Section C: Program Components

In this section…

U.S. Code Search Tips:

Subtitle D: Click here. Scroll down to Subtitle D.

Section 423: Click here. Enter "Title: 42" and "Section: 11383". Then click on "42 USC Sec. 11383".

Section 424: Click here. Enter "Title: 42" and "Section: 11384". Then click on "42 USC Sec. 11384".

Section 425: Click here. Enter "Title: 42" and "Section: 11385". Then click on "42 USC Sec. 11385".

Section 426: Click here. Enter "Title: 42" and "Section: 11386". Then click on "42 USC Section 11386" and scroll down to "(2) Contents".

Section 11382: Click here. Enter "Title: 42 " and "Section: 11382". Then click on "42 USC Sec. 11382".

Section 11384: Click here. Enter "Title: 42" and "Section: 11384". Then click on "42 USC Sec. 11384".

See Understanding SHP for more guidance on SHP program components.

SHP has four program components and two project types to help homeless people achieve independence. Program components include Transitional Housing, Permanent Housing, Supportive Services Only and Innovative Supportive Housing. Applicants may choose whichever approach best suits the needs of the people they intend to serve.

SHP also has two project types, Safe Havens and Homeless Management Information Systems (HMIS). These projects are called “types” instead of “components” because they are not listed as program components in the Act or program regulations. Safe Havens is a separate program that was authorized by Congress (see Subtitle D of the McKinney-Vento Act), but never funded. HUD recognized that the activities of Safe Havens were eligible and put statements in the NOFAs that Safe Haven projects were eligible for SHP funding. HMIS is an eligible activity that can be funded in any component (see Section 423(a)(7) of the Act) or can be funded as a dedicated or shared project.

Component 1: Transitional Housing

Transitional housing (TH) is a type of supportive housing used to facilitate the movement of homeless individuals and families to permanent housing. Basically, it is housing in which homeless persons may receive supportive services that enable them to live more independently. The supportive services may be provided by the organization managing the housing or coordinated by them and provided by other public or private agencies. Transitional housing can be provided in one structure or several structures, at one site or in multiple structures at scattered sites.

Limitation of Stay in Transitional Housing

SHP funds can be used in the following ways to provide new transitional housing or expand already existing transitional housing:

  • Acquisition
  • Rehabilitation
  • New construction
  • Leasing
  • Supportive services
  • Operations
  • Administration
  • Technical Assistance
  • HMIS

Homeless individuals and families may reside in transitional housing for up to 24 months. However, if permanent housing for the individual or family has not been located or if the individual or family requires additional time to prepare for independent living, they remain for a period longer than 24 months. Assistance may be discontinued for a transitional housing project if more than half of the homeless persons remain in the project longer than 24 months. See the program regulations at 24 CFR 583.300(j).

Access to Supportive Services in Transitional Housing

Transitional housing grantees or project sponsors are required to make services available to program participants in accordance with section 425 of the McKinney-Vento Act and the regulations at 24 CFR 583.300(d), (e) and (f). For more information on supportive services, see Section D Eligible Activities.

Transitional housing residents who move to permanent housing are no longer considered homeless as defined by HUD, and therefore are not eligible to receive further services. However, projects may continue to provide SHP-funded case management services to these participants for a six-month follow-up period. See the regulations at 24 CFR 583.120 for more information.

Transitional housing participants can continue to receive follow-up services from the transitional housing facility for up to six months after they leave the program. Services may still be needed when a family moves to permanent housing, and these services can be tapered off or provided through other funding streams as the family makes the transition.

Movement from Transitional to Permanent Housing

Housing placement assistance should be part of any transitional housing project in order for the project to meet the program goals. Transitional housing residents may need assistance with all the tasks and stress involved in locating, obtaining, moving into, and maintaining the housing. Discrimination in the housing market may make the situation more difficult. Without third-party intervention, some graduates may resort to renting substandard or inappropriate housing or relapse into homelessness.

A comprehensive approach to locating housing includes preparing and training clients in searching for, securing, and maintaining their own housing, developing relationships with local producers and managers of housing to which graduates could move, and helping clients establish a savings plan so they can afford to move.

In many instances, assistance also entails direct contact and negotiation of rental terms in tandem with graduates and money to help pay move-in costs. However, keep in mind that the most successful graduates of transitional housing are those who have taken the lead in deciding where they will live permanently.

Return to Top

Component 2: Permanent Housing for Homeless Persons with Disabilities

SHP funds can be used in the following ways to provide new permanent supportive housing or expand already existing permanent supportive housing:

  • Acquisition
  • Rehabilitation
  • New construction
  • Leasing
  • Supportive services
  • Operations
  • Administration
  • Technical Assistance
  • HMIS

The Permanent Housing for Persons with Disabilities component (PH) is another type of supportive housing. It is long-term housing that provides supportive services for homeless persons with disabilities. This type of supportive housing enables special needs populations to live as independently as possible in a permanent setting. The supportive services may be provided directly by the grantee or project sponsor or by entities under written agreement with the grantee or project sponsor. Selection of these entities after initial application is submitted to HUD and is subject to compliance with procurement requirements. Conflict of interest rules also apply. The supportive services provided in connection with a project shall address the special needs of individuals (such as homeless persons with disabilities and homeless families with children) intended to be served by a project. To require or not to require resident participation is within the discretion of the grantee. Permanent housing can be provided in one structure or several structures at one site or in multiple structures at scattered sites.

16-Person Limit

The housing structure for the PH component allows for SHP funds to be used to house 16 or fewer persons in a single structure. If there are more than 16 people, then an explanation is required as to how local market conditions necessitate this size, and how neighborhood integration can be achieved for the residents. Grantees should note that permanent housing units may be part of a larger development. For more information on the 16-person limit, see Section 424(c) of the Act.

Types of Permanent Housing Structures

Structures may include most housing types. For example, they can be apartments, single-family houses, duplexes, group homes, or single-room occupancy units.

Persons with Disabilities in SHP

In the McKinney-Vento Act (Section 11382), the PH component assists homeless persons with a disability. The term “disability” means:

  1. A disability as defined in Section 223 of the Social Security Act ;
  2. To be determined to have, pursuant to regulations issued by the Secretary, a physical, mental, or emotional impairment which:
    1. is expected to be of long-continued and indefinite duration,
    2. substantially impedes an individual’s ability to live independently, and
    3. of a nature that could be improved by more suitable housing conditions (e.g., a substance abuse disorder if the person’s impairment could be improved by more suitable housing conditions);
  3. A developmental disability as defined in Section 102 of the Developmental Disabilities Assistance and Bill of Rights Act of 2000 of this title; or
  4. The disease of acquired immunodeficiency syndrome (AIDS) or conditions arising from the etiologic agency for acquired immunodeficiency syndrome.

For guidance on determining participant eligibility at program entry and complying with eligibility requirements, see Section B Eligible Participants.


Transitional Housing vs. Permanent Housing for Persons with Disabilities

  Transitional Housing Permanent Housing
Statutory Citation 42 USC 11384(b) & the McKinney-Vento Act, Section 424(b) 42 USC 11384(c) & the McKinney-Vento Act, Section 424(c)
Special Regulations 24 CFR 583.300(j)  
Description Supportive housing used to facilitate the movement of homeless individuals and families to permanent housing. Homeless persons may reside in transitional housing for up to 24 months and receive supportive services that enable them to live more independently. Long-term, community-based housing that provides supportive services to homeless persons with disabilities. Permanent housing enables special needs populations to live as independently as possible in a permanent setting.
Length of Stay Up to 24 months, unless permanent housing has not been located or the resident needs more time to prepare for independent living. An additional six months of follow up services may also be provided to exiting TH clients. Indefinite
Eligible Activities Acquisition
Rehabilitation
New construction
Leasing
Operating
Supportive services
Technical Assistance
HMIS Administration
Acquisition
Rehabilitation
New construction
Leasing
Operating
Supportive services
Technical Assistance
HMIS Administration
Eligible Populations Homeless persons and families, including those with disabilities Homeless persons with disabilities and their families

For more information on the differences between the Transitional and Permanent Housing components, see Understanding SHP .

Return to Top

Component 3: Supportive Services Only

SHP funds can be used in the following ways to provide new supportive services only projects or expand already existing supportive services only projects:

  • Acquisition
  • Rehabilitation
  • Leasing
  • Supportive services
  • HMIS

Note: SHP cannot be used for new construction or operating costs in supportive services only projects. The prohibition is statutory.

Supportive Services Only (SSO) projects use grant funds to provide supportive services to homeless persons who do not reside in housing provided by the grantee or project sponsor, either using grant funds or using other funds. Typically, the grantee or project sponsor conducts outreach to street people, provides services at a drop-in center, or provides services to the residents of homeless assistance projects that are operated by other providers.

SSO Project Characteristics

SSO projects may be in a structure or structures at a central site, or they may be in multiple structures at scattered sites where services are delivered. Projects may also be operated independent of a structure, e.g., street outreach or mobile vans for health care. Regardless of the design, SSO projects must assist homeless persons to obtain and remain in permanent housing, increase their incomes, and live independently. All SHP components are focused on helping participants achieve permanent housing.

Supportive Service Costs vs. Operating Costs in SSO Projects

Because Section 423(a)(4) of the McKinney Act defines operating costs as the costs of operating housing, SSO projects cannot receive grant funds for operating costs. Grant funds may be used for the actual costs of providing supportive services and for administration of the grant.

More examples of eligible SSO costs are given in Section D Eligible Activities.

One example of an ineligible supportive services cost in an SSO program is training for supportive services staff. This expenditure is not eligible because the SHP funds are meant for the direct benefit of homeless persons.

Examples of eligible supportive services costs in SSO projects

  • The cost of computers and desks used in a job readiness training program are eligible supportive services costs;
  • The salaries of staff directly contacting homeless persons in an outreach program, are eligible supportive services costs; and
  • The purchase of vehicles for transporting homeless persons to other services and job training sites is an eligible SSO cost. The cost of fuel, insurance, and repairs are also eligible.

Return to Top

SHP funds can be used in the following ways to provide new innovative supportive housing or expand already existing innovative supportive housing:

  • Acquisition
  • Rehabilitation
  • New construction
  • Leasing
  • Supportive services
  • Operating costs
  • Administration
  • Technical Assistance
  • HMIS

Component 4: Innovative Supportive Housing

Section 426(b)(2) of the McKinney-Vento Act (42 USC 11386(b)(2)) makes the innovative quality of a proposal a selection criteria that HUD must use in awarding SHP grants. HUD has implemented this requirement through the NOFA process by creating the Innovative Supportive Housing Component.

In particular, a proposed innovative project must demonstrate that it meets three criteria: it represents a distinctively different approach when viewed within its geographic area; it is a sensible model for others; and it can be replicated elsewhere.

Note that almost every eligible project fits in one of the component categories above. Very few projects have received SHP funding under the innovative category. An applicant should not propose a project under this component unless a compelling case is made that these criteria can be met. The activities in an innovative project must also meet eligible program requirements as established in the regulations at 24 CFR Part 583 .

Return to Top

Project Type: Safe Havens

Safe Havens are a type of SHP project with distinctive characteristics originating in Subtitle D of the McKinney-Vento Act (42 USC 11391-11399). In 1994, Congress amended the McKinney Act to authorize a new program called the Safe Havens for Homeless Individuals Demonstration Program, however Congress has never appropriated funds for that program. Neither has HUD published regulations implementing the program. Recognizing that the activities of the authorized Safe Havens program were eligible in SHP, HUD began in 1994 to solicit applications for Safe Havens SHP projects through its annual NOFA. HUD expects to continue this practice in the future.

A Safe Haven is a form of supportive housing that serves hard-to-reach homeless persons with severe mental illness who are on the street and have been unable or unwilling to participate in housing or supportive services. Safe Havens serve as a refuge for people who are homeless and have a serious mental illness.

Safe Havens serve as a portal of entry providing basic needs (such as food, showers, clothing), as well as a safe and decent residential alternative for homeless people with severe mental illness who need time to adjust to life off the streets and to develop a willingness and trust to accept services. Safe Haven projects must comply with the SHP requirements to conducts an on-going assessment of client needs for services. Safe Haven projects must also make services available to the participants that address the special needs of the clients. This information is necessary to assess the progress of the project in moving clients to independent living (see Section 426(2) of the McKinney-Vento Act).

Any one or a combination of the following activities can be used to provide a new Safe Haven or expand an already existing Safe Haven:

  • Acquisition
  • Rehabilitation
  • New construction
  • Leasing
  • Supportive services
  • Operations
  • Administration
  • HMIS

Due to the special needs of the participants of the Safe Haven projects there are some specific characteristics that contribute to the success of a Safe Haven facility, such as intensive and skilled outreach to this hard-to-reach population; engagement at a pace comfortable for the participant; intake/assessment; understanding that it is this participant’s inability to get through the intake process at traditional shelters that make them candidates for Safe Havens; and supportive service delivery at the participant's pace.

Safe Haven Design

The Safe Haven must comply with all SHP requirements in addition to specific Safe Haven requirements:

  • Must serve hard-to-reach homeless persons with severe mental illnesses who are on the streets and have been unable or unwilling to participate in supportive services;
  • Must allow 24-hour residence for an unspecified duration;
  • Must have private or semi-private accommodations;
  • Must limit overnight occupancy to no more than 25 persons;
  • May include a drop-in center as part of outreach activities; and
  • Is a low demand facility where participants have access to needed services, but are not required to utilize them.

Safe Havens and the Continuum of Care

The success of any Safe Haven project rests upon the strength of the linkages it has with all other components of the Continuum of Care. Through linkages with the community (particularly State and local mental health agencies) the project can better deal with some of the issues that can arise when developing a Safe Haven. Issues such as NIMBYism, appropriate housing design, and the unique staffing issues for this type of project, are just some of the issues that can be overcome by strong partnerships within the local community.

Safe Havens Resource Information

For more information and guidance on developing a Safe Haven, see In from the Cold: Creating Safe Havens for Homeless People on the Street.

Return to Top

Project Type: HMIS

Beginning in 2001, HMIS activities became eligible under SHP to help facilitate the implementation and operation of a CoC-wide HMIS. HMIS is an eligible activity under any component (see Section 423(a)(7) of the McKinney-Vento Act) and a project type that funds shared or dedicated HMIS projects. Although HMIS is treated as a project component for application purposes, HMIS is not a separate program component.

Congress amended Section 423(a) (42 USC 11383(a)(7)) of the McKinney Act in 2001 to make the costs of implementing and operating management information systems for purposes of collecting unduplicated counts of homeless people and analyzing patterns of use of McKinney-Vento assistance eligible under SHP. While regulations have not been published on the use of HMIS funds, HUD has imposed certain requirements through the NOFAs and has published two Notices on HMIS: the Homeless Management and Information Systems Data Technical Standards Final Notice (69 FR 45888) and the Homeless Management and Information Systems Data Technical Standards Final Notice: Clarification and Additional Guidance on Special Provisions for Domestic Violence Provider Shelters (69 FR 61517).

Applicants can request SHP assistance for dedicated or shared HMIS projects. Applicants requesting dedicated HMIS assistance use SHP funds to purchase HMIS software and computers, and to pay the salary of HMIS staff. Applicants requesting shared HMIS assistance share the costs of the HMIS implementation with other providers. Shared HMIS projects are classified as the type of housing or activity that they are providing. For example, if a transitional housing facility is sharing the cost of the HMIS implementation with other providers, that project continues to be classified as transitional housing.

Eligible HMIS Costs

The 2002 NOFA described the HMIS activities that are eligible for funding. Eligible HMIS activities include:

  • Purchasing HMIS software;
  • Leasing or purchasing needed computer equipment for providers and the central server; and
  • Staffing associated with operating the HMIS, including training providers, day-to-day administration of the HMIS, analyzing HMIS data and preparing reports for providers, the continuum and HUD using HMIS data.

HMIS activities that are ineligible for SHP funding are:

  • Planning and development of HMIS systems, including all costs incurred prior to implementation;
  • Development of entirely new software systems; and
  • Replacing State and local government funding for an existing HMIS.

Current grantees should review the NOFA under which they were funded for applicable requirements.

Special Information for Domestic Violence Providers

On January 5, 2022 President Bush signed into law the Violence Against Women and Department of Justice Reauthorization Act of 2005, P.L. 109-162 (VAWA). The law included new rules about the participation of domestic violence service providers in HMIS. HUD will issue guidance on the law and clearly direct programs about how to participate in HMIS according to the new rules. Grantees should look to future Federal Register publications for guidance on implementing VAWA. HUD has published the following Notice providing initial information on VAWA (The Violence Against Women and Department of Justice Reauthorization Act of 2005: Applicability to HUD Programs (72 FR12696).

Return to Top

Previous Section | Table of Contents | Next Section