TLDR
HUD's CoC match requirement is in-kind heavy and under-documented at nearly every homeless services nonprofit. Organizations that track match informally through narrative summaries rather than source documentation routinely face match shortfalls discovered by auditors after the grant year closes.
HUD Continuum of Care (CoC) Reporting Requirements
The HUD CoC program comes with reporting obligations layered across three systems: HMIS for client data, e-snaps for grant applications and the Annual Performance Report, and LOCCS for payment drawdowns. Managing all three well requires disciplined processes that run throughout the grant year - not annual sprints before deadlines.
The match requirement adds a fourth obligation that many organizations underestimate. In-kind match is permissible and often comprises the majority of what homeless services nonprofits submit, but only when documented at the source.
Annual Performance Report: Structure and Deadlines
The APR captures what a CoC project accomplished during its operating year:
- Clients served: Unduplicated counts by population (chronically homeless, veterans, families, youth)
- Outcomes: Exits to permanent housing destinations, length of time homeless, income increases, returns to homelessness
- HMIS data quality: Percentage of records with complete entry/exit data, income information, and housing destination data
APRs are due within 90 days of the project operating year end. For a June 30 operating year end, the APR is due September 28. For a December 31 operating year end, the APR is due March 31.
HUD evaluates APR outcomes against the project’s approved performance targets. Significant deviations may trigger a monitoring visit or require a formal corrective action plan submitted through e-snaps.
HMIS Data Quality: The Invisible Compliance Risk
HMIS data quality is not a technology problem - it is a compliance problem. HUD evaluates HMIS data quality as part of APR review, and poor quality data translates directly to poor outcome scores regardless of actual program effectiveness.
Key data quality standards:
| Metric | HUD threshold |
|---|---|
| Missing exit destination | < 10% of exits |
| Income unknown at program entry | < 20% |
| Income unknown at program exit | < 20% |
| Record entry more than 30 days late | < 5% |
Organizations with chronic HMIS quality issues - typically understaffed case management teams with no designated data lead - need structural solutions, not reminders. Designating a data quality lead with dedicated weekly time to run and remediate quality reports is the operational change that moves these metrics.
Match Documentation: The Most Audited CoC Requirement
The 25% match requirement (applied to total award minus leasing costs) generates more monitoring findings than any other CoC compliance area. The problem is almost never that organizations don’t generate sufficient in-kind - it is that they don’t document it contemporaneously.
Acceptable in-kind match sources and documentation:
| Match type | Documentation required |
|---|---|
| Volunteer labor | Signed log with name, role, date, hours; valued at Independent Sector rate |
| Donated space | Letter from property owner with FMV and period; or lease showing below-market rate |
| Donated goods | Receipts or appraisal at FMV at time of donation |
| Services donated by another agency | Letter from agency confirming service, date, hours, and staff cost |
| Staff from parent organization | Inter-entity service agreement; time records at actual cost |
Match must meet the same allowability standards as federal expenditures: necessary and reasonable for the project, documented, and not supplied by another federal source.
LOCCS Drawdowns: Reimbursement Mechanics
CoC grants are reimbursement-based. The organization incurs and pays costs, then draws reimbursement from LOCCS. Key requirements:
- Drawdowns must be supported by GL expenditure detail matching the draw amount by budget category
- Only costs incurred within the grant operating period are eligible for reimbursement
- Drawdowns for administrative costs must stay within the approved budget percentage
Maintain a drawdown log tracking each LOCCS draw: date, amount by budget category, and the GL periods covered. This log becomes essential when auditors reconcile cumulative draws to total grant expenditures.
How GrantPipe Helps
GrantPipe’s grant management module tracks expenditures by HUD budget category in real time, making LOCCS drawdown support extraction a report pull rather than a manual reconciliation exercise. The match tracking module maintains in-kind match logs by type and date, with supporting documentation attached - the same format HUD monitors expect when they arrive for a site visit. The activity log provides a complete, timestamped record of every grant transaction and compliance action throughout the operating year.
Free resource
Get the Nonprofit Grant Compliance Checklist
A practical checklist for post-award grant compliance: restricted funds, reporting cadence, audit prep, and common failure points. Delivered by email.
Source: 24 CFR Part 578, Section 578.73
- Continuum of Care (CoC)
- A local planning body that coordinates housing and services for people experiencing homelessness. CoCs apply to HUD for funding and distribute grants to local project sponsors through a competitive process.
DEFINITION
- HMIS
- Homeless Management Information System - the client-level data system used to collect information on people experiencing homelessness. All CoC-funded projects must enter client data into the local CoC's HMIS system.
DEFINITION
- e-snaps
- HUD's online grants management system for the CoC program. Used for grant applications, executed grant agreements, APR submission, and budget amendments.
DEFINITION
- LOCCS
- Line of Credit Control System - HUD's payment disbursement system. Recipients draw CoC funds from LOCCS on a reimbursement basis after documenting expenditures.
DEFINITION
- Annual Performance Report (APR)
- The standard HUD reporting form for CoC projects, submitted through e-snaps within 90 days of the project operating year end. Captures client outcomes, HMIS data quality, and budget expenditures.
DEFINITION
Q&A
How is CoC in-kind match documented?
In-kind match must be documented with source records equivalent to those required for federal expenditures. Volunteer labor requires signed volunteer hour logs with name, role, date, and hours - valued at the Independent Sector's published volunteer rate (currently $33.49/hour for 2024). Donated space requires a signed letter from the property owner confirming fair market value and the period of use. Donated goods require receipts or appraisals at fair market value. Narrative summaries of match without supporting documentation are rejected by monitors.
Q&A
What does HMIS data quality failure look like in audit findings?
Audit findings typically cite specific percentage failures: more than 10% of clients missing exit destination data, more than 20% of clients with unknown income at program entry or exit, or more than 5% of records with data entry gaps exceeding 30 days past the service event. These findings affect the APR outcomes, which affect future competitive scoring. HUD monitors use APR data quality reports directly from the HMIS to assess whether the finding is corrected in subsequent years.
Q&A
Can CoC funds be used for staff not employed directly by the grant recipient?
Yes, under specific conditions. Contracted services are allowable if procured in accordance with 2 CFR Part 200 Subpart D procurement standards. Staff provided by a parent organization or affiliate through a service agreement (inter-entity billing) is allowable if priced at actual cost and documented with time records. HUD requires that the contracted service is necessary for the approved project activities and that the contract was reviewed and approved by the CoC lead agency.
Frequently asked