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FY 2013 – FY 2014 CoC Program Competition: A Few Notes About the 7-Day Grace Period for GIW Changes

The Notice of Funding Availability (NOFA) for the Fiscal Years 2013 and 2014 Continuum of Care (CoC) Program Competition was posted on Friday, November 22nd. As stated in the NOFA, CoCs with an approved FY 2013 CoC Registration have a brief window of opportunity to amend the FY 2013 Grant Inventory Worksheet (GIW) to make changes (e.g., add an eligible project) that impact Annual Renewal Demand (ARD). All changes to the GIW must be approved by HUD by 5:00 pm local time on December 4, 2013.

Following are a few important items for CoC leadership and Collaborative Applicants to understand when contemplating GIW changes:

  • FY 2013 CoC Registration closed on November 18, and the CoC Competition opened on November 22, less than 5 days apart. The GIW used by CoCs to agree to the Annual Renewal Demand (ARD) in CoC Registration should not need significant changes at this time. However, we understand that sometimes an error is made, which is why HUD implemented the 7-day grace period for amendments. This process is primarily aimed at those CoCs that forgot to include an eligible grant on the GIW. This process is not for budget line item changes or other minor adjustments that do not impact the Annual Renewal Amount.
  • We have already received questions about the points related to the accuracy of the GIW. Please note that it is not HUD’s intent to penalize CoCs if new 2012 projects that are listed on the GIW are not executed on time by HUD. The NOFA states that “HUD will remove the annual renewal amount from a CoC’s FY 2013 ARD if it determines that any project listed on a CoC’s final FY 2013 GIW was a new project awarded in the FY 2012 CoC Program Competition that did not have an executed grant agreement by December 31, 2013.” If HUD removes an FY2012 project because it was not executed by HUD by December 31, this will not impact the CoC’s score. The CoC’s score is impacted if the CoC adds an eligible project after the 7-day grace period.
  • New projects funded for one year in FY2012 that execute grant agreements in December must have an operating start date of 12/1/2013 or 1/1/2014, which makes the project eligible for renewal with FY2013 funds (i.e. expiring January 1 – December 31, 2014). Note that the recipient enters the operating start date in LOCCS at the time of the first draw of funds, and that LOCCS automatically defaults back to the first day of the month as the operating start date.
  • If a new project awarded in FY2012 does not go to grant agreement by December 31, it will be eligible for renewal with FY2014 appropriated funds (assuming that it goes to grant agreement in 2014).
  • If the CoC leaves an eligible renewal project off of the GIW in error and does not realize this until after the grace period is closed, the project may still apply for renewal funding; however, the final ARD and Tier 1 amount will not be adjusted to accommodate the addition.
  • All CoCs may apply for CoC Planning funds. This is not contingent on the execution of a planning grant, if one was awarded, in FY2012.

The due date of final HUD-approval for requested changes to the FY 2013 GIW is December 4, 2013 by 5:00 pm local time. The detailed information can be found in the FY 2013 - FY 2014 CoC Program Competition NOFA, Additional Overview Information, d. Amendments to FY 2013 Registration. 

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