Continuum of Care

Reallocation Projects

Reallocation refers to the process by which a Continuum of Care (CoC) shifts funds in whole or in part from existing CoC-funded projects that are eligible for renewal to create one or more new projects. Reallocation only applies to the annual competition Notice of Funding Opportunity (NOFO). HUD expects CoCs to reallocate funds from non- and/or under-performing projects to projects addressing higher-priority community needs that align with HUD priorities and goals. Through reallocation, CoCs can create new, evidence-informed projects by eliminating projects that are underperforming or are more appropriately funded from other sources. The NOFO dictates what types of projects may be created through reallocation in a given competition.

The Continuum of Care Board, as the CoC governing body, authorizes the Collaborative Application Committee (CAC) to make decisions regarding reallocation in close partnership with the Joint Office of Homeless Services (JOHS), as the CoC Lead Agency. The CAC is comprised of members of the CoC Advisory Board who do not have a conflict of interest associated with CoC funds. See below for information about the 2024 reallocation policy.

2023 Reallocation Policy

In 2023, the CAC expanded their reallocation policy to be more robust and clear for all renewal projects.

The CAC makes a final determination about reallocation of funds based on the below criteria. If the CAC decides to reduce or eliminate an existing renewal project, Tier 1 funds are reallocated to higher performing projects based on the annual CoC solicitation process. You can find the 2023 Permanent Housing Bonus and Reallocation Project Solicitation at https://johs.us/2023/07/06/continuum-of-care-funding-opportunity/. The solicitation includes the evaluation criteria used by the CAC to select new or expanded projects to forward to HUD.

  • History of Reallocation
  • Performance and Outcome Measures
  • Spend-Down and Grant Management

Reallocation is a multi-year process. When a project is identified as meeting criteria for reallocation, they will have one year to improve their performance outcomes and/or cost effectiveness. At the time of initial identification of meeting criteria for reallocation, the project will be given improvement goals for the next year and technical assistance. If, after that year of working toward improvement, the project has not met its improvement goals, then project will be up for reallocation in that year’s NOFO.

Here is the full OR-501 Portland/Gresham/Multnomah County Continuum of Care Reallocation Policy.