Earlier this year, a change was made in eLOCCS indicating CoC Program-funded projects had 120 days after the expiration of the period of performance to submit the Annual Performance Report (APR) and any final voucher requests for funds expended on eligible budget line items during the project’s period of performance (grant term). The change was made due to an update to 2 CFR 200.344(a) that states, “The recipient must submit, no later than 120 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award.” 

The Office of Special Needs Assistance Programs (SNAPS) noticed this error and contacted the eLOCCS program office stating the date change violated 24 CFR part 578 for CoC Program funded grants. 24 CFR 578.109(b) states, “Applicants must submit all reports required by HUD no later than 90 days from the date of the end of the project’s grant term.” The eLOCCS office corrected the information in eLOCCS back to 90 days.  

24 CFR 578.109(b) takes precedence over 2 CFR 200.344(a); therefore, all CoC Program recipients must submit their Annual Performance Reports (APRs) and any final voucher draws within the 90-day reporting period.  

Therefore, all CoC Program funded recipients are required to submit APRs and final eLOCCS voucher request no later than the 90th day after the period of performance end date.