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Learn More About Coordinated Entry
BY JUDITH TACKETT
When Coordinated Entry first started, homelessness leaders compared it to creating something akin to match.com. You list the available resources in the community and make an appropriate match.
In theory, this means that the most vulnerable of our unhoused neighbors would be matched with the most intensive services approach, and ultimately linked with a permanent supportive housing program. Folks with medium needs would be matched with Rapid Rehousing, which offers time-limited assistance. And some households would only need help with accessing an affordable place. And so on.
The federal government has required local communities to implement a coordinated entry process to serve people experiencing homelessness and link them to housing and services more efficiently. In its interim rule for the Continuum of Care (CoC) program, which was published in 2012, the U.S. Department of Housing and Urban Development (HUD) required local CoC’s “to establish and operate a ‘centralized or coordinated assessment system’ (referred to as ‘coordinated entry’ or ‘coordinated entry process’) with the goal of increasing the efficiency of local crisis response systems and improving fairness and ease of access to resources, including mainstream resources.”
Let me quickly explain the difference between the CoC Program and the CoC, which is often misunderstood because both of them are generally referred to as CoC.
The Continuum of Care refers to a group of stakeholders within a geographic area that comes together to plan and coordinate housing and services for people experiencing homelessness. This is the group tasked with building a homeless crisis response system, which locals also refer to interchangeably as a Housing Crisis Resolution System.
The Continuum of Care Program is the federal funding program that HUD administers in an annual competition. Nashville currently receives about $9.7 million in CoC funding for various local homelessness programs with the potential to increase that amount to over $11 million next year.
To receive CoC funding as well as other dollars including the federal Emergency Solutions Grant (ESG), which is also managed by HUD, local communities must run a Coordinated Entry (CE) process.
Interestingly enough, when you try to google the definition of CE, you get different responses depending on which community you pick. Here is how HUD defines CE per the CoC Program interim rule at 24 CFR 578.3:
“… a centralized or coordinated process designed to coordinate program participant intake assessment and provision of referrals. A centralized or coordinated assessment system covers the geographic area, is easily accessed by individuals and families seeking housing or services, is well advertised, and includes a comprehensive and standardized assessment tool….’”
The four core components of a CE process are Access, Assessment, Prioritization, and Referral. Communities originally had to meet the following CE requirements (copied and pasted from HUD):
Cover the entire geographic area claimed by the CoC;
Be easily accessed by individuals and families seeking housing or services;
Be well-advertised;
Include a comprehensive and standardized assessment tool;
Provide an initial, comprehensive assessment of individuals and families for housing and services; and,
Include a specific policy to guide the operation of the centralized or coordinated assessment system to address the needs of individuals and families who are fleeing, or attempting to flee, domestic violence, dating violence, sexual assault or stalking, but who are seeking shelter or services from non-victim specific providers.
Additional requirements were added in 2017, and the full HUD Notice is available online at https://www.hud.gov/sites/documents/17-01CPDN.PDF. Some of these additional mandates expand on the initial CE requirements. Others are new. The details are too long to include here, but some of the highlights that stood out to me are as follows:
Every access point must offer the same assessment approach and must be usable by all people who experience or are at risk of homelessness.
The CoC’s written policies and procedures must include a process by which individuals and families may appeal CE decisions.
CoCs must maintain CE written standards that prohibit the CE process from screening people out of the CE process due to perceived barriers related to housing or services.
Ensure that all people in different populations and subpopulations in the CoC’s geographic area, including people experiencing chronic homelessness, veterans, families with children, youth, and survivors of domestic violence, have fair and equal access to the CE process, regardless of the location or method by which they access the system.
People must be able to access homelessness prevention services funded with ESG Program funds through the CE process. To the extent that other homelessness prevention programs participate in the CE process, the policies and procedures must also describe the process by which persons will be prioritized for referrals to these programs.
The CE process must allow participants autonomy to freely refuse to answer assessment questions and to refuse housing and service options without retribution or limiting their access to assistance. Written policies and procedures must specify the conditions for participants to maintain their place in the coordinated entry prioritized list when the participant rejects options.
HUD made additional recommendations that promote a person-centered approach to the system, and as part of those, HUD mentioned prolonged stays on waiting lists for housing resources, which can have a negative impact on the well-being of participants. Thus, the federal government simply recommended that “if a community cannot offer housing resources to every prioritized household experiencing homelessness in 60 days or less, then the CoC should tighten its prioritization standards in order to more precisely differentiate and identify for resources those households with the most needs and highest vulnerabilities.” HUD further states that this means that CoC’s “will need to develop strong relationships with providers of mainstream resources in order to offer these households as much assistance as possible to help resolve their homelessness outside of the dedicated homeless assistance system.”
Communities have a choice of developing a system in accordance with HUD requirements only or building a local system that meets and expands upon those federal requirements. In other words, while the federal government mandates the implementation of CE for its resources, how it is done is up to the cities. That leaves room for a nuanced approach.
Political pressure based on NIMBY (Not In My Back Yard) movements (usually loud voices from affluent neighborhoods), and the response to the COVID pandemic, as well as a shift toward increased criminalization supported at the federal and state levels, have had the effect that local CoC’s often see themselves forced to strictly follow federal requirements, thereby, limiting the scope of the work. We see that when communities suddenly create policies that prioritize encampment closures at the cost of other vulnerable people (sometimes more vulnerable) who do not happen to live in the targeted encampment.
While all people in the CE system have a need for housing or housing stability (let’s not forget about the people at risk of homelessness), CE is also about connecting people to the correct resources including support services. To do so, we need an inventory of all available resources in our community beyond CoC, ESG and other federal dollars designated for homelessness, which we started to build in 2021. Only then can we build a functional local system that allows for a nuanced approach in which we make appropriate referrals and match different households with the right interventions. This would also allow for room to make adjustments. What if people who were super vulnerable are recovering from their trauma after a few years? They won’t need the intensity of a permanent supportive housing program, and we could free up those resources for another household in need.
CE allowed communities to move from a first-come, first-served model to a system that prioritizes people with the highest needs who otherwise would not be able to obtain housing on their own. However, the hyper-focus on prioritization of the most vulnerable people has had some side effects. Providers who are already constantly overwhelmed and tired feel the intensity of their work and often are overwhelmed, which can lead to high turnover. High turnovers lead to the quick hiring of inexperienced staff, who are often asked to have a higher than recommended workload without the necessary tools or full understanding of best practices.
Other challenges I read and heard about from national and local sources include:
Perceptions that CE is disempowering people;
Concerns about accuracy, reliability, and racial bias of assessment tools;
Concerns about the implementation of case conferencing, which also includes the lack of participation by some organizations;
Challenges with a lack of available resources (and the knowledge of those available resources) to make appropriate referrals;
Lack of truly listening to clients about their needs, which results in giving a choice that they already said they would not be able to succeed in;
Lack of service connections and warm handoffs once people are matched to housing; and
The treatment of CE assessment as a service in and of itself — rather than a tool to offer service assistance and housing matches.
Finally, I have been surprised how many national researchers have voiced their reluctance to fully endorse the CE process. Some were downright dismissive when I mentioned CE’s potential to them. This indicates to me that they have been observing inconsistencies in many communities.
However, I have been a supporter of CE because I believe it has the potential to serve people more efficiently and fill some gaps as long as cities understand that a more nuanced approach to the HUD requirements is necessary to ensure a people-centered approach that works.
Here are some benefits:
CE has the potential to foster transparency about available resources across a community;
Case conferencing, if done well, can promote a more holistic assessment process that fosters filling gaps in services;
Trust and collaboration increase when providers work together in a transparent manner through CE implementation;
Data collection through CE, if done in a safe and protected manner, provides a more accurate picture of homelessness and identifies local gaps in resources;
CE data can help advocate for policy changes and resources; and
The consistency of a solid CE process based on input from people with lived experience and expertise allows for building trust and breaking down silos.
Each community is taking a slightly different approach in how they implement CE. It is challenging, as diiv sternman pointed out in a blog post titled The Promise of Coordinated Entry on endhomelessness.org. Our local CoC has the opportunity to continuously improve the process to ensure we are not leaving people behind or caving too much to the current political pressure from all levels of government to make homelessness invisible rather than preventing and ending it.
