Can CoC Planning Grant funds be used to provide payments or stipends through gift cards to people with lived experience who are assisting the CoC?

HUD AAQ response:

Stipends paid to people with lived experience who actively participate in CoC planning activities would be an eligible planning cost. Payments in any form must be consistent with the Collaborative Applicant’s internal financial management policies and procedures and meet the conditions below.

Payment can be offered in ways that meet the needs and preferences of participants. This can include check, cash, gift cards, electronic gift cards, and electronic/virtual wallet (such as Venmo or Cash APP).

Section 578.39 of the CoC Program interim rules provides that collaborative applicants may use CoC planning funds for the costs of:

  • Developing a communitywide or regionwide process involving the coordination of various stakeholders and homeless or formerly homeless individual,
  • Determining the geographic area that the CoC will serve,
  • Developing a CoC system,
  • Evaluating the outcomes of projects for which funds are awarded in the geographic area (including funds awarded under the Emergency Solutions Grants program),
  • Participating in the Consolidated Plan(s) of the jurisdiction(s) in the geographic area,
  • Preparing and submitting the application to HUD on behalf of the CoC membership, and
  • Monitoring recipients and subrecipients and enforcing compliance with program requirements.

The collaborative applicant would be responsible for documenting that the person was conducting work on eligible CoC planning activities, using time sheets or similar documentation. Additionally, the collaborative applicant would need to ensure that the stipend was reasonable according to Omni Circular 2 CFR 200.

Please note: this response has been provided based on the current requirements and guidance available. Notices or other HUD-issued guidance in the future may change the current requirements. Additionally, the response provided in this email is specific to the question you submitted and may not apply to similar questions. Therefore, please use discretion in providing the response to others, as the answer may not apply to their particular situations.

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