Questions & Answers

In HUD's e-snaps system, RRH and SSO are two separate project types, and each one requires its own project application: its own budget, its own set of screens, and its own submission. There isn't a combined “RRH + SSO” application format. So, while your LOI could describe both ideas together, the application step itself will need to be structured as either one project application (choosing RRH or SSO) or two separate project applications (one for each). If you do submit two, each one is reviewed and scored independently in the CoC's local ranking process. A strong score on one doesn't carry over to the other, and each stands or falls on its own merits, budget justification, and readiness.

As a quick reference on the two project types: RRH (Rapid Re-Housing) provides short- to medium-term rental assistance paired with case management to help people move directly from homelessness into permanent housing and stabilize there. SSO (Supportive Services Only) funds a defined set of supportive services (things like outreach, case management, or coordinated entry functions) without a housing or rental assistance component attached.

One thing that applies no matter which structure you choose: every project, RRH or SSO, must operate through the CoC's Coordinated Entry (CE) process. That means referrals and enrollments must come through CE — this isn't optional or something a project can opt out of based on how many applications you submit or the type of application.

Given that this would be your agency's first HUD grant, it may be worth having an internal conversation about capacity (things like HMIS data entry, financial and grant reporting requirements, and the administrative lift of standing up compliance systems for a new federal award) and weighing that against whether one or two simultaneous project applications makes sense for where you are right now. ARCH is happy to talk through the tradeoffs whenever it's useful.

See ARCH's RRH vs. SSO Cheat Sheet for a side-by-side of the two project types — also covered in a recent ARCH training.

e-snaps is not open for applications, and HUD has not provided a time frame for when e-snaps will open. This is why the CoC created an extended local application, so agencies can move forward on the local competition while HUD works through the e-snaps issue on its end. ARCH shared full details on the extended application in an email to all applicants on July 14.

Based on ARCH's review of the FY 2026 CoC NOFO and applicable VAWA requirements, the FY 2026 CoC NOFO does not supersede VAWA's survivor-centered requirements. While HUD is placing increased emphasis on supportive service participation, treatment, recovery, employment, and self-sufficiency — particularly for certain Transitional Housing projects — this does not mean that victim service providers must require survivors to participate in substance use treatment or other supportive services as a condition of receiving housing, if doing so would conflict with VAWA requirements.

For domestic violence providers, supportive services should continue to be offered using a survivor-centered, voluntary approach. Applicants should describe how survivors are offered and connected to substance use treatment, behavioral health services, employment, and other supportive services when appropriate — but, consistent with VAWA requirements, participation in those services should remain voluntary for survivors. The Office on Violence Against Women specifically states that survivors must not be required to participate in supportive services to receive transitional housing assistance.

The standard requiring 20 hours per week of participant engagement for new Transitional Housing projects is also not limited to substance use treatment. HUD identifies a broad range of eligible activities that may count toward the 20-hour engagement expectation, including case management, counseling, treatment, volunteering, work therapy, education, job training, community-building activities, and employment. A domestic violence project can satisfy this expectation through survivor-centered services — trauma-informed case management, safety planning, legal advocacy, counseling, peer support, life-skills training, education, employment services, and other voluntary supportive services — without requiring participation in substance use treatment.

Although ARCH believes this interpretation is consistent with the FY 2026 CoC NOFO and VAWA requirements, ARCH has submitted this question to HUD (CoCNOFO@hud.gov) requesting written clarification, and recommends victim service providers with the same question also submit it directly to HUD — this is one of those issues where getting HUD's written interpretation is valuable. A question could simply ask: For victim service providers operating CoC-funded Joint TH-RRH projects, how should the FY 2026 NOFO's emphasis on supportive service participation and treatment engagement be implemented in a manner consistent with VAWA's survivor-centered and voluntary-services requirements?

Status: Answered by ARCH based on current HUD guidance and applicable VAWA requirements. ARCH has submitted this question to HUD (CoCNOFO@hud.gov) requesting written clarification and will update this answer once HUD responds.

If your match commitment is still pending, identify the anticipated match source in your local application and indicate that the formal commitment letter is pending. You can submit this on agency letterhead if you've already submitted your local application.

You will need the formal written match commitment before you finalize and submit the project application to HUD if your project is accepted by Ranking and Review, so please work on securing it as soon as it becomes available.

Also, be sure to verify that your anticipated match source is eligible to be used as match for a HUD Continuum of Care grant. Not all funding sources may be used to satisfy the CoC Program match requirement, so it's important to confirm eligibility before relying on those funds — see ARCH's Match Funds Cheat Sheet for guidance on what does and doesn't qualify.

ARCH encourages agencies to provide the commitment letter as soon as possible once the source is confirmed, so there's adequate time to review all application materials before the HUD submission deadline.

ARCH: Will you please clarify what type of certification you are requesting?

Agency: I believe I need the HUD HMIS Participation & Data Quality Certification. The ESG one was specific to that grant.

ARCH: Thank you for the clarification. I am still not certain which certification you are referencing. If you would please forward the information or guidance indicating where this certification is being requested, we will review it and provide any required documentation, if applicable.

Status: Still being confirmed. ARCH has asked the agency to forward the specific guidance referencing this certification requirement so we can confirm what, if anything, is needed. This entry will be updated once resolved.

ARCH, as the Collaborative Applicant for the Alabama Balance of State Continuum of Care, is committed to conducting a fair, open, and transparent local competition. All applications received will be reviewed in accordance with the FY 2026 Competition Policies and Procedures and evaluated using the same established process by the Ranking and Review Committee and CoC Board.

Yes, since your project is a renewal that has not yet completed its first operating year and an APR is not yet available, please complete Section D using the HMIS data that is available from your project start date through the most current date possible.

Where applicable, please note in your response that the project has not yet completed its first year of operation and that an APR is not yet available.

The FY 2026 CoC NOFO references harm reduction on pages 31 and 85. The NOFO itself doesn't provide a detailed definition — instead, HUD directs applicants to existing federal guidance on harm reduction principles and eligible supportive services.

ARCH encourages every applicant agency to review the U.S. Department of Health and Human Services' Dear Colleague Letter on Harm Reduction. It lays out the supplies, services, and approaches previously identified under the harm-reduction umbrella that may be supported, where allowable, under the CoC Program.

HHS Dear Colleague Letter on Harm Reduction (PDF)

Still need clarification after reviewing the guidance? Applicants are encouraged to contact HUD directly. Per the FY 2026 CoC NOFO: CoCs, Collaborative Applicants, and project applicants needing information or technical support on the NOFO or the e-snaps application may email CoCNOFO@hud.gov. Starting two days before the application deadline, HUD will respond only to emergency technical support requests through the deadline of August 26, 2026, 8:00 PM ET. Applicants experiencing technical difficulties should contact HUD immediately and document every attempt to get help.

This letter is also posted under Local Competition Documents on the FY26 CoC Program Competition page.

No. The FY 2026 CoC NOFO does not require agencies to end existing Permanent Supportive Housing (PSH) projects and convert them to Transitional Housing (TH). It does, however, signal a real shift in HUD's funding priorities, and that distinction matters. Existing PSH renewal projects remain eligible for renewal — HUD has not said all PSH projects must become TH. What has changed is where new funding is headed: HUD is placing much greater emphasis on Transitional Housing, Supportive Services Only (SSO) projects, recovery-oriented services, and employment and self-sufficiency activities, backed by a $1.3 billion investment priority for new TH and supportive service projects. That makes those project types far more competitive for new funding than in previous years.

For an agency that currently has PSH: a successful PSH renewal can still be submitted for renewal, and there's no requirement to voluntarily convert it to TH. That said, if a project underperforms, the CoC could decide, subject to HUD rules and the local competition, to reallocate those funds.

For AL-507 specifically, this is a forward-looking consideration rather than an active one right now — the CoC currently has no PSH programs or units. If it becomes relevant down the road, ARCH's approach would be to protect any strong-performing PSH renewals rather than push automatic conversion, encourage agencies pursuing new projects to consider TH or SSO given how closely those align with FY 2026 priorities, and evaluate any reallocation decisions based on performance and community need, not simply because HUD is emphasizing TH.

Overall, AL-507's approach is a balanced one: preserve effective PSH where it's meeting the needs of chronically homeless households, while strategically expanding TH and supportive service models where they fill real gaps and align with HUD's new priorities.

A DV Bonus SSO Coordinated Entry (SSO-CE) project is not a housing program, and it isn't traditional case management. Its purpose is to create and operate a victim service provider coordinated entry system that connects survivors to the most appropriate housing and services while maintaining confidentiality. HUD specifically allows victim service providers to run a coordinated entry process separate from the CoC's HMIS-based system, as long as it meets HUD's coordinated entry requirements.

These projects can fund coordinated entry assessments, housing navigation, safety planning, crisis intervention, eligibility determination, matching survivors to housing resources, and referrals to RRH, TH, PSH, ESG, mainstream benefits, and legal aid. They can also fund coordination with the CoC's coordinated entry system while protecting survivor confidentiality, trauma-informed CE policy development, confidential case conferencing, HMIS-comparable data collection, and the staffing, supervision, training, and administrative costs to run all of that.

What they can't fund is any form of direct housing assistance: rental assistance, leasing, operating housing, hotel or motel stays, utility assistance, security deposits, or other direct financial assistance. Those require a Rapid Re-Housing, Transitional Housing, or Joint TH-RRH project instead.

HUD is looking for a trauma-informed, survivor-centered coordinated entry process that improves coordination between the CoC's CE system and the victim service provider's process, with survivors who have lived experience involved in its design. If an agency receives SSO-CE DV Bonus funding, ARCH's expectation, as the CoC's Collaborative Applicant and Coordinated Entry Lead, is that the agency coordinates with ARCH; participates in the CoC's CE policies and governance; works with all AL-507 victim service providers who choose to participate, not just its own clients; operates this as a confidential, survivor-centered process on behalf of the CoC's DV system; and makes referrals based on participant choice, safety, and availability, not simply into its own programs.

ARCH would not interpret the NOFO as intending SSO-CE funds to coordinate services only for an agency's own clients — that looks more like agency case management than a CoC-wide coordinated entry project. Any SSO-CE DV Bonus project should be able to show how it supports the CoC-wide victim service provider coordinated entry process and remains available to all participating victim service providers across AL-507, consistent with HUD's view that coordinated entry is a CoC-wide responsibility, not a standalone agency activity.

HUD Form 2996 is the Certification for Opportunity Zone Preference Points. It's only used if an applicant wants HUD to award up to 4 federal preference points for proposing activities in a qualified Opportunity Zone, which requires certifying that 50% or more of the requested award will be used in one or more Opportunity Zones.

It is not part of ARCH's local scoring. Opportunity Zone points are HUD preference points applied during HUD's own review of the project application, separate from the CoC's local ranking and scoring criteria.

Not every applicant needs to submit it. Only applicants who believe they qualify for the Opportunity Zone preference need to submit the form — if a project isn't located in, or spending at least 50% of its funds in, an Opportunity Zone, the applicant simply won't receive those preference points.

See the full HUD Form 2996 section, with links to the form and NOFO guidance, on the FY26 CoC Program Competition page.

HUD Form 2996 asks the applicant to estimate the percentage of the total federal award that will directly benefit Opportunity Zone census tracts, by selecting a funding range (76–100%, 51–75%, etc.). It's an estimate supported by the project design, not a line-by-line accounting exercise.

The estimate should be grounded in where the grant-funded activities will actually happen. A facility-based Transitional Housing project located in an Opportunity Zone can usually support a high estimate, since the housing and services are delivered there. Scattered-site RRH is much harder to support, since participants lease units throughout the community — applicants shouldn't claim the threshold unless they reasonably expect at least half of the rental assistance and services to land in Opportunity Zone tracts. A countywide or regional SSO project needs to estimate where staff time and participant services actually reach clients; if only a minority of participants are served in Opportunity Zones, the 50% threshold shouldn't be certified.

For AL-507 applicants specifically, TH projects have the easiest path if the building sits in an Opportunity Zone, while RRH and SSO-CE projects are harder to support given how spread out their service areas typically are.

ARCH would not encourage applicants to complete HUD-2996 unless they can confidently support the certification — it's a federal certification, so it needs a reasonable, documented basis. If an applicant can't explain why they chose a given percentage, ARCH recommends not claiming the Opportunity Zone preference points. Given the makeup of most AL-507 projects, especially RRH and countywide services, few applicants are likely to legitimately meet the 50% threshold unless they're running a facility-based project located within an Opportunity Zone.

Yes. Local applications should be emailed to ARCH by the local competition deadline regardless of whether e-snaps is open. Once HUD fully opens e-snaps, projects will go in and answer the required questions there. ARCH's ranking and review process uses the local application for scoring, not the e-snaps submission.

Please provide documentation of your organization's most recent program monitoring, if applicable. This may include monitoring reports, monitoring letters, or correspondence from HUD, a state or local funding agency, or another funding source. If no monitoring has occurred, please indicate “Not Applicable.”

Please provide documentation demonstrating that your organization has legal control or the authority to use the property where the proposed project will operate. Examples include a deed, lease agreement, memorandum of understanding, use agreement, or other documentation showing site control, as applicable to your project.

Yes. This is a written certification from your organization stating that CoC Program funds will not be used to operate or support any illegal drug injection or “safe consumption” site, consistent with HUD requirements. A signed statement on your organization's letterhead is sufficient.

The FY 2026 NOFO states: “Awards made under this NOFO will not be used to fund any project, service provider, or organization that operates illegal drug injection sites or ‘safe consumption sites’ in violation of 21 U.S.C. § 856, knowingly permit the use or distribution of illicit drugs on property under their control in violation of 21 U.S.C. § 856(a)(2), or knowingly distribute drug paraphernalia in violation of 21 U.S.C. § 863.”

The NOFO also clarifies that this is not a requirement that program participants be sober to receive assistance, participate in treatment to receive assistance, or be terminated from assistance for a first-time drug-related program or lease violation (NOFO Section III.B.4).

ARCH has drafted a sample certification, posted under Local Competition Documents on the FY26 CoC Program Competition page.

This is a common mix-up between two different provisions in HUD's Detailed Instructions for Renewal Project Applications, and untangling them matters because they lead to different outcomes.

The 10% reference under “Important Reminders” is about shifting funds between budget line items — for example, moving money from Supportive Services into Rental Assistance — inside a renewal that's already at its HUD-established renewal amount. Shifts of 10% or more between line items require review and approval from your local HUD field office representative. That provision has nothing to do with whether your total request is going up; it's about moving money around within a budget that's staying the same size.

What actually determines whether Expansion is needed is simpler: a renewal application's budget can only go up to the project's HUD-established renewal amount (the Annual Renewal Amount, or ARA), as shown on the Grant Inventory Worksheet (GIW) HUD issues to the CoC each year. That figure doesn't grow because a project wants to add households or increase supportive services and admin costs — regardless of what percentage increase that represents.

Any funding requested above that established renewal amount is, by definition, Expansion-eligible funding rather than renewal funding. Expansion is a separate, voluntary process (described starting on page 19 of the Detailed Instructions) for requesting additional funding on top of an existing renewal — more households, more services, more admin. It's submitted as its own new project application in e-snaps, alongside the renewal application, not folded into it.

One important timing note: Expansion applications have to be submitted as their own separate local application and their own separate e-snaps project application before ARCH's local competition closes. If that window has already passed for the current cycle, it isn't possible to convert a renewal application into an Expansion application after the fact, or to fold additional households or services into the renewal at that point — that's a timing issue, not a statement that Expansion would have been the wrong path.

If your FY26 renewal budget is above your project's GIW-established renewal amount, revise the renewal application to match the GIW figure. If you're planning to grow a program, flag that with ARCH early so we can plan together for a separate Expansion application within a future competition window.