per § 578.53(e)(8) broader than § 578.53(e)(16)
- Full time students are eligible for CoC Programs if they meet all eligibility requirements.
- In the case of an emergency transfer in a CoC-funded program where the non-transferring household member was the source of the household's eligibility, the transferring household members will not meet the eligibility requirements for the program.
However, they can retain rental assistance until the expiration of the lease in effect at the time of the qualifying household member's eviction or lease bifurcation.
For example: a household consists of members A, B, and C who reside together in PSH that is subsidized with CoC funding; Household Member A is the member with the qualifying eligibility for the PSH program (e.g., chronically homeless with a disability) and was the perpetrator of a domestic violence incident against B and C; and Household members B and C are now qualified for and seeking an emergency transfer. Household members B and C can remain in the program until the expiration of the lease in effect at the time that household member A was evicted or the lease was bifurcated. However, after the expiration of the lease, household members B and C must transition out of the program and no other CoC funds may be used to subsidize their rental assistance as they are not independently eligible for the program without the qualifying household member A.
Verification method | Details |
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Community members can serve as third party verification if they are verifying specific months of chronic homelessness. However, community member observations may not be used to document Category 1 homelessness. | Service providers and social workers can serve as third party verification if they are verifying specific months of chronic homelessness. Third party verification must come from someone that has observed you. However, community member observations may not be used to document Category 1 homelessness. |
The registration with the local police department does not constitute a compliant third-party verification. Verification from a member of law enforcement (as with other services providers such as health care professionals) must include the approximate date(s) when the officer encountered the individual and must also provide details regarding the encounter outlined in the next column. |
For more, see HUD FAQ 2760. |
Service providers such as emergency shelter staff and healthcare professionals. | |
Self-certification limit The limits of self-certification began on January 15, 2016 and they apply to those enrolled in the program (whether they are housed or not). All participants enrolled prior to January 15, 2016 are exempt from the limits on self-certification. | Per HUD's Defining "Chronically Homeless" Final Rule, up to 25% of households in a given operating year may be self-certified. Per CoC FAQ 2872, to determine whether you are at this limit, you would calculate whether or not you are meeting the requirement that at least 75% of program participants have third-party documentation for at least 9 months of their homelessness history based on program participants that enrolled after January 15, 2016 and had been enrolled in the program for 180 days or more. This is because you have 180 days from enrollment to obtain compliant third-party documentation and the rule took effect on January 15, 2016. |
CoC program requirements to documenting chronic homelessness
Veterans' chronic homelessness documentation
The CoC Program Interim Rule § 578.75(b) requires all CoC-funded leasing and rental assistance to meet the Housing Quality Standards (HQS) laid out in 24 CFR 982.401.
These HQS require that "rooms used for sleeping" have the following:
- Working electricity, including two outlets or one outlet and one permanently installed ceiling or wall fixture (such as a ceiling light)
- Enough natural or artificial light to make sure tenants can carry out normal indoor activities
- Ceilings, walls, and floors
- Basic security
- No lead-based paint hazards
- At least one window. Windows that are accessible from the outside, either because they are less than 6 feet from the ground or because there is a fire escape or other means of reaching them, must be lockable. Windows that are designed to open must work.
The Categorically Excluded and Not Subject To 24 CFR 58.5 (CENST) form is only required on the programmatic level and not by individual units rented with CoC funds. It must be completed once every five years by a tenant-based leasing or rental assistance project.
California-based projects are presumed by HUD to be in compliance with HUD’s Airport Hazard regulations without further evaluation; presumed to be in compliance with the Coastal Barrier Resources Act because the CoC area is in a state that does not include any Coastal Barrier Resources; and presumed to be in compliance with the National Flood Insurance Program without further evaluation since flood insurance is recommended but not required for tenant-based leasing and rental assistance.
Forms
We understand the importance of program compliance and have created forms that can be used as tools to assist service providers in complying with complex components of implementation.
- Addendum for CoC lease requirements
- Environmental review for CEST activities
- Environmental review for exempt/CENST activities
- HUD model DV certification form
- HUD model notice of occupancy rights form
- Landlord certification form under CoC HQS waiver
- Rent reasonableness checklist and certification
- RRH to PSH transfer request form
- Homelessness documentation checklist
- Chronic homelessness documentation checklist
- DedicatedPLUS PSH eligibility checklist
- Form A - Homelessness certification
- Form B - Observation of living conditions
- Form C - Certification based on provider judgement
- Form D - Verification of disability
- Form E - Homelessness self-declaration
- Form F - Certification based on intake conversation
- Form G - Certification based on intake conversation or intake staff observation
Environmental Review for Exempt/CENST (Categorically Excluded Not Subject To) Activities | |
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Use this form if your project only includes one or a combination of the following, and no other activities:
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Limited Scope Environmental Review CoC | |
Use this form if your project does not include rehabilitation, acquisition, or new construction but includes leasing or rental assistance activities in existing buildings. | |
Limited Scope Environmental Review Instructions | |
View instructions on how to prepare “Limited Scope” Environmental Review. |