Solicitation of Comment on Continuum of Care Formula Docket No FR5476N044 Clyde Barr Policy Analyst cbarrmainehousingorg 2076245772 Current PPRN Calculation Combination of The formula used to award ESG program grant funds and ID: 611716
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Continuum of Care Program:Solicitation of Comment on Continuum of Care FormulaDocket No. FR5476N044
Clyde Barr
Policy
Analyst
cbarr@mainehousing.org
207.624.5772Slide2
Current PPRN Calculation
Combination of
The formula used to award ESG program grant funds and
CDBG fundsCurrent CDBG “dual formula” system:Larger of the two calculations assigned, less a pro rata reduction**ensures the total amount allocated is within the amount appropriated for fundingSlide3
Previous Comments
Not representative of the number of individuals & families experiencing homelessness in their geographic area
CDBG formula was not appropriate for PPRN
Disliked the reliance on “urban blight” as reflected in the age of the housing stockpredominantly from western States, counties, and citiesOpposed to reductions for renewal projectsSlide4
Developing New PPRN FormulasHUD sought to maintain the basic structureData sources need to be:
Relevant
Accurate
TimelyReadily availableChose not to incorporate PIT directlyUsed average of two yearsSlide5
Overview of Proposed FormulasGoal: to approximate the actual homeless need in communities Diminished reliance
on annual PIT
P
re 1940s housing & Overcrowding not includedSlide6
Overview of Proposed Formulas
Formula A
Formula
BFormula CFormula D10% * population15% * poverty25% * affordability gap25% * rent-burdened ELI households25% * rental units25% * poverty25% * affordability gap25% * rent-burdened ELI households
25% * rental units
25% *
population
25% * poverty
50% * hybrid factor
25% * poverty
25% * affordability gap
50% *
hybrid factorSlide7
Alt Formula
“A”
COCNUM
COCNAME
PPRN15
Baseline Allocation
Alt Formula
$ Diff
PCT Diff
ME-500
Maine Balance of State
CoC
$3,712,281
$4,157,086$4,288,146$575,86515.51%ME-502Portland CoC$1,222,088$1,884,953$624,340-$597,748-48.91%ME-5**One Maine CoC$4,934,369$6,042,039$4,778,650-$155,719-3.16%
FORMULA WEIGHTS PEARSON’S CORRELATION10% * population No significant correlation15% * poverty .15325% * affordability gap .31025% * rent-burdened ELI Households .33625% * rental units .444
34% of
CoCs
funding could decrease between $307 - $25,955,807
Slide8
Alt Formula
“B”
COCNUM
COCNAME
PPRN15
Baseline Allocation
Alt Formula
$ Diff
PCT Diff
ME-500
Maine Balance of State
CoC
$3,712,281
$4,157,086$4,205,686$493,40513.29%ME-502Portland CoC$1,222,088$1,884,953$631,500-$590,588-48.33%ME-5**One Maine CoC$4,934,369$6,042,039$4,703,350-$231,019-4.68%FORMULA WEIGHTS PEARSON’S CORRELATION25% * poverty .15325
% * affordability gap .310 25% * rent-burdened ELI Households .33625% * rental units .444
35% of
CoCs
funding could decrease between $646 - $25,410,952
Slide9
Alt Formula
“C”
COCNUM
COCNAME
PPRN15
Baseline Allocation
Alt Formula
$ Diff
PCT Diff
ME-500
Maine Balance of State
CoC
$3,712,281
$4,157,086$4,254,856$542,57514.62%ME-502Portland CoC$1,222,088$1,884,953$612,211-$609,877-49.90%ME-5**One Maine CoC$4,934,369$6,042,039$4,536,819-$397,550-8.06%
FORMULA WEIGHTS
PEARSON’S CORRELATION
25% * population
No significant correlation
25% * poverty .153
50% * hybrid .393
37% of
CoCs
funding could decrease between $406 - $25,701,362Slide10
Alt Formula
“D”
COCNUM
COCNAME
PPRN15
Baseline Allocation
Alt Formula
$ Diff
PCT Diff
ME-500
Maine Balance of State
CoC
$3,712,281
$4,157,086$3,795,378$83,0972.24%ME-502Portland CoC$1,222,088$1,884,953$701,758-$520,330-42.58%ME-5**One Maine CoC$4,934,369$6,042,039$4,166,388-$767,981-15.56%FORMULA WEIGHTS PEARSON’S CORRELATION25% * poverty .15325% * affordability gap .310 50% * hybrid factor .393
37% of
CoCs
funding could decrease between $8,279 - $22,436,373
Slide11
A Deeper Look. . .100 Largest PIT 38% - 44% of
CoCs
see decreased fundingMean PIT: 4,075Median PIT: 2,165100 Smallest PIT23% - 26% of CoCs see decreased fundingMean PIT: 189Median PIT: 185Slide12
Big Picture of “Alt” Formulas
%
Negative Funding by Census Regions
RegionAlt “A”Alt “B”Alt “C”Alt “D”National34%35%37%37%
New England
54%
54%
50%
54%
Mid-Atlantic
65%
70%
67%
74%Midwest ENC42%44%45%44%Midwest WNC35%35%39%42%South Atlantic22%22%25%28%East South13%13%13%13%West South15%15%18%18%Mountain11%11%28%17%Pacific24%24%29%24%Slide13
Custom Calculation
COCNUM
COCNAME
PPRN15
Baseline Allocation
Alt Formula
$ Diff
PCT Diff
ME-500
Maine Balance of State
CoC
$3,712,281
$4,157,086
$5,194,189$1,481,90839.92%ME-502Portland CoC$1,222,088$1,884,953$841,561-$380,527-31.14%ME-5**One Maine CoC$4,934,369$6,042,039$5,705,002$770,63315.62%
FORMULA WEIGHTS
PEARSON’S CORRELATION
15%
* poverty .153
15%
* pre-1940
housing .113
20% * affordability gap .310
50%
* hybrid .393
37% of
CoCs
funding could decrease between $8,531 - $18,982,831Slide14
% Difference
Maine
Alt FormulasCOCNUMPPRN15Alt AAlt BAlt CAlt D
Custom
ME-500
$3,712,281
15.51%
13.29%
14.62%
2.24%
39.92%
ME-502
$1,222,088-48.91%-48.33%-49.90%-42.58%-31.14%ME-5**$4,934,369-3.16%-4.68%-8.06%-15.56%15.62%Including pre-1940s housing has a positive impact in the northeast and a negative impact in the west and south AtlanticSlide15
“Alt” Formulas vs. Custom
%
Negative Funding by Census Regions
RegionAlt “A”Alt “B”Alt “C”Alt “D”CustomNational34%
35%
37%
37%
37%
New England
54%
54%
50%
54%
39%Mid-Atlantic65%70%67%74%54%Midwest ENC42%44%45%44%43%Midwest WNC35%35%39%42%39%South Atlantic22%22%25%28%40%East South13%13%13%13%13%West South15%15%18%18%24%Mountain11%11%28%17%28%Pacific24%24%29%24%29%Slide16
HUD wants to know our thoughts:Slide17
Thoughts on. . .The four proposed formula options
More than 1/3 of
CoCs
could see funding decrease with all proposed funding formulasNew England & Mid-Atlantic states are disproportionately affectedSlide18
Thoughts on. . .Factors and corresponding weights
Including pre-1940s housing increases funding in
the
Models with the hybrid factor have the most CoCs that could lose fundingThere is not a one size fit allSlide19
Thoughts on. . .DUAL OR MULTI-FORMULA SYSTEMSupport a dual or multi-formula
system
Regional
differences should be accounted in funding systemPre-1940s housingVariable’s impact will decrease with timeSlide20
Thoughts on. . .language that would prevent a CoC
from losing more than a certain portion of their
PPRN
YES – HUD should adopt language that would prevent a CoC from losing more than X% of its fundingSlide21
Thoughts on. . . Other comments on CoC
formulas
ESG 75/25 split should be discontinued
75/25 ESG Entitled/Non-entitled SplitAlt AAlt BAlt CAlt D
MCoC
-35%
-36%
-36%
-38%
PCoC
-32%
-32%
-36%
-28%Other comments on CoC formulasESG 75/25 split should be discontinued75/25 ESG Entitled/Non-entitled SplitAlt AAlt BAlt CAlt DMCoC-35%-36%-36%-38%PCoC-32%-32%-36%-28%Slide22
Thoughts on. . . Other comments on CoC formulas
Declining
importance of
annual PIT a good ideaHypothesis, including more robust count data from new HUD Performance Metric 3 (number of homeless persons) could:Smooth out funding discrepancies Provide a truer picture of needSlide23
Questions?