Tulare County task force grapples with HAP 6 rules; staff urge prioritizing navigation centers and mapping encampments

At a Tulare County Task Force on Homelessness meeting on 2025-06-01, county staff and task force members reviewed eligible uses and application requirements for the state'9s HAP Round 6 funding and discussed a required county-wide encampment mapping effort.

The HAP Round 6 NOFA requires regions to demonstrate sustainability for existing interim housing before spending on many other categories. "We must first fully fund all transitional housing projects before any funds can be devoted to any other use categories," a county staff presenter said, reading from the NOFA and stressing that "interim housing" is the round'9s central focus.

The requirement means applicants must document: (1) total existing interim housing shelters and beds, (2) any beds proposed to be added during the grant term, (3) total estimated capital and operating costs for existing and proposed beds, and (4) funding sources and amounts to sustain those beds. Staff warned that the NOFA gives a 50% minimum requirement on housing solutions, a continuing 10% youth set-aside, a 7% administrative cap and a 1% HMIS set-aside, and that the state requires documentation of sustainability through 2029.

Why it matters: HAP 6 differs from prior rounds by elevating interim (bridge/low-barrier) housing in the funding waterfall. In practice, that can prevent regions from using HAP 6 dollars for street outreach, hygiene services, or other non-housing activities until interim housing and then permanent supportive housing are documented as fully funded. County staff called that sequencing "one of the most important aspects" of the NOFA and said it narrows where local funds can be directed.

Task force members raised three central uncertainties that staff will seek from the state: (1) a clear definition of "interim housing" (the NOFA text mixes terms and does not fully define which kinds of emergency or seasonal shelters qualify), (2) whether an interim housing operator that refuses to participate in HMIS or to adopt Housing First practices can be treated as ineligible for HAP funding, and (3) how strictly the state will verify and audit encampment mapping and sustainment plans.

Several members said the practical effect of the rules could be that most HAP 6 dollars would be needed to sustain navigation centers and other existing interim programs rather than to create new housing. "My opinion is this is really funneling us to get people visibly off of the streets," one task force member said. Staff recommended prioritizing navigation centers and the warming/seasonal shelter at Eden House, if the state counts those facilities as interim housing.

Encampment mapping and response requirements were a significant portion of the discussion. The NOFA asks regions to identify encampments, estimate the number of people at each site, and explain how local jurisdictions will respond and set milestones. Staff proposed a county map (for example, a Google map or an Esri layer) that would show approximate encampment location and an assigned outreach team, with safeguards to avoid protected health information. The group discussed technical options (Esri GIS, APIs to HMIS, or using an existing transit or agency map) and warned about licensing and ongoing costs after the grant term.

Members noted operational friction: law and code enforcement priorities (for example, posting 48-hour notices) often conflict with outreach teams'9 objectives. Staff warned that an enforcement-focused local ordinance that requires people to move every few days is likely to create short moves ('9move 200 feet'9) rather than a durable solution without additional interim capacity.

Funding strategy: staff described using capital infusions into capitalized operating reserves (COSR) for Homekey and other projects as a way to create longer-term rental subsidy capacity within a limited funding horizon. The state'9s guidance allows COSR infusions to be treated as an expenditure even if the COSR supports operations beyond the HAP grant term; staff called COSR infusions among the best available options to create stability.

Next steps: staff will request written clarifications from HCD and Cal ICH on the definition of interim housing and on whether operators that do not participate in HMIS or Housing First can be excluded. The group noted an application deadline in late August and emphasized that many counties statewide are seeking similar clarifications on a compressed schedule.

Ending: Task force members generally favored prioritizing existing navigation centers and seasonal shelters in a county HAP 6 application, while seeking state guidance on definitions and on how to treat operators who decline HMIS or Housing First. Staff will assemble interim housing inventory data and reach out to operators to gather capital and operating cost and funding-source information required by the NOFA.